Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo

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Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo
Statement of Evidence
        Planning Scheme Amendment C235

 Bendigo City Centre Heritage Study Stage 1

          Report prepared for City of Greater Bendigo
                                       9 March 2021
Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo
Acknowledgement of Country

At Context we acknowledge that we work and live on the land of the First Australians. We know
that this land was never ceded, and we respect the rights and interests of Australia’s first people in
land, culture, and heritage. We acknowledge their Elders past and present and support the
concepts of voice, treaty, and truth in the Uluru Statement from the Heart.

Report Register
The following report register documents the development and issue of the report entitled
Statement of Evidence—Bendigo Planning Scheme Amendment C235 - Bendigo City Centre Heritage
Study Stage 1, undertaken by Context in accordance with its quality management system.

Job Number           Issue Number          Notes/Description                           Issue Date
2739                 1                     Statement of Evidence - DRAFT               4 March 2021
2739                 2                     Statement of Evidence                       9 March 2021

Quality Assurance
The report has been reviewed and approved for issue in accordance with the Context quality assurance
policy and procedures.

Copyright
Historical sources and reference material used in the preparation of this report are acknowledged and
referenced in footnotes and/or in figure captions. Reasonable effort has been made to identify, contact,
acknowledge and obtain permission to use material from the relevant copyright owners.

Unless otherwise specified or agreed, copyright in this report vests in Context and in the owners of any
pre-existing historic source or reference material.

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(Commonwealth) Copyright (Moral Rights) Amendment Act 2000. Context’s moral rights include the
attribution of authorship, the right not to have the work falsely attributed and the right to integrity of
authorship.

Right to Use
Context grants to the client for this project (and the client’s successors in title) an irrevocable royalty-free
right to reproduce or use the material from this report, except where such use infringes the copyright
and/or Moral Rights of Context or third parties.
Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo
CONTEXT

Contents
1         Introduction                                                                         1
    1.1     Purpose                                                                            1
    1.2     Instructions                                                                       1
    1.3     Sources of Information                                                             1
    1.4     Qualifications, Experience and Area of Expertise                                   1
    1.5     Summary of Opinion                                                                 2
    1.6     Further changes recommended in response to submissions                             2
    1.7     Declaration                                                                        2

2         Strategic basis to amendment C235                                                    3

3         Methodology of the Study                                                             3
    3.1   Background                                                                           3
    3.2   Scoping report                                                                       3
    3.3   Assessment and reporting                                                             4
    3.3.1 Historical context                                                                   4
    3.3.2 Place histories                                                                      4
    3.3.3 Field survey and documentation                                                       5
    3.3.4 Comparative analysis                                                                 5
    3.3.5 Assessment against criteria                                                          6
    3.3.6 Statement of significance                                                            6
    3.3.7 Mapping                                                                              7
    3.3.8 Statutory recommendations                                                            7

4         Response to Submissions                                                              9
    4.1   Introduction                                                                          9
    4.2   Former Bendigo Timber Company Store at106 Williamson Street, Bendigo (Submission 4) —
    Appearing                                                                                   9
    4.2.1 Recommendations and Amendment C235                                                    9
    4.2.2 Statement of Significance                                                             9
    4.2.3 Heritage Matters for Discussion                                                     10
    4.3   Bendigo Bowling Centre at 159 Hargreaves Street, Bendigo (Submission 7) — Not appearing
          17
    4.3.1 Recommendations and Amendment C235                                                  17
    4.3.2 Statement of Significance                                                           17
    4.3.3 Heritage Matters for Discussion                                                     18

5         References                                                                         21

6         Appendix A                                                                         22

Statement of Evidence and Report to Planning Panel
Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo
1 Introduction

      1.1 Purpose
[1]   I, Kim Roberts, have prepared this statement of evidence for Greater Bendigo City Council in relation to
      Amendment C235 to the Greater Bendigo Planning Scheme Amendment (the Amendment).

[2]   The Amendment proposes to implement the recommendations of the ‘Bendigo City Centre Heritage Study
      Stage 1’ (the Study), prepared and revised by Context in 2016-17 and 2020 respectively.

      1.2 Instructions
[3]   This statement of evidence has been prepared in response to the instructions of the City of Greater
      Bendigo (Council) in regard to the inclusion of properties assessed in the Study as being of heritage
      significance in the Heritage Overlay (HO) as part of Amendment C235 (the Amendment) to the Greater
      Bendigo Planning Scheme.

[4]   It has been requested that I review submissions and provide an opinion on the heritage significance of the
      following two individual properties that have been recommended for the inclusion in the HO:

      •      the former Bendigo Timber Company,106 Williamson Street; and

      •      the Bendigo Bowl at 159 Hargreaves Street, Bendigo.

      1.3 Sources of Information
[5]   This statement draws upon the following documentation:

      •      Context 2020, ‘Bendigo City Centre Heritage Study Stage 1’.

      •      Planning Practice Note 1 ‘Applying Heritage Overlay’ (PPN1), 2018.

      •      Richard Apperley et al 1989, Identifying Australian Architecture.

      •      Lovell Chen 2013, City of Greater Bendigo Thematic Environmental History.

      1.4 Qualifications, Experience and Area of Expertise
[6]   I am an architect and heritage consultant and have been engaged in the heritage field for over 16 years.
      I have been actively providing heritage and heritage asset management advice to private individuals and
      businesses, municipal councils, and the Victorian Director of Housing and Secretary of Human Services
      regarding sites listed at Local, State and National level during this time. My PhD focused on a postwar
      memorial site in Hiroshima, Japan, part of which was listed on the World Heritage List. I am a member of
      the Victorian Design Review Panel where I engage in peer review of architectural projects, particularly
      those within heritage contexts. I have extensive experience working with the Planning Scheme, and an
      solid understanding of the Planning Scheme Amendment process. I have acted on behalf of the Director
      of Housing at Planning Panels in the past.

[7]   The area of expertise I have that is relevant to this Planning Panel hearing is the assessment of cultural
      heritage significance of places, buildings and structures within the wider Victorian context.

[8]   My curriculum vitae outlining my heritage qualifications and experience with respect to heritage issues is
      attached as Appendix A to this report.

