The National Trust has submitted to consultation for the Train and Tram Zone Activity Centres Program, calling on the Department of Transport and Planning to embed heritage expertise within its staff, create safeguards for unassessed local heritage places, and prioritise protection of existing green infrastructure as density increases.

Since 2024, the state government has been embarking on the largest roll out of local planning reforms Victoria has seen in nearly forty years. We acknowledge that Victoria faces a genuine housing challenge that requires ambitious and coordinated action, and Activity Centres clustered around existing train and tram infrastructure represent a sensible spatial framework for directing growth. However, the Victorian Government has not clearly communicated how heritage places will be considered throughout the design and implementation of the Activity Centre program. This silence has generated real uncertainty and anxiety in local communities.

Our Position

Our message has remained consistent throughout the broader planning reform agenda: The National Trust supports densification in and around heritage areas, if the change is managed in a way that retains the cultural heritage values of those places. We also support the government’s 30% canopy cover target, but systems must be implemented to help Councils and developers achieve these goals.

We believe that with the right policy and guidance in place, planning reforms, such as the Train and Tram Zone Activity Centres Program can deliver significant housing outcomes while utilising and protecting the heritage character that makes Victoria’s suburbs desirable places to live. However, we find that explanation and policy with regard to the Heritage Overlay has been largely absent from the Activity Centres program and related planning frameworks.

Streamlining processes should reduce unnecessary burden — not reduce safeguards.

What’s Missing from the Activity Centre Program

The Case for a Dedicated Heritage Planning Unit

We are calling on the Department of Transport and Planning (DTP) to establish a dedicated local heritage planning unit, with specialist expertise to provide both strategic and statutory advice on how planning reforms will intersect with local heritage overlays. This unit should support DTP’s own Activity Centre planning teams, as well as Councils, who will need resourcing and guidance to manage the increased demands the program places on them.

The Heritage Council of Victoria’s State of Heritage Review: Local Heritage (2020) identified systemic underfunding of local heritage planning functions across Victoria. Many Councils already lack the staff and expertise needed to manage the volume and complexity of heritage-related planning decisions. The Activity Centres Program will substantially increase that pressure.

If heritage is to be successfully integrated into Activity Centres and other planning pathways designed to speed up development approvals, decision-makers within DTP must have meaningful access to staff who understand how local Heritage Overlays operate and to ensure they are not ignored as our planning system is changed.

Local Heritage at Risk

Our concern is not for those places already protected by the Heritage Overlay. The proposed new planning controls do not change existing Heritage Overlays, and development proposals must still be assessed under any applicable Heritage Overlay requirements.

The concern lies with the places that are not yet in the Heritage Overlay, but may still be of local heritage significance. Indeed, many places of genuine cultural, architectural, or community value have simply not yet been formally assessed and protected.

Under the Activity Centres program’s ‘deemed-to-comply’ pathways remove public notice requirements and VCAT appeal rights for certain applications. These expedited permit approvals create strong incentives for demolition, and there are currently no processes to pause and assess places of potential heritage significance.

Green Infrastructure is Heritage Too

Heritage is not only about buildings. Cultural landscapes, tree canopies, private gardens, and established green space are heritage assets that contribute environmentally, socially, and economically to the places we call home.

Many of the nominated Activity Centres, particularly in Melbourne’s established middle ring, have relatively low levels of public green space precisely because they have historically incorporated significant private green space. That private canopy and landscaping has long performed essential functions such as; urban cooling, biodiversity support, and contributions to community wellbeing.

We are concerned that in efforts to meet the criteria to access a ‘deemed-to-comply’ assessment, developers will seek construction of apartments with increased footprint size, therefore removing and reducing trees and vegetation on private lots.

Adaptive Reuse

There is currently no meaningful guidance or encouragement within the Activity Centres program for adaptive reuse or retrofitting existing buildings. This gap will inadvertently encourage demolition, resulting in the release of embodied carbon and waste of existing materials, when the smarter and more sustainable path is the reuse of what we already have.

It is a well established principle that, “the greenest building is the one that’s already built.” Adaptive reuse delivers housing supply, retains neighbourhood character and streetscape, preserves embodied energy, and produces places with genuine identity and liveability. This kind of infill and adaptive reuse should be actively incentivised and streamlined through the program, not left out of scope.

Underutilised shop-top spaces are a case in point, and are a common feature of Activity Centre retail cores across Melbourne. Incentivising owners to refurbish these residential spaces would deliver housing close to public transport, within existing buildings, without impacting the local streetscape.

The National Trust is committed to working constructively with DTP and the Victorian Government to address heritage concerns and ensure heritage is visible in the policy and guidelines of the Activity Centres program and broader state planning reforms.

Read our full submission here.

Feature Image: A trolley going down a street. Credit:Dylan Cohen on Unsplash.