Statement of Evidence and Report to Planning Panel

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Statement of Evidence and Report to Planning Panel
Statement of Evidence and
Report to Planning Panel
Greater Bendigo Planning Scheme Amendment C235

106 Williamson Street, Bendigo
Statement of Evidence

Prepared by Peter Lovell

Instructed by
Rigby Cooke Lawyers

March 2021
Prepared by                 Prepared for

                            Spring Design and Development
                            Pty Ltd
Statement of Evidence and Report to Planning Panel
Statement of Evidence and Report to Planning Panel
Statement of Qualifications and Experience, and Declaration

Authorship

This statement has been prepared by Mr Peter Haynes Lovell, Director of Lovell Chen Pty Ltd, Architects
and Heritage Consultants, Level 5, 176 Wellington Parade, East Melbourne, assisted by Ms Charlotte
Jenkins, Heritage Consultant and Ms Libby Richardson, Heritage Consultant. The views expressed in the
statement are those of Mr Peter Lovell.

Qualifications and Experience
I have a Bachelor of Building degree from Melbourne University and have been director of the above
practice, which I established with Richard Allom in 1981. Over the past 40 years I have worked in the
field of building conservation and have been involved in, and responsible for, a wide range of
conservation related projects. These projects include the preparation of conservation/heritage studies
for the Borough of Queenscliffe, the former City of South Melbourne, the former City of Fitzroy and the
former City of Port Melbourne. In addition, I have acted as heritage advisor to the Borough of
Queenscliffe and the former City of South Melbourne. In the area of conservation management
planning I have been responsible for the preparation of a wide range of conservation analyses and plans
including those for the Melbourne Town Hall and Administration Building, the State Library and
Museum, the Supreme Court of Victoria, Werribee Park, the Regent Theatre, the Bendigo Post Office,
Flinders Street Station, the Old Melbourne Observatory and the Mt Buffalo Chalet. I have been
responsible for the preparation of strategic planning reports for Government House, Canberra, the
Melbourne Town Hall and the Supreme Court of Victoria.

In the area of building conservation works I have been involved in and directly responsible for the
investigation, design and documentation of a wide range of projects including the ANZ Gothic Bank at
380 Collins Street, the Collingwood, Melbourne and Fitzroy Town Halls, the Athenaeum and Regent
Theatres, Parliament House, Melbourne, Government Houses in Canberra and Perth, and the Supreme
Court of Victoria Court of Appeal.

I am a member of long standing of the National Trust of Australia (Victoria) and Australia ICOMOS
(International Council on Monuments and Sites). I am also an honorary fellow of the Royal Australian
Institute of Architects.
Over the past twenty years I have appeared frequently before the former Historic Buildings Council, now
the Victorian Heritage Council, and the Victorian Civil and Administrative Tribunal in relation to matters
relating to conservation, adaptation and redevelopment of historic places.

Instructions
My instructions in relation to this matter comprised an email request and meeting with the owners to
provide a preliminary appraisal of the heritage merits of the proposed listing, and subsequently an email
request from Rigby Cooke to provide expert evidence and appearance at this panel hearing.

References
As relevant to my consideration of the matter, documents which I have addressed as relevant in the
preparation of this report include:
    •   Bendigo City Centre Heritage Study Stage 1, Volumes 1 and 2 (Context, April 2020)
    •   Greater Bendigo Planning Scheme Amendment C235, Explanatory Report
    •   Planning Practice Note No. 1, Applying the Heritage Overlay

LOVELL CHEN                                                                                             1
Statement of Evidence and Report to Planning Panel
Declaration

I have made all the inquiries that I believe are desirable and appropriate and no matters of significance
which I regard as relevant have to my knowledge been withheld from the panel.

Peter Lovell

LOVELL CHEN                                                                                                 2
Statement of Evidence and Report to Planning Panel
1.0        Introduction
This statement of evidence has been prepared for Rigby Cooke Lawyers on behalf of Spring
Development and Design Pty Ltd, the owner of the property at 106 Williamson Street, Bendigo and
relates to Amendment C235 of the Greater Bendigo Planning Scheme.
As related to the subject property, the amendment seeks to include 106 Williamson Street Bendigo in
the Schedule to the Heritage Overlay of the Greater Bendigo Planning Scheme and to amend Planning
Scheme Map 19HO. The amendment seeks to introduce permanent individual controls (HO931) over
the subject property which currently is not included in the Schedule to the Heritage Overlay.
The subject property is located on the southern corner of Williamson and Mollison streets. The existing
building presents as a single storey retail building with glazed shopfronts addressing the street
frontages.

Figure 1      Locality plan, the location of 106 Williamson Street is indicated by the red star
              Source: www.street-directory.com.au

1.1        Preliminary advice

In June 2020 Lovell Chen undertook a preliminary appraisal of the proposed inclusion of 106 Williamson
Street in the Heritage Overlay (refer Attachment A). The advice involved a limited examination of the
heritage issues and concluded as follows:
           The conclusion of this preliminary review is that 106 Williamson Street Bendigo, on
           the basis of work completed to date, is unlikely to meet the threshold for local
           listing as satisfying Criteria A or D, but that it is likely to satisfy Criterion E. In
           satisfying Criterion E the elements of direct relevance to that criterion are the
           Williamson and Mollison street’s facades and a depth of the butterfly roof facade
           behind Mollison Street sufficient to understand the form. The remaining area of
           the building is of little or no significance.

           Should the site be included in the heritage overlay, in considering future
           redevelopment the options present as follows:

               •    Retention of the complete building to the extent of the currently mapped
                    heritage overlay area

LOVELL CHEN                                                                                           3
Statement of Evidence and Report to Planning Panel
•    Retention of the street facades with a nominal depth of 6 metres on
                    Williamson Street and 8 metres on Mollison Street

               •    Retention of the Mollison Street facade and return (8 metres) on
                    Williamson Street, with an 8 metre depth of structure behind

               •    Demolition and referencing the design aesthetic in the redevelopment
           The design of the building is not one which readily lends itself to partial retention,
           nor, in this case is this necessarily a desirable heritage or design outcome. As such
           the last of these options is one which might seriously be entertained in delivering a
           preferred whole is site development outcome.

This advice is discussed further in the following assessment.

2.0        Amendment C235
In the exhibited documentation, the subject property is identified as HO931 in the Schedule to the
Heritage Overlay of the Greater Bendigo Planning Scheme. The Schedule to the Heritage Overlay
identifies that external paint controls, internal alteration controls and tree controls do not apply to the
property. The extent of the heritage overlay is indicated at Figure 2.

