Mixed use development - 100 Edinburgh Rd Castlecrag

To Whom it May Concern
I wish to formally object to the proposed development at 100 Edinburg Road Castlecrag for the following reasons:
1) Excessive Height and Scale: The proposed building is far too high and significantly out of proportion with the surrounding neighbourhood. Its scale I inconsistent with the established character of Castlecrag and would dominate the local streetscape.
A proposal with a maximum height of 5 stories (back of street -5 stories - front of street 3-4 stories) would be acceptable to me.
2.) Disregard for Excisting Approvals and Planning Controls: The proposal appears to ignore existing approvals and planning expectations currently in place for the site and surrounded area. Council approved a building which goes in line with the wish of the community and myself. Any redevelopment should respect the planning framework already established rather than override it.
3.) Impact on Heritage Character of Castlecrag:Castlecrag is a suburb of important heritage significance, strongly associated with the planning vision of Walter Burley Griffin and Marion Mahony Griffin. The proposed development does not adequately reflect or respect the unique heritage, environmental, and architectural values of this nationally significant suburb. Australia has not a long history, the little history we have should be preserved. Walter Burley Griffin would turn in his grave if he would see this proposal.
4.) Traffic and Congestion Concerns: Traffic management in this area is already inadequate. Local roads are congested and access points are limited. Adding approx. 150 appartments will place unacceptable pressure on surrounding streets, intersections, parking availability and overall traffic flow, particularly during peak hours. If affordable housing of apparently 10 appartments is the reason of this development consideration by the NSW government, it is a heavy price to pay to achieve this.
5.) Lack of Genuine Community Consultation: The local community has not been properly consulted. Residents feel ignored by the NSW Goverment in a process that should involve meaningful engagement with those most directly affected by such a major proposal. At the community gatherings where more than 250 residents participated each time (more than 10 % of the population of Castlecrag) no NSW Goverment representative or anyone from the development company was present.
6.) Overdevelopment and Loss of Local Amenity: The proposal represents overdevelopment of the site and risks permanent damage to the amenity, character, and livebility of Castlecrag.

For these reasons, I strongly urge the decision-makers to reject this proposal or require substantial redesign to better reflect the heitage significance , infrastructure capacity, and community expectations of Castlecrag.

Yours faithfully,
Ron Koehler

I am a resident and property owner in the Griffin Heritage Conservation Area. I have read the EIS for this proposal. I support housing development on this site but I have two specific technical concerns that I do not believe have been adequately addressed.

1. The height justification relies on planning provisions that may not apply
The proposal is lodged as State Significant Development through the HDA pathway. I understand that is the legal basis. My concern is with the planning merit argument used throughout the EIS to justify 48.96 metres.

The EIS cannot rely on existing WLEP 2012 controls to justify this height as those controls permit approximately 15 to 16 metres. Instead it relies on LMR provisions as its primary contextual argument, asserting that because LMR could enable buildings of up to 24 metres on nearby land, a 48.96 metre building is compatible with the emerging context.
LMR provisions apply within 800 metres of a nominated town centre. The EIS states the site is approximately 850 metres from Northbridge. On the applicant’s own figures the site is outside the threshold. The EIS does not acknowledge this. It simply asserts in the next sentence that LMR applies because adjoining land is within 800 metres, applying the benefit of a provision to a site that does not meet the threshold by pointing to neighbouring lots.

If LMR provisions do not apply to this site the primary planning merit argument for the height, scale, visual impact, heritage impact and shadow assessments throughout the document requires revision. I request that DPHI require the applicant to confirm the precise basis on which LMR provisions are said to apply to this site and if they do not, to provide an alternative justification for 48.96 metres from first principles.

2. The shadow diagrams show significant impact that has not been assessed
Shadow diagrams in Appendix Z show the proposed building’s shadow extending well beyond the site boundary to the south at 2pm and 3pm on 21 June, reaching across residential properties

The diagrams exist but the assessment does not. There is no property by property analysis, no hours of solar access lost, no assessment of impacts on outdoor areas. The EIS text dismisses the entire southern impact by asserting it is similar to the approved development. The approved development was 15.75 metres. This proposal is 48.96 metres on a site that slopes toward those properties. The diagrams themselves contradict the assertion. At 2pm and 3pm the proposed shadow extends significantly further south than the approved scheme outline shown in red.

I request that DPHI require a quantified property by property shadow assessment for all affected properties.

I wish to lodge a formal submission strongly opposing the proposed development at 100 Edinburgh Road, Castlecrag.
This proposal constitutes an inappropriate overdevelopment that is fundamentally inconsistent with the established character, heritage significance and infrastructure capacity of Castlecrag. Its scale, massing and intensity are excessive for this location and would result in unacceptable and long‑lasting impacts on the local community.

Excessive Scale and Character Incompatibility
The proposed development is entirely out of character with the surrounding low‑density residential area. Castlecrag is defined by modestly scaled dwellings, generous setbacks, significant vegetation and a strong relationship to the natural landscape.
There is no development of comparable scale in the immediate surrounding area. The proposal introduces a bulk and intensity that would visually dominate the streetscape and undermine the cohesive character of the suburb. Approval would set an undesirable precedent for further overdevelopment, fundamentally altering the nature of Castlecrag.

Impact on the Griffin Heritage Area
Castlecrag is internationally recognised for its Griffin heritage, with planning principles that prioritise low‑impact development, harmony with topography, retention of bushland and human‑scale design. The proposed development is inconsistent with these principles and would have a serious adverse impact on the Griffin heritage area. Its scale and form undermine the cultural landscape and planning legacy that make Castlecrag unique. Once compromised, this heritage significance cannot be restored.

