State Significant Development
Response to Submissions
Lourdes Killara
Ku-ring-gai
Current Status: Response to Submissions
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Redevelopment of existing seniors housing with new buildings for independent living units and upgrades to the residential care facility.
Attachments & Resources
Request for SEARs (1)
SEARs (1)
EIS (53)
Agency Advice (5)
Submissions
Showing 1 - 20 of 57 submissions
Name Withheld
Object
Name Withheld
Object
KILLARA
,
New South Wales
Message
I object to the re-exhibited SSD – 88004956 for the following reasons:
The applicant has not adequately addressed key issues previously raised regarding redevelopment of this site by Ku-ring-gai Council, other agencies and the community.
In particular the site is identified as bushfire prone, including Vegetation Category 1 and Vegetation Buffer, and is located within the Bush Fire Attack Level (BAL) Flame Zone and BAL 40. The proposed development has not addressed the following deficiencies:
• Bushfire evacuation risks for the vulnerable and less mobile aged residents remain unresolved. The Sydney North Planning Panel’s (SNPP) previous refusal of Levande's proposals included these reasons. The current application does not change the physical danger of the site.
• To achieve an acceptable Bushfire Attack Level (BAL) rating for vulnerable seniors, the developer will be required to clear significant native vegetation for an Asset Protection Zone (APZ) Encroachment APZs. This is completely contrary to Council and the NPWS policies to retain and preserve native bushland , causing irreparable permanent environmental degradation of the Garigal National Park boundary
• In a NSW fire season similar to the one in 2019/20 evacuating hundreds of seniors with little or no mobility via one dead-end road during an active fire is a logistical disaster waiting to occur. It is particularly concerning given the uncharted fire events in Europe in 2026 where temperature records have been broken and uncontrolled wildfires have reached areas not seen since the Second World War with total destruction of buildings. A similar season in NSW and particularly around Sydney will be catastrophic and put residents of such a development at great risk from smoke inhalation and direct fire impacts.
• The option of ‘sheltering in place’ is also not feasible due to the mental and physical stress on elderly residents. Common practice appears to now be to evacuate whole residential areas affected by severe fires. If these areas have included mobile residents with vehicles what does this mean for residents in the proposed development?
• Restricted access to the site via a cul-de-sac directly bordering high-risk bushland contravenes fundamental safety principles of the NSW Rural Fire Service (RFS) Planning for Bush Fire Protection guidelines.
• The design features of the buildings with extensive balconies and multistorey do not indicate good protection against ember attack in a fire season from the adjacent Garigal National Park valley. This is unacceptable.
The applicant has not adequately addressed key issues previously raised regarding redevelopment of this site by Ku-ring-gai Council, other agencies and the community.
In particular the site is identified as bushfire prone, including Vegetation Category 1 and Vegetation Buffer, and is located within the Bush Fire Attack Level (BAL) Flame Zone and BAL 40. The proposed development has not addressed the following deficiencies:
• Bushfire evacuation risks for the vulnerable and less mobile aged residents remain unresolved. The Sydney North Planning Panel’s (SNPP) previous refusal of Levande's proposals included these reasons. The current application does not change the physical danger of the site.
• To achieve an acceptable Bushfire Attack Level (BAL) rating for vulnerable seniors, the developer will be required to clear significant native vegetation for an Asset Protection Zone (APZ) Encroachment APZs. This is completely contrary to Council and the NPWS policies to retain and preserve native bushland , causing irreparable permanent environmental degradation of the Garigal National Park boundary
• In a NSW fire season similar to the one in 2019/20 evacuating hundreds of seniors with little or no mobility via one dead-end road during an active fire is a logistical disaster waiting to occur. It is particularly concerning given the uncharted fire events in Europe in 2026 where temperature records have been broken and uncontrolled wildfires have reached areas not seen since the Second World War with total destruction of buildings. A similar season in NSW and particularly around Sydney will be catastrophic and put residents of such a development at great risk from smoke inhalation and direct fire impacts.
• The option of ‘sheltering in place’ is also not feasible due to the mental and physical stress on elderly residents. Common practice appears to now be to evacuate whole residential areas affected by severe fires. If these areas have included mobile residents with vehicles what does this mean for residents in the proposed development?
• Restricted access to the site via a cul-de-sac directly bordering high-risk bushland contravenes fundamental safety principles of the NSW Rural Fire Service (RFS) Planning for Bush Fire Protection guidelines.
• The design features of the buildings with extensive balconies and multistorey do not indicate good protection against ember attack in a fire season from the adjacent Garigal National Park valley. This is unacceptable.
Attachments
Name Withheld
Object
Name Withheld
Object
KILLARA
,
New South Wales
Message
OBJECTION to State Significant Development Application SSD -88004956
Lourdes Retirement Village Killara
95-97 Stanhope Road, Killara
I object to the exhibited SSD – 88004956 for the following reasons:
The applicant has not adequately addressed key issues previously raised regarding redevelopment of this site by Ku-ring-gai Council, other agencies and the community. In particular the environmental and biodiversity impacts of the proposed development as follows:
• The detrimental environmental impacts of a significantly higher density development adjacent to Garigal National Park. These are impacts that Ku-ring-gai Council and the NPWS will be required to deal with and include weed and noxious species invasion, pollutant runoff, and artificial light pollution—directly into a pristine national park ecosystem.
• Significant loss of mature tree canopy, further reducing critical tree canopy in the Ku-ring-gai local government area due to the proposal requiring clearing pf dozens of mature, hollow-bearing native trees that provide critical nesting habitats for local fauna.
• Impacts and threats to vulnerable local wildlife from the much higher density construction, much larger building and hard surface footprint and ongoing high-density human activity which will permanently disrupt the wildlife corridors used by threatened species, including the Powerful Owl and eastern pygmy possum.
• Isolation of significant wildlife populations through the destruction of local biodiversity corridors. The site acts as a critical steppingstone corridor for avian and canopy-dwelling species moving through Ku-ring-gai.
• An inadequate proposed Biodiversity Offset Strategy. The developer proposes purchasing distant biodiversity offsets which do not remediate the direct, localized ecological destruction that will occur as a result of the development at this location.
• The development encroaches on Riparian Zones with any uncontrolled runoff during the long demolition and construction phase threatening local creek lines feeding directly into the water catchment.
• Runoff of stormwater and site pollutants leading to valley erosion and local creek and downstream pollution into National Park waterways.
• Soil instability on the steep slopes of the site which will be exacerbated by heavy excavation and earthworks on the site's steep terrain risking slope instability and landslip hazards that could impact lower-lying national park terrain.
For the above reasons the SSD application No 88004956 should be refused in its present form.
Lourdes Retirement Village Killara
95-97 Stanhope Road, Killara
I object to the exhibited SSD – 88004956 for the following reasons:
The applicant has not adequately addressed key issues previously raised regarding redevelopment of this site by Ku-ring-gai Council, other agencies and the community. In particular the environmental and biodiversity impacts of the proposed development as follows:
• The detrimental environmental impacts of a significantly higher density development adjacent to Garigal National Park. These are impacts that Ku-ring-gai Council and the NPWS will be required to deal with and include weed and noxious species invasion, pollutant runoff, and artificial light pollution—directly into a pristine national park ecosystem.
• Significant loss of mature tree canopy, further reducing critical tree canopy in the Ku-ring-gai local government area due to the proposal requiring clearing pf dozens of mature, hollow-bearing native trees that provide critical nesting habitats for local fauna.
