Category Archives: Heritage

Heritage

MORE HERITAGE LOST ??????

GERA supports the National Trust, RSL and the Glen Eira Historical Society in urging residents to  contact Council/Councillors to request

  • An independent heritage advisors assessment of the historical significance of a rare World War 1 Soldiers Rest Home located at 294 Kooyong Road, Caulfield, within the context of the City of Glen Eira. This Rest Home, built by public subscription and known as the Caulfield Rest Home (later Montgomery House), was formerly operated by the Red Cross and staffed by volunteer nurses.  The building is not currently protected by a Heritage Overlay.
  • Deferring the decision on Planning Permit Application (GE/PP-28748/2015), beyond 17th May, 2016, to allow for
    • Preparation and assessment of an Independent Heritage Advisor’s Report on the historic significance/merits of the Caulfield Rest Home within the context of the City of Glen Eira, and
    • Heritage Victoria to receive submission and assess the historic significance/merits of Montgomery House within the context of Victoria.

The above planning permit seeks to demolish the Caulfield Rest Home (in 2017) to provide an additional 30 beds within a planned new Aged Care/Dementia  Facility, operated by an independent Christian charity (HammondCare) and located adjacent to the Caulfield Hospital.

Those advocating retention of the Caulfield Rest Home are not opposing the continuation of the site’s usage for the provision of aged and/or dementia care.  Rather they are advocating that the development of the new facility should not be at the expense of heritage and that the Caulfield Rest Home could and should be integrated within the proposed development.   Such integration would be in accordance with the heritage and planning objectives included in

  • The Victorian the 1987 Planning and Environment Act and
  • Glen Eira’s Planning Scheme
    • Municipal Strategic Statement, and
    • Heritage Clause 21.10, and
    • Local Policies

While HammondCare is proposing a pictorial record, memorial pavilion and poppy garden instead of incorporating the Rest Home within the proposed new facilities this is seen as a poor substitute when  the “real thing” could be retained rather than lost forever.

Recent media and internet articles referring to the historic significance of the Caulfield Rest Home are:

A summary of the above articles is as follows:

Today T

  • The Caulfield Rest Home is the last intact building from Caulfield Hospital’s era as one of Australia’s biggest World War I repatriation hospitals.  Built in 1916 entirely by funds and materials raised/donated by the local community, it was an outpatient home for World War 1 soldiers, providing support, comfort and friendship for recovering soldiers.  Prior to the advent of purpose built rest homes, convalescing (from major/catastrophic injuries) soldiers were inappropriately housed in the verandahs and dinning rooms of military hospitals with little opportunity to socialize (with families or fellow patients) or to acquire new skills to aid their re-entry into the community.

Skills

  • The Caulfield Rest Home continued to play an important part in Red Cross Services during and between two world wars. From 1958 it operated as a handicraft centre in the grounds of the then Southern Memorial Hospital, until the Red Cross’ lease expired in 1976. In 2000 it was renovated and re-opened in 2001 as Montgomery Nursing Home with 30 beds for dementia and aged care patients. In 2015 the site was leased by HammondCare.
  •  The Caulfield Rest Home is believed to be the only purpose-built rest home remaining in Victoria and one of the only surviving tangible links to a highly significant period of Caulfield’s history.

 For readers wishing to contact Council/Councillors and object to this planning permit application, a proposed objection and Council/Councillor contact details are available on the Trust Advocate website.

Coming less than 12 months after the appalling  loss of Frogmore, GERA urges readers ensure their views are made known to Council.

FROGMORE UPDATE

Many readers will remember GERA’s unsuccessful “ Save Frogmore Campaign” (1 Wahgoo Road, Carnegie) and Glen Eira Council’s shameful 9/6/2015 decision to abandon applying heritage protection to Frogmore House before it could be assessed by an Independent Planning Panel (effectively denying all stakeholders access to the appropriate due planning scheme amendment process). The end result being the demolition of Frogmore House occurring in July, 2015.

Unfortunately, it appears that an addendum has recently been added to the shameful Frogmore Saga.   This time it is related to processing the of the planning permit application for a two storey Aged Care Facility which includes a proposal to remove 88 trees from the site.

