Victorian Environmental Assessment Council
Location: Victoria

1 Comments on the Draft Report

The RHSV welcomes the VEAC investigation into historic places. We are especially glad that the committee has taken a broad view of historic matters and delighted that the report mentions the formation of the RHSV in 1909 as ‘an early indication of an emerging interest’ in heritage. We hope the final report will also recognise the importance of the RHSV and its 340 affiliated local historical societies as significant actors in the preservation and promotion of Victoria’s heritage.

This submission is offered in the hope that VEAC can continue its work and be bolder in working through the implications of its analyses in its final recommendations. Portions of this report reflect discussion with sister organisations and their submissions, notably the Old Treasury Building.

We believe that the report represents a significant advance in thinking that will help Victoria get back on the front foot in preservation, maintenance, promotion and use of its built heritage, after a period of unfortunate failure to advance, and even backsliding, during the last twenty years.

We agree with virtually the entire analysis offered in the draft report, in particular that ‘short-term or project-based management of heritage assets is often inefficient, not cost-effective’ (Foreword) and that ‘there is a need for a detailed survey of the heritage of Victoria’s public estate’ (2.4).

We welcome the clear recognition that history and heritage underpin our identity as Victorians, and that historic places play a key role in reflecting the core stories of the Victorian community. The RHSV recommends that the final report include more adventurous recommendations about resourcing historic places, in particular that it recommend the creation of a special-purpose public lottery, or support the Commonwealth’s proposed National Heritage Lottery (contained in the recently released Australian Heritage Strategy), to assist history and heritage buildings and projects achieve sustainable funding.

The RHSV recommends that the final report go further in considering built ensembles. The terms of reference call for (a) a review of ‘historic places on public land’ and (b) ‘an assessment of current information, management arrangements for historic places in Victoria and any issues and opportunities related to their future protection, use and sustainability’. As the report notes, ‘There are several notable types of historic places on public land in Victoria that are not afforded a high prominence such as mechanics’ institutes, war memorial avenues of honour, and green heritage including botanic gardens (1.4)’.

These are serious omissions, but the report fails to mention an even more fundamental omission. Following the Victorian Heritage Register, the draft report rarely deals with historic precincts. These pose a serious issue because what makes them significant precincts is the multiplicity of historic buildings, each of which may not be individually significant. As a result of the formulation of the Heritage Act 1995, protection of such buildings is left to local councils and their Heritage Overlays, which are a very weak protection in the face of developers, who can pressure Councils and threaten resort to VCAT, where heritage overlays generally count for little.

The draft report acknowledges the ‘need for a detailed survey of the heritage of Victoria’s public estate’ (2.4) but ‘VEAC has not made a new assessment of significance or values, but instead utilised existing material and catalogued it in a format which can be more readily analysed’ (2.4). We believe that the final report should include a recommendation to government to carry out a systematic detailed survey of heritage, beginning with but not limited to heritage on public land.

2 The RHSV and its Headquarters

The RHSV has, as the report acknowledges, played a key role for more than a century in preserving Victoria‘s heritage. The RHSV has a direct role in managing one building, the former Royal Australian Army Medical Corps Training Depot, known as the Drill Hall, at the corner of William and A’Beckett Streets Melbourne. It has been the major co-tenant for fifteen years.

The Drill Hall is owned by the Ministry of Planning on a Torrens title, which puts it out of line with many government-owned heritage buildings on Crown Land. The Drill Hall therefore reflects the confusion and the multiplicity of authorities that the draft report mentions, and is a prime example of the difficulties of appropriate management.

Despite the RHSV’s long tenure in the building, the RHSV is still awaiting a long-term lease and arrangements for management.

A discussion of the Drill Hall building is included as an appendix.

The RHSV recommends that historic buildings in an anomalous position, such as the Drill Hall (‘owned’ by the Planning Minister), should be clearly included in the category of heritage buildings on public land.