Figure 2      Detail of the Heritage Overlay map 19HO with the subject site indicated
              Source: Part of map 19HO, exhibited as part of Amendment C235 of the Greater Bendigo
              Planning Scheme

2.1        Bendigo Heritage Study Stage 1

The subject property was included in the Bendigo City Centre Heritage Study Stage 1 (April 2020) (the
Study) undertaken by Context. The Study was commissioned by the City of Greater Bendigo to
undertake revisions to the Study (initially prepared in 2016-7), to review and update the individual place

LOVELL CHEN                                                                                                   4
Statement of Evidence and Report to Planning Panel
citations to be in line with the updated Planning Practice Note No. 1.1 The Study recommended 18 new
individual places, including one place extension, one serial listing and one place of potential state
significance. Individual citations were prepared for the 18 sites.

The citation for 106 Williamson Street identifies the subject property as being of individual significance
and recommends that it be included in the Heritage Overlay on a permanent basis.

The Study notes that the Greater Bendigo Thematic Environmental History (2013) could be expanded
upon to incorporate the commercial and industrial history as the Study particularly focussed on the
business and industry that has shaped the city centre following the mining boom.
In considering post-war development, the Study identified the former Beaurepaire Motor Garage, 404-
406 Hargreaves Street, the Bendigo Bowl (159 Hargreaves Street) and 339 Hargreaves Street (assessed
but not recommended as an individually significant place) in the Study as comparable examples of post-
war places. Under Section 3.3 ‘Assessing and reporting’ the Study provides the following comment with
regard to comparative analysis and post war sites.

           Postwar heritage is an expanding area of heritage consideration and not many
           comparative examples of Modernist buildings are included in Heritage Overlays
           outside metropolitan Melbourne. In the absence of local examples with existing
           heritage controls, the comparative analysis considers examples of similar postwar
           places in other local government areas to establish an appropriate ‘benchmark’. In
           rare cases, comparisons have been drawn between places within the study area
           and unnominated places located within the City of Greater Bendigo that do not
           have existing Heritage Overlays. This was where they provided a direct comparison
           in terms of their architectural providence, style or type or due to their geographic
           proximity to the subject site in question.

           When the place under assessment was considered to be of equal or better quality
           than the ‘benchmarks’, it was judged to meet the threshold of local significance
           and considered worthy of inclusion in the City of Greater Bendigo Heritage Overlay.

           Places that were found to be of a lesser quality than the ‘benchmarks’ were not
           recommended for inclusion in the Heritage Overlay. 2

2.2        Heritage citations

The property citation prepared by Context includes a statement of significance, history, description,
comparative analysis and assessment against criteria. These sections are variously discussed through
the statement.

2.2.1      Statement of significance
The statement of significance for the subject property is included in the Study, exhibited as part of
Amendment C235 is reproduced below:

           WHAT IS SIGNIFICANT

           106 Williamson Street, Bendigo, built in 1959-1960 for the Bendigo Timber
           Company by builders Green Brothers, is significant.
           Significant fabric includes the:

1        Department of Environment, Land, Water and Planning, Planning Practice note No.1, August 2018.

2        Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 1, April 2020, p.16

LOVELL CHEN                                                                                                  5
Statement of Evidence and Report to Planning Panel
•   original built form and scale of the building, including the low-slung
              asymmetrical butterfly roof;

          •   expressed structural steel frame;
          •   brick walls;

          •   cantilevered awnings;

          •   the notable glazing pattern which features bays of tilted windows; and
          •   recessed entry with stonework wall.

          HOW IT IS SIGNIFICANT

          106 Williamson Street, Bendigo, is of local historic, representative and aesthetic
          significance to the City of Greater Bendigo.

          WHY IT IS SIGNIFICANT
          106 Williamson Street is historically significant for its association with the Bendigo
          Timber Company which traded from the site between 1921-87. The subject
          building was purpose built for the company by Greens Brothers builders in 1959-60
          after a fire destroyed all previous buildings on the site in January 1959. It was the
          third premises occupied by the Bendigo Timber Company on this site, with fires
          destroying the earlier two buildings.

          The Bendigo Timber Company was formed as a partnership between Walter G.
          Hyett and George De Araugo with business operations commencing on 19
          December 1921. Walter Hyett had been a prominent Master Builder in Bendigo,
          whilst also holding large farming interests in the Mallee region of Victoria.
          Consequently, he was widely known and respected throughout northern Victoria.
          George De Araugo was for many years the manager of Hume and Iser, timber
          merchants, Bendigo, with extensive experience in the timber industry. The
          combination of these two men laid a solid foundation for a business that was to
          grow into the largest timber, hardware, joinery and paint establishment operating
          outside the metropolitan area. A major part of the Bendigo Timber Company’s
          operations was the manufacturing of kit form houses from the 1930s through until
          the 1950s under the name of Ready Cut Homes, a company that also had branches
          in Melbourne and Sydney. The company supplied plans, timber and a builder for
          the construction of these homes through a payment scheme. It was engaged in the
          erection of shops, hotels, stores, dwellings and every type of farm building. As the
          company expanded, it ceased construction operations and devoted its efforts to
          the supply of building materials to a rapidly expanding client base of builders and
          the general public. (Criterion A)

          The former Bendigo Timber Company building built in 1959-60 is a fine example of
          an intact modernist commercial building constructed in the post-World War II era.
          It demonstrates characteristics of the modern architectural idiom developed in the
          postwar era. Modernist buildings frequently adopted a ‘machine aesthetic’ using
          industrially processed materials such as steel, concrete, glass and prefabricated
          elements. The use of long-span structural frames and lintels meant that buildings
          no longer relied on load-bearing walls and greater areas of glazing were possible.
          These structural developments brought a new freedom to the expression of walls,
          windows, and roofs as independent design elements and a similar freedom to the
          planning of interior spaces. (Criterion D)

LOVELL CHEN                                                                                        6
Statement of Evidence and Report to Planning Panel
The former Bendigo Timber Company building is aesthetically significant for its
           ‘modern’ style where structure and function are expressed as part of its aesthetic.
           Key features include expressed steel columns and extensive glazing to its principal
           elevations, an asymmetrical low-slung butterfly roof and clerestory windows. Of
           particular note are the cantilevered verandahs, lower section tilted windows and
           the entry porch bound by a single steel column and rubble stonework cladding at
           the Mollison Street corner. (Criterion E)3
2.2.2      Property grading

The property is identified as a significant heritage place in the Bendigo City Centre Heritage Study, Stage
1. A definition for significant heritage places is not included in the Study or at Clause 22.06 – Heritage
Policy. Consistent with Planning Practice Note No. 1 a letter grading has not been applied.4
The Greater Bendigo Heritage Incorporated Plans – Permit Exemptions provides a definition for
significant places and individual place Heritage Overlay. These are reproduced below:

           Individual place Heritage Overlay: is a single heritage place that has cultural
           heritage significance additional to its context. These places may also contribute to
           the significance of a heritage precinct. Significant places will usually have a
           separate citation and statement of significance.