BRIEF RECAP

The 9/6/2015 decision to abandon heritage decision for Frogmore was made

  • despite
    • a Council commissioned Independent Heritage Expert Assessment (Jan, 2015), which unequivocally recommended Heritage Protection at the Municipal Level.
    • it being inconsistent with the Glen Eira Municipal Strategic Statement, Glen Eira Planning Scheme and the 1987 Planning and Environment Act objectives of planning for Victoria. Inadequate strategic justification was provided to support this inconsistency.
    • a recommendation from the National Trust
    • considerable community support for Heritage Protection to be applied to Frogmore (petition of approx. 1000 signatures, planning conference 300+ letters of support for protection vs. 2 against protection)
    • Council’s
      • Instigation (reportedly by Mayor Magee) of an Interim Protection Order for Frogmore in Jan, 2015
      • 2/2/2015 6 to 3 decision to proceed with Heritage Protection based on the January, 2015 Heritage Advisor’s Report (For Protection Crs. Sounness, Okotel, Lobo, Delahunty, Esakoff and Magee; Against Protection Crs. Pilling, Hyams and Lipshutz)
  • based on
    • reliance on an inappropriate process (the planning permit approval process) to determined Heritage Values vs. the appropriate Planning Scheme Amendment process
    • reliance on an outdated (2002) Municipal Wide Heritage Assessment that recognised Frogmore as significant but excluded it from Heritage Protection in part because in was not located in a heritage protection area.   This flawed 2002 application of  the “safety in numbers” concept to heritage determination overrode the January 2015 assessment (which in addition to many other factors), recommended protection due to it’s individual location (rarity) and took into account social and demographic changes that had occurred since 2002. “It’s a victim of it’s own rarity”
    • that the potential purchaser (Jewish Care) had acted in good faith and undertaken significant expenditure in identifying and negotiating the site for re-development as an Aged Care Facility. FYI – caveat emptor is not listed as either a planning or heritage consideration
    • an unsubstantiated determination of Net Community Benefit of 120 beds. With 120 beds equating Jewish Care’s assessment of site potential if Frogmore wasn’t retained.  Clearly, this net community benefit calculation ascribes a zero value to heritage.
    • the decision of Heritage Victoria not to award State Level Protection to Frogmore which was a decision based on an assessment at the broader State Level rather than smaller Municipal Level. Council’s use of the Heritage Victoria decision as a justification, ignores the fact that Heritage Protection, within Australia, provides for heritage recognition and protection at the Municipal Level. It also ignores the fact that Council’s commissioned 01/ 2015, Heritage Advisors Assessment was undertaken at the Municipal Level and recommends protection at that level

 “Frogmore is significant to the locality of Carnegie and Murrumbeena and City of Glen Eira and should be conserved as one of the cultural assets of the city   … Frogmore House should be included in the schedule to heritage over lay clause 43.01 by the Glen Eira Planning Scheme”.

  • a casting vote – in the absence of the Mayor (Magee) and declarations of conflicts of interest (arising since February, 2015) from the Deputy Mayor (Delahunty) and Cr. Esakoff, the immediate past Mayor Cr. Pilling took and chair and exercised his casting vote. (For Protection Crs. Sounness, Okotel, Lobo; Against Protection Crs. Pilling (2 votes), Hyams and Lipshutz)

CURRENT ISSUE

9/6/2015              Decision to abandon heritage protection

17/6/2015           Planning Permit Application for a 2 storey Aged Care Facility at 1 Wahgoo Road, Carnegie, lodged with Council for Council review.

21/7/2015            Frogmore House Demolished

13/9/2015            1 Wahgoo Road, Carnegie site aerial photo ex Nearmap

wahgoo spetember 2015

15/9/2015           Advertising period for Planning Permit Application commenced, ie. plans made available for residents review and possible objections.

Included in the permit documentation provided for residents review is a proposal for the removal of 88 trees – we’d appreciate readers assistance in finding them in the above 13/9/2015 aerial photograph.

To aid you below is a aerial picture of the site circa January, 2015.

Frogmore H&L

And a picture taken during the July 2015 demolition works

012 T

29/9/2015           Advertising period completed. Objections received to be considered by Council in near future.

FROGMORE – GLEN EIRA’s SHAME

Words fail, the pictures can do the talking.

