GML’s Experience in Heritage in NSW · 2019-08-02 · Working Draft for Comment—Better Placed—Design Guide for Heritage 4 GML’s Comments Overall • The document lacks the

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GML Heritage Pty Ltd

ABN 60 001 179 362

www.gml.com.au

23 August 2018

Government Architect New South Wales

L3, 320 Pitt Street

SYDNEY NSW 2000

Re: Working Draft for Comment—Better Placed—Design Guide for Heritage

Dear Sir or Madam,

GML Heritage Pty Ltd (GML) is pleased to provide comment on the Government

Architect New South Wales’ (GANSW) working draft, Design Guide for Heritage

(DGH).

GML commends the GANSW in initiating the DGH in line with the Better Placed

strategic approach to guide aspirations of good design for the built environment

of NSW into the future.

GML’s Experience in Heritage in NSW

For over 27 years GML has been at the forefront of heritage consulting. We

have worked on over 4000 projects, in suburbs and cities as well as iconic

destinations and World Heritage sites such as Angkor, Antarctica, Lake Mungo

National Park and the Sydney Opera House.

Through bold new approaches to heritage and general involvement in the

heritage field, we shape heritage futures through clever, independent thinking,

trusted advice, and powerful solutions for projects from planning to completion.

Our work is focused on services and projects across Aboriginal cultural

heritage, archaeology, interpretation and design, landscapes, public history,

and community engagement.

Summary of GML’s Comments

In summary, our comments on this well-intentioned document are:

• The government architect’s foreword establishes the inherent tension

throughout the document where design is conflated with a sophisticated

understanding of history and heritage, when really it is focused on built

form.

• Most of the parts of this document simply repeat more concise, well-

established guidelines and standards, such as the ICOMOS Burra

Charter.

• Determine the audience for the DGH and amend it accordingly—is it for

developers and design teams working on state significant development,

Working Draft for Comment—Better Placed—Design Guide for Heritage www.gml.com.au 2

the general public or the experienced heritage professional? Different language and content would

be appropriate for each.

• The DGH is extremely wordy, some of the language is not accessible, there is a lot of jargon, and

the word ‘design’ is used excessively.

• There is no mention of State Significant Development processes. Is this document primarily aimed

at developers and larger public places, as Better Placed is? If not, then a wider range of concepts

and case studies needs to be included.

• The DSG should remain a high-level guide, and not seek to replace the well-respected and more

detailed Design in Context document.

• Review the logical sequence of information. For example, we recommend that ‘explaining heritage’

is located upfront in the document, which would be useful for audiences not familiar with heritage

practice, and could be simplified (ie making reference to other existing heritage principles and guides

rather than repeating their content).

• Clarify the document’s relationship to Better Placed. While the design objective ‘Better Fit’ lends itself

well to case studies for good design for heritage, the other design objectives appear to be a forced

fit and are not necessarily relevant.

• Improve reference to current industry standards such as the Australia ICOMOS Burra Charter and

Design in Context and use language/terminology consistent with these documents to avoid

confusion. Direct reference to the Design in Context design criteria should be made.

• Archaeology and Aboriginal archaeology are not well referenced, and risk undervaluing these

important site types. References to these appear too late in the document.

• Consider relocation of the case studies to an appendix at the end of the document, to improve the

flow of the document.

• Include more images, with detailed captions, and a broader representation of example location (city,

regional and rural), place type, cultural diversity and architectural era / style, in the case studies and

selected images generally. Examples representing a broader range of architectural firms would also

be beneficial.

• Review images selected and include better examples and case studies which provide clear and

uncontentious precedence for good design outcomes in heritage places. Captions provide a good

opportunity to articulate the positive heritage and design outcomes of the example. Images which

are evocative, but do not show good design in a heritage context, should be replaced.

• Case study examples that we consider to be good include the Art Gallery Ramp and 40 Crown Street

(but this image does not warrant appearing in both Better Placed and the DGH). Case study

examples that we consider to be poor or controversial include the Moree Baths and Lennox Bridge.

GML can suggest an improved range of examples, if GANSW would like this assistance. More infill

and adaptive re-use examples could be included.

• The glossary at the back of the document appears to include words popularised in the Office of the

Government Architect rather than in common usage by heritage professionals.


We offer these comments in the spirit of collaboration. More detailed comments on the draft Design Guide

for Heritage are provided in the attachment. We would be happy to discuss these further with you.

Yours sincerely

GML Heritage Pty Ltd

Sharon Veale

CEO


GML’s Comments

Overall

• The document lacks the clarity of language, layout and design guidance contained in the existing documents ‘Design in Context’ and ‘New Uses for Heritage Places’.

• It is extremely wordy, the language is not always accessible, there is a lot of jargon, and the word ‘design’ is used excessively.

• The target audience is owners, architects, consultants and builders but the document does not seem to target these groups specifically. The target audience of the Better Placed suite of documents is developers on major projects and State Significant Developments. The DGH is not explicit about this. If the DGH is intended to be a subset of Better Placed, it needs to be introduced as such.

• The attempt to fit this document into the Better Placed framework is awkward and takes up a lot of the document. Perhaps a graphic presentation on the inside front cover would be a better way to outline this relationship; however, outlining the detail of the relationship between the documents is not relevant to the audience and readers would be directed to Better Placed itself rather than have to read about it across many places here.

