Mixed Use Development 2-6 Willock Ave, 23 Kiora Road, Miranda

The height of this proposed building is ridiculous and far too high! Street parking is already impossible given the number of units in the area and being down the road from a major shopping center, a Cole's shopping center, a police station, and a train station. Adding 116 more units on top of all of this will only add to this congestion and add significant stress to the existing residents. The height will also be ridiculously disproportionate to other buildings in the area and will significantly hinder the suburb appeal. This proposed change will significantly hinder my personal wellbeing and create distress due to the construction noise and mess and pollutants in the air, and due to the atrocious increased traffic impact the build will have. This is a terrible proposal that is ludicrous and will harm many many people.

I object to the project, while we appreciate the philantrophic aim of the project, the development plan location is very close to a Primary School and to residential area with families having kids of all ages. This area is not for transient people as described on the development plan, and to quote: “diverse range of uses and services including homelessness, crisis housing, domestic violence services, alcohol and drug services, employment services, financial counselling health, community partnerships, Salvos shop etc.) This area is for people who already built and uprooted their families in Miranda. I am interested to know if the school Our Lady Star of the Sea Primary School has submitted their comments.

I own a unit in SP52108, 8-14 Willock Avenue, adjacent to the proposed development.
The development of a 60 metre high 17 story tower is significantly higher than surrounding buildings, and the 25 metre LEP limit, and will look totally out of place.
This 60 metre height will not only create shadowing of my building, but the courtyard, grassed areas, gardens and paved areas. These sunny spaces are vital for everyone, especially the children living at SP52108, which surrounds the proposed development.
Another serious concern of mine is the additional traffic. The corner of Willock Avenue and Kiora Road, is already dangerous. I believe that the additional traffic created from 116 units on this corner, will cause chaos.

FORMAL OBJECTION SUBMISSION
State Significant Development Application
Mixed Use Development – 2-6 Willock Avenue & 23 Kiora Road, Miranda NSW
Application Number SSD-80438964
Applicant Salvation Army (THQ) Property Trust & Argon Property Pty Ltd
Subject Site 2-6 Willock Avenue & 23 Kiora Road, Miranda NSW 2228
Proposed Development Mixed-use: 17-storey residential tower (116 units) + Salvation
Army Community Facility
Proposed Height 60 metres / 17 storeys (LEP maximum: 25 metres)
Proposed FSR 5.5:1 (LEP maximum: 2:1)
Decision-Maker NSW Independent Planning Commission / Department of Planning
Submitter Peter White
Property Unit 94, 8-14 Willock Ave. Miranda NSW 2228. SP52108 (directly affected)
Date of Submission 12 March 2026

