Mixed Use Development 1 King Street Concord West

I write to formally object to the proposed development at 1 King Street, Concord West, which seeks to construct a 144-metre high-rise building containing approximately 1,400 residential units. This proposal represents a gross overdevelopment that is fundamentally unsustainable and incompatible with the area's character, infrastructure capacity, and planning controls.
________________________________________
1. Gross Non-Compliance with Height Controls
The proposal seeks a building height of 144 metres in an area where the maximum permitted height is 22 metres. This represents a 554% breach of existing planning controls. Such an extreme departure from established height limits:
• Undermines the integrity of the local planning framework
• Sets a dangerous precedent for future overdevelopment
• Demonstrates disregard for community-endorsed planning vision
• Cannot be justified under any reasonable planning assessment.
Height controls exist to protect neighbourhood character, view corridors, and to ensure development is proportionate to infrastructure capacity. This proposal violates all these principles.
________________________________________
2. Transport Infrastructure Inadequacy
Rhodes Station Overcrowding
Rhodes Station is already operating beyond comfortable capacity during peak periods. The addition of 1,400 units (potentially 2,000-3,500+ residents) would:
• Exacerbate dangerous overcrowding on platforms
• Increase wait times as commuters cannot board full trains
• Create safety risks during emergency evacuations
• Further strain a station that already experiences regular service disruptions.
Road Network Congestion
George Street and Pomeroy Street are already congested during peak periods. This development would add:
• Approximately 1,400-2,100 additional vehicles (assuming 1-1.5 cars per unit)
• Increased delivery and service vehicle traffic
• Construction traffic impacts lasting several years
• Reduced traffic flow and increased journey times for existing residents.
No traffic assessment can adequately mitigate the impact of adding this volume of vehicles to local roads that lack capacity for expansion.
________________________________________
3. Train Service Capacity
Trains serving Rhodes Station and Concord West are already at or beyond capacity during peak periods. The T9 Northern Line experiences:
• Commuters unable to board during morning and evening peaks
• Standing room only from Rhodes through to the CBD
• No planned infrastructure upgrades to increase service frequency or train capacity.
Adding thousands of new residents will make an already untenable situation completely unworkable, forcing residents into cars and worsening road congestion.
________________________________________
4. Community Infrastructure Deficits
The proposed density would create severe pressure on:
Schools
• Local primary and secondary schools are already at or near capacity
• No new schools are planned for the immediate area
• Increased demand would force children to travel greater distances.
Medical Services
• Local GP clinics and medical centres would face increased demand
• Hospital emergency departments already under pressure
• Ambulance response times may be affected by traffic congestion.
Parks and Open Space
• The development provides inadequate communal open space for 1,400 units
• Existing local parks would face unsustainable pressure
• Recreation facilities cannot accommodate such population growth.
Childcare
• Childcare centres in the area already have extensive waiting lists
• Demand from new families cannot be met by existing facilities.
________________________________________
5. Environmental and Amenity Concerns
Overshadowing
A 144-metre tower would cast extensive shadows over:
• Neighbouring residential properties
• Public parks and recreation areas
• Surrounding streets, reducing amenity and safety.
Wind Impacts
High-rise buildings of this scale create dangerous wind tunnels at street level, making public spaces uncomfortable and potentially unsafe.
Visual Impact
The proposed height is completely out of character with the surrounding area, creating a wall effect and dominating the skyline inappropriately.
Construction Impacts
Construction of this scale would create:
• Years of noise, dust, and vibration affecting nearby residents
• Heavy vehicle movements damaging local roads
• Parking and access disruptions.
________________________________________
6. Sustainability Concerns
This proposal is fundamentally unsustainable:
Energy Grid
• Local electricity network may require augmentation
• Increased peak demand contributing to grid stress.
Waste Management
• 1,400 units will generate enormous waste volumes
• Collection and disposal infrastructure inadequate
• Increased waste vehicle movements on local streets.
Social Sustainability
• Overdevelopment creates communities without adequate services
• Reduces quality of life for existing and future residents
• Creates car-dependent populations despite proximity to train station.
________________________________________
7. Affordable Housing and Social Mix
High-density developments of this scale typically:
• Deliver minimal genuine affordable housing
• Create imbalanced communities lacking diversity
• Result in investor-owned units with high tenant turnover
• Fail to build stable, connected neighbourhoods.
________________________________________
8. Precedent Setting
Approval of this development would:
• Signal that planning controls are meaningless
• Encourage similar excessive proposals across the area
• Undermine community trust in the planning system
• Lead to cumulative overdevelopment impacts.
________________________________________
Conclusion
This proposal represents opportunistic overdevelopment that prioritises developer profit over community wellbeing, infrastructure capacity, and planning integrity. The extreme departure from height controls, combined with inadequate transport infrastructure, overcrowded trains, and insufficient community facilities, renders this development fundamentally unsustainable.
I urge the planning authority to:
1. Refuse this application on grounds of non-compliance with height controls
2. Refuse this application on grounds of infrastructure inadequacy
3. Uphold existing planning controls that reflect community expectations
4. Require any future proposal to comply with the 22-metre height limit
5. Conduct comprehensive infrastructure planning before considering density increases.
The community deserves development that enhances liveability, respects planning controls, and provides necessary infrastructure. This proposal fails on all counts.

