BACKGROUND
In 2016, HPG proposed establishing a NSW Department of Education environmental field studies centre in the 10 Terminal complex on Middle Head. HPG believed there was scope for both Federal and State governments to cooperate in this venture and presented the proposal to the then NSW Minister for Education, the Hon. Rob Stokes, in early 2017.
However, after progressing with HPG’s proposal several years later, the Department of Education and NPWS instead agreed to establish an Environmental Education Centre (EEC) in state-managed Sydney Harbour National Park land at historic Middle Head Fort. In 2022, a draft amendment to the Sydney Harbour National Park (SHNP) Plan of Management was proposed to allow new buildings to enable this development. HPG strenuously opposed the amendment at that time.
In early 2023, the public became aware of the scope of the plan to adapt the small historic Soldiers Institute building and add a new building and infrastructure in the SHNP, including a large Covered Outdoor Learning Area (COLA), a storage room, and toilets, supported by an accessible driveway and mobility parking spaces. HPG does not support the construction of new buildings on Middle Head. We made representation to the Hon Penny Sharpe, Minister for the Environment and Heritage on 14 June 2023 and again on 18 September 2023 strongly opposing the amendment to allow new buildings in the historic Middle Head Fort precinct when the nearby 10 Terminal complex offered a suitable alternative. We wrote to the Minister again on 16 December 2023, advising that the revised plan for the COLA is unacceptable and requesting an extension of time to inform the community and allow feedback. Likewise, we have appealed to the Minister for Education, the Hon Prue Car, on 18 September 2023 and 16 December 2023 urging her to consider locating the EEC in 10 Terminal and to grant an extension of time for public comment.
Representations to the NSW Department of Education and the NPWS to reconsider the proposed construction by School Infrastructure NSW (SINSW) have been ignored. The proposed site is in the highly culturally sensitive and military-significant historic 19th-century Middle Head fort. The most recent public exhibition of the plans revealed a shocking lack of consideration for these heritage and natural values in the effort to push ahead with establishing an Environmental Education Centre.
HERITAGE
Not only does the construction of new buildings in this precinct require an amendment of the Sydney Harbour National Park Plan of Management, setting a dangerous precedent for future developments, but the selected site is historically, culturally and socially most significant. It carries high archaeological potential for the military and indigenous.
The Middle Head Conservation Management Plan* (Conservation Management Plan) says on page 25, “One of the most important aspects of the site as it now stands is the archaeological resource related to the former occupation as a military site. In addition, the possibility that the site may have been part of the Bungaree Farm site.”
The map on page 153 of the Conservation Management Plan shows that the whole area proposed for the planned construction of a COLA, toilets and storage areas has ‘high potential sensitivity.’ Such a construction would have a very detrimental impact on this sensitive environment and is an inappropriate development of the site.
The Conservation Management Plan on page 47 and in Figure 5.3.1 sums up the issue: ”New buildings within the confines of the moat perimeter would be an inappropriate response to the cultural significance of the site as a whole.”
“New structures would intrude …. and break down the site’s interpretative value.” A much more acceptable option is to locate the Centre in the nearby 10 Terminal complex as originally envisaged. This base is currently being restored and is empty. From the plan, the western wing of Building 3 in 10 Terminal appears to provide a ready-made area suitable for learning, ablution, and storage spaces for an EEC
In August 2023, Robert Newton, Acting Director of Greater Sydney for the National Parks and Wildlife Service, informed HPG that the Heritage Council had not yet approved the proposal. He advised that any proposal to consider an alternative location for the EEC will be decided by the Department of Education and the Harbour Trust. We have written to the Department of Education outlining our concerns and are awaiting a response.
HPG encourages the Department of Education and the Harbour Trust to work together to find an alternative solution to the existing proposal. The Harbour Trust has indicated that they are open to such a discussion.
HPG’s considerations are:
The location of the planned EEC is in one of the state’s most sensitive heritage areas.
An inappropriate new building is proposed to accommodate 120 children per day.
A ready-made alternative for the EEC exists in nearby 10 Terminal on Harbour Trust land.
Ten Terminal is close to the bus drop-off area and is safer for the children’s passage to the EEC
THE PROCESS
The proposed development is on public exhibition and (following an extension of time) open for comment until Friday 15 March 2024.
Once the public submissions are reviewed the only steps required to be undertaken by SINSW before works are undertaken are:
Lodgement of a Review of Environmental Factors (REF), (which includes a biodiversity and ecology, and bushfire assessment already obtained by SINSW), with NPWS.
Lodgement of an application for approval under Section 60 of the Heritage Act 1977 for the works to proceed.
It is imperative for the community to let their views be known. This is the last chance to have your say. In view of this, it is very concerning that there has been little effort to inform the public of what has been planned since it was first announced. At the public exhibition of the planned design on Wednesday 9 December 2023, a SINSW representative claimed there had been letterbox drops in the local areas, but several HPG members who reside very close to the National Park on Middle Head have reported not receiving any information.
The latest information pack dated December 2023 (you can download a copy here >) provides minimal detail. The cover features an image of an area not even part of the planned development. The artist impressions are not honest representations of how the proposed COLA will look. The buildings are shown at strange angles as flat grey monochromes designed to confuse. It is a most disingenuous document.
SINSW is “seeking feedback on the design plans for the existing building.” However, there is NO detail on the proposed modifications to the Soldiers Institute building, which is largely intact and of great heritage value in its extant state (interior and exterior).
SCOPE OF PROPOSED NEW BUILDING AND INFRASTRUCTURE
The proposed new building is very very close to the historic Soldiers Institute.
The design of the COLA has been altered slightly from the earlier versions we saw. The roof pitch is lower, and they added gable ends echoing the Soldiers Institute roof. It is, however, still extremely unsympathetic alongside the Soldiers Institute in terms of the proportions and finishes. The height and ceiling levels of the COLA are lower than those of the heritage building. It is built with steel posts and concrete, completely at odds with the Soldier’s Institute building from around the late 1890s to early 1900s. How can this be an acceptable addition in this location?
CLEARING BUSHLAND
The COLA will also mean a large area of bushland will be cleared for bushfire mitigation and safety. This is shown in diagrams in the information pack but as small diagrams with hard-to-see lines to indicate what might be cleared.
Community members who made the time to view the ‘exhibition’ were told that bushland to be cleared is degraded. They are implying that it does not matter and completely missing the point that all bushland is precious habitat that can be restored, as has been achieved in many swathes of bushland by volunteers, including those of the Mosman Bushland and Parks Association.
HPG’s Position
HPG supports providing educational resources and has always championed the possibility of environmental education activities on Middle Head, using existing buildings with a light touch. HPG never advocated the building of any new structures on these heritage lands. The HPG committee has proposed that the Department of Education work with the Harbour Trust to utilise space in the Harbour Trust’s 10 Terminal complex on Middle Head.
HPG does not support new buildings adjoining the heritage-listed Soldiers Institute in the Sydney Harbour National Park. The proposal is completely inappropriate for such a culturally sensitive heritage location.
* Sydney Harbour National Park Middle Head Historic Buildings – Conservation Management Plan. Paul Davies Pty Ltd, Architects Heritage Consultants Final Report January 2003. Download a copy here >