           Significant place: A significant place is a single heritage place that has cultural
           heritage significance independent of its context. These places may also contribute
           to the significance of a precinct. Significant places will usually have a separate
           citation and statement of significance.5

3.0        History

The citation for the subject property as included in the exhibited documentation for Amendment C235 is
reproduced as follows:

           106 Williamson Street, Bendigo, is a large commercial building, built in 1959-60 as
           the third premises of the Bendigo Timber Company on this site. It stands on the
           Crown Allotments 6 and 7, section 6C, Sandhurst, which was purchased by H.
           Backhaus on 21 April 1854.

           By 1891, the Bendigo Tramways Company had erected tram sheds and offices on
           part of the land. The balance of the allotments was used by the Bendigo Electric
           Company. The Bendigo Tramways Co. was short-lived; in 1892 the Bendigo Electric
           Company purchased the land and equipment of the tramway power station,
           including the buildings and land in Williamson Street. The Bendigo Electric
           Company provided electric power, equipment and installations on a commercial
           basis, including street lighting for the Bendigo City council.
           In 1914 the subject site was leased to Edward Button, carrier, and to C. E. Miller
           and Co., carriers, in 1920. Around 1921-22 the Bendigo Timber Company took over
           the lease with the property remaining in the ownership of the Backhaus Estate. On
           14 March 1931, a fire burnt the Bendigo Timber Companies stores and mills,
           located in Williamson Street and Mollison Street, to the ground. Due to the loyalty

3        Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 2, April 2020, pp.212-213.

4        Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 1, April 2020, p.25.

5        City of Greater Bendigo, Greater Bendigo Heritage Incorporated Plan – Permit Exemptions’, January 2018, p.3.

LOVELL CHEN                                                                                                             7
Statement of Evidence and Report to Planning Panel
of staff, merchants and clients, the business was re-established quickly on the same
          site and continued to expand.

          In 1945, Walter Hyett of the Bendigo Timber Company, leased the site, ‘land and
          buildings’, rated at £125. Gordon Hyett, who was taken into partnership by his
          father in 1929, took over the Bendigo Timber Company in 1945 when Walter Hyett
          went into semi-retirement. In 1957-58, the Bendigo Timber Company continued to
          lease the site, described as ‘land, buildings etc.’ valued at £740, indicating that
          further buildings may have been erected on site in the period 1945-57. On 25
          January 1959 a fire destroyed the Bendigo Timber Company premises, including
          yard, offices and stock. The estimated damage was £100,000.

          The whole site was subsequently cleared and two new buildings were erected in
          1959-60: one to house the Bendigo Timber Company’s hardware store and sales
          area (the subject site at 106 Williamson Street) and another at 113-133 Mollison
          Street built by James Michell and Sons, which housed offices and joinery
          manufacturing operations (today the building, with an altered façade, houses a
          variety of businesses). The building at 106 Williamson Street was designed for the
          Bendigo Timber Company and built by Green Brothers of Epsom.
          In 1986, the Bendigo Timber Company agreed to sell its property in the site bound
          by Williamson, Mollison and McLaren streets, approximately three acres of land, to
          make way for a proposed shopping centre. The following year the company
          vacated the subject site and relocated to new premises, on company-owned land in
          the Deborah Triangle Industrial Estate at the corner of Adam and Abel streets,
          Golden Square.

          Forty Winks took over the building at 106 Williamson Street soon after the Bendigo
          Timber Company vacated the site in 1987 and continues to occupy it today.

          The Bendigo Timber Company

          The Bendigo Timber Company was formed as a partnership between Walter G.
          Hyett and George De Araugo. with business operations commencing on 19
          December 1921.

          Walter Hyett had been a prominent Master Builder in Bendigo, whilst also holding
          large farming interests in the Mallee region of Victoria. Consequently, he was
          widely known and respected throughout northern Victoria. George De Araugo was
          for many years the manager of Hume and Iser, timber merchants, Bendigo, with
          extensive experience in the timber industry. The combination of these two men
          laid a solid foundation for a business that was to grow into the largest timber,
          hardware, joinery and paint establishment operating outside the metropolitan
          area.

          When the Bendigo Timber Company commenced business, it was engaged in the
          erection of shops, hotels, stores, dwellings and every type of farm building. As the
          company expanded, it ceased building operations and devoted its efforts to the
          supply of building materials to a rapidly expanding client base of builders and the
          general public.

          Arthur Leggo, a metallurgist who had previously managed the Victor Leggo
          Chemical Company, entered the business partnership in 1926. Leggo was to play an
          integral role in the growth of the business afterwards.

          In 1929 George De Araugo retired from the partnership, and in 1934 Walter Hyett
          purchased the interest of Arthur Leggo to become the sole proprietor.

LOVELL CHEN                                                                                      8
In 1931 the Bendigo Timber Company produced a catalogue with plans and prices
          for Ready Cut Homes kit form houses, which could be delivered to a building site,
          and also arranged a builder, if required, along with finance. The company
          continued to manufacture these houses until the early 1950s.
          In 1962 Gordon Hyett left the company and John Bourchier was appointed general
          manager; he resigned in 1972 when he was elected to the Australian House of
          Representatives as the Liberal member for Bendigo. He served in the Federal
          parliament until 1983 when he was defeated by John Brumby.

