Mixed use development - 100 Edinburgh Rd Castlecrag

100 Edinburgh Road Castlecrag, 14 storey proposed development objection.

It is insanity such a massive over 14 story twin-tower development, instead of the current approved 3 story rebuild was ever allowed to even be lodged. It will sit ATOP the very highest point in the area, and will be the next ‘Blues Point Tower’ if approved - an ugly eyesore for a mile around.

The current developers CONquest, have done bare lip service to ‘public consultation’ – deliberately poorly advertised by them, and sent PR staffers along, with vague and fake models of height and scale, and no real answers to questions. Just PR spiel, that was often largely fiction it seems upon resident questioning..

There is a current approval for *THREE* story development to this site, which had a supermarket, new apartments and retail shops. Please advise owners CONquest to proceed with that fully approved project - end of story. They on-bought THAT approved project, and are just attempting naked profiteering here.

That THREE story plan took YEARS of public consultation to get approved, and was the correct height and bulk for veery historic Castlecrag. In the 100 years of this suburb, *NOTHING* higher than 2 stories has even been erected commercially.

Castlecrag is 4 kms from the nearest railway or metro station, and has a near non-existent ‘203’ public Government Bus route to the Terminus and end of Edinburgh Road, that has been curtailed heavily in recent years and runs just a few times each day. It is NOT a ‘transport hub’ as CONquest lamely claim.

There is a just ONE narrow road in and out of Castlecrag - jammed tight as it is, and with a large hospital in Edinburgh Road, DOUBLING car traffic will create ne of the nastiest traffic snarls of Sydney as the Developer themselves admits. Indeed may even result in a death, if Ambulances are blocked.

Walter Burley Griffin founded this suburb from raw bushland, to blend in with nature. *NOTHING* was to exceed the high of the gum trees and until now – nothing has ever exceeded that in 100 years.

Willoughby Council has FAR exceeded its new development quota, in and around Chatswood etc – it is not as it they are anti-development, or anti new housing - they are not. Willoughby Council totally opposes this wildly excessive 14 story new plan, as you know and have formally opposed it.

Castlecrag is HISTORIC, and that character needs to be retained. Weekly walking tours of the Heritage listed Griffin houses take place - it is a tourist draw and not EVERYTHING in Sydney needs to look like North Sydney or Chatwood or Epping. There must be balance.

Glen Stephens – resident for 35 years.
4 The Tor Walk, Castlecrag.

I object to this development on a number of grounds, both technical, in that it does not comply with the various planning schedules, both local and state (where exceptions to local planning regulations can be overridden, for State Significant Developments), and social, in that there is significant opposition from local residents.
1) The proposed development does not comply with the Willoughby Local Environmental Plan 2012. it is way above the height limit (5.4 times the current LEP limit of 9 metres, as admitted in the developer's statutory compliance table, Appendix D, page 15, clauses 6.4(1) and (3)), and the floor space ratio is also far beyond the limit (4.2:1, against the current LEP limit of 1:1). The developer has used a fast-tracked HDA pathway, requesting rezoning to allow the proposal as it stands, but so far no determination approving such a development, has been made, so that it is currently non-compliant.
2) The developer claims that the SEPP bonus provisions would justify a development that is so vastly out of scale compared to the standard provisions, but it does not even conform to, but vastly exceeds, the requirements of those provisions, regarding a) how far is is from the Northbridge Town Centre (850-900 metres walking distance, as against the 800 metre LMR radius), b) the permissible height for shop-top housing (24 metres, which is only half of the proposed development height) , c) the floor space ratio (proposed 4.2:1, as against the current LEP 1:1 ratio), and d) the affordable housing component (10 of 150 apartments, for 10 years only, against the Housing SEPP minimum of 15 years; it should be noted that the Council requested that it be in perpetuity).
3) Perhaps most important of all, the development is completely out of context relative to the Griffin Heritage Conservation Area, which it directly adjoins on its eastern and southern boundaries. It is totally out of scale (the Griffin Conservation Area envisages "single storey, or in rare cases two storey [buildings], subordinate to and harmonious with the landscape") and would be visible from a great distance, totally in conflict with the current skyline of Castlecrag. Furthermore, it would cause significant shading over the surrounding houses.
4) The Eastern Valley Way-Edinburgh Road intersection is currently considered to be saturated with traffic, and the developer is unable to quantify the impact of the proposed 150 new dwellings. Due to the inadequacy of public transport in the area - limited and infrequent bus services, and no rail or metro infrastructure - the residents are forced to use private car transport, so that this intersection is of the utmost importance; during the morning peak hour, which combines business and school traffic, and even in the afternoons, with only the school traffic, there are significant wait times to get through the intersection, as also during the evening peak hour. In this context, emergency traffic - fire engines, ambulances and police vehicles - must also be considered, and increasing the population and the consequent traffic, to the extent planned by the developer, will create a dangerous situation.
5) The people who live in Castlecrag consider that it is a very special suburb, and the developer's community survey results showed that 89% of respondents were concerned about the proposed height of the development, 83% were concerned about the traffic impact, and 83% were concerned about the effect on local character. Of the 66 respondents, only 2 (i.e. 3%) had no major concerns. Note further that the number of respondents was fairly limited, evidently due to lack of meaningful outreach by the developer, who also admitted that it was not prepared to modify its proposal based on input received. However, at the 18th March 2026 meeting with the Castlecrag community, the developer's social consultant, Astrolabe, noted "significant frustration and distress" shown by the fairly large number of Castlecrag resident attendees.
I request that the Minister reject this development application, which will severely impact Castlecrag, removing the village atmosphere of the area, which for many years has been a meeting place for the Castlecrag community, something which we have all missed during the extended period from the initial proposal until the present, and which threatens never to return, should this development go ahead.

I am writing to object strongly to the proposed nearly 15 story development in Castlecrag. This is not simply a question of height, density or housing supply. It is a question of what we believe is worth protecting.

Castlecrag is not an interchangeable suburb. It has architectural, cultural and historical significance. Its landscape, built form, scale and relationship to the bush are part of its meaning. A 15 story development would not merely add housing, it would permanently alter the character of the area and set a precedent that cannot easily be undone.

There is a deeper concern here. Beauty has lost much of its standing in public decision making. Too often, places of meaning are sacrificed in the language of efficiency, growth, housing targets or alleged social good. But a city that stops protecting beauty, proportion, heritage and cultural significance becomes poorer in ways that cannot be measured only through planning yield.

Sydney is still a young city by world standards. We do not have centuries of protected urban fabric behind us. That makes the places we do have even more important. If areas such as Castlecrag, with their distinctive architectural and environmental identity, cannot be protected, then what exactly do we stand for as a city?

In many European cities, places of cultural and architectural significance are treated as civic inheritance. They are not casually overridden because a larger building can be justified on economic or policy grounds. Sydney should be mature enough to recognise that progress does not mean erasing what gives a place its soul.

I understand the need for more housing. I understand the pressures facing Sydney. But housing policy should not become a blunt instrument that allows any scale of development, anywhere, regardless of local meaning, heritage, landscape or community identity. Affordable housing should not be used as a moral shield for poor planning or excessive development.

The question the government must ask is not only, “Can this be built?” but “What will this decision mean in 20 years?” What will Castlecrag look like if developments of this scale are permitted? What precedent will be set for other culturally significant areas? What kind of city are we leaving behind?

A 15 story development in Castlecrag would represent a profound failure of stewardship. It would signal that even our most distinctive places are negotiable when enough pressure is applied.

I urge the government to reject the proposed scale of this development and to protect Castlecrag’s architectural, cultural and environmental significance. Increased housing should be pursued with care, proportion and respect for place, not through developments that overwhelm the very character that makes an area worth living in.