      Statement of Evidence and Report to Planning Panel
      Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo
1.5 Summary of Opinion
[9]    The Amendment adds significant heritage properties to the HO and should be supported. The inclusion of
       the former Bendigo Timber Company, 106 Williamson Street, Bendigo, is justified by the current citation
       – minor amendments to which are proposed as part of this submission. The inclusion of the Bendigo Bowl,
       159 Hargreaves Street, Bendigo, is justified by the current citations – without amendments.

[10]   The place citations for each property determine that they meet a ‘threshold’ of local significance based on
       HERCON Criteria. Further, they respond to the broad historical themes articulated in City of Greater
       Bendigo Thematic Environmental History, provide a locality history that seeks to bridge gaps in the
       understanding of the postwar development of Bendigo inherent in the local Thematic Environmental
       History (2013), and provide a comparative analysis against properties currently subject to the HO and
       other relevant examples in the local area or elsewhere.

       1.6 Further changes recommended in response to submissions
[11]   I recommend the following changes in response to the submission regarding the Former Bendigo Timber
       Company, 106 Williamson Street Bendigo:

           •     That an additional historic theme—Theme 5.3 Marketing and retailing is added to the list of
                 historic themes associated with the subject site.

           •     That minor revisions are made to the history, comparative analysis and Statement of
                 Significance of the place citation to clarify the importance of the 1959-60 retail storefront in the
                 evolution and diversification of the Bendigo Timber Company’s operations and the place’s
                 historical significance and add further references and qualifications to existing statements.

           •     That the heritage citation is revised to note the changes to the original door joinery to the main
                 entrance.

[12]   A revised citation for Former Bendigo Timber Company, 106 Williamson Street Bendigo is included as
       Appendix A of this evidence.

[13]   No changes other than minor editorial changes are proposed to the place citation for the Bendigo Bowl,
       159 Hargreaves Street, Bendigo.

       1.7 Declaration
[14]   I have made all the inquiries that I believe are desirable and appropriate and no matters of significance
       which I regard as relevant have to my knowledge been withheld from the Panel.

       Signed,

       Dr Kim Roberts

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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Statement of Evidence - Planning Scheme Amendment C235 Bendigo City Centre Heritage Study Stage 1 - City of Greater Bendigo
2 Strategic basis to amendment C235

[15]   The ‘Bendigo City Centre Heritage Study Stage 1’, as revised on 3 April 2020, (the “Bendigo City
       Centre Heritage Study”, “the City Centre Study”, or “the study”) should be taken as the strategic basis
       for Amendment C235. It contains an explanation of the assessment methodology, summarises the
       findings and recommendations of the Study, and contains the heritage citations for places
       recommended for the Greater Bendigo Heritage Overlay.

       3 Methodology of the Study

       3.1 Background
[16]   GML Heritage Victoria Pty Ltd (trading as Context, formerly Context Pty Ltd) prepared the ‘Bendigo
       City Centre Heritage Study Stage 1’ in 2019-20.

[17]   In 2016-17, Context Pty Ltd shortlisted and carried out detailed assessments of a selection of places
       and precincts from an original list of 38 places and four precincts that were identified as potential
       heritage places by Council officers during an extensive fieldwork in 2013. The statement of significance
       for the City Centre Precinct, made up of Bendigo Civic Precinct (HO3) and Rosalind Park Precinct
       (HO10), was also reviewed and revised.

[18]   In 2019, Context was engaged to undertake revisions to the City Centre Heritage Study Stage 1,
       according to the project scope specified in the City of Greater Bendigo project brief dated 11 April 2019.
       The revisions provided an opportunity to review and update the individual place citations prepared in
       2016-17 according to Amendment VC148 and the updated PPN01, 2018.

[19]   Detailed assessments of 18 places were carried out in accordance with PPN01. The list of places
       assessed derives from the earlier version of the study carried out by Context Pty Ltd in 2016-17.

[20]   Context’s project team managed the entire study process, carried out the initial field survey, assessed
       all individual places of potential heritage significance. The Context team for the 2019 revisions to the
       City Centre Heritage Study Stage 1 was led by me, with assistance from heritage consultants Chairim
       Byun and Mark Huntersmith who conducted the research, comparative analysis, assessment using the
       HERCON criteria and wrote the place citations. I provided project direction, provided ongoing input into
       the project and reviewed reports.

[21]   The methodology of the project was divided into two distinct stages with associated tasks. The first
       stage involved a scoping report to confirm the scope of the study. The second stage involved a
       confirmation of the historical research, assessment, and reporting on the place involved in the study.
       These are outlined in the following sections of this report.

       3.2 Scoping report
[22]   The first milestone of the Study was to confirm the number of places with potential heritage values
       (both individual places and precincts) to be assessed, prioritised from the list provided in the Project
       Brief. Previous heritage studies were reviewed as were the contemporary photos of all places supplied
       by the City of Greater Bendigo.

[23]   The scoping report was prepared through a combination of preliminary desktop research and field
       survey work. The recommendations arising from this work were provided in the form of a draft Scoping
       Report submitted to the client, Greater City of Bendigo, in May 2016. Feedback from the client Project
       Manager was subsequently received and incorporated into the next stage of the Study.

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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[24]   A final version of the Scoping Report incorporating client feedback was prepared in May 2016. This
       included preliminary findings and recommendations for the detailed assessments as follows:

       •       A review of the Bendigo Civic Precinct (HO3) citation with a threshold assessment to state
               level.

       •       25 individual places to be assessed for their individual significance.

[25]   These recommendations were reviewed, and minor adjustments made by the client Project Manager.
       An additional place, the Vahland fountain and horse trough was added to the list and preliminary
       research was requested on 173 Hargreaves Street and 159 Hargreaves Street as it was felt that they
       may have individual significance.