I wish to lodge a formal objection to the proposed Bilbergia development at 1 King St Concord West. This proposal represents urban growth that is detrimental to the capacity and character of the area. My concerns are as follows:
1. Building Height
The updated building height proposal of 144 metres is drastically above the current maximum building height allowance of 22 metres. This dramatic change will irreversibly alter the skyline and character of Concord West, which is valued for its traditionally single-home or low-rise apartment block character. This is not a minor variation; it is a complete transformation that disregards planning harmony and visual cohesion.
2. Overdevelopment and Population Density
The proposal includes 1300 apartments across 8 towers (6-38 storeys). This density is incompatible with existing infrastructure and community fabric. It risks creating a congested, high-rise enclave in an area historically defined by detached homes and open streetscapes.
3. Traffic and Access Risks
The proposed site is served by a single primary access road in and out; a road and existing junction already under pressure. Adding thousands of residents and their vehicles (plus daily delivery/service vehicles etc) will create dramatic and dangerous congestion, impede emergency access and degrade road safety. This extra traffic load will also impact existing residents and access to their properties. No credible traffic mitigation measures have been outlined, nor is there any evidence of sympathetic community understanding of this issue.
4. Inadequate Public Transport
Concord West and Rhodes train stations are already overcrowded during peak hours. This development will exacerbate the strain without any commitment to new rail capacity or additional bus services. Furthermore, there are no bus stops or separated cycleways near the site, undermining sustainable transport options.
5. Pressure on Local Healthcare
Concord Hospital, the primary health facility for the area, is already operating near capacity. Adding potentially thousands of new residents without corresponding investment in healthcare infrastructure is irresponsible and will compromise community wellbeing.
6. Loss of Suburban Character
This development will erode the unique identity of Concord West. High-rise towers will overshadow (both literally and figuratively) heritage streetscapes, creating visual disharmony and diminish the suburb's distinctive character. The social impact is equally concerning; rapid densification often weakens established community networks and reduces liveability.
7. Infrastructure Strain
Schools, parks and utilities will be overwhelmed by the proposed population increase.
8. Environmental Impact
Large-scale excavation for basements and loop roads will disrupt local ecosystems and increase flood risk. High-rise buildings will create shadows effecting established green environments. Large scale development adds paved surfaces, raising the heat levels at ground level. Adding 5000+ new residents creates added rubbish. These rubbish and recycling needs will put pressure on an already inadequate system. Canada Bay Council does not yet support large scale unit-block recycling education programs that work.
9. Precedent
Approving this high-rise development application sets a dangerous precedent for unchecked and unethical high-rise expansion in similar low-density, traditional suburbs.
In conclusion, I urge the Department to rethink the scale of this proposal. Respect must be given to the established community - its character, capacity, capabilities, infrastructure. The lives and liveability of established residents MUST be considered before approving this development.

I object to the project because:
* Building height is excessive (allowed 22m, proposed 144m)
* Number of homes is too high (600 -> 1400)
* Public transport is insufficient
* Traffic will increase. George Street is already jammed during school hours
* Concord Hospital cannot handle the extra population
* Security concerns to the quiet neighbourhood due to the increased population
I urge the Department to carefully consider these concerns before approving this development.

Object to increase the maximum height of building standard from 55 m to 144m. This can significantly affect exposure to sunlight to neighborhoods. Further, the increase of height will bring much more residents that adversely affect local traffic. There is no other way out from 1 King Street via George street to other suburbs and vice versa. Now the traffic is very bad during school time. If no other connection roads are built, the traffic can only be much worse.

So many new apartments (1400 new homes! ) can cause very bad traffic congestion around my area. There is only one road in and out, the proposed 1468 new parking spaces can bring potentially 1500 new cars to this road.
Current public transportation can not support such many new families. Concord West train station has already been full for only 15min/T9 train. No buses stopping at concord west station as well.
Concerns on Healthcare, as we have limited position at Concord Hopital for more and more families around this area.

Do not support the proposal of increasing the maximum height of building standard to 144 metres to allow for 38 storey buildings - Rhodes and Wentworth point clearly demonstrate that such high density living with ‘one road in and one road out’ creates grid locks and increased traffic risks. George Street and Pomeroy Street already have seen an immense increase in traffic in recent years, and with the recent development of two new low rise and medium density dwelling sites on George Street and Rothwell Ave, traffic is expected to increase further once new occupants move in.

To Whom It May Concern,
I am writing to share my thoughts on the proposed development at 1 King Street, Concord West. While I understand the need for growth in our area, I have several serious concerns regarding the scale of this project and how it will impact our local community.
Specifically, I’d like to highlight the following issues:
• The Scale of the Buildings: The proposed height of 144 m is a massive jump from 55 m. Such a tall structure feels out of character for our neighborhood and would be quite overwhelming for the surrounding streets.
• Population Density: Increasing the number of homes from 600 to 1,300 is a huge shift. I’m worried that our local infrastructure simply isn't ready for that many new residents all at once.
• Traffic and Safety: This is the most important issue. With only one road leading in and out, traffic is already a challenge. Adding hundreds of more cars would make daily commutes difficult and, more importantly, could create safety issues for emergency access.
• Public Transport Pressure: Our local stations at North Strathfield, Concord West and Rhodes are already very crowded during peak hours. Without a significant boost to services, adding 1,300 new households will make the commute even tougher for everyone.
• Essential Services: Our local healthcare system, particularly Concord Hospital, is already under a lot of pressure. I’m concerned that our medical services won’t be able to keep up with such a sudden influx of people.
I truly hope the Department takes these community concerns to heart when reviewing the proposal. We want to ensure that any new development helps this area thrive rather than putting too much strain on the people who live here.
Thank you for taking the time to read my submission.
Best regards,
Yen-Ju Lin

I am making a submission regarding the proposed Bilbergia development at 1 King Street, Concord West.
I object to the proposal because:
Building height is genuinely too excessive for the surrounding homes nearby. And with the height, comes an excessive amount of people that will reside in them, which will cause MAJOR traffic issues. There is quite literally only one road in and out to this area (from pomeroy/george st) and with conjestion with parking and movement of private vehicles instigated from constant events at Sydney Olympic Park and daily school drop offs and pickups at the public school on Victoria Ave, this will exacerbate the traffic. I am wholeheartedly and logically objecting this project if there is only one road to get in and out. I would be much less resistant if there was a road connecting King St and Queen St, like a road crossing above the Concord West Station, because at the moment there is only a tiny pedestrian tunnel.