Inappropriate Location; Not a TOD or Transit‑Supported Area
This site is not located within or near a Transport Oriented Development (TOD) precinct, nor is it within walking distance of a train line or major public transport hub. Introducing a development of this scale in a car‑dependent location is poor planning practice and inconsistent with established strategic planning objectives. Higher‑density development should be focused in areas with appropriate transport capacity and infrastructure, which is not the case at this site.

Traffic, Access and Infrastructure Concerns
The local road network, including Edinburgh Road and surrounding streets, is not designed to accommodate the traffic volumes likely to be generated by a development of this size. The proposal raises serious concerns regarding increased traffic congestion, reduced pedestrian and cyclist safety, and additional pressure on already constrained local infrastructure and services. These impacts would significantly reduce local amenity and safety for residents.

Amenity and Environmental Impacts
The scale and bulk of the proposal are likely to result in increased overshadowing, loss of privacy, and visual impacts that are inconsistent with the bushland character of Castlecrag. Any loss of vegetation would further erode the distinctive environmental qualities of the area.

Conclusion
In summary, this proposal is:
Excessive in scale
Incompatible with the established and future character of Castlecrag
Detrimental to the Griffin heritage area
Poorly located in relation to transport infrastructure
Likely to result in unacceptable traffic, infrastructure and amenity impacts

For these reasons, I strongly urge the consent authority to refuse this proposal.

The area has significant heritage value and has no high rise
There has been significant medium rise development in the vicinity with no additional infrastructure
There is no additional transport option i.e. it is not near a major rail or metro hub.
Any claim of enhancing low-cost housing stock is spurious - the asking prices will exceed affordability criteria for lower income earners, at the price points the more likely market are o/s property portfolio buyers.
Medium rise - 3 stories with cafe retail would be more sympathetic.

Submission Against Proposed Development
100 Edinburgh Road, Castlecrag (former Quadrangle site)
To: Department of Planning, Housing and Infrastructure
From: Resident of Castlecrag
Date: 21 April 2026

I strongly object to the proposed development at 100 Edinburgh Road, Castlecrag. I am a local resident with a young family and we walk, play, and travel through the village every day. This proposal is far too big for the site and not suitable for the area.

1. Wrong use of the HDA / SSD pathway
The HDA process was meant to speed up housing in areas close to good transport and services. This site does not meet those standards because:
• It is not close to a train, metro, or light rail station.
• Bus services on Edinburgh Road and Eastern Valley Way are limited.
• There are no planned transport upgrades to support this development.

Using this pathway to ignore Willoughby Council’s height and density rules is unfair. Those rules were properly set only two years ago. Increasing the approved 38 apartments to 150 apartments in an 11-storey tower is not reasonable housing growth.

2. Too large for the Griffin Conservation Area
The site is in and next to the Walter Burley Griffin Conservation Area, which is historically important. An 11-storey tower would:
• Overpower the low-rise and leafy character of the area.
• Be seen from many parts of the suburb and across Middle Harbour.
• Damage the heritage value of Castlecrag.

3. Negative impact on KU Castlecrag Preschool
KU Castlecrag Preschool is right next to the site. This proposal would:
• Block sunlight to the outdoor play areas, especially in winter.
• Change the quiet and peaceful setting of the preschool.
• Cause years of noise, dust, and vibration during construction.

Any studies about sunlight, noise, or construction should focus on the actual preschool play areas, not just the property boundary.

4. Traffic problems
Castlecrag has limited road access, mainly through Eastern Valley Way and Edinburgh Road. This development would add many more cars to already busy roads.

Main concerns include:
• Too many cars on single road in and out of Castlecrag
• Eastern Valley Way / Morotai Crescent intersection, just down from Edinburgh Road, is already difficult and unsafe. More cars on Eastern Valley Way will further compound this issue.
• No traffic light or road upgrades are proposed to support the increased car volume.
• Edinburgh Road is meant to become a safer pedestrian area, which conflicts with more traffic.

5. Poor pedestrian safety
Footpaths on Eastern Valley Way are narrow and incomplete in some places. They are not suitable for the extra people a 150-apartment project and supermarket would bring.

This is a safety concern, especially for children walking to schools, preschool and shops in their local area.

6. Poor design quality
This project does not show design excellence because:

• It looks like a generic apartment block.
• Materials and style do not match Castlecrag’s unique character.
• It appears focused on profit rather than good local design.
• There is no clear evidence of a design competition or proper review process.

The previously approved 3–5 storey scheme was much more suitable for this site.

7. Construction and basement impacts
A large basement for 150 apartments and retail would require major excavation on a sloping sandstone site. This could cause:
• Damage to neighbouring buildings and retaining walls.
• Groundwater issues.
• Long periods of loud rock-breaking noise and vibration.
• Heavy truck traffic on local roads not built for this level of construction use.

There is not enough evidence these risks have been properly addressed.

Conclusion
The already approved 38-apartment, 3–5 storey mixed-use project is the right outcome for this site. It provides housing, improves local shops, and respects the character of Castlecrag.

The new 11-storey proposal is too large, unsuitable for the area, and would create serious impacts on the preschool, roads, pedestrian safety, heritage values, and nearby homes.

I respectfully ask the Department to refuse this application and reconsider using the SSD / HDA process for sites like Castlecrag that do not meet the intended criteria.

