The Planning Assessment Report by Evolution Planning, October 2013 was prepared for Middle Head Health Care for the Development Application of the proposed residential Aged Care Home (The Cove at Middle Head).Headland Preservation has studied this document, at the recent public meeting on 20 February we highlighted the following errors and omissions in this report.
OMMISSION: 1. page 1 states: "the report accompanies an Action Application, made under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999."
COMMENT: No details of the Action Application were provided. The Trust says "the application form was completed by Boffa Robertson Group on behalf of the proponents, and submitted to the Harbour Trust as part of its application to the Harbour Trust. The form is not related to any referral to the Department of Environment under the EPBC Act. Application forms are not included in public exhibition material as they are for internal administrative purposes only, and may contain applicants’ private information such as home address and personal phone numbers." The form can be viewed here.
ERROR: 2. page 1 states: that the Trust is “the consent authority for any Action”
COMMENT: The Minister for the Environment is also a consent authority under the EPBC Act.
MISLEADING: 3. page 1 states: “This report has been prepared in the context of the amended Plan of Management”
COMMENT: The Draft Amended Plan of Management was put out for public comment and we were told in December no decision had been made. Therefore the report refers (and reads) as if it is being evaluated under a plan that has been adopted.
ERROR: 4. page 3 states: "The buildings to the immediate west of the site have been adaptively re-used for temporary visitors accommodation."
COMMENT: There is no (nor has there ever been) ‘accommodation’ anywhere in Middle Head Precinct. The inclusion of this statement seems to suggest a precedent and that by association a residential facility is acceptable for the site.
MISLEADING: 5. page 5 states: “Parts of the site have been used for dumping (illegal or otherwise)”
COMMENT: This is not evident, open spaces on the site are currently fenced off (for security and safety); spaces appear to be used for storage including stones and garden material. This seems like a misleading statement designed to devalue the site in people’s minds.
ERROR: 6. page 10 discusses tree removal and states “18 Trees will be removed – 15 being within the proposed building footprint.”
COMMENT: this statement is based on the tree assessment report which is using an incorrect footprint drawing for the new building on the northern part of the site (replacing existing 3 Barracks buildings), the orientation (the arc) of the new building was altered and the change will mean more trees will need to be removed. Together with other trees to be removed for open space upgrading and for the carpark on the western side of the 10 Terminal Buildings (page 3 of the Landscape Report Reduced) we believe the figure will be closer to 30.
ERROR: 7. page 14 & 17 the proposal refers to the development as: “adaptive reuse and interpretational reconstruction”COMMENT: We can find no such term “interpretational reconstruction” used by heritage authorities. “Reconstruction” has a specific heritage meaning which is “Reconstruction means returning a place to a known earlier state and is distinguished from restoration by the introduction of new material into the fabric. (Australia Burra Charter).” It is not true that the Barracks buildings are being returned to an earlier known state (barracks).
MISLEADING: 8. page 14 says: “Public access to the Trust land is not hindered by the proposed Action.”
COMMENT: “Hindered” is a misleading word, and could be interpreted to mean there is no loss of public access. There will be fenced private gardens; these are clearly shown in drawings and perspective drawings. The Trust has insisted that there will be no loss of public land, they seem to be including the current fenced off areas as land that would never have been made public yet in the original plans it clearly indicates that the fences were to be removed so that there would be access.
MISLEADING: 9. page 15 (and also page 16/17) states the “The site is conveniently located to public transport.”
COMMENT: No NOT convenient, the site is very isolated! Bus services start from about 7am with buses every hour, with a few extra services at peak hours. Last bus leaves Middle Head at 7.07pm.
ERROR: 10. page 16 states that “The overall Result (of proposed development) will be an increase in vegetated land.”
COMMENT: Under the present Plan of Management most of the carparks were to be removed and returned to parkland. Under this proposal they will be retained so there is a loss of vegetated land.
ERROR: 11. page 18 states that “The removal of the Barracks buildings is consistent with the preferred Outcomes contained within the Plan of Management which allows for the possible replacement of the buildings with car parking at the lower level.”
