Feature Image: Comedy Theatre, 228-240 Exhibition St Facade. Source: VHD.

Earlier this month, the National Trust formally submitted its objection to the Future Melbourne Committee regarding a Ministerial Permit Application proposing a 27-storey mixed-use development at the rear of Melbourne’s iconic Comedy Theatre. The project would include office space and a 270-room residential hotel. The application replaces a former 2022 proposal for a 32-storey office tower.

Image: Architectural Drawing of Proposed Ministerial Planning Referral – TPMR-2022-12 at 222 & 240 Exhibition Street, Melbourne. Source: FMC Agenda 2/12/2025.

The Comedy Theatre is listed on the Victorian Heritage Register, recognised not only as an outstanding and intact example of an interwar theatre but also for its deep connection to Melbourne’s vibrant theatre scene throughout the twentieth century. It is the only live theatre constructed in Melbourne in the first half of the twentieth century and an unusually ‘intimate’ venue, reflecting the evolution of live performance in the city. The theatre is a cornerstone of Melbourne’s cultural and entertainment landscape, and its surrounding context enhances its significance.

Image: Comedy Theatre 228-240 Exhibition St Lonsdale Street. Source: VHD.

The National Trust has serious concerns about the overwhelming scale of the proposed development. We find the current tower design threatens to dominate the site, undermining the heritage integrity of the Comedy Theatre and eroding the local cultural values associated with its setting. Approving such a project would set a concerning precedent for heritage sites across the CBD, potentially weakening both the Victorian Heritage Register and Melbourne’s broader cultural landscape.

This referral did not provide Melbourne City Council with an opportunity to comment directly on heritage matters, as the Comedy Theatre is included in the Victorian Heritage Register any buildings or works will require separate approval from Heritage Victoria under the Heritage Act 2017. However, the Comedy Theatre is also subject to a Heritage Overlay (HO632) under the Melbourne City Planning Scheme. We are therefore disappointed that the Future Melbourne Committee voted to advise the Department of Transport and Planning that the Council does not object to the application, subject to the inclusion of certain conditions, without any consideration or reference to local heritage values of the Comedy Theatre and its CBD setting. This was after the National Trust and the community urged the Future Melbourne Committee to take a broader perspective in assessing the application, beyond planning compliance and amenity considerations.

Image: Interior Comedy Theatre, Melbourne, November 2010. Source: VHD.

Good development should respect the scale, character, and cultural significance of heritage sites and their setting, not simply meet procedural requirements. In the case of the Comedy Theatre, the height and form of the proposed tower demand scrutiny, not only considering the theatre’s state-significance, but also the potential impacts on the cultural values of the CBD setting that supports this significance.

Thoughtful planning and good design require more than ticking boxes. To ensure the safeguarding of spaces that define our city’s character, culture, and history, we must consider wider local heritage values of place beyond amenity and compliance with relevant Design and Development Overlays. The Comedy Theatre is one such space, it deserves protection from developments that would overwhelm and threaten its cultural heritage values at all levels of significance.

Images: Before and After Architectural Drawing of Proposed Ministerial Planning Referral – TPMR-2022-12 at 222 & 240 Exhibition Street, Melbourne. Source: FMC Agenda 2/12/2025.