Either way, even if another road was added to connect the King St side of the station to the Queen St side, I would still very much object the height of the development, it is genuinely inconsiderate of those who have been living here and clearly there is zero consideration for the opposing opinions to this project. I have attended zooms and in person meetings and in both circumstances I felt as if my concerns were not addressed but rather a deflective response was given. For example it would constantly be along the lines of "we have conducted research into this area...." or "we don't have the answers to give for that yet, but we assure it will be good" essentially dismissing our opinions. This way, with each opportunity we are given to voice our opinions certainly feels like a box ticking exercise, and although I have received comments saying this is absolutely not a box ticking exercise, it still feels that way, as there is absolutely no change or action taken to our concerns.

I will state that if this development goes ahead without a second road/means to get in and out being developed, that this has ABSOLUTELY been a box ticking exercise. You may have conducted "research" in traffic flow and what not, but we/I the resident/s, who actually live here, who first hand experience the daily life and ongoings in this area would 100% have much more accurate insight than any technology simulation of traffic you have conducted.

I respectfully urge the Department to carefully consider these concerns before approving this development.

This development sits within a small alcove of residential homes. To think that a 38 story Tower is even remotely possible amongst this quiet low rise suburb is abhorrent. There is only one access road in existence with no plans for additional access to be made to the area. Currently to leave my street and turn right to head towards Pomeroy Street and Parramatta road, we have a significant wait as traffic is built up back to this one King Street development and we are required to turn left and then u turn to join the traffic to try and exit the area. With one lane in to this area and only one lane out, it is ludicrous to think that this section of North Strathfield and Concord West can possibly cope with any more congestion and hundreds of additional cars. A further concern is the equipment, machinery and large to enormous vehicles required to construct this enormous tower and adjoining towers. The area is already stretched with medical centres and our local Concord Hospital beyond capacity. My family has had to be treated laying across chairs in a hallway at Concord Hospital as there is no capacity for more patients. Local doctors are having to be booked three weeks in advance with little possibility of an appointment sooner. Our schools in the area have waiting lists for years. The day cares also have ridiculous waiting times for families.

Please come out to our area, please come and look at the low rise developments that have just been completed. They are in keeping with the landscape of this section of North Strathfield and Concord West. They are not ridiculous tall towers that can be seen for miles away that take over our beautiful landscape and our beautiful vista. This is not the correct site for a tower of that capacity and that heigh. The original plans for four to five low rise towers with commercial underneath was far more in keeping with the current landscape that our suburb has. For these developers to try and convince myself and my neighbours that people who reside in this tower and adjoining towers will not have motor vehicles is non sensical. To think that people look after their families and do their grocery shopping without a motor vehicle is a ridiculous suggestion and something that does not equate to living in 2025.

Our area was rezoned with some of my neighbours thinking they were going to be instant millionaires and much to their disappointment here we are all now trying to save our suburb from this horrendous development. Developers do not have the pockets deep enough to purchase our beautiful homes in this beautiful area and provide us with the compensation we deserve for tearing down our homes and building multiple unit complexes that are not necessary. We have two recently completed low rise apartment blocks, a huge block is going up next to Rosebank college at Five Dock. There are further blocks being built at Rhodes and in Sydney Olympic Park. I implore you to leave our small section of North Strathfield and Concord West to low rise development. We will end up in oversupply in this area and it is not necessary to have such an enormous Tower in a small nook of Concord West, without any further access point other than our one lane in and our one lane. The Tower will be a huge eyesore to the rest of Concord West and North Strathfield and will devalue our properties. A tower that will require ridiculous sized machinery to be able to build that will destroy our one road and that will create endless issues for people trying to commute both the Concord West and North Strathfield stations. A tower with adjoining towers and another 1300 units is not necessary in this section of our suburb, it is absolute overkill and it will overshadow all the residents in that part of Concord West that simply have a domestic home to live in. Reports that you have been provided are from old studies. There is no way that Bilbergia conducted up to date current studies of our area. You only need to be here in the morning, at school time, on a weekend or even during the day to see the bottle neck that is created on Pomeroy Street through to Underwood road through to Parramatta road and on George Street. It is a complete gridlock and it does not move. If you are trying to get to your home at any of those times you are stuck in an area where traffic does not move. George Street has no further capacity for more traffic!!!!

As I mentioned earlier, please remove yourself from your desks and your screens, drive down George Street in the morning, at school time, in afternoon peak hour an experience the reality of the fact that we are at capacity in this area of North Strathfield and Concord West. The implications of a development of this size is enormous. Please insist that these developers who are only interested in their bottom line, build a low rise complex. They have already made their billions at Rhodes, please leave this small residential pocket alone.

George street will not cope with the increase in traffic. There is only one way in at out . The traffic was bad when wests pac was there . Also Concord West station will be flooded with extra passengers . The trains already full from Rhodes passengers . Sometimes it is impossible to get on a train cause of all the Wentworth point passengers . I am comforted about the increase of traffic this will cause . George street is not wide enough to cope with traffic from 1300 apartments . Concord west station will not cope with extra passages from 1300 passengers . It’s bad enough now . I object to this proposal.

