The following formal submission have been made public
Submitter: Richard MorrisonComments
Works Approval Submissions
National Capital Authority
Treasury Building, King Edward Terrace
Parkes, ACT 2600, Australia
Online submission
To whom it may concern
NCA WORKS APPROVAL LIGHT RAIL STAGE 2A
SUBMISSION
The Lake Burley Griffin Guardians (the Guardians) is a non-profit community group established in 2015 and is committed to safeguarding one of Australia’s greatest designed landscapes, the open space of Lake Burley Griffin and its lakeshore landscape setting, that, as a unit, is a significant monument to our nation.
Summary
The Guardians considers that commentators on this WA have been placed in a difficult position as the documentation is deficient in a range of key areas and recommends the dismissal of this project until an improved assessment of it is made possible by the re-submission of a revised more complete and better directed proposal.
The WA documentation is inadequate from a number of perspectives:
1. It should include the entire City to Woden Light Rail project to be consistent with best practice environmental and heritage planning and approval practice.
2. WA documentation is missing: GML’s referred to separate report on ‘the potential impacts to the intrinsic features of the Melbourne and Sydney Buildings’; the NCA’s Commonwealth Avenue Master Plan. (2022).
3. The AECOM: Landscape and Visual Assessment Impact Assessment (15 December 2022) has ignored an assessment of the important view from Commonwealth Avenue currently and long available to the southwest, across the Lake to the Brindabellas. This view sets the viewer in the context of the Lake, wider Canberra, the region’s topography and exposes the viewer to the Griffins’ wider vision for his city in a landscape – a key aspect of the national significance of Canberra and a critical to the role of the NCA.
4. A misquoting of an important paragraph of the NCP in relation to how heritage in the Designated Area should be treated. This may have led possibly to, combined with certain quoted advice from the ACT Heritage Council and the absence of a potentially critical document, Philip Leeson Architects: Sydney and Melbourne Buildings CMP (January 2022), a diminishment of the impact assessment of the project on the heritage of the perceived relationship and co-dependency between the ACT Heritage listed Sydney and Melbourne Buildings. This leaves the reviewer of the WA documentation at a disadvantage in assessing the project’s likely impact in regard to these heritage buildings.
5. The omission of certain heritage information on various places within the project impact zone. This information deriving from a number of obvious sources. This omission may have led to the WA documentation missing various potential impacts.
Introductory statement
In past submissions on NCA WA’s and EPBC Act Referrals, the Guardians have referred to the need to follow best environmental and heritage planning and approval practice by considering the entirety of a project rather than components, particularly where those components imply or are necessary precursors to a further stage or stages of some larger project. This view of ours is authoritatively reinforced by the guidelines provided by the Commonwealth Environment Department to proponents who might be making an EPBC Act Referral ‘on what constitutes an action’ and does it constitute a ‘split referral’?
The EPBC Act policy test in such circumstances, is ‘will splitting reduce the ability to achieve the objects of the EPBC Act?’. Paralleling this, in our view, the splitting of the Light Rail project approvals conducted by the NCA as currently received would reduce the ability to achieve the objects of the NCA’s approvals process because it ignores the undisputed, co-dependency of 2A and 2B and should not be allowed. The remaining portion of the Gungahlin to Woden Light Rail project, that is, City to Woden, should be assessed now as a single unit. The co-dependency is clearly seen in the explicit references in the ACT Government’s planning documentation, the media releases, online information and the enormous concomitant-works intended - with its disproportionate execution cost, for this short extension of the 2A section of the network from Civic to Commonwealth Park - prior to the track being extended across the Lake to Woden.
Thus, the Guardians are of the (consistent) view that this WA should not be approved and the CRA be required to submit a proposal for the entire City to Woden project for Works Approval.
Comments
Missing important documents and anomalies
1. There is an omission of the separate report that was to be prepared by GML on ‘the potential impacts to the intrinsic features of the Melbourne and Sydney Buildings’ (see p90 and p99). The handling of the effect of the project here could be better understood if this report was available. The diminishment of the apparent, potential impact as a result of a misinterpretation of the NCP and ACT Heritage/Government advice, may have had at least one effect on the overall impact assessment of the project on both heritage, and visual and landscape values here. The potential impact would seem to have not been adequately dealt with from a larger perspective. (See below.)
