AHAA Analysis & Solutions

Prior to the establishment of AHAA, the need for a review of the current situation and policy environment for our national heritage assets became clear to most heritage stakeholders – organisations, special interest groups and individuals

Burnie Paper Mill (Thomas Ryan Photography)


The toll of lost heritage is mounting. Heritage funding seems to be diminishing, competition ever more intense, and the detrimental impact of the current federal heritage asset policy approach became self-evident. How could it be that the Minister for Agriculture, Water and the Environment had responsibility for Heritage? Where is the federal focus on Heritage? No surprise then, that  the media reports and reputational damage of irreplaceable Indigenous heritage sites are being destroyed, and the scheduled review of the Australian National Heritage Strategy was again postponed until after the 2022 election. Nothing to see here?


The AHAA analysis and campaign is based upon four key propositions:

 1. Australia’s Heritage Assets are shared by all

Australia’s heritage assets hold meaning for all citizens, regardless of state and territory, borders and legislation. If we accept that heritage assets are shared by us all, then the legislative separation between ‘owners’ or responsible authorities in relation to heritage assets is counter-productive, ie. responsibility should not span three levels of government and private ownership. Inconsistencies result. Similarly, inconsistencies, confusion, often poor management of heritage asset arise with the counter-productive demarcation between heritage assets found on land, and those found on, above or below the water. Consequently, there is duplication and competition in bureaucracies, uneven access to financial support, and inequitable distribution of heritage expertise. Across Australia, heritage assets remain in jeopardy and the threat of loss is heightened.

2. A National Approach to Heritage Assets is required

Australia is without effective Heritage policy or oversight in relation to identification and protection our shared heritage assets. The current devolved responsibility approach adopted by the federal government has resulted in loss. State and local governments, cultural heritage bodies, community-based heritage stakeholders, industry and business sectors need leadership from the federal government to implement a best-practice model of success.

Currently the disparity between States and Territories in relation to the identification, preservation and funding is exacerbating heritage loss across the nation. Regrettably even post 2022 Federal election there is an apparent resistance to cite the word ‘Heritage’ in the relevant Ministerial portfolio title. Although some States and Territories have acknowledged the value of heritage in this way, others have not. This simply failure to acknowledge the significance or value of ‘Heritage is indicative of a persistent problem in Australia,

At all levels of government, the economic value of heritage assets is seldom acknowledged and as a consequence is in jeopardy with the threat of loss. 

3. Dispersed Responsibility Approach is a Failure

Without question valuable heritage assets are in jeopardy across Australia. A key causal factor is that the federal government has pursued the strategic policy agenda of shifting responsibility for Australian heritage assets to the states. A clear and significant demonstration of this disregard for and devaluation of national heritage assets is that it lies within the Department of Agriculture, Water and Environment (AWE). The AWE website lists ‘Heritage’ alongside ‘Parks’ revealing the low status of heritage assets compared to ‘natural’ assets. Further evidence of the federal government’s failure to either acknowledge the cultural significance of heritage assets, or recognise the economic potential of heritage tourism, appears in funding mechanisms. The Australian Heritage Grants Program 2021-22 is managed through the Department of Industry, Science, Energy & Resources, and applications go through Government Business. The value of heritage assets barely registers as a concern with  federal or state ministers despite their having legislative responsibility. This ministerial pattern of disregard for heritage assets translates into bureaucratic disregard. This manifests as chronic underfunding and an apparent reluctance to properly assess the economic value of heritage or cultural tourism. When significant heritage assets are neglected and lost, neither government nor bureaucrats choose to calculate opportunity-loss. This is a national crisis of neglect or and policy deficit.

