Crows Nest OSD Site A - Detailed SSDA

Dear Sirs,

The submitted EIS is substantially deficient in several critical areas, it contains:
• fundamental procedural flaws,
• unsubstantiated claims regarding community support,
• weak justifications for significant departures from statutory amenity standards, and
• underdeveloped assessments of key environmental impacts.

These deficiencies are of such an extent that they prevent a robust and confident determination of the application in its current form and demonstrate a failure to adequately address the Planning Secretary's Environmental Assessment Requirements (SEARs) and is not in the public interest to approve.

Based on the analysis highlighted in the attached report, it is recommended that the consent authority should not determine the application in its current form. The proponent should be required to undertake significant further work to address the identified deficiencies.

Refer to attached submission

To the Assessing Officer,

I object to the Detailed State Significant Development Application (SSDA) for the Crows Nest Over Station Development (Site A).

While I support the integration of transport and development, the current detailed proposal deviates significantly from the original strategic intent for this precinct. By prioritizing residential Build-to-Rent (BTR) over the originally approved commercial floor space, this proposal undermines the economic future of St Leonards/Crows Nest and creates unacceptable amenity impacts.

My objection is founded on the following grounds:

1. Strategic Misalignment: Loss of Employment Floor Space
The St Leonards and Crows Nest 2036 Plan identifies this precinct as a vital "Global Economic Corridor."

Erosion of Commercial Capacity: Site A was concept-approved for commercial office use to generate local jobs and support the daytime economy. Converting this prime site to residential (BTR) permanently extinguishes its potential as a commercial hub.

Dormitory Effect: Without sufficient commercial floor space, Crows Nest risks becoming a high-density dormitory suburb with no daytime economic activity. We need jobs near homes, not just homes near trains.

2. Unacceptable Overshadowing of Hume Street Park & Ernest Place
Hume Street Park is the only significant green space serving this rapidly densifying area.

Solar Access: The bulk and height of the proposed tower will cast extended shadows over Hume Street Park and potentially Ernest Place (the village plaza) during key lunch and afternoon hours.

Amenity Loss: These spaces are the "lungs" of the Crows Nest Village. Compromising their solar access for a private tower contradicts the principle of preserving public amenity in high-density precincts.

3. Traffic Chaos in a Pedestrian Zone
The interface between the Metro station, the new tower, and the existing village is a critical pedestrian zone.

Service Vehicle Conflict: A BTR development of this scale requires high-frequency servicing (deliveries, removalists, maintenance) and ride-share pick-ups. The current plan for vehicular access via Clarke/Hume Streets is inadequate and will create dangerous conflicts with the thousands of commuters exiting the Metro.

Local Road Failure: The surrounding road network (Pacific Highway/Oxley St) is already at failure levels (Level of Service F) during peaks. Adding hundreds of new residential movements to this gridlock is unsustainable.

4. Visual Impact and Heritage Transition
The proposal fails to transition respectfully to the low-scale Crows Nest Conservation Area immediately to the east.

Visual Bulk: The tower presents a sheer, bulky façade that dominates the fine-grain "village" shops on Willoughby Road.

Heritage Interface: The detailed design lacks the necessary "stepping down" required to protect the heritage significance of the adjacent conservation area. It reads as an aggressive commercial imposition rather than a thoughtfully integrated addition.

Conclusion
This detailed SSDA represents a "bait and switch"—trading the promised employment benefits of the concept approval for a residential product that offers higher returns to the developer but lower long-term value to the community.

I urge the Department to reject this application and require the applicant to return to a scheme that delivers the commercial/employment floor space originally promised to the North Sydney community.

Sincerely,