To: NSW Department of Planning, Housing and Infrastructure
Subject: Formal Objection to SSD-81999457 – 1 King Street, Concord West
Application Name: Mixed-use development – 1 King Street, Concord West
Submitter Status: Resident of Mackenzie Street, Concord West

Attn: Director, State Significant Development Assessments,
I am writing to lodge a strong objection to the State Significant Development (SSD) application for 1 King Street, Concord West. While I support the sustainable renewal of the former Westpac site, the current proposal is an extreme over-development of a geographically constrained site that lacks the necessary infrastructure to support it.

My objection is based on the following legal, statistical, and planning grounds:
1. Failure of Strategic Planning Merit & Recent Regulatory Controls
This proposal represents a disregard for the recently established planning controls for the area.
* The 400% Breach: As of late 2025, the Canada Bay Local Environmental Plan (LEP) 2013 was updated to allow for heights of 20m to 42m on this site. This SSD seeks to jump to 144m (38 storeys).
* Section 4.15(1)(a) Objection: Under the EP&A Act 1979, the consent authority must consider local planning instruments. Approving a height nearly four times the recently gazetted limit undermines the integrity of the NSW planning system and ignores the "orderly and economic use" of the land.

2. Infrastructure Failure: The 2029 Development Gap
Transport for NSW (TfNSW) data confirms that the local road network is already at a breaking point.
* Homebush Bay Drive / Underwood Road: This intersection currently operates at Level of Service (LoS) F (Total Failure) during peak periods, handling over 4,500 vehicles per hour.
* The Lag: The $200 million upgrade to this intersection is not scheduled for completion until 2029. Approving 1,300+ apartments (and approximately 1,500 additional vehicle movements) before this upgrade is operational is planning negligence.
* The George Street Bottleneck: The reliance on "filtered" right turns (turns without dedicated green arrows) at George Street means that increased volume will result in permanent gridlock, with queues spilling back into residential Mackenzie and Tenterfield Streets.

3. The "Alcove" Safety Risk & Demand for New Access
The Concord West precinct is a geographical "alcove" with only one primary vehicle access point.
* Emergency Access & Resilience: High-density precincts must have resilient evacuation and emergency access routes. The current one-way-in, one-way-out configuration via George Street and the Correys Avenue rail crossing is unsafe for an additional 3,000 residents.
* The Requirement: I propose that no planning approval be considered until the NSW Government gazettes a New Concord West Traffic & Access Master Plan. This must include a new road connection or bridge (e.g., a grade-separated crossing over the Northern Rail Line) to provide a secondary ingress/egress point for the site.

4. Commercial Yield vs. Public Interest
The site’s value uplift from industrial to a 38-storey residential precinct represents a multi-billion dollar windfall for the developer.
* Inadequate Contribution: The proposed infrastructure contributions represent a fraction of the project’s end-value and are insufficient to remediate the systemic traffic failures it will cause.
* Community Impact: The developer captures the profit while the residents of Concord West pay the price in lost privacy, permanent overshadowing of low-rise Mackenzie Street, and a significant decrease in local livability.

Conclusion
I urge the Department to reject the 144m height proposal and enforce a design in keeping with the 600-dwelling/42m limit previously identified by the City of Canada Bay. Development must be infrastructure-led; until the Homebush Bay Drive upgrades are completed and a second road access point for the King Street alcove is secured, this site is physically unsuitable for this level of density.
Sincerely,
Robert
Mackenzie Street, Concord West

Eight buildings ranging in height of between 6 and 38 storeys is a significant diverge from established planning frameworks in Greater Sydney. This is well outside the scale and bulk of what is considered appropriate for NSWs Transport-Oriented Development framework (maximum 24m height for buildings containing shop top housing) which has been applied to nearby North Strathfield Metro precincts. This project fails to deliver the “missing middle” density, runs counter to design and amenity guidelines, and risks overwhelming infrastructure and local character.

I am making a submission regarding the proposed Bilbergia development at 1 King Street, Concord West.
I object to the proposal because:
• Building height is excessive (allowed 22 m, proposed 144 m)
• Number of homes is too high (600 → 1400)
• Traffic will increase dangerously; only one road in/out
• Public transport is insufficient; Concord West Station and Rhodes Station are overcrowded
• No bus stops or separated cycleways nearby
• Local healthcare (Concord Hospital) cannot handle the extra population
I urge the Department to carefully consider these concerns before approving this development.

I strongly support the NSW Government’s decision on Concord Central. This project will bring much-needed housing, create jobs, and boost the local economy. It will also make the area more lively and vibrant. Once the shopping centre opens, residents will have easy access to everyday shopping and services right on their doorstep, instead of having to travel to Rhodes. This will make daily life much more convenient and greatly improve the quality of life for people in the community. Overall, this is a very positive and welcome development.

I support the NSW Government’s decision regarding Concord Central because it will significantly increase housing supply, generate additional tax revenue, and create employment opportunities. The development will also bring greater vitality to the local community. Once the shopping centre is completed and opens, residents will enjoy much more convenient access to everyday shopping and services, without needing to travel to Rhodes. This will greatly improve quality of life for people living in the area and is a very positive outcome overall.

I am writing to formally object to the proposed development at 1 King Street, Concord West due to the significant and unacceptable impacts it will have on the local area and surrounding community.

1. Traffic Congestion and Local Road Safety

The proposal will substantially increase traffic volumes on King Street, George Street, Parramatta Road access points, and surrounding local streets, which already experience congestion during peak hours.

