Heritage Impact Statement

St Kilda Road Heritage Statement Domain Station Precinct.

It should be noted that the conclusion of this impact statement states that it is for the early works only.
The major concern for those affected is MMRA are proceeding as though heritage concerns do not matter.

It also does not cover the South African Soldiers War Memorial.

We recommend reading the whole document that can be found at the MMRA website.

This is quite a large PDF document running to over 60 pages.
Reproduced below is the main impact section the document.

VHR: H2359
Prepared for
Melbourne Metro Rail Authority

5.0 Assessment of heritage impact
5.1 Heritage considerations
5.1.1 Heritage Act 1995
Under s.73 (1) of the Heritage Act 1995 in determining an application for a permit the Executive Director
must consider (amongst other considerations):
• s.73 (1) (a) the extent to which the application, if approved, would affect the cultural heritage
significance of the registered place or registered object
Under s.73(1A) of the Heritage Act 1995 in determining an application for a permit the Executive
Director may consider:
• s.73 (1A) (a) the extent to which the application, if approved, would affect the cultural heritage
significance of any adjacent or neighbouring property that is—
(i) subject to a heritage requirement or control in the relevant planning scheme; or
(ii) included on the Heritage Register
The impact of the proposal on the cultural heritage significance of St Kilda Road and any adjacent
heritage places is assessed at 5.2 below.
5.1.2 VHR documentation
The key considerations in assessing the heritage impacts of the work are the heritage values of the place
as set out in the VHR statement of significance (refer section 2.1).
Consideration has also been given to the VHR permit policy, which reads as follows:
The purpose of the Permit Policy is to assist when considering or making decisions
regarding works to a registered place. It is recommended that any proposed works
be discussed with an officer of Heritage Victoria prior to making a permit
application. Discussing proposed works will assist in answering questions the owner
may have and aid any decisions regarding works to the place.
The extent of registration of St Kilda Road in the Victorian Heritage Register
affects the whole place shown on Diagram 2359 including the land, all buildings,
roads, trees, landscape elements and other features. Under the Heritage Act 1995
a person must not remove of demolish, damage or despoil, develop or alter or
excavate, relocate or disturb the position of any part of a registered place or object
without approval. It is acknowledged, however, that alterations and other works
may be required to keep places and objects in good repair and adapt them for use
into the future.
If a person wishes to undertake works or activities in relation to a registered place
or registered object, they must apply to the Executive Director, Heritage Victoria
for a permit. The purpose of a permit is to enable appropriate change to a place
and to effectively manage adverse impacts on the cultural heritage significance of a
place as a consequence of change. If an owner is uncertain whether a heritage
permit is required, it is recommended that Heritage Victoria be contacted.
Permits are required for anything which alters the place or object, unless a permit
exemption is granted. Permit exemptions usually cover routine maintenance and
upkeep issues faced by owners as well as minor works or works to the elements of
the place or object that are not significant. They may include appropriate works
that are specified in a conservation management plan. Permit exemptions can be
granted at the time of registration (under s.42 of the Heritage Act) or after
registration (under s.66 of the Heritage Act).
Conservation management plans
It is recommended that a Conservation Management Plan is developed to manage
the place in a manner which respects its cultural heritage significance.
Other approvals
Please be aware that approval from other authorities (such as local government)
may be required to undertake works.
Ground disturbance may affect the significance of the place and, subject to the
exemptions stated in this documents, requires a permit.
Cultural heritage significance
Overview of significance
St Kilda Road is historically significant as one of Melbourne’s longest and grandest
major thoroughfares. For over a century this European-style boulevard has had an
iconic status as the southern gateway to the city. Dating from the 1850s St Kilda
Road was developed into a magnificent tree-lined boulevard during the late
nineteenth century. Its significance is evident across the width of the full carriage
way including the grassed medians, kerbing, bluestone kerbs and channels,
footpaths and consistent tree plantings. It is of aesthetic significance as a place of
beauty and a visually outstanding elements in Melbourne’s urban landscape. The
sweeping views between the Shrine of Remembrance, St Kilda Road, and Swanston
Street are significant for the emphasis on St Kilda Road as a processional route
between the Shrine and the city. There are also important visual associations with
the Queen Victoria Garden and Domain Parklands and Alexandra Gardens to the
The VHR documentation includes a suite of permit exemptions (refer to Appendix D), addressing routine
maintenance and other relatively minor works to the registered place to allow for ongoing operation
and functional requirements.
5.2 Assessment of heritage impact
The VHR statement of significance confirms that St Kilda Road is of historical and aesthetic significance
to the State of Victoria. In summary, these values relate to the early date of establishment, its evolution
into a ‘magnificent tree-lined boulevard’ in the European style, its role in ceremonial and celebratory
processions (both historically and ongoing), and the visual relationship with the Shrine of Remembrance.
In this context, the values attach to the whole of the place, and individual components, such as
bluestone/other kerb and channel, trees and roadway layout, contribute to its significance, overall
character and presentation.
The heritage impacts associated with the early works for the Metro Tunnel arise through the removal of
contributory elements and qualities within the heritage place, including trees and medians, albeit these
impacts will be mitigated over time through reinstatement works to follow.
The historical associations of the place will be unaffected as a result of the proposed works and will
remain. These associations are well documented and widely understood. There will be an impact on the
aesthetic qualities of the boulevard in the affected section of St Kilda Road. This is as a result of the
removal of up to 103 predominantly mature and over-mature trees and associated medians.