          In January 1973, John Gurr was appointed general manager and, in 1982, a
          director. Timber Holdings (Alstergren) purchased the company in 1982 and in 1988
          the Colonial Sugar Refining Company (CSR) became the new owners. On behalf of
          CSR, in 1989 John Gurr sold the business to BBC Hardware who were in turn taken
          over by Bunnings in 2001.6

The context for the construction of the subject building was one in which the Bendigo Timber Company
(BTC), as a well established supplier of timber and hardware, and as a builder, was in direct competition
with local hardware and timber suppliers, Hume and Iser Pty Ltd.7 The two companies had similar
offerings, which in the past had included prefabricated homes. Regarding premises, the BTC operated
from a number of locations around Bendigo, but had occupied the site on the corner of Williamson and
Mollison streets since 1920-21. The site on the corner of Mollison and Williamson streets had been
selected for its central location as compared to the more remote Hume and Iser operations, located on
Charleston Street, north-east of the city centre.8

A fire in 1931 burnt the premises to the ground, but it was quickly re-established in the same site. A
further fire in 1959, again saw the premises destroyed, and cleared and the current building erected.
Aerial photographs from the mid twentieth century show the site as a cluster of buildings around the
property boundaries, with a yard for trucks in the centre (Figure 3 - Figure 5). The aerial photograph
from 1967 shows the redeveloped site (Figure 6).
The new building was constructed to accommodate a new modern showroom and stores, which
included the headquarters of the Hardware and Paint Departments (Figure 6).9 The new showrooms
largely used the services of local businesses, including Green Bros of Epsom as the builders. Green Bros
were also responsible for the construction of other large-scale buildings in Bendigo including the
Britannia Theatre10 and Le Breton’s Pictures open air theatre.11 Green Bros also were notable in the
1950s for their pre-fabricated homes which could be purchased in 2, 3 and 4 bedroom packages. 12
Located in Epsom, 5 miles from Bendigo, the group offered delivery of the homes and setting down. 13

6       Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 2, April 2020, pp.206-8.

7       Mike Butcher, The Rose and Iser Story, Holland House Publishing, 2016, p.45.

8       Mike Butcher, The Rose and Iser Story, Holland House Publishing, 2016, p.45.

9       ‘Big Distributing Centre’, Bendigo Advertiser, 20 February 1960, p.11.

10      ‘To-day’s Events’, The Bendigo Independent, 16 January 1915, p.6.

11      ‘Le Breton’s Pictures’, The Bendigo Independent, 6 December 1912, p.6.

12      ‘Advertising’, The Riverine Grazier, 23 November 1951, p.1.

13      ‘Advertising’, The Riverine Grazier, 23 November 1951, p.1.

LOVELL CHEN                                                                                                9
The BTC showroom boasted displays of home amenities, power tool sets and large stocks of paints,
plumbing fittings.14 The company offices were located at the adjacent site, to the immediate west of
the subject site, on Mollison Street. As reported upon at the time of the opening, the BTC maintained a
policy of providing the best and most modern service it could to Bendigo.15 On opening, the new
showroom was described as follows:

          The new showrooms of the Bendigo Timber Co. Pty Ltd are designed with one
          thought in mind – the convenience of the firm’s many customers. Self-selection of
          goods – the most modern of buying aids in the Australian hardware trade – is the
          base on which the company has built the layout of the store. The philosophy of
          self-selection begins with the showroom office. Here the feature wall, visible from
          almost any part of the showroom, is composed of a checkerboard pattern showing
          a complete range of Australian plywoods, including the striking parquet plywood
          flooring. The outside of the office features all styles of vertical linings. The theme
          is continued down the centre of the showroom with easily accessible, readily seen
          open shelving, showing builders’ hardware, house-building tools and plumbing
          requisites. Backing these display shelves are bulk store shelves holding supplies of
          all the goods on display. In the showroom store itself the prospective home builder
          can see at a glance any of the basic requirements necessary for fitting out a house.
          Every type of bath, stove, hot water system, joinery or washbasin is on the floor. It
          is the company’s proud boast that everything necessary to fit out a house can be
          viewed in the building.

          Smaller hardware items, such as brushes, can be seen and bought on the self-
          service principle, so widely applied in the grocery stores of today. A battery of
          mobile stands and counters is readily available for any special displays of any
          hardware, paint or plumbing item. Backing the building housing the new
          showroom is a timber yard, where smaller quantities of all building requirements
          can be seen and bought. Larger orders can be delivered to the customer from the
          main company timber yard in Carpenter and Minto Streets. 16
As promoted in the 1970s the Bendigo Timber Company claimed to be a regional leader in new products
referencing a number of contemporary suppliers.17 The site was sold in 1986, with Forty Winks taking
over the site from 1987.

14      ‘Big Distributing Centre’, Bendigo Advertiser, 20 February 1960, p.11.

15      ‘Press a Button’, Bendigo Advertiser, 20 February 1960, p. 10.

16      ‘Service is our watchword’, Bendigo Advertiser, 20 February 1960, p.10.

17      ‘Advertising’, The Australian Women’s Weekly, 26 May 1977, p.70.

LOVELL CHEN                                                                                          10
Figure 3      1945 aerial photograph of the subject site indicated
              Source: Landata, Victorian Land Registry Services, Historical Aerial Photography Collection

Figure 4      c. 1950-4 view of the subject site (indicated)
              Source: Charles Daniel Pratt, State Library of Victoria

LOVELL CHEN                                                                                            11
Figure 5      1956 aerial photograph with the subject site indicated
              Source: Landata, Victorian Land Registry Services, Historical Aerial Photography Collection

Figure 6      1967 aerial photograph with the subject site indicated
              Source: Landata, Victorian Land Registry Services, Historical Aerial Photography Collection

LOVELL CHEN                                                                                            12
4.0        Description

The description of 106 Williamson Street as contained in the citation for the building, included in the
exhibited documentation is reproduced below:
           106 Williamson Street, Bendigo, is a large commercial building built in 1959-60 by
           Green Brothers builders as the third premises of the Bendigo Timber Company on
           this site.

           The building is located on the southern corner of Williamson and Mollison Streets.
           It is built on a large allotment with a recessed corner entry porch facing Mollison
           Street.

           Consistent with the key tenants of modernist architecture the building’s structure
           and function are expressed as part of its aesthetic. The building is constructed of
           brick with expressed steel columns and extensive glazing to its two principal
           facades to Williamson Street and Mollison Street. An asymmetrical low-slung
           butterfly roof falls from the long sides of the building. A row of clerestory windows
           sits directly below the roof line facing Williamson Street.
           The Williamson Street elevation is divided into seven equal bays, stepped to follow
           the fall of the site and divided by expressed steel columns. Three pairs of bays have
           consistent and regular glazing with the lower section tilted. The final bay forms the
           entry porch and is bounded by a single steel column at the Mollison Street corner.
           Cantilevered verandahs step down the elevation.

