Pro-forma submission letter – due 14 May

STEP 1 Read our FAQ HERE

STEP 2 For an analysis of the new proposal go HERE

STEP 3 Write your letter, suggested pro-forma below. You may also download this letter in WORD format here pro forma letter


Email to: [email protected]

CORRECT EPBC Fax Number is: 02 6274 1620

or post:
Referral Business Entry Point, EIA Policy Section (EPBC Act)
Approvals and Wildlife Division
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
Canberra ACT 2601


Re: Middle Head Healthcare Pty Ltd / Residential Development / Middle Head Road, Middle Head, Mosman, NSW / Development of a Residential Care Facility, Referral reference No. 2014/7194

To Whom It May Concern:

I strongly believe that, at minimum, this proposal should be determined a “controlled action”, however it would be preferable to reject it because it is “clearly unacceptable”.

It has a significant impact on the environment under the EPBC Act.

I understand this proposal is a revision of an earlier proposal which was strongly criticised by the broad community, the National Trust NSW and Mosman Council.

Significant impact on

1. The quality and character of location and

 2. Social and cultural aspects of location

I believe that the loss of public access to what is now public parkland would alter the quality and character of the location and would affect the social and cultural aspects of the location.

The fundamental principle is that this land was set aside, to be managed by Sydney Harbour Federation Trust, for public use. It is inconceivable that this land should be alienated for private use.

The development

  1. Has a much greater footprint than the existing single storey buildings
  2. Has a scale and bulk out of all proportion to its environs, dominating the surrounding area
  3. Will require the construction of a 150 metre long, 2-3 metre high steel heat shield “wall”  which would dramatically obstruct the spectacular views of Sydney Harbour and would be a major blot on the landscape
  4. Stress the capacity of Middle Head Road. This is a very narrow road in a national park, with barely room for 2 cars to pass in some places, and used by pedestrians and cyclists.


The unprecedented introduction of this Residential Care Facility would overwhelm Middle Head, which has small-scale part-time activities, bushland, and historic fortifications. These are all compatible uses in a national park on this iconic headland at the entrance to Sydney Harbour.

Significant Impact on Cultural Heritage values

The 10 Terminal Complex buildings are listed on the Commonwealth Heritage List. It has a long, rich military heritage and is a significant component of the military history of the Middle Head and Georges Heights heritage site.

The proposal would demolish most if not all of 10 Terminal.

That would deny current and future generations the opportunity to visit rare and significant buildings which are tangible reminders of the facilities which served important roles in Australia’s military past over many decades.

Significant Impact on Natural Values

The new Residential Care Facility will be visible from major scenic vantage points on Middle Head and from Sydney Harbour. Its 24/7 operation including night-time operations are incompatible within a national park.

Heritage Significance Appears to be Downgraded by Proponent

In 2007 a Conservation Management Plan (CMP) for Middle Head was commissioned by the Sydney Harbour Federation Trust. It rated all buildings in 10 Terminal (excluding the post-war Building 2) as having “exceptional” heritage significance.

However the proponent also relies on a previous study which is a lesser study and was commissioned by Defence Property Disposal Unit in 1998 when they were trying to sell the land. Therefore the proponent’s gradings are lower than the Trust’s own CMP gradings.

The downgrading of significance and without peer review in the context of a related development outcome is contrary to the intent of the EPBC Act and would cast doubt upon the outcomes of any development approval process.

Adaptive Re-Use Claim by Proponent Appears to be Misleading

I do not believe this is adaptive re-use.

The proponent claims the Residential Care Facility is a “sympathetic adaptive re-use process”. I believe that is false and misleading. The proposal envisages the demolition of most of the heritage buildings.

Adaptive re-use is the adaptation of historic buildings from one use to another while preserving their heritage value. Adaptive re-use is self-defeating if it fails to protect the building’s heritage values.

Accordingly, the proposal does not qualify as adaptive re-use.


Your Name

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Note: for more information making your own submission please download this checklist: EPBC-referral-submissions-checklist-when-responding-to-Invitation-to-Comment-on-a-referral-from-DoE-website