In February we prepared a submission to Heritage Victoria objecting to the proposed demolition of the Yarra Building within Federation Square to facilitate the construction of a bespoke Apple Global Flagship Store. In our submission we expressed our concern that the application had been submitted prior to the resolution of the heritage registration (following our nomination of the place to the Victorian Heritage Register), particularly as the granting of a permit to demolish part of the Square would have a significant impact on the site’s heritage values, and therefore on the Heritage Council’s determination of those values.

We also believe that it is very problematic to assess a permit application for a place, particularly one so complex, which does not have a formally adopted Statement of Significance. This subverts the process of good heritage practice, as outlined in the Australia ICOMOS Charter for Places of Cultural Significance, 2013 (the Burra Charter), which states the management of a heritage place should be informed by an understanding and analysis of its significance. The Heritage Impact Statement prepared by Urbis (HIS) identifies the Yarra building as having “moderate heritage significance with respect to aesthetic criterion”, however this is not qualified by an analysis of the building’s values in relation to the other components of the Square. In Urbis’s analysis of significance it is noted that the statements of significance prepared by the National Trust and the Executive Director do not include “a discrete detailed analysis of the heritage significance as an individual element, nor of the considerations relevant to any alterations to Federation Square as necessary over time to accommodate change”. Arguably, the statements of significance do not reflect the complexity of the place because they have not been resolved through the registration process or examined further through the preparation of a Conservation Management Plan.

Yarra Building at Federation Square slated for demolition to facilitate the construction of an Apple Global Flagship Store

It is also problematic that the plans provided with the application are not fully resolved or detailed, which is noted in the HIS. In Fed Square Management’s response to the Executive Director’s Request for Information dated 24 January 2019, it is also noted that neither the plans nor the physical model being made available to Heritage Victoria incorporate the modifications required by the Minister for Planning detailed in correspondence dated 30 September 2018, and that a digital model has not been prepared. We note that the Minister’s correspondence has not been made available as part of the current application, and we understand these changes are not reflected in the Book of Plans provided with the application. This lack of detail is unacceptable for a permit application which contemplates a major change to any heritage place, let alone one of Melbourne’s most prominent attractions and our premier civic space.

We nevertheless recognise that the Executive Director is required to consider the permit application under the Heritage Act 2017, including the following provisions under Section 101:

(a) the extent to which the application, if approved, would affect the cultural heritage significance of the registered place or registered object;
(b) the extent to which the application, if refused, would affect the reasonable or economic use of the registered place or registered object.

In our submission, linked in full here, we have addressed these provisions in turn, with reference to the permit documentation included in the Heritage Impact Statement. To summarise, we believe the proposal would have an unreasonable negative impact on the heritage values of Federation Square, and do not believe that the economic case provides adequate justification for these impacts. We do not believe that these impacts can be adequately mitigated through permit conditions, and therefore call on the Executive Director to reject the application.

To read more about the Federation Square campaign to date, please click here.