A strong heritage project in New South Wales depends on one key document: the Statement of Heritage Impact (SHI) . This report explains how your plans respect the history of your property while allowing for new work. Councils use it to decide if your project can move forward.
When an SHI is clear and complete, approvals often come faster and with fewer questions. When it is weak, you may face delays, higher costs, and extra requests for information.
A Statement of Heritage Impact explains how your proposed works affect a place’s heritage significance and how you will avoid or reduce any potential harm. It is the core document that forms the basis of your heritage application to a local council or Heritage NSW.
At Michael Bell Architects , we have been guiding heritage projects since 1998. With more than 25 years of practice, our team has helped hundreds of homeowners and estate owners across NSW navigate the heritage approvals process. Our work has been recognised with a National Trust NSW award and we have been shortlisted for the Waverley Council Heritage Awards.
Led by Principal Architect Michael Graeme Bell (NSW Registration #6335), we specialise in heritage restoration, conservation, and complex council submissions. We created this guide to share our knowledge with you. It gives a clear step by step roadmap for preparing a professional SHI that councils will respect.
In this guide, you will learn:
- What a Statement of Heritage Impact is and how it fits in the NSW planning system
- When an SHI is required for a Development Application (DA) or s.60 Application
- The key sections and evidence every SHI must include
- How to prepare a complete submission pack and avoid common mistakes
What is a Statement of Heritage Impact (SHI/SOHI)
A Statement of Heritage Impact explains how your proposed works affect a place’s heritage significance and how you will avoid or reduce any potential harm. It is the core document that forms the basis of your heritage application to a local council or Heritage NSW.
In simple terms, an SHI is a report that answers three key questions for council:
- What is important about this place? (Its Significance)
- How will our project affect what is important? (The Impact)
- What have we done to respect its importance? (The Mitigation)
The SHI provides the council's Heritage Officer with a clear, evidence-based story. It proves that you have respected the rules set out in the local Local Environmental Plan (LEP) and Development Control Plan (DCP) . It also shows your design aligns with the national best-practice principles of the Burra Charter . A well-prepared SHI gives the council confidence that your project is a sensitive and well-considered addition to the area.
When is an SHI Required in NSW?
You need an SHI when heritage controls apply—such as a conservation area, a listed item, or works that may affect significant fabric. The requirement is not just for major works; even seemingly minor external changes can trigger the need for an SHI.
Use our Interactive Heritage Pathway Planner below to determine if your project requires an SHI and what kind of application you might need.
Interactive Heritage Pathway Planner
Is your property a listed heritage item OR located within a Heritage Conservation Area (HCA)?
(Check your council's LEP Heritage Map or Section 10.7 Certificate)
An SHI is likely not required.
Unless your works could impact a neighbouring heritage item. It is always wise to confirm your project is exempt before proceeding with any work.
Confirm Your Project is ExemptAre you proposing works beyond minor, like-for-like maintenance?
(e.g., additions, new structures, demolition, painting, fencing)
An SHI may not be required.
However, some councils have specific rules for minor works in heritage areas. It is critical to check your local Development Control Plan (DCP) .
Clarify Your Council's Minor Works RulesIs the property also listed on the State Heritage Register (SHR) ?
Result: SHI Required for Council DA.
Your project needs a Statement of Heritage Impact (SHI) as part of a Development Application (DA) submitted to your local council.
Plan Your Council DA SubmissionResult: SHI Required for State s.60 Application.
Your project needs an SHI (and likely a CMP) as part of a Section 60 Application to Heritage NSW . This is a more complex process than a standard council DA.
Get Help with Your State Heritage ApplicationWho Can Prepare an SHI?
Councils expect an SHI prepared by a qualified heritage consultant or a registered architect experienced in NSW heritage approvals . This demonstrates that the report’s findings are professional, credible, and based on sound conservation principles.
- Heritage Consultant: A specialist in historical research, policy analysis, and significance assessments.
- Registered Architect (with Heritage Experience): An architect brings the critical advantage of seamlessly integrating the SHI's findings into the architectural plans, ensuring mitigation measures are practical and buildable.
Michael Bell Architects : Architect-Led Heritage Expertise
At MBA, our architect-led process ensures your SHI and design are perfectly aligned. With over 25 years of experience and a National Trust NSW award , we provide complete, coordinated documentation packs for heritage approvals across Sydney and regional NSW.