I also ask that this objection be genuinely considered. Many residents have spent time raising real planning concerns that deserve a proper response.

1.The original DA which was approved by Council and the supported by the community at large. It was a measured response to a need to redevelop this site.
2.There has been continued development of medium density housing along Eastern Valley Way and the western side of Edinburg Road. None of this development exceeds 3 to 4 storeys. The new proposal will dwarf anything that surrounds it and is totally out of character for the area.
3.The current Government undertook to develop multi-storey housing along major transport routes, most specifically rail. The Castlecrag development can in no way be categorised as being anywhere near a major transport hub. In fact its height far exceeds that of the new developments along the Pacific Highway and rail corridor from Roseville to Wahroonga.
4. The duplicity of suggesting this development contains affordable housing is quite hard to believe. Around 10 apartments at a reduced rent for 15 years, which I believe is to equivalent to around 20% of the median rental for the area. This will still be unaffordable for even some lower middle income residents, let alone a pensioner!
5.Access into and out of Castlecrag is by one major artery i.e. Edinburgh Road. The developer's representatives at the last information session admitted that the development would further impact on the current problem of access especially during peak hour. They also acknowledged that there was an assumption that more residents would use public transport. They had know way of justifying this assumption and admitted that any increase in public transport was not part of the proposal and beyond their control. Much of Castlecrag has steep and narrow winding streets unsuited to large vehicles such as buses. So to expect elderly residents to walk significant distances to public transport is grossly unreasonable.
6.Castlecrag is recognised as a significant example of a suburb planned by the world renowed Burley-Griffin architects. What is being suggested is a development at the immediate gateway to the suburb. A number of local and overseas architects have strongly condemned the proposal.
7.The developer has given no indication of awareness of the aged sewerage system in the Castlecrag, and many other, areas. When questioned they basically said it was not their problem but had to be dealt with by Sydney Water. I have spoken to Sydney Water empolyees when they have been regularly on-site for repairs. These Tradespeople confirmed that the system will be overwhelmed by the increasing load placed on it.
8.It seems self evident that the more than 3 fold increase in the size of the development is driven by profit motive alone. The height increase beyond any surrounding medium density dwellings is to obtain views from the mutimillion dollar apartments on the upper floors. The claims of nimbyism by the Premier and his minister are quite fatuous. I believe neither of them has visited the community to justify the listing of this building as a State Significant Development. In short I believe the development is driven by profit motive and political expediency. It cannot be justified considering the many negatives.
9. The developer paid for an already approved DA, they have been duplicitous and should be held to the original DA that was included in their purchase.

The proposed development in outrageous in its scale.The developer has complete disregard for Castlecrag and what the Crag means to residents including with the original plans by Walter Burley Griffin to make this a fabulous place to live.
There are no residential developments in the immediate area above 3 levels the site is not within a TOD area..
This development should not be approved the fact that it’s being considered in its current form is a disgrace.
Ray Gent

My comments concern traffic safety, scale and suitability of the proposal.

Concerning traffic, I believe that what the developer reported to me as constituting the basis for their plan is not correct: that is, the classification of the intersection of Edinburgh Road and Eastern Valley Way as being in the highest rank of available transport service. Several of the bus lines 'serving' the location only pass through without stopping on the way to/from the city. The service along Edinburgh Rd is very infrequent. The route to Chatswood winding and lengthy. There is no direct access to either Metro or the train line at Chatswood, only at North Sydney. As a consequence, it is likely the selected site will depend mostly on private car traffic, both for residents and shoppers as well as deliveries for the planned supermarket and shops. I note that the proposed single ingress/egress point for the whole development lies within 100 paces of busy traffic lights at the 4-way intersection of two major roads: congestion and accidents are surely predictable, as is access for emergency vehicles etc. Both restriction of scale of the building and/or remedial traffic planning for Castlecrag as a whole are needed, as I have commented to the developer in two different submissions. This landlocked suburb has only two roads leading into and out of it, the lesser of which is a narrow and winding street debouching onto Eastern Valley Way at the bottom of a steep dip with no traffic lights. In addition, existing new residential developments are increasing density already around the main intersection.

In terms of suitability of design, I believe that Castlecrag is uniquely based upon a whole-of-suburb design by the world-famous architects, Marion and Walter Griffin, encompassing a large section of the present roads, houses, community facilities (including a hospital, school and pre-school and public library as well as an outdoor theatre and multiple walking paths and reserves. The site proposed is literally a Gateway Site to a carefully planned and largely preserved human-scale living communal precinct. This means that the development's own design should enhance and complement the suburb as a whole, not dominate it in the way a building like Blues Point Tower-- however admirable as the work of another eminent architect -- imposes itself upon a whole peninsula.

I urge the panel to take into account both scale of building, traffic impacts and complementarity of design with the exisiting nature of the suburb when evaluating this proposal. I note that the proposal as approved at the DA stage by Willoughby Council constitutes a reasonable approach to all these concerns, and I question whether the proposal before the panel is equally able to meet those three criteria in its current form.

Castlecrag is internationally recognised for its planning and architectural significance, based on the principles of Walter Burley Griffin and Marion Mahony Griffin. The Conservation Area is defined by:

* Low-scale, landscape-integrated dwellings
* Minimal visual impact from the public domain
* Retention of native vegetation and natural topography
* A cohesive architectural language that responds to the bushland setting

The proposed apartment development, by its scale, bulk, and intensity, is fundamentally at odds with these principles. It introduces a built form that is visually dominant and inconsistent with the fine-grain residential character that defines Castlecrag.