       3.3 Assessment and reporting
       3.3.1     Historical context
[26]   A contextual history for Bendigo was prepared, with a particular focus on the city centre area, providing
       an overview of its nineteenth and twentieth-century periods of development of various typologies
       (industrial, commercial, community and residential). Summaries of the full contextual history, as well
       as the excerpts from the relevant sections of the City of Greater Bendigo Thematic Environmental
       History (Thematic Environmental History), are used in the ‘Historical Context’ in place citations to set
       the context for each individually significant place. It was noted that the Thematic Environmental History
       provided a general lack of coverage of the postwar era of Bendigo’s development. As such, thematic
       histories covering the different aspects and phases of development were expanded and drawn on in
       the comparative analysis sections of the citations to provide context for the relevant period or place
       typology.

       3.3.2     Place histories
[27]   Individual histories were prepared for each individual place and the revised City Centre Precinct,
       providing answers to fundamental questions such as when the buildings were built, for whom, by whom
       (builder and designer, if known), and the impact of changes over time (both physically and in use).
       Biographical information on associated persons or organisations was also included where available.

[28]   Researchers mainly drew upon the following primary and secondary sources:

       •       Previous municipal heritage studies and Thematic Environmental Histories (1993-2016);

       •       Local histories;

       •       Goldfields Libraries Historical Rate Search;

       •       Certificates of title;

       •       Rate books;

       •       Parish plans;

       •       Probate and Administration Records (Public Records Office Victoria);

       •       Trove and Newspapers.com newspaper searches;

       •       State Library Victoria online collections of historic maps, plans and photos;

       •       Museum Victoria online collections;

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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•       Victorian Collections online collections; and

       •       Sands & McDougall street directories.

       3.3.3    Field survey and documentation
[29]   The initial field survey for the ‘Bendigo City Centre Heritage Study Stage 1’ was undertaken in April
       and early May 2016. The project team was accompanied by Robyn Ballinger, project historian and Rod
       Duncan, urban planner. The purpose of the large multidisciplinary consultant team was to review the
       places through several different perspectives –a historian familiar with the study area and sources; an
       urban planner with a deep knowledge of Bendigo’s more recent history, and members of the team
       familiar with the built heritage and architecture of Bendigo. Members of the consultant team reviewed
       all places and precincts listed as part of the Project Brief.

[30]   The Context project team carried out further site inspections as part of the revised scope of the City
       Centre Study. In order to identify changes to the fabric since the last visit in May 2016, each individual
       place assessed in 2016-2017 was re-surveyed on 15-16 October 2019, 28 November 2019 and 20
       January 2020. Additional details and new evidence was added to citations where relevant to support
       revised significance assessments and to achieve a higher degree of clarity and accuracy of the
       analysis.

[31]   The properties were only viewed and recorded (in notes and photographs) from the public domain,
       with the exception of 96 Mollison Street, for which a detailed external and internal inspection was
       carried out.

[32]   These site visits informed the subsequent preparation of the description.

[33]   A further site visit was conducted at 106 Williamson and 159 Hargreaves Street, Bendigo in the course
       of preparing this Statement of Evidence.

       3.3.4    Comparative analysis
[34]   Comparative analysis is a critical step in determining if a place or precinct meets the local (or State)
       threshold for heritage significance. The PPN01 advises that:

            … some comparative analysis will be required to substantiate the significance of each place. The
            comparative analysis should draw on other similar places within the study area, including those that
            have previously been included in a heritage register or overlay.

[35]   Comparative analysis is considered particularly important in deciding if a place is of architectural
       significance or of rarity value in a given area but can be applied to most place types to determine their
       relative importance in a locality or wider area.

[36]   In the comparative analysis process, similar places (in terms of built-date, type, and/or architectural
       style) already included in the Greater Bendigo Heritage Overlay were used as ‘benchmarks’ to provide
       a basis for comparison. Potential heritage places were compared according to a range of criteria,
       including how well they represented a historical theme, their architectural design quality, intactness
       and integrity, and rarity.

[37]   Postwar heritage is an expanding area of heritage consideration and there is a relative lack of
       comparative examples of Modernist buildings included in Heritage Overlays outside metropolitan
       Melbourne. In the absence of local examples with existing heritage controls, the comparative analysis
       considers examples of similar postwar places in other local government areas to establish an
       appropriate ‘benchmark’. In rare cases, comparisons have been drawn between places within the study
       area and unnominated places located within the City of Greater Bendigo that do not have existing

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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Heritage Overlays. This was where they provided a direct comparison in terms of their architectural
       provenance, style or type and/or geographic proximity to the subject site.

[38]   When the place under assessment was considered to be an example of equal or better merit than the
       comparative ‘benchmark’ places, it was judged to meet the threshold of local significance and
       considered worthy of inclusion in the City of Greater Bendigo Heritage Overlay.

[39]   Places that were found to be of a lesser merit than the ‘benchmark’ places were not recommended for
       inclusion in the Heritage Overlay.

       3.3.5    Assessment against criteria
[40]   In accordance with the PPN01, heritage places are identified as meeting either the threshold of ‘State
       Significance’ or ‘Local Significance’. Places of local significance can include places that are important
       to a particular community or locality. Some of the places of local significance may also be important to
       the entire City of Greater Bendigo, but this is not essential to meet the local significance threshold.

[41]   The PPN01 advises that assessment of whether a place meets the local or State threshold should be
       determined in relation to model heritage criteria (also known as the HERCON Criteria).

[42]   In the context of these assessments, where the criteria say, ‘our cultural or natural history’, it should
       be understood as ‘Greater Bendigo’s cultural or natural history’.

[43]   For each place, a discussion was prepared for each of the criterion for which they were considered to
       meet the threshold of local significance. In some cases, this discussion concluded that the place did
       not meet the threshold for that criterion within the local context and was thus only of ‘local interest’.

       3.3.6    Statement of significance
[44]   With the introduction of Amendment VC148 to the Victorian Planning Provisions on 31 July 2018, all
       places (individual places and precincts) to be covered by the Heritage Overlay in a planning scheme
       amendment are now required to have a Statement of Significance included in an Incorporated
       Document of the Planning Scheme.

[45]   For each individual place found to meet the threshold of local significance for at least one of the criteria,
       a statement of significance was prepared, summarising the most important facts and the significance
       of the place/precinct.

