Preliminary Assessment of the New Proposal


May 8, 2014

Proposal for Residential Care Facility, Ten Terminal Complex, Middle Head dated 23/4/14

This is our preliminary assessment of the new proposal prepared for purposes of a public meeting.

It has not been possible in such a short timeframe to fully evaluate the proposal. However we feel this preliminary assessment gives a clear but unflattering view of the proposal and highlights issues which support the conclusion that the matter needs a full and comprehensive review by the Minister for the Environment.

This will be achieved if everyone possible can demand that the Minister conducts a “controlled action”, which requires a formal assessment.

The developer would prefer a “not a controlled action” decision, known as a tick and flick.

We hope that this information will assist in letters and e-mails to the Minister.

How is the new proposal different?

The proposed development is now on the south side of Middle Head Road and does not include the re-development of the 3 barracks including the underground parking.

The Sydney Harbour Federation Trust (SHFT) has not confirmed that the barracks will be removed. Removal of the barracks is a separate issue.

The buildings on the south side of the road (the 10 Terminal Complex) have been enlarged in scale and bulk.

There is SIGNIFICATLY MORE DEMOLITION of the heritage listed 10 Terminal and we are advised that virtually nothing will remain.

There is also a new parking lot shown on the new proposal, which is presently green space.

There is also a new 100+ metre continuous steel heat-shield firewall between 2-3 metres high along the edge of the bushland/ridge which would block views of the Harbour from the proposal walking track.

Comments about the Sydney Harbour Federation Trust FAQ Posted on their Website

HPG disagrees with these statements posted on the Sydney Harbour Federation Trust (SHFT) Website about the new proposal and feels they are misleading.

  1. 1.      “The overall footprint, number of rooms, and new building height of the proposed facility has been reduced.” SHFT

The overall footprint* seems reduced but the facility is still about the same size as four suburban hotels and roughly as large as all the other buildings on the precinct combined. The number of BEDS has been reduced from only 93  to 89 (86 rooms).

*footprint must include buildings, enclosed spaces, and car parking requirements, whether reserved or public. Because the previous underground parking (36 spaces) is now located above ground, this also takes public space and must be included.

We have not had time to measure the new footprint* but we do not think it is substantially smaller if parking is included.

  1. “The proposal involves retaining and refurbishing the front and rear brick buildings and” SHFT

We are advised that it is quite likely that these buildings would not survive demolition. The interiors are all to be demolished.

  1. “replacing the side wings with a new two-storey extension designed to replicate the existing courtyard configuration of the complex” SHFT

It is not an extension it is a massive new 2-storey building.

  1.  “A new two-storey building of similar height is proposed to replace the rear garage building” SHFT

This is a completely new building completely replacing the existing garage and larger than previously.

  1. “The new structures have been designed to be lower than the highest existing building” SHFT

The highest existing building would be one of the garages, and this is high (not one storey) and it appears that the new building height is not much lower than the previous proposal but there is no height statistic.

  1. “The design proposes a new public landscaped corridor through the building cluster to link the public park to the north and south of the buildings.”SHFT

“Proposed Public Access corridor between Buildings 1, 2 & 3 and 6&7 is unrealistic. The buildings are too close together, linked by a covered way and to the public will appear like private property, part of this huge institutional complex. It is doubtful people would use it”

Michal K Tomaszewski B. Arch., FRAIA. (architect ret.)

Heritage Significance Downgraded by Proponent

  • 10 Terminal is listed on the Commonwealth Heritage List.
  • The proponent claims that the new plan “satisfactorily conserves the heritage significance of the place, which in this case is the past military use of the buildings”
  • However they intend to demolish most of the buildings and conserve the heritage by “Archival Recording and Interpretation Strategy”. Such strategy is yet to be prepared.
  • The National Trust of Australia NSW (peak heritage body) disagrees

The Trust strongly disagrees with this assessment. The Heritage Impact Statement relies on Sydney Harbour Federation Trust, Comprehensive Plan 2003 which adopts the heritage significance assessment undertaken by Godden Mackay Logan for Georges Heights and Middle Head Defence Site in 1998, while the site was still owned and controlled by the Defence Department. That heritage significance assessment states that Ten Terminal is rated as having some significance, except Building 6, which is rated as having low significance.