Submission: Objection to Castlecrag Mixed-Use Development (100 Edinburgh Road)

I am writing to formally object to the proposed Castlecrag mixed-use development at 100 Edinburgh Road.

This proposal represents a significant and inappropriate overdevelopment of a highly sensitive and historically important suburb. My concerns centre on heritage, scale, traffic and safety, as well as the practical realities of how this development will function for local families.

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1. Heritage: A globally significant Walter Burley Griffin landscape at risk

Castlecrag is widely recognised as one of the most intact Walter Burley Griffin landscapes in the world. The suburb was carefully designed to harmonise with the natural environment, with low-rise buildings integrated into the bushland setting.

This proposal does not respect that legacy.

Introducing twin towers of up to 12–14 storeys into this context fundamentally undermines the planning philosophy that defines Castlecrag. It risks permanently damaging the visual character, environmental harmony, and heritage significance of the area.

Approving this development would set a dangerous precedent for further erosion of this unique landscape.

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2. Scale: Grossly out of character with the existing and approved context

The scale of this proposal is excessive and unjustified.
• The site already has an approved development of 3–5 storeys that was supported by the community and appropriately considered through local planning processes
• The proposed height of up to 14 storeys is a dramatic and unreasonable escalation
• This is not a marginal increase—it is a complete departure from what is appropriate for this location

An 11+ storey building does not belong in a low-rise peninsula suburb.

The justification of “affordable housing” does not warrant such an extreme uplift in height and density—particularly when only a small proportion of the development is allocated to this purpose.

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3. Traffic and Safety: A peninsula that cannot cope

Castlecrag has a fundamentally constrained road network.
• There is effectively one main road in and one main road out
• The Edinburgh Road / Eastern Valley Way intersection is already heavily congested
• Local roads are narrow, residential, and not designed for high-density traffic volumes

Even under a smaller, previously proposed development, traffic modelling indicated significant delays and queuing.

With a development of this scale:
• Residents may experience multiple light cycles just to exit the suburb
• Queues could extend close to 1 kilometre along Edinburgh Road
• Delays could increase to up to 10 minutes or more at peak times

Importantly, this is not a problem that can be easily resolved through minor upgrades or signal changes. The constraints are physical and structural — the road layout, intersection capacity, and peninsula geography limit any meaningful expansion.

This means congestion is likely to become a permanent condition, not a temporary one.

The impact will also extend beyond Castlecrag. This key intersection connects to major commuter routes used by residents travelling to and from the Northern Beaches. Additional congestion at this location will have flow-on effects across the broader road network, further slowing already busy commuter corridors.

This is not just an inconvenience—it is a safety issue, particularly for families, pedestrians, and emergency vehicle access.

There is no train line, no metro, and limited public transport alternatives to offset this increase in density.

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4. Everyday usability: parking and access realities

Beyond the broader planning concerns, there are practical issues about how this development will function day-to-day.

At community information sessions, it was acknowledged that parking provision—particularly for the proposed supermarket—would be limited, with an expectation that many people would walk or cycle instead.

That may suit some, but it does not reflect the reality for many residents.

As a young mum with a 5-month-old baby, I rely on being able to access shops easily by car. Everyday tasks like grocery shopping involve prams, bags and time pressures, and are not always practical on foot.

In my own household, I also support a family member with mobility needs who requires accessible parking. That alone highlights how quickly limited parking becomes a real constraint.

We are not an outlier—this is a normal household scenario. A development of this scale needs to properly accommodate these everyday access needs, not assume ideal conditions that don’t reflect how people actually live.

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5. NSW Heritage Strategy: Policy intent vs planning reality

The timing of this proposal is particularly concerning given the recent release of the NSW Heritage Strategy by the State Government.

The Strategy reinforces that heritage should guide how our neighbourhoods evolve and recognises that community perspectives are essential to understanding what is significant about a place.

There is a clear disconnect between those principles and what is being proposed here.

The Castlecrag community has already engaged constructively and supported a lower-scale, more appropriate development for this site. That position reflects a deep understanding of the suburb’s character and heritage value.

It is essential that heritage advice provided through the Environmental Impact Statement genuinely reflects both the significance of the Walter Burley Griffin landscape and the strength of community concern.

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6. State planning process overriding local input

It is deeply concerning that this proposal is being assessed under State Significant Development pathways, removing meaningful decision-making from local council and the community.

The local community has already demonstrated support for a more appropriate, lower-scale development on this site. This proposal disregards that work and that trust.

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7. Community concern

There is clear and widespread concern within the community about this proposal.

Consultation undertaken by the developer itself indicates a significant level of opposition. According to those results, over 75% of respondents were not supportive of the proposal, while only around 3% expressed support.

This is not a marginal or divided response — it reflects a community that is overwhelmingly uncomfortable with the scale and impact of what is being proposed.

This level of opposition should not be dismissed or outweighed by a proposal that is so clearly out of step with both community expectations and the established character of Castlecrag.

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Conclusion

This proposal is:
• Inconsistent with the heritage significance of Castlecrag
• Excessive in scale and out of character
• Likely to create unacceptable traffic and safety impacts
• Unrealistic in its assumptions about transport and parking
• Misaligned with both community expectations and stated government heritage principles

I strongly urge the NSW Government to reject this proposal in its current form and ensure that any future development is respectful, appropriately scaled, and genuinely responsive to the unique character of Castlecrag.

I am a Castlecrag resident and I strongly object to this application. I want to be straightforward about what concerns me most, that is the lived reality of what this oversized development could mean for the people who already live here, both during construction and long after it.
I walk and drive this area regularly. I know these streets and intersections intimately. I saw the impact of the demolition period on surrounding homes and businesses. I am outraged that a proposal of this scale being seriously considered for this location. I worked for Lendlease for many years and know the reality of constructing a building of this scale and housing this many additional people.
THE CONSTRUCTION ALONE WOULD BE YEARS OF DAMAGE
Before a single resident moves in, this development would impose years of disruption on the existing community, which has not been given anywhere near enough weight in this assessment. The developer’s ‘consultation’ was woeful and dishonest, claiming affordable housing, while blatantly advertising luxury residences on their signage.
Building 12 storeys at the entrance to a tiny peninsular suburb means years of heavy vehicles-concrete trucks, excavation equipment, cranes, delivery vehicles moving through roads that already struggle at peak times. Then there are the vehicles of the workers required for a project of this scale. There is no car park, so they will have to park in surrounding residential streets, leaving no parking for locals who want to patronise the businesses, or catch the bus to work.
Edinburgh Road and the Eastern Valley Way (EVW) intersection is the only way in and out of Castlecrag. There is no staging route, no bypass, no alternative. Every construction vehicle uses the same junction every that existing resident depends on, every single day.
It’s hard to get out now. There are only two lanes. Because EVW is a wide street it gets a long pedestrian green (red arrow). If the car at the front is turning left, you can wait a long time to go straight ahead and not many cars get through. I can’t imagine how disruptive it will be for the poor residents of Moratai Crescent. Their home values and quality of life will be destroyed.
The noise, the dust, the vibration, the road disruption these are not abstract concerns. This development sits at the only entrance to the suburb. Every construction vehicle, every concrete truck, every delivery has to pass through that point. For residents trying to get in or out of Castlecrag during what would be years of construction, there is no way around it. Even a more modest development will be disruptive.
I have not seen a construction management plan that takes this seriously. The assessment treats construction as a temporary inconvenience to be managed. For the residents of this peninsula, it would be an extended ordeal. That’s true of any size construction, but it will be much longer if it’s 12 storeys rather than five,
THE INFRASTRUCTURE CANNOT COPE WITH WHAT COMES AFTER
My concern does not end when construction does. Hundreds of new dwellings at the entrance to Castlecrag would place permanent, ongoing pressure on infrastructure that was never designed to support them. There are already several new developments nearby on EVW.
The road network is the most obvious problem. Castlecrag is a peninsula. Edinburgh Road feeds into a single intersection with Eastern Valley Way. That is the geography of this suburb and it does not change regardless of what traffic modelling says about clearance times. More dwellings means more vehicles means more pressure on a junction that already backs up. When that junction becomes too congested, the overflow goes through Sunnyside Crescent a narrow residential street that will become a dangerous rat run regardless of what anyone intends.
Public transport does not solve this. The nearest heavy rail is St Leonards and the nearest Metro is Crows Nest, neither is walkable from Castlecrag. The bus services here are not frequent enough to represent a genuine alternative to the car for most people's daily needs. The applicant cannot point to public transport as mitigation and then propose a development of this scale in a location this poorly connected.
Parking will overspill into surrounding streets. That is not a prediction, it is what happens when large developments underestimate demand, which they routinely do.
A FIRE COULD CREATE A CATASTROPHIC EMERGENCY WITH PEOPLE UNABLE TO EVACUATE.
Castlecrag is a bush suburb. Beyond roads and parking: what about the cumulative pressure on green space, on the bush tracks I walk on the tree canopy that defines the look and feel of this suburb? A development of this footprint and height will change the light, the drainage, and the character of the surrounding environment in ways that cannot be overstated.