The proposal represents a clear overdevelopment, characterised by:

* Excessive building bulk and scale relative to surrounding development
* A density outcome inconsistent with the established low-density character
* Reduced landscape setting and inadequate deep soil zones
* Likely impacts on privacy, solar access, and outlook for adjoining properties

This level of intensification is not appropriate within a sensitive heritage conservation area and sets an undesirable precedent for further erosion of planning controls.

Castlecrag is not equipped to support large-scale apartment development. Key concerns include:

* Traffic and Access: Narrow, winding roads with limited capacity to accommodate increased traffic volumes
* Parking Pressures: Likely overflow parking impacting already constrained streets
* Public Transport: Limited public transport options relative to the proposed density
* Services and Utilities: Existing infrastructure was not designed for high-density development

Approving developments of this scale without corresponding infrastructure upgrades places undue strain on the locality and diminishes amenity for existing residents.

The proposal is likely to result in:

* Removal of significant native vegetation
* Disruption of the natural bushland character
* Increased stormwater runoff and associated impacts
* Loss of the visual “bush setting” that is integral to the identity of Castlecrag

The Griffin vision was one of harmony between built form and landscape. This proposal moves in the opposite direction.

It is also important to note that the Willoughby City Council local government area is already accommodating significant housing growth and is contributing to the NSW Government’s housing targets, including those associated with the Transport Oriented Development (TOD) Program.

Recent planning reforms have identified appropriate locations for increased density, typically centred around transport hubs and areas with existing infrastructure capacity. Castlecrag is not one of these locations.

There is no demonstrated strategic need to introduce additional high-density development in a sensitive heritage conservation area when:

* Housing targets are already being met or exceeded within the LGA
* More suitable, better-serviced locations have been identified for increased density
* The subject site lacks the transport and infrastructure characteristics that underpin TOD principles

Allowing this proposal would undermine the strategic intent of the TOD framework by directing density to inappropriate locations.

The proposal appears inconsistent with the intent of the Willoughby City Council Local Environmental Plan and Development Control Plan, particularly in relation to:

* Heritage conservation
* Built form and scale
* Landscape character
* Streetscape integration

It also fails to reflect the long-standing community expectation that Castlecrag’s unique character will be protected, not diluted through inappropriate development.

Approval of this development would create a damaging precedent, encouraging similar over-scaled proposals within the Conservation Area. This would lead to incremental erosion of the very qualities that make Castlecrag unique and significant.

For the reasons outlined above, the proposed Conquest apartment development should be refused. It is:

* Inconsistent with the heritage significance of the Burley Griffin Conservation Area
* An overdevelopment of the site
* Unsupported by local infrastructure
* Contrary to the strategic intent of the TOD framework
* Detrimental to the environmental and landscape character of Castlecrag

We respectfully request that the NSW Government give due consideration to these concerns and reject the proposal in its current form.

NSW PLANNING PORTAL SUBMISSION
Objection to State Significant Development
100 Edinburgh Road, Castlecrag NSW 2068
Submission Type: Objection
Summary of Position:
I strongly object to the proposed development. The proposal is inappropriate in scale, inconsistent with heritage protections and represents a misuse of the State Significant Development pathway.
Key Reasons for Objection:
1. Heritage Impact
Castlecrag is a nationally and internationally significant planned suburb designed by Walter Burley Griffin and Marion Mahony Griffin. The proposed 11-storey towers are fundamentally incompatible with the low-rise, landscape-integrated character of the Griffin Heritage Conservation Area and would cause irreversible damage to its integrity.
2. Excessive Height and Scale
The proposal for two 11-storey towers and approximately 150 units is grossly excessive. It represents a significant departure from the previously approved 3–5 storey, 38-unit scheme and is entirely out of character with the surrounding built environment.
3. Strategic Planning Inconsistency
The site is not located within a designated housing growth area and lacks proximity to major transport infrastructure. The proposal is inconsistent with NSW planning policy, which directs higher density development to appropriate, well-serviced locations.
4. Misuse of State Significant Development Pathway
The application appears to rely on the SSD pathway to bypass local planning controls and heritage protections. There is no justification for treating this development as state significant in a manner that overrides established local planning frameworks.
5. Traffic and Infrastructure Impacts
The scale of the development will place significant strain on local roads and infrastructure. Insufficient detail has been provided to demonstrate that these impacts can be appropriately managed.
6. Community and Expert Opposition
The proposal is strongly opposed by the Castlecrag Progress Association, the Walter Burley Griffin Society, local residents, and Willoughby Council (8–1 resolution). This reflects well-founded concerns supported by heritage and planning expertise.
7. Precedent
Approval would set an unacceptable precedent for high-rise development within a protected heritage suburb, undermining the integrity of planning controls and heritage conservation efforts.
Conclusion:
The proposed development is inappropriate, excessive, and inconsistent with both local and state planning principles. It would cause permanent harm to the heritage significance and character of Castlecrag.
Declaration:
I request that the NSW Planning Department refuse this application in its entirety.
Name:
Richard Morris
Address:
PO Box 4232 Castlecrag NSW 2068
Date:
22 April 2026

SSD 90134958, 100 Edinburgh Road, Castlecrag

I support more housing and more diverse housing, including affordable housing. This proposal is not “more housing at a sensible scale.” It is a tower outcome in a low scale local centre, and the EIS reads as contrived in the way it tries to justify it.

