Sydney Modern Gallery

8 December 2017

Director Key Sites Assessments, Planning Services
Department of Planning and Environment
GPO Box 39
Sydney NSW 2001

Dear Director,

Art Gallery of New South Wales Expansion - Sydney Modern - State Significant Development (SSD) 14_6471

National Trust representatives have received a number of briefings at the Art Gallery of NSW by the Sydney Modern Project Team, its consultants and architects and thanks the Art Gallery of NSW for this opportunity. There have been a number of improvements as the plans have progressed and some of the Trust's criticisms appear to have been taken on board.

However, the Trust firmly holds the view that the updated Conservation Management Plan for the Royal Botanic Gardens & Domain should have been made publicly available before any Development Application was lodged. This CMP would then have informed the Development Application and associated documentation such as a Heritage Impact Statement and Environmental Impact Statement. This view was put to the Art Gallery of NSW on several occasions but the Development Application was lodged without an accompanying Conservation Management Plan. In the Trust's view, this is an extraordinary and inappropriate situation.

It is essential that there be a Conservation Management Plan for the Art Gallery Site indicating its relationship, to and in, its context and setting, which includes the Domain and the Royal Botanic Gardens. This "first step in the process" is fundamental as a Conservation Management Plan provides parameters to guide initial decision-making on:

(1) are there any areas which may be, on further investigation, be appropriate for development;

(2) what form and scale might such development take;

(3) what are the likely impacts of such development; and

(4) how the impacts are to be managed.

The Royal Botanic Gardens, the Domain and the Art Gallery need to be considered as a single entity, with each part being an essential piece in the mosaic of the historic precinct bounded by Macquarie Street, the Opera House, the Harbour, Government House, Woolloomooloo Finger Wharf, the Register General's Department , the Cathedral, the Museum and Hyde Park. This is a Precinct that ought to be declared under the State Environmental Planning Policy (State Significant Precincts) 2005 given that sites such as the Opera House and Barrangaroo are on this Planning Policy.

The Trust also holds the long standing view that there should be no further net loss of open space in the Royal Botanic Gardens / Domain for the construction of new development.

The Heritage Impact Statement prepared by GML Heritage summarises the main impact on the Royal Botanic Gardens and the Domain: -

"The main adverse heritage impacts relating to the Royal Botanic Gardens and the Domain relate to the construction of the proposed Sydney Modern Buildings over a landscaped area of the site...."

The Royal Botanic Gardens and Domain Landscape Conservation Area was listed on the National Trust Register in May, 1976 recognising it as the second oldest botanic gardens in the southern hemisphere (1816) and for containing many important structures and memorials from early Colonial times when it formed part of the Governor's (Phillip's) Domain. The listing noted that the Gardens layout was exceptionally important.

The Art Gallery of New South Wales was listed on the National Trust Register in April, 1979 as forming a substantial cultural landmark in Sydney and for its strongly classical facade of rich detail that has continued the building tradition in the former Governor's Domain of eclectic masonry structures set in park-like settings. The Royal Botanic Gardens and Domain was listed on the State Heritage Register in April 1999. The NSW Art Gallery has not yet been listed on the State Heritage Register and the National Trust has raised this omission with the Art Gallery of NSW and State Government at the highest levels.

The proposed development involves loss of public open space even though the brief for the most recent Management Plan required that there should be no net loss of open space with any new development. There appears to be no clear strategy for mitigating this loss of public open green space. The Trust opposes any loss of public open space.

At the very least the Royal Botanic Gardens Trust needs appropriate and significant contribution for the loss of so much open space and the NSW Government needs to make a public commitment on this as soon as possible.

Comparisons with the National Gallery of Victoria, in terms of floor space, are not necessarily valid as the National Gallery of Victoria is spread over two sites. This raises the question of a new Sydney Modern beyond the Domain / Royal Botanic Gardens or the alternative development of the site to the south-east of the present buildings. It should be noted that Melbourne's equivalent public open spaces to Sydney's Domain have not suffered development pressures. New major building developments should be sited in the Sydney CBD or at a site where vital green space is not compromised.