           The entry porch features a wall clad in stonework, which has since been
           overpainted. The entry porch also features a glazed entry door with highlight
           windows.

           The Mollison Street elevation is similar to the Williamson Street elevation with
           regularly glazed bays and a cantilever verandah. A second entry way and solid brick
           wall section can also be noted on this façade.18

4.1        The architects

The designers of the building were Eggleston MacDonald & Secomb. The firm of A S & R A Eggleston
was formed in 1937 as a partnership between noted architect Alec Eggleston and his son Robert. In the
1930s and 1940s, the firm designed a variety of commercial and industrial buildings. On his father’s
death in 1955, Robert Eggleston formed a partnership with two younger members of the practice,
Roderick MacDonald and Francis Secomb. The new firm of Eggleston MacDonald & Secomb (EM&S)
operated practices in Melbourne and Bendigo. Throughout the 1950s the firm was responsible for a
number of structurally expressive buildings in the Bendigo area such as the Bendigo Creche and Day
Nursery (1957)19 and the Beaurepaire Tyre Service Station (1959). EM&S also gained commissions for
specialised industrial projects, such as the Mason, Firth McCutcheon printing plant in Cheltenham
(1958); Redmond Inglis Printers (1962) and Thomas Frame Company (1962-63) in Notting Hill; and the
award-winning BHP Melbourne Research Laboratories (1969) in Mulgrave. 20

18     Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 2, April 2020, pp.208-9.

19     In February 2016, Expressions of Interest were called for the purchase and relocation of the Nursery and Creche building.
       https://www.architectureanddesign.com.au/news/city-of-greater-bendigo-seeking-eoi-for-former-ben#

20     Encyclopedia of Australian Architecture, Goad & Willis, 2012, pp. 227-228.

LOVELL CHEN                                                                                                                   13
In the 1960s and 1970s, EM&S undertook commissions for educational institutions including: University
of Melbourne; Caulfield Institute of Technology; La Trobe University; Melbourne Teachers’ College;
Monash University; and the Australian National University (Acton Campus).

4.2       Bendigo Timber Hardware Showrooms
The former Bendigo Timber Company showroom and sales premises is located at the south corner of
Williamson and Mollison streets, Bendigo (Figure 7). It is a single storey rectangular building with an
asymmetrical butterfly roof, with falls in a north-south direction. The longer façade fronting onto
Williamson Street is fully glazed with a deep awning stepping down in three sections to accommodate
the east-west site fall towards the corner of Williamson and Mollison streets. The primary entrance to
the building, recessed at the corner of Williamson and Mollison streets, takes the form of a square
entrance court with a stone feature wall facing Williamson Street, a steel column roof support at the
corner, and a glazed entrance and brick wall facing Mollison Street. The Mollison Street facade is
comprised of glazed and brick infill sections with a deep awning and a secondary shop front entrance.
The prominent feature of the building is in the treatment of the display windows, the lower two thirds
of which are angled at an approximate 60 degrees towards the footpath (Figure 9 & Figure 10).

The building is a steel frame and brick structure: the street facades (north and west) are comprised of
structural steel columns interspersed with steel framed glazing and brick infill to Mollison Street; the
south and eastern walls of the building are constructed of brick. The south wall contains sections of
clerestory glazing and a former entrance (Figure 11).
The interior of the building is open, segregated by a row of steel columns supporting the valley of the
butterfly roof form. Although the Williamson Street façade follows the site fall, internally the showroom
floor is at one level, resulting in the east end of the building being below the level of the Williamson
Street footpath (Figure 12).

All exterior surfaces are painted: steel columns and glazing bars; brick walls; stone feature wall; and
entire south wall including clerestory windows.

LOVELL CHEN                                                                                                14
Figure 7      View of the north facing façade along Williamson Street and recessed corner entrance

Figure 8      View of the west facing façade along Mollison Street

Figure 9      Glazing panels along Williamson Street

LOVELL CHEN                                                                                          15
Figure 10     Glazing panels along Mollison Street

Figure 11     View of the south (rear) façade of the building from Mollison Street

Figure 12     View of the interior of the building, looking towards Mollison Street

LOVELL CHEN                                                                           16
Figure 13      Internal view of the Williamson Street facade showing the tilted window frame and
               awkward boxing out of the cantilever awning structure

4.3         Locating the Bendigo Timber and Hardware Showrooms

The Bendigo Timber and Hardware showrooms represent an early commission within the life of the
young EM&S practice. Commissions of the practice appear to have ranged from the modernisation of
older buildings (Myers, Bendigo 1955; United Insurance Company 1958) to a broad range of emerging
new building types, such as the Beaurepaire Tyre Service Station in Bendigo (1959) and premises for
companies with specialised needs for modernised industrial processes such as the Office Block and
Factory for Mason, Firth and McCutcheon in Cheltenham (1958) (refer Table 1).

The former Bendigo Timber Company showroom presents as a building which utilises contemporary
materials and construction techniques that were readily available and popular at the time. As a
showroom, steel construction enabled a large span open space, as well as facilitating an ‘open front’
retail environment in which the traditional singular ‘show window’ was expanded to the entire façade as
a ‘giant showcase’.21

Architecturally, the showroom expresses the Modernist design aesthetic being pursued by a number of
younger practices of the day – Boyd, Grounds, McIntyre, Borland. As compared to the work of their
contemporaries and their own work in Bendigo and elsewhere, (the Beaurepaire Tyre Service Station
and the now relocated Bendigo Creche and Day Nursery), it presents, however, as a less accomplished
example. Less successful details include the forming of the angled steel window frames and the boxed
out shop entry on Mollison Street (Figure 10)

21      Walter Bunning, ‘Retail Store Design’, Architecture in Australia, July-Sept, 1953, p.70.

LOVELL CHEN                                                                                           17
Additionally and of note is the awkward manner in which the awning verandah connects to the facade;
on Williamson Street partially cutting across highlight windows above and on Mollison Street concealing
the butterfly roof. The awning appears to be a later alteration as the image from the Bendigo Advertiser
makes evident, the absence of the stepped fascia to the Williamson Street elevation (Figure 14). The
fact that it may have been a later addition is also suggested in the poorly resolved internal detail where
the verandah structure penetrates the facade resulting in a boxed out bulkhead which entirely conceals
the highlight windows.