3 The Role of Local Historical Societies

The draft report mentions that there are some 19,365 heritage overlay places and precincts identified under the municipal planning scheme. These are distributed across the state (Figure 2.3). Local heritage overlays are thus the most important tool for preservation of our heritage. But there is a great need for this tool to be strengthened.

Local Councils are under-resourced to deal with heritage. Few Councils have officers with heritage expertise; those that do mostly only employ them on a limited part-time basis. Thus heritage issues are generally left to planning officers. With the government’s proposed rate freeze, this area is unlikely to gain additional resources.

More importantly, local heritage overlays tend to be considered alongside planning issues, and Council planning officers are often focused on these planning issues to the detriment of heritage considerations. Moreover, even when Councils do refuse permits on grounds that include heritage, they are often challenged by developers and taken to VCAT, where heritage issues get short shrift. As the Review Paper implies (in its suggestion ‘to require the tribunal [in certain circumstances] to consist of a member or members with an in-depth and up-to-date knowledge of heritage legislation and practice’—Review Paper, p. 9), VCAT does not have the expertise and is unlikely to gain it to the extent required to deal appropriately with heritage issues. These issues are often raised in the context of a planning dispute in which the heritage aspect is submerged in planning considerations. The legalistic case-by-case approach enshrined in the legislation creating VCAT works against heritage considerations.

Local historical societies are well placed to act as watch-dogs in the preservation of heritage. And they are often either occupying or aspiring to occupy disused buildings of historic importance, such as court houses and mechanics’ institutes.

The RHSV recommends that VEAC’s final report include consideration of the potential role of local historical societies in both these regards.

4 The Need to Extend State Involvement to Places on Local Heritage Overlays

That in itself will not be sufficient. Given the significance of local heritage overlays, the state must act to provide a back-up authority to overcome both the disparities in Councils’ differing treatment of preservation issues and the danger to sites covered under local heritage overlays from Council.

The RHSV therefore submits that, in regard to sites on public land covered under local heritage overlays:

• Local Heritage Overlays should be subject to state overview and responsibility;
• When considering planning issues involving Local Heritage Overlays, local Councils and, a fortiori, VCAT, be required to seek advice from the Heritage Council and take into consideration the long-term cultural impact of the proposal;
• In the event of decisions from Councils and/or VCAT involving the possible alteration or demolition of buildings on public land covered under local heritage overlays, the Heritage Council of Victoria approval be required before irrevocable material change proceeds.

5 The Need to Extend Financial Support.

It is clear from the draft report that much more needs to be done to provide financial support to maintain our heritage. The RHSV urges VEAC to push for the government to think big on this. Cultural tourism will play an increasing role, and Australia (including Victoria) is particularly well placed as an Anglo outpost in Asia to attract visitors seeking historic western cultural heritage.

To think about this, we suggest that VEAC should push for consideration of the concept of patrimony. It is the heritage we have inherited from previous generations that enriches our daily lives. If we think of our historic places and precincts as patrimony, we can begin to think more seriously of their value.

The RHSV recommends that VEAC include in its final report realistic options for raising funds for history and heritage, foremost among them being the example of Lotterywest. Lotterywest distributes an annual proportion of its profit from lotteries to heritage and culture in Western Australia. Last year it distributed about $15M. It also provides triennial funding to some organisations, including the National Trust in WA.

One significant project of adaptive re-use supported by Lotterywest was the Wanslea Project, which received some $6M and subsequently gained a Heritage Award. See https://www.nationaltrust.org.au/news/wanslea-cancer-wellness-centre-win-at-wa-heritage- awards-2/. Lotterywest has made a huge contribution to the sustainability of heritage and culture in Western Australia and establishing a similar model in Victoria could make a profound difference.

The National Lottery in the UK provides a similar model.

The RHSV, together with the wider Australian history and heritage movement as represented by the Federation of Australian Historical Societies, has for the last two years expressed support for the Commonwealth’s mooted proposal for a National Heritage Lottery. That proposal now has firm substance as part of the Australian Heritage Strategy. We urge the Victorian government to support this national initiative if it is not able to establish a separate Victorian lottery.

