Redevelopment of the Australian War Memorial referral 2019/8574 for consideration under the Environmental Protection and Biodiversity Conservation Act 1999

Roger Pegrum April 2020

These comments are based on material provided by the Australian War Memorial as part of the process of public consultation in January 2020. The drawings included in the referral are preliminary in nature and generally do not include dimensions, levels or building cross sections. Attached for reference is correspondence in which I asked that architectural plans and cross sections be provided.

The attached email of 25 January 2020 from the Deputy Program Director states that the Memorial intended to submit preliminary documentation in late February for assessment as a ‘controlled action’. At the date of this submission, the documentation has not been made available. I note also that the Australian War Memorial on 26 February 2020 sought a variation of the proposal to expand the scope of works to include inter alia additions and refurbishments to the C E W Bean Building, a re-profiled parade ground and associated engineering and infrastructure works. I may make further submissions when this additional documentation is available.

the National Heritage List

1. The Australian War Memorial and the Memorial Parade (Anzac Parade) were included in the National Heritage List on 20 April 2006. The Schedule to the notice of inclusion notes that the values of the place satisfy six of the nine National Heritage criteria including criterion (e) ‘the place’s importance in exhibiting particular aesthetic characteristics valued by a community or cultural group’.

2. This submission responds particularly to the architectural aesthetic integrity and commemorative intent of the Australian War Memorial pertaining especially to NHL criterion (e):

• ‘the AWM in its setting is of outstanding importance for its aesthetic characteristics, valued as a place of great beauty by the Australian community • the main building and the surrounding landscape … act as reminders of important events and people in Australia’s history • the AWM together with Anzac Parade form an important national landmark that is highly valued by the Australian community • As part of the Parliamentary Vista, the AWM makes a major contribution to the principal views from both Parliament Houses and Mount Ainslie; • Views from Anzac Parade to the Hall of Memory and from the Hall of Memory along the land axis are outstanding’.

3. I have also considered the proposed redevelopment in the context of the values expressed against NHL criterion (b) (‘possession of uncommon, rare or endangered aspects of Australian natural or cultural history’) specifically:

• ‘The AWM is a purpose built repository reflecting the integral relationship between the building, commemorative spaces and the collections • This is unique in Australia and rare elsewhere in the world. These values are expressed in the fabric of the main building, the entrance, the Hall of Memory, the collections and the surrounding landscape’. the Commonwealth Heritage List

4. The Australian War Memorial was included in the Commonwealth Heritage List on 22 June 2004. The Summary Statement of Significance notes that the Official Values of the place relate to seven of the criteria for inclusion in the CHL. Of particular relevance to the proposed redevelopment are criterion D ‘Characteristic values’, criterion E ‘Aesthetic characteristics’ and criterion F ‘Technical achievement’.

5. The Official Values of the place under criterion D ‘Characteristic values’ are specifically: • ‘the Memorial building is one of Canberra’s earliest major examples of Australian Art Deco architecture, with fine examples of applied art in the same style’.

2 Official Values under criterion E ‘Aesthetic characteristics’ are specifically: • ‘the War Memorial is an important landmark in Canberra, Australia’s National Capital. • As the terminating building at the northern end of the land axis of Griffin’s city design and one of only three buildings sited on the axis, the Memorial makes a major contribution to the principal views from both Parliament Houses’. Official Values under criterion F ‘Technical achievement’ describe the attributes of the Memorial as: • ‘its distinctive massing and symmetry, • its prominent siting on the Land Axis, • its landscaped grounds and • its setting against the backdrop of the forested slopes of Mount Ainslie’.

This submission

6. The National Heritage values and the Commonwealth Heritage values taken together express the present functional, historical and aesthetic values in the architectural and landscape values of the AWM in its setting. I make this submission as a relevant expert (cv attached). My submission is:

The Commonwealth continue to protect these values in total in the interests of Australians. Considering the following reasons, the Minister should not approve the proposed redevelopment.

the proposed redevelopment

7. The referral proposes significant changes to the main entrance of the Memorial on the southern face of the building and replacement of the Anzac Hall at the rear of the site with a new and larger Anzac Hall connected to the Memorial building by a lofty glazed courtyard. In my opinion, these large new additions will overwhelm the original Memorial and will diminish the ‘outstanding importance’ of the ‘AWM in its setting’ which is ‘valued as a place of great beauty by the Australian community’. NHL criterion (e)

8. It is an important part of the three dimensional design of the Memorial that it is raised above the level of the city streets with steps and terraces fitted to the gentle slopes of Mount Ainslie. This arrangement allows direct medium and long distance visual