Figure 14     View of the building, 20 February 1960
              Source: Bendigo Advertiser, 20 Feb 1960, p.7

While clearly exhibiting the features and aesthetic associated with post war Modernist buildings of the
time the building presents as potentially one delivered within a modest budget. While embracing
modern architecture and contemporary retail design in elements such as the butterfly roof form, angled
display windows and a recessed entrance at the street corner embellished with a feature wall, the
outcome lacks the cohesion and distinction evident in other of their commissions of the same period.
These include the work of the practice in Bendigo and elsewhere completed during the 1950s and 1960s
as illustrated in Table 1.
Table 1 Examples of work by Eggleston MacDonald and Secomb

 Year         Type           Image

 1953         Brights
              Store,
              Geelong

                             Source: State Library of Victoria, Peter Wille, H91.244/1907

LOVELL CHEN                                                                                            18
1955           Myer
                remodelled
                façade,
                Bendigo

                                    Source: State Library of Victoria, Peter Wille, H91.244/1864

 1957           Bendigo
                Creche and
                Day Nursery,
                later Park
                Road Early
                Learning
                Centre
                formerly in
                Rosalind
                Park

                                    Source: National Archives of Australia, 1957
                                    It is noted that a review of childcare services in the City of Greater Bendigo was
                                    undertaken in 2013, with plans to close the Park Road Early Learning Centre
                                    announced in 2014. The centre was officially closed at the end of 2015.22 In
                                    2016, the building was sold at auction to Gerard K House Pty Ltd and was
                                    subsequently relocated to Osborne Street where it is being converted into a
                                    private residence.23

22      ‘Bendigo Early Learning Centre to close’, Bendigo Advertiser, 28 October 2014, available at
        https://www.bendigoadvertiser.com.au/story/2654995/bendigo-childcare-centre-to-close/

23      ‘A new home for a piece of Bendigo history’, Bendigo Advertiser, 13 October 2017, available at:
        https://www.bendigoadvertiser.com.au/story/4986686/new-home-for-piece-of-citys-history/

LOVELL CHEN                                                                                                    19
1954-57      Beaurepaire
              Pool and
              Gymnasium,
              University of
              Melbourne

 1954-59      Beaurepaire
              Tyre Service
              Station,
              Bendigo

                              Source: Cross Section, July 1959

 1958-9       House at
              Bendigo

                              Source: Architecture in Australia, January-March 1959, p.91.

LOVELL CHEN                                                                                  20
1958         Mason, Firth
              McCutcheon
              office block
              and factory,
              Highett

                             Source: State Library of Victoria, Peter Wille, H91.244/1909

 1958         United
              Insurance
              Company
              Ltd, Bendigo

                             Source: Architecture in Australia, July-Sept 1958

 1959-60      Bendigo
              Timber
              Company

                             Source: Bendigo Advertiser, 20 Feb 1960, p.7

LOVELL CHEN                                                                                 21
1962         Redmond
              Inglis
              Printers,
              Notting Hill,
              Victoria

                              Source: State Library of Victoria, Peter Wille, H91.244/1916

 1962-63      Thomas
              Frame and
              Company,
              Notting Hill,
              Victoria

                              Source: State Library of Victoria, Peter Wille, H91.244/1918

 1963         Eggleston
              MacDonald
              and Secomb
              offices,
              Carlton

                              Source: State Library of Victoria, Peter Wille, H91.244-1870

LOVELL CHEN                                                                                  22
1969         BHP
              Melbourne
              Research
              Laboratories,
              North
              Clayton,
              Victoria

                               Source: State Library of Victoria, Peter Wille, H91.244/1874

5.0        Assessment of heritage issues
In assessing the worthiness of this place for inclusion in the Schedule to the Heritage Overlay, the Study
has identified that the subject site satisfies three of the heritage listing criteria as identified in Planning
Practice Note No. 1. Those criteria are as follows:

           Criterion A: Importance to the course or pattern of our cultural or natural history
           (historical significance)

           Criterion D: Importance in demonstrating the principal characteristics of a class of
           cultural or natural places or environments (representativeness).

           Criterion E: Importance of exhibiting particular aesthetic characteristics (aesthetic
           significance)

5.1        Criterion A: Historical significance

In meeting Criterion A at a local level the citation for 106 Williamson Street states as follows:

           106 Williamson Street is historically significant for its association with the Bendigo
           Timber Company which traded from the site between 1921-87. The subject
           building was purpose built for the company by Greens Brothers builders in 1959-60
           after a fire destroyed all previous buildings on the site in January 1959. It was the
           third premises occupied by the Bendigo Timber Company on this site, with fires
           destroying the earlier two buildings.

           The Bendigo Timber Company was formed as a partnership between Walter G.
           Hyett and George De Araugo with business operations commencing on 19
           December 1921. Walter Hyett had been a prominent Master Builder in Bendigo,
           whilst also holding large farming interests in the Mallee region of Victoria.
           Consequently, he was widely known and respected throughout northern Victoria.
           George De Araugo was for many years the manager of Hume and Iser, timber
           merchants, Bendigo, with extensive experience in the timber industry. The
           combination of these two men laid a solid foundation for a business that was to
           grow into the largest timber, hardware, joinery and paint establishment operating
           outside the metropolitan area. A major part of the Bendigo Timber Company’s

LOVELL CHEN                                                                                                  23
operations was the manufacturing of kit form houses from the 1930s through until
           the 1950s under the name of Ready Cut Homes, a company that also had branches
           in Melbourne and Sydney. The company supplied plans, timber and a builder for
           the construction of these homes through a payment scheme. It was engaged in the
           erection of shops, hotels, stores, dwellings and every type of farm building. As the
           company expanded, it ceased construction operations and devoted its efforts to
           the supply of building materials to a rapidly expanding client base of builders and
           the general public. (Criterion A)
This is a site and building with a relatively well documented history. However, the history of the use of
the place after the opening of the current building in 1960 remains largely unresearched. The history is
one, which as with many places included in the Schedule to the Heritage Overlay, accounts for the
development of the place over time and identifies individuals associated with that development. In
determining that the place satisfies Criterion A the citation notes that the site is associated with the
following historic themes taken from the Greater Bendigo Thematic Environmental History (2013):

       5.0 Building Greater Bendigo’s industries and workforce

       5.1 Processing raw materials
       5.2 Developing a manufacturing capacity

While recognising that the site as a whole has a long and interesting history which is associated with the
above themes the existing building was a place constructed as a building trade retail premises. As such
its ability to evidence these themes is limited. While activities on the greater site – including timber
milling, manufacture of kit homes – may have been linked to these themes, the current building is not.
As such the building presents as one of many retail premises in the centre of Bendigo and not one which
can be elevated for reasons of historical significance. In forming this view it is acknowledged that as
noted in the Study, there has been limited consideration of the development of Bendigo in the post war
period, but in the absence of such work having been completed the elevation of this building in
isolation, on grounds of historical significance does not present as warranted.