• Impacts and threats to vulnerable local wildlife from the much higher density construction, much larger building and hard surface footprint and ongoing high-density human activity which will permanently disrupt the wildlife corridors used by threatened species, including the Powerful Owl and eastern pygmy possum.
• Isolation of significant wildlife populations through the destruction of local biodiversity corridors. The site acts as a critical steppingstone corridor for avian and canopy-dwelling species moving through Ku-ring-gai.
• An inadequate proposed Biodiversity Offset Strategy. The developer proposes purchasing distant biodiversity offsets which do not remediate the direct, localized ecological destruction that will occur as a result of the development at this location.
• The development encroaches on Riparian Zones with any uncontrolled runoff during the long demolition and construction phase threatening local creek lines feeding directly into the water catchment.
• Runoff of stormwater and site pollutants leading to valley erosion and local creek and downstream pollution into National Park waterways.
• Soil instability on the steep slopes of the site which will be exacerbated by heavy excavation and earthworks on the site's steep terrain risking slope instability and landslip hazards that could impact lower-lying national park terrain.
For the above reasons the SSD application No 88004956 should be refused in its present form.
Peter Graham
Object
Peter Graham
Object
KILLARA
,
New South Wales
Message
I have read: (a) the Environmental Impact Statement
(b) Clause 4.6 Variation
(c) Visual Impact Statement
(d) JMT Consulting's Transport Impact Statement.
I have ascertained the Zoning and Heritage Conservation status of properties in Stanhope Road east of the Railway line through to the site (Lot 21 DP 634645-3498m2 known as 97 Stanhope Road and Lot 22- 4.94ha -No.95) -All R2 Low Density Residential- THE OBJECTIVE OF WHICH IS TO PROVIDE FOR THE HOUSING NEEDS OF THE COMMUNITY WITHIN A LOW DENSITY RESIDENTIAL ENVIRONMENT THAT IS COMPATIBLE WITHTHE EXISTING ENVIRONMENTAL AND BUILT CHARACTER OF Ku-ring-gai.
JMT describes the application much better than the EIS and VIA :
"The site has a ...substantial street frontage of approximately 380m along Stanhope Road. The area to the north and west is characterised by low-density residential dwellings ...
Currently, the site comprises the existing 172-dwelling Lourdes Retirement Village, including 108 independent living units, 64 serviced retirement apartments, and an 83 residential aged care facility (...operated by Opal [Healthcare]), administartive buildings and additional resident community facilities. The buildings vary in scale from one to three storeys, with pitched rooves.
The site has a main vehicular access point via Stanhope Road ...{and] is serviced by a local bus route (556) which ...provides public transportation to Lindfield.
Key components of the proposed works include:
Staged demolition of the existing 172 seniors housing dwellings...
Torrens subdivision ... to completely separate the existing partly subdivided [a new legal concept?] residential aged care facility from the remainder of the retirement village site ...
demolition of the existing connection with the hostel building...
demolition of the buildings connecting the residential aged care to the retirement serviced apartments
Construction of a new seniors [55 years of age or older] housing development comprising 9 'boutique' seniors housing blocks [with a separate "CLUBHOUSE"- glamorous home units, perhaps, in high rise buildings with lifts on a different parcel of land with separate title from any residential care facilities- see the EIS p.9 - "The Lourdes Retirement Village WILL BE SUBDIVIDED ... TO SEPARATE THE EXISTING... RESIDENTIAL CARE FACILITY FORM THE REMAINDER OF THE SITE AND WILL DELIVER A TOTAL OF 145 Independent Living UNITS"]
Provision of a new community facility to support a range of social and recreational uses [the CLUBHOUSE]
[ To get a fair impression of "before" and "after", compare JMT's coloured aerial photo of the present situation in their Figure 3 with the Developer's top photograph in Figure 9 on page 29 of the EIS.
2 consolidated 1-2 storey basements, providing car parking [264 being 258 residential and 6 staff]
JMT says "the site is not located on a major on-road (bus) public transport corridor nor is it adjacent to a major road. Therefore future construction of the development is not forecast to cause significant disruptions to public transport , pedestrians, cyclists or general road users.
[This totally overlooks that Stanhope Road between Redgum Avenue and Nelson Street is the MAIN THOROUGHFARE dictated by the Council to be used by Cyclists passing through Killara travelling north to south and vice-versa.
There is a recently established bus route to Lindfield railway station which services the site, which has buses travelling at speed along Stanhope Road, which is exceedingly undulating, with significant blind spots, with buses stopping along the way. Stanhope Road has large SUV and other cars parked on both sides of the road almost every day and night. When buses tear along the road between the parked cars, there is frequently inadequate space for two vehicles to pass one another. Young children heading to and from school and cyclists are at great risk of injury with buses using Stanhope Road.
(b) Clause 4.6 Variation
(c) Visual Impact Statement
(d) JMT Consulting's Transport Impact Statement.
I have ascertained the Zoning and Heritage Conservation status of properties in Stanhope Road east of the Railway line through to the site (Lot 21 DP 634645-3498m2 known as 97 Stanhope Road and Lot 22- 4.94ha -No.95) -All R2 Low Density Residential- THE OBJECTIVE OF WHICH IS TO PROVIDE FOR THE HOUSING NEEDS OF THE COMMUNITY WITHIN A LOW DENSITY RESIDENTIAL ENVIRONMENT THAT IS COMPATIBLE WITHTHE EXISTING ENVIRONMENTAL AND BUILT CHARACTER OF Ku-ring-gai.
JMT describes the application much better than the EIS and VIA :
"The site has a ...substantial street frontage of approximately 380m along Stanhope Road. The area to the north and west is characterised by low-density residential dwellings ...
Currently, the site comprises the existing 172-dwelling Lourdes Retirement Village, including 108 independent living units, 64 serviced retirement apartments, and an 83 residential aged care facility (...operated by Opal [Healthcare]), administartive buildings and additional resident community facilities. The buildings vary in scale from one to three storeys, with pitched rooves.
The site has a main vehicular access point via Stanhope Road ...{and] is serviced by a local bus route (556) which ...provides public transportation to Lindfield.
Key components of the proposed works include:
Staged demolition of the existing 172 seniors housing dwellings...
Torrens subdivision ... to completely separate the existing partly subdivided [a new legal concept?] residential aged care facility from the remainder of the retirement village site ...
demolition of the existing connection with the hostel building...
demolition of the buildings connecting the residential aged care to the retirement serviced apartments
Construction of a new seniors [55 years of age or older] housing development comprising 9 'boutique' seniors housing blocks [with a separate "CLUBHOUSE"- glamorous home units, perhaps, in high rise buildings with lifts on a different parcel of land with separate title from any residential care facilities- see the EIS p.9 - "The Lourdes Retirement Village WILL BE SUBDIVIDED ... TO SEPARATE THE EXISTING... RESIDENTIAL CARE FACILITY FORM THE REMAINDER OF THE SITE AND WILL DELIVER A TOTAL OF 145 Independent Living UNITS"]
Provision of a new community facility to support a range of social and recreational uses [the CLUBHOUSE]
[ To get a fair impression of "before" and "after", compare JMT's coloured aerial photo of the present situation in their Figure 3 with the Developer's top photograph in Figure 9 on page 29 of the EIS.