COMMENT: The proponent is (again) referring to the AMENDED Management Plan, which is not approved. The existing Middle Head Management Plan page 42 indicates demolition of one or more of the buildings to "open up the parkland" and says “If the buildings are adaptively reused, the architectural style, roof form, and choice of exterior materials should be sympathetic to the existing character of the precinct.”. The present proposal is not for the adaptive reuse of the Barracks buildings.
MISLEADING: 12. page 20: “The existing Barracks buildings are to be removed and a new building constructed which adopts a similar architectural style; will have similar massing and roof form characteristics”
COMMENT: Thus is highly misleading because the footprint is almost double the existing footprint and similar in height therefore it is much “larger” overall.
DISAGREE: 13. page 25 claims that: “The proposed development, being for the adaptive re-use and interpretation of existing buildings will have limited impact on the streetscape.”
COMMENT: There is little adaptive reuse at all. We disagree the proposed changes, including the new proposed building to replace the 3 Barracks buildings with its change on orientation thereby moving the building close to the road on the eastern side, access to underground parking, access roads for the movement of meals, laundry and other materials between the Barracks building and 10 Terminal ambulance bay, and removal of trees will have a big impact on the streetscape.
Above: Phil addressing the large public meeting re Middle Head 23 January 2014 1. INTRODUCTIONA Development Application has been made to the Sydney Harbour Federation Trust for a private 93 unit aged care residential facility on public land at Middle Head in Sydney Harbour. It is proposed to convert and enlarge the ‘Ten Terminal’ buildings, and to demolish and build on the Barracks site on the other side of Middle Head Road, so as to accommodate the facility. Middle Head is well recognised nationally as being a very significant and special place.In order to objectively and appropriately assess the merits of this application, one needs to go back in time to see how it was that the Trust was established, to look closely at the Act governing the Trust and the various plans that it has made, the heritage values of Middle Head and the particular site where the development is proposed, and to evaluate the actual proposal and any impacts it may have on those heritage and environmental values. It is then and only then that one can make a proper assessment as to what should happen to these buildings on Middle Head. That must be done in accordance with the obligation under the Act to protect, conserve and preserve the environmental and heritage values of this significant place.
Middle Head one of a number of significant sites in Sydney Harbour saved by the community 2. THE BATTLE FOR SYDNEY HARBOURA real and desperate 
Above: Ten Terminal and Barracks site at Middle Head proposed for aged care facilityThe Australian School of Pacific Administration (ASOPA), the 15 weatherboard ‘huts’ on the right as you proceed east along Middle Head Road past the oval, was built in 1941 and is of considerable heritage significance. It recently has been ‘restored’ and renovated keeping its heritage values and leased. This has been done to the Trust’s best practice standard. Public access has also been maintained.The School of Military Engineering (later Ten Terminal) was built c1941. During the Second World War it was occupied by the School of Military Engineering Anti-aircraft and Fortress Wing. The School of Military Intelligence occupied the buildings from 1958 and the Ten Terminal Regiment from 1974 to 1998. In 1998 it was handed to the Sydney Property Disposal Unit. The community battle prevented its sale to private developers. It remains unoccupied and has not yet been ‘restored’ and renovated.The three timber Barracks buildings and laundry are on the left hand side of Middle Head Road just past the Oval proceeding east. Apart from the small ‘Guard House’ close to the oval which is to be kept, there are no other structures on what is a natural area abutting the National Park. The Barracks were built 1951-55 and are not occupied.