The Trust continues to urge the investigation of alternate sites for the Sydney Modern proposal such as the `void' beneath the Barangaroo Headland.

The Trust considers there are major problems with the proposed development in the Domain. These include: -

* The present proposal would result in a significant reduction in the area of "open space" and have major impacts on the presentation and setting of the historic building, especially the ability to see and appreciate the building in the round. The `shelter' structure is intrusive and bears no relationship to the existing Gallery in its form and alignment. It appears to be unnecessarily large and would `compete' strongly with the historic building particularly in the manner in which it impacts on the northern elevation.

* The building on the Land Bridge (Entrance Plaza) and the adjoining building to the north opposite Woolloomooloo Gate (Entrance Pavilion) have a setback of respectively 5.75m and 9.95m from Mrs Macquaries Road. The Entrance Pavilion has a height of between 7m and 8m above the road. These buildings are too close to the road, and by being too far forward, impact on the view cone from the north. The white colour and the large reflective glass windows are too stark for the garden environment. Most importantly the proposal confuses the significant entry experience to the existing building. These buildings should be further set back behind the line of the front façade of the historic Art Gallery building.

* The footprint for the proposal is massive. The "site area" is more than double the existing Art Gallery of New South Wales footprint.

The National Trust recognises that a Sydney Modern proposal would extend the number of cultural assets for Sydney and increases visitation and revenue generation for the NSW Art Gallery. The Trust strongly supports such a cultural and social objective but believes that the proposal should not be sited in the Domain.

The re-use of the former oil depot for functions associated with the NSW Art Gallery is supported by the Trust. However, the current proposal is intrusive, involving the removal of many of the original historic piers. Any redevelopment of this facility should retain all original fabric intact.

The National Trust is concerned that the NSW Government has made no commitment to increase recurrent funding for the AGNSW. Without such a commitment, the proposed expansion could only be sustained by shifting the focus still further towards corporate functions and away from care for the collection and the program.

A commitment of $244 million in public money towards construction costs appears to have been made without considering the broader cultural needs of the people of the State of NSW. Many cultural institutions remain starved of funds. New South Wales still lacks a dedicated museum of Aboriginal history.

Parramatta remains the only major city in Australia without a public gallery - It would be better for an Art Gallery of NSW satellite to be built in Parramatta and the Powerhouse Museum maintained at its historic and most suitable location in Ultimo.

Yours sincerely


Graham Quint
Director Advocacy

Please see attachment for submission.

I object to the proposal for construction of the Sydney Modern Gallery for the following reasons:

1. Inappropriate design and placement of a new structure adjacent to the existing gallery. I have been fortunate to have spent time in galleries in the UK, Europe and the United States; galleries with walls for paintings not for taking in the view. No gallery had glass walls as the Sydney Modern design proposes. The walls of a gallery are for display of paintings, not for providing views of the external environment. Clearly this design demonstrates the decision of The Trust to provide an attractive space for hire for private functions raising revenue for the Gallery which is no longer adequately financed by the Government.
2. Building on land which is publicly owned and administered by the Botanic Gardens and Domain Trust is unacceptable. Loss of open space and removal of 140 trees is a shameful proposal. The offer of financial compensation could never repay for the loss of open space and removal of trees. Is this really an offer from the Department of Environment?
3. Mrs Macquarie's Road and the Woolloomooloo Gate should not be impacted by a transfer to the Art Gallery.
4. There is no point in pursuing construction of a new building when an increase in recurrent funding for The Gallery is not on offer from the Government. This really underlines the need for the Director of The Gallery to focus on advocacy for sustainable finance to support the curatorial and acquisitions functions of The Gallery.
5. The administration of the existing gallery should concentrate on providing exhibitions of existing and overseas collections and the government should have regard for the need of a gallery in the Western Suburbs.

Please do not proceed with this ill-conceived proposal.