GONE FOREVER

Southwards View 016 T2

Northwards Views

The truck is where Frogmore Stood

004 T

011 T

012 T

WAS FOR 135 YEARS

Frogmore in summer w T

 October, 2014

 

 

FROGMORE – Department of Planning Appeal

Demolition on Frogmore House itself has started – on the southern side of the house the verandah has been removed and trees are being sawn down.   On the northern side the 1960’s-1990’s extensions (of no heritage merit) are rapidly being demolished.

At the end of last week GERA spoke with an Advisor in the Department of Planning – it seems despite the our assertions (which are supported by presented documentation and the National Trust*) that Council’s 9/6/2015 decision was fundamentally flawed**,  the Department of Planning is reluctant to get involved in a decision that has already been made by another level of government.

Many of the Save Frogmore supporters are wondering why

  • ministerial approval is required for either a Municipal Planning Scheme and Planning Scheme amendments, and
  • a provision for a Ministerial Direction was included in the Planning and Environment Act 1987.

Please keep calling/emailing the Minister for Planning’s office so that our next posting is not entitled “Vale Frogmore”.  Your calls/emails are having an impact.

 Email:                    richard.wynne@parliament.vic.gov.au

 Telephone:         (03) 8392 6175

*****************

Footnotes

National Trust Letter* (click to enlarge)NT Letter P1 TNT Letter P2 Fundamental Flaws**

  • Disregards accredited Independent Heritage Advice received in January, 2015
  • lacks adequate strategic justification, particularly with regards the determination of net community benefit
  • is inconsistent with the Glen Eira Planning Scheme (Heritage and Aged Care) and the 1987 Planning and Environment Act objectives of planning for Victoria
  • denies all stakeholders access to the appropriate due planning scheme amendment process,

 

 

 

 

 

******************

Fundamental Flaws*

  • Disregards accredited Independent Heritage Advice received in January, 2015
  • lacks adequate strategic justification, particularly with regards the determination of net community benefit
  • is inconsistent with the Glen Eira Planning Scheme (Heritage and Aged Care) and the 1987 Planning and Environment Act objectives of planning for Victoria
  • denies all stakeholders access to the appropriate due planning scheme amendment process,

 

 

FROGMORE – D-Day Countdown

Update – 1/7/2015 – Buildings included in yesterday’s first photo now rubble.

002

007

********************************************

It appears the Victorian Department of Planning is “caught up in red tape” and even though aware that demolition is imminent, has yet to review Glen Eira Council’s highly questionable decision to abandon heritage protection for Frogmore House.

 Frogmore Demolition Works – 30/6/2015

 Demolition works are currently concentrated on the 1960’s – 1990’s Aged Care Extensions which were superficially connected to Frogmore and were not to be included in the Heritage Overlay. (Frogmore’s iconic tower is visible in the background)

008

 003

 Surrounding residents’ report that Frogmore House currently remains externally intact, however, internally doors, stairs and various other fittings have been removed.  Their “D-day” estimate, based on progress to date, is that Frogmore may well be “gone” by the end of the week (at the latest early next week).

 Apparently, the slow pace of the Department of Planning is attributable to a need for a specific rationale for a State Government Department to get involved in a decision that has already been made by another level of government.

Of course GERA believes that Glen Eira’s decision to abandon the heritage protection doesn’t stand up to planning scrutiny. The arguments presented on this site have also been presented to the Minister (14/6), together with relevant documentation (ie. January, 2015 Council commissioned Heritage Advisor’s Report and Recommendation, Council’s 3/2/2015 rationale to protect and 9/6/2015 rationale not to protect) and approximately 350 signed form letters from the community. We are also aware of that a large number of our readers (both within the Glen Eira community and the broader community) have also contacted the Department of Planning in support of heritage protection for Frogmore.

Given the recently announced State Heritage Review, residents are now wondering why the Department is not making the review of Frogmore a priority.   After all in January, 2015 Frogmore was unequivocally recommended for Heritage Protection at the Local Level (historic significance, architectural merit, rarity and associations), yet in making it’s 9/6/2015 abandon decision Council ignored that expert report and reverted to Council’s 2003 dubious decision not to apply heritage protection as Frogmore was not located within an identified heritage area.  Frogmore hasn’t moved but heritage standards and social attitudes have.

We know it’s a repetitive ask but clearly the above photo’s show that this really is your last chance to save Frogmore.   Please contact the Planning Minister to lobby for urgent action.