[46]   Each statement was prepared in accordance with The Burra Charter: The Australia ICOMOS Charter
       for Places of Cultural Significance (rev. 2013); using the HERCON criteria, and applying the thresholds
       of local or State significance. Each assessment is summarised in the format complying with the
       guidance in the PPN01, namely:

            •    What is significant? – This section should be brief, usually no more than one paragraph or a
                 series of dot points. There should be no doubt about the elements of the place that are under
                 discussion. The paragraph should identify features or elements that are significant about the
                 place, for example, house, outbuildings, garden, plantings, ruins, archaeological sites, interiors
                 as a guide to future decision makers. Clarification could also be made of elements that are not
                 significant. This may guide or provide the basis for an incorporated plan which identifies works
                 that may be exempt from the need for a planning permit.

            •    How is it significant? – Using the heritage criteria above, a sentence should be included to the
                 effect that the place is important. This could be because of its historical significance, its rarity, its
                 research potential, its representativeness, its aesthetic significance, its technical significance
                 and/or its associative significance. The sentence should indicate the threshold for which the
                 place is considered important.

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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•      Why is it significant? – The importance of the place needs to be justified against the heritage
                   criteria listed above. A separate point or paragraph should be used for each criterion satisfied.
                   The relevant criterion reference should be inserted in brackets after each point or paragraph, for
                   example “(Criterion G)”.

       3.3.7     Mapping
[47]   The PPN01 states in regard to mapping:

            The Heritage Overlay applies to both the listed heritage item and its associated land. It is usually
            important to include land surrounding a building, structure, tree or feature of importance to ensure that
            any development, including subdivision, does not adversely affect the setting, context or significance
            of the heritage item. The land surrounding the heritage item is known as a ‘curtilage’ and will be
            shown as a polygon on the Heritage Overlay map. In many cases, particularly in urban areas and
            townships, the extent of the curtilage will be the whole of the property (for example, a suburban
            dwelling and its allotment).

            However, there will be occasions where the curtilage and the Heritage Overlay polygon should be
            reduced in size as the land is of no significance. Reducing the curtilage and the polygon will have the
            potential benefit of lessening the number of planning permits that are required with advantages to
            both the landowner and the responsible authority.

[48]   On this basis, there are two types of mapping for the individual places recommended by this study:

       •        Individual places that are to be mapped to the extent of the title boundaries. The majority of the
                individual places in the study were mapped in this way.

       •        Individual places for which a HO is recommended that is less than/different to the extent of the
                title boundaries. In the case of the Bendigo Timber Company, for example, the recommended
                mapped boundaries of the HO are both less than the title boundaries to the southwest of the
                building, but exceed the boundaries along the street frontages of the site in order to incorporate
                the building’s cantilevered verandahs which overhang the public realm footpath.

       3.3.8     Statutory recommendations
[49]   The statutory recommendations for places assessed to be of local significance are made in accordance
       with relevant policies and guidelines set out in PPN01.

[50]   PPN01 describes additional controls that can be included in the Schedule to the HO for a place or
       precinct, including:

       •        External Paint Controls – to control changes to paint colours; particularly important if evidence
                of an early colour scheme survives; note that a planning permit is always required to paint a
                previously unpainted surface (for example, face brick, render, stone, concrete, timber shingles).

       •        Internal Alteration Controls – to be used sparingly and on a selective basis for special interiors
                of high significance.

       •        Tree Controls – to be applied only where a tree (or trees) has been assessed as having heritage
                value, not just amenity value.

       •        Fences and Outbuildings which are not exempt from advertising planning permit applications –
                demolition applications for early fences and/or outbuildings that contribute to the significance of
                a place must be publicly advertised if this control is in place, and the accelerated VicSmart permit
                process cannot be used. (Note that a planning permit is required to alter, demolish or replace a

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
                                                                                                                        7
fence or outbuilding even if this box is not chosen, however public notice of the permit application
              is not required – Clause 43.01-4).

       •      Included on the Victorian Heritage Register – can only be entered by Heritage Victoria.

       •      Prohibited uses may be permitted – this allows additional uses not normally permitted in a given
              zone, subject to a planning permit; it is most frequently used to give redundant buildings a wider
              range of future use options to ensure their long-term survival, for example, purpose-built shops
              in residential areas.

       •      Incorporated Plan has been adopted for the place/precinct – an incorporated plan is sometimes
              prepared to introduce permit exemptions for a precinct or provide specific guidance in managing
              a complex site.

       •      Aboriginal heritage place – note that Aboriginal heritage significance was not assessed as part
              of the Bendigo City Centre Heritage Study Stage 1.

[51]   When making statutory recommendations, recommendations for these additional controls were made
       where appropriate. In cases where Tree Controls or Fence and Outbuilding non-exemptions are
       recommended, the specific elements to be protected have also been indicated for inclusion in the
       Schedule to the HO to provide clear guidance. For example: Tree Controls: Yes – English Oak.

[52]   For the purpose of this evidence and in regard to the two individual properties discussed below, I note
       that no Internal Controls were proposed.

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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4 Response to Submissions

       4.1 Introduction
[53]   This section of the report contains information regarding places where an owner or their representative
       has made a formal submission to Council or will be appearing at the Amendment C235 Panel hearing.
       For each place the heritage-related objections are summarised, and my response is provided.

[54]   In my evidence, I will respond only to issues related to the heritage significance of the places, such as its
       intactness (and condition where this impacts upon intactness), history and comparison to other places. I
       will generally not respond to non-heritage issues, such as maintenance costs, property value or future
       development plans, as it is more appropriate that these considerations are dealt with as part of any specific
       planning permit application for the place.

       4.2 Former Bendigo Timber Company Store at106 Williamson Street,
           Bendigo (Submission 4) — Appearing
       4.2.1    Recommendations and Amendment C235
[55]   This place was assessed as part of the ‘Bendigo City Centre Heritage Study Stage 1’ and found to be of
       local significance. It is recommended for inclusion in the Greater Bendigo Heritage Overlay as an individual
       place. The reasons for its significance are set out below.