The Honourable Ann Symonds AM
Friend of the Botanic Gardens and Member of The Art Gallery

Please find attached as PDF file submission opposing the development of Art Gallery of NSW Sydney Modern building.
The file is 40 pages long, in PDF format as required and named: "Submission regarding extension of Art Gallery of NSW, October 2017 ver 1"
If the file does not load correctly or is defective otherwise, please contact my email to resend the file.
Thank you

Director
Key Sites Assessments, Planning Services
Department of Planning and Environment
GPO Box 39, Sydney, NSW 2001


12 December 2017


LETTER OF OBJECTION TO PLANNED REDEVELOPMENT OF AGNSW - HERITAGE


Dear Director of Key Sites Assessments

I am writing to object to the likely adverse heritage impacts associated with the redevelopment of the Art Gallery of New South Wales (AGNSW), entitled "Sydney Modern" and advertised at:
http://www.planning.nsw.gov.au/Assess-and-Regulate/Projects/Sydney-Modern/Documents . In my opinion the consent authority should not approve of this development in this location.

I am a heritage consultant based in Sydney, previously employed at NSW Heritage Office/ Heritage Branch/ Heritage Division where I was a project manager for the World Heritage nomination of the Sydney Opera House in 2005. During the rest of my employment there I was a listings officer for the State Heritage Register (SHR)--including working on a curtilage extension for the Royal Botanic Gardens to include the Tarpeian Way in 2011. More recently, while working for the eminent heritage architects Clive Lucas Stapleton, I was responsible for an interpretation plan for NSW Parliament House and the conservation plan history for Hyde Park Barracks, both major historic sites located adjacent to the Domain. As an independent researcher, I recently undertook a large oral history project with the National Library of Australia about the drafting of the Burra Charter--Australia's widely accepted guideline for heritage practice. My training was as an Australian art and architectural historian and during my academic years I co-authored two books on Australian women architects with two eminent built environment academics (Professor Robert Freestone and Professor Julie Willis). I have sat on the National Trust's Built Heritage Committee since 2008. My particular expertise lies in Australian historical place research, the history of Australian heritage practice and heritage significance assessment.

In my opinion the advertised "Sydney Modern" redevelopment of the AGNSW will have major adverse heritage impacts on both the surrounding Royal Botanic Gardens & Domain and the AGNSW itself. The Heritage Impact Assessment (HIS) by GML Heritage, which accompanies the proposed redevelopment, fails to adequately acknowledge the "significance" of both places and thus does not provide an adequate account of the likely adverse heritage should the plan go ahead in this form.

The GML HIS states, accurately but incompletely, that the AGNSW is listed on the local heritage register of the City of Sydney LEP (GML, 2017, p61). To be fair, the report goes on to offer a much more comprehensive statement of the place's heritage significance than the local listing's "statement of significance" but it does not acknowledge the place as certainly meeting the threshold for "state" significance and possibly meeting the threshold for "national" significance. In order to properly inform its readers, the HIS should also have alerted us to the fact that for many years the AGNSW has been earmarked for state listing on the SHR and the affected area of the Royal Botanic Gardens & Domain has been earmarked for national listing on the National Heritage List. It is on the public record that the Heritage Council of NSW declared, at its meeting of 2 September 2011, that the AGNSW was a place which is "indisputably of State heritage significance" (along with Sydney Grammar School, Sydney Hospital and Royal Australian College of Physicians). At that meeting the council delegated its authority to the Director of the Heritage Division progress the listing of these four places on the SHR--a delegation which has not yet been exercised.

At that meeting in 2011, Heritage Council of NSW recognised the Royal Botanic Gardens & Domain as part of the suite of places in the vicinity of Macquarie Street under investigation for inclusion in the large central Sydney precinct listing for National Heritage Listing then called "Colonial Sydney" (see minutes at: www.environment.nsw.gov.au/resources/heritagebranch/heritage/heritagecouncil/hcminutes2011September374.pdf, p4).
This national nomination is now being progressed under the title, "Governor's Domain and Civic Precinct." Its assessment documents may be viewed on the Australian Heritage Council's webpage at: www.environment.gov.au/heritage/organisations/australian-heritage-council/national-heritage-assessments/governors-domain-and-civic-precinct-proposed-national-heritage-listing . The draft map for this nomination shows the AGNSW as excluded from the listing but the proposed site of its Sydney Modern extension as included within the proposed curtilage (see attached map).