THIS IS NOT THE RIGHT PLACE
I understand that Sydney needs housing. I’m the parent of two young adults. I do not object to development as a principle. What I object to is this development, in this location, at this scale on a peninsular suburb with one road in and out, beside a heritage conservation area of international significance, in a location that no state or local planning strategy has identified as suitable for this kind of intensification.
There is already an approved development for this site. DA-2024/13 allows a 3 to 5 storey mixed-use building. That is not nothing. It is a meaningful contribution to housing that works within the actual constraints of this location. The applicant has chosen to pursue something three to four times that height instead, and the justification appears to be that the current political environment around housing might make that possible. Developer greed and state government laxity working together to destroy a heritage suburb
It shouldn't. The controls that apply to this site exist because Castlecrag , its roads, its heritage, its bushland, its community, cannot absorb what this proposal would bring. Not during construction, and not after it.
I urge the consent authority to refuse this application.
Kylie Fuller
Castlecrag

I am writing to object to the proposed development at 100 Edinburgh rd.

I have lived at the above address since the early 90s. As a longstanding resident of the area, I have become very concerned by the proposed development at 100 Edinburgh Rd. The site’s status as a Stage Significant Development needs to be withdrawn. Willoughby City Council has strict development controls to ensure that development is done appropriately needs to retain control of the area. The original low-rise proposal was appropriate as the site needed to be developed. The developer also needs to make a profit. I understand that the current cost of building makes this more difficult, hence the need for 150 apartments.

However, the profits of a developer are not paramount. The local area cannot be destroyed on the altar of profit. 150 apartments will lead to over 150 new cars in the area. There is no train or metro station, just a few buses that are already oversubscribed.

These cars will then be parked on the surrounding streets causing congestion to the local area. It will be impossible for residents to enter or leave Castlecrag. My daughter and her family live in Castlecrag and we see the level of congestion when we visit them or take our grandchildren to school. With 150 apartments at the top of the street it will be impossible to enter or leave the suburb. This will have an impact on side streets as well. The intersection between Eastern Valley Way and Edinburgh Road will be totally blocked with major traffic impacts and safety issues as well.

A building of this size will be visually unappealing. This is a suburban area without any high-rise developments. This will be totally out of place. It also sets a dangerous precedent. If this is allowed to proceed, then what is next? Every strip of shops could turn into a skyrise! It will detract from the beautiful and leafy lower North Shore. It will also destroy the adjoining and historically important Griffin conservation zone – there will be shading and congestion with parked cars from the new development.

There is little social benefit either, with only ten affordable apartments. The remaining 140 will cost millions and will no doubt be sold on the overseas market due to the restrictions on buying existing properties.

This development cannot go ahead and needs to be withdrawn as a State Significant Development. A 12+ storey development with all the associated impacts will destroy the local community. The only winner will be developer.

Bernardita Naguit.

6 May 2026
Objection to the SSD-90134958: Proposed mixed use development at 100 Edinburgh Road , Castlecrag.
I write to express strong objection to the proposal, SSD-90134958, which will vastly increase the scale of the development at 100 Edinburgh Road, Castlecrag to the detriment of the local community and the Willoughby City Council (WCC). The Minister must refuse this cynical application and must not vary the approved development conditions for DA-2024/13 which were so vigorously debated, tested and finally adopted by Government.

The Edinburgh Development Group Pty Ltd proposal is an extravagant initial proposition made in expectation of an eventual counteroffer and compromise. It must be rejected outright.

Ten years ago, our family relocated to Castlecrag because we loved the immersive landscape experience, of living in the bush, the calm streets, the sympathetic and quality architecture, the social cohesion and respect for neighbours’ rights and amenity. We were impressed by Council’s robust development controls, the integrity of its planning and approval processes and the enthusiastic work of many local volunteers to protect the intrinsic values of this special place.

The Edinburgh Development Group development proposal is grossly over scaled. It:
• contravenes the WCC planning controls, policies and guidelines,
• conflicts with the unique heritage values of the estate and the Griffin philosophy of buildings being subservient to the landscape;
• will generate significant extra traffic that will clog the primary and limited access into and out of the suburb; and
• will overshadow many residents homes, remove their sunlight access, destroy their amenity, and diminish their property value.

The Edinburgh Development Group proposal will undermine community values and social cohesion.
It is a gross ambit claim to maximise profits by a development company which has made no meaningful attempt to engage the community, to respect its wishes, and which has ignored the vast investment by Council and the local residents over many decades to achieve sympathetic development and protect a unique way of life. To give any support to this new proposal will set a dangerous precedent for Willoughby Council and indeed the whole planning system in NSW.

The SSD-90134958 proposal must be rejected in its entirety.

Yours faithfully


Ross de la Motte
Registered Architect, #7398, AIA
Registered Landscape Architect, #10, FAILA

I am writing to formally object to the State Significant Development Application for 100 Edinburgh Road. As a local resident, I am deeply concerned by the scale of this proposal, which represents an unprecedented departure from the established planning controls and the unique character of Castlecrag.

Issue 1: Extreme Non-Compliance and Reliance on Non-Existent Rezoning

The proposal is profoundly non-compliant with the Willoughby Local Environmental Plan 2012. While the law permits a maximum height of 9 metres and an FSR of 1:1, this development seeks 48.96 metres and an FSR of 4.2:1—representing over five times the height limit and four times the floor space limit. The applicant’s own documents admit that "LEP standards are superseded by concurrent rezoning" (Appendix D), yet this rezoning does not exist and has not undergone a Gateway determination. Granting consent based on a "workaround" that has not been through proper community consultation is an improper exercise of planning power.

Issue 2: Impact on the Griffin Heritage Conservation Area Gateway

The site sits on the literal boundary of the Griffin Heritage Conservation Area (C4). The applicant’s Statement of Heritage Impact admits the site is at a "gateway into the Conservation Area" and concedes there will be "visual contrast due to the scale disparity between the new building and the lower-scale heritage dwellings." A 13-storey tower is irreconcilable with the Walter Burley Griffin ideal of "subordinating the suburban ideal to the landscape." The admitted overshadowing of heritage dwellings to the east further demonstrates that this scale is contextually inappropriate.

Issue 3: Unquantified Impacts on an Already-Failing Intersection

The Traffic Impact Assessment admits the Edinburgh Road / Eastern Valley Way intersection is already operating at Level of Service F with a degree of saturation of 1.122. Alarmingly, the consultant concedes that their model "is not representative" at this failing level. This means the applicant has failed to quantify the actual impact of 150 new dwellings on an intersection that is already saturated, posing a significant risk to local infrastructure and safety.

