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David Scott

PO Box 485
North Hobart TAS 7000
16 June 2015
The Deputy Secretary Corporate, Heritage and Land
Department of Primary Industries, Water, Parks and the Environment

General Manager, Cultural & Natural Heritage Division

Director, Heritage Tasmania
Members of the Tasmanian Heritage Council
Staff of Heritage Tasmania

Dear Sir
I hereby tender my resignation from the State Service, effective of COB 9 July 2015.
27 years of experience in heritage management indigenous, natural and historic and 19 years senior
experience in the public sector including positions managing the ACT Heritage Unit and as deputy manager
to the much larger entity of Heritage Victoria, leads me to conclude that my ongoing tenure at Heritage
Tasmania is untenable because this organisation has lost its way as the state heritage agency.
The strategic direction of the organisation - distinct from operational practise and implementation appears to no longer consider leadership in heritage management across Tasmania and the delivery of high
standards of cultural heritage management, project governance or even public administration as
worthwhile business considerations. After years of working in an environment of industrial democracy
with strong support for my team and self, I perceive that in the last 12 months political and personal
motives have begun to dominate governance of the organisation; while concepts of open communication,
accountability and transparency have all but disappeared. I have never experienced an organisation in
which individual leaders have strived to avoid accountability for initiatives they instigated and shift blame
upon other parties be it the Secretariat for having to undertake the project, or the staff for
implementation issues. This behaviour has not gone unnoticed by the staff, some of which have also been
told they are effectively expendable that anyone who cannot keep up with delivery of the initiative may
need to consider leaving HT. When I advised there were a number of staff at risk of health problems and
workers compensation claims due to the excessive workload, which in any other organisation would be
considered matters I must escalate to my supervisor, I was simply told it was my responsibility to manage
the needs and wellbeing of staff.
I have sought repeatedly at Team Leader or other meetings to escalate matters of concern in terms of poor
heritage outcomes, poor governance and high risks/threats, only to have them summarily dismissed by the
Director. I strongly doubt whether any of these matters were ever passed on to the Secretariat and I have
been constrained in discussing matters of THC-relevance with the THC Chair because all meetings with the
Chair are controlled by the Director.
I wish to make it clear the focus of my concerns relate primarily to the areas of HT/DPIPWE governance.
Whilst I have my suspicions it is difficult to separate accountabilities between various parties due to the
way information has been communicated or not communicated. I am not seeking to level any concerns at
the new divisional head and THC Chair, nor the operational management and staff of HT.

I offer the following explanation of my three key concerns and some suggestions for action.

Strategic Concerns
The three strategic matters of greatest concern to me are:
(i) The Tasmanian Heritage Register Integrity Project. As coordinator of the significance review I have
done all I can to implement this project to the project plan with its almost-impossible schedule,
however I have never not during the project or the ~5 preceding years where the Director was
continuously proposing it should be done - supported the principle of removing large numbers of
places from the THR prior to there being a practical model for managing local heritage and some form
of consensus with stakeholders.
Many heritage practitioners including myself agree that in the ideal world, the register should be an
inventory of places of state heritage significance, and local government should manage local heritage
as per the COAG agreement. However most Tasmanian councils are 1/5 to 1/10 the size of their
mainland counterparts, so until some major resource-sharing initiatives between the smaller local
councils exist or there is a resource sharing arrangement between smaller councils and HT/state
government the above ideal is not achievable in Tasmania and some form of alternative needs to be
I believe the intent of COAG was for state governments to develop a holistic framework for managing
all heritage within their jurisdictions, define roles for state and local organisations that were achievable
and avoided duplication. The intent was not for state heritage agencies to take a self-serving approach
of minimising their resource burden by purging the state register without considering the
consequences for local councils or the places, and ignoring the reality that the community expects the
state government to lead the way in defining a holistic framework for managing heritage at all levels
and does not expect heritage to be placed at risk for administrative convenience.
Aside from a dubious interpretation of the COAG agreement my greatest concern with this project is
the perceived inconsistency between the Ministers clearly stated directive to the THC that having a
rigorous and defensible process was of paramount importance not the number of places to be
removed, versus the agencies position (as stated by the Director) that 1650 places must be removed
and the process will continue for several years as HTs #1 priority.
Ultimately, I believe the places recommended in the 2015 round for removal are of very low
significance so the potential impact upon Tasmanias heritage in removing them should be minimal.
To mitigate any further impact, there is an opportunity for the Minister and agency to extract itself
from the project at the end of the current round, whereby the Minister can successfully announce a
rigorous process has completed which affected a compromise of half the places being removed and
half being retained based upon their significance. This opportunity was raised within HT but summarily
dismissed, as it did not fit the agency agenda and I was informed that the next round would look at the
graded 2 places then the graded 3 if necessary until 1650 places were removed. This internal
obsession with removal numbers is counter to the process being based upon significance, having
rigour and being in accordance with good heritage management practice. Nor is there likely to exist a
single heritage practitioner within the state that will support grade 2 removals at the present time.
In addition, I have repeatedly advised that in the current environment 1650 removals is simply
unachievable that assessing the grade 2 places will take far more effort than the grade 1 reviews, and