On 4 May 2016 an early version of the Sydney Modern redevelopment proposal was presented to the Heritage Council of NSW, presumably because it was understood that the council had an interest in the heritage management of the AGNSW as a place slated for listing on the SHR. The Heritage Council minutes noted (in part):
* "The importance of an analysis of the impact to the landscape, views and access, particularly in relation to the Domain and RBG.
* "The importance of maintaining the main entrance.
* "Concern about converting public space to private space and the setting of a precedent.
(www.environment.nsw.gov.au/resources/heritagebranch/heritage/heritagecouncil/council-minutes-may2016-429.pdf)

In June 2017 the Australian Heritage Council's latest publication of places for "priority assessment" noted "Colonial Sydney" at the top of the list and gave it an assessment timeframe of 30 June 2018 (www.environment.gov.au/system/files/pages/8ac00639-6069-454e-a191-e6b8a3eed9a2/files/fpal-amalgamated-june2017.pdf). A press release by Josh Frydenberg, Federal Minister for the Environment and Energy, dated 10 September 2017, confirmed:
"The [Australian Heritage] Council is also currently assessing Colonial Sydney for National Heritage listing . . . The Minister has requested the Council prioritise this assessment and consider it as part of the broader review of ensuring the protection of Australia's places and monuments that relate to our early colonial history." (www.environment.gov.au/minister/frydenberg/media-releases/mr20170910.html)

Most recently the Heritage Council of NSW's State Heritage Register Committee resolved, on 28 September 2017, that the Heritage Division should progress the SHR listing of the AGNSW by consulting with its owner to develop site specific exemptions prior to the NOI (Notice of Intention to List report). (http://www.environment.nsw.gov.au/resources/heritagebranch/heritage/heritagecouncil/state-heritage-register-committee-minutes-september2017.pdf)

It is good heritage practice that a place under investigation for a higher level heritage listing should be treated as if it already has that higher heritage listing status. Certainly the owner-managers of both the AGNSW and the Royal Botanic Gardens & Domain have been well informed of these state and national heritage listing nominations over the years and they should have informed their heritage consultant GML. Even if they hadn't, GML would be independently aware of the Colonial Sydney listing because they have been engaged to provide expert advice to it. (For example, I read GML's draft history for the Colonial Sydney listing last year when working on Hyde Park Barracks, another property affected by the national nomination.)

It is a fundamental principle of the Australia ICOMOS Burra Charter that the heritage significance of a place be properly understood when considering making changes to it. Yet the GML HIS, dated November 2017, described only the established legislative status of the two affected places but did not mention these imminent state and national listings affecting both places. It did not reference the research and analysis about the two places that must have been undertaken in relation to both state and national listing proposals. The GML HIS has not presented a proper description of the heritage status or analysis of the heritage significance of the AGNSW or the Royal Botanic Gardens & Domain. Therefore its consequent analysis of the heritage impacts of the proposed Sydney Modern development cannot be relied upon.

Like other critics of the proposal, I object to the loss of open public space from the Domain and Royal Botanic Gardens. I believe that this alone is a major and unacceptable heritage impact on a place of recognised local, state and national significance. Moreover, the latest submission by the National Trust of NSW (to the Director, Key Sites Developments, dated 8 December 2017) observed there are no plans to increase recurrent funding to the AGNSW although the redevelopment will more than double the space of the gallery. This suggests the new space will have to pay for itself through corporate and other private functions. This issue seemed to occurred to the Heritage Council of NSW in 2016 when they expressed "Concern about converting public space to private space" (see above). If so, I consider this to be a further major and unacceptable heritage impact. Thirdly I consider the undermining of the functioning and prominence of the historic entrance of the AGNSW to be another major and unacceptable heritage impact.

Sincerely

(Dr) Bronwyn Hanna

cc: Bruce Donald AM
[email protected]

See attached letter.

Please see attached submission

IMPORTANT: Sincerest apologies. The previous two versions of my submission had pages which were somehow missing or corrupted in the process of sending them. If you could disregard the two previous PDF submissions made by Andrew Andersons and take this as the final document.

Apologies again and please feel free to contact me if there are any issues.