Core Sections of a Strong SHI
A council-ready SHI includes a significance statement, impact and mitigation analysis, LEP/DCP responses, and clear visual evidence. Its structure must be logical and easy for a council assessor to follow.
| Core SHI Section | What It Is & Why It's Needed | Key Evidence Examples |
|---|---|---|
| 1. Site & Proposal Description | Sets the context for the assessor. | Site address, Lot/DP, heritage listing, zoning, brief summary of works. |
| 2. Historical Overview | Establishes the historical narrative of the place. | Historic photos, Parish Maps, title deeds, previous approvals. |
| 3. Statement of Significance | The formal argument for why the place has heritage value. | A summary statement and detailed assessment against NSW Criteria A-G. |
| 4. Impact Assessment | The objective analysis of how the proposal will affect significance. | Analysis of impacts on fabric, form, scale, setting, and views. |
| 5. Mitigation & Justification | Explains how you will minimise harm, referencing the Burra Charter . | Details on material selection, design changes, and commitment to reversibility. |
| 6. LEP/DCP Compliance Table | Proves you have met every relevant local planning control. | A clause-by-clause response table. |
| 7. Conclusion | A final summary that the proposal is justifiable on heritage grounds. | A clear concluding statement. |
Evidence Types You’ll Need (Plans, Photos, Research)
Support every conclusion with labelled photos, scaled drawings, and referenced historic sources tied to specific elements.
- Photographic Schedule: A set of high-resolution, labelled, and dated colour photographs showing the property, its key features, and its context within the streetscape.
- Scaled Architectural Drawings: A full set of plans (site plan, floor plans, elevations, sections) at standard scales (e.g., 1:100, 1:50) showing existing conditions and the proposed changes clearly differentiated.
- Historic Research: Referenced material from sources like the State Library, local council archives, or Trove to support the historical overview and significance assessment.
- Fabric Analysis: A "fabric map" or annotated elevation can be used to identify original, early, and intrusive (non-significant) building materials and forms.
Heritage Significance Criteria (A–G) — How to Apply Them
You must assess your property against each of the NSW heritage significance criteria (A–G) to build a robust argument.
- (a) Historical: Its role in the pattern of local history.
- (b) Associative: Its connection to a person or group of importance.
- (c) Aesthetic: Its design quality or landmark value.
- (d) Social: Its value to a contemporary community.
- (e) Technical/Research: Its potential to yield information or show technical achievement.
- (f) Rarity: Its status as a rare or uncommon example.
- (g) Representative: Its quality as a fine example of its class.
Step-by-Step: How to Prepare an SHI (NSW)
Follow these 12 steps to plan, draft, and lodge an SHI that addresses council requirements and heritage principles.
- Step 1: Confirm Triggers and Approval Pathway: Review your Section 10.7 certificate and council LEP maps to determine your exact heritage listing (HCA, Local, State). This dictates whether you need a DA or s.60 approval.
- Step 2: Engage Your Qualified Author: Engage a registered architect with heritage experience or a specialist heritage consultant to lead the preparation of the SHI and submission pack.
- Step 3: Conduct Background and Archival Research: Gather all available historic information to build a historical narrative.
- Step 4: Complete a Site and Fabric Survey: Thoroughly document the existing site with photos and measured drawings.
- Step 5: Draft the Statement of Significance (Criteria A-G): Assess the property against the NSW criteria to formally define why it is important.
- Step 6: Analyse the Proposal's Heritage Impact: Objectively analyse how your design affects the identified significance.
- Step 7: Define and Design Mitigation Measures (Burra Charter): Refine the architectural design to reduce harm, documenting changes as mitigation strategies.
- Step 8: Prepare the LEP/DCP Compliance Table: Go through council’s planning controls clause by clause and write a specific response for each.
- Step 9: Draft the Full SHI Document: Assemble all sections into a single, cohesive, and easy-to-read report.
- Step 10: Coordinate All Consultant Inputs: Ensure the SHI is perfectly aligned with reports from all other project consultants.
- Step 11: Assemble the Complete Submission Pack: Gather all required forms, plans, and reports as required by your council.
- Step 12: Lodge via the NSW Planning Portal: Submit your application online after a final quality assurance check.
How an SHI Integrates with DA or s.60 Applications
Your SHI underpins your approval by explaining its effects on significance. For sites on the State Heritage Register (SHR) , the SHI must also reference the site's Conservation Management Plan (CMP) and its conservation policies.
| Aspect | Development Application (DA) | s.60 Application |
|---|---|---|
| Trigger | Works to a local heritage item or in an HCA. | Works to a State Heritage Register (SHR) item. |
| Assessing Authority | Local Council | Heritage NSW |
| Governing Framework | Council LEP & DCP | Heritage Act 1977 & site's CMP |
| Typical Council Queries | Focus on streetscape character, form, and materials. | Focus on impact on state-level significance and adherence to CMP policies. |
Common SHI Mistakes (and How to Avoid Them)
Most SHI refusals come from missing sections, weak evidence, or misreading local planning rules—issues you can prevent with careful preparation.