2. The WA documentation provided does not include the critical NCA’s 2022 Commonwealth Avenue Master Plan, either as part of the ACT Government consultant’s documents or separately by the NCA as a courtesy, given its criticality in contributing to the intended, post-construction form of the Avenue. Neither is it publicly available separately on the NCA website. Oddly, it does not appear to have gone through a community review stage before its use in this critical proposal and such a review may have identified issues requiring adjustment.
This absence of public exposure is alarming as this Master Plan has been used as a key document in the proposed tree planting programme on the west side of Commonwealth Avenue. This aspect of the landscaping is supported by general statements in the NCP for continuous planting along the main avenues, including this one.
Main avenue masterplans recommended (in the required hierarchy of planning documents) to be prepared by the NCP, are necessarily more detailed planning prescriptions for the avenues than could be included in the NCP so are more tailored to the particular form and details of the individual, respective avenues. It might be expected that works plans would be customised to reflect the need to maintain significant vistas where they might not be if general statements such as those of the more, high-order document/s, like the NCP, are followed without the closer scrutiny of the master plans, and indeed, any subsequent works-related landscape and visual assessments.
It is acknowledged by the Guardians that a summary of the ‘Principles’ from the missing Master Plan are included in the Landscape and Visual Assessment Impact Assessment. This summary is an inadequate substitute for provision of the full document to allow an understanding of how the document with its own approach, has been used to inform the Assessment.
Missing recognition of an important vista
The AECOM: Landscape and Visual Assessment Impact Assessment (15 December 2022) provided in the WA documents has ignored an assessment of the important view currently available to the southwest, across the Lake to the Brindabellas, which sets the viewer in the context of the Lake, wider Canberra, the region’s topography and exposes the viewer to the Griffins’ wider vision for his city in a landscape. At this time of year, it also usually reveals an attractive vista of snow-capped hills in the distance.
This latter perspective is encapsulated in the final few Principles from the missing Master Plan, summarised (at pp140-141) in this impact assessment document, but this perspective has not been picked up as it should be. It was also a view revealed as being of heritage importance in the Indigenous consultation (see GML Light Rail City to Commonwealth Park Heritage Impact Assessment (December 2022) p6). So why hasn’t it been considered as a worthy view for impact consideration?
To maintain this vista, a reduced density of trees is required, rather than the proposed continuous line of trees on this west side of Commonwealth Avenue.
It seems likely that the currently proposed plantings may be related, but not acknowledged here, to the screening of the intended development of an apartment and mixed-use, estate adjacent to the Avenue at West Basin. If this is the rationale, the wall of trees is related to a function outside this light rail project. It is an external, potential, future factor to this present works project and, in our view inappropriate for inclusion apparently to screen the West Basin development, particularly without discussion or justification.
This vista is too important to hide from the future Avenue users for this reason in the Guardians’ view.
The Guardians would prefer to not have multi-storey buildings on the this edge of Commonwealth Avenue – they should be removed from the current West Basin planning, substantially reduced in height and/or pulled back from the edge significantly.
It might also be seen as inappropriate to hide the present, significant, advantageous public vista from this main avenue, by privatising the same view for the exclusive use of the privileged occupants of any high-rise structures that may be built along this Avenue edge.
Assessment of project impact on the registered heritage of the Melbourne and Sydney Buildings
Referred to above, a misquoting of the NCP may have led to at least one significant error in assessing the impact of the project on heritage, and visual and landscape values along the main avenue in relation to an ACT Heritage place, the landmark Melbourne and Sydney Buildings.
The NCP requires, at: 2.4.4 Principles for Objective two – Urban design and heritage, that:
‘a. The National Capital Authority will consider heritage places in Designated Areas as Commonwealth Areas for the purposes of protecting the environment in the manner currently afforded under the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) and any subsequent legislation.’
The GML Light Rail City to Commonwealth Park- Heritage Impact Assessment (December 2022) quotes from the NCP (at p17), in the context of discussing the requirements of the Commonwealth Management Principles regarding the need for the Commonwealth to manage ‘Commonwealth Heritage Places’, but has added to the above the following words at the end of the paragraph:
’, unless they are managed by the ACT Government and included in the ACT Heritage Register.’
It is not clear from where these extra words have come. They do not appear in the (undated) version of the NCP on the NCA website. A footnote to the quoted paragraph provides a reference to a 2019 version of the NCP but the Guardians cannot recall these words ever being present from the time of NCP Amendment 86 in 2016, when the above paragraph was added.