Personal Impact

"As someone who uses this intersection daily for the school run, I already experience significant delays. The addition of hundreds of cars from this development will make our local streets unusable and safe pedestrian access to the library and local shops nearly impossible."

Conclusion and Request for Refusal

In light of these admitted exceedances and the lack of statutory basis for an envelope of this scale, I request that the Minister refuse the application. In the alternative, I ask that the matter be deferred pending a properly exhibited Planning Proposal and referred to the Independent Planning Commission for a public hearing.

Dear Sir/Madam
I wish to strongly object to the development proposed for 100 Edinburgh Rd Castlecrag. Having reviewed the exhibition documents, I make the following points:
1. The proposed development is excessive in scale and goes way beyond the previously accepted height limits. I note that the proposed development exceeds event the nearby Northbridge town center limits, even though Castlecrag has a lower classification and unlike Northbridge, Castlecrag in not a designated growth area.
2. The scale and mass of the proposed building undermines the unique heritage of Castlecrag which is small-scale, village style. There is no local precedent for this scale of development and it will destroy the sense of place, visual distinction, and the Griffin heritage of our suburb.
3. The design itself is ugly compared to the previously approved development and will result in shadowing that will destroy the ambiance of our village, casting long shadows to the south and severely impinging the visual experience of our suburb's entry. It creates a skyline that is completely out of sync with this area.
4. The increased height and scale, above approved limits, results in additional dwellings and no doubt car movements that are not compatible with our suburb's single-entry point along Edinburgh Rd. This will have traffic and parking consequences that will constrict movement in and out of the suburb particularly at peak times. As there is no rail or metro, and VERY limited bus services, all new residents will rely on private cars which cause safety risks and no doubt excessive queuing to get in and out of the suburb.
5. The proposal includes tree removals that go significantly beyond the previously approved design. I see that 22 trees are to be removed which I understand equates to approx 42% of all live trees on the site! The tree canopy is a distinct feature of our suburb and it's Griffin legacy -- this proposal destroys that.
6. I question the proposal's set back methodology and urge you to examine this closely. The proposed set back appears to be based on a 3-5 story scheme rather than a 11+ story and (which is contrary to planning principles) and will result in an overwhelming bulk form of out of place skyline.
7. Finally, the purported "affordable housing" claim is spurious, since this is clearly a high end development and will not contribute to solving the housing shortage.
I wish to emphasize that I am not against development, however, this unique heritage area must be protected from inappropriately sized overdevelopment that risks the opportunity to create new housing that is at an appropriate scale and adds to the visual landscape in a way that honours the Griffin tradition.
Sincerely,
Stephanie Graham
302 Edinburgh Rd
Castlecrag

Michael Fisher
19 Garden Place, Willoughby NSW 2068
Submission – Objection to Proposed Development at 100 Edinburgh Road

I wish to formally object to the proposed development at 100 Edinburgh Road.
I am the owner of a townhouse in Garden Place, which is part of a townhouse complex, two storey height, that blends comfortably within the Willoughby, Northbridge, Castlecrag environment. We are located within 400 metres of the proposed development at 100 Edinburgh Rd.
My concerns relate to fundamental issues of planning compliance, traffic and transport impacts, and the overall integrity of the application. Taken together, these issues demonstrate that the proposal is inappropriate for the site and inconsistent with the established planning framework.
Planning Non-Compliance and Strategic Misalignment
At its core, the proposal does not align with the intent of the E1 Local Centre zoning. This zone is clearly intended to support small-scale, village-style mixed-use development. What is being proposed here is a level of intensity and built form that goes well beyond that expectation. The planning controls anticipate low to mid-rise development that complements the established character—not a high-rise outcome that effectively redefines it.
The justification for the scale of the proposal appears to rely on Low to Medium Rise uplift principles. However, the site is not located within an area designated for such uplift and is not eligible for the associated increases in height or density. The comparison drawn with Northbridge is misplaced. Northbridge is a recognised growth centre with a very different planning context, and it is not appropriate to apply that logic to a sensitive locality such as Castlecrag.
There is also no credible basis to treat this proposal as a form of transit-oriented development. The site is not supported by rail or metro infrastructure, and local bus services are limited in both frequency and coverage. Increasing density in a location without adequate transport infrastructure runs counter to established planning principles.
The proposed height and scale are excessive when considered against both local and regional benchmarks. The development exceeds parameters seen in nearby centres, despite this area having a lower planning classification and a more sensitive character.
This is further highlighted by the surrounding context. The site is adjacent to predominantly low-rise residential development. Introducing a building of this scale creates a stark and abrupt contrast, with no precedent in the locality. Rather than integrating with its surroundings, the proposal would dominate them.
The Environmental Impact Statement also appears to mischaracterise the planning context. Assumptions about future growth are not supported by the zoning framework for Castlecrag, which is not identified as a growth area and is recognised as having heritage and character sensitivities.
While the application asserts design excellence, the concerns raised by the Design Review Panel suggest otherwise. Issues relating to bulk, massing, street interface, heritage response, and overshadowing remain unresolved and go to the heart of the proposal’s suitability.
There are also concerns regarding the presentation of compliance. The apparent combining and rounding of retail and public space areas to meet threshold requirements raises questions about the accuracy and integrity of the reporting, further undermining confidence in the application.
Traffic and Parking Impacts
The proposal raises significant concerns in relation to traffic generation, road capacity, and parking adequacy.
A development of this scale will inevitably increase vehicle movements. This is reflected in the proposed expansion of parking from 163 to 376 spaces. It is difficult to reconcile such a substantial increase with claims that traffic impacts will be reduced. This inconsistency calls into question the reliability of the supporting analysis.
The traffic modelling itself appears flawed. The suggestion that increased density will result in reduced impacts contradicts both logical expectations and earlier assessments. Without a clear explanation, this significantly weakens the credibility of the conclusions.
The existing road network is already under pressure, particularly during peak periods when congestion and queuing are common. The 5-way traffic light at the intersection of Edinburgh and Eastern Valley Roads during morning peak hour to 9am and the afternoon peak hour from 3-4.30pm currently results in long delays and extended traffic lengths. The traffic assessment for the original development proposal noted that even that limited development tested acceptable wait times. The proposal does not appear to provide meaningful mitigation to address these existing conditions, let alone the additional demand generated by the development.
There is also a high likelihood of “rat-running” through surrounding residential streets as drivers seek to avoid congestion. These streets are not designed for increased traffic volumes and this behaviour would create additional safety risks for residents.
Pedestrian safety is another concern. The increase in traffic near shops, schools, and crossings will heighten the risk of accidents, particularly during peak periods when both pedestrian and vehicle activity is greatest.
Despite the increased provision of parking, the proposal still falls below required standards. This shortfall will inevitably spill over into surrounding streets, placing additional strain on local parking and negatively affecting residents and businesses.
Public Transport Limitations
The proposal places considerable reliance on public transport accessibility, however this is not supported by the reality of the site.
The nearest rail stations are approximately 3 to 4 kilometres away, making them impractical for regular use. As such, rail cannot be considered a viable transport option for most residents.
Bus services, which appear to be the primary alternative, are limited in frequency and coverage, particularly outside peak weekday hours. This makes them an unreliable option for daily commuting or general travel, increasing the likelihood that residents will depend on private vehicles.
There is also an inconsistency within the project documentation. While the planning justification presents the site as well-serviced by public transport, other parts of the documentation acknowledge that access is limited. This contradiction raises concerns about the accuracy of the overall assessment.
In practical terms, the lack of convenient and reliable public transport undermines any claim that the development represents a sustainable or transport-oriented outcome.
Modified Development – Mischaracterisation
The application frequently refers to the proposal as a “modified development” of DA-2024/13. This characterisation is misleading.
The current proposal is supported by a rezoning application that seeks to significantly increase building height and floor space ratio. This represents a fundamentally different development, not a modification of an existing approval.
In addition, the application relies on consultant reports prepared for the earlier DA. These reports were specific to a different proposal and cannot reasonably be relied upon to assess the impacts of a substantially altered development.
A proposal of this scale and nature should be supported by updated, development-specific studies across all relevant disciplines. The reliance on previous material further undermines confidence in the adequacy and accuracy of the assessment.