| # | Mistake | Why It Happens | How to Fix It |
|---|---|---|---|
| 1 | Missing Core Sections | Using an incomplete template. | Use a comprehensive structure covering all required sections. |
| 2 | Incorrect Trigger Assessment | Failure to confirm pathway before drafting. | Confirm DA/s.60/SHR triggers early via a Section 10.7 Certificate. |
| 3 | Unqualified Author | Using an unqualified preparer leads to a weak, easily rejected report. | Engage a registered architect or heritage consultant with proven experience. |
| 4 | No Clause-by-Clause Table | Omitting the detailed LEP/DCP compliance table. | Include a response table cross-referenced to the proposal's plans. |
| 5 | Weak Significance Analysis | Lack of detailed, evidence-based application of the NSW A-G criteria. | Apply all NSW heritage criteria A-G with specific supporting evidence. |
| 6 | Inadequate Visual Evidence | Omitted, unlabelled, or low-quality photos and no scaled drawings. | Include high-resolution, labelled photo plates and fully scaled plans. |
| 7 | Misaligned Consultant Inputs | Plans/reports from different consultants contradict the SHI narrative. | Hold a pre-submission review with all consultants to ensure alignment. |
| 8 | No Clear Mitigation | Failing to propose concrete conservation solutions for identified impacts. | Apply Burra Charter principles like reversibility and compatibility. |
| 9 | CMP-SHI Disconnect | The SHI for an SHR site fails to reference the site's governing CMP. | Cross-reference the CMP's policies throughout the SHI's impact analysis. |
| 10 | A Rushed, Late Pack | Rushed assembly leads to omissions, errors, and a poor first impression. | Use a checklist and start assembly early to ensure a complete, professional pack. |
Submission Pack & Lodgement
Assemble the SHI within a complete submission pack, confirm any complex issues at a pre-lodgement meeting, then lodge via the NSW Planning Portal with your checklist complete.
Your Submission Pack Checklist:
- A Cover Letter summarising the proposal.
- Completed Council Application Forms.
- Statement of Heritage Impact (SHI) .
- Architectural Plans (Site, Floor Plans, Elevations, Sections).
- Photo Plate Schedule.
- Any other required reports (e.g., Arborist, Engineer, CMP).
- File names must be clear and follow council conventions.
MBA Can Help (Architect-Led SHI & Heritage Submission Services)
MBA prepares council ready SHIs and complete heritage packs, coordinating consultants and approvals to reduce delays and RFIs. Our architect-led process ensures that your heritage report and architectural design are perfectly synchronised. We don’t just write about sympathetic design—we draw it, detail it, and get it approved.
If you are planning a heritage project and need expert guidance, engage MBA to prepare a robust SHI and manage your entire heritage submission.
Glossary of Key Terms
- Burra Charter: The national best-practice principles for conserving heritage places in Australia.
- CMP (Conservation Management Plan): A detailed document guiding the long-term care of a heritage site, mandatory for many SHR-listed properties.
- DA (Development Application): A formal application to a local council for approval to carry out development.
- DCP (Development Control Plan): Detailed planning and design guidelines that support the main LEP.
- LEP (Local Environmental Plan) : The primary legal planning document for a local government area, which includes heritage listings.
- s.60 Application: An application made under Section 60 of the Heritage Act 1977 for works to a State Heritage Register item.
- SHR (State Heritage Register) : The official list of places and objects of particular importance to the people of NSW.
Frequently Asked Questions
A Statement of Heritage Impact (SHI) is a report that assesses how a proposed development will affect the heritage significance of an item or conservation area. It justifies the project and explains how any negative impacts will be minimised.
You need an SHI for a Development Application (DA) to a local council if your property is a local heritage item or in a Heritage Conservation Area. You need an SHI for a Section 60 (s.60) Application to Heritage NSW if your property is on the State Heritage Register (SHR) .
A qualified professional, such as a heritage consultant or a registered architect with demonstrated experience in NSW heritage approvals, should prepare the SHI. Councils give more weight to reports from experienced authors.
For a property on the State Heritage Register (SHR), a Conservation Management Plan (CMP) is the primary guiding document. The SHI must demonstrate that the proposed works are consistent with the conservation policies outlined in the property's CMP.
Planning a heritage project in NSW?
Our architect-led process ensures your heritage report and architectural design are perfectly synchronised. Contact us today for expert guidance on your submission.
If you’re ready for an initial complimentary consultation with Michael, please book a date and time convenient below.
Initial consultations are limited to 30 mins at no charge, via video call or face to face in our Ultimo studio. If you would like Michael to attend your site, he would be pleased to do so, however an hourly rate fee will be charged.