King Street and surrounding roads are not designed to accommodate the traffic generated by over 1,300 new dwellings, retail uses, service vehicles, and construction traffic. Increased congestion will negatively impact:
- Residents accessing Concord West Station
- School drop-off and pick-up traffic
- Emergency vehicle access
- Pedestrian and cyclist safety, particularly near intersections and narrow footpaths

The existing road network lacks capacity, and there is no certainty that required upgrades will be delivered in advance of occupation.

2. Strain on Concord West Train Station and Public Transport

Concord West Station is already heavily used during peak periods, with overcrowded platforms in Rhodes, this will lead to overcrowding at Concord West Station who those commuting into the city and limited accessibility. A development of this scale will place further pressure on:
- Peak-hour train services
- Overcrowded train station posing a safety risk to passengers
- Station access points and pedestrian pathways
- Limited commuter parking in surrounding streets

There is insufficient evidence that public transport infrastructure can absorb the population increase without a decline in service quality and commuter safety.

3. Overshadowing, Loss of Sunlight and Privacy

The proposed tower heights (up to approximately 38 storeys) will result in:
- Significant overshadowing of nearby residential areas
- Loss of sunlight to homes, balconies, and public spaces
- Reduced solar access, particularly in winter months

Residents in surrounding streets will experience loss of privacy due to elevated sightlines into homes and private open spaces, which will permanently reduce residential amenity.

4. Incompatibility with Local Character

Concord West is characterised by low-rise residential housing and small-scale industrial land, not high-rise residential towers. The scale and density of this proposal is entirely inconsistent with the existing and desired character of the suburb.

The development represents an abrupt and extreme transition in built form, rather than a gradual or sensitive response to the local context.

5. Insufficient Community Infrastructure

The proposal will significantly increase demand on already stretched local infrastructure, including:
- Schools and childcare services
- Medical centres and health services
- Parks, open space and recreational facilities

There is inadequate provision of new community infrastructure relative to the scale of population increase, which will diminish the quality of life for both new and existing residents.

6. Flooding and Environmental Concerns

The Concord West area has known stormwater and flooding sensitivities. The scale of this development, with extensive hard surfaces and basement structures, risks:
- Increasing stormwater runoff
- Exacerbating local flooding issues
- Reducing environmental resilience during extreme weather events

Mitigation measures proposed do not adequately address cumulative flood risk.

7. Construction Impacts

The prolonged construction period will cause ongoing disruption including:
- Noise and vibration
- Dust and air quality impacts
- Heavy vehicle movements through residential streets
- Loss of on-street parking

These impacts will affect residents for many years, not just during short-term works.

Conclusion

The proposed development at 1 King Street, Concord West is excessive in scale, incompatible with the local area, and will place unacceptable strain on transport, infrastructure, and community amenity.

For these reasons, I request that the proposal be refused or substantially redesigned, with:
- Significantly reduced building heights and density
- Proper transport and infrastructure upgrades guaranteed
- A design that better reflects the character and capacity of Concord West

Submission Objecting to State Significant Development SSD-81999457
1 King Street, Concord West
I object to the above State Significant Development application. I am a resident living in very close proximity to the subject site and will be directly and adversely affected by the construction and operation of the proposed development.

While I acknowledge the strategic importance of development, the application, as submitted, fails to demonstrate that the scale and intensity of the proposal can be delivered without unacceptable impacts on nearby residents, and therefore does not satisfy the public interest test under the Environmental Planning and Assessment Act 1979.

1. Construction Traffic and Parking Impacts
The proposal involves the construction of eight buildings up to 38 storeys, including extensive basement excavation, resulting in a prolonged construction period with a large workforce and heavy vehicle movements.
Although the EIS includes discussion of construction traffic and access (refer EIS Section [Construction Traffic / Transport]), it fails to provide sufficient certainty that construction workers will not rely on surrounding residential streets for parking. Existing parking in the area is already constrained, and the displacement of resident parking has not been adequately assessed.
Consistent with recent SSD refusal reasoning, the proposal relies on management measures rather than demonstrated outcomes, and does not provide enforceable mechanisms to ensure construction-related parking and access impacts are avoided rather than merely mitigated.

2. Dust, Dirt, Noise and Environmental Impacts
The scale and duration of excavation and construction works will generate ongoing dust, dirt, noise, and vibration impacts over several years.
While the EIS proposes standard mitigation measures (refer EIS Section [Construction Environmental Management / Air Quality / Noise]), these measures are generic in nature and do not adequately respond to the proximity of existing residences or the cumulative impacts of multiple concurrent construction activities.
As has been noted in recent SSD decisions, the absence of detailed, site-specific and enforceable controls results in insufficient certainty that impacts can be managed to an acceptable level, particularly over a prolonged construction period.

3. Residential Amenity and Public Interest
The cumulative construction impacts will result in a significant and prolonged loss of residential amenity for nearby residents. These impacts include reduced access, loss of parking, degraded air quality, persistent noise, and disruption to daily life.
The EIS does not adequately demonstrate that these impacts are reasonable, necessary, or proportionate to the public benefits claimed. In practical terms, the impacts will be borne disproportionately by nearby residents, while the primary benefits accrue to the proponent.
Accordingly, the proposal fails to strike an appropriate balance between development outcomes and community wellbeing, and does not demonstrate that it is in the public interest.

For the reasons outlined above, previous applications and projects in the areas have failed to demonstrate that construction and environmental impacts can be adequately managed or that residential amenity will be appropriately protected. In its current form, the proposal should not be approved.
At a minimum, the application should be substantially amended and supported by robust, enforceable and site-specific construction management measures before any approval is contemplated.