It is apparent the words ‘and any subsequent legislation’ are precautionary and refer to subsequent Commonwealth legislation that may follow a possible change/replacement of the current EPBC Act. They do not refer to ACT legislation if this is where GML’s additional words derive, and are an inaccurate interpretative extension.
The extra words might be interpreted, were they a valid inclusion and actually found in the NCP, as an attempt to somehow establish an NCP override to the EPBC Act. The intent of the Commonwealth Management Principles, developed in the EPBC Act Regulations and the related Guidelines, is to establish clear Commonwealth Agency responsibilities for heritage that it may own or manage. These additional words attempt to pass responsibility to another jurisdiction. It may even reduce/alter the strength of that intended heritage care depending on the way that other jurisdiction may provide or exercise protection of its heritage in which they are legally invalid.
There are a number of ACT Heritage Register places that might be impacted by this project and affected by these extra words (of unknown origin) but one, in particular stands out. This is the ACT Register listed place of the Melbourne and Sydney Building. It is noted above that a separate potential impacts report on this place, to be prepared by GML, in addition to their larger report, is not in the provided WA documentation. Nor is the ‘ACT Heritage Council approved’ CMP for this place provided or linked, however, this is online. It, Philip Leeson Architects: Sydney and Melbourne Buildings CMP (January 2022), expands, for additional management guidance on the place’s citation as would be expected and provides (on pp 34-35) a list of ‘significant features’ (inter alia). The first of these is: ‘The prominent setting and landmark qualities of the Sydney and Melbourne Buildings, as well as their planned relationship to each other, Northbourne Avenue and City Hill.’
The omission of this special GML report has significance because of a statement (on p90 of the provided GML report) that the ‘landscaping concept is supported by ACT Heritage’ (was the Council consulted?). The extra words if they had been in the NCP and were effective, might be called on here to justify the ACT Government’s assessment, overriding potential Commonwealth assessment that the landscaping and other impacts were a problem, as it might.
The emphasis in the listing information, apart from the two buildings being included in the one ACT Register listing, pays scant attention to the urban development implication of the two, matching landmark structures, of very similar design, built in the same period, taking up whole blocks, facing each other on opposite sides of this end/start of Northbourne Avenue. They are a pair and should be treated together and visually, not ‘separated’ by light rail features including landscaping, as they need to be ‘read’ together, irrespective of the registered boundaries.
This relational aspect between the two buildings is picked up strongly in the Assessment of Viewpoints in the Landscape and Visual Impact Assessment AECOM (15 Dec 2022) (at p61), perhaps because, whilst it responds to the fact of listing, it does what is expected in this kind of assessment and is concerned more with the obvious visual and landscape relationship that demands consideration.
However, oddly, despite recognising this as a strong ‘Visual stimulation rationale’ here, in the Summary of Impact Table (Table iii) and here assessing the mitigated impact as High and (Overall High to Moderate), it provides a Qualitative rating only as Neutral. Could this latter be as a result of the misinformation of the above-cited NCP extra words apparently ceding management of this issue to the ACT Government and its specific advice on this issue that the proposals here are acceptable? The Qualitative rating should be higher.
Clearly there are issues here that are not being taken into account in the impact assessment that should be. Could this anomaly be explained in the special, separate report indicated by GML that was provided to the ACT Government on ‘the potential impacts to the intrinsic features of the Melbourne and Sydney Buildings’ that unusually has not been provided with the WA documentation?
The Register of the National Estate (and other sources) as a source of heritage information was omitted.
The project impact assessments found in the various reports, whilst considering listings and various nominations to current statutory lists, has omitted consideration of the now, non-statutory Register of the National Estate as a source of discrete, professional heritage information (although likely with some overlap to other used documentation), whether the place was listed or not. For instance, consideration of the (1998) City Hill, Parliament House Vista (1987), Sydney and Melbourne Buildings (1980) and Lake Burley Griffin Conservation Area (indicative) documentation, on these places has been omitted from consideration.
Other useful information might have been derived from the several NHL nominations for Lake Burley Griffin and surrounds (with some name changes and inclusions/exclusions). Also, information may have been derived from reports such as the National Trust of Australia (ACT) Study of the Social Values of Lake Burley Griffin and its setting (2009).