6 The RHSV’s Response to the Draft Recommendations

In general, we support the recommendations in the draft paper. We respond here to the recommendations already foreshadowed with some caveats and some suggestions for further action.

Recommendation 1: Accountability for public land heritage
We strongly support creating a Commissioner for public land heritage, with a role in cross-agency strategic planning. We note, however, that the draft report makes no mention of resourcing this agency. We urge VEAC to put the need for significant resources for such a Commissioner.

Recommendation 2: Minimum standards for management of historic places on public land
We support the development of minimum standards, but we believe that the final report should spell out the ‘obligation’ it envisages placing on future committees of management. Most committees consist of community volunteers. The Proposals Paper does not identify additional funding resources to support their task. Manifestly, committees of management taking responsibility for significant heritage places are supporting the state in its objectives. They need and deserve support.
We submit that supporting them with properly resourced training programs is the least that VEAC can suggest in its final report. But we argue strongly that VEAC should put to government that financial resources and expertise will be needed to enable such committees to maintain this state heritage.

Recommendation 3: Rigour and utility of data on historic places
We support the recommendations.

Recommendation 4: Addressing under-representation of some place types
We strongly support a review to address underrepresentation of certain place types on the Victorian Heritage Register. We believe, however, that this should be spelt out to include not only buildings like Mechanics’ Institutes but also precincts. We also believe that gender has been overlooked as a criterion for judging the heritage worthiness of certain places and that preservation of material evidence of women’s contribution to our history is thereby under-rated.
We are alarmed by the proposal to look for historic places to be removed from the VHR ‘to reduce over-representation’. Representativeness is not a negative criterion. We will never achieve it by reducing coverage to the lowest common denominator. Inclusion on the register should be permanent and irrevocable except in extreme circumstances.
The RHSV strongly recommends that this part of Recommendation 4 be deleted from the final report.

Recommendation 5: Recognising and protecting shared values
We support this recommendation.

Recommendation 6: Improving government leasehold arrangements
We support this recommendation.

Recommendation 7: Improving arrangements and support for community-based committees of management
A standardised template for a Business Plan may be a useful tool for community committees of management. However, we stress that it should be simple in format and avoid placing additional burdens on already under-resourced committees.

Recommendation 8: A trust for public land heritage
We strongly support this recommendation, with the proviso that sufficient funding be provided.

Recommendation 9: A revolving fund for public land heritage
See Recommendation 5 above.

Appendix: The former Royal Australian Army Medical Corps Training Depot, 239 A’Beckett Street Melbourne

The former Royal Australian Army Medical Corps Training Depot has been the headquarters of the RHSV since 1999. It is classified on the Victorian Heritage Register (B6139). The citation reads as follows:

Built in 1938 for the Army Medical Corps, this drill hall and offices is a superior and intact example from a distinctive public building design-type which successfully combined the prevailing Moderne influences with the formal classical revival solemnity desired for public architecture. It is also symbolic of a development of a continuing use-type (drill halls), reflecting a re-interpretation of what had been hitherto an almost stereotyped design response to the type and a substantial, well- preserved and prominent example of the Australian preparation for World War II. This new type of drill hall was designed by the talented architect, G H Hallandal, working under the Director of the Victorian branch of the Department of Works, H J Mckennel.
Classified: 01/10/1990

Despite this listed status, the Drill Hall is a prime case example of the threats to government- owned historic properties. Its ownership by the Planning Minister provides something of an anomaly. The RHSV and its major co-tenant, the Victorian Concert Orchestra, have developed the building into the major heritage and performing arts community centre in the Melbourne CBD. These organisations, and their several sub-tenants, make an enormous contribution to the cultural heritage and broader culture of Melbourne and Victoria. However, it is uncertain whether the Planning Department wishes to continue to own the building as it is not necessarily a core function, even though Heritage Victoria is based within the Ministry. A previous government investigated the sale of the building for redevelopment, which would have necessitated demolition, but stepped back when the tenants mounted a public campaign.