Looking in more detail at the trees to be removed, with the exception of Tree DK025, a Grey Poplar, the
103 trees are Elms located on the outside of the double avenue configuration, and London Planes
located in central medians separating inner and outer running lanes on both sides of St Kilda Road.
The trees proposed to be removed include:
 Mature and over-mature Elms, which date from the original, late nineteenth century avenue
planting, with a number of juvenile and semi-mature specimens planted in recent decades as
replacements of original avenue trees,
 c. 1960 London Planes, which were planted as replacement of the original inner avenue which
predominantly consisted of Poplars. A number of smaller juvenile and semi-mature Planes are
located within the central avenue, representative of replacement and infill plantings
undertaken in recent years,
 One Grey Poplar (DK025) of which the origin is not clear, though the size of the tree suggests it
dates at least from the mid-twentieth century.
A number of other Grey Poplars located in this section of St Kilda Road have been recently replaced with
Elms by the City of Melbourne.
There is some variation in the ULE of the trees, primarily a consequence of the much later planting date
of the London Planes in the central avenue, which have generally longer assessed life expectancies.
Overall, of the trees to be removed:
 34 have an assessed ULE of up to 10 years;
 24 trees have a ULE of between 11-20 years; and
 45 trees have a ULE of in excess of 20 years.
The proposed early works along St Kilda Road will result in the removal of 103 trees from an
approximately 770 metres length of St Kilda Road from south of Dorcas Street in the north, to the
Toorak Road West intersection in the south. Whilst some trees will remain within this precinct, the
greater majority of trees will be removed as part of this early works phase, resulting in a significant
impact to the aesthetic qualities of the place in this location. The works will be transformative in the
construction phase of the Metro Tunnel, and for a period of time the heritage qualities of this section of
St Kilda Road will not be evident in the fabric that is present. The impact clearly is significant in the short
The short-term heritage impact can be mitigated over time through the longer-term vision for the
restoration of the boulevard layout and planting and tree canopy to the affected section of St Kilda
Road. In this context, the impact to the aesthetic qualities of the place can be considered to be a
temporary one, with the replacement of trees proposed as part of delivery of the Metro Tunnel project.
Some changes will be required to the final road functional layout, however a double avenue
configuration of regularly spaced Elms and Planes along St Kilda Road will be reinstated to the greatest
extent possible in the context of the finalised functional road layout. The replacement trees will also be
planted in improved tree plots with better quality soils and water sensitive urban design, this ensuring
their improved vigour and longer life, further mitigating the impact on the heritage significance of St
Kilda Road.
In considering the impact in this location, it is noted that the works for the Metro Tunnel are proposed
either side of an existing gap within the St Kilda Road avenue layout as a result of the Domain
Interchange. Further to the south, the removal of trees in the bend of St Kilda Road limits the visual
impact in longer views of St Kilda Road. The impact will be most evident within the immediate area. St
Kilda Road at Domain and Albert roads also has an open quality deriving from existing infrastructure and
the layout of the intersection itself.
It its recognised that it will take time for the new trees to deliver the aesthetic qualities of mature
plantings in the boulevard presentation of St Kilda Road. Equally, change is inevitable in the
management of formal heritage landscapes including boulevard plantings and commemorative avenues,
where these are living places which require active management through tree replacement programs.
Many of the trees to be removed are approaching the end of their ULE. While not suggesting the works
are related to a specific replacement program, equally, the impact is similar where the change can be
mitigated through tree replanting.
In addition to the reinstatement of trees, the heritage character and presentational quality of the
reinstated roadway will be further referenced through re-use of salvaged bluestone and kerbing where
possible. Although bluestone is the dominant material used for kerb and channel in St Kilda Road, the
section of roadway proposed for occupation by the construction area also includes concrete kerb and
gutter and modern bluestone insertions. It is evident that the much of the bluestone fabric has been
relocated as is expected in an evolving roadway. This section of the road has undergone significant
change over the life of the road, including the establishment of medians, the introduction of the Domain
Interchange and associated modification of roadway infrastructure. The range of materials included in
the kerbs and channels are shown in the images included in the description (Figure 10 to Figure 17). The
existing bluestone will be stored and reinstated as part of the final layout of St Kilda Road at the
conclusion of construction of the Metro Tunnel. It is noted that it is not intended to record the existing
location of the bluestone and reinstate to match existing conditions. The final road layout will be
different from the existing conditions and an exact reinstatement will not be possible. The majority of
the existing bluestone is not in its original location and the heritage significance of the bluestone is
related to the overall character of the road, rather than specific elements bluestone.
In relation to the proposed modifications of tram infrastructure, St Kilda Road has accommodated trams
and their associated infrastructure since the late nineteenth century and the removal of modern