 Contact details

Email:                    richard.wynne@parliament.vic.gov.au

Telephone:         (03) 8392 6175

Mail:                      Level 20, 1 Spring Street, Melbourne, VIC 3000

Twitter:                http://twitter.com/rwynnemp

 

To assist you, please feel free to cut and paste the following guideline

Hon. Richard Wynne, Minister for Planning

Request to review Glen Eira City Council Planning Scheme Amendments 136 (interim Protection) and C137 (Local Heritage Overlay) for 1 Wahgoo Road, Carnegie (a.k.a. Frogmore)

I request that you urgently act to re-instate interim protection for Frogmore while Department of Planning reviews the strategic justifications presented by Glen Eira City Council in support of it’s 9/6/2015 resolution to abandon heritage protection for 1 Wahgoo Road, Carnegie (a.k.a. Frogmore).

Glen Eira Council has not addressed key planning issues and disregarded accredited heritage advice. The end result being a resolution to withdraw/abandon planning scheme amendments C136 (interim protection) and C137 (heritage protection) that

  • denies all stakeholders access to the appropriate due planning scheme amendment process,
  • lacks adequate strategic justification, and
  • is inconsistent with the Glen Eira Planning Scheme and the 1987 Planning and Environment Act objectives of planning for Victoria

FROGMORE’S LAST GASP

Frogmore in summer w T

Frogmore – October, 2014

Less than 10 days after Council’s seriously flawed 9/6/2015 resolution to abandon local heritage protection for Frogmore its days are clearly numbered.

  • Vegetation has been cleared, fences erected and portable toilets installed.
  • Planning Permit (GE/PP-28101/2015) for “Redevelopment of existing site for a new residential aged care facility” has been lodged.

As per our previous posting, GERA has been lobbying, Richard Wynne, Minister for Planning, to act to re-instate interim protection for Frogmore, to enable his Department’s review of the strategic justifications presented by Council in support of it’s 9/6/2015 abandon heritage protection resolution.

Clearly, time is of the essence and we again urge the community to email or call the Minister to request him to act.

PLEASE EMAIL OR CALL NOW – otherwise, the next time you hear of Frogmore it will be in a demolition announcement.

Contact details

Email:                    richard.wynne@parliament.vic.gov.au

Telephone:         (03) 8392 6175

Mail:                      Level 20, 1 Spring Street, Melbourne, VIC 3000

Twitter:              http://twitter.com/rwynnemp

 To assist you, please feel free to use the following guideline

Hon. Richard Wynne, Minister for Planning

Request to review Glen Eira City Council Planning Scheme Amendments 136 (interim Protection) and C137 (Local Heritage Overlay) for 1 Wahgoo Road, Carnegie (a.k.a. Frogmore)

I request that you urgently act to re-instate interim protection for Frogmore while Department of Planning reviews the strategic justifications presented by Glen Eira City Council in support of it’s 9/6/2015 resolution to abandon heritage protection for 1 Wahgoo Road, Carnegie (a.k.a. Frogmore).

Glen Eira Council has not addressed key planning issues and disregarded accredited heritage advice. The end result being a resolution to withdraw/abandon planning scheme amendments C136 and C137 that

  • denies all stakeholders access to the appropriate due planning scheme amendment process,
  • lacks adequate strategic justification, and
  • inconsistent with the Glen Eira Planning Scheme and the 1987 Planning and Environment Act objectives of planning for Victoria

NO MORE FROGMORE

RIP Frogmore T

We regret to inform readers that at last Tuesday’s (9/6/2015) Council Meeting, Councillor’s resolved to withdraw/abandon heritage protection for Frogmore via the planning scheme amendment process (ie. heritage overlay).

Thus, Frogmore’s future will now be inappropriately determined by a planning permit approval process which does not consider heritage unless that heritage has been previously recognised via a heritage overlay.

The Age – 11/6/2015

National Trust 10/6/2015

Historic Home to face the wrecking ball – 11/6/2015 – Magic1278 (linked added 16/6/2015).

Glen Eira Leader – articled added 16/6/2015.

Leader on Frogmore Decision T

GERA believes that the resolution to halt the amendment process

  • does not give appropriate consideration to the heritage retention values shown by the significant community support for the preservation of Frogmore.
  • does not recognise that the Planning Scheme Amendment process is the appropriate  heritage recognition process
  • has disregarded current expert heritage advice without sound reasons
  • has not provided adequate strategic justification for withdrawing/abandoning the amendments

AMENDMENT C136  and C137 BACKGROUND

These amendments were initiated by residents (ie. a petition comprising approximately 1,000 signatures) in December, 2014, and resulted in a Council decision to commission an Independent Local Heritage Assessment of Frogmore.  Council defined the Assessment’s terms of reference.