5.2        Criterion D: Representative significance

In meeting Criterion D at a local level the citation for 106 Williamson Street states as follows:

           The former Bendigo Timber Company building built in 1959-60 is a fine example of
           an intact Modernist commercial building constructed in the post-World War II era.
           It demonstrates characteristics of the modern architectural idiom developed in the
           postwar era. Modernist buildings frequently adopted a ‘machine aesthetic’ using
           industrially processed materials such as steel, concrete, glass and prefabricated
           elements. The use of long-span structural frames and lintels meant that buildings
           no longer relied on load-bearing walls and greater areas of glazing were possible.
           These structural developments brought a new freedom to the expression of walls,
           windows, and roofs as independent design elements and a similar freedom to the
           planning of interior spaces. (Criterion D)

In the initial appraisal of this building Lovell Chen stated as follows:

           In a Bendigo context 106 Williamson street presents as a place which pursues
           Modernist design ideas in a place specific context rather than as one of a distinct
           class of places. As noted in the citation, there are few comparable places within
           Bendigo which evidence like Modernist design ideas and those which are noted are
           similarly discrete events and not readily comparable. As such 106 Williamson
           Street does not present as a place which is important in demonstrating the
           principal characteristics of a class of cultural places which is important in a Bendigo
           context.

LOVELL CHEN                                                                                             24
In further assessing this issue the BTC showroom is an example of a post-war commercial building
located in the centre of Bendigo. Within this group it is one of a small number of buildings of the period
which exhibit individually distinct Modernist design ideas. Within the immediate catchment of the
Study area these include the Beaurepaire Tyre Service Station (VHR H1736), the Bendigo Bowl and the
former Paterson’s store at 339 Hargreaves Street. Beyond these three buildings there are others in the
central Bendigo area, which loosely continue Modernist ideas (adopting local and international styles) in
later but equally distinct buildings (refer Table 2).
While these buildings exhibit the characteristics which are associated with post World War II era
commercial development, they do not present as coherent class of places. The BTC showroom,
individually, is demonstrative of Modernist design in form and materials, but is not representative of a
class of places which is of note within the Study area or Greater Bendigo. Accordingly, it is not a building
which meets this criterion.
Table 2 Comparisons to the subject site

 Year      Place          Controls          Image

 1963      59             HO918
           Hargreaves     (proposed:
           Street         Criteria A, B,
                          D, G)
           Bendigo
           Bowl
           Moore &
           Hammond

 1954-     404            HO150
 59        Hargreaves
                          VHR (H1736)
           Street

           Beaurepaire
           Motor
           Garage

LOVELL CHEN                                                                                              25
c. late     339               Assessed but
 1950s       Hargreaves        not
             Street            recommended
                               as an
             JB Hi-Fi
                               individually
                               significant
                               place as part
                               of the Study

                                                     ‘339-355 Hargreaves Street is a postwar building of some
                                                     architectural interest in the upper façade design. The ground floor
                                                     shopfront has been modified. Research into the place's original
                                                     condition was inconclusive in placing the design within a context
                                                     for architect or style. Without this information it is considered
                                                     below the threshold for individual significance as a postwar
                                                     place.’24

 c. late     45 Mitchell       Located
 1950s       Street,           within HO3
             Bendigo           Bendigo Civic
                               Precinct, no
                               individual
                               overlay

 c.          52 Mitchell       Not included I
 early       Street,           the schedule
 1960s       Bendigo           to the
 -early                        Heritage
 1970s                         Overlay of the
                               Greater
                               Bendigo
                               Planning
                               Scheme

24         Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 1, April 2020, p.49

LOVELL CHEN                                                                                                     26
c. late     49 Mitchell
 1960s-      Street,
 early       Bendigo
 1970s

5.3          Criterion E: Aesthetic significance

In meeting Criterion E at a local level the citation for 106 Williamson Street states as follows:

             The former Bendigo Timber Company building is aesthetically significant for its
             ‘modern’ style where structure and function are expressed as part of its aesthetic.
             Key features include expressed steel columns and extensive glazing to its principal
             elevations, an asymmetrical low-slung butterfly roof and clerestory windows. Of
             particular note are the cantilevered verandahs, lower section tilted windows and
             the entry porch bound by a single steel column and rubble stonework cladding at
             the Mollison Street corner. (Criterion E)25
As concluded in the Lovell Chen preliminary appraisal, it is agreed that the Bendigo Timber Company
showroom meets Criterion E as a place of aesthetic significance at a local level. As one of a small group
dating from the same period, it is a building which exhibits a contemporary modernity as was being
pursued by a number of younger post war architectural practices. While not as well resolved as other
examples of the work of the architects Eggleston MacDonald and Secomb, and compromised in its
appearance by seemingly later cantilever awnings, it remains a locally significant example of a
Modernist design. The key features of the design are the extensive glazed shop fronts with angled glass,
the corner entrance with stone clad feature wall, the externally expressed steel columns and the
butterfly roof form.

6.0          Conclusions and recommendations
As a result of this review of the recommendation to include 106 Williamson Street in the Schedule to the
Heritage Overlay, I agree that the place satisfies Criterion E at a local level and is worthy of inclusion.

A revised statement of significance, with marked changes, has been included below.

6.1          Revised statement of significance

The following provides a revision to the statement of significance prepared as part of the Bendigo City
Centre Heritage Study Stage 1. It is recommended this replace the existing statement of significance:

25         Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 2, April 2020, pp.212-213.

LOVELL CHEN                                                                                                 27
What is significant

          106 Williamson Street, Bendigo, built in 1959-1960 for the Bendigo Timber
          Company by builders Green Brothers, is significant.
          Significant fabric includes the:

          •   original built form and scale of the building, including the low-slung
              asymmetrical butterfly roof;

          •   expressed structural steel frame;

          •   brick walls;
          •   cantilevered awnings;

          •   the notable glazing pattern which features bays of tilted windows; and

          •   recessed entry with stonework stone feature wall.
          How is it significant

          106 Williamson Street, Bendigo, is of local historic, representative and aesthetic
          significance to the City of Greater Bendigo.