Conclusion
For the reasons outlined above, the proposed development represents a significant departure from the applicable planning framework and fails to adequately address key issues relating to scale, transport, and infrastructure.
It is inconsistent with the intent of the zoning, unsupported by appropriate transport infrastructure, and likely to impose unacceptable impacts on the local road network and surrounding community.
Accordingly, I respectfully request that the application be refused.
Michael Fisher

In my opinion of the Conquest development, 100 Edinburgh Castlecrag, I shall avoid vituperation as it will alienate the reader. I ask questions instead:

1. How did an approved development of circa three storeys suddenly become eleven to thirteen storeys without public approval?
2. Did anyone notice that the height of the development is a civil aviation hazard, if not an invitation to terrorist attack? OK this is facetious but twin towers? But honestly!
3. Did anyone point out that major high-rise developments in Castlecrag had been ruled out citing existing growth centres, such as Chatswood, is the proper place for these?
4. Did anyone do an impact study on the effects of the significant increase in motor traffic on the only convenient egress intersection (Edinburgh Road and EVW) ? Will there be a move to erect a flyover there? Or perhaps better would be a traffic flow restriction on car movements by number plate.
5. I suspect that heritage is not a consideration as this is an abstract concept which takes a backseat to the profit motive. Is this a fair statement?
6. We read that the Conquest has quadrupled the projected yield on the AUD 106 million development cost (https://www.theurbandeveloper.com/articles/conquest-100-edinburgh-road-hda-exhibition-nsw)
7. Has anyone examined the business case for the ROI? It will be eyewatering I suggest. If I had no scruples I would invest myself. But I do and can abide neither hypocrisy nor naked self interest at the expense of others.
8. Has Willoughby Council denied any conflicts of interest in the Development?
9. Has Willoughby City Council's Urban Tree Management Policy had an effective role in protecting trees that are scheduled for removal? Or is the Policy a perfunctory instrument of the tick-the-box variety?
10. Suppose for a moment that the current global crisis leads not only to a significant recession but to a global depression. Cost of capital goes up, the Development stalls and Conquest goes into receivership. Has Conquest a strategy to deal with this scenario? Would we be looking at a hole in the ground for the next 20 years with Council providing costs for maintenance, removing wastewater, restricting access, protecting against vandalism? A project that stalls halfway is an expensive catastrophe.

I am writing to express my concerns relating to the current proposal for re-development of the Quadrangle Village centre in Castlecrag. I am not a resident of the suburb but live within the Willoughby LGA and regularly enjoy visiting to walk through the heritage character streets and the bushland paths that weave through the area, and to socialise at its friendly local cafes and restaurants. It’s a place of great natural and built beauty that provides invaluable social, recreational and wellbeing opportunities for locals and the many visitors who appreciate the beauty of the urban bushland environment and the Burley Griffin heritage.

I cannot understand how this project has attained SSD ‘significance’. It is not located in a transport hub, commercial centre, or growth area and the apartments will not be affordable to those impacted most by a shortage of reasonably priced housing. The only ‘significant’ thing about this development would be the loss of heritage, amenity, liveability, and community.

I volunteer for both the local Bushcare program and environmental community group, Willoughby Environmental Protection Association. WEPA is a registered charity focused on preserving natural heritage, protecting local bushland and wildlife and mitigating the impacts of pollution in our locality. As a result of my environmental advocacy, one of my main concerns is the potential loss of 22 trees within the building zone, and in particular the proposed removal of eight high-value indigenous, established canopy trees. The proposal also lacks a comprehensive tree management plan to ensure survival of remaining trees and capacity for future deep soil plantings. Trees provide play a critical health and wellbeing role - keeping our city cool, providing clean air, storing carbon and the provision of habitat for our vulnerable local wildlife.
Should this proposal be approved, the NSW Government’s target of 40% canopy cover across Greater Sydney will slip further away. In 2019 ArborCarbon data for the Willoughby LGA recorded tree canopy at 35.6%, declining by almost 5% to 33.9% in 2022. We are suffering from a three-pronged attack as houses supersize; established gardens are surrendered to increase housing supply; and there are regular incidents of foreshore homeowners illegally removing trees on public land in selfish pursuit of ‘tree-free’ harbour views. There was the devastating 2023 loss of over 250 trees in the neighbouring bushland reserve of Castle Cove and Castlecrag is also a hot-spot for illegal removals. Sydney’s Northern ‘green heartland’ is an asset being undervalued by the NSW Government. It is Sydney’s lungs and its natural air-conditioner. Our decision-makers have an obligation to ensure that density is done well, safeguarding high value habitat and overall canopy growth.
In addition to the negative environmental impact, I believe the current proposal should be denied due to -

The devaluing of Walter Burley Griffin Heritage:
The unique design of the Griffin conservation Area has been preserved through covenants that ensured its buildings remained subordinate to the natural bushland and sandstone landscape. Our decision-makers have a responsibility to protect the legacy of one of our iconic designers and the valuable history of our city. The recent released NSW Heritage Strategy included a ministerial statement that “Heritage matters. It strengthens communities, supports wellbeing, and benefits our economy and environment…This strategy aims to share these benefits fairly across NSW’. This development does not support the heritage of Castlecrag, and this is reflected in the advice from the State Govt Architect, which found that the proposal is a poor standard of design.

Not location-appropriate:
The Castlecrag location should not meet SSD criteria as it is not a designated growth centre, commercial or transport hub. There is no train or metro and only a limited bus service, so future residents will bring more cars onto our already overloaded roads. The excessive bulk, scale and height is not appropriate for one of Sydney’s most valued urban bushland landscapes. The development does not comply with the C4 zoned Environmental Living guidelines that govern Castlecrag development, to protect its wildlife, natural heritage and the visual amenity for residents and visitors.

Inadequate community consultation:
One of the 5 key principles in the NSW Heritage Strategy is that ‘Community voices are critical to understanding heritage significance’. The consultation process for this development has been inadequate. The community has a right to be angered by the SSD proposal, as they were actively involved in the original, approved design and supportive of the 5-story/38 apartment project. This 15-story block is not supported by the community. It is frustrating when politicians throw shallow NIMBY accusations at residents, when it is their failure to protect local landscape, heritage, and community that has instigated resident action. They are rightly calling for Government to step up to the important strategic planning responsibility that is pre-requisite to designing a world-class city. I urge the panel to honour the ministerial statement and unwind the free rein given to developers to devastate our urban landscape for their monetary gain. Respect the values and rights of local communities over greedy external corporate interests.

Traffic and safety implications
Edinburgh Rd is essentially the single road for traffic moving in and out of the suburb and congestion builds up quickly at the intersection to Eastern Valley Way. The proposed development is located at this this busy four-way intersection, on the crest of a hill, already the site of numerous accidents involving cars and pedestrians. The additional load of cars at this high-traffic point increases the risk to pedestrians, cyclists, and motorists. There is also the increased likelihood of emergency vehicles being held up by traffic, which could be life-threatening.

