The Headland Preservation Group (HPG) was formed over 26 years ago to protect the significant natural, cultural and heritage values of Sydney Harbour foreshore lands, including and in particular, Middle Head. It is the vision of HPG to conserve, protect and interpret these values which are of great national importance.
Read HPG’s submission on the Sydney Harbour National Park Draft Amendment to the Plan of Management (Draft Amendment) below or you can download a PDF copy here >
POSTSCRIPT: Since making our submission, HPG had become aware of a highly relevant document with design information that was not revealed when public comment was solicited. This document, a Schools Infrastructure Project Update for Middle Head – Gubbah Gubbah, from October 2022, reveals an unsympathetic design for a large new structure adjoining the heritage-listed Soldiers Institute that is completely inappropriate for such a culturally sensitive heritage location.
Download the Schools Infrastructure Project Update here >
HPG Submission
Background
Currently, the Sydney Harbour National Park (SHNP) Plan of Management (PoM) does not allow new buildings at Middle Head. The Draft Amendment proposes to add Middle Head to the list of sites within SHNP that allows for new buildings to be constructed.
The Draft Amendment proposes new buildings that will enable the development of an Environmental Education Centre to be considered within the Middle Head precinct. It is proposed that the Soldiers Institute on land managed by National Parks and Wildlife Service (NPWS) may be adaptively re-used for that purpose and that new buildings will include a Covered Outdoor Learning Area (COLA), a storage room and public toilets supported by an accessible driveway and mobility parking spaces.
HPG supports the establishment of an Environmental Education Centre at Middle Head. However, it does not support the adaptive re-use of the Soldiers Institute as an Environmental Education Centre requiring the construction of new buildings and associated infrastructure for the following reasons:
1 . The proposal destroys an existing use and fails to use alternative proximate structures.
The Soldier’s Institute is currently used for the corporate volunteer program and serves as a lecture and community uses room. Within the confines of the Soldiers Institute grounds is a community garden. These uses will be unavailable to the community if an Environmental Education Centre is established at this location. As there are very few community facilities in the Mosman area, the loss of this facility for community use would be significant. HPG considers that the existing use of the Soldiers Institute should not be compromised.
On neighbouring land managed by the Sydney Harbour Federation Trust (Harbour Trust) there are many buildings that could be utilised for the purposes of an Environmental Education Centre. HPG’s original proposal to establish a Department of Education Environmental Centre at Middle Head was written envisaging that it would be located in the adjacent 10 Terminal
complex. The recently renovated 10 Terminal complex has ample space to provide for such a centre. It is intended that 10 Terminal complex will also house a world class interpretation centre showcasing the environmental, heritage and Indigenous values of Middle Head. This use would be complementary to the establishment of an Environmental Education Centre at this location.
NPWS has committed to working with Harbour Trust in the creation of a unified Headland Park, and HPG considers that it is appropriate in these circumstances for the two entities to work together in the implementation of the proposed Environmental Education Centre on land managed by the Harbour Trust.
2 . The proposal adversely impacts a precinct of environmental and national historical significance.
The Middle Head precinct is highly important for its natural features and cultural history, as it holds:
Highly significant remnant bushland supporting 3 distinct vegetation types and 71 species of animal,
Important cultural significance for Aboriginal people. PoM, Page 126, describes the nationally important heritage of this site as containing an ‘exceptional collection of… Aboriginal archaeological heritage, a concentration not found elsewhere in the metropolitan area’,
Nationally significant colonial and military history and fortifications described as ‘the most diverse and complete collection of fortifications and defence sites in Australia’ which are listed on the State Heritage Register’ (PoM, Page123).
The construction of new buildings and associated infrastructure will not promote the conservation of the core values of the site, will be unsympathetic to the context of the site, and is likely to have a deleterious impact on its military heritage.
3 . It will set a dangerous precedent for future development of new buildings.
Schools Infrastructure of New South Wales (SINSW) has not revealed the scale, style or type of materials to be used in the construction of an intended COLA or associated infrastructure or other ‘new building(s)’ that may be proposed to be built at Middle Head. These decisions will be undertaken at a later date, after amendment of the PoM to allow the construction of new buildings is passed. It is poor governance, dangerous and inappropriate to amend the PoM before these decisions are made and communicated to the public.
If recent COLA’s built by SINSW are of any indication of the proposed construction, then such infrastructure is likely to be unsympathetic to this location.
Amending the PoM to add Middle Head to the list of sites that allows new buildings without detailed plans being previously provided sets a dangerous precedent for any new development at Middle Head, increasing the likelihood that new developments may not be in keeping with this important historic precinct.
4 . The proposal is a waste of taxpayers’ funds.
NPWS and Harbour Trust should work collaboratively and exhaustively to determine whether existing facilities on land managed respectively by them can be allocated to this project before expenditure of any further financial resources is contemplated.
Conclusion
HPG supports the existing use of the Soldiers Institute being retained for the purposes of community activities and visitors to the site.
If SINSW proposes new buildings to facilitate an Environmental Education Centre, HPG does not support the Soldiers Institute being adaptively re-used for such a purpose.
HPG opposes the construction of new building(s) as they are likely to disrupt the aesthetic and nationally important historical heritage of the Middle Head precinct.
HPG is also of the firm belief that the new buildings proposed are not imperative at the proposed site, as there is existing infrastructure within the Middle Head precinct which could be utilised for the stated purposes.
Jill L’Estrange President
Headland Preservation Group
6 January 2023