However a much more comprehensive, full Conservation Management Plan prepared in 2007 by Robertson & Hindmarsh Pty Ltd for the Sydney Harbour Federation Trust finds that these buildings” – National Trust to Mosman Council May 6, 2014

“form an exceptionally rare collection of such buildings at a National level. Within NSW only the almost contemporary School of Artillery at North Head and the former 12th 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.

Aesthetically the building is typical of the permanent buildings designed as training facilities in Australia during the 1930s and 1940s.” Robertson and Hindmarsh Conservation Management Plan 2007 Middle Head, for Sydney Harbour Federation Trust

  • Again, according to the SHFT’s own Conservation Management Plan (Robertson and Hindmarsh 2007) for the Middle Head Precinct

“The significance of the site and the building complexes is such that, with very few exceptions, all the buildings should be retained, adaptively re-used with minimal interference in the fabric of the buildings and landscape and interpreted with appropriate signage. Original World War 2 buildings should not be demolished but be adaptively re-used for uses compatible with their original and community uses.

The building complexes built rapidly during the war, namely the School of Military Engineering (1941) and the Signals Camp (1941) should be recognised as rare, significant military complexes at a national level.”

  • The proponent has amended its original Heritage Impact Statement to now include many references, including a heritage report by Godden MacKay Logan, which was undertaken in 1998 on behalf Defence Department Sydney Property Disposal Unit.
  • This was undertaken when Defence was trying to sell the sites and before the SHFT was established. It is assumed that the tone of this report is a reflection of the fact that a lower rating would assist the sale.  A similar position applies today, unfortunately.
  • The Godden MacKay report gave a low heritage value to the site.
  • Conclusion – the proposal would involve a total loss of a nationally significant rare complex.

New 150 metre Heat Shield

Because the development is in a Category 1 dangerous bushfire-prone area, the new plan includes a very long unsightly barrier on the southeast edge of the bushland/ridgeline that will prevent views of the Harbour.

Major Significant Alienation of Public Land

  • The legal advice is that the new proposal is not legal under SHFT’s Middle Head Management Plan 2007, which is the statutory document for the land.
  • Footprint includes buildings, enclosed open space, and a new car park
    • There are 2 new buildings
    • The main building is still 2-storey and the footprint is larger most significantly to the east
    • The adjacent “garage” building also has larger footprint
    • There are numerous enclosed outdoor areas being
      • East courtyard
      • Obelisk courtyard and terrace
      • Signals courtyard
      • Dementia courtyard
      • Forecourt (not enclosed but at the front of the building so not usable public space
      • West courtyard (not mentioned in Heritage Impact Assessment)
      • There is a brand new parking lot on parkland to the west
        • There are 27 parking bays proposed for the west side and this was not on the previous proposal.
        • This area is presently beautiful trees and open green-space.
        • Existing car parks to the east
          • There are presently acres of car parks to the east
          • These car parks were intended to be removed and re-grassed in the Middle Head Management Plan
          • It is likely that the aged care home will “appropriate” them
          • This is why they were included in the draft amendment to the management plan
          • Proposal now only calls for 29 spaces
          • Previous proposal required 46 spaces
          • However the number of beds is only reduced by 4%
          • This does not add up
          • “Public Open Space” access through the buildings
            • There are 2 narrow public access shown on the plan
            • One is a vehicular access road
            • The other is a narrow access between 2 large buildings.
            • We do not consider this usable public space.
            • Conclusion – there is a significant impact and alienation of public parkland due to footprints, enclosed gardens, additional parking lot to be built, appropriated public car parking, and unusable open space. As the facility is by far the most dominant building in the precinct and a case of overbuilding, it will compete for the use of all adjacent public land, to a degree not examined by either the proponent or the SHFT.