RE: Development Application SSD 6471 - Sydney Modern, Art Gallery of NSW, Sydney

To Whom it May Concern

Thank you for the opportunity to make a submission in support of the Art Gallery of New South Wales's recent Sydney Modern Project State Significant Development Application. This submission - in the attached PDF document - expresses strong support for this major project from the Art Gallery Society of New South Wales, the Art Gallery's membership body.

The Art Gallery Society supports the Sydney Modern Project because it will enable the people of NSW to enjoy more outstanding international art exhibitions; will offer increased display space for the Gallery's significant permanent collection; allow the Society to grow a more diverse membership; attract greater cultural tourism to NSW, and ensure the Gallery remains vibrant and relevant for many generations to come.

Yours sincerely,


Brian Ladd Ron Ramsey
President Executive Director
Art Gallery Society of NSW Art Gallery Society of NSW

Objection to the Sydney Modern Development proposal - DA SSD6471 3/11/17 by
John David Chesterman AM B.Arch dipT&CP LFAIA FPIA
I acknowledge that some of the material and opinion set out below is included in an objection co-authored with Bruce Donald, Gillian Appleton and Ros Andrews.
I object strongly to the proposed location and consequent design of the Art Gallery of NSW's proposal for its Sydney Modern Gallery - on the grounds that it would seriously damage the highly valued visual quality of:
* The setting of the existing historically significant Art Gallery building,
* The setting of the Woolloomooloo Gate to the Botanic Garden,
* The character of Mrs Macquarie's Road.
* The view from the Art Gallery to The Harbour
and would break the continuous tree line that forms the skyline of the Domain ridge when viewed fro the East.
I have carried out a detailed review of the Visual Impact Assessment (VIA) prepared as part of the EIS on the Proposal, which in my opinion, grossly understates the Proposal's adverse impacts.
As a long time premium member of the Art Gallery Society, I am supportive of the Art Gallery expanding its capacity, but not in a way that is so destructive of its surroundings, of The Domain and to itself.
I believe that there other ways of achieving its commendable objectives. To my knowledge alternatives have not (at least publicly) been adequately canvassed and they are briefly discussed below.
The Land-bridge
Following the construction of the Cahill Expressway across Circular Quay, Fig tree Avenue (across the Domain adjacent to northern boundary to the Botanic Garden) was significantly widened, with a bridge across it carrying Mrs Macquarie's Road. The Art Gallery sat at the edge of a deep cut down to the new road.
The construction of the Eastern Distributor (the ED) in the late1990's required further upgrading of this roadway. The ED was initially proposed as a surface or shallow-cut six-lane motorway from Macquarie St to the Airport. Its announcement caused a considerable public outcry and the government halted the project for review.
I was appointed by RTA as their urban design consultant to review the initial design submitted by the already selected design-build contractor for the project and assist in designing and negotiating a proposal that was more suited to its various contexts.
The notion of a tunnel from Woolloomooloo to the already existing land-bridge parallel to Macquarie Street was, at my instigation, investigated. However due to a subterranean geological fault it was found to be extremely costly - so the next best (by no means cheap) solution, a land-bridge to the north of the Gallery and the use of noise walls became the adopted solution where the motorway crosses the Domain.
The form of the land-bridge closely follows the natural contours of the Domain prior to the construction of Fig-tree Avenue, but the location of trees upon it was influenced by structural logic. An existing stand of trees to its north was reinforced with further planting.
The Gallery and the RBG management were both consulted during the design process. The capital cost of the land-bridge is being recovered by user tolls.
It was built largely to protect the natural context of the Art Gallery Building - not for its expansion.
The proposed Sydney Modern Building
The Gallery conducted a limited design competition to select an architect and a design for Sydney Modern. The entries can be seen on the Gallery's website. The winning SANNA proposal has the virtue of relative modesty that probably explains its selection. However, the VIA (An Appendix to the EIS) clearly illustrates the substantial and adverse changes of character that it would have, but interprets these impacts as only "Moderate." This is hard to credit.
Before a considerable amount of money is committed to a site and design that are not in the public's and Gallery's best interests a broadly based publically accessible comparative analyses of it and three alternatives should be carried out. The alternatives should include:
1. A four-storey structure attached to the Eastern end of the existing gallery building, where there is plenty of space that is of very little functional or recreational value to the Domain. The Gallery's Eastern façade has been substantially altered over time and is not, as incorrectly claimed in the EIS, a Vernon façade.
Entered at the Eastern end of the long central gallery in the building, Sydney Modern could have a clearly identified image. The new building would be prominent and could be linked at each level to the Gallery and share existing service access. It would enjoy excellent views that would include the Harbour (better than those from the proposed site).
2. Building within the splendid huge space under the Headland Park at Walsh Bay as part of the cluster of cultural institutions in this area. Without the need to build in a manner that keeps water out, generous and well-finished spaces could be afforded. A Metro station is planned immediately adjacent to this space.