Richard Morrison
Vice Convenor
11 May 2023
National Capital Authority
Treasury Building, King Edward Terrace
Parkes, ACT 2600, Australia
Online submission
To whom it may concern
NCA WORKS APPROVAL LIGHT RAIL STAGE 2A
SUBMISSION
The Lake Burley Griffin Guardians (the Guardians) is a non-profit community group established in 2015 and is committed to safeguarding one of Australia’s greatest designed landscapes, the open space of Lake Burley Griffin and its lakeshore landscape setting, that, as a unit, is a significant monument to our nation.
Summary
The Guardians considers that commentators on this WA have been placed in a difficult position as the documentation is deficient in a range of key areas and recommends the dismissal of this project until an improved assessment of it is made possible by the re-submission of a revised more complete and better directed proposal.
The WA documentation is inadequate from a number of perspectives:
1. It should include the entire City to Woden Light Rail project to be consistent with best practice environmental and heritage planning and approval practice.
2. WA documentation is missing: GML’s referred to separate report on ‘the potential impacts to the intrinsic features of the Melbourne and Sydney Buildings’; the NCA’s Commonwealth Avenue Master Plan. (2022).
3. The AECOM: Landscape and Visual Assessment Impact Assessment (15 December 2022) has ignored an assessment of the important view from Commonwealth Avenue currently and long available to the southwest, across the Lake to the Brindabellas. This view sets the viewer in the context of the Lake, wider Canberra, the region’s topography and exposes the viewer to the Griffins’ wider vision for his city in a landscape – a key aspect of the national significance of Canberra and a critical to the role of the NCA.
4. A misquoting of an important paragraph of the NCP in relation to how heritage in the Designated Area should be treated. This may have led possibly to, combined with certain quoted advice from the ACT Heritage Council and the absence of a potentially critical document, Philip Leeson Architects: Sydney and Melbourne Buildings CMP (January 2022), a diminishment of the impact assessment of the project on the heritage of the perceived relationship and co-dependency between the ACT Heritage listed Sydney and Melbourne Buildings. This leaves the reviewer of the WA documentation at a disadvantage in assessing the project’s likely impact in regard to these heritage buildings.
5. The omission of certain heritage information on various places within the project impact zone. This information deriving from a number of obvious sources. This omission may have led to the WA documentation missing various potential impacts.
Introductory statement
In past submissions on NCA WA’s and EPBC Act Referrals, the Guardians have referred to the need to follow best environmental and heritage planning and approval practice by considering the entirety of a project rather than components, particularly where those components imply or are necessary precursors to a further stage or stages of some larger project. This view of ours is authoritatively reinforced by the guidelines provided by the Commonwealth Environment Department to proponents who might be making an EPBC Act Referral ‘on what constitutes an action’ and does it constitute a ‘split referral’?
The EPBC Act policy test in such circumstances, is ‘will splitting reduce the ability to achieve the objects of the EPBC Act?’. Paralleling this, in our view, the splitting of the Light Rail project approvals conducted by the NCA as currently received would reduce the ability to achieve the objects of the NCA’s approvals process because it ignores the undisputed, co-dependency of 2A and 2B and should not be allowed. The remaining portion of the Gungahlin to Woden Light Rail project, that is, City to Woden, should be assessed now as a single unit. The co-dependency is clearly seen in the explicit references in the ACT Government’s planning documentation, the media releases, online information and the enormous concomitant-works intended - with its disproportionate execution cost, for this short extension of the 2A section of the network from Civic to Commonwealth Park - prior to the track being extended across the Lake to Woden.
Thus, the Guardians are of the (consistent) view that this WA should not be approved and the CRA be required to submit a proposal for the entire City to Woden project for Works Approval.
Comments
Missing important documents and anomalies
1. There is an omission of the separate report that was to be prepared by GML on ‘the potential impacts to the intrinsic features of the Melbourne and Sydney Buildings’ (see p90 and p99). The handling of the effect of the project here could be better understood if this report was available. The diminishment of the apparent, potential impact as a result of a misinterpretation of the NCP and ACT Heritage/Government advice, may have had at least one effect on the overall impact assessment of the project on both heritage, and visual and landscape values here. The potential impact would seem to have not been adequately dealt with from a larger perspective. (See below.)