What is proposed is a tower scheme, not a mid rise local centre outcome
The EIS seeks “a 4 storey podium” with “two 11 storey residential envelopes” above, plus five basement levels, delivering 150 dwellings.
It also seeks a maximum building height of 48.96 metres, an FSR of 4.2:1, and 376 car spaces.

The EIS’s own comparison table shows the scale jump is extreme: 38 dwellings to 150, and 15.75 metres to 48.96 metres.
That is not “incremental uplift.” It is a step change.

Right place, right scale, and this is the wrong scale
The EIS itself describes low scale built form immediately around the site. For example, west of the site it notes “low scale residential dwellings of primarily one and two storeys.”
It also describes two storey mixed use buildings nearby, and low density residential zoning to the north and south in the broader context.

The EIS tries to normalise 11 storeys by claiming nearby provisions could allow “built forms between 4–8 storeys” and that the proposal is compatible with that “likely future context.”
Even on their own framing, that points to mid rise, not 11 storeys.

The same EIS also says “LMR” and “Infill Housing 30%” provisions allow “envelopes up to 24m in height.”
This proposal is 48.96m.
That is not a reasonable extension of “emerging” controls. It is doubling them.

Requested outcome
Approve more housing only with a mid rise envelope: 4 to 5 storeys to Edinburgh Road, and maximum 7 storeys to the rear, with enforceable step backs, setbacks, and separation.

Overshadowing and amenity are being minimised, and the document contradicts itself
The EIS admits the development will “result in overshadowing to the south,” but then claims the impacts are “similar” to the approved scheme and “acceptable.”
That assertion is not a substitute for a rigorous impact test at 11 storeys.

More importantly, the EIS also admits a clear internal amenity failure that is a direct symptom of pushing too much bulk and height: “more than 15% of apartments do not receive direct sunlight at the winter solstice,” which it says is “not consistent with the ADG’s recommendations.”
A scheme that cannot meet baseline solar expectations for its own residents should not be waved through on the basis that shadows are “acceptable.”

Requested outcome
Independent peer review of solar access and overshadowing for surrounding properties and for the proposed apartments. If impacts are material, mandate the reduced envelope above.

Traffic and access is the clearest example of a contrived narrative
The EIS repeatedly leans on buses and accessibility, including claiming a “well established bus network” with direct access to major centres.
Yet it also proposes five basement levels and 376 car spaces.
That is not a public transport led design. That is car infrastructure on a huge scale.

The EIS states “Access to the site is provided via Edinburgh Road, by way of a combined entryway,” and that waste vehicles enter from Edinburgh Road.
It also states the intersection of Eastern Valley Way and Edinburgh Road is “operating below desired standards in the morning peak hour” because right turn traffic exceeds capacity and overflows into through lanes.
Despite that, the proposal still concentrates all movements onto Edinburgh Road.

This is exactly backwards. The site has major frontage to Eastern Valley Way, and the access strategy should use it to reduce pressure on the Edinburgh Road movements and the intersection.

Requested outcome
Require the proponent, in consultation with TfNSW, to assess and implement if feasible:

Ingress from Eastern Valley Way for southbound vehicles via a safe left in, and
Egress to Eastern Valley Way for southbound dispersal via a safe left out,
so that a significant portion of trips do not need to use Edinburgh Road to move south.

If TfNSW will not permit Eastern Valley Way access, require a funded, deliverable intersection upgrade package that directly addresses the EIS acknowledged morning peak failure mode.

Affordable housing is being used as a narrative, while being deliberately minimised
The EIS sets out its alternatives and explicitly rejects an “Infill Affordable Housing” option because 15% affordable is “not feasible,” and because “the 15% requirement is too great.”
It then prefers the HDA scheme because it provides “greater density” and “a lower affordable housing component.”

At the same time, the proposal delivers 10 affordable dwellings, and only for “a minimum of 15 years.”
That is not a credible trade off for a 48.96 metre, 150 dwelling tower scheme.

Requested outcome
Either reduce the scale to mid rise, or materially increase the affordable housing offer and tighten delivery and duration commitments.

Wind and public domain comfort show the ground plane is being compromised
The wind mitigation measures include relocating an entrance away from “accelerated winds,” and avoiding outdoor dining around a corner.
A local centre should improve street comfort and activation. If the scheme needs to move entrances and avoid uses to be comfortable, the bulk is part of the problem.

Requested outcome
Require redesign that achieves acceptable ground plane comfort without avoiding uses and relocating entrances.

Cumulative impacts are acknowledged, then brushed aside
The cumulative impact section identifies construction noise and traffic as having potential cumulative impacts.
Given the scale of excavation, parking, and traffic concentration, this cannot be dealt with by generic management plans. It requires enforceable design changes, and enforceable traffic mitigation.

Conclusion
I support more housing. I do not support two 11 storey envelopes at 48.96 metres in this context, justified by arguments that simultaneously rely on “mid rise emergence,” while doubling the height they cite, and minimising amenity and traffic issues they themselves acknowledge.

Consent should not be granted unless the proposal is redesigned to a mid rise outcome: 4 to 5 storeys to Edinburgh Road, maximum 7 storeys to the rear, with materially reduced overshadowing, and a credible access strategy that uses Eastern Valley Way for both ingress and egress, or delivers equivalent intersection performance outcomes through funded upgrades.

I am writing to provide a submission regarding the proposed development at 100 Edinburgh Road, Castlecrag.