I support density done well and remined the panel that Willoughby is already delivering on its allocated housing quota. High-density housing is being approved in our transport and commercial hubs, where it can contribute more affordable housing without over-burdening existing infrastructure. We have one chance to get it right and can’t hand Sydney over to developers who will put their interests ahead of the amenity and liveability of our city. Conquest purchased based on the original approved DA for 38 apartments up to 5 stories. Please reject this new DA and ensure that the developers adhere to environmental and planning regulations that govern this precious yet vulnerable bushland suburb.

Submission objecting to the Edinburgh Road / Eastern Valley Way SSD

I object to the State Significant Development Application lodged by Edinburgh Group Investments Pty Ltd for the former supermarket site at the corner of Edinburgh Road and Eastern Valley Way, Castlecrag. This proposal seeks to overturn, in one step, a local planning framework that was the product of extensive, good‑faith consultation between Willoughby Council and its community, and to replace it with a development envelope more than five times the permitted height and more than four times the permitted floor space under the Willoughby Local Environmental Plan 2012. That planning framework has already enabled a more modest, community‑supported development outcome for this site. The applicant’s proposal disregards that work, causes unacceptable harm to the Griffin Heritage Conservation Area, and imposes an entirely inappropriate scale of development in a location with poor public transport access and already failing traffic conditions.

1. Disregarding the community‑endorsed planning framework and delivering poor‑quality outcomes

The Willoughby LEP 2012 did not emerge in isolation. It was the outcome of a deliberate, good‑faith planning process undertaken by Council with extensive community input, balancing renewal of the Castlecrag local centre with clear limits on height, scale and built form to protect amenity and heritage character. That process has already resulted in an approved development envelope for this site that aligns with the LEP controls and has community support.

This proposal discards that framework entirely. Instead of working within the planning controls developed through consultation, the applicant seeks approval for a 48.96‑metre, 13‑storey building with a floor space ratio of 4.2:1 — despite the LEP permitting 9 metres and 1:1. The applicant does not even attempt to justify those departures through a clause 4.6 request. Instead, it asserts that “LEP standards are superseded by concurrent rezoning” (Appendix D), even though no such rezoning has been made, exhibited or approved. This approach bypasses the very planning process that allowed the existing, community‑supported scheme to proceed.

The consequences of this disregard are evident in the quality of outcomes proposed. The applicant’s own Apartment Design Guide compliance table admits that 30 per cent of apartments will receive no direct sunlight at the winter solstice (Appendix H), double the maximum permitted failure rate. These are not simple trade‑offs; they are the result of pushing scale far beyond what the site and planning framework were designed to accommodate.

2. Disregard for Castlecrag’s heritage significance

Castlecrag is a nationally recognised garden suburb designed by Walter Burley Griffin and Marion Mahony Griffin, defined by buildings that are deliberately low‑scale and subordinate to the landscape. The site directly adjoins the Griffin Heritage Conservation Area and abuts the Griffin Centre heritage item at 120 Edinburgh Road.

The applicant’s own heritage consultant concedes that the site is “a gateway into the Conservation Area” and that “there will be some visual contrast due to the scale disparity between the new building and the lower‑scale heritage dwellings” (Appendix W). It also admits that heritage‑appropriate roof forms “would be inappropriate at this scale”, that overshadowing of heritage dwellings will occur, and that there are significant views into and out of the Conservation Area — yet no harbour view impact assessment has been undertaken.

These are not minor or technical impacts. They strike at the very attributes the Conservation Area is listed to protect: scale, setting, skyline and landscape integration. Clause 5.10 of the LEP requires those impacts to be considered. On the applicant’s own admissions, a 13‑storey tower at this location cannot be reconciled with that obligation.

3. An unsuitable location with unquantified traffic impacts

This proposal is for 150 apartments, 376 car parking spaces and substantial retail floor space in a location that is kilometres from the nearest rail station, is not within walking distance of any metro or light rail, and is already served by an intersection that the applicant admits is failing.

The Traffic Impact Assessment records the Edinburgh Road / Eastern Valley Way intersection as operating at Level of Service F in the morning peak, with a degree of saturation of 1.122 (Appendix Q). The applicant then concedes that, at this level of failure, the traffic model “is not representative”. In plain terms, the applicant cannot reliably quantify the impact of 150 additional dwellings because the baseline conditions are already beyond the model’s capacity. Treating this site as having “very high accessibility” and relying on outdated traffic generation rates only compounds that flaw.

Under section 4.15(1)(b) of the EP&A Act, the consent authority must consider the likely impacts of the development. Those impacts have not been properly assessed for the most critical constraint affecting the site.

I have lived in Castlecrag for more than 27 years and raised my family in this deliberately low‑rise, heritage suburb. I am not opposed to change or renewal of the local centre, but this proposal would fundamentally alter how we live day to day. The scale of this building would dominate the approach to the neighbourhood, change outlooks and light, and funnel additional traffic into an intersection that already makes everyday trips e.g. school runs, bus access, walking to local shops, stressful and unsafe. What has been presented does not feel like a careful evolution of the neighbourhood, but an imposition that ignores both the character of Castlecrag and the experience of the people who live here.

Requested outcome

For these reasons, I ask the Minister to refuse the application and to give proper weight to the community‑endorsed planning controls and the already approved development outcome that respects both Castlecrag’s heritage significance and the intent of the Willoughby LEP.

I have no reportable political donations to declare.

Regards
L.McDonald

I object to the State Significant Development Application lodged by Edinburgh Group Investments Pty Ltd for the former supermarket site at the corner of Edinburgh Road and Eastern Valley Way, Castlecrag.

I am 23 years old and have lived in Castlecrag my entire life. What concerns me most about this proposal is not just its size or design, but the way it has been advanced: by sidelining democratic planning processes, dismissing community consultation, and attempting to sweep aside a Local Environmental Plan that was developed with, and relied upon by, local residents and ratepayers acting in good faith.

Our community engaged with the consultation process in good faith on the understanding that it would meaningfully guide future development decisions. The planning framework has already produced an approved development outcome for this site that aligns with the plans height, floor space and character controls and has community support. The applicant has chosen not to build that approved scheme. Instead, it seeks a vastly larger development that directly contradicts the planning controls negotiated with the community.

The applicant’s own Community engagement outcomes report and Social impact assessment record overwhelming concern from participants, with high levels of objection to height, scale, traffic and local character. The Social impact assessment identifies “disenfranchisement” as a very high negative social impact, noting significant frustration and distress during community sessions.

Despite this, the proposal increased in scale between consultation rounds, including a 72 per cent increase in parking numbers, with no meaningful opportunity for the community to respond to those changes. Consultation processes that proceed while results are ignored are not genuine engagement, they are just going through the motions as procedural gestures.

The current roads are already stressed during peak periods, In my opinion increasing the amount of traffic will only make a bad situation worse and will likely result in rat runs on our quiet backstreets.

As someone who has grown up here, I was taught that laws and regulations matter, that community voices count, and that governments and developers are bound by processes designed to balance private interest with public good. To me the proposal tells young residents like me that long‑term engagement, participation and reliance on planning frameworks is pointless, that decisions will ultimately be made over our heads if enough scale and money are involved. It undermines trust in public institutions and leads to impressions of shady backroom deals.

I ask the Minister to refuse the application. The proposal disregards the proposal developed in consultation with ratepayers, undermines democratic participation, and is contrary to the public interest.