3. Decentralizing to a location such as Paramatta - which could have considerable social benefits.


Comments on the Sydney Modern VIA 4/12/17
The Clouston VIA is a long and thorough document containing good images, much of which is, however, of little relevance because in most of the more distant and complex views analyzed, the Sydney Modern Proposal is of insignificant size and its visual impacts predictably low, or it can barely be seen.
However, the VIA's analyses of critical, mostly close up, views (11 - 20) that are in or of an area of high heritage and landscape value, because of the criteria applied in their analyses, reaches unbalanced conclusions that are inconsistent with the "before and after" images provided.
The bulk of the proposed building is misleadingly said to "cascade lightly" down to the Oil tanks. However where it is:
- adjacent to Mrs Macquarie's Road,
- seen from the Land-bridge lawn
- seen from within the Art Gallery building, and
- seen from the Woolloomooloo Gate to the Botanic Gardens
it would appear as white, largely un-articulated, boxes replacing a substantial stand of trees and views to The Harbour (and a glass-roofed entry structure that relates to nothing and will be of limited utility in this exposed location).
The Comparative Analyses of Visual Impacts on the Table below demonstrates why the visual impact of the Sydney Modern proposal is unacceptably HIGH.
The EIS asserts that the proposed building "speaks of the future". It would be more accurate to say that it shouts about it. The visual relationship between the existing Art Gallery Building and its important setting and the proposed Sydney Modern Building is one of extreme and intrusive contrast.
It is also worth noting that the claimed views from the terraces of the proposed building would be severely compromised or completely blocked by the substantial substation building to its north.
VP VIA PAGES
LOCATION & DESCRIPTION OF CHANGE EIS ASSESSMENT THIS ASSESSMENT
11 50-51 Opposite the Woolloomooloo RBG Gate, this view demonstrates an unsympathetic total change in character MOD HIGH
12 53-54 View of gallery from road looking Sth is almost totally blocked MOD HIGH
13 55-56 View East from road across Landbridge is largely obscured HIGH HIGH
14 56-57 From the Pavilion Café a large sector of the view is substantially changed from being natural (and also a distant view) to that of a large modern building. MOD HIGH
15 58-59 Views 15, 16 & 17 are experienced by pedestrians arriving at AGNSW on foot across the Domain MOD MOD/HIGH
16 60-61
and by motorists and pedestrians using Art Gallery road and Mrs Macquarie's Road HIGH
17 62-63 At present the Art Gallery building is seen within the natural setting provided by the stand of trees to the north of the land-bridge lawn. This visually significant stand would be destroyed and replaced by the proposed Sydney Modern. MOD/
HIGH HIGH

18 64-65 As can be seen, a view of the Harbour is eliminated from the most important public outlook from AGNSW and in a most unsympathetic manner MOD HIGH
19 66-67 It is unclear why the existing trees on the Land-bridge have been eliminated (vegetation to be removed) as they are located in the only position (over structure) where they can enjoy adequate soil depth. This is not a significant façade of the AGNSW building. The new trees shown are unlikely to be feasible. MOD MOD/HIGH
20 68-69 It is very unfortunate that the continuity of tree-line on the eastern ridge of the Domain (an important feature) would be destroyed - as can be seen from this view, and probably also from view-points further to the east. MOD HIGH

ASSESSMENT OF VISUAL IMPACTS using the images from critical View Points provided in the submitted Visual Impact Assessment - as shown on the pages noted in Column 2.