2 consolidated 1-2 storey basements, providing car parking [264 being 258 residential and 6 staff]
JMT says "the site is not located on a major on-road (bus) public transport corridor nor is it adjacent to a major road. Therefore future construction of the development is not forecast to cause significant disruptions to public transport , pedestrians, cyclists or general road users.
[This totally overlooks that Stanhope Road between Redgum Avenue and Nelson Street is the MAIN THOROUGHFARE dictated by the Council to be used by Cyclists passing through Killara travelling north to south and vice-versa.
There is a recently established bus route to Lindfield railway station which services the site, which has buses travelling at speed along Stanhope Road, which is exceedingly undulating, with significant blind spots, with buses stopping along the way. Stanhope Road has large SUV and other cars parked on both sides of the road almost every day and night. When buses tear along the road between the parked cars, there is frequently inadequate space for two vehicles to pass one another. Young children heading to and from school and cyclists are at great risk of injury with buses using Stanhope Road.
Attachments
Wai Chan
Object
Wai Chan
Object
KILLARA
,
New South Wales
Message
There is a lack of alternative emergency access for the entire site. The developer has completely failed to secure a secondary, viable emergency-only access and escape route through the surrounding properties and area to alleviate the Stanhope Road choke points, as well as many other associated problems relating to extreme bushfire hazards, including risks to residents and the local community. This is a holding submission. I reserve the right to submit independent safety reviews. Sincerely, Wai Chan
Scott Savage
Object
Scott Savage
Object
LINDFIELD
,
New South Wales
Message
OBJECTION - SSD-88004956, Lourdes Retirement Village, Killara
Scott Savage, Northcote Road, Lindfield NSW 2070
I object to the Clause 4.6 height variation and to the staging. Attached: covering letter; Annexure A (grounds, 25pp; sources and caveats); Annexure B (Figures 1-7).
Every room of my house looks to the ridge where the taller buildings would go; Building H is 261m from my lounge window. I SUPPORT the bushfire retreat, the 56m APZ, the cut from 172 to 145 dwellings and the consolidated footprint - spreading it out would only cost more trees. I am asking for fewer storeys on the same footprints. This village should be rebuilt; its residents deserve better than forty-year-old buildings in a flame zone.
Every figure below is the applicant's own.
1. THE VARIATION IS BIGGER THAN STATED. The sections annotate a lift overrun 1.30m above roof level on every building (Building A roof RL +120.15, overrun +121.45). The Standard Instrument Dictionary measures building height to the highest point "including plant and lift overruns". Measured properly, Building A is ~19.70m against a 9.5m standard - 107%, not the 60% reported. SO WHAT: the Department is asked to approve a variation whose size has been understated by half.
2. NOBODY CAN SAY HOW TALL IT IS. DA205 shows Building A with six levels, five above ground on the south. The EIS says "2-5 storey" in one line and "2 to 4 storeys" eleven lines later; s4.7.4 gives Buildings E and F "two additional lower part storeys to the south". SO WHAT: there is no consistent statement of what is being approved, and every inconsistency runs one way.
3. THE CANOPY PROMISE IS BROKEN. The Scoping Report told the Department the taller buildings "will sit below the canopy of the trees and not be visible from external locations". The arborist has since measured every tree: of 254 retained, 230 have a recorded height and the median is 12.0m. Building A at 18.4m stands taller than 206 of them. SO WHAT: the assurance on which this variation was foreshadowed is contradicted by its own arborist. A building above nine tenths of the trees meant to conceal it is not below the canopy.
4. THE AFFECTED SIDE WAS NEVER ASSESSED. Every exceedance is on a southern elevation. Every viewpoint within 200m is on the northern side, where the buildings comply. No viewpoint on the southern side is closer than 337m. All 19 are public domain views; the report names Tenacity as the test for private views and never applies it. The VIA's own Northcote Rd cameras sit at RL +100.90 and +103.77; Building H's roof is RL +115.80 and Building A's overrun RL +121.45, so these buildings stand 12 to 21m above my street across a valley, on a slope carrying unbroken canopy. SO WHAT: the "negligible" finding rests on an assessment that excluded the direction and the receivers actually affected. It is not evidence the Department can rely on.
5. BUSHFIRE IS NOT WHY THE TREES GO. Of 366 trees to be removed, the arborist attributes 16 to bushfire - 116 to buildings, 58 to roads, 33 to grading, 127 to landscaping. SO WHAT: the trees are not going to make the village safe. They are making room for the buildings whose height is excused by safety.
6. A STATED GROUND FOR THE VARIATION IS UNTRUE. The Clause 4.6 says the proposal "remains well below the maximum FSR permissible on the site" and offers that as proof it prioritised "safety and good design over maximising yield". The EIS s7.1.3 and the FSR Clause 4.6 both record the ILU component at 0.5:1 - the ceiling under s108. SO WHAT: cl 4.6(3) requires the applicant to demonstrate sufficient environmental planning grounds. One of the grounds relied on is contradicted by its own documents, all three dated 22 June 2026.
7. NO COMPLIANT ALTERNATIVE WAS EVER TESTED. The alternatives section considers doing nothing, other uses and the earlier taller schemes - never the same retreat at a lower yield. The applicant also concedes it locates parking in semi-subterranean levels, "instead pushing them above the height limit". SO WHAT: the claim that bushfire compels this height is untested, and part of it is admitted to be a car parking decision.
8. NOBODY HAS MEASURED THE HAZARD. The district Bush Fire Risk Management Plan 2016-21 named this site - asset 76, "Likely / Catastrophic / Extreme / 1B" - and prescribed a mosaic burn, programmed once for 2016/17. The 2023 plan replacing it names no aged care asset at all. The NSW fire history dataset records no fire in the bushland south and east of the site. DPHI's own report calls that bushland vegetation Category 1, the highest risk category, and Levande markets Lourdes as "nestled on the edge of Garigal National Park". The APZ is nonetheless sized "to achieve the BAL-29 provisions" - 29 kW/m2 - when PBP 2019 s3.2 says "for most SFPP developments, 10kW/m2... is the maximum exposure at any point of the building wall". SO WHAT: under PBP the APZ is calculated from fuel load, which depends on time since fire. No record of it burning, no statement of its fuel load, apparently the residential radiant heat threshold rather than the aged care one - and 145 households of elderly people proposed on the other side of it. If that threshold is wrong, the entire retreat rests on the wrong number.
9. THE EVACUATION STUDY MEASURES THE WRONG THING. The only numerical analysis is that a bushfire evacuation generates "170 vehicles" at a volume-to-capacity ratio of 0.23 on Stanhope Road. SO WHAT: that tests whether the road is wide enough once people are already in cars. Seniors housing is a Special Fire Protection Purpose precisely because occupants "may be unable to self-evacuate". Whether a frail resident can get down four storeys and into a vehicle is nowhere addressed.
10. THE SAFETY ARRIVES LAST, AND THE RESIDENTS GO FIRST. Demolition of the Flame Zone dwellings - the act creating the APZ - is Stage 3, after 126 of 145 units are built and sold. No stage has a completion date, there is no sunset condition, the staging is only "indicative". Meanwhile Stages 1A and 1B both begin by relocating existing residents INTO those Flame Zone buildings, where they remain through three stages for "a number of years" while Stage 1A demolishes and rebuilds the road they would escape along. The Social Impact Assessment rates this "Low-Medium negative" and calls it "short-term disruption to residents' established routines". It does not mention bushfire at all.