The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) is central to managing heritage preservation in Australia. Under this Act the federal government has responsibility for World and National Heritage listed assets including natural, indigenous, built-form, maritime wrecks and cultural heritage. There is also additional federal legislation relating to Aboriginal laws and wrecks. The efficacy of these legislative protections is in doubt. The independent Samuel Review in October 2020 found that the EPBC Act was inadequate and has failed. Although the EPBC Act has primacy across the three levels of government, it does not provide for the obligations prescribed under UNESCO and the World Heritage Charter. The EPBC Act and its operation requires fundamental  reform. The system is clearly broken. (Note Post Election: July 2022 Implementation of the recommendations out forward in the Samuels Report arising from independent Review of the Environment Protection and Biodiversity Act 1999 (EPBC Act) is promised by the end of 2022 (media 20/7)  (Post Federal Election – Promised adoption  2022) 

4. Elections are a powerful trigger for reform
  • Australians are considering what is important to them
  • Candidates are competing for attention and votes
  • Heritage stakeholders are numerous, Australia wide and have observed decades of neglect and incompetence by various federal governments. 
Factors for Consideration

Australian States and Territories cannot afford to continue mismanaging and squandering valuable and unique heritage assets. The list of lost heritage assets is alarming for the nation. It is shameful that those who are responsible do nothing.

1. ‘Known’ factors:
  • Heritage is a shared national asset
  • Australia continues to squander invaluable cultural heritage assets
  • Heritage stakeholders are witnessing significant irretrievable losses
  • The level of grass-roots support for and engagement with heritage matters is immense
  • Dedicated Federal or State Ministerial Portfolios enable stronger representation
  • Assigning responsibility for national heritage into inappropriate ministries such as Agriculture, Water Environment or Sports is clearly ineffective in preventing loss of heritage assets
  • Heritage-listing as a protective device has ‘no teeth’ nor does it protect our heritage assets
  • The independent Review of the Environment Protection and Biodiversity Act 1999 (EPBC Act) , the primary heritage legislation. ie. Samuel Report 2020 was damning. (Note July 2022 Implementation of the recommendations out forward in the Samuels Report arising from independent Review of the Environment Protection and Biodiversity Act 1999 (EPBC Act) is promised by the end of 2022 (media 20/7)  (Post Federal Election – Promised adoption  2022) 
  • The Australian Heritage Council has crippling statutory limitations on its power (July 2022 We are advised that reform is underway)
  • The Australian Heritage Council has crippling statutory limitations on its power
  • Few decision-makers, and even fewer politicians, despite the data, understand the true economic value of heritage assets
  • Funding for heritage conservation,, restoration, promotion etc. is woefully inadequate and ever more highly contested – local, state, federal and philanthropic
  • Current sources of funding for all forms of heritage assets are inadequate, inequitable and varies very widely among states
  • Protection of Indigenous heritage assets barely exists and has persistently failed
  • Climate change will further jeopardize places of heritage significance across Australia
  • Heritage Tourism is irrefutably a multibillion-dollar industry, which relies upon investment in, and preservation of, heritage assets
  • By international standards the presentation and access to Australian heritage assets is poor and lacking vision and professional expertise
  • Growing deficit in heritage trade skills in Australia leaves heritage assets vulnerable to shoddy restoration and conservation
  • Cultural heritage tourism is acknowledged as the foremost growth area of tourism, even in the significantly changed world post-Covid.
2. ‘Unknown’ factors – and potential electoral ‘game-changers’:
  • Power of pre-election commitments made by candidates, successful or otherwise
  • Legislative interplay between Federal and State governments
  • Incidence, and extent of ‘pork-barrelling’ by politicians in relation to heritage fund distribution
  • Inequitable capacity in the community to actually apply for funding – awareness, time, expertise
  • Level of property developer or mining company access to and influence over, politicians or decision-makers
  • Conservation sector is inevitably professionally compromised – experts-for-hire and development interests influencing heritage decisions at all levels of government.
Proven Solutions Exist
A National Heritage Policy 

Many other nations acknowledge that heritage assets are shared assets having national value into posterity. They adopt national policies to better protect and preserve national heritage assets. And in doing so, they optimize the economic value of such heritage assets into the future. Although various levels of government in Australia have over decades canvassed the need for heritage policy to ensure that heritage assets are protected, there has been no effective change. Persistent loss of valuable heritage assets in Australia continues.

Both Federal and State governments have failed to halt the heritage loss. Asset Loss. he relevant legislative protection is inadequate. Causal factors include underfunding preservation, downgrading ministerial responsibility by tolerating policy or legislative inadequacy. In relation to nationally shared Heritage assets, the federal government has been found wanting, and has taken the least courageous line possible on heritage preservation.