• The word ‘consultants’ is used ambiguously in the document. Does it mean heritage consultants?

• GML would suggest more adaptation/infill examples, examples from regional NSW, suburban residential examples (if the general public is part of the target audience), and examples of successful interpretation projects. Images selected for each example need to show a variety of angles ie exteriors and interiors, photographs taken during the day and not at night as they are harder to see, the design changes and where adaptation has taken place. Image captions need more analysis to avoid being taken out of context. The current image captions contain little analysis.

• There needs to be more images and a larger variety of examples representing a broader range of:

locations;

built types;

cultural diversity;

design change approaches;

architectural firms; and

architectural historic periods.


Part One—Introducing the Design Guide for Heritage

Section Comment

1.1 Why Heritage Matters This section outlines various types of change and use of heritage places but the images selected do not show this range. More images are needed.

1.2 About this Guide Consider a detailed Appendix of case studies rather than high level captions which could be taken out of context.

The Burra Charter is not a nested document under Better Placed and the order of documents on page 12 should be reordered to reflect this. The description of the Burra Charter on p 12 is slightly misleading. The Charter is specifically a ‘standard of practice for those who provide advice, make decisions about, or undertake works to places of cultural significance, including owners, managers and custodians’. The way is it phrased here suggests that it is specifically about making changes to places. This is only one element of the guidance in the charter. The Burra Charter process is clear—understand significance, develop policy, manage in accordance with policy. This should be articulated specifically in the document on p 12. Consider including the Burra Charter flow chart. Similarly, on p 44, the section ‘Provide for the change to be reversed…’ does not reflect the definition of change in the Burra Charter or the Practice Note relating to Article 22.

1.3 How to Use this Guide

This section explains who can use this guide rather than ‘how to’. GANSW could include diagrams which illustrate the relationship between Better Placed objectives and the existing best practice heritage documents ie make reference to Design in Context published by Heritage Office.


Part Two—Better Design for Heritage

Section Comment

2.2. Good Design for Heritage

The Design Criteria of Design in Context are lost in the new Better Placed objectives and case studies based on them. It would not be appropriate at this stage to supersede Design in Context as the Design Criteria are architectural devices and qualities/analysis of context which assist all professionals. These elements should be included or referenced within the Design Guide for Heritage:

• Character

• Scale

• Form

• Siting

• Materials and colour

• Detailing

2.3 Better Placed Objectives

This section does not warrant its own full heading. We suggest that this section is prefaced by an overarching conservation and new design objectives of ‘Identify Significance’ and ‘Conserve Significance’ and include reference to Burra Charter Conservation Principles. Alternatively, GML suggests that summary objectives should be included within 1.2 About this Guide, and all introductory Better Placed references should be kept in a single section and 2.2 should be enhanced with overarching conservation principles.

There is nothing here about protecting and understanding significance. This is key to designing for heritage places. This section should be deleted as it is relevant only at a high level.

Only Better Placed Objective 1 ‘Better Fit’ is specifically relevant to context, but the case study doesn’t provide enough detail to replace Design in Context. Perhaps it should refer to it.

The rest of the Better Placed objectives are more general, and some intangible. Perhaps reference to the Burra Charter would help align these more closely with heritage industry concepts.

Better for Community—is this section still about buildings? Moree Baths needs a description about the work undertaken to this heritage place and the impact this had on the community. It sits at odds with the other case studies and seems to be very tokenistic. Other examples of places of importance to Aboriginal people might include Tranby in Glebe or the Cyprus Hellene Club or landscape areas and archaeological sites.

2.4 Design Processes for Heritage

As above, consider aligning or relating the processes and Better Placed objectives to the Burra Charter to help align more closely with heritage industry concepts.


Part Three—Explaining Heritage

Section Comment

General Comments GML would suggest re-ordering this section, and placing it after Section 2.2 which would flow better into Section 2.4.

3.1 Heritage Policy in NSW

Australia ICOMOS and the Burra Charter

NSW Heritage Division Policies

3.2 Heritage Lists and Gaining Approval

Lists, LEP and DCPs

3.3 What is Significance and How is it Assessed?

Investigate Significance (Research and Place Investigation)

Assess Significance (Statement of Significance)

Heritage Documents: Managing Significance and New Design

Conservation Management Plans and Strategies

Statement of Heritage Impact

3.5 Regulations and Planning

3.1 Heritage Lists This section has ‘heritage lists’ and ‘gaining approval’ content. Gaining approval may be better located in Section 3.4, or include approval in the heading.

No mention of State Significant Development processes.

Consistency in references—NSW Heritage Act Criteria mentioned on p 51 and as the Heritage Council of NSW criteria on p 52.

3.3 Heritage Documents

Subheadings are not consistent types of information.

Glossary The glossary at the back of the document should include words in common usage and include broadly accepted meanings.


Suggested Project Examples

Example of Project Analysis Example Range of Images

Tramsheds, Glebe


Spice Alley, Kensington Street Precinct


The Mint, Macquarie Street


Wynyard Stair, Wynyard—Interpretation


Crown 515, Surry Hills