As a local resident, I am also concerned that the proposed site-specific rezoning, including the introduction of significantly increased building heights and floor space ratios, is inconsistent with the objectives of the Canada Bay Local Environmental Plan 2013, particularly as they apply to land zoned R3 Medium Density Residential in the surrounding area.
The R3 zone under the Canada Bay LEP 2013 is intended to provide for medium-density housing in a manner that is compatible with the existing character of the area, while ensuring a reasonable scale transition between different forms of development and protecting residential amenity. The proposed rezoning departs substantially from these objectives by enabling development of a scale and intensity that is wholly inconsistent with the established and planned R3 context.
By permitting building heights of up to approximately 144 metres on a single site, the proposal establishes an exceptional planning outcome that undermines the orderly and economic use of land envisaged by the LEP. It creates a significant disparity between the development potential of the subject site and that of surrounding R3-zoned properties, effectively constraining the future redevelopment options of neighbouring land while exposing them to increased amenity impacts such as overshadowing, visual dominance, and loss of privacy.
This approach erodes planning certainty for local residents and represents ad-hoc, site-specific planning rather than a strategic, precinct-based approach consistent with the LEP’s objectives. In my view, the proposal fails to properly respect the intent of the Canada Bay LEP 2013 and does not achieve an appropriate balance between intensified development and the protection of existing residential areas.

If the Department and the Minister consider that the scale and intensity proposed for the subject site are appropriate for this location, then it is reasonable to expect that surrounding land within the same planning context be given equitable consideration for similar future planning outcomes.
At present, nearby properties zoned R3 Medium Density Residential remain constrained by significantly lower height and floor space controls under the Canada Bay LEP 2013, while the subject site is proposed to benefit from a substantial, site-specific uplift. This creates a clear inconsistency in planning outcomes and places surrounding landowners at a long-term disadvantage, both in terms of development potential and amenity impacts.
Local residents reasonably expect that planning controls will be applied consistently and transparently, and that significant changes to height and density will occur through a strategic, precinct-wide rezoning process, rather than through isolated amendments that benefit a single site. If increased heights and densities are considered appropriate in this location, then a broader review of planning controls for the surrounding area should be undertaken to ensure fairness, certainty, and alignment with the principles of orderly and economic planning.
In the absence of such a strategic approach, the proposal risks undermining confidence in the planning framework and fails to appropriately balance private development uplift with the reasonable expectations of neighbouring landowners.

Appendix EE SSDA Noise & Vibration Impact Assessment

This review of Appendix EE – Noise and Vibration Impact Assessment identifies a number of material deficiencies in the assessment of construction-related impacts on nearby residents. While the report models individual noise and vibration sources, it does not adequately address the cumulative, prolonged, and residential-scale impacts arising from a development of this size and duration.
The assessment relies heavily on assumptions, generic mitigation measures, and the deferral of critical matters to post-approval management plans. As a result, it fails to provide the level of certainty required to demonstrate that construction noise, vibration, and associated impacts can be managed to an acceptable level over the life of the project.
The findings below outline why these deficiencies are fundamental in nature and why they represent matters of planning acceptability that cannot be resolved through conditions of consent.

1. Prolonged Construction Impacts – Not Properly Assessed as a Long-Term, Cumulative Risk

Reading through the documents the following is noted:
• Treats construction noise and vibration as short-term, activity-by-activity events, assessed in isolation using 15-minute averages under the ICNG framework (Section 6.2–6.4).
• Explicitly states that “a detailed construction program and methodology has not been finalised” and defers key matters to a future Construction Noise & Vibration Management Plan (CNVMP) at CC stage (Section 6.1, Section 6.6).
What is missing that needs to be addressed is:
• No assessment of total construction duration despite acknowledging excavation, piling, deep basements and 8 towers up to 38 storeys (Sections 3.1 and 6.1).
• No cumulative assessment of repeated exceedances of Noise Management Levels (NMLs) over months or years.
• No health or wellbeing impact assessment from prolonged exposure, despite predicted exceedances at multiple receivers (Section 6.4.3).
• No modelling of chronic disruption to sleep, work-from-home, or daily living patterns.
Why this is a unacceptable:
• ICNG compliance does not override the EP&A Act requirement to assess likely impacts over the life of the development.
• The document concedes exceedances of NMLs and Highly Affected NMLs (HANMLs) are “likely to occur occasionally” (Section 6.4.3), yet provides no framework to manage prolonged exposure.
• Deferring this to conditions inverts the assessment process—the consent authority is being asked to approve a project without understanding its full construction impact envelope.

2. Traffic, Parking and Construction Vehicle Noise – Assumed, Not fully Assessed

Reading through the documents the following is noted:
• Assumes generic truck movements for noise modelling (e.g. “no more than 1 truck movement in a 15-minute period”) without linking to a construction traffic plan (Section 5.6).
• Focuses narrowly on acoustic output, not real-world impacts on residents.

What is missing that needs to be addressed is:
• No assessment of construction worker parking and associated early-morning noise in residential streets.
• No analysis of cumulative truck movements, queuing, reversing alarms, idling, or on-street congestion.
• No linkage between construction traffic noise and:
o Loss of on-street parking
o Reduced access for residents and services
o Pedestrian and cyclist safety
Why this is a unacceptable:
• Noise impacts from traffic are inseparable from parking and access impacts, yet the assessment artificially isolates acoustics from lived conditions.
• The assumptions used to demonstrate compliance are unsupported by any binding construction logistics framework.
• These are not matters that can be safely left to conditions because they affect baseline feasibility of the site.