       4.2.2    Statement of Significance
[56]   The statement of significance in the citation dated 3 April 2020 reads as follows:

            WHAT IS SIGNIFICANT

            106 Williamson Street, Bendigo, built in 1959-1960 for the Bendigo Timber Company by builders Green
            Brothers, is significant.

            Significant fabric includes the:

            •    original built form and scale of the building, including the low-slung asymmetrical butterfly roof;

            •    expressed structural steel frame;

            •    brick walls;

            •    cantilevered awnings;

            •    the notable glazing pattern which features bays of tilted windows; and

            •    recessed entry with stonework wall.

            HOW IT IS SIGNIFICANT

            106 Williamson Street, Bendigo, is of local historical, representative and aesthetic significance to the City
            of Greater Bendigo.

            WHY IT IS SIGNIFICANT

            106 Williamson Street is historically significant for its association with the Bendigo Timber Company
            which traded from the site between 1921-87. The subject building was purpose built for the company by
            Greens Brothers builders in 1959-60 after a fire destroyed all previous buildings on the site in January
            1959. It was the third premises occupied by the Bendigo Timber Company on this site, with fires
            destroying the earlier two buildings.

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       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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The Bendigo Timber Company was formed as a partnership between Walter G. Hyett and George De
            Araugo with business operations commencing on 19 December 1921. Walter Hyett had been a
            prominent Master Builder in Bendigo, whilst also holding large farming interests in the Mallee region of
            Victoria. Consequently, he was widely known and respected throughout northern Victoria. George De
            Araugo was for many years the manager of Hume and Iser, timber merchants, Bendigo, with extensive
            experience in the timber industry. The combination of these two men laid a solid foundation for a
            business that was to grow into the largest timber, hardware, joinery and paint establishment operating
            outside the metropolitan area. A major part of the Bendigo Timber Company’s operations was the
            manufacturing of kit form houses from the 1930s through until the 1950s under the name of Ready Cut
            Homes, a company that also had branches in Melbourne and Sydney. The company supplied plans,
            timber and a builder for the construction of these homes through a payment scheme. It was engaged in
            the erection of shops, hotels, stores, dwellings and every type of farm building. As the company
            expanded, it ceased construction operations and devoted its efforts to the supply of building materials to
            a rapidly expanding client base of builders and the general public. (Criterion A)

            The former Bendigo Timber Company building built in 1959-60 is a fine example of an intact modernist
            commercial building constructed in the post-World War II era. It demonstrates characteristics of the
            modern architectural idiom developed in the postwar era. Modernist buildings frequently adopted a
            ‘machine aesthetic’ using industrially processed materials such as steel, concrete, glass and
            prefabricated elements. The use of long-span structural frames and lintels meant that buildings no longer
            relied on load-bearing walls and greater areas of glazing were possible. These structural developments
            brought a new freedom to the expression of walls, windows, and roofs as independent design elements
            and a similar freedom to the planning of interior spaces. (Criterion D)

            The former Bendigo Timber Company building is aesthetically significant for its ‘modern’ style where
            structure and function are expressed as part of its aesthetic. Key features include expressed steel
            columns and extensive glazing to its principal elevations, an asymmetrical low-slung butterfly roof and
            clerestory windows. Of particular note are the cantilevered verandahs, lower section tilted windows and
            the entry porch bound by a single steel column and rubble stonework cladding at the Mollison Street
            corner. (Criterion E)

       4.2.3    Heritage Matters for Discussion
[57]   The submitter does not support the inclusion of 106 Williamson Street, Bendigo, as an individually
       significant place in the Heritage Overlay. This section responds to the objection raised in Submission 4,
       focusing on heritage matters only. The key points raised by the submitter are provided in italics beneath
       a series of subheadings below, with my response following each excerpt.

[58]   As part of the submission, a memorandum was provided by Lovell Chen the purpose of which was ‘to
       provide a preliminary review of the conclusions of the Heritage Citation prepared for 106 Williamson Street,
       Bendigo in the ‘Bendigo City Centre Heritage Study Stage 1’. The review was prepared in the context of
       a proposed redevelopment of the site which to date had anticipated the demolition of the subject building.
       The Lovell Chen memorandum has been reviewed in relation to the points of objection raised by the
       submitter.

       Postwar development is not a theme in Bendigo’s Thematic Environmental History

[59]   Although the building does provide some curious design elements, it is noted the Greater Bendigo
       Thematic Environmental History – 2013, which identifies the important distinguishing characteristics of the
       municipality, does not identify post war development, and in particular modernist development, as a major
       theme in Bendigo’s history. As such it is argued that the building does not actually support or enhance the
       heritage character of the city… Post-war development is not explored as a theme in the Greater Bendigo
       Thematic Environmental History, aside from a brief reference to soldier settlement. There is likewise no
       reference to modernist development in the document. This would indicate that development in this period
       has not previously been identified as a major theme in Bendigo’s history, although the historical context

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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provided in the citation suggests that there was a level of commercial development, at least in a
       concentrated area, in this period.

[60]   As noted earlier in sections 3.3.1 and 3.3.4 of this report, I acknowledge that Bendigo’s Thematic
       Environmental History does not cover postwar development in the City of Greater Bendigo. This ‘gap’ was
       identified by Lovell Chen in the report prepared by them to describe and summarise the methodology,
       tasks and outputs of the Thematic Environmental History prepared by them in 2013.

[61]   At this time Lovell Chen identified that ‘Twentieth century buildings, structures and landscapes throughout
       the municipality, including civic residential development represent a ‘gap’ in the collection of heritage
       places with heritage controls.’ They concluded in this regard that the undertaking of future heritage
       studies/’gap’ filling work of Twentieth Century Development was a priority.

[62]   This suggests, and I would agree with this suggestion, that postwar development in the Greater Bendigo
       area is a theme of likely importance within the history of Bendigo, one that requires urgent research and
       assessment.