2. The WA documentation provided does not include the critical NCA’s 2022 Commonwealth Avenue Master Plan, either as part of the ACT Government consultant’s documents or separately by the NCA as a courtesy, given its criticality in contributing to the intended, post-construction form of the Avenue. Neither is it publicly available separately on the NCA website. Oddly, it does not appear to have gone through a community review stage before its use in this critical proposal and such a review may have identified issues requiring adjustment.
This absence of public exposure is alarming as this Master Plan has been used as a key document in the proposed tree planting programme on the west side of Commonwealth Avenue. This aspect of the landscaping is supported by general statements in the NCP for continuous planting along the main avenues, including this one.
Main avenue masterplans recommended (in the required hierarchy of planning documents) to be prepared by the NCP, are necessarily more detailed planning prescriptions for the avenues than could be included in the NCP so are more tailored to the particular form and details of the individual, respective avenues. It might be expected that works plans would be customised to reflect the need to maintain significant vistas where they might not be if general statements such as those of the more, high-order document/s, like the NCP, are followed without the closer scrutiny of the master plans, and indeed, any subsequent works-related landscape and visual assessments.
It is acknowledged by the Guardians that a summary of the ‘Principles’ from the missing Master Plan are included in the Landscape and Visual Assessment Impact Assessment. This summary is an inadequate substitute for provision of the full document to allow an understanding of how the document with its own approach, has been used to inform the Assessment.
Missing recognition of an important vista
The AECOM: Landscape and Visual Assessment Impact Assessment (15 December 2022) provided in the WA documents has ignored an assessment of the important view currently available to the southwest, across the Lake to the Brindabellas, which sets the viewer in the context of the Lake, wider Canberra, the region’s topography and exposes the viewer to the Griffins’ wider vision for his city in a landscape. At this time of year, it also usually reveals an attractive vista of snow-capped hills in the distance.
This latter perspective is encapsulated in the final few Principles from the missing Master Plan, summarised (at pp140-141) in this impact assessment document, but this perspective has not been picked up as it should be. It was also a view revealed as being of heritage importance in the Indigenous consultation (see GML Light Rail City to Commonwealth Park Heritage Impact Assessment (December 2022) p6). So why hasn’t it been considered as a worthy view for impact consideration?
To maintain this vista, a reduced density of trees is required, rather than the proposed continuous line of trees on this west side of Commonwealth Avenue.
It seems likely that the currently proposed plantings may be related, but not acknowledged here, to the screening of the intended development of an apartment and mixed-use, estate adjacent to the Avenue at West Basin. If this is the rationale, the wall of trees is related to a function outside this light rail project. It is an external, potential, future factor to this present works project and, in our view inappropriate for inclusion apparently to screen the West Basin development, particularly without discussion or justification.
This vista is too important to hide from the future Avenue users for this reason in the Guardians’ view.
The Guardians would prefer to not have multi-storey buildings on the this edge of Commonwealth Avenue – they should be removed from the current West Basin planning, substantially reduced in height and/or pulled back from the edge significantly.
It might also be seen as inappropriate to hide the present, significant, advantageous public vista from this main avenue, by privatising the same view for the exclusive use of the privileged occupants of any high-rise structures that may be built along this Avenue edge.
Assessment of project impact on the registered heritage of the Melbourne and Sydney Buildings
Referred to above, a misquoting of the NCP may have led to at least one significant error in assessing the impact of the project on heritage, and visual and landscape values along the main avenue in relation to an ACT Heritage place, the landmark Melbourne and Sydney Buildings.
The NCP requires, at: 2.4.4 Principles for Objective two – Urban design and heritage, that:
‘a. The National Capital Authority will consider heritage places in Designated Areas as Commonwealth Areas for the purposes of protecting the environment in the manner currently afforded under the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) and any subsequent legislation.’
The GML Light Rail City to Commonwealth Park- Heritage Impact Assessment (December 2022) quotes from the NCP (at p17), in the context of discussing the requirements of the Commonwealth Management Principles regarding the need for the Commonwealth to manage ‘Commonwealth Heritage Places’, but has added to the above the following words at the end of the paragraph:
’, unless they are managed by the ACT Government and included in the ACT Heritage Register.’
It is not clear from where these extra words have come. They do not appear in the (undated) version of the NCP on the NCA website. A footnote to the quoted paragraph provides a reference to a 2019 version of the NCP but the Guardians cannot recall these words ever being present from the time of NCP Amendment 86 in 2016, when the above paragraph was added.