To whom it may concern

The attached PDF submission from the Art Gallery Society of NSW in support of the Sydney Modern Project replaces the earlier PDF version of the same document forwarded by Mr Brian Ladd, President of the Art Gallery Society of NSW earlier today.

Ron Ramsey
Executive Director
Art Gallery Society of NSW

See attached file

Please see attachment

Objection to the Sydney Modern Development proposal " DA SSD6471 3/11/17 by
John David Chesterman AM B.Arch dipT&CP LFAIA FPIA

I acknowledge that some of the material and opinion set out below is included in an objection co-authored with Bruce Donald, Gillian Appleton and Ros Andrews.

I object strongly to the proposed location and consequent design of the Art Gallery of NSW’s proposal for its Sydney Modern Gallery - on the grounds that it would seriously damage the highly valued visual quality of:
• The setting of the existing historically significant Art Gallery building,
• The setting of the Woolloomooloo Gate to the Botanic Garden,
• The character of Mrs Macquarie’s Road.
• The view from the Art Gallery to The Harbour
and would break the continuous tree line that forms the skyline of the Domain ridge when viewed fro the East.

I have carried out a detailed review (attached) of the Visual Impact Assessment (VIA) prepared as part of the EIS on the Proposal, which in my opinion, grossly understates the Proposal’s adverse impacts.
As a long time premium member of the Art Gallery Society,

I am supportive of the Art Gallery expanding its capacity, but not in a way that is so destructive of its surroundings, of The Domain and to itself.
I believe that there other ways of achieving its commendable objectives. To my knowledge alternatives have not (at least publicly) been adequately canvassed and they are briefly discussed below.

The Land-bridge
Following the construction of the Cahill Expressway across Circular Quay, Fig tree Avenue (across the Domain adjacent to northern boundary to the Botanic Garden) was significantly widened, with a bridge across it carrying Mrs Macquarie’s Road. The Art Gallery sat at the edge of a deep cut down to the new road.

The construction of the Eastern Distributor (the ED) in the late1990’s required further upgrading of this roadway. The ED was initially proposed as a surface or shallow-cut six-lane motorway from Macquarie St to the Airport. Its announcement caused a considerable public outcry and the government halted the project for review.
I was appointed by RTA as their urban design consultant to review the initial design submitted by the already selected design-build contractor for the project and assist in designing and negotiating a proposal that was more suited to its various contexts.
The notion of a tunnel from Woolloomooloo to the already existing land-bridge parallel to Macquarie Street was, at my instigation, investigated. However due to a subterranean geological fault it was found to be extremely costly â€" so the next best (by no means cheap) solution, a land-bridge to the north of the Gallery and the use of noise walls became the adopted solution where the motorway crosses the Domain.
The form of the land-bridge closely follows the natural contours of the Domain prior to the construction of Fig-tree Avenue, but the location of trees upon it was influenced by structural logic. An existing stand of trees to its north was reinforced with further planting.
The Gallery and the RBG management were both consulted during the design process. The capital cost of the land-bridge is being recovered by user tolls.
It was built largely to protect the natural context of the Art Gallery Building â€" not for its expansion.

The proposed Sydney Modern Building
The Gallery conducted a limited design competition to select an architect and a design for Sydney Modern. The entries can be seen on the Gallery’s website. The winning SANNA proposal has the virtue of relative modesty that probably explains its selection. However, the VIA (An Appendix to the EIS) clearly illustrates the substantial and adverse changes of character that it would have, but interprets these impacts as only â€oeModerate.” This is hard to credit.

Before a considerable amount of money is committed to a site and design that are not in the public’s and Gallery’s best interests a broadly based publically accessible comparative analyses of it and three alternatives should be carried out.

The alternatives should include:

1. A four-storey structure attached to the Eastern end of the existing gallery building, where there is plenty of space that is of very little functional or recreational value to the Domain. The Gallery’s Eastern façade has been substantially altered over time and is not, as incorrectly claimed in the EIS, a Vernon façade.
Entered at the Eastern end of the long central gallery in the building, Sydney Modern could have a clearly identified image. The new building would be prominent and could be linked at each level to the Gallery and share existing service access. It would enjoy excellent views that would include the Harbour (better than those from the proposed site).