I object strongly to this proposal, which would fundamentally change the character of the entire area, not just that of the famous bush suburb of Castlecrag, with no reasonable justification.
- the proposal uses the cover of a ''state significant development'' to put forward a design which is totally out of place with the surrounding area and buildings; creates a huge, oversized eyesore at the entrance to a suburb renowned worldwide for blending in with the surrounding bushland; and has paid lip service at best to heritage concerns, overshadowing of surrounding homes and consultation with residents
-there is no comparable sized building anywhere near the site, and development along eastern valley way has been kept at 2-3 storeys at most- the proposal is in the wrong place
- years of consultation have gone into planning controls for the site (council consulting with the community), and a DA process which eventually went to the state planning committee. What was agreed to was less than a quarter of the height of the current proposal
-notwithstanding the permanent destruction to the suburb and the surrounding area, such a proposal is not justified in this location because:
a) we are not on a transport corridor. outside of an hour or two of the peak, we are very poorly served by transport, and are no-where near a major rail line. This development belongs along a heavy rail line, but even along the north shore line/ pacific highway, such massive developments are not present except in city centres like chatswood or st leonards
b) the idea that these luxury apartments with water views, advertised as they have been, would do anything to alleviate the housing crisis, or provide realistic accommodation for essential workers close to transport, is laughable
c) the building proposed is not in an area where such developments are planned or fit in- there is nothing vaguely comparable anywhere near the site
d) the road infrastructure is not sufficient to support the increased traffic- Castlecrag has essentially only one road in and out with no direct ingress/ egress from the site on to eastern valley way
- The developer has cynically paid lip service to their responsibilities and have
a) excavated and advertised the site as if it is already approved
b) run community meetings with clearly no intention to compromise or listen
c) claimed to care about environmental and heritage concerns but have included blatant falsehoods/ misrepresentations in this proposal in a cynical attempt to appear to be addressing concerns

Castlecrag can do its bit to increase housing, with a responsible low rise development which respects the heritage and character of the area. and there are multiple opportunities along eastern valley way to do the same. This is already occurring and future scope is substantial
Please do not allow this inappropriate, out of place and cynically constructed proposal to permanently tarnish a world-renowned, beautiful bushland suburb, especially as there is no commensurate benefit, except to the developer

I moved to Castlecrag as a 17-year-old in 1987 and attended Willoughby Girls High School for Years 11 and 12. We lived at the very end of Edinburgh Road, and over the years I’ve watched this suburb remain much the same in many ways. Castlecrag has always felt like a small village, and I believe the people who live here deeply value its unique character and strong sense of community.

I won’t repeat all the qualities that make Castlecrag special, as I’m sure they have already been highlighted by many others. Instead, I’d like to share my perspective as both a long-term resident and someone who has owned and operated a local business here for more than 25 years.

Growing up at the bottom of Edinburgh Road was wonderful, but it also came with challenges. Public transport has always been limited, with buses running infrequently, meaning most families relied heavily on private transport or lifts from parents and siblings. Nearly 40 years later, very little has changed in that regard.

As the owner of a skin clinic located at the entrance to Castlecrag beside the council car park, I have had a daily view of how busy and strained this narrow gateway into the suburb already is. Since opening my business in 2000, I have witnessed the morning and afternoon traffic build-ups, road rage incidents, accidents, near misses, children crossing busy roads, and elderly residents struggling to move safely through the area. These are not isolated incidents — they are part of the daily reality of life here.

Over time, Castlecrag has naturally gone through cycles of older residents moving on and young families moving in, much like when my own family arrived in 1987. However, despite these changes, the suburb itself has remained relatively small and delicate in terms of infrastructure.

My concern is that development at the proposed scale will place significant pressure on a community that is already operating at capacity. With only one main road in and out of Castlecrag, I genuinely believe increased traffic will compromise safety for both residents and visitors, particularly children and older people. Buildings will stand for decades, but the consequences of inadequate planning and safety risks may be irreversible.

In my view, the currently approved plans for 38 apartments are likely the maximum level of development the area can reasonably absorb without long-term negative impacts. Expanding beyond that risks changing the nature of the suburb in ways that may not be sustainable for the community.

I want to make clear that I am not opposed to growth or positive change. As a small business owner who has experienced the challenges of COVID, local business closures, and years of disruption from nearby construction, I understand the importance of bringing new people and energy into the area. Growth can be positive, but it needs to be carefully considered and balanced, particularly in a suburb with limited infrastructure and a strong community identity.

As both a resident and business owner, I respectfully ask that you reconsider the proposed scale of this development and work more closely with the local community to ensure any future plans support the long-term well-being, safety, and sustainability of Castlecrag and the wider community.

Objection to the Conquest Development Proposal — Lisa Sergeant, Castlecrag
I am pro-housing. Sydney faces an acute housing crisis driven by extreme affordability issues, low vacancy rates, and chronic supply shortages. But being pro-development does not mean accepting bad development. I object to this proposal on three clear grounds.

1. The affordable housing benefit is token and time-limited
Only 10 of 150 units (6.67%) are offered as affordable — none of them family-sized. There is no binding commitment to priority groups such as key workers or at-risk families. The affordability period is just 10 years, falling short of the Housing SEPP 2021 minimum of 15 years and well short of Willoughby Council's own submission calling for affordability in perpetuity. The applicant also quietly switches the measurement metric from GFA — as required by Willoughby LEP clause 6.8 — to units, leaving the statutory test unanswered.
Granting a 5.4-fold height exceedance and a 4.2-fold floor space exceedance in exchange for 10 small apartments locked in for a decade is not in the public interest. The benefit is calibrated to be the least the applicant could offer while justifying the maximum density they are seeking.

2. The proposal is irreconcilable with the Griffin Heritage Conservation Area
The applicant markets Castlecrag's character as a selling point, then proposes a 13-storey, 48.96-metre tower at the literal gateway to the Griffin Heritage Conservation Area — directly abutting heritage item I253 at 120 Edinburgh Road, the Griffin Centre..
Griffin's 1920s vision was architecture subordinate to landscape. The Willoughby DCP 2023 reflects this: buildings should be "single storey, or in rare cases two storey, subordinate to and harmonious with the landscape." A 13-storey tower is neither. Notably, the community is not opposed to development here — it has already championed an award-winning 3-storey building plan for this site, demonstrating that sensitive, context-appropriate development is both possible and supported.
The applicant's own heritage consultant (Weir Phillips, Appendix W) concedes the point: "visual contrast due to scale disparity," overshadowing of HCA dwellings, and that heritage-appropriate roof forms "would be inappropriate at this scale." The report contains no photomontages, relies on a site visit over two years stale, and never assessed impacts from inside HCA dwellings — avoiding the very questions of setting, skyline, and landscape integration that define the HCA's significance.
Under clause 5.10 of the Willoughby LEP 2012, the consent authority must consider heritage impact on any adjacent HCA. On the applicant's own admissions, this proposal fails that test.


3. The proposal will overwhelm a peninsula community already at its transport limits
Castlecrag is a peninsula suburb with one road in and one road out, and some bus services so infrequent that Route 194 has no morning service and Route 203 has a nine-hour daytime gap. This is not a community with transport capacity to absorb 150 new dwellings.
The Edinburgh Road / Eastern Valley Way intersection is already failing — not by the objectors' assessment, but the applicant's own. The Traffic Impact Assessment (Appendix Q, Table 16) records Level of Service F with a degree of saturation of 1.122 in the morning peak, with right-turn overflow already spilling into through-traffic lanes. The applicant's consultant then concedes the SIDRA model output "is not representative" at LoS F.
In plain terms: the applicant cannot quantify the traffic impact of this development because their own model breaks down at current conditions — before a single new resident arrives.
The assessment is further undermined by reliance on the superseded 2002 RTA traffic generation guide, a claim of "very high accessibility" for a site 2.56 kilometres from the nearest train station, and no cumulative impact assessment against the five other approved developments already in the precinct.
Under section 4.15(1)(b) of the EP&A Act, the consent authority must consider the likely impacts on surrounding infrastructure. The applicant has failed to quantify those impacts on the most critical constraint in this proposal — a signalised intersection that is already at breaking point.