3. Dust, Air Quality and Health – Entirely Outside Scope Despite Known Risk

Reading through the documents the following is noted:
• Explicitly limits itself to noise and vibration only (Section 1).
• Acknowledges deep excavation, piling and material handling (Sections 3.1, 6.4.1).

What is missing that needs to be addressed is:
• No assessment of dust generation (PM10 / PM2.5) during prolonged excavation.
• No consideration of health impacts on children, elderly residents or those with respiratory conditions.
• No recognition of interaction between dust, open windows, and the report’s reliance on windows-closed acoustic compliance (Sections 4.3, 4.6).

Why this is a unacceptable:
• The document relies on residents keeping windows closed to achieve noise compliance, while failing to assess air quality impacts that may force windows to be opened or closed.
• This creates an internal contradiction in environmental performance.
• Air quality impacts from major excavation are predictable and foreseeable, not speculative, and their omission renders the assessment incomplete.

4. Noise and Vibration – Exceedances Acknowledged but Normalised

Reading through the documents the following is noted:
• Identifies multiple receivers (R1–R6) where construction noise is predicted to exceed NMLs and HANMLs during piling, hammering and concrete pours (Section 6.4.3).
• Relies heavily on:
o Conservative assumptions
o Future mitigation
o Respite periods
o Complaint-driven responses

What is missing that needs to be addressed is:
• No enforceable limits on frequency or duration of exceedances.
• No binding commitment to avoid early morning or consecutive-day impacts.
• No assessment of vibration-related amenity loss, only damage thresholds (Sections 6.3.1–6.3.2).

Why this is a unacceptable:
• The assessment accepts that residents will experience repeated exceedances as a normal condition of approval.
• Amenity impacts are treated as a management problem, not a planning constraint.
• This approach has been repeatedly criticised in recent SSD refusals where mitigation cannot neutralise scale and duration of impacts.

The Noise & Vibration Impact Assessment:
• Defers critical impact analysis to post-approval stages
• Normalises prolonged amenity loss
• Fails to assess cumulative, health, and livability impacts
• Relies on assumptions rather than binding frameworks
Taken together, these omissions mean the consent authority cannot be satisfied under the EP&A Act that the development’s impacts on nearby residents are acceptable or manageable.

This review of Appendix EE – Noise and Vibration Impact Assessment identifies a number of material deficiencies in the assessment of construction-related impacts on nearby residents. While the report models individual noise and vibration sources, it does not adequately address the cumulative, prolonged, and residential-scale impacts arising from a development of this size and duration.

The assessment relies heavily on assumptions, generic mitigation measures, and the deferral of critical matters to post-approval management plans. As a result, it fails to provide the level of certainty required to demonstrate that construction noise, vibration, and associated impacts can be managed to an acceptable level over the life of the project.
The findings below outline why these deficiencies are fundamental in nature and why they represent matters of planning acceptability that cannot be resolved through conditions of consent.

I am making a submission regarding the proposed Bilbergia development at 1 King Street, Concord West.
I object to the proposal because:

• Building height is excessive (allowed 22 m, proposed 144 m)

• Number of homes is too high (600 → 1400)

• Traffic will increase dangerously; only one road in/out

• Public transport is insufficient; Concord West Station and Rhodes Station are overcrowded

• No bus stops or separated cycleways nearby

• Local healthcare (Concord Hospital) cannot handle the extra population
I urge the Department to carefully consider these concerns before approving this development.

Having reviewed the EIS and its appendices, my submission raises and seeks addressment of a number of concerns, specifically related to infrastructure like traffic, access and transport capacity, accuracy of the proposed submission’s-built form scale and design excellence, overshadowing and view impact statement, impact to the local community’s character, as well as amenity impacts when considering access to walkable services, the impact on Concord Hospital and lack of schools to service this development.

Overarching recommendation: In its current form, the proposal is excessive, poorly integrated with its surroundings, and unsupported by existing or planned infrastructure. In truth the EIS and supporting attachments do not sufficiently demonstrate that traffic, transport, design excellence standards, shadowing, or community and social infrastructure impacts have been mitigated to acceptable levels. I request the Department refuse consent in its current form or require significant amendments (including reduction to a maximum of 20 storeys heights) and conditions to protect existing amenity and ensure a genuinely high-quality outcome for Concord West. This will ensure that there is meaningful consideration given to the community consultation feedback and needs identified via this (and previous) consultative activity. With amendments, this can be a major and impactful development for the people of Concord West, Billbergia and NSW Government alike but not in it's current form.

There are a number of matters that need to be adequately resolved or mitigated in the exhibited documentation, covered in attachment A, which relate to:
1. Road Network and Local Infrastructure Impacts
2. Application is considered in isolation and lacks consideration of cumulative impacts across the corridor
3. Public Transport Capacity – T9 Northern Line
4. Lack of Health and Education Services
5. Built Form, Height & Urban Design Concerns
6. Affordable Housing isn’t sufficient
7. Impacts for Pets
8. Staging provides limited benefits to the community until completion of stage 3
9. Connecting to Country Report presents as biased

Rather than proposing the development does not proceed at all, I have instead proposed a list of practical recommendations the NSW Government should consider to deliver a development that better meets community needs, outlined below:

- Recommendation 1: Reduction of apartment block height of up to 20 storeys or in line with Government’s assessment of George Street’s capacity, considering known constraints and current infrastructure challenges.