3 connection with the Land Axis and the central parts of the city and reinforces the special nature of the Memorial as part of the national memory. In my opinion, the proposed new southern entrance at the level of the parade ground would damage this relationship of the Memorial with Anzac Parade and the design of Canberra: ‘the AWM together with Anzac Parade form an important national landmark that is highly valued by the Australian community’. NHL criterion (e)

9. The project proposes to remove Anzac Hall and replace it with a new Anzac Hall and glazed courtyard. In my opinion, there are a number of good reasons not to demolish the existing Anzac Hall, first among which is that the building meets all expectations in regard to design quality and respect for both the Memorial building and its landscape setting. Anzac Hall is listed along with the main building and the surrounding landscape, the Hall of Memory, the Roll of Honour and the collections as ‘reminders of important events and people in Australia’s history’. Nothing in the referral suggests that the existing Anzac Hall has any deficiencies other than not being bigger. The need for additional exhibition space in a single location should be questioned but, if found to be essential, could be met with a clever addition rather than demolition. NHL criterion (e)

10. ‘The values of the AWM building are expressed in the fabric of the main building, the entrance … and the surrounding landscape’. I suggest that there are alternative approaches to achieving the objectives of the Memorial without the demolition of Anzac Hall, without removing the open space behind the Memorial and obscuring the original fabric of the building and without replacement of the original entrance to the Memorial with an underground point of entry. NHL criterion (b)

background: the commemorative intent

11. The Australian Heritage Database notes the ‘grand entrance’ as one of the ‘major commemorative spaces’ of the Memorial:

‘The AWM is a unique commemorative institution that functions as a memorial, a museum, an archive and a centre for research ... the major commemorative spaces are the grand entrance, the central courtyard and Pool of Remembrance, the flanking cloisters with the Roll of Honour and the copper domed Hall of Memory’.

4 Australian Heritage Database, National Heritage List, Australian War Memorial and the Memorial Parade, Anzac Parade, Campbell, ACT at Appendix A in Attachment E AWM Redevelopment HIA pp.95, 130

12. The 1925 competition to select the design for an Australian War Memorial in Canberra described the site as ‘on the southern slope of Mount Ainslie … on the axial line from Capitol Hill passing to Mount Ainslie, within a reserve of approximately 30 acres’. Architects were told that the building should respond to the landscape of Canberra with its broad expanse and distant views. It was widely understood that public buildings in Canberra should be light in colour: ‘this would be particularly important with regard to the War Memorial which, with the huge mass of Mount Ainslie immediately behind it, would make it impossible for the building, no matter how massive, to compete with it in size’. Federal Capital Commission: Australian War Memorial Canberra Architectural Competition July 1925 – February 1927: a review by William Lucas FRGS 1927

13. Sixty-nine submissions were received from architects in Australia, New Zealand, Great Britain and the United States. Design 52 by Emil Sodersten, a Sydney architect, was seen by the competition adjudicators as having an attractive layout ‘and a sequence so good that it has been classified as one of the best submitted’. The adjudicators also reported that, with the possible exception of design 41 by another Sydney architect John Crust, no design submitted ‘was likely to come within the sum available for the building’. Federal Capital Commission: Australian War Memorial Canberra: Architectural Competition Report and Supplementary Report by the Australian Board of Adjudicators (Charles Rosenthal, J S Murdoch and Leslie Wilkinson), September and October 1926

14. Of the design by Sodersten, the adjudicators said that its architecture ‘is exceptionally restrained and expressive of the purpose of the building’. Crust’s design was built around a court of honour and colonnades within which would be inscribed the names of the more than 60,000 Australians who had fallen in the War. Crust and Sodersten were each awarded honorariums for their work and were invited to collaborate on a new design which would combine Sodersten’s ‘solemn and fortress-like’ design with Crust’s court of honour and colonnades. Beryl Strusz, The History of the Australian War Memorial Building, Australian War Memorial Staff Research Program, 1994-95

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Sodersten competition design 1925

Crust competition design 1925

15. In March 1928 the design prepared by Sodersten and Crust was referred to the Parliamentary Standing Committee on Public Works. The proposed building was an impressive linear composition astride the axis of the city with a symmetrical façade, a clear address and approach sequence and a logical internal plan. The Committee took evidence from a wide range of experts in all areas of design and construction and concluded that ‘the building as designed will result in the production of a monument of appealing interest and beauty’. Professor Leslie Wilkinson, who had been one of the adjudicators in the design competition, told the Committee that he had seen drawings, models and photographs of the proposed structure and that ‘one of its great merits is that it cannot be labelled as belonging to any particular style of architecture’. The Committee recommended that ‘erection of the building on the site selected should be proceeded with at the earliest opportunity’. Parliamentary Standing Committee on Public Works, Report together with Minutes of Evidence relating to the Proposed Australian War Memorial Canberra, 1928