considering the conservative/cautious approach taken by the THC in considering the grade 1 places I
estimated a review of the more-significant grade 2 places would not result in more than 50 removals.
To seek to remove grade 2 places at the current time makes no business sense there is nil heritage
benefit and little other administrative or political benefit, it will impact Tasmanias heritage to some
degree, and it will certainly impact the public credibility of the Minister, the THC and the agency in
managing heritage. If the integrity review and removals continue into 2016 then the project will cease
to be a question about the credibility of the THR and will to all stakeholders and the public - become
a question of the credibility of the participants.
A final point on meeting the need for process rigour in the Integrity Project. I developed a professional
methodology to help review significance, which has evolved through practical experience from the
assessors and addressing the emerging concerns from the Registration Committee. Ultimately every
place has gone through the rigour of being assessed by a heritage professional, QAd by a heritage
professional, reviewed by a subcommittee and reviewed and decided upon by the full THC. I fail to
understand by what basis it was then considered appropriate for the Director HT to review and modify
the final THC statutory decisions. He has no legal authority to do so; even as delegate one cannot
override decisions of a peak body, and for me such an adhoc last-minute review act makes a mockery
of the application of professional rigour and due process.
(ii) Over delegation of statutory powers. I have always supported the appropriate delegation of statutory
powers to improve business delivery and I believe the delegations introduced last year to expedite a
number of works approval matters have already reaped positive benefits for customers.
Recently, I was shown proposals for expanding delegations which left just one THC statutory decisionmaking responsibility outside of HT control. I raised very strong ethical concerns over this which I
consider not to be driven by business need but by a desire to limit the powers and change the role of
the THC in a non-transparent manner.
I have worked in Heritage Victoria, where the Director has most of the statutory powers and believe
that is a workable arrangement when (i) the Director is clearly identified in the legislation as the
decision-maker for specific actions, and (ii) the Director has public credibility in heritage management
by being a senior heritage practitioner (albeit one with public admin experience and political nous). In
Tasmania, where the legislation sets the community expectation as the THC being the decision-maker
independent from any government official, it is ethically inappropriate to transfer the majority of
statutory powers to a government official especially without community notification/input.
(iii) Power struggles and personality conflicts between THC & HT. Over 10 years I have witnessed the
relationship between each successive THC Chair and the Director HT turn bitter due to personality
issues and uncertainty or roles and responsibilities, and witnessed THC members play for control of HT
resources and the HT Director play for greater control of THC business. There is clearly a systemic
failure of the functions and powers of each body, and the inability to work as a single team distracts
the focus of both from delivering good heritage outcomes. For the staff, who are obliged to be to
impartial and duly provide for two masters because thats in the best business interest, it impacts
productivity and enjoyment of the workplace.


Hence, as the departing senior heritage practitioner in the state service, I provide the following suggestions
to the agency (in order of priority):
1. Terminate the Integrity Project at conclusion of the grade 1 review this year so as to minimise the
impact on Tasmanias heritage and preserve the credibility of the Minister, THC and agency. Future
removals are not impossible but should be predicated on there being a workable framework for
managing local heritage, and some positive new additions having been made to the THR to
demonstrate the intent of government to improve the THR rather than just dismantle it.
2. Relocate HT to a physical location integral to the remainder of the division. This is critical to
overcoming professional and personal isolation of HT staff by allowing informal interactions and
(potentially) even joint projects with other CNH staff, and opening up communication between staff
and the departmental and divisional executive (avoiding the inconvenience and reliance on the
Director for this).
3. Review the respective roles, decision-making powers and resourcing of the THC and HT to avoid
duplication and avoid future internal power games and conflicts. Some of this may be addressed
through processes/systems and some may require legislative change. In particular:

measures must be put in place to ensure that the development of strategic heritage initiatives and
any heritage-related HT business plan initiatives are always a collaborative effort between the THC
and HT (and Minister as appropriate), not a competition.

a strategic approach to statutory delegations needs to be formulated and all current delegations
should be reviewed. The community needs to be notified of which statutory decisions allocated to
the THC will be undertaken under delegation (even if only on the web site) and if the intent is for a
government official is to take over most of the THC statutory decisions then that should be made
clear in the legislation and the serious consideration needs to be given to whether that person
must have a professional heritage qualification.

4. Review the structure of HT team structures and positions/duties, salary levels and problems with the
professional stream, senior officer roles and locations, to ensure business needs are to be met.
5. Consider preparing a concise strategic plan for heritage management in Tasmania, which could be a
few web pages and not more than a double-sided A3, to communicate to the public:

An explanation of the differing levels/types of heritage that exist in Tasmania - state heritage v
local heritage v community organisations v national/world -and the governments intention for
how each are/will be managed including where statutory delegations exist or may exist.

Summarise proposed business initiatives (projects & programmes) for the coming year(s), ideally a
3-year vision

This plan should be a collaborative effort between the THC, HT and Minister potentially even provide
a reasonable basis for the Ministers Letter of Expectation and would ideally be put out every 3 years
and reviewed annually.
Because of the arbitrary dismissal of so many of my concerns over the last year, for the sake of ensuring
appropriate standards of governance are achieved within the organisation I feel compelled to circulate my
letter of resignation to the THC and HT all of whom have a stake in the governance of this organisation.
I apologise for any awkwardness this may cause, however I believe the agency needs to provide a
reasonable demonstration to these parties that it is considering and addressing the issues facing HT at the

present time, and not just my concerns. I understand a systems review is commencing and this may
provide a vehicle to consider such matters.
One day I look forward to once again contributing to the management of Tasmanias heritage, and I wish
the agency and the THC all the best in its heritage management enterprise.
Yours sincerely

David Scott
Registration Manager