SO WHAT: frail people are to be moved into buildings this application itself calls unsafe, held there for years with their escape route dug up, and the risk recorded as an inconvenience to their routines. The Special Fire Protection Purpose provisions exist for exactly these residents. This scheme puts them nearest the fire and last in the queue for the protection meant to justify it. If the hazard is real enough to justify a 60% height variation, it is real enough to be removed before anyone is moved towards it.
11. AND NOTHING CHECKS THIS AFTERWARDS. On 10 Oct 2023 the Member for Davidson told Parliament: "The Minister for Planning and Public Spaces advised on 5 July 2023: Any future Development Application submitted for the site must be formally referred to the RFS for its detailed consideration and will require a Bush Fire Safety Authority to be issued by the RFS under s100B." That was the assurance given to this community. But s4.14(1B) of the EP&A Act provides: "This section does not apply to State significant development", and no s100B authority is required for SSD. I make no criticism of the Minister - on the pathway contemplated in 2023 the advice was right. SO WHAT: the RFS role here is advisory. No later authority can refuse this or condition it. This determination is the only occasion bushfire safety will ever be tested - which is exactly why nothing can be left to the occupation certificate or to Stage 3. The same speech quoted Ku-ring-gai Council: it "does not want to be held in any way responsible in the event of a bushfire-related incident and any resulting coronial inquest". Council is no longer the consent authority. The Department is.
WHAT I ASK
1. Refuse the Clause 4.6 height variation as it stands.
2. Withhold consent unless no part of any building, including parapets, plant and lift overruns, projects above the canopy of the retained trees, with the datum taken from the arborist's own measured heights and a maximum RL conditioned per building.
3. Before determination require: heights re-stated to the top of each lift overrun; one consistent storey schedule; existing and retained canopy coverage; time since fire and assumed fuel load; the radiant heat threshold used; and survey-verified photomontages from private homes on this side of the valley, including my two viewpoints in Annexure B. I will make my property available.
4. Require a height-compliant retreat modelled at a lower yield, and the reasons for rejecting it. Reconcile "well below the maximum FSR" with the 0.5:1 figure.
5. Restructure the staging: Flame Zone demolition and the APZ first; no occupation certificate for Stages 2 or 3 until the APZ is certified to PBP 2019; a stage-specific evacuation plan approved before Stage 1A; a sunset condition.
6. State what role the RFS has had, whether a s100B authority will be required, and if not how the Department has satisfied itself on what the RFS would otherwise have examined - and publish its advice.
Read these documents against each other and they do not agree - on the height, the storeys, the floor space, whether the buildings sit above or below the canopy. Every disagreement runs one way. Please test the figures, not the summaries.
These residents should get their new village. They should not live in the flame zone to earn it.
I request the opportunity to speak to this submission at any public meeting. I declare I have made no reportable political donation or gift in the period relevant to this application.
Scott Savage, Northcote Road, Lindfield NSW 2070
Scott Savage, Northcote Road, Lindfield NSW 2070
I object to the Clause 4.6 height variation and to the staging. Attached: covering letter; Annexure A (grounds, 25pp; sources and caveats); Annexure B (Figures 1-7).
Every room of my house looks to the ridge where the taller buildings would go; Building H is 261m from my lounge window. I SUPPORT the bushfire retreat, the 56m APZ, the cut from 172 to 145 dwellings and the consolidated footprint - spreading it out would only cost more trees. I am asking for fewer storeys on the same footprints. This village should be rebuilt; its residents deserve better than forty-year-old buildings in a flame zone.
Every figure below is the applicant's own.
1. THE VARIATION IS BIGGER THAN STATED. The sections annotate a lift overrun 1.30m above roof level on every building (Building A roof RL +120.15, overrun +121.45). The Standard Instrument Dictionary measures building height to the highest point "including plant and lift overruns". Measured properly, Building A is ~19.70m against a 9.5m standard - 107%, not the 60% reported. SO WHAT: the Department is asked to approve a variation whose size has been understated by half.
2. NOBODY CAN SAY HOW TALL IT IS. DA205 shows Building A with six levels, five above ground on the south. The EIS says "2-5 storey" in one line and "2 to 4 storeys" eleven lines later; s4.7.4 gives Buildings E and F "two additional lower part storeys to the south". SO WHAT: there is no consistent statement of what is being approved, and every inconsistency runs one way.
3. THE CANOPY PROMISE IS BROKEN. The Scoping Report told the Department the taller buildings "will sit below the canopy of the trees and not be visible from external locations". The arborist has since measured every tree: of 254 retained, 230 have a recorded height and the median is 12.0m. Building A at 18.4m stands taller than 206 of them. SO WHAT: the assurance on which this variation was foreshadowed is contradicted by its own arborist. A building above nine tenths of the trees meant to conceal it is not below the canopy.
4. THE AFFECTED SIDE WAS NEVER ASSESSED. Every exceedance is on a southern elevation. Every viewpoint within 200m is on the northern side, where the buildings comply. No viewpoint on the southern side is closer than 337m. All 19 are public domain views; the report names Tenacity as the test for private views and never applies it. The VIA's own Northcote Rd cameras sit at RL +100.90 and +103.77; Building H's roof is RL +115.80 and Building A's overrun RL +121.45, so these buildings stand 12 to 21m above my street across a valley, on a slope carrying unbroken canopy. SO WHAT: the "negligible" finding rests on an assessment that excluded the direction and the receivers actually affected. It is not evidence the Department can rely on.
5. BUSHFIRE IS NOT WHY THE TREES GO. Of 366 trees to be removed, the arborist attributes 16 to bushfire - 116 to buildings, 58 to roads, 33 to grading, 127 to landscaping. SO WHAT: the trees are not going to make the village safe. They are making room for the buildings whose height is excused by safety.
6. A STATED GROUND FOR THE VARIATION IS UNTRUE. The Clause 4.6 says the proposal "remains well below the maximum FSR permissible on the site" and offers that as proof it prioritised "safety and good design over maximising yield". The EIS s7.1.3 and the FSR Clause 4.6 both record the ILU component at 0.5:1 - the ceiling under s108. SO WHAT: cl 4.6(3) requires the applicant to demonstrate sufficient environmental planning grounds. One of the grounds relied on is contradicted by its own documents, all three dated 22 June 2026.
7. NO COMPLIANT ALTERNATIVE WAS EVER TESTED. The alternatives section considers doing nothing, other uses and the earlier taller schemes - never the same retreat at a lower yield. The applicant also concedes it locates parking in semi-subterranean levels, "instead pushing them above the height limit". SO WHAT: the claim that bushfire compels this height is untested, and part of it is admitted to be a car parking decision.
8. NOBODY HAS MEASURED THE HAZARD. The district Bush Fire Risk Management Plan 2016-21 named this site - asset 76, "Likely / Catastrophic / Extreme / 1B" - and prescribed a mosaic burn, programmed once for 2016/17. The 2023 plan replacing it names no aged care asset at all. The NSW fire history dataset records no fire in the bushland south and east of the site. DPHI's own report calls that bushland vegetation Category 1, the highest risk category, and Levande markets Lourdes as "nestled on the edge of Garigal National Park". The APZ is nonetheless sized "to achieve the BAL-29 provisions" - 29 kW/m2 - when PBP 2019 s3.2 says "for most SFPP developments, 10kW/m2... is the maximum exposure at any point of the building wall". SO WHAT: under PBP the APZ is calculated from fuel load, which depends on time since fire. No record of it burning, no statement of its fuel load, apparently the residential radiant heat threshold rather than the aged care one - and 145 households of elderly people proposed on the other side of it. If that threshold is wrong, the entire retreat rests on the wrong number.