tramway infrastructure and the construction of new stops will not have a heritage impact in and of
itself. The new tram stops will require the removal of contributory heritage fabric, however the new
infrastructure itself will not result in any impact on the assessed significance of St Kilda Road. Tramway
infrastructure is an acknowledged part of the character and function of St Kilda Road and the proposed
tramway works reflect this.
5.2.1 Compliance with Environmental Performance Requirements
While the detail of the proposed reinstatement of St Kilda Road is subject to detailed design and future
applications under the Heritage Act, it is also relevant to note there are stringent requirements on
project delivery, which will ensure an appropriate and high quality outcome.
Specifically, impacts to the heritage place will be required to be mitigated consistent with specific EPRs
(Version 4.0) for the project. Compliance with the project EPRs will ensure works are undertaken in a
manner which limits tree removals as far as is possible, that ensures retained trees are protected and
that appropriate conditions are provided for future tree reinstatement. In referencing the draft EPRs, it
is recognised that these are subject to IAC review and review by the Minister for Planning as part of the
EES process and the final form of the EPRs is not confirmed.
AR1: During detailed design, review potential tree impacts and provide for maximum tree retention on
both public and private land, also having regard to valuable habitat linkages or corridors where
It is acknowledged that trees will require removal due to the nature of the proposed works at ground
level and the proposed construction methodology. Up to 103 trees are proposed for removal as part of
early works. MMRA is committed to retaining as many trees as possible during the project and will
continue to review opportunities to maximise tree retention through detailed design.
Subject to detailed design, a small number of additional trees may require removal during the main
works construction phase. Any required further tree removals would be the subject of separate permit
AR2: Reinstate quality soils to sufficient volumes to support long-term viable growth of replacement
trees. Ensure ongoing supply of water to tree root zones, especially during their establishment stage.
Employ water sensitive urban design principles (WSUD) principles where possible
Use of irrigation and water sensitive urban design, including specification of high quality replacement
soils, will ensure trees are provided superior growing conditions to secure long-term future amenity. It is
noted that this will be the subject of future heritage permit applications.
AR3: Re-establish trees to replace loss of canopy cover and achieve canopy size equal to (or greater than)
healthy, mature examples of the species in Melbourne. Consult with the City of Melbourne, the City of
Port Phillip and Heritage Victoria as applicable. Policy documents that should be referenced to reestablish
trees and valued landscape character include: (as relevant to St Kilda Road)
 The City of Melbourne’s Tree Retention and removal Policy 2012 (excluding sections 8.2 and 8.3)
and Urban Forest Strategy, South Yarra Urban Forest Precinct Plan, Central City Urban Forest
Precinct Plan, Carlton Urban Forest Precinct Plan and Kensington Urban forest Precinct Plan
 The City of Port Phillip’s Community Amenity Local Law No.1 and Greening Port Phillip – An
Urban Forest Approach
The re-establishment of trees must also consider the contribution to creation of habitat corridors and
linkages where possible.
Removed trees will be replaced with super-advanced stock (1000 litre containers or larger with a likely
height in the order of six metres) as quickly as practical during phased works rather than at the end of
the Project. This will allow for trees to establish and be managed whilst other works are completed. It is
anticipated that by the time of project delivery, many replacement trees will have established and will
be actively growing, rather than installed at final stages as is often the case with construction projects.
AR4: Prior to construction commencing of main works or shafts in affected areas, prepare and
implement Tree Protection Plans for each Precinct in accordance with AS4970-2009 Protection of Trees
on Development Sites, addressing the detailed design and construction methodology of the project.
This will provide a high degree of certainty that trees within St Kilda Road peripheral to works and
proposed to be retained will be adequately managed and protected.
CH3: Prior to construction, undertake archival photographic recording in accordance with Heritage
Victoria specification for the archival photographic recording of heritage places and objects where places
are to be demolished or modified
A photographic record of the existing site conditions will be undertaken consistent with EPR CH3.
As discussed at 5.2, it is noted that much of the bluestone fabric has been relocated as part of the
evolving roadway configuration. More detail documentation of existing fabric is not considered to be
necessary in this instance and a photographic record of the general arrangements of this part of St Kilda
Road will be sufficient to meet the requirements of the EPR.
CH20: In consultation with VicRoads, Heritage Victoria, and/or relevant local councils replaced removed
trees in St Kilda Road to re-establish the boulevard formation.
By replacing trees with super-advanced stock (1000 litre containers or larger with a likely height in the
order of six metres) as quickly as practical during phased works, rather than replanting all trees at the
end of the project timeframe, will allow for replacement across precincts to establish and be managed
whilst other works are completed in different areas. The overall objective is to re-establish the
boulevard formation of trees, a key element of the significance of the place.
CH22: Ensure that, where impacted by project works, street fabric and infrastructure is conserved and/or
accurately reconstructed.

