What Changed in the 2023 NSW Heritage Guidelines

In 2023 the Heritage Council of NSW reissued the two guidelines that govern most heritage reports prepared as a condition of development consent in New South Wales: the guideline for Statements of heritage impact (often abbreviated SOHI) and the guideline for archival recordings of heritage items (often abbreviated PAR). Together they replaced four older publications — one from the 1990s and three from the early 2000s — that consultants, councils and heritage officers had been working from for two decades.

The substance of NSW heritage practice has not changed. The statutory framework (the Heritage Act 1977, the relevant Local Environmental Plan, and any Conservation Management Plan) still governs what can and cannot happen to a heritage item. What changed is the document a council, the Land & Environment Court or Heritage NSW expects to receive as evidence that an applicant has properly considered the heritage significance of the place. This article is a short, plain-English guide to the new guidelines for property owners, architects and builders.

The 2023 Statement of Heritage Impact Guideline

The 2023 guideline Statements of heritage impact replaces the 1996 and 2002 editions. It consolidates the two older documents into a single reference and sharpens the four core questions a SOHI is expected to address:

• —What aspects of the proposal respect or enhance the heritage significance of the item or area?
• —What aspects could have a detrimental impact on the heritage significance, and why are they a necessary part of the proposal?
• —What sympathetic solutions have been considered and discounted, and why?
• —How does the proposal relate to the relevant Conservation Management Plan, LEP heritage provisions, DCP and the NSW Heritage Manual?

The 2023 guideline also formalises expectations around the level of detail proportionate to significance: a SOHI for minor works to a locally listed item is expected to be shorter and more focused than a SOHI for major works to a State Heritage Register item. That proportionality was implicit in the older guidelines but is now explicit, which gives both consultants and consent authorities a clearer test for whether a report is fit for purpose.

The 2023 Photographic Archival Recording Guideline

The 2023 guideline Guidelines for preparing archival recordings of heritage items as a condition of consent replaces two older publications: How to prepare archival records of heritage items (1998) and Photographic recording using film or digital capture (2006). The substantive changes are:

• —Clear three-tier model. The 2023 guideline distinguishes simple, measured and comprehensive recordings, and explicitly assigns each level to a category of works (minor works, moderate works, major works or demolition). This makes the consent authority’s job — deciding which level to require — less subjective.
• —Digital-first capture. The 2006 publication was written when film was still in regular professional use. The 2023 guideline assumes digital photography and provides updated technical expectations (resolution, format, colour space, metadata) for the resulting image catalogue.
• —Lodgement clarified. The new guideline is more specific about where the bound report and digital deliverable are to be lodged, and what council and Heritage NSW expect to receive before construction works can commence.

What Changed in Practice for Property Owners and Architects

For most owners of a heritage item or a property within a Heritage Conservation Area, the 2023 updates are not a reason to reconsider a project that was already in planning. The kinds of works that need a SOHI are the same. The kinds of works that trigger a PAR condition on consent are the same. What is different is that:

• —Reports prepared against the older guidelines are increasingly being flagged by council heritage officers as out of date. Some councils now ask for a re-issue when a SOHI references the 1996 or 2002 publications, even if the substance is sound.
• —The proportionality test in the 2023 SOHI guideline tends to produce shorter, sharper reports for minor works. That is good news for owners of locally listed terraces and contributory buildings — the report you need is more focused than it used to be.
• —The clearer three-tier PAR model means consent conditions are easier to interpret. If the condition says ‘measured recording’, the deliverable list is now well defined, which reduces the risk of a recording being rejected after the fact.

What Still Applies — Burra Charter and the NSW Heritage Manual

The 2023 guidelines update the form of the documents, not the underlying methodology. Two earlier reference works continue to sit underneath them:

• —The Burra Charter (Australia ICOMOS, 2013 revision) remains the foundation of conservation practice in Australia. Its principles — do as much as necessary and as little as possible, retain significant fabric, make new work distinguishable from the original — are referenced throughout the 2023 NSW guidelines and continue to govern conservation decisions on significant items.
• —The NSW Heritage Manual continues to set out the seven NSW Heritage Assessment Criteria (a–g) used to assess significance, and the methodology for preparing a Conservation Management Plan. The 2023 SOHI guideline references the Manual rather than replacing it.

The official publications are available on the Heritage NSW website at environment.nsw.gov.au/topics/heritage.

Where Trace Heritage Sits

Trace Heritage prepares Statements of Heritage Impact and Photographic Archival Recordings to the 2023 NSW guidelines as a matter of course. Director Charlotte Simons holds a Master of Heritage Conservation from the University of Sydney, has served as a Council Heritage Officer in NSW local government, and is an Expert Witness in the NSW Land & Environment Court. If you have a development application on a heritage item or within a Heritage Conservation Area and want a consultant who works to the current guidelines from the first draft, please get in touch.