9. THE EVACUATION STUDY MEASURES THE WRONG THING. The only numerical analysis is that a bushfire evacuation generates "170 vehicles" at a volume-to-capacity ratio of 0.23 on Stanhope Road. SO WHAT: that tests whether the road is wide enough once people are already in cars. Seniors housing is a Special Fire Protection Purpose precisely because occupants "may be unable to self-evacuate". Whether a frail resident can get down four storeys and into a vehicle is nowhere addressed.
10. THE SAFETY ARRIVES LAST, AND THE RESIDENTS GO FIRST. Demolition of the Flame Zone dwellings - the act creating the APZ - is Stage 3, after 126 of 145 units are built and sold. No stage has a completion date, there is no sunset condition, the staging is only "indicative". Meanwhile Stages 1A and 1B both begin by relocating existing residents INTO those Flame Zone buildings, where they remain through three stages for "a number of years" while Stage 1A demolishes and rebuilds the road they would escape along. The Social Impact Assessment rates this "Low-Medium negative" and calls it "short-term disruption to residents' established routines". It does not mention bushfire at all.
SO WHAT: frail people are to be moved into buildings this application itself calls unsafe, held there for years with their escape route dug up, and the risk recorded as an inconvenience to their routines. The Special Fire Protection Purpose provisions exist for exactly these residents. This scheme puts them nearest the fire and last in the queue for the protection meant to justify it. If the hazard is real enough to justify a 60% height variation, it is real enough to be removed before anyone is moved towards it.
11. AND NOTHING CHECKS THIS AFTERWARDS. On 10 Oct 2023 the Member for Davidson told Parliament: "The Minister for Planning and Public Spaces advised on 5 July 2023: Any future Development Application submitted for the site must be formally referred to the RFS for its detailed consideration and will require a Bush Fire Safety Authority to be issued by the RFS under s100B." That was the assurance given to this community. But s4.14(1B) of the EP&A Act provides: "This section does not apply to State significant development", and no s100B authority is required for SSD. I make no criticism of the Minister - on the pathway contemplated in 2023 the advice was right. SO WHAT: the RFS role here is advisory. No later authority can refuse this or condition it. This determination is the only occasion bushfire safety will ever be tested - which is exactly why nothing can be left to the occupation certificate or to Stage 3. The same speech quoted Ku-ring-gai Council: it "does not want to be held in any way responsible in the event of a bushfire-related incident and any resulting coronial inquest". Council is no longer the consent authority. The Department is.
WHAT I ASK
1. Refuse the Clause 4.6 height variation as it stands.
2. Withhold consent unless no part of any building, including parapets, plant and lift overruns, projects above the canopy of the retained trees, with the datum taken from the arborist's own measured heights and a maximum RL conditioned per building.
3. Before determination require: heights re-stated to the top of each lift overrun; one consistent storey schedule; existing and retained canopy coverage; time since fire and assumed fuel load; the radiant heat threshold used; and survey-verified photomontages from private homes on this side of the valley, including my two viewpoints in Annexure B. I will make my property available.
4. Require a height-compliant retreat modelled at a lower yield, and the reasons for rejecting it. Reconcile "well below the maximum FSR" with the 0.5:1 figure.
5. Restructure the staging: Flame Zone demolition and the APZ first; no occupation certificate for Stages 2 or 3 until the APZ is certified to PBP 2019; a stage-specific evacuation plan approved before Stage 1A; a sunset condition.
6. State what role the RFS has had, whether a s100B authority will be required, and if not how the Department has satisfied itself on what the RFS would otherwise have examined - and publish its advice.
Read these documents against each other and they do not agree - on the height, the storeys, the floor space, whether the buildings sit above or below the canopy. Every disagreement runs one way. Please test the figures, not the summaries.
These residents should get their new village. They should not live in the flame zone to earn it.
I request the opportunity to speak to this submission at any public meeting. I declare I have made no reportable political donation or gift in the period relevant to this application.
Scott Savage, Northcote Road, Lindfield NSW 2070
Attachments
Name Withheld
Object
Name Withheld
Object
LINDFIELD
,
New South Wales
Message
TO WHOM IT MAY CONCERN:
31 July 2026
Being a resident of this area for a few years, I thought I would provide you with some feedback and some insight as to the area in which you propose to develop.
1. I see a significant problem having aged residents, some with severe issues both mentally and physically trying to exit the area if there are any emergency situations as the road, Stanhope Road does not constitute or support heavy traffic flow and heavy vehicles - I feel it is just so unrealistic and quite dangerous.
2. I also find it quite bemusing, that each of these SSD's have hundreds of pages of information of which, the general population is having to read and I believe it is on purpose that they try to inundate people with high volumes of information to confuse and frustrate residents. I also find it quite extraordinary that only a few boundering properties were notified my mail as this affects a significant area of land and landowners within the area.
3. What about the impact on the environment and biodiversity impacts with loss of tree canopy, native trees and wildlife?
4. I would think developers could have chosen a better suited area within Kuringgai for this proposed development. If it was smaller in scale, height, volume and more considerate of the existing environment, residences would not be as vocal in condemning these projects.
5. The traffic reports that have been conducted are highly inaccurate. Each working day is different and differs with parking capacity on streets, coupled with large vehicles parked blocking line of sight and buses using narrow streets makes for precarious driving lines.
Thanking you for taking the time to read my assessment.
Yours faithfully
31 July 2026
Being a resident of this area for a few years, I thought I would provide you with some feedback and some insight as to the area in which you propose to develop.
1. I see a significant problem having aged residents, some with severe issues both mentally and physically trying to exit the area if there are any emergency situations as the road, Stanhope Road does not constitute or support heavy traffic flow and heavy vehicles - I feel it is just so unrealistic and quite dangerous.
2. I also find it quite bemusing, that each of these SSD's have hundreds of pages of information of which, the general population is having to read and I believe it is on purpose that they try to inundate people with high volumes of information to confuse and frustrate residents. I also find it quite extraordinary that only a few boundering properties were notified my mail as this affects a significant area of land and landowners within the area.
3. What about the impact on the environment and biodiversity impacts with loss of tree canopy, native trees and wildlife?
4. I would think developers could have chosen a better suited area within Kuringgai for this proposed development. If it was smaller in scale, height, volume and more considerate of the existing environment, residences would not be as vocal in condemning these projects.
5. The traffic reports that have been conducted are highly inaccurate. Each working day is different and differs with parking capacity on streets, coupled with large vehicles parked blocking line of sight and buses using narrow streets makes for precarious driving lines.
Thanking you for taking the time to read my assessment.
Yours faithfully
Name Withheld
Object
Name Withheld
Object
KILLARA
,
New South Wales
Message
Acoustic Pollution in a Quiet Valley:
The jackhammering, demolition, continuous flow of trucks and construction over an extended three stage period, plus the introduction of massive commercial HVAC systems, cooling towers and daily delivery bays will destroy the natural acoustic sanctuary of the Garigal bushland boundary. These outcomes should not be allowed in any shape or form.
This is a holding submission; I reserve the right to submit independent acoustic impact reviews.