The RHSV has been recommending that it be established as the Committee of Management for the Drill Hall with an eighty-year lease. As mentioned above, The RHSV recommends that historic buildings in an anomalous position, such as that of the Drill Hall (‘owned’ by the Planning Minister), should be clearly included in the category of heritage buildings on public land.

Further background on the Drill Hall
The Drill Hall, as it is popularly known, was built at the southern corner of William Street and A’Beckett Street, Melbourne, between 1938 and 1939 by J Whitelaw, Richmond, at a budget cost of 25,947 pounds. The architect was George Hallandal of the Victorian section of the Department of the Interior, Works Branch. The featured materials are brick and plaster. Visitors appreciate the strong vertical and horizontal lines, fluted pilasters, arches, keystones, coffered ceilings, built-in seats, Dutch or stable doors and the quality of the work of bricklayers, plasterers and carpenters.

The site was continuously occupied by the Army from 1866 to 1988. From 1866 the small weatherboard West Melbourne Orderly Room and the adjoining drill hall were used by Colonial Volunteer forces. In 1900 a contract was signed for the construction of new weatherboard quarters at the eastern end of the site. All were demolished for the Medical Corps buildings.

Post-war use of the building to 1988 included Medical Corps Reserve training, premises for the 3rd Psychology Unit, army publicity (with printing equipment), intermittent drill training (including rehearsals for Legacy shows) and garaging of vehicles. The western end of the building became the premises of the Royal Historical Society of Victoria in August 1999.

The building has two large drill halls with offices along their northern side. The drill halls are separated by a public foyer off A’Beckett Street. Messes are placed at the centre – for sergeants – and at the east and west ends of the building – for ‘other ranks’ and officers respectively.

The principal entrance is in A’Beckett Street, and it is here that the words ‘Army Medical Corps’ and the badge of the Corps are pressed into the cement cornice. Of the numerous additional entrances to the east and west, one on Williams Street leads to the Officers’ Mess.

The building was the result of both the defence build-up just prior to World War II and the end of the 1930s Depression when government sponsored construction was used to employ tradespeople. Many government offices were built in Canberra and throughout Australia, including those for the Commonwealth Bank, post offices and telephone exchanges. A great many buildings were also constructed for the Army, Navy and Air Force.

The building was designed to provide for the administration, organisation and implementation of training, research and advice in medical, hygiene and hospital procedures, the provision of services and the issuing of stores and payroll.

Prior to mobilisation for World War II the Army had only three permanent medical officers. The militia organisations during World War I were the backbone of the Corps. These were backed up by civilian medical personnel who could be called up but most had no military or field training whatsoever and even the militia had had no on-going training since 1918. The Australian Army Medical Corps numbered 35 in 1938-1939 and increased to 49 during the following 12 months. By 1943-1944 the total number was 32,100 – 2,500 doctors, 3,500 nurses, 900 non-medical officers (scientists and technicians) and 25,300 other ranks. Women were not admitted to the Australian Army Medical Corps until September 1940.

The drill hall had a number of functions: as an indoor parade ground for marching and equipment drill; as a gymnasium and for physical training; as a social centre offering activities such as dances, film nights etc. and for displays. The mezzanine (the ceiling of a row of offices) allows for observation of the activities on the floor of the hall. The design of the ceiling of the drill hall is reminiscent of suburban cinemas of the time.

Further Information

• Allom Lovell and Associates Pty Ltd. Former Army Medical Corps Drill Hall: an assessment of the architectural and historical significance prepared for Oak Pty Ltd, May 1990.
• Nelson, Avar and Sawyer, Terry, Interim heritage assessment: Army Medical Drill Hall, September 1988.

See more at: https://www.historyvictoria.org.au/about-us/our-headquarters