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The design by Sodersten and Crust approved by PWC 1928 Australian War Memorial XS0003

16. The principal elements of the Memorial were described by the Public Works Committee as ‘a central sunlit garden court having on each side a Roll of Honour sheltered by arcaded cloisters which lead to a domed Hall of Memory. Surrounding the court of honour are grouped the lower flanking wings of the galleries containing the memorial collection … the central court of honour will be … 212 feet long and 35 feet wide containing ornamental trees, flowers and sweet-smelling shrubs and a central mirror pool 75 feet long, 15 feet wide and about 1 foot deep’.

View from Mount Ainslie c.1938 Frozen in Time Gallery

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17. The Committee endorsed the unanimous view of the witnesses that the site ‘is pre-eminently the most suitable that could be suggested for a building of the nature contemplated’. The Committee reported that the main approach to the Memorial would be ’50 feet wide, gently rising to the lower terrace which is shown at the 1925 feet level … a broad flight of steps in three stages will connect the upper and lower terraces opposite the main portal’. These upper and lower terraces and steps and the location of the main entrance in the centre of the southern façade were and remain integral parts of the overall composition.

18. The Depression and other issues delayed the start of construction of the first stage of the building until 1934. Tenders for construction of the second and final stage of the Memorial closed in September 1937. Development of the design by Sodersten in this time saw the opening up of the southern end of the court of honour and the introduction of tall pylons each side of the main entrance. The AWM Heritage Register notes that ‘the building’s entry, with a pyloned low arch, provides a dramatic entry to the central cloistered space’. awm.gov.au>default>files>Heritage Register August 08.pdf

19. The Australian War Memorial was opened by the Governor- General on Armistice Day 1941. Photographs taken at the time show cars arriving at a lower terrace level (now referred to as the parade ground) with a series of circular landscaped terraces and three broad flights of steps rising to an upper terrace (now known as the forecourt) at the foot of the main entrance stair to the Memorial.

20. Visitors to the Memorial were told that the building would leave ‘a deep and imperishable impression’:

‘Beyond the portal, the garden court leads by way of the Pool of Reflection to the Hall of Memory, flanked by the arcaded cloisters in which is to be empanelled the bronze entablature of the Roll of Honour … upon its completion, the Hall of Memory will contain three sublime features – stained glass, sculpture and mosaic ... three great stained glass windows … will depict the outstanding qualities of the Australian fighting men and women’. Guide to Australian War Memorial, Halstead Press, Sydney 1941

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Drawing by Sodersten c. 1936 showing terrace levels and formal landscape design

9 aerial photo showing terraces and Memorial entrance c. 1941 AWM 100793

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Anzac Parade 1966 National Library of Australia

11 21. The newly opened Memorial demonstrated the essential elements of the Sodersten competition design including the Hall of Memory with its distinctive dome, the horizontal spread of the museum wings and a single central entrance. The Memorial was approached on axis and via several flights of stairs with a final flight of stairs to the building entry. A memorable nighttime view of the Memorial was captured in a 1966 photograph following the construction of Anzac Parade and the installation of the original street lighting standards. In this photograph, the main entrance appears as a small black dot halfway up the face of the building and the whole Memorial appears to float above the top of Anzac Parade. This iconic image of the Memorial is reflected in the logo for the Australian War Memorial.

the new southern entrance

22. It is proposed that a new southern entrance be ‘integrated into the Parade Ground to provide street level access into the Memorial, thereby enhancing accessibility and connectivity’. The meaning of ‘accessibility’ in this instance is not clear. This is a busy traffic intersection. There is presently no access to the Memorial site from Anzac Parade and only limited signalised pedestrian crossing on Limestone Avenue. Given the proximity of Limestone Avenue and Fairbairn Avenue and the general absence of pedestrian movement in this area, ‘connectivity’ of the Parade with the Memorial and ‘street level access’ would seem to be neither possible nor desirable. Attachment E AWM Redevelopment HIA op. cit. p.88

23. At first glance, the proposed new southern entrance might appear to reinstate the formal connection of the lower and upper level terraces in the design approved by the Parliamentary Works Committee in 1928. But the new stairs seem to be in two long flights

12 instead of the present three easier flights, possibly a more arduous climb. And the proposed new entrance to the Memorial building at the level of the parade ground would forever change the solemn approach to the Memorial on axis and by way of the central portal and stairs.