I want to be clear at the outset: I support appropriate development of this site. Renewal of the former Quadrangle is needed and overdue. However, the scale and intensity of the current proposal are not appropriate for this specific location, and do not align with the physical, transport, and heritage constraints of Castlecrag.

1. Scale is inconsistent with site constraints

The proposed development represents a significant escalation in density relative to the surrounding area. Castlecrag is not a high-density centre, and the site does not function as a transport or commercial hub capable of supporting this level of intensity.

This is not an objection to development — it is an objection to overdevelopment relative to site capacity.

2. Traffic and access constraints

The most critical issue is traffic.

* Castlecrag effectively operates with a single primary entry and exit corridor, creating a natural bottleneck.
* The proposal will materially increase traffic volumes without credible evidence that the surrounding road network can absorb this safely or efficiently.
* Increased congestion directly impacts emergency access, safety, and daily livability.

Given these constraints, the traffic impact is not a marginal issue — it is fundamental to whether the site can support this development at all.

An independent traffic assessment should be required, not solely reliance on developer-commissioned modelling.

3. Lack of alignment with public transport capacity

The site is not located within a high-capacity public transport corridor.

* There is no rail access.
* Bus services are limited in frequency and capacity.
* The proposal assumes a behavioural shift toward public transport that is not supported by existing infrastructure.

As a result, the development will remain car-dependent, compounding the traffic impacts outlined above.

4. Heritage and character impact

Castlecrag, and particularly the surrounding Griffin Conservation Area, has a well-established and sensitive village character.

The proposed scale:

* Risks overpowering the existing built form
* Undermines the architectural and environmental intent of the area
* Creates a precedent that is inconsistent with the locality’s planning framework

This is not simply aesthetic — it is a planning and heritage integrity issue.

5. Community consultation concerns

While consultation has been undertaken, it did not appear to be meaningful.

At a recent session, it was explicitly stated that the SSD process limits the influence of local council and community input. This creates the perception that consultation is procedural rather than genuine.

Effective planning requires not just consultation, but consideration. That has not been demonstrated.

6. Inconsistency between planning controls and proposed outcome

There appears to be a disconnect between:

* The planning proposal controls (including height expressed in AHD/metres), and
* The scale of development now being proposed (in terms of storeys and density)

This raises concern that the proposal is testing or exceeding the intent of the approved controls, rather than working within them.

7. Precedent risk

Approving a development of this scale in this location would set a significant precedent for similar uplifts in areas not designed to accommodate them.

This has broader implications beyond this single site and should be considered carefully.

Conclusion

This site should absolutely be redeveloped. However:

The current proposal exceeds what the site, infrastructure, and surrounding environment can reasonably support.

I urge the consent authority to:

* Require independent traffic and infrastructure assessments
* Reassess the appropriate scale and density for the site
* Ensure that heritage and village character are preserved
* Demonstrate that community input has been genuinely considered

A more balanced, context-appropriate development would likely receive broad community support. The current proposal does not.

The revised plan of a twin 12-storey residential building is way off the current Castlecrag community landscape and against the area's rich heritage and historical importance - the original Griffin design of a nature-friendly community. The revised plan has not been appropriately consulted with local community, disregards the local traffic and public transport limitations, violates the trust with local community when we supported the original DA. This SSD application is a disgraceful act of profiting, taking advantage of State government's housing crisis.

Please review the attach document explaining my objections to this new grossly over reaching submission.

As the owner and resident of 116 Edinburgh Road, Castlecrag, I live immediately adjacent to the proposed project and share a common driveway subject to a Permanent Right of Carriageway DP609580 as the only access to the rear of my property. I had reached an agreement with the previous owner of the site based on DA 2024-13 and DA 2024-17 approved by Council and The Northern Sydney Planning Committee. I was advised that our shared driveway was due to be demolished as part of the development and access would be unavailable for between six months and a year, as reinstatement of the Right of Carriageway would be given priority.
Since Conquest has taken over I have learned that it is not planned for the Right of Carriageway to be reinstated until the proposed development is completed and an Occupation Certificate issued, a time frame of up to 3 years or possibly more. This is completely unacceptable as there is no long term parking near and I will be competing with a significant number of tradesmen and women for the whole of this time. This forms the major basis of my personal objection and I see no reason why Conquest’s EIS and DA cannot address this. Additionally, I am extremely concerned that the deeper excavation to provide more levels of parking will severely impact the stability of my property given its proximity to my foundations.
On a more general note I object to the scale of the new proposal as it will cause major overshadowing not only to my property but many others in the immediate vicinity.
Also the traffic impact on Edinburgh Road generally and more particularly the impact during rush hours of vehicles trying to exit my shared driveway to turn east towards the junction with Eastern Valley Way cannot be underestimated. Traffic is already backed up to the junction with Rutland Avenue during the morning peak .
While these are just a small number of my reasons to object to the project, I am at a complete loss as to why this application should be even considered as a State Significant Development as it fails its own guidelines in almost every area without even considering Castlecrag’s heritage and its relationship to the architect of our nation’s capital. I urge the Minister and the HDA to approve the previous DA as a reasonable and just compromise for our unique suburb.
Anne Richards

The project is not an appropriate one for the local precinct. Castlecrag is a special part of Sydney as a significant heritage area - the Griffin heritage area. This proposed development is wildly out of character and 'out-of-sync' with the 'Castlecrag feel'.It is too high for the local area s there is nothing of comparable size/height in the surrounding area. It challenge the local traffic flow in this distinct peninsular suburb. . It is not visually sympathetic to its surrounds and it is inappropriate for its location ,which is not located near a TOD precinct or a train line.
I object to this development.