1. Introduction and Standing
I am the owner/resident of Unit 94, 8-14 Willock Ave. Miranda NSW 2228 – a unit located directly to the West of the proposed development site and is among the properties severely impacted by this application.
I formally OBJECT to State Significant Development Application SSD-80438964 for a 17-storey, 60-metre mixed-use tower at 2-6 Willock Avenue and 23 Kiora Road, Miranda. My objection is grounded in multiple serious planning, amenity, traffic, and urban design concerns, each addressed in detail below. This development, as proposed, represents an unconscionable imposition on the amenity, liveability, and property rights of immediately surrounding residents. It massively exceeds applicable planning controls and has not adequately assessed or mitigated its impacts on neighbouring properties, including mine.
2. Gross Non-Compliance with Existing Planning Controls
The proposal seeks amendments to both the maximum building height and floor space ratio (FSR) permissible on this site under the Sutherland Shire Local Environmental Plan 2015 (SSLEP 2015).
The scale of departure from existing controls is extraordinary and should weigh heavily against approval.
Control LEP Maximum Permitted Proposed (Excess)
Maximum Height 25 metres 60 metres (+140% above limit)
Maximum FSR 2:1 5.5:1 (+175% above limit)
Number of Storeys ~7-8 storeys (at 25m) 17 storeys (more than double)
A departure of this magnitude – requiring concurrent rezoning to even be permissible – should not be approved without demonstrable, overwhelming public benefit. No such benefit has been established. The modest affordable housing contribution of approximately 5 units (4.3% of 116) is wholly inadequate to justify the permanent and devastating impacts on surrounding residents. The surrounding residential context is characterised by 2-7 storey buildings. The proposed tower would be more than twice the height of any nearby building and would permanently alter the character and skyline of this neighbourhood in an irreversible way.
3. Devastating and Unmitigable View Loss
Adjacent units currently enjoy significant views that are central to its amenity and value. These include:
• Expansive water views
• Views of the Sydney city skyline
• Open sky and sunlight from the northern aspect
• Visual connection to the open landscape beyond the development site
The proposed 60-metre, 17-storey tower will completely and permanently obliterate all of these views. Because the tower rises to 60 metres – nearly two and a half times the 25-metre LEP limit –there is absolutely no view corridor that can be preserved. This is a total view loss, not a partial or minor impact.
Under the principles established in Tenacity Consulting v Warringah Council [2004] NSWLEC 140, the courts have identified the following factors relevant to assessing view loss by owners of units:
• The value of the view being impacted (water and city views are among the most highly valued)
• The extent of the impact (total obliteration is the most severe possible outcome)
• The nature of the view loss (from a private residence, not a public space)
• Whether the viewing opportunity was reasonable and long-standing (yes, it pre-dates this application)
Applying these principles, the view loss to dozens of adjacent units which current enjoy the panorama and increased property value represents the most serious category of impact. The applicant's Environmental Impact Statement does not adequately address this impact, and no mitigation is possible given the proposed building envelope. This ground alone warrants refusal of the application.
4. Catastrophic Loss of Solar Access and Sunlight
Many units currently receive full sunlight throughout the day. This is not merely a lifestyle amenity, it is a fundamental aspect of residential liveability recognised in NSW planning policy, including the Apartment Design Guide (ADG).
A 17-storey, 60-metre tower directly to the East of my property will cast an enormous shadow over my unit. A key impact - The Apartment Design Guide requires that at least 70% of apartments in a development receive a minimum of 2 hours direct sunlight between 9am and 3pm on the winter solstice. This standard has been designed to protect future residents, but equivalent protection must extend to existing residents.
• The loss of solar access has health, wellbeing and energy cost implications for residents of my building as well as prevent the potential installation of solar panels on our Block B and C on Willock Ave
• The winter solstice shadow diagrams, if accurately prepared, will confirm the catastrophic shadow cast by a 60-metre building on properties to the south and east
The EIS does not provide adequate shadow analysis for the neighbouring residential buildings to the south, including 25-27 Kiora Road. The applicant must be required to provide comprehensive shadow diagrams showing the impact on all existing residential buildings at 9am, 12pm and 3pm on the winter solstice, and the Department must find that the impacts are acceptable before any determination is made.
5. Severe and Unreasonable Privacy Intrusion
The proposed 17-storey building will place dozens of residential balconies and habitable room windows at direct eye level or above my unit and private balcony. The impacts are severe and unreasonable:
• Residents on upper floors of the proposed tower will have a direct, unimpeded line of sight down onto my private balcony, effectively making it unusable as a private outdoor space
• The glazed façade of the proposed building will allow residents to see directly into my unit through my own windows and balcony doors
• The building contains 116 apartments, meaning potentially hundreds of residents will have a direct view into my private living spaces
• No screening or privacy measures can adequately address direct overlooking from a building 2-3 times taller than my own
• The ADG requires a minimum 9-metre separation between windows of habitable rooms and balconies of adjacent buildings to ensure adequate privacy. The proximity of the proposed tower to 25-27 Kiora Road and the extreme height differential make compliance with this intent impossible
Privacy is a fundamental right of residential amenity. The loss of privacy described above cannot be mitigated by planting, screens or design changes – it is an inherent consequence of placing a 17-storey tower immediately adjacent to lower-scale residential buildings. This impact should be a decisive factor against approval.
6. Traffic Congestion and Parking Crisis
6.1 Existing Intersection Already at Failure
The Transport Impact Assessment (Appendix I) confirms that the Kiora Road / Willock Avenue intersection is already operating at unacceptable levels of service during peak periods:
Period Level of Service Worst Movement (Right Turn to Kiora Rd)
AM Peak (currently) Level D 55.4 sec delay; 21.9m queue
PM Peak (currently) Level F (FAILURE) >70 sec delay; 78.8m queue
Level of Service F is the worst possible rating in traffic engineering – it represents total breakdown of intersection capacity. The fact that this intersection is ALREADY at Level F during the PM peak is a fundamental reason why this development should not proceed without major intersection upgrades.
6.2 The Right Turn from Willock Avenue onto Kiora Road is Near Impossible
As a daily user of this intersection, I can confirm from personal experience what the traffic data shows: the right-hand turn from Willock Avenue onto Kiora Road during peak periods is extremely difficult and often dangerous. Vehicles must cross two lanes of high-speed traffic on Kiora Road – a major arterial road – with limited sight lines and against continuous traffic flow. During school drop-off and pick-up times, with Our Lady Star of the Sea Primary School directly opposite, the situation is already dangerous.
Adding 116 residential apartments plus a community facility to a site accessed via Willock Avenue will significantly increase the number of vehicles attempting this near-impossible manoeuvre. The Transport Impact Assessment does not propose any physical intersection improvement to address this. This is unacceptable.
6.3 School Safety – Our Lady Star of the Sea Primary School
The development site is directly across Kiora Road from Our Lady Star of the Sea Catholic Primary School. During school drop-off (8:00am-9:00am) and pick-up (3:00pm-4:00pm) periods, Kiora Road and Willock Avenue already experience severe congestion from school traffic. These are the same peak periods identified in the Traffic Assessment as experiencing the worst intersection performance.
Adding 200-300+ additional daily vehicle movements from this development, including residents departing and arriving via Willock Avenue, will materially worsen conditions around a primary school. The safety of school children crossing Kiora Road during these congested periods must be weighed against the approval of this development.
6.4 Parking Shortfall
The development proposes only 155 car parking spaces against a DCP requirement of between 166 and 398 spaces. The applicant justifies the shortfall on the basis of the site’s public transport accessibility. However:
SEE THE COMPLETE FILE

Re: Objection to Proposed 16‑Storey Residential Development at 23 Kiora Rd

I wish to formally lodge my objection to the proposed 16‑storey residential development comprising 116 units at the corner of Kiora Road and Willock Avenue. While I acknowledge the role of development in supporting population growth, this proposal raises substantial concerns regarding its suitability, its impact on the surrounding community, and its alignment with responsible planning principles.