          Why is it significant

          106 Williamson Street is historically significant for its association with the Bendigo
          Timber Company which traded from the site between 1921-87. The subject
          building was purpose built for the company by Greens Brothers builders in 1959-60
          after a fire destroyed all previous buildings on the site in January 1959. It was the
          third premises occupied by the Bendigo Timber Company on this site, with fires
          destroying the earlier two buildings.

          The Bendigo Timber Company was formed as a partnership between Walter G.
          Hyett and George De Araugo with business operations commencing on 19
          December 1921. Walter Hyett had been a prominent Master Builder in Bendigo,
          whilst also holding large farming interests in the Mallee region of Victoria.
          Consequently, he was widely known and respected throughout northern Victoria.
          George De Araugo was for many years the manager of Hume and Iser, timber
          merchants, Bendigo, with extensive experience in the timber industry. The
          combination of these two men laid a solid foundation for a business that was to
          grow into the largest timber, hardware, joinery and paint establishment operating
          outside the metropolitan area. A major part of the Bendigo Timber Company’s
          operations was the manufacturing of kit form houses from the 1930s through until
          the 1950s under the name of Ready Cut Homes, a company that also had branches
          in Melbourne and Sydney. The company supplied plans, timber and a builder for
          the construction of these homes through a payment scheme. It was engaged in the
          erection of shops, hotels, stores, dwellings and every type of farm building. As the
          company expanded, it ceased construction operations and devoted its efforts to
          the supply of building materials to a rapidly expanding client base of builders and
          the general public. (Criterion A)

          The former Bendigo Timber Company building built in 1959-60 is a fine example of
          an intact modernist commercial building constructed in the post-World War II era.
          It demonstrates characteristics of the modern architectural idiom developed in the
          postwar era. Modernist buildings frequently adopted a ‘machine aesthetic’ using
          industrially processed materials such as steel, concrete, glass and prefabricated
          elements. The use of long-span structural frames and lintels meant that buildings

LOVELL CHEN                                                                                        28
no longer relied on load-bearing walls and greater areas of glazing were possible.
           These structural developments brought a new freedom to the expression of walls,
           windows, and roofs as independent design elements and a similar freedom to the
           planning of interior spaces. (Criterion D)
           The former Bendigo Timber Company building is aesthetically significant for its
           ‘modern’ style where structure and function are expressed as part of its aesthetic.
           Key features include expressed steel columns and extensive glazing to its principal
           elevations, an asymmetrical low-slung butterfly roof and clerestory windows. Of
           particular note are the cantilevered verandahs, lower section tilted windows and
           the entry porch bound by a single steel column and rubble stonework cladding
           stone feature wall at the Mollison Street corner. (Criterion E)26

6.2        Extent of heritage overlay and exempt works

As relevant to the establishment of a suitable curtilage Planning Practice Note No. 1 states as follows:

           The Heritage Overlay applies to both the listed heritage item and its associated
           land. It is usually important to include land surrounding a building, structure, tree
           or feature of importance to ensure that any development, including subdivision,
           does not adversely affect the setting, context or significance of the heritage item.
           The land surrounding the heritage item is known as a ‘curtilage’ and will be shown
           as a polygon on the Heritage Overlay map. In many cases, particularly in urban
           areas and townships, the extent of the curtilage will be the whole of the property
           (for example, a suburban dwelling and its allotment).

           However, there will be occasions where the curtilage and the Heritage Overlay
           polygon should be reduced in size as the land is of no significance. Reducing the
           curtilage and the polygon will have the potential benefit of lessening the number of
           planning permits that are required with advantages to both the landowner and the
           responsible authority.
The extent of the proposed heritage overlay is the building footprint as extended into Williamson and
Mollison streets to incorporate the awning verandahs. On the basis that the awning verandahs are
confirmed as not original it is recommended that the extent exclude these elements and be limited to
the building footprint (Figure 16). Additionally, it is recommended that a site specific incorporated
document be prepared to assist in managing future works.
The building is one with a relatively large footprint and the elements and features which contribute to
significance are primarily associated with the facades to the two street frontages. The butterfly roof
form is also of significance, but to a degree this is as associated with the facades and as visible from
Mollison Street. While decisions regarding the impact and appropriateness of works is a matter which
can be addressed under relevant heritage policy, this presents as a place where it would assist to
provide some more explicit guidance.
The proposed mechanism to provide this guidance would be a site specific incorporated plan. The plan
would provide for permit exemptions from the provisions of the Heritage Overlay in accordance with
Clause 43.01-2 of the Greater Bendigo Planning Scheme. Consistent with the existing Greater Bendigo
Heritage Incorporated Plan – Permit Exemptions27, a permit would be required if it cannot be
demonstrated that a proposal complies with the exemptions set out in incorporated plan, noting that

26       Context Pty Ltd, Bendigo City Centre Heritage Study Stage 1: Volume 2, April 2020, pp.212-213.

27       City of Greater Bendigo, Greater Bendigo Heritage Incorporated Plan – Permit Exemptions, January 2018, p. 3.

LOVELL CHEN                                                                                                             29
the plan does not provide permit exemptions from a permit if required by any other provision of the
Greater Bendigo Planning Scheme.
The plan would allow for partial demolition and redevelopment of the building as a permit exempt
action within specific constraints. Those constraints would be as follows:
    •   Demolition of the existing building to within two internal column bays (approx. 9.2 metres) of
        the Mollison Street frontage (Figure 17) and to within 4.5 metres of the Williamson Street
        frontage.
    •   Construction of new works to within two internal column bays (approx. 9.2 metres) on the
        Mollison Street frontage and to within 4.5 metres on the Williamson Street frontage rising to
        no higher than two storeys above the highest point of the existing roof.

Figure 15     Currently proposed mapping of the heritage overlay

Figure 16     Proposed revised extent of the heritage overlay (red) with the exempt area indicated
              (yellow)

LOVELL CHEN                                                                                           30
Figure 17     View of the interior of the building, looking towards Mollison Street, with the approximate
              depth of the two column bays indicated by the red line

LOVELL CHEN                                                                                           31
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