- Recommendation 2: Removal of a tower to make way for, or if not pursued, an alternate location identified for a (and build of) a second overpass (vehicles, including cars and bikes and pedestrians) to Queen Street. This will provide another road outlet from the proposed development, removing George Street as the only road in, or out of the development as well as a new ‘underpass’ replacing current King Street and Queen Street ageing underpass that is not fit-for-purpose, safe and would not service a development of this size.

- Recommendation 3: Revised, second independent and broader modelling with the proposed improvements considered, and varying days, across peak ‘core work hours’ and during ‘school drop off periods. Include a number of samples across varying days across various months, with these dates and times clearly listed for transparency.

- Recommendation 4: Reduced number of carparks and improved street signage to ensure maximum limited hours to reduce lack of parking or access to the new ‘central village’ and increased bike parking spots to encourage active travel.

- Recommendation 5: Further enhancements of proposed upgrades to George St as well as further improvements to Queen Street, Pomeroy Street and Beronga Street with upgrades to roads and infrastructure are staged. In addition mandate delivery of key intersection upgrades and George Street access improvements prior to staged occupancy triggers (e.g., 25%, 50%, 75% of dwellings occupied) with measurable Key Performance Indicators (KPIs) that ensure roads are upgraded prior to the population increase.

- Recommendation 6: Review proposed staging, frontloading the King Street enhancement during stage 1, immediately providing access (vehicle and pedestrian) upon completion of this stage, rather than waiting till Stage 3 for any access benefits.

- Recommendation 7: Reduce maximum tower heights, size and seek further investment required to ensure community needs, in line with other proposed or approved developments (Rhodes Central), as well as considering cumulative impacts on roads, and infrastructure due to other surrounding developments.

- Recommendation 8: Seek updated material comparisons/modelling with suburbs of similar density and population profiles, not Strathfield, Rhodes and Olympic Park which are already high density and have supporting infrastructure. FSR references are not appropriate, comparative or fit for purpose.

- Recommendation 9: Work with Transport NSW to identify ways to remediate current constraints on the existing line, detailing these in final plans, noting the documentation provided indicates seating as ‘not available during peak times’ (a challenge for those with disabilities or other needs, as experience by the project team themselves when modelling. Consider additional station requirements like platform coverage to ensure traveller safety and developer contributions for upgrades.

- Recommendation 10: Develop revised active transport improvements, including direct pedestrian and possibly cycle-way to the proposed upcoming North Strathfield Metro Station, providing direct and accessible access to the transport hubs referenced multiple times in this submission. Additionally, a cycle lane or road markings from the development to local parklands to ensure access to upcoming light rail connections.

- Recommendation 11: The developer contributes to additional infrastructure funding for local hospital expansions, as deemed appropriate by the NSW Government to sufficiently support the surrounding community population.

- Recommendation 12: The NSW Government reserves a portion of the site for (and commits to building) a new Public Government High School to service the area of Concord West.

- Recommendation 13: Revised designs that focus on a reduction in tower height (across all buildings, no higher than 20 storeys), more defined stepped height transitions, greater slender tower formations, enhanced podium setbacks, greater tower separation, and articulated facades that incorporate greenery to better blend in with the surrounding environment. Additionally, revised designs that increase sunlight to central park, communal space, apartments in this development (some of which receives 0 hours of sunlight) to achieve solar compliance standards and to limit impact on surrounding neighbours.

- Recommendation 14: Further community consultation and advertised Town Halls to understand impacts be it social, psychological, actual and perceived, with an action plan developed to address this community feedback. This has not been sufficiently addressed in Appendix D, Community Engagement Table and not adequately covered in Appendix X, Community Infrastructure Needs Assessment.

- Recommendation 15: Consideration of Canda Bay’s LEP and further council consultation to understand an appropriate compromise that better reflects the area, while contributing to NSW Government Housing Supply targets. This development is more than twice the height previously approved by Canada Bay Council.

- Recommendation 16: Increased retail space (which is artificially inflated by inclusion of Childcare space), in line with original proposal and increase to community amenities, including new, developer funded local pool and community centre as provided with a smaller, Rhodes Development (Rhodes Central) as opposed to resident pool. This would ensure ‘walkable’ and accessible nature of the proposed development.

- Recommendation 17: Amendments to designs to better maintain solar access to nearby residences and public open spaces, including the proposed central park.

- Recommendation 18: The current proposal should include additional low-income housing, or ‘buy-to-rent’ housing components to ensure housing supply is accessible by a range of community members.

- Recommendation 19: Include provision of a small, fenced off dog park and a playground for children, with no dog access to ensure safe access for pets and children alike as part of this development.

- Recommendation 20: Bring forward the central park and walkway proposed in Stage 3 to stage 1, frontloading the positive impact for community and providing greater access to Concord West Station upon the completion of Stage 1 that would otherwise see pedestrians re-routed around George Street and Victoria Ave to access the station.

- Recommendation 21: Group Buildings P1, P2, P3, B1, B2, B3 and C (appendix B) as Stage 1 and reduce maximum heights to a maximum of 20 storeys. Group buildings D and E (reducing height to the same height as building D) and complete as Stage 2 bringing forward community benefits. Remaining buildings A1 and A2 to be completed as Stage 3, providing final retail boost once population increases and minimising impact to those accessing previous stages due to isolated nature of buildings.

- Recommendation 22: Independent Connecting to Country Impact assessment delivered by (and attended by) the NSW Government and/or NSW Government representatives (as opposed organised by the developer) with more defined action plans on how concerns or opportunities will be addressed.

I thank you for your consideration of this submission, and look forward to the NSW Government and Billbergia addressing a number of these issues collaboratively with the community to realise a better but still profitable development.

Hayden Beven, Local Resident