The jackhammering, demolition, continuous flow of trucks and construction over an extended three stage period, plus the introduction of massive commercial HVAC systems, cooling towers and daily delivery bays will destroy the natural acoustic sanctuary of the Garigal bushland boundary. These outcomes should not be allowed in any shape or form.
This is a holding submission; I reserve the right to submit independent acoustic impact reviews.
Name Withheld
Object
Name Withheld
Object
LINDFIELD
,
New South Wales
Message
The height/scale of the proposed development (6 storeys) remains out of keeping with the surrounding houses which are only 2 storeys and are part of the crown blocks heritage conservation area.
Intensive extended (24 hour) operational lighting required for a high-density aged care facility will result in significant light pollution and nocturnal disruption that will blind and permanently displace nocturnal wildlife along the national park boundary. This is a holding submission; I reserve the right to submit detailed flora and fauna impacts.
Intensive extended (24 hour) operational lighting required for a high-density aged care facility will result in significant light pollution and nocturnal disruption that will blind and permanently displace nocturnal wildlife along the national park boundary. This is a holding submission; I reserve the right to submit detailed flora and fauna impacts.
Ku-ring-gai Council
Object
Ku-ring-gai Council
Object
Name Withheld
Object
Name Withheld
Object
KILLARA
,
New South Wales
Message
To the Department of Planning, Housing and Infrastructure,
I am the owner and resident of a property immediately adjoining the proposed redevelopment of the Lourdes Retirement Village. As one of the residents who will be directly affected by both the construction and long-term operation of this project, I respectfully submit my objection to the proposed development.
At the outset, I acknowledge the importance of providing modern, safe and accessible accommodation for older Australians. I also recognise that the existing retirement village requires renewal and improved bushfire protection. However, the need to modernise the facility should not come at the expense of neighbouring residents, the unique environmental qualities of Killara, or the long-term public interest.
After reviewing the Environmental Impact Statement, Transport Impact Assessment and Bushfire Assessment, I remain concerned that the proposal does not adequately demonstrate that its environmental, traffic, construction and neighbourhood impacts can be satisfactorily managed.
My concerns are outlined below.
1. Permanent Loss of Bushland Character
Killara is widely recognised for its leafy streets, mature tree canopy and close relationship with surrounding bushland. These characteristics are fundamental to the identity of the suburb and are valued by residents throughout the Ku-ring-gai Local Government Area.
Although the applicant states that biodiversity retention has been prioritised and that landscaping will be enhanced, the proposal nevertheless requires extensive site modification, new internal roads, basement excavation, hard surfaces and Asset Protection Zones surrounding much of the development. The cumulative effect of these works will permanently alter the existing landscape character.
Importantly, the proposed Asset Protection Zones are not a temporary measure. They require ongoing vegetation management throughout the life of the development, including regular removal of understorey vegetation, pruning, fuel reduction and continued maintenance to comply with bushfire requirements. While these measures may improve fire protection, they also represent an ongoing reduction in the ecological quality of the bushland interface rather than a one-off impact.
The Environmental Impact Statement presents landscaping as mitigation; however, newly planted ornamental landscaping cannot replace the environmental value, habitat function and mature canopy provided by existing native vegetation.
2. Overdevelopment Within a Sensitive Residential Environment
The applicant repeatedly emphasises that the proposal reduces the number of independent living units from 172 to 145. While numerically correct, this comparison does not adequately reflect the true intensity of the redevelopment.
The proposal introduces nine multi-storey residential buildings, substantial basement parking, new roads, retaining structures and extensive infrastructure works. The overall building bulk, visual presence and urban form will be significantly greater than the existing village.
The proposal therefore represents a substantial increase in built form despite the reduction in dwelling numbers.
As a resident immediately adjoining the site, I am concerned that the redevelopment is inconsistent with the established low-density garden suburb character that has long defined Stanhope Road.
3. Construction Impacts Have Been Underestimated
The most immediate impacts on neighbouring residents will occur during the demolition and construction phases.
The proposal involves demolition of existing buildings, extensive excavation, construction of basement levels, installation of services, retaining walls and new roads before the new buildings can even commence.
These activities are likely to continue over several years.
The reports acknowledge that a detailed Construction Traffic Management Plan will only be prepared at a later stage if consent is granted.
This means that many of the most significant impacts—including heavy vehicle movements, construction traffic routes, worker parking, dust suppression, noise management and pedestrian safety—have not yet been fully assessed.
Residents are therefore being asked to accept substantial uncertainty regarding the impacts that they will experience.
For neighbouring properties such as mine, construction impacts cannot simply be dismissed as temporary inconvenience. Multi-year exposure to continuous construction activity has genuine consequences for residential amenity, health, wellbeing and enjoyment of one's property.
4. Reliance on Future Management Plans
A recurring concern throughout the documentation is the reliance on management plans that are yet to be prepared.
Many significant matters are deferred until after development approval, including:
Construction Traffic Management;
Bushfire Emergency Management;
Landscape Management;
Environmental Management; and
Operational management procedures.
Rather than demonstrating that impacts can be avoided now, the proposal relies heavily upon future documentation prepared after approval has already been granted.
This approach shifts considerable uncertainty onto neighbouring residents and reduces the opportunity for meaningful public scrutiny.
State Significant Developments should demonstrate that environmental and community impacts have already been appropriately resolved before consent is issued, rather than relying upon future conditions to address unresolved issues.
5. Traffic and Road Safety
The Transport Impact Assessment concludes that the proposal will generate relatively low traffic impacts and will not materially affect the surrounding road network.
However, transport modelling does not always reflect the practical experience of residents.
Stanhope Road is primarily a quiet residential street used daily by families, pedestrians, cyclists and elderly residents.
Even relatively modest increases in traffic, delivery vehicles, service vehicles and visitor parking can materially affect safety and residential amenity.
In addition, emergency evacuation during bushfire events depends upon efficient movement along Stanhope Road.
While the Bushfire Assessment proposes improved emergency access and evacuation planning, these arrangements are still dependent upon future emergency management planning and operational procedures rather than demonstrated real-world performance.
Given the vulnerability of elderly residents, any uncertainty regarding evacuation capacity should be treated with particular caution.
6. Visual Amenity, Privacy and Residential Enjoyment
The proposal will fundamentally change the outlook experienced by adjoining residents.
The introduction of larger buildings, increased building height, expanded hard surfaces and additional lighting will inevitably affect the privacy and visual amenity currently enjoyed by neighbouring properties.
Although the applicant concludes that visual impacts are acceptable, these assessments are largely based upon professional judgement rather than the lived experience of residents who will face these buildings every day.
As the immediate neighbour at 91 Stanhope Road, I do not believe the cumulative impacts on outlook, privacy, sense of openness and residential character have been adequately acknowledged.
7. Independent Review is Warranted
All major technical assessments supporting this proposal—including planning, transport, bushfire, landscape and environmental reports—have been commissioned by the applicant.
While this is common practice, the scale and environmental sensitivity of this proposal justify an independent peer review before any approval is granted.
Independent review would provide greater confidence that the conclusions reached by the applicant's consultants are robust, objective and fully reflect the interests of the wider community.
8. Public Interest
State Significant Development should not simply deliver improved private facilities.
It should also demonstrably enhance the broader public interest.
In my view, the proposal has not adequately balanced the competing interests of redevelopment, environmental conservation, neighbourhood character and residential amenity.