The project, as proposed, is not in scale with the village aspect of Castlecrag, which has only one road for access/egress.
The proposed project is double the size of what had been approved previously and not in scale of other development diagonally opposite on Eastern Valley Way. It will impact traffic. It will impact the current school system. It will impact real estate values. The retail services planned will not be able to cater for the overwhelming number of residents. Castlecrag is not served adequately by public transport; the project will, by its overshadowing of the surrounding properties, impact and diminish the enjoyment for those owners.

This development is a huge win for Castlecrag, bringing in much needed housing and better affordability without compromising on the beautiful design our suburb is known for. It’s a fantastic opportunity for the younger generation to finally get a foot in the door and stay close to their parents and the community they grew up in. We need this growth to keep our neighborhood vibrant and ensure that local families aren't forced apart by a lack of housing options. Supporting this project means choosing a future where the next generation actually has a place to call home right here in the suburb they love.

There are several aspects of this proposal which I object to:
1. The form and design of the development is of a scale and height that is completely out of character with the suburb and is in conflict with the local council development guidelines and also seems to be to some extent in conflict with the government's own guidelines.
It justified the height based on the site's proximity to the Northbridge LMR which allows for 4-8 storeys plus Infill Affordable Housing Options of an additional 30%. The proposal is for 11 storeys at the lowest point and 13 storeys at the highest. The maximum with the LMR and Infill Affordable Housing Provisions would be 10 storeys.
The site is outside the LMR 800m so I do not believe it should be governed by this provision. The EIS document states that the LMR height provisions are 24m (or allowing for the additional 30% infill affordable Housing provision = 31 m). The proposed development is 48 m in height. Well above the provision.
The proposed building would tower over every structure in the area and be completely out of character with the location. We need housing but why can't the developer at least build to the LMR standard of a maximum of 8 storeys?
2. Traffic. The developer has undertaken studies which indicated that "the intersection of Eastern Valley Way and Edinburgh Road is operating below desired levels in morning peak hours as the right turning traffic exceeds the right turn lane capacity and is overflowing into through traffic lanes on north approach of Eastern Valley Wy. The intersection of eastern Valley Way and Sunnyside Crescent is failing as there are high traffic volumes travelling north and south on Eastern Valley Way and the minor road movements have a high delay."
In other words, the developers own study indicates the traffic is already a problem and adding additional vehicles from this development which have no other option but to use the problem intersection, will worsen the problem further.
The developer indicated in their EIS that a" a prliminary CTMP has been provided within the TIA which presents and initital plan to manage traffic during construction activities" Firstly, there is no detail on this plan and also it does not say anything about on going traffic management with the increased volume once completed.
The mitigation strategy of the availability of "a Green Travel Plan to ensure people know how to get to the subject development by walking, cycling or public transport" is nonsense and "hail Mary" attempt to bandaid the issue.
They also indicated a mitigation strategy to increase bus services to the area which have been reduced in recent times. See section on Public Transport.
3. The criteria for approval under the government's SSD process, indicates that the development should be near major transport infrastructure and have effective and frequent - defined as less than 15 minutes frequency. The Developer's EIS claims that there are more that adequate public transport options available. Let me break down what is available:
* The nearest station is 3 kms away (St Leonards)
* there are 4 bus services
- 203 to the city - Departs approximately every 30-40 minutes depending on the time of day within an operating window of 7:41 to 17:00.
- 207 to the city - Departs approximately every 18-30 minutes depending on thr time of day within an operating window of 05:28 to 18:56
- 194 - to the city - departs approximately every 30 minutes within an operating window to 06:19 to 09:49
- 267 - to Chatswood - Departs approximately every 20-30 minutes within an operating window of 06:18 to 21:08
- 275 - to Chatswood - Departs approximately every 60-120 minutes within an operating window to 09:15 to 14:15 with very limited stops (3)
In summary, NONE of these bus services fall within the frequency range set by the government and only one Bus 207 operates with extended hours to accommodate normal working hours.
4. Affordable Housing. I am VERY sympathetic to the financial stress that finding affordable housing for key workers such as teachers, retail workers, nurses, police etc as well as pensioners. However, the mathematics of believing a development like this in Castlecrag is flawed. The government's definition of Affordable Housing in Section 1.4 of the Environmental Planning & Assessment Act or 1979 indicates that housing should be available for people on low to moderate income. The Act goes onto the define the target income groups of :
- Very Low Income = <50% of the area's median income
- Low Income = 80% of the area's median income
- Moderate income = 80-120% of the area's median income
From discussions with various real estate forms and research of local rental market, it is estimated that the average rent for a 1 bedroom apartment would be approximately $860. GIven the Affordable Housing provision provides a discount of 30% this equates to around $600 weekly rent.
From various data sources the average weekly income for each targeted group profession would be:
- Retail Worker = $1,334 making rental payments 45% of their net salary
- Teacher = $1,981 making rental payments 30% of their net salary
- Nurse - $1,667 making rental payments 36% of their net salary
- Police - $1,923 making rental payments 31% of their net salary
According to the Australian Housing and Urban Research Institute this means that ALL targeted groups would be over the 30% definition of "rental stress". I do not consider this to be "affordable".
5. Cultural Significance. Castlecrag has a rich architectural history being designed initially by Walter and Marion Burley Griffin. Although the development site is technically outside the Griffin Heritage area - it is adjacent to the boundary so outside by a matter of a few metres! - it will overshadow (literally and figuratively) the heritage site and is completely at odds with the Griffin's stated objective of making the architecture of the suburb sympathetic to the natural surrounds - regardless of the materials used . It is simply to large and will dominate the entrance to the area.
In summary, I am pro development - where it is well considered & suitable for the area. I applaud the government's efforts to increase supply for affordable housing for key workers. Having spent billions of dollars on the new metro on the lower north shore, it would seem far more sensible to develop this more affordable corridor which is close to all required transport and infrastructure.

