This submission is made on the basis of the documents publicly notified on the SEWPAC website.
The Property Council recognises that Canberra as a consequence of its role in, and contribution to, town planning history exhibits a range of qualities that are highly valued by both the local Canberra community and the wider Australian community. However, the Property Council seeks reconsideration of the proposal to place larger parts of the city and its surrounds on the National Heritage Register on the following grounds:‐
1. The consultation documentation does not clearly articulate the qualities or values that are worthy of national heritage listing, nor demonstrate how these qualities or values meet the National Heritage Listing Criteria set out in the EPBC Regulations;
2. The consultation documentation contains inconsistencies which obscure the intended extent and impact of the proposed National Heritage listing;
3. The proposed National Heritage listing is unnecessary and will not provide any additional recognition or protection of heritage qualities or values above and beyond those embodied in existing Commonwealth legislation and statutory planning documents;
4. The proposed National Heritage listing will impose significant and potentially onerous referral and approval requirements on development, duplicating existing statutory approval processes and is contrary to ongoing initiatives by both Commonwealth and Territory Government to reduce ‘green tape’;
5. The proposed National Heritage listing will create an additional avenue through which vexatious and/or frivolous objections to development can be made, with flow on impacts on the viability of development;
6. The proposed National Heritage listing will bring into play more rigorous criteria regarding the need for approval of foreign investment proposals by the Foreign Investment Review Board, impose further hurdles on property investment in Canberra and could lead to economic strangulation in certain parts of the local economy;
7. The proposed National Heritage listing has the potential to impede development in Canberra, thereby compromising the achievement of other strategic planning outcomes.
Having regard to all of the above, and particularly the fact that the objectives of the proposed listing are already well met by existing legislation administered by the National Capital Authority (NCA), the Property Council submits this proposal be rejected.