The long-term urbanisation of a highly sensitive bushland interface, combined with prolonged construction impacts and ongoing vegetation management requirements, represents a significant and lasting change to the local community.
These impacts extend well beyond the boundaries of the development site and deserve careful consideration.
Conclusion
For the reasons outlined above, I respectfully request that the Department refuse the application in its current form.
Should the Department nevertheless consider granting consent, I strongly request that the proposal first be substantially revised to reduce building bulk, better protect neighbouring residential amenity, minimise permanent environmental impacts, provide greater certainty regarding construction management, and undergo independent review of the key technical assessments.
As the immediate neighbour, I respectfully ask the Department to give significant weight to the concerns of affected residents and to ensure that any decision reflects not only the needs of future occupants, but also the long-term environmental, social and community values that make Killara a unique place to live.
Thank you for considering my submission.
Yours faithfully,
I am the owner and resident of a property immediately adjoining the proposed redevelopment of the Lourdes Retirement Village. As one of the residents who will be directly affected by both the construction and long-term operation of this project, I respectfully submit my objection to the proposed development.
At the outset, I acknowledge the importance of providing modern, safe and accessible accommodation for older Australians. I also recognise that the existing retirement village requires renewal and improved bushfire protection. However, the need to modernise the facility should not come at the expense of neighbouring residents, the unique environmental qualities of Killara, or the long-term public interest.
After reviewing the Environmental Impact Statement, Transport Impact Assessment and Bushfire Assessment, I remain concerned that the proposal does not adequately demonstrate that its environmental, traffic, construction and neighbourhood impacts can be satisfactorily managed.
My concerns are outlined below.
1. Permanent Loss of Bushland Character
Killara is widely recognised for its leafy streets, mature tree canopy and close relationship with surrounding bushland. These characteristics are fundamental to the identity of the suburb and are valued by residents throughout the Ku-ring-gai Local Government Area.
Although the applicant states that biodiversity retention has been prioritised and that landscaping will be enhanced, the proposal nevertheless requires extensive site modification, new internal roads, basement excavation, hard surfaces and Asset Protection Zones surrounding much of the development. The cumulative effect of these works will permanently alter the existing landscape character.
Importantly, the proposed Asset Protection Zones are not a temporary measure. They require ongoing vegetation management throughout the life of the development, including regular removal of understorey vegetation, pruning, fuel reduction and continued maintenance to comply with bushfire requirements. While these measures may improve fire protection, they also represent an ongoing reduction in the ecological quality of the bushland interface rather than a one-off impact.
The Environmental Impact Statement presents landscaping as mitigation; however, newly planted ornamental landscaping cannot replace the environmental value, habitat function and mature canopy provided by existing native vegetation.
2. Overdevelopment Within a Sensitive Residential Environment
The applicant repeatedly emphasises that the proposal reduces the number of independent living units from 172 to 145. While numerically correct, this comparison does not adequately reflect the true intensity of the redevelopment.
The proposal introduces nine multi-storey residential buildings, substantial basement parking, new roads, retaining structures and extensive infrastructure works. The overall building bulk, visual presence and urban form will be significantly greater than the existing village.
The proposal therefore represents a substantial increase in built form despite the reduction in dwelling numbers.
As a resident immediately adjoining the site, I am concerned that the redevelopment is inconsistent with the established low-density garden suburb character that has long defined Stanhope Road.
3. Construction Impacts Have Been Underestimated
The most immediate impacts on neighbouring residents will occur during the demolition and construction phases.
The proposal involves demolition of existing buildings, extensive excavation, construction of basement levels, installation of services, retaining walls and new roads before the new buildings can even commence.
These activities are likely to continue over several years.
The reports acknowledge that a detailed Construction Traffic Management Plan will only be prepared at a later stage if consent is granted.
This means that many of the most significant impacts—including heavy vehicle movements, construction traffic routes, worker parking, dust suppression, noise management and pedestrian safety—have not yet been fully assessed.
Residents are therefore being asked to accept substantial uncertainty regarding the impacts that they will experience.
For neighbouring properties such as mine, construction impacts cannot simply be dismissed as temporary inconvenience. Multi-year exposure to continuous construction activity has genuine consequences for residential amenity, health, wellbeing and enjoyment of one's property.
4. Reliance on Future Management Plans
A recurring concern throughout the documentation is the reliance on management plans that are yet to be prepared.
Many significant matters are deferred until after development approval, including:
Construction Traffic Management;
Bushfire Emergency Management;
Landscape Management;
Environmental Management; and
Operational management procedures.
Rather than demonstrating that impacts can be avoided now, the proposal relies heavily upon future documentation prepared after approval has already been granted.
This approach shifts considerable uncertainty onto neighbouring residents and reduces the opportunity for meaningful public scrutiny.
State Significant Developments should demonstrate that environmental and community impacts have already been appropriately resolved before consent is issued, rather than relying upon future conditions to address unresolved issues.
5. Traffic and Road Safety
The Transport Impact Assessment concludes that the proposal will generate relatively low traffic impacts and will not materially affect the surrounding road network.
However, transport modelling does not always reflect the practical experience of residents.
Stanhope Road is primarily a quiet residential street used daily by families, pedestrians, cyclists and elderly residents.
Even relatively modest increases in traffic, delivery vehicles, service vehicles and visitor parking can materially affect safety and residential amenity.
In addition, emergency evacuation during bushfire events depends upon efficient movement along Stanhope Road.
While the Bushfire Assessment proposes improved emergency access and evacuation planning, these arrangements are still dependent upon future emergency management planning and operational procedures rather than demonstrated real-world performance.
Given the vulnerability of elderly residents, any uncertainty regarding evacuation capacity should be treated with particular caution.
6. Visual Amenity, Privacy and Residential Enjoyment
The proposal will fundamentally change the outlook experienced by adjoining residents.
The introduction of larger buildings, increased building height, expanded hard surfaces and additional lighting will inevitably affect the privacy and visual amenity currently enjoyed by neighbouring properties.
Although the applicant concludes that visual impacts are acceptable, these assessments are largely based upon professional judgement rather than the lived experience of residents who will face these buildings every day.
As the immediate neighbour at 91 Stanhope Road, I do not believe the cumulative impacts on outlook, privacy, sense of openness and residential character have been adequately acknowledged.
7. Independent Review is Warranted
All major technical assessments supporting this proposal—including planning, transport, bushfire, landscape and environmental reports—have been commissioned by the applicant.
While this is common practice, the scale and environmental sensitivity of this proposal justify an independent peer review before any approval is granted.
Independent review would provide greater confidence that the conclusions reached by the applicant's consultants are robust, objective and fully reflect the interests of the wider community.
8. Public Interest
State Significant Development should not simply deliver improved private facilities.
It should also demonstrably enhance the broader public interest.
In my view, the proposal has not adequately balanced the competing interests of redevelopment, environmental conservation, neighbourhood character and residential amenity.
The long-term urbanisation of a highly sensitive bushland interface, combined with prolonged construction impacts and ongoing vegetation management requirements, represents a significant and lasting change to the local community.
These impacts extend well beyond the boundaries of the development site and deserve careful consideration.
Conclusion
For the reasons outlined above, I respectfully request that the Department refuse the application in its current form.
Should the Department nevertheless consider granting consent, I strongly request that the proposal first be substantially revised to reduce building bulk, better protect neighbouring residential amenity, minimise permanent environmental impacts, provide greater certainty regarding construction management, and undergo independent review of the key technical assessments.