[63]   It is my opinion that this acknowledged ‘gap’ in the Thematic Environmental History of postwar
       development in Greater Bendigo should not exclude the assessment and inclusion of postwar places in
       the Heritage Overlay. On the contrary, this work should be undertaken as a priority before significant
       heritage places are lost. It is important to note that heritage is not static but evolving; what is considered
       to be of heritage significance changes over time. There has been a marked shift in the appreciation of
       postwar places, buildings and structures in recent times. This has resulted in many municipalities
       undertaking studies that focus on the postwar era. Further, it is not unusual for gap studies to identify
       places of heritage significance that add layers to and expand existing historical understandings of a
       locality. This is where the open nature of the themes established in ‘Victoria’s Framework of Historical
       Themes’, which are expanded upon in local Thematic Environmental Histories, are an aid to assessment.

[64]   Seeking to bridge the identified postwar heritage gap in the Thematic Environmental History, the citation
       for the former Bendigo Timber Company store has incorporated a short locality history which provides an
       overview of the postwar economic boom and the development implications for the central area of Bendigo.
       It is considered that this additional historical information in combination with consideration of the broad
       historic themes identified in ‘Victoria’s Framework of Historical Themes’ and Thematic Environmental
       History, the specific place history and analysis of comparative examples for benchmarking purposes
       provides an adequate basis for the assessment of the subject site.

       Focus of the place history

[65]   It is considered the findings of the 2020 Heritage Study places considerable emphasis on the subject
       buildings [sic] association with the historical use and development of the site for its perceived heritage
       significance rather than the significance of the building itself. With this being the third building constructed
       by the Bendigo Timber Company on the site, it is understood that much of the historically significant
       activities that occurred on the land, in association with the Bendigo Timber Company, actually occurred
       prior to the buildings [sic] construction.

[66]   The Bendigo Timber Company formed in 1921 and was a business that evolved and changed over the
       course of its history until its purchase by Timber Holdings in 1982. Subsequent changes of ownership saw
       the Colonial Sugar Refining (CSR) Company take over the company in 1988 prior to the sale of the
       business in 1989 to BBC Hardware, who were taken over in turn by Bunnings in 2001.

[67]   This is a historical trajectory that was not uncommon for locally owned and operated building supplies
       businesses in Victoria in the twentieth to early twenty-first century. A similar story of business growth,
       diversification, and take-over by a large home hardware chain store is a broad trajectory shared by rival

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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Bendigo building supplies store, Hume and Iser which operated from 35-37 Charleston Place, Bendigo
       from 1880. The Hume and Iser Mitre 10 store still operates from the original Hume and Iser site but, unlike
       the former Bendigo Timber Company store, no built fabric associated with the historic operations of the
       Hume and Iser business remain.

[68]   As detailed in the place history of the citation for the former Bendigo Timber Company store, the company
       was first involved in the construction of buildings before refocusing its operations towards the supply of
       building materials to a client base that included the building industry and the general public. On 14 March
       1931 a fire destroyed Bendigo Timber Company stores and mills, but the business was quickly re-
       established on the same site and continued to expand. Part of this business expansion included the
       manufacture and sale of kit homes. This commenced in 1931, the year of the fire, and continued to the
       early 1950s. It is unknown if the fire was catalyst in this diversification of operations, however the need to
       rebuild the company’s premises may have facilitated this change in the scope of the business.

[69]   A second fire on 25 January 1959 once again destroyed the Bendigo Timber Company premises,
       destroying the yard, offices and stock. Once again, the business was quickly re-established. Two buildings
       were erected: a building at 113-133 Mollison Street which housed joinery manufacturing operations and
       offices, and the subject building at 106 Williamson Street which was a new showroom and sales area.
       This second building, with its distinctive glazed shopfronts to two streets, evidences the importance and
       scale of the retail focus of the Bendigo Timber Company at this time. In their memorandum, Lovell Chen
       notes that the citation for the subject site emphasises the historical importance of the Bendigo Timber
       Company producing kit homes but that the subject building ‘appears to have been used as a traditional
       hardware shop and its 1959-60 construction date was after the kit home aspect of the business had
       ceased’. They conclude that the building does not have a strong/close association with the production of
       kit homes and therefore question the ascribed historical significance of the company, despite concurring
       that the Bendigo Timber Company ‘was a long running and successful business in the Bendigo context’.

[70]   The existing citation documents a history of the site and of the Bendigo Timber Company that is one of
       growth, diversification, and evolution of which the kit homes arm of the business was only part. However,
       review of the place citation in light of Lovell Chen’s peer review leads me to acknowledge that the
       additional historical detail supplied regarding the kit home phase of the business, and lack of a key
       historical theme connection with the place, may distract from the core historic significance of the subject
       site. This historic significance is connected with the Bendigo Timber Company’s broad-based historic
       occupation of the broader Williamson/Mollison Street site and the remnant building’s association with the
       company’s service to the community and demonstration of aspects of the Thematic Environmental
       History’s historic theme 5.0 Building Greater Bendigo’s industry and workforce.

[71]   Specifically, the place is associated with themes: ‘5.1 Processing raw materials’ and ‘5.2 Developing a
       manufacturing capacity’ connected with the Bendigo Timber Company’s historical operations on the site
       in the areas of construction, timber milling and manufacturing. However, through the physical fabric of its
       built form it directly demonstrates or evidences historic theme 5.3 Marketing and retailing in which the
       Bendigo Timber company developed into a major timber and building supplies provider to both the building
       industry and the general public over the long course of its occupation of this prominent site in the central
       area of the city of Bendigo.

[72]   My review of the place citation in response to the submission regarding this subject site leads me to
       recommend that historic theme 5.3 Marketing and manufacturing should be added to the list of applicable
       historic themes associated with the subject site within the citation. It is also recommended that some minor
       revisions are made to the history and Statement of the Significance of the place citation to clarify and
       reinforce the historic significance of the place that is currently encapsulated the existing concluding
       sentence of the Criterion A assessment:

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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As the company expanded, it ceased construction operations and devoted its efforts to the
                supply of building materials to a rapidly expanding client base of builders and the general public.

       Historical significance (Criterion A)

[73]   On the basis of this limited assessment the degree to which the subject site and building can be ascribed
       significance as satisfying historical value at a local level is potentially not met. In many respects the history
       of the site is likely to be one which is repeated for many such places, many of which would not be ascribed
       heritage significance as a result. There is nothing which has been identified beyond the fact that the site
       is associated with a long-term successful business which elevates the place above others.