Conclusion
This proposal asks for extraordinary planning concessions — heights and densities that dwarf what the LEP permits — in exchange for benefits that are minimal, time-limited, and in one case miscalculated. It would place a 13-storey tower at the gateway to one of Sydney's most significant heritage areas, on a peninsula whose sole intersection is already operating beyond capacity.
I urge the consent authority to refuse this application.

Firstly, I object to the scale and height of this project which does not relate to any existing structures in the immediate precinct or suburb.

Secondly, it is my considered opinion that the development lacks acknowledgment for the unique Griffin character of this suburb. The Griffin Heritage value is of National / World value & should be clearly evident & appreciated in the level of relevant detail in the landscape and architecture in the proposal.

To the Department of Planning, Housing and Infrastructure,

I am writing to object to the proposed State Significant Development at 100 Edinburgh Road, Castlecrag.

I want to make clear from the outset that I am not opposed to development of this site. I lived in Castlecrag for ten years while raising my two boys, and the old shopping centre was an important part of our daily lives and the broader community. Like many residents, I have been saddened to see the site sitting vacant for so long and I strongly support seeing it revitalised and brought back into productive use.

Castlecrag deserves a thriving local centre again. It deserves shops, services, housing and renewed community activity. However, I do not believe this proposal is the right development for this site or for this community.

My concern is not with development itself, but with the extraordinary scale and intensity of what is being proposed. The current application bears little resemblance to the previously approved development and represents a dramatic escalation in height, density and bulk. The originally approved scheme was approximately five storeys with 38 apartments. The current proposal seeks approval for two 11-storey towers containing 150 apartments, five basement levels, extensive retail space and 376 car parking spaces.

This is not a modest increase or refinement of an approved project. It is a completely different scale of development.

Castlecrag is a unique suburb with a deeply valued landscape character. It was designed around the principles of integrating buildings into the natural environment, not dominating it. The existing planning controls reflect this character and seek to maintain the low-scale, landscape-oriented nature of the area. This proposal, however, seeks to override those controls through a State Significant Development pathway that removes decision-making from local council and the local community.

I find this deeply concerning.

The proposal relies on substantial variations to height and floor space ratio controls, along with a concurrent rezoning process, effectively asking the State Government to change the rules in order to accommodate a development that would otherwise not be appropriate for the site.

While the application repeatedly refers to “design excellence” and “landscape integration,” the reality is that two 11-storey towers on this ridgeline will fundamentally alter the visual character of Castlecrag. The development will be highly visible from surrounding areas and will introduce a level of scale and urban intensity that is entirely out of step with the surrounding neighbourhood.

I am also concerned about the traffic impacts associated with a development of this size. Edinburgh Road and Eastern Valley Way are already heavily used and difficult intersections at peak times. Adding 150 apartments, supermarket traffic, retail activity and hundreds of additional vehicle movements will place significant pressure on local roads and further reduce amenity for residents.

The proposal also raises concerns regarding landscape loss and environmental impact. Castlecrag’s identity is inseparable from its mature trees, sandstone landscape and bushland setting. While the documentation refers to landscape planting and tree retention, it is difficult to reconcile those claims with a development that includes five levels of basement excavation across most of the site footprint. The reduction in deep soil zones and removal of established vegetation will inevitably change the nature of the site and surrounding environment.

Another issue that concerns me is the apparent lack of clarity throughout parts of the documentation. In reviewing the application material, there appear to be inconsistencies regarding tree removal and the distinction between impacts previously approved under earlier consents and additional impacts arising from the current proposal. At a minimum, this creates uncertainty and makes it difficult for residents to properly understand the full extent of the proposal and its cumulative impacts.

I also question whether genuine design excellence has been demonstrated. The proposal seeks significant planning concessions while avoiding a competitive design process. In my opinion, if a project is seeking such substantial departures from established planning controls, it should be required to demonstrate an exceptional level of public benefit and architectural merit through a more rigorous and transparent process.

Importantly, I believe many residents who object to this proposal are not anti-development, despite how they are sometimes portrayed. Most people I speak to support renewal of the site and understand the need for additional housing. What many of us oppose is overdevelopment — particularly where it comes at the expense of the very qualities that make Castlecrag special.

There is a good project possible on this site. A revitalised village centre with well-designed medium-density housing, quality public space and thoughtful integration into the surrounding landscape could receive broad community support. But this proposal goes too far. It prioritises scale and yield over context, character and long-term community outcomes.

I respectfully ask the Department to carefully consider whether this development genuinely reflects the planning intent for Castlecrag and whether the public benefits claimed by the applicant outweigh the significant impacts associated with the proposal.

In its current form, I do not believe this application should be approved.

Yours faithfully,

Rebecca

Statatutory compliance table
The proposal is not consistent with the objective of the EP&A Act. In particular it is not is a ‘well serviced area’, does not allow for ‘orderly’ development of the land due to the excessive height and solar impacts on neighbouring properties and does not align with the strategic plans applicable to the locality of castlecrag.
The proposal does not promote sustainable management of built heritage within the vicinity of the site and is in sark conflict with the Heritage zone located directly adjacent to the site.
The development does not promote quality design as evidenced by the inability for the development to achieve support from the Design excellence committee. The development uses a pre approved footprint and simply dumps over 100 more apartments distributed in two towers at the top of an escarpment. With non compliant setbacks on the podium and excessive scale and height resulting in a bulk and mass that cannot achieve design excellence do to it being out of context with the surrounding locality.

The EOI have been declared state significant under the ministerial order. This order was approved under false pretences with regard to locality, proximity to major transport and context and should be revoked.

The developer and builder does not hold any Icert qualifications and has not demonstrated that they can deliver an occupiable building under the building and practitioner act. Noting they have yet to deliver a residential medium to high density project under the act.

The proposed development does not achieve ADG compliance, specifically; solar access, open public space and equal rights provision of affordable housing.

The proposal does not comply with the Apartment design guide with regard to locality, context, mass, height, setbacks, activation of facades, key view corridors.

Traffic modelling confirms that current the key intersections are preforming at level F& C, (Edinburgh Rd & Eastern valley way) and F,F at Eastern Valley Way and Sunnyside Cres) nothing that the inclusion and commentary on other intersections within the system are misleading on capacity given Edinburgh road is the only signalised entry and exit point into Castlecrag.
The background traffic growth adopted does not take into account the new proposed scale of the development at 1%per annum. Noting that key intersections received F,D and FF.

Traffic impact assessment has relied on unfounded and non sensical assumptions regarding 10 year forecasts and directional distribution noting that PTC confirm external transport needs to be improved and green action plan is required to be implements to avoid congestion due to the proposed development.

Zoning and permissibility; Willoughby local environmental plan. The previous approved DA complies and supports the objective of this plan. The Proposed development exploits the objectives and is inconsistent with Councils strategic planning. The development is Inconsistent with conserving and enhancing the unique sense of place and does not achieve urban design quality and does not integrate with the desired character and cultural heritage of local centres.

Part 4 principal development standards have been exploited. With this proposal exceeding the development standards by well over the 20% nominated. This development exceeds these standards by over 70%.

Non compliant with Heritage conservation Section 5.10.

Section 6.7 active street frontages has not been satisfied on the western elevation with a 6.8m to 11.1m wall being proposed as an active street frontage

Section 6.8 affordable housing. 9 of the 10 affordable housing stock proposed will receive 0% direct sunlight in the winter. Noting that summer shadow diagrams have not been provided.

Desgin Excellence – DRP feedback has not been complied with under this proposed development. Design excellence under the guidelines can not be achieved under the current proposal.

6.2 performance criteria; Reinforce the Griffin philosophy that the built form is subordinate to the surrounding natural environment. Non compliant due to height and scale. Rising 49 m in the sky and 40m above the tallest tree on Edinburgh Road.