On 3/2/2015, based on the findings and recommendation of that Independent Local Heritage Assessment, Council initiated amendments C136 (Interim Protection) and C137 (Heritage Overlay, ie. permanent protection).

 “Frogmore is significant to the locality of Carnegie and Murrumbeena and City of Glen Eira and should be conserved as one of the cultural assets of the city.  …  Frogmore House should be included in the schedule to heritage over lay clause 43.01 by the Glen Eira Planning Scheme”.

 The above 2015 Frogmore Independent Heritage Assessment (a.k.a. Graeme Butler Report) recommendation was based on a detailed analysis of

  • Frogmore’s heritage merits (historic, architecture, rarity and associations) in its own right, and
  • in comparison with Glen Eira’s identified historic building stock

and measured the analysis results against the assessment criteria

  • applicable to Glen Eira’s 1996-2003 Municipal Heritage Survey and
  • Heritage Victoria’s current heritage criteria, assessed within the context of the Glen Eira municipality (5 of 8 criteria satisfied, only 1 is required to be met)

 The National Trust supports the findings and recommendation of the 2015 Frogmore Independent Local Heritage Assessment.

 On 9/6/2015, although nothing has occurred that would alter the 2015 Frogmore Local Heritage Assessment findings or recommendation, the resolution not to proceed to a hearing before an Independent Planning Panel was made, based on a casting vote.  In the absence of 3  Councillors which included the Mayor and Deputy Mayor (apologies from the Mayor and Deputy Mayor Delahunty and Cr. Esakoff declaring conflicts of interest which had arisen since their participation in the 3/2/2015 resolution to commence the protection process), the immediate past Mayor (Cr. Pilling) took the chair and the casting vote.   The voting was 4 to 3.

Voting for withdrawal/abandon – Crs. Hyams, Lipshutz and Pilling (2 votes)

Voting to continue the amendment process – Crs. Sounness, Okotel and Lobo.

 DISREGARDING ACCREDITED EXPERT ADVICE

  • The 2015 Frogmore Independent Heritage Advisor’s Local Assessment should supersede the 1996-2003 Glen Eira Municipal Heritage Survey, which excluded Frogmore from a local heritage overlay.   However, support for the withdrawal/abandoning of the Amendments C136 and C137, is reliant upon the 1996-2003 Heritage Survey.  A survey which contradicts the findings and recommendation of the 2015 Independent Heritage assessment.
  • The need to consider Frogmore in the context of the municipality (9/6/2015 Officer’s Report) does not justify abandoning the planning scheme amendments. Nor does it recognise that the detailed 2015 Frogmore Heritage Assessment was undertaken at the Local Level.
  • Asserting that the 2015 Frogmore Local Assessment recommended protection “because” of associations (refer Officers Report – 9/6/2015) “downplays” the 2015 Local Heritage Assessment’s recommendation that is based on a detailed assessment of Frogmore’s historic significance, architectural merit, rarity and associations.
  • Inappropriately referencing Heritage Victoria’s March, 2015 Assessment (which did not recommend State Level Protection), “blurs the line” between State and Local Assessments. When a State Assessment recommends State Level Protection, local level protection automatically follows. Conversely, the absence of State Level protection does not, and should not, impact recognition of significance at the Local Level.
  • The 1996-2003 decision not to include Frogmore in a heritage overlay was based on
    • Frogmore not being located in an “identified heritage area” – this is not a current heritage assessment criteria and arguably a stand-alone location enhances, rather than diminishes, heritage value.
    • Addition of extensions (1960’s – 1990’s) surrounding the building – Amendment C137 does not apply to these extensions which are described as being “superficial” in the 2015 Frogmore Local Assessment
    • Obscured street visibility (due to extensions) – not a heritage assessment criteria and able to be addressed during re-development.
    • Non original modifications – the 2015 Frogmore Local Assessment did not find these modifications significant.
  • Does not adequately consider the National Trust’s recommendation to preserve Frogmore via the applying a local heritage overlay.

