Georgia Hill, ‘Flow, Fold’ (2023), Sydney. Public art consultancy and curatorial direction by ART AID.
A claim is worth more when it is tested rather than asserted.
In a companion piece I argued that Australia's strength in public art is not the existence of a “percent for art” mechanism, but how deeply it has been embedded into private development through local planning. Here is that claim, tested.
Sydney set against four cities with serious public art reputations: San Francisco, Birmingham, Hong Kong and Shanghai. The differences are sharper than expected, and they make the case better than advocacy could.
San Francisco: the closest comparison
San Francisco is the city that looks most like Sydney on paper, and the comparison is instructive precisely because it is close.
The city's downtown public art requirement dates to its 1985 Downtown Plan. It compels certain large private projects to provide public art worth at least one percent of construction cost, with real institutional weight behind it: a planning database, an arts commission, a public art trust fund, decades of accumulated work. This is a mature system, and an impressive one.
But notice two things. The requirement is geographically narrow, built around the downtown core rather than applied as a general principle across the city. And the program has spent years defending the very premise that a private development should carry this obligation at all. In the wider American context, public art requirements on private development have been repeatedly framed and litigated as an imposition on developers.
That is the quiet contrast. San Francisco has a comparably sophisticated mechanism in a defined zone. What it has had to fight for is the cultural consensus that the obligation is legitimate in the first place, the thing the Australian sector has largely already won.
Birmingham: strong art, softer mechanism
Birmingham is a genuine public art city. It has the landmark works and the regeneration pedigree to prove it, with large flagship art budgets flowing through its major developments for decades.
But the British planning system treats percent for art cautiously, and as UK practitioners themselves put it, the phrase should generally be loosely applied. Contributions tend to be negotiated project by project through planning agreements rather than triggered by a clear, codified percentage tied to development value. Guidance leans on persuasion, the argument that art adds identity and long-term value, rather than a standing requirement.
Birmingham can point to wonderful individual outcomes. What it has less of is a systematic, predictable, policy-driven pipeline applied consistently across private development. Quality by negotiation is not the same as quality by design of the system itself.
Hong Kong and Shanghai: a different model
Hong Kong and Shanghai are the most useful comparisons of all, because they break the frame.
Hong Kong has a long-running government Public Art Scheme, substantial arts funding, community art embedded in public housing, and design guidelines for privately owned public space. It is not short of cultural investment or ambition. What it does not have is Sydney's specific instrument: a codified planning-policy requirement that ties a percentage of private development cost to commissioned public art as a routine condition of approval. The energy sits in government schemes, private sponsorship, and increasingly developer-led placemaking, culture pursued through funding and patronage rather than a planning mandate.
Shanghai, and mainland Chinese cities more broadly, sit further along that same axis: spectacular cultural building, much of it developer-driven or state-directed at scale, but not channelled through the kind of distributed, local-government planning mechanism that defines the Australian model.
This matters for the argument. It would be easy, looking at Asia's cultural building boom, to feel that Australia is behind. On ambition and sheer scale, in places, perhaps. But on the specific question of how you reliably get good public art into the everyday private development that actually makes up a city, not the trophy projects, the ordinary ones, the Asian models are pursuing something different, not something more advanced. Australia's distributed, policy-embedded approach is genuinely its own thing.
What the comparison shows
Lay the five cities side by side and a pattern emerges. San Francisco has a comparable mechanism, but confined to a zone and culturally contested. Birmingham has the artistic outcomes but a softer, negotiated mechanism. Hong Kong and Shanghai have ambition and investment but pursue them through funding and patronage rather than a planning mandate on private development.
“Not the city with the biggest budgets, but arguably the one where the system itself is most deliberately designed to produce good public art as a normal by-product of ordinary development.”
Sydney, and the broader Australian local-government model behind it, has the unusual combination: a percentage mechanism, tied to private development, applied through local planning policy as a routine and broadly accepted condition, with curatorial scaffolding around it.
That is a quietly remarkable thing for a young country to have built, and it is not an accident. It is the product of decades of unglamorous policy work at the local government level, the kind of work that does not make headlines and is easy to take for granted right up until you compare it with how everyone else does it.
The lesson for developers is not that Australia is behind and needs to catch up. It is closer to the opposite.
We are working inside one of the more sophisticated public art systems in the world, and most of us treat it as paperwork. The opportunity is to treat it as what it actually is: a competitive cultural instrument, already built, waiting to be used with intent.
ART AID works on both sides of that system, preparing public art plans and strategies for developers and precincts, and advising councils and government on cultural policy. If you have an obligation approaching, or a project you would rather lead with than comply with, we would love to talk.
ART AID is a public art and cultural consultancy working at the intersection of art, community, and place. To find out more about our work visit art-aid.co or follow @artaidau.