It is apparent the words ‘and any subsequent legislation’ are precautionary and refer to subsequent Commonwealth legislation that may follow a possible change/replacement of the current EPBC Act. They do not refer to ACT legislation if this is where GML’s additional words derive, and are an inaccurate interpretative extension.
The extra words might be interpreted, were they a valid inclusion and actually found in the NCP, as an attempt to somehow establish an NCP override to the EPBC Act. The intent of the Commonwealth Management Principles, developed in the EPBC Act Regulations and the related Guidelines, is to establish clear Commonwealth Agency responsibilities for heritage that it may own or manage. These additional words attempt to pass responsibility to another jurisdiction. It may even reduce/alter the strength of that intended heritage care depending on the way that other jurisdiction may provide or exercise protection of its heritage in which they are legally invalid.
There are a number of ACT Heritage Register places that might be impacted by this project and affected by these extra words (of unknown origin) but one, in particular stands out. This is the ACT Register listed place of the Melbourne and Sydney Building. It is noted above that a separate potential impacts report on this place, to be prepared by GML, in addition to their larger report, is not in the provided WA documentation. Nor is the ‘ACT Heritage Council approved’ CMP for this place provided or linked, however, this is online. It, Philip Leeson Architects: Sydney and Melbourne Buildings CMP (January 2022), expands, for additional management guidance on the place’s citation as would be expected and provides (on pp 34-35) a list of ‘significant features’ (inter alia). The first of these is: ‘The prominent setting and landmark qualities of the Sydney and Melbourne Buildings, as well as their planned relationship to each other, Northbourne Avenue and City Hill.’
The omission of this special GML report has significance because of a statement (on p90 of the provided GML report) that the ‘landscaping concept is supported by ACT Heritage’ (was the Council consulted?). The extra words if they had been in the NCP and were effective, might be called on here to justify the ACT Government’s assessment, overriding potential Commonwealth assessment that the landscaping and other impacts were a problem, as it might.
The emphasis in the listing information, apart from the two buildings being included in the one ACT Register listing, pays scant attention to the urban development implication of the two, matching landmark structures, of very similar design, built in the same period, taking up whole blocks, facing each other on opposite sides of this end/start of Northbourne Avenue. They are a pair and should be treated together and visually, not ‘separated’ by light rail features including landscaping, as they need to be ‘read’ together, irrespective of the registered boundaries.
This relational aspect between the two buildings is picked up strongly in the Assessment of Viewpoints in the Landscape and Visual Impact Assessment AECOM (15 Dec 2022) (at p61), perhaps because, whilst it responds to the fact of listing, it does what is expected in this kind of assessment and is concerned more with the obvious visual and landscape relationship that demands consideration.
However, oddly, despite recognising this as a strong ‘Visual stimulation rationale’ here, in the Summary of Impact Table (Table iii) and here assessing the mitigated impact as High and (Overall High to Moderate), it provides a Qualitative rating only as Neutral. Could this latter be as a result of the misinformation of the above-cited NCP extra words apparently ceding management of this issue to the ACT Government and its specific advice on this issue that the proposals here are acceptable? The Qualitative rating should be higher.
Clearly there are issues here that are not being taken into account in the impact assessment that should be. Could this anomaly be explained in the special, separate report indicated by GML that was provided to the ACT Government on ‘the potential impacts to the intrinsic features of the Melbourne and Sydney Buildings’ that unusually has not been provided with the WA documentation?
The Register of the National Estate (and other sources) as a source of heritage information was omitted.
The project impact assessments found in the various reports, whilst considering listings and various nominations to current statutory lists, has omitted consideration of the now, non-statutory Register of the National Estate as a source of discrete, professional heritage information (although likely with some overlap to other used documentation), whether the place was listed or not. For instance, consideration of the (1998) City Hill, Parliament House Vista (1987), Sydney and Melbourne Buildings (1980) and Lake Burley Griffin Conservation Area (indicative) documentation, on these places has been omitted from consideration.
Other useful information might have been derived from the several NHL nominations for Lake Burley Griffin and surrounds (with some name changes and inclusions/exclusions). Also, information may have been derived from reports such as the National Trust of Australia (ACT) Study of the Social Values of Lake Burley Griffin and its setting (2009).
Richard Morrison
Vice Convenor
11 May 2023