24. The referral notes that ‘the project will reinstate the existing forecourt and stairs which will be used as a secondary entrance primarily for ceremonial purposes … the proposed new subterranean entrance will require removal and reinstatement of existing stoneworks to the main Memorial entrance including stairs, podium stone paving entrance (sic) and some of the entry steps. Both the new southern entrance and existing main Memorial entrance will remain functional, however it is anticipated that the majority of visitors will utilise the new southern entrance when accessing the Memorial …

… this will change the original sense of arrival to the building for visitors … the proposed new design will also alter the front view of the original building … however the symmetrical configuration continues to be respected and the original building will continue to dominate the heritage place, thereby retaining the heritage setting and values … the ceremonial entrance at the upper level will still remain as per the original Memorial layout for ceremonial events’. Attachment E op. cit. pp.95, 130

25. The referral notes that ‘the main entrance forms part of the original Memorial building … external elevations of the main entrance to the Memorial have been identified as having a low tolerance for change’. The introduction of a large new building forward of the façade of the Memorial and the relegation of the original entrance to ‘ceremonial’ is inconsistent with this ‘low tolerance for change’. Attachment E op. cit. pp.15, 127

26. The location of the entrance to the Memorial is important not only for those arriving at or departing from the building but also for those already within it. When the Memorial was opened in 1941, the pylons at the main entrance framed a rather empty view of the Canberra valley and the provisional Parliament House. The present view from the entrance area and from the doorway to the Hall of Memory is more impressive. As noted in the NHL listing, ‘views from Anzac Parade to the Hall of Memory and from the Hall of Memory along the land axis are outstanding’. In 1981, following his win in the competition for the design of Australia’s permanent Parliament House, Romaldo Giurgola prepared a sketch showing the view from

13 the Memorial of Anzac Parade and both the old and new Houses of Parliament.

27. The Memorial is presently approached from the east by road at the level of the upper forecourt or from the west at a slightly lower level and by foot from large surface carparks at the rear of the site. Movement from the upper level forecourt to the Memorial itself is on foot using the original granite stairs, possibly pausing after eight easy steps for a look back at the city, then seven more steps and at the threshold two final steps and suddenly you see the central courtyard garden and the lofty Hall of Memory beyond.

Anzac Parade 1981 del. Romaldo Giurgola

28. Arrival and departure from the Memorial is an awe-inspiring experience, even if you have been there many times before. Lift access is available as needed but climbing and descending by stairs is for most people a critical part of the experience of the Memorial. In my opinion, the proposed subterranean journey to and from one corner of the Memorial is not a fair or reasonable substitute for the directness and dignity of the original approach and entry.

14 29. The proposed future use of the original steps and entrance portal ‘primarily for ceremonial purposes’ cannot be supported and in any event would be seen as discriminatory and unmanageable. It would remove for almost all visitors the experience of arriving at the heart of the shrine after a short and a formal flight of stairs and, when leaving the building, the opportunity would be lost to connect the Memorial with views of the capital city and its democratic symbols. If space at a lower level for arriving visitors is needed for operational or security reasons, those visitors should be returned as soon as possible to the level of the upper forecourt. Their route should stay on the line of the land axis so that they may enter the Memorial directly using the stairs and entrance portal designed for that purpose. Such an arrangement would also remove the need to excavate under the Memorial with the associated risks of damage to building fabric.

the new Anzac Hall and glazed courtyard

30. The Parliamentary Standing Committee on Public Works recommended in 1999 that the Anzac Hall be constructed at a cost of $11.9 million. The Committee noted the ‘striking architecture’ of a ‘modern flexible exhibition hall’. The Committee did not support an additional estimated cost of $2 million for a roof of copper or zinc and the roof was subsequently built using steel. Parliamentary Standing Committee on Public Works, Report relating to the proposed Anzac Hall Extension Australian War Memorial Canberra, 1999

31. Anzac Hall presently provides almost 3100 sqm of exhibition space and the sought after additional gallery space is said to be approximately 4500 sqm. The referral notes that the new Anzac Hall must be ‘respectful of the main Memorial building; sensitive to the landscape setting of the Memorial precinct; and adhere to the principles of symmetry and scale of the main Memorial building’. It is also claimed that a proposed glazed courtyard linking the new Anzac Hall to the original Memorial building ‘will strengthen and improve connectivity, thereby improving the visitor experience and enhancing circulation’. Attachment E op. cit. pp.91, 95, 132, 182