2. Building within the splendid huge space under the Headland Park at Walsh Bay as part of the cluster of cultural institutions in this area. Without the need to build in a manner that keeps water out, generous and well-finished spaces could be afforded. A Metro station is planned immediately adjacent to this space.

3. Decentralizing to a location such as Paramatta â€" which could have considerable social benefits.
Comments on the Sydney Modern VIA

The Clouston VIA is a long and thorough document containing good images, much of which is, however, of little relevance because in most of the more distant and complex views analyzed, the Sydney Modern Proposal is of insignificant size and its visual impacts predictably low, or it can barely be seen.
However, the VIA’s analyses of critical, mostly close up, views (11 â€" 20) that are in or of an area of high heritage

and landscape value, because of the criteria applied in their analyses, reaches unbalanced conclusions that are inconsistent with the â€oebefore and after” images provided.
The bulk of the proposed building is misleadingly said to â€oecascade lightly” down to the Oil tanks. However where it is:
- adjacent to Mrs Macquarie’s Road,
- seen from the Land-bridge lawn
- seen from within the Art Gallery building, and
- seen from the Woolloomooloo Gate to the Botanic Gardens
it would appear as white, largely un-articulated, boxes replacing a substantial stand of trees and views to The Harbour (and a glass-roofed entry structure that relates to nothing and will be of limited utility in this exposed location).
The Comparative Analyses of Visual Impacts on the attached table demonstrates why the visual impact of the Sydney Modern proposal is unacceptably HIGH.
The EIS asserts that the proposed building â€oespeaks of the future”. It would be more accurate to say that it shouts about it. The visual relationship between the existing Art Gallery Building and its important setting and the proposed Sydney Modern Building is one of extreme and intrusive contrast.
It is also worth noting that the claimed views from the terraces of the proposed building would be severely compromised or completely blocked by the substantial substation building to its north.

See attached submission.

Please see attached submission.

Please see submission attached.

Please see submission attached.

Please see submission attached.

As a West facing resident of Woolloomooloo's Finger Wharf, I am very concerned about the visual impact Sydney Modern will have upon the area for myself, other residents, the local businesses, and visitors to the area. The views of the City from the Wharf are some of the finest in Sydney and the plan, as it is, will be extremely detrimental to these views.

I have the following concerns:

- The new structure is prominent when viewed from the Wharf and will dominate the view.

- The new structure will reduce privacy and make the Wharf feel `overlooked'

- The new buildings are extremely large and above tree height.

- The colour of the new structure is stark white with significant areas having sheer walls and no windows. This is not in keeping with the area, will not blend in and will be very unpleasant to view from the Wharf.

- Many large and mature trees are being removed for the new building. These trees form an integral part of the current viewpoint towards the city. Action appears to have been taken to reduce the impact of the new buildings on the views from the Botanic Garden. This appears to have been remedied by moving trees to the Botanic Garden side at the expense of views from the Wharf.

- Visitors to the new building will create significant noise for residents of the Wharf, especially as there is a large, interrupted open space between Sydney Modern and the Wharf. This will be especially bad during large events.

I propose the following remedial actions:

Colours - more natural / designed to blend in / complement the existing buildings.

Gardens - much more extensive planting around the building, including more trees to break up the buildings and to allow the buildings to blend in more on the wharf-side.

Rooftop gardens - use extensively, in a similar way to the gardens on top of the Lincoln Crescent terraces site, including trees to reduce the visual impact of the building.

Green curtains - foliage to grow down the building, again to make it blend in, especially on sections of the sheer walls.

In summary, the buildings need to be surrounded by greenery, especially mature trees. This is particularly lacking on the Wharf side of the building. The structure also needs to use more subtle colours to make it blend into the current landscape and existing buildings.

There is an opportunity to make Sydney Modern have a positive impact to the area and the heritage views from the Wharf to the City. However, this requires the building to blend in and complement the local setting.

The current plan will dominate and overwhelm the existing view from the wharf to the City and will irreparably harm one of the finest views in Sydney.