I object to this proposed development.
A. The proposed development is too tall for the low rise suburb
B. The building should comply with current height restrictions for a 3 storey development
C. The proposed development conflicts with local expectations and requirements.
D. The proposed development incompatible with the historic heritage of the suburb
E. Building high priced apartments is not helping with any “housing crisis”.
F. Community consultation on what is acceptable was not carried out and was stated by the developer the proposal was fait accompli.
G. The intersection is at capacity and the close proximity of the proposed development will exacerbate and cause extreme interference with traffic flow on the intersection on the main roads.
H. The proposed development’s extra traffic will cause blockage to the main thoroughfares of both Eastern Valley Way and west Edinburgh Road, especially in the afternoon peak hour.
I. The proposed development will create blockages in traffic trying to leave Castlecrag.
J. The proposed development creates an evacuation and ambulance access hazard.
K. Does not achieve any objective of providing reasonably priced housing for solving any “housing crisis”, in fact may hinder the objective of more reasonably priced desirable housing by diverting scarce building resources to a high priced area from lower priced suburbs where the requirements of lower price housing is needed.
A 12 storey building of high priced apartments in a low rise high priced suburb not in a transport hub
is not “state significant” to help medium priced housing.
***
In detail:-
1. The area and site has a height restriction for R3 (3 storey) development. This is a 12 storey (or 14 on the Southside) proposal. This proposed development does not fit into the area. There is Chatswood nearby that would be more appropriate for transport, employment and size/height compatibility.
2. There is an already approved development designed with consultation with the local community – DA2024/13. What “State significance” is it to have a high priced, high rise in a low rise suburb?
3. Building multi-million dollar apartments does not help any “housing crisis” and being a new build will likely by bought by overseas investors and remain empty, not creating extra housing for local inhabitants.
4. Castlecrag is one of a few suburbs in Australia with a special heritage. A High rise does not fit into that ethos.
5. The two “consultations” made by the developer in 12th November 2025 and 18th March 2026 were only information sessions and the Developer’s representative even conceded that what was presented was the proposal, no consultation just responses to questions. So this proposal has no consultation with local community.
6. The 14 storey south face will be casting large overshadowing over houses in the Sailors Bay Creek valley.
7. The development does not help the “housing crisis” by providing multi-million apartments in a traffic restricted area. The “affordable” housing units will be located in the lowest and most slum like area – (lowest floors on the shady south side) in an area where transport is not particularly good to employment areas, it is not on a transport hub, buses only. The development does not help the “housing crisis” by diverting the very scarce building resources we have in this country away from lower cost areas where real and suitable to employment areas affordable housing can be built. A higher priced development can afford to outbid resources from a lower cost one.
8. The adjacent intersection is at capacity before the approved low rise (proposed 3 storey) development. The additional traffic load for traffic entering Castlecrag will be blocking the main roads – North bound Eastern Valley Way and East bound Edinburgh Road:-
a. Additional vehicles on Eastern Valley way north will overflow the right – hand turn slip lane into Castlecrag and block the main traffic lane.
b. Additional vehicles east bound Edinburgh Road going to Castlecrag will block vehicles rounding corner to go north on the central lane due to light cycles. This will reduce the flow of east bound traffic on Edinburgh Road going north to Roseville and beyond.
c. Additional traffic created by this large proposed development will create additional traffic leaving Castlecrag and interfacing delays will be caused by the traffic entering and leaving the proposed development.
d. The entrance to this enlarged development is less than 100m from the traffic lights and with the additional traffic queuing – re above item ( c ) will restrict the number of cars entering east Edinburgh Road by not clearing the right –hand turning lane on Eastern Valley way and hence blocking the north bound lanes of the main traffic flow re item ( a ) above.
e. Traffic leaving Castlecrag will be adversely affected by the extra load of the proposed development. Flow to the intersection is controlled by the traffic signals at the intersection. With traffic flow on the main roads being chocked of the extra entry traffic, the light cycles plus interference of the extra traffic generated by the development – includes big trucks for the shops and supermarket – the queues of cars trying to leave Castlecrag could extend back pass the roundabout and toward the bend in the road 250m+ with 3 + light cycles to exit the suburb.
9. The additional traffic blockages indicate above will severely affect ambulance entry and exit of ambulances to the hospital in Castlecrag
10. Suburb evacuation from Castlecrag in mainly through that intersection which will be severely overloaded by this proposed development – re bushfire or any other emergencies. There is only one other road out.
11. The area is not particular well serviced by public transport. Buses only go through the intersection, which already is at critical. The majority of buses using the intersection do not stop at Castlecrag and turn right into west Edinburgh Road – nearest stop 1 km to the north at Smith Street Castle Cove. Running more buses for additional Castlecrag commuters will just increase the loading of the Intersection. The area is not a transport hub.