[74]   While PPN01 does not incorporate clear guidelines for the assessment of Criterion A within the local
       context it is accepted practice to defer to the guidelines for the heritage assessment criteria provided in
       ‘The Victorian Heritage Register Criteria and Threshold Guidelines’ (Heritage Victoria, reviewed and
       updated 3 December 2020).

[75]   These guidelines indicate that order to satisfy Criterion A:

           •    The place/object has a CLEAR ASSOCIATION with an event, phase, period, process, function,
                movement, custom or way of life in Victoria’s cultural history.

           •    The association of the place/object the event, phase etc IS EVIDENT in the physical fabric of
                the place/object and/or documentary resources or oral history.

           •    The EVENT, PHASE etc is of HISTORICAL importance, having made a strong or influential
                contribution to Victoria.

[76]   The use of these tests within the local context would see Victoria/Victoria’s replaced with Greater Bendigo.

[77]   The subject building at 106 Williamson Street readily satisfies the first of these tests. It has a clear and
       undisputed association with the operations of the Bendigo Timber Company, being built as business’s
       new purpose-built showroom and sales building for the company in 1959-60. The Bendigo Timber
       Company was one of only a handful of timber and building supplies merchants operating in the region
       from the 1920s. They were second only to Hume and Iser as the longest running business of their type in
       the district and were recognised as one of the major timber suppliers in Northern Victoria when the
       business was sold in 1988. That both the former Bendigo Timber Company and Hume and Iser were taken
       over by two of the major home hardware chain stores (Bunnings and Mitre 10 respectively), is testimony
       to the scale, reach and standing of these formerly locally owned and operated businesses.

[78]   The second test is satisfied insofar as the distinctive built fabric of the former showroom and sales building
       at 106 Williamson Street provides ample evidence of the importance the company ultimately grew to place
       on its retail presence within the central area of the City of Bendigo as a mature business. This is shown
       in the considerable scale of the building and its large expanses of glazing along both street frontages that
       create display windows to showcase the businesses products to its clients in both the building industry
       and the general public.

[79]   The third test is satisfied due to the nature of the Bendigo Timber Company as a major local and regional
       supplier of timber and building materials. As a construction and manufacturing company turned supplier,
       the Bendigo Timber Company, had the opportunity to make a significant contribution to the development
       and growth of Bendigo during the interwar and postwar periods. This contribution would have been
       realised though the company’s operations in the areas of construction, timber milling, and kit home
       manufacturing and sales but ultimately extended into the increasing marketing and retail focus of the
       business as a key supplier of building materials to industry and the general public within the region. This

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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sizable company would have also contributed to the community though its provision of employment
       opportunities and through its contributions to the local economy.

[80]   Further historical research undertaken in the course of preparing this evidence indicates that the Bendigo
       Timber Company was one of a small number of timber merchants operating in the region from the 1920s.
       It become the second longest running business of its type in the district and was recognised as one of the
       major timber suppliers in Northern Victoria at the time that the business was sold in 1988.1 Local Bendigo
       historian, Mike Butcher, has an interest in the activities of the Bendigo Building Company and believes
       that together with Hume & Iser the business made an important contribution to the city’s infrastructure.2

[81]   Accordingly, it is my opinion that the former Bendigo Timber Company showroom and sales building is of
       historical significance in Bendigo and that the subject building satisfies Criterion A.

       Representative Significance (Criterion D)

[82]   In a Bendigo context 106 Williamson street presents as a place which pursues Modernist design ideas in
       a place specific context rather than as one of a distinct class of places. As noted in the citation there are
       few comparable places within Bendigo which evidence like Modernist design ideas and those which are
       noted are similarly discrete events and not readily comparable. As such 106 Williamson Street does not
       present as a place which is important in demonstrating the principal characteristics of a class of cultural
       places which is important in a Bendigo context.

[83]   With reference again to ‘The Victorian Heritage Register Criteria and Threshold Guidelines’ (2020), in
       assessing if a place satisfies Criterion D it is important to demonstrate that the subject place exhibits the
       principal characteristic of a particular class of cultural place. These characteristics are the major features,
       qualities or attributes that define that class of place. A class of cultural place generally refers to a sub-
       category of a broader place type. In the instance of the subject building at 106 Williamson Street the
       broader place type is the commercial building typology with the class being Modernist architectural design
       built in the post-World War II era. That Bendigo does not have many surviving examples of this particular
       class of building does not preclude the acknowledgment of the building as an exemplar of postwar
       Modernist design as applied to a commercial building and as a previously underappreciated layer of the
       city’s historic development.

[84]   Key characteristics of the Modern architectural idiom developed in the postwar era include the use of steel,
       concrete, glass and prefabricated elements. The use of long-span structural frames and lintels meant that
       buildings no longer relied on load-bearing walls and greater areas of glazing were possible. These
       structural developments brought a new freedom to the expression of walls, windows, and roofs as
       independent design elements and a similar freedom to the planning of interior spaces. 106 Williamson
       Street demonstrates these principal characteristics of this class of buildings. As Lovell Chen acknowledge
       elsewhere in memorandum, the building ‘presents as an assembly of elements common to Modernist
       design thinking.’

[85]   A place might satisfy Criterion D by demonstrating the attributes of its type and yet be an uncommon
       example of its class, and therefore rare. The fact that there are few comparable places within Bendigo
       does not exclude the place from satisfying Criterion D. Uncommonness does not exclude a place from
       demonstrating the principal characteristics of the class. It is my opinion that 106 Williamson Street,
       Bendigo demonstrates the key characteristics of postwar Modernist architecture as applied to a

       1
        Age 10 August 1988:63.
       2
        Bendigo Advertiser 28 February 2016, accessed online on 3 March 2021 via
       https://www.bendigoadvertiser.com.au/story/3756557/search-for-historic-houses/.

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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commercial building. These characteristics remain evident in the built fabric as the building is of high
       intactness and integrity. As such, Criterion D is satisfied.