Above: Ten Terminal is comprised of the buildings at top left centre, the Barracks are the three buildings in lower part of photo and ASOPA is the collection of light coloured ‘huts’ top right5. HERITAGE ASSESSMENTThe applicant for an aged care facility on Middle Head has lodged a ‘Heritage Impact Statement’ (heritage report) with the application.The heritage report in relation to the Ten Terminal precinct states:“The former brick and tile World War 2 School of Military Engineering buildings at Middle Head (later Ten Terminal) form a relatively rare collection of such buildings at a National level. Within NSW only the almost contemporary School of Artillery at North Head and the former 12 Lines of Communication complex at Boronia Park (Gladesville) are known to survive outside military establishments.”“Although used variously for training and administration, substantial documentary and physical evidence of the original configuration and detail of the building survives, including window joinery, doors and partitions.”Ten Terminal is listed on the Commonwealth Heritage List. Clearly it is of considerable heritage significance given its design, rarity, intactness, history and setting on significant public land adjoining the national park. It should be restored with appropriate uses.Appropriate uses for Ten Terminal could involve the interpretation of that site and ASOPA adjoining, interpretation of the natural values of Trust land and adjoining national park, and of the important Aboriginal occupation of this area. It is the only site that could give direct information to visitors who wish to enjoy and learn about Middle Head.The Barracks buildings on the other hand are of low, if any, heritage significance. They are considered in the report:“The assessment of significance of III Anti-Aircraft Battery Barracks Precinct concludes that it does not, as a specific part of the Middle Head and Georges Heights military area, reach the thresholds of the Commonwealth significance assessment criteria.”In my view the natural values of the northern side of Middle Head Road past the oval heading east far outweigh any argument for the retention of the Barracks buildings. They must go.6. THE AGED CARE PROPOSALThe application is for a 93 unit private residential aged care facility on public land at MiddleHead.It is proposed to be on both sides of Middle Head Road, the route that leads directly to the Middle Head entrance of Sydney Harbour National Park.
Above: Blue is the existing footprint and Below: Red is the proposed footprint and yellow is private open space 
It is intended to add a second storey, slightly set back, over the existing single storey buildings of Ten Terminal. In doing so the whole character of Ten Terminal is visually and factually changed. Its heritage values are seriously adversely affected.The footprint of the new facility is greater than existing, as can be seen in the plans and drawings and in the model. There is to be ‘screening’ landscaping around the facility which will also include a secured outside area for dementia patients. Instead of being able to walk through the collection of buildings and into some or all of the buildings, the public will be kept out of what would become a private facility. This is contrary to the object of the Act “to maximise access”.
Above: The applicant’s model of the proposed aged care facility showing the significant adverse impacts to the character and heritage values of the existing Ten Terminal buildingsThe applicant’s heritage report states:“The proposed adaptation of the former School of Military Engineering to provide an aged persons' health care facility will cause significant physical changes to the fabric, form and interiors of some building elements and the setting of the precinct.”The extended and enlarged footprint and an underground car park for a new building to replace the three Barracks, all this in an area that should become a natural place, means one thing. This building must never happen.The aged care facility is clearly contrary to the object of the Act to protect, preserve and conserve the environmental and heritage values of these significant lands.It is also contrary to the Trust’s Comprehensive Plan, to the way it is obliged to go about its planning and the way to date it has gone about its planning. The record of the Trust is without equal in Australia. What it has achieved at Chowder Bay, at Woolwich, at Georges Heights and to date at Cockatoo and elsewhere is truly remarkable and has brought great credit to all involved. It is also one of the few Government bodies that genuinely listen to community. What the community asks is for the Trust to maintain its high standard.7. WHAT SHOULD HAPPEN(a) The application or proposal should not proceed. Alternatively, if it does proceed it should be rejected. It is simply not appropriate.(b) The Barracks must come down. This area adjoining the national park should be natural. (c) Ten Terminal must be restored given its significance.(d) Appropriate uses for Ten Terminal, after further consideration by the Trust and community, could include the interpretation of its significant values, interpretation of ASOPA and the natural areas of both the Trust’s lands and the national park. It could also provide information for visitors and others who are coming to Middle Head.(e) One matter that I also have a very strong view on is that somewhere on Georges Heights or Middle Head there should be a place that recognises the incredible culture and history of the Aboriginal peoples, generally and as it relates to this particular area. The site of Ten Terminal or part of it or nearby land may or may not be an appropriate place. What is or is not appropriate must come from Aboriginal peoples. No other way is acceptable.(f) The Trust and National Parks should work very closely in the way they welcome people to Middle Head and how they interpret and care for Middle Head.(g) The call from the community to the Trust is clear. Keep your high standards. The community fought hard for this. The Act is clear and insists upon it.(h) The call to the Government is also clear. Properly fund the Trust. Get it to the point where its buildings have been restored to a level for appropriate uses or leasing. Then it can truly be said that the Trust is self-funding. It can then also be said that the Trust’s sites embody world’s best practice.Phil Jenkyn OAM4 February 2014