As discussed at 5.2, it is noted that much of the bluestone fabric has been relocated as part of the
evolving roadway configuration and there is no imperative to document and reinstate bluestone
elements as existing. The full reconstruction of the existing roadway layout is not proposed, rather, it is
anticipated that salvaged materials, such as bluestone kerb and channel, will be incorporated into the
future road functional layout.

5.2.2 Technical Note 40
In addition to the EPRs developed for the EES, it is relevant to note that MMRA Technical Note 40 has
been prepared in response to additional information requested by the IAC. As well as general advice on
arboricultural matters across the project area, MMRA has stated that, where appropriate, super
advanced tree replacement stock can be utilised to mitigate against loss of amenity (MMRA response
No. 8). Super advanced trees are trees supplied in 1000 litre containers or larger, with a likely height in
the order of 6 metres.
Further information can be found at:
5.2.3 Adjacent heritage places
It is noted that there are a number of heritage places located adjacent to, or in the vicinity of, the
proposed works. Of those places which are adjacent to the proposed works, including the Shrine
Reserve, Melbourne Grammar School and the former Kellow Falkiner showrooms, there will be no
associated heritage impact. While it will alter the context of these places, the removal of trees in St Kilda
Road itself will not have an adverse impact on their significance. Nor will the introduction of new
infrastructure within St Kilda Road (related to trams) have an adverse visual impact. The new tram stop
at Park Street will be located to the west of the Shrine Reserve, however this is similar to the existing
condition of the Domain Interchange, with the new stop further to the north. There will be no impact on
the appreciation of the Shrine Reserve as a result of this proposal. The Domain Parklands and the Tram
Shelter are located well outside of the proposed construction site area.
Works to the South African Soldiers Memorial (VHR H1374), associated with the preparation works for
the establishment of a construction site at the location of the proposed Domain station will be subject
to a separate permit application under the Heritage Act 1995.
6.0 Conclusion
The approach taken to the design for early works is one where the road functional design, tram layout
and services works have been designed to minimise tree removal and associated impacts on the
heritage values, presentation and character of St Kilda Road. The area contemplated for construction
purposes in the EES has been reduced through a process of review and refinement and this process will
be ongoing through the detailed design phases of the project. As identified in this HIS, there is a
commitment to retaining as many trees as possible during the project and opportunities to maximise
tree retention through detailed design in accordance with EPR AR1 will be pursued.
In considering the impacts on the registered heritage place associated with early works, the proposed
works are confined to a limited extent of St Kilda Road and there will not be an impact on the overall
presentation of the greater length of St Kilda Road. St Kilda Road will continue to read as a boulevard for
the majority of its length and in time replanting will restore the aesthetic qualities associated with the
loss of trees and associated canopy in the affected section.

Future reinstatement works will be undertaken consistent with Heritage Victoria’s requirements and the
project EPRs, which are focussed on the restoration of the treed character of the roadway as part of the
overall design for permanent infrastructure in this location.
The loss of substantial numbers of mature trees in a concentrated area is challenging and there will be
an adverse impact on the aesthetic qualities of the place in this location as a result. Accepting this, the
impact will be mitigated over time by the future works including the reinstatement of removed trees
with super-advanced specimens of like species. Improved growing conditions for replacement trees are
a component of the replacement regime and this will ensure the long-term viability of the boulevard
planting and the restoration of the valued aesthetic qualities. A key focus for future replacement works
is one where the traditional character of the place is reinforced and future works will include the use of
like materials for the kerb and channel arrangement to ensure a consistency in presentation. Where
feasible, it is proposed that the future work will involve the re-use of stored bluestone.
Permanent and temporary tram stops and associated infrastructure are typical of the existing environs
of St Kilda Road and will not detract from the significance of the place.
Other changes associated with the project including new station infrastructure (entries, vents and the
like) are subject to future permit application/s under the Heritage Act.

In conclusion, considering the extent of works and their location within the registered place, and the
mitigation measures proposed, the impact of early works for the Metro Tunnel is one that can be
accommodated with no significant long-term impact on the heritage values of St Kilda Road as a whole.