       Aesthetic significance (Criterion E)

[86]   From an aesthetic perspective the building presents as an assembly of elements common to Modernist
       design thinking. These are primarily associated with the two street facades and roof form, rather than
       extending into the interior, which in many respects is simply a large open plan retail space. While
       potentially architect designed, the composition does not present as one which is strongly directional in its
       approach.

[87]   I agree with Lovell Chen’s assessment that the subject building is an assembly of elements frequently
       used in postwar Modernist architecture. I am unclear, however, as to what is inferred by the statement
       regarding the lack of directionality of the built form composition.

[88]   It is my opinion that the compositional qualities of the building are packaged with a reasonable degree of
       skill. The typography of the site and the functional requirements of the building have been navigated and
       compositionally expressed in a coherent if not entirely streamlined manner. The buildings aesthetic
       cohesion is evident in asymmetrical low-slung butterfly roof, dynamic, tilted fenestration, expressed steel
       structural frame, stepped cantilevered verandahs and inset corner porch. The structural steel frame
       enables the interior of the building to be used as a large open plan retail space. While this structural
       system is a function of the building envelope and related to the Modernist design principles at play it is
       noted that interior controls as such are not proposed.

[89]   I note that Lovell Chen do not dispute that the building potentially satisfies the requirements for Criterion
       E:

            As noted in the citation, elements which distinguish the place include the asymmetrical butterfly roof form,
            a well-accepted feature of Modernist design, particularly in the 1950s, the window system with its slanted
            glazing and the awning verandah roof arrangement. In all cases the delivery is not particularly refined
            and while of visual interest is less successful than the Former Beaurepaire Motor Garage, 404-406
            Hargreaves Street, but comparable to the Bendigo Bowls, 159 Hargreaves Street.

[90]   Lovell Chen assert that the design ‘delivery is not particularly refined’ (p.5), however then go on to note
       that ‘the subject building (lightweight, structurally ambitious with large expanses of glazing, novel window
       treatments etc) borrows from ‘important 1950s Melbourne buildings (even Boyd and McIntyre buildings)
       and it generally seeks to sit within this group …’.

[91]   I acknowledge that the building does not have the same level of design sophistication of comparative
       examples listed for State significance. This includes the former Beaurepaire Motor Garage, 404-406
       Hargreaves Street, Bendigo, referenced in our comparative analysis. I do however maintain that the
       building presents a more sophisticated architectural scheme than that of the Bendigo Bowl, 159
       Hargreaves Street, Bendigo, which is not assessed to meet Criterion E.

[92]   It is my opinion that the former Bendigo Timber Company showroom and sales building satisfies Criterion
       E as a place of aesthetic (architectural) significance at a local level.

       Integrity of the place

[93]   Regarding integrity, the principal facade appears to be more-or-less intact with all windows in place. Some
       alteration has taken place at the primary entry. Original door joinery to the main doorway through the
       portico has been replaced, however, original door joinery survives at a second point of entry along the
       Williamson Street frontage. Overpainting of the façade brickwork has diminished an understanding of the
       materiality of the building.

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
                                                                                                                           15
[94]   In the citation the overpainting of the brickwork is noted. This is a reversible change and I maintain the
       opinion that this does not overly impinge on an understanding of the building’s original materiality or its
       overall integrity. I note the changes to the original door joinery to the main entrance and consider it
       appropriate to add these changes to the description and integrity sections of the citation.

       Proposed curtilage

[95]   In satisfying Criterion E the elements of direct relevance to that criterion are the Williamson and Mollison
       street’s facades and a depth of the butterfly roof facade behind Mollison Street sufficient to understand
       the form. The remaining area of the building is of little or no significance.

[96]   As noted earlier in this report, PPN01 Applying the Heritage Overlay states that:

            It is usually important to include land surrounding a building, structure, tree or feature of importance to
            ensure that any development, including subdivision, does not adversely affect the setting, context or
            significance of the heritage item. … However, there will be occasions where the curtilage and the
            Heritage Overlay polygon should be reduced in size as the land is of no significance.

[97]   In this instance it is my opinion that the extent of the curtilage for the place be the footprint of the building
       including the depth of the verandahs which extend over the footpath area into the road reserve
       approximately 3 meters beyond property boundary (approximately 36 meters along Williamson Street and
       27 meters along Mollison Street). The verandahs of the former Bendigo Timber company building are an
       integral component of the building’s design and any reduction of this curtilage could result in partial
       demolition of the building. This would have a detrimental impact of the aesthetic significance of the place
       and its representative significance as an exemplar of postwar Modernist architectural design as applied
       to a commercial building.

       Potential development options

[98]   Potential development options for the site are discussed as a series of options in the conclusion of the
       Lovell Chen memorandum. The concluding remarks regarding the options tabled are as follows:

[99]   The design of the building is not one which readily lends itself to partial retention, nor, in this case is this
       necessarily a desirable heritage or design outcome. As such the last of these options is one which might
       seriously be entertained in delivering a preferred whole is site development outcome.

[100] In our evidence, we respond only to issues related to the heritage significance of the places, such as its
       intactness (and condition where this impacts upon intactness), history and comparison to other places.
       We will generally not respond to non-heritage issues, such as maintenance costs, property value or future
       development plans/options, as these are properly dealt with at the planning permit stage. However, it is
       noted that the proposed restriction of the Heritage Overlay curtilage to the built form rather than property
       boundary does provide for development of that significant portion of the site without the constraints
       associated with a Heritage Overlay.

       4.2.4    Conclusion and Recommendations
[101] It is my opinion that:

       •       106 Williamson Street Bendigo is of local significance (individual place) to the City of Greater
               Bendigo as it satisfies the threshold for Criterion A, Criterion D and Criterion E.

       •       That an additional historic theme—Theme 5.3 Marketing and retailing is added to the list of
               historic themes associated with the subject site.

       •       That minor revisions are made to the history, comparative and Statement of Significance of the
               place citation to clarify the importance of the 1959-60 retail storefront in the evolution and

       Statement of Evidence and Report to Planning Panel
       Planning Scheme Amendment C235 - Bendigo City Centre Heritage Study Stage 1—March 2020
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