Majority Demolition of Heritage Buildings, not Adaptive Reuse

  • The proponent claims that this is adaptive reuse
  • This is the definition from the Burra Charter

Adaptive reuse

Adaptive reuse is the adaptation of historic buildings from one use to another while preserving their heritage value.

Sometimes this may be nothing more than a change in activities, however in many situations buildings require modifications to suit their new purpose. As a result, reuse allows historic buildings to be properly cared for, and their origins to be understood and remembered, even where their purpose and function have changed.

Adaptive reuse is an important element in retaining historic buildings and other places for future generations. What’s more, there are considerable benefits for environmental sustainability.

  • The Department of Environment booklet “Adaptive Reuse: Preserving our Past, Building Our Future” states

“Adaptive reuse is self-defeating if it fails to protect the building’s heritage values”

  • HPG does not believe this proposal is adaptive reuse.
  • The number of beds is only reduced from 93 to 89.
  • To accommodate this almost same number of beds but on only side of the road requires larger buildings and significantly more demolition.
  • We are advised that the Demolition Plan is not a viable plan and would result in at least 75% demolition and quite possibly all.

Demolition Proposal

The demolition as documented is misleading.

By the time the roof, ceiling & the internal walls are demolished there will be nothing bracing the external walls. They will become unstable and for safety will have to be demolished.

Even if, at a great cost, existing walls are braced & retained as shown on the plans, when new windows, doors, floor to ceiling heights etc are put in, there will not be anything left of the existing walls.

When the internal walls are demolished, existing floors will likewise have to be demolished to accommodate new layout and consequent new services. This is not even mentioned on the Demolition Plans which in my opinion are misleading to say the least.

Above comments apply to the demolition of Buildings 1,3,6 & 7. I believe it is proposed Building 2 to be demolished in its entirety.

Michal K Tomaszewski B. Arch., FRAIA.
(architect ret.)

No Public Consultation

There has been no public consultation on this new plan, and the proponent has chosen to seek approval first from the Minister rather than the SHFT. Apparently this is allowed.

The proponent will still need approval from the SHFT in addition to the Minister, not only for the proposal but the SHFT would need to amend its Management Plan which would require the further approval of the Minister.

The proponent states that is has consulted with the SHFT to develop the new plan (around 2 months at least), however the community was not made aware of the new plan until it went on exhibition last week (30 April 2014) at the Department of the Environment.

The fact that the SHFT has been consulted on this new plan which requires almost total demolition of buildings that the SHFT itself rates the 10 Terminal Complex of high heritage significance AND that is not legal under its own Management Plan is not understandable to us.

Barracks Removal


“Public consultation on the draft amendment to the Middle Head Management Plan indicated strong community desire for the removal of the two-storey timber barracks buildings on the northern side of Middle Head Road.

Their demolition would present the Harbour Trust with an opportunity to create a continuous stretch of open public parkland from HMAS Penguin to the tip of Middle Head. The new park would include increased public open space, create spectacular look-outs across Middle Harbour and introduce a new network of walking tracks and improved visitor facilities. The removal of the timber buildings would also improve views of the peninsula from Middle Harbour.”


  • There is no relation between the new proposal and the ability of the SHFT to remove the 3 Barracks.
  •  Under the SHFT’s Middle Head Management Plan they could always be removed.

Gross Floor Area

We have not had time to obtain exact measurements but believe that the overall floor area is similar to the original proposal which was 2 sides of the road.


While the SHFT and proponent maintain that the new proposal is more acceptable than the previous one which they supported and then, apparently abandoned, any analysis does not support their joint views. The plan seems to reduce the footprint somewhat but adds a car park and a much larger and bulkier buildings.

In the process the 10 Terminal Complex, high heritage buildings and a critical part of our military heritage and history, will be lost completely. The operation of the facility cannot fail to push other activities to the side and take away the community’s use of public land as granted by the SHFT, in addition to the land already lost to the facility.

Once built it would be irreversible. It has been undertaken without sufficient effort to develop alternatives which are less intrusive and more in keeping with the environment of Middle Head.