Proven National Heritage Strategy

National Heritage asset policies in the United Kingdom offer a successful proven model for Australia to adopt. Since the introduction in 1994 of a national heritage support mechanism in the form of the National Heritage Lottery Fund, there has been a positive impact on heritage asset management in the UK. This mechanism has been, and continues to be, substantial, accessible and impressive. These impacts not only relates to funding, but also perhaps equally powerfully, acknowledge Heritage assets in such a way as to generate an economic uplift for UK tourism – domestic and international – as well as employment. Importantly it also accelerates heritage skills development, training, mentoring – much of it community-focussed and also prioritising diverse and disadvantaged communities and groups.

Another positive ‘consequence’ is given that the Heritage Lottery Fund enjoys popular support and it has perhaps actually increased wider public engagement with all types of heritage assets – both tangible and intangible. Heritage policy and legislative shifts led to the Heritage Lottery Fund and to re-defining ‘heritage’ in the UK. Its broad impact has been described as ‘transformative’. It is said to have ‘democratised’ public perceptions about ‘heritage,’ which in the past had been associated with the elite. The Heritage Lottery Fund is a mechanism through which to disperse heritage funds in a way, which is both equitable and informed by professional expertise. The creation of a dedicated Ministry for Heritage at that time served to strengthen the national focus and cohesive policy on heritage.

Noting earlier Australian experience with public lotteries and in particular capacity to generate revenue, in designing their lottery model, the UK had ample time to refine their initial lottery legislation specifically % funding allocation. The lottery immediately proved to be both popular and lucrative beyond expectations. Most importantly it painlessly, without complaint, provided massive funding for heritage places, projects and conservation as well as boosting the cultural tourism sector.

Disparity in Heritage Strategies

Consider differing State and Territory response to Heritage Ministries and Lotteries in relation to Heritage. The disparity supports the AHAA call for greater Federal oversight of heritage assets,

Western Australia has a Ministry for Culture and the Arts; Sport and Recreation; International Education and  Heritage. WA also has a Dept. of Planning Lands and Heritage and the State Lottery successfully delivers a stream of heritage funding eg. 2021  $2.8 million was  granted to the National Trust of Australia WA for Heritage projects and events,

South Australia  No reference to the term ‘Heritage’ on a Ministerial level SA . Heritage matters sit within Dept of Environment and Water. No Lottery.

Queensland    No reference to the term ‘Heritage’ on a Ministerial level except for the Ministry of Aboriginal and Torres Strait Islander cultural heritage. Other Heritage matters lie with Ministry of the Environment & Great Barrier Reef and within  the  Dept of Environment and Science. No Lottery. Note: In 2019 National Trust (Qld) called on the State govt to establish a heritage Lottery.

Northern Territory has a Minister for Arts, Culture and Heritage; and a Minister for Desert Knowledge. No Lottery.

ACT  has a Minister for Heritage and the Environment.No Lottery

NSW has a Minister for Environment and Heritage.No Lottery. Note: Sydney Opera House was built with the proceeds of a State Lottery.

Tasmania has a Minister for Heritage .N. Lottery. Note: In 2016 a submission to an Upper House inquiry to help fund heritage sites preserve and restore Tasmanian heritage sites was proposed.

Global Lottery Examples :

New Zealand used a lottery as the mechanism through which to generate support for heritage projects. The NZ model does not focus on heritage. The NZ Lotteries Commission distributes its lottery profits through the NZ Lottery Grants Board. The Lottery Environment and Heritage Committee make grant decisions, which is one of 20 such lottery committees. Heritage grant applications are considered alongside all other community applications.See https://www.communitymatters.govt.nz/lottery-environment-and-heritage/

South Africa  has a Heritage Day Lotto – an annual draw which takes place on 24 September and offers a jackpot of R255 million to support heritage..


Prioritising Heritage Management

There is unquestionably widespread public alarm about heritage loss, and there is widespread support for this policy shift among heritage stakeholders nationally. The media reports heritage degradation with depressing regularity. Let’s ensure our political aspirants and representatives in the 2022 election grasp this urgent necessity before more heritage assets are irrevocably lost, squandered in ignorance and political apathy.

To use the vernacular – adoption of policy reform in Australia’s National Heritage Strategy is a ‘no-brainer.’

Register Your Interest

Register to become part of the Australian Heritage Advocacy Alliance – simply email your contact details to: info@ahaa.net.au