32. It is of note that the referral concedes that the proposed new Anzac Hall and glazed courtyard ‘will substantially alter the visual setting created by the existing Anzac Hall and potentially obscure part of the northern elevation of the main Memorial building’. The documentation adds that ‘the existing aerobridge is considered an

15 unsympathetic addition to the main Memorial building that impedes views of the building ‘in the round’ from ground level’. Attachment E op. cit. vol 1 pp.23, 140

33. Reference is made to public and professional recognition of the design excellence of Anzac Hall in the form of national architectural awards and for these reasons alone the proposal to demolish the existing building should be reconsidered. Issues of sustainability and environmental responsibility add to this argument as does the presence of embodied energy in such a large and soundly constructed public building.

34. In my opinion, it would be a most unfortunate outcome if Anzac Hall were to be demolished. There are other options. It might be possible, for example, to find the additional exhibition and other space sought by the Memorial by excavating one or more new basement levels within the footprint of the existing Hall, perhaps with some underground expansions beyond the existing walls. There is no reason to assume that the new level(s) below the ground will cost more than a new building above ground and importantly the existing relationship of Anzac Hall with the Memorial building will not be damaged.

Anzac Hall 2000 source: Denton Corker Marshall

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35. Desired flexibility in future use can be ensured by heavyweight construction, large clear spans and double or triple height volumes with stairs, lifts, escalators and generous electrical and other service infrastructure. External lifting pits can be readily installed for bulky objects. Natural light may be introduced in many ways. Steps could be taken to address any perceived deficiencies with the existing aerobridge and to upgrade visitor facilities in the area. The roof of the Hall could at the same time be replaced with copper or zinc if that is the wish of the Memorial.

36. In my opinion, the redevelopment of the Australian War Memorial should not proceed in the form proposed. It would result in an unacceptable impact on the symbolic role, heritage values and architectural integrity of the Memorial and its critical role in the identity of Canberra and Australia.

Roger Pegrum April 2020

Roger Pegrum is a Life Fellow of the Royal Australian Institute of Architects. He is the author of The Bush Capital and A Very Great City One Day and was the Australian Government Architect from1986 to 1988.

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Roger Michael Pegrum curriculum vitae

attachment 2 email correspondence with the Australian War Memorial January/February 2020

Dear Chris

Thank you for your email and the links you have provided to documentation for this project. It has been valuable to read at length the full EPBC submission.

As discussed when we met on site, I have a long personal and professional interest in the War Memorial and Anzac Parade. In 1963 I worked at the National Capital Development Commission with Sir William Holford on the plans for Anzac Parade and I designed the original lights along the Parade.

I would be grateful to learn more about both broad intentions and detail planning for the proposed new southern entrance to the Memorial. You have noted the comparative lack of architectural plans and cross sections for this part of the work and have offered to chase up some more detail. I look forward to receiving whatever documents are available.

I would also be pleased to know the likely next steps in the development program and the timing for further consultation.

Thank you for your assistance.

Regards

Roger Pegrum

On 25 Jan 2020, at 12:10 pm, wrote:

Good afternoon Roger

Thank you for your time this morning discussing the Memorial’s development project.

As I said during our conversation, I’ve spoken to hundreds of Australians in the past few months as part of our consultation, our discussion was one of the most reasonable ‘give and take’ exchanges I’ve had during the process and I appreciate how you conducted yourself very much – not everyone was so open to our side of the story or so calm in delivering theirs.

I’ve attached all the EPBC referral documentation as requested – you can get it direct from the Department of Environment and Energy website too, but it’s painfully slow so this will be easier.

Should you wish to access the documentation via DoEE the link below will take you to their website where you’ll need to search for AWM Redevelopment Referral (2019/8574): http://epbcnotices.environment.gov.au/publicnoticesreferrals/

As we briefly discussed the Memorial’s initial referral has, after the public comment period, been assessed as a ‘controlled action’ and will be assess via Preliminary Documentation. The Memorial intends to submit this documentation in late February 2020 and we would expect DoEE to undertake their public consultation on that documentation shortly thereafter.

The EPBC documentation I’ve provided has more renders than drawings or plans, so if the sections etc. available aren’t sufficient please let me know and I’ll chase up some more detail for you.

Again, thank you for your time this morning and for your thoughtful commentary.

Yours sincerely

Chris

Deputy Program D rector

Austra an War Memor a Deve opment Project

Austra an War Memor a | GPO Box 345 Canberra ACT 2601 | www.awm.gov.au

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