As the immediate neighbour, I respectfully ask the Department to give significant weight to the concerns of affected residents and to ensure that any decision reflects not only the needs of future occupants, but also the long-term environmental, social and community values that make Killara a unique place to live.
Thank you for considering my submission.
Yours faithfully,
Name Withheld
Object
Name Withheld
Object
LINDFIELD
,
New South Wales
Message
This development is of a scale that will significantly impact on the local environment. The height of the development will overlook the surrounding bush and visually impact on properties across the valley on Northcote Rd. The excavation and building work will generate damaging run off into Gordon Creek.
Furthermore, Lindfield cannot accommodate increased population density of this scale. Our local roads are highly congested with traffic pinch points especially around the railway bridges at Lindfield shops.
Furthermore, Lindfield cannot accommodate increased population density of this scale. Our local roads are highly congested with traffic pinch points especially around the railway bridges at Lindfield shops.
Daniel Mendes
Support
Daniel Mendes
Support
Chatswood
,
New South Wales
Message
I support the project
Issac Leung
Object
Issac Leung
Object
KILLARA
,
New South Wales
Message
There is to much to write here, our submission is attached in the word document.
Attachments
Qi Ma
Object
Qi Ma
Object
KILLARA
,
New South Wales
Message
The proposed development would create a serious and unacceptable safety risk by concentrating a high density of frail and vulnerable residents in a geographically constrained cul-de-sac that is served by a single access route. Stanhope Road is a narrow road with limited capacity and functions as a critical single point of access and egress. In any emergency, particularly a bushfire event, the lack of alternative escape routes would significantly compromise evacuation and emergency response capabilities.
The proposal would intensify population density in an area surrounded by bushland, substantially increasing risk exposure for residents who may have reduced mobility and require assistance to evacuate. Locating a large number of aged and frail residents in such a constrained environment is inconsistent with fundamental life safety principles and raises serious concerns regarding emergency management, evacuation feasibility, and resident protection.
Furthermore, the development appears to be contrary to the intent and objectives of the NSW Planning for Bush Fire Protection Guidelines, which emphasise safe access and egress, evacuation capability, and the protection of life as paramount considerations in bushfire-prone areas. The reliance on a single narrow access road represents a significant bottleneck that could become impassable during a bushfire emergency, placing residents, staff, and emergency services personnel at unacceptable risk.
For these reasons, the proposal should be refused unless it can clearly demonstrate compliance with bushfire safety requirements and provide safe, reliable, and redundant access arrangements that adequately protect vulnerable residents during emergency events.
This sis a holding submission; i reserve the right to submit the detailed independent safety review as the assessment progresses
The proposal would intensify population density in an area surrounded by bushland, substantially increasing risk exposure for residents who may have reduced mobility and require assistance to evacuate. Locating a large number of aged and frail residents in such a constrained environment is inconsistent with fundamental life safety principles and raises serious concerns regarding emergency management, evacuation feasibility, and resident protection.
Furthermore, the development appears to be contrary to the intent and objectives of the NSW Planning for Bush Fire Protection Guidelines, which emphasise safe access and egress, evacuation capability, and the protection of life as paramount considerations in bushfire-prone areas. The reliance on a single narrow access road represents a significant bottleneck that could become impassable during a bushfire emergency, placing residents, staff, and emergency services personnel at unacceptable risk.
For these reasons, the proposal should be refused unless it can clearly demonstrate compliance with bushfire safety requirements and provide safe, reliable, and redundant access arrangements that adequately protect vulnerable residents during emergency events.
This sis a holding submission; i reserve the right to submit the detailed independent safety review as the assessment progresses
Xin Song (Steven) Qu
Object
Xin Song (Steven) Qu
Object
Killara
,
New South Wales
Message
I strongly object to this proposal on traffic safety and emergency access grounds.
The Stanhope Road intersection already experiences significant congestion and gridlock. In the event of a bushfire, medical emergency, or other evacuation scenario, the intersection would become a critical choke point. The escape route is unacceptably narrow and could be completely blocked by queued traffic, effectively trapping residents within the neighbourhood and preventing both evacuation and emergency vehicle access.
This creates an unacceptable risk to public safety. A road network that relies on a single constrained intersection for access and egress lacks the resilience required during emergencies. Any additional traffic generated by the proposal is likely to exacerbate existing congestion and increase the likelihood of total intersection failure during peak periods or emergency events.
This is a holding submission. I reserve the right to provide further detailed traffic, transport, and emergency access evidence, including expert analysis, at a later stage.
Accordingly, the application should not be approved unless it can be conclusively demonstrated that the Stanhope Road intersection and associated road network can safely accommodate additional traffic while maintaining reliable emergency access and evacuation capacity for all residents.
This is a holding submission; i reserve the right to tender detailed traffic arguments.
The Stanhope Road intersection already experiences significant congestion and gridlock. In the event of a bushfire, medical emergency, or other evacuation scenario, the intersection would become a critical choke point. The escape route is unacceptably narrow and could be completely blocked by queued traffic, effectively trapping residents within the neighbourhood and preventing both evacuation and emergency vehicle access.
This creates an unacceptable risk to public safety. A road network that relies on a single constrained intersection for access and egress lacks the resilience required during emergencies. Any additional traffic generated by the proposal is likely to exacerbate existing congestion and increase the likelihood of total intersection failure during peak periods or emergency events.
This is a holding submission. I reserve the right to provide further detailed traffic, transport, and emergency access evidence, including expert analysis, at a later stage.
Accordingly, the application should not be approved unless it can be conclusively demonstrated that the Stanhope Road intersection and associated road network can safely accommodate additional traffic while maintaining reliable emergency access and evacuation capacity for all residents.
This is a holding submission; i reserve the right to tender detailed traffic arguments.
Name Withheld
Object
Name Withheld
Object
KILLARA
,
New South Wales
Message
Unrealistic traffic generation modeling: The developer’s traffic reports drastically underestimate the actual daily vehicle movements of shift-changing staff, nursing specialists, medical deliveries, and visiting families. There is only one entry to the whole project, which I think would terribly affect our daily travel through the Stanhope road. This is a holding submission; I reserve the right to tender detailed traffic arguments.
Name Withheld
Object
Name Withheld
Object
Killara
,
New South Wales
Message
Very harmful for local communities, road are narrow and quite , can not afforded for such huge projects and population.
Name Withheld
Object
Name Withheld
Object
Killara
,
New South Wales
Message
Inadequate On-site Parking Provision: Under-sizing the on-site parking spaces will force staff and visitors to park illegally or overflow onto the already narrow, chocked lanes of Stanhope road. this is a holding submission; I reserve the right to tender detailed traffic arguments.
Name Withheld
Object
Name Withheld
Object
KILLARA
,
New South Wales
Message
Strain on Local Water and Sewage Infrastructure:The existing local utility, water and sewage networks are not built to absorb a sudden high-density institutional surge of this magnitude.This is a holding submission. I reserve the right to submit independent hydraulic analysis.
Guilin Li
Object
Guilin Li
Object
KILLARA
,
New South Wales
Message
Psychological Harm to Current Vulnerable Residents:Forcing the frail, elderly residents currently living on-site to endure years of high-impact demolition,structural drilling,and heavy dust poses an unacceptable risk to their health and wellbeing.This is a holding submission.I reserve the right to submit further evidence regarding aged-care welfare.