STRATEGIC JUSTIFICATION

  • Given the 2015 Frogmore Independent Heritage Advisor’s Local Assessment findings and recommendation, Glen Eira Council’s decision not to proceed with local heritage protection for Frogmore is inconsistent with the

– purpose and objectives of the Glen Eira’s Municipal Strategic Statement (MSS – Clause 21.10) and

– Glen Eira’s Planning Scheme (GEPS – Clause 41.01 – Purpose) and

– objectives of planning for Victoria, as identified by the Planning and Environment Act 1987.

The supporters of these amendments (C136 and C137) agree with the objectives and purposes of these documents and have consistently argued that good planning should result in an outcome that would retain Frogmore for current and future residents without preventing redevelopment (Aged Care or other permitted use), albeit a “scaled back” development. The protection of heritage values is a valid planning consideration in planning decisions.

  • The site is a large site (8,000 sqm, of which approximately 1,000 sqm accommodates Frogmore House and its significant vegetation identified in the 2015 Frogmore Local Heritage Assessment) that presents a unique opportunity for a good planning outcome that caters for multiple community usages, ie. preservation of heritage and redevelopment as an Aged Care Facility that is consistent with and encouraged by the above documents.

Abandoning Amendment C137 will not put in place orderly planning controls that conserve and enhance buildings identified as significant while also providing for sympathetic redevelopment that balances the present and future interests and needs of Glen Eira’s residents.

  • The suggestion that planning issues (particularly those related to heritage issues on large lots) are more appropriately addressed during the planning permit approval process (Officer’s Reports 3/2/2015 and 9/6/2015) is inconsistent with the above documents and will result in ad hoc, piecemeal decisions. The planning permit process only considers planning controls that are in place – no heritage controls = no Frogmore.

Abandoning Amendment C137 will not provide an appropriate forum to consider Frogmore’s heritage.

  • It is extremely difficult to see “The Minister for Planning has, to date, not responded to Council’s request of 4 February 2015 to place interim heritage control over the land” as a justification to withdraw/abandon the amendments.

Additional comments

  • No plans for the proposed redevelopment have been lodged with Council and, contrary to Officer’s Reports (3/2/2015 & 9/6/2015), the site has yet to be acquired by the potential developer. The sales agreement is conditional upon obtaining planning approval.
  • Net Community Benefit (NCB) – refer 9/6/2015 Officer’s Report (Section 6 Public Notice – Objectors), is frequently mentioned yet rarely documented or quantified. Recent discussions determine its value as being 120 beds.
    • No detailed professional analysis substantiating this determination (that NCB = 120 beds) has been presented.  The potential developer’s optimal proposed development comprises a 120 bed facility and the loss of Frogmore. Despite the 2015 Frogmore Local Heritage Assessment, this NCB determination clearly assigns a zero value to heritage.
    • Neither the Officer’s Report (9/6/2015) or Councillor discussion refer to the proposed developer’s planning conference comment that while their analysis indicated that a 60 bed facility was viable and would enable Frogmore to be retained, the developer was not interested in a lesser development and would prefer to look for an alternative site
  • That the potential developer had acted in good faith, undertaken due diligence and incurred significant costs in identifying the property as suitable and plan preparation (Officer’s Report’s 3/2/2015 & 9/6/2015 and Councillor discussion). While this is a regrettable situation, it is however, not a strategic justification for abandoning the heritage protection process.
  • That by abandoning the heritage overlay process, the potential developer avoids lengthy delays in site redevelopment. This is not a strategic justificiation for abandoning the heritage protection process.

It sets a dangerous precedent if unsubstantiated Net Community Benefit, “good faith”, costs incurred by the developer and the avoidance of developmental delays are deemed to provide sufficient justification for abandoning the planning scheme amendments. The protection of heritage values is a valid planning consideration in planning decisions.

In conclusion,

  • we re-iterate our earlier comments that Glen Eira Council has not addressed key planning issues and disregarded accredited heritage advice. The end result being a decision to withdraw/abandon planning scheme amendments C136 and C137 that is without adequate strategic justification and denies all stakeholders access to the appropriate due planning scheme amendment process, and

– reviews the 2015 Local Heritage Assessment and the withdraw/abandon justifications

– decides an appropriate course of action ie. either deny Council’s application to withdraw or abandon Amendments C136 & C137 or use Ministerial Direction to ensure that an appropriate heritage recognition process is undertaken.