1. Traffic Conditions Already Operating Beyond Capacity

The intersection of Kiora Road and Willock Avenue is subject to significant congestion. Traffic delays along Kiora Road are commonplace during peak periods, weekends, and major retail events. The introduction of a development of this scale will markedly increase vehicle movements in an area already struggling to cope with existing demand. This will heighten risks for pedestrians, cyclists, and residents and further compromise the efficiency and safety of the local road network.

2. Anticipated Construction Impacts and Public Health Concerns

A project of this magnitude will necessitate an extended demolition and construction period, resulting in continuous heavy‑vehicle activity. This will exacerbate current traffic issues and may expose the community to prolonged noise, dust, and air‑quality impacts. Such conditions pose risks to vulnerable groups, including children, older residents, and individuals with existing health conditions.

3. Inappropriate Building Height and Overshadowing Effects

The proposed 16‑storey structure is inconsistent with the predominantly low‑mid rise character of the surrounding residential area. Its height will generate significant overshadowing of neighbouring properties, reducing access to natural light, diminishing privacy, and adversely affecting residential amenity. Furthermore, the visual prominence of a tower of this scale will alter the established character of the locality and may set an undesirable precedent for future high‑rise development.

4. Increased Pressure on Parking and Public Infrastructure

Parking availability in this part of Miranda is already severely constrained. Instances of vehicles parking on nature strips—resulting in damage to footpaths and public landscaping—are frequently observed. The addition of 116 units, irrespective of on‑site parking allocations, will intensify pressure on surrounding streets. This will likely lead to further deterioration of public assets and create additional barriers for pedestrians, including those using prams, mobility aids, or wheelchairs.

For the reasons outlined above, I strongly oppose the proposed development in its current form. I respectfully request that Council reassess the appropriateness of this application and give due consideration to the significant and long‑term impacts it will impose on the local community.

Thank you for your attention to this submission.

Along with Parking issues, beautiful views taken away from us, a tranquil view that gives us peace to our mental health, natural sunlight over shadowed by the project, major traffic congestion which is happening during peak hours already let alone a big project that will inject more major traffic, more noise pollution (at the moment there are peaceful times enjoyed on a Sunday with the open space and birds surrounding the area), less green space, more issues with the traffic leading up to the school throughout the week. A small area to put up this big project, people hanging around from the welfare centre. Many negatives especially when you and your family are directly being affected next door. More pressure on Kiora Rd and Willick Ave and our surroundings roads.
NOT HAPPY AT ALL.

The building is disgustingly oversized for the surrounding area.It will destroy the amenity of residents around it.
Loss of sunlight will affect residents health and cause depression.
The corner is already contested with heavy traffic and noise this will only increase the problem.
Where will residents visitors park as there is never anywhere near for Mothers with prams to visit their parent.
It will the blight on the area as it dwarfs all around it.
By all means build some thing new to ease the housing shortage but keep don’t lower people’s lives and housing prices with this monstrously 17 storey mistake.
Please kept the building a reasonable height as the surrounding area.We live in the suburbs not inner city where this belongs.

Dear Council

I’ve been an owner since 2004 and now feeling very distressed that the Salvation Army are seeking approval for their high rise apartment block including a welfare centre below. Right next to the Wilshire apartment. Which will mean that every single person in our 117 block units including family and friends who come to visit will be directly impacted and negatively affected by this project. Along side surrounding unit blocks and the school across the road.

Firstly, this will block my whole entire city views that initially attracted me to my apartment. I worked so hard for and paid so much to enjoy and now could be potentially taken away from me and my family.

Also living on the fifth level the project will block the sunlight coming in due to the high rise building. I enjoy the morning and afternoon sunlight in my lounge room and sunroom. This may also mean I’d need to turn on the lights resulting in more expenditure.

Secondly, I did not buy my unit to have other tenants possibly looking into my lounge room and invading my privacy and my family’s privacy or have views of a brick wall. We enjoy the open space, looking out at the city lights, the water views and greenery which brings us peace and relaxation into our lives. Whenever my daughter is feeling down and depressed as she suffers from anxiety and depression these views have truly been her savour.

Thirdly, the parking issue which we currently have will only get worse because families now have two, three or four cars and at times we have to park down at the tennis courts, the park and around Coles to find a parking spot.

Fourthly, the congestion of having 116 units on top of the ground floor Salvation Army going in and out of the area will become unbearable. Already on weekends there’s a long queue of cars trying to get to Westfield Miranda and I’ve seen people parking on Kiora Rd and Willock Ave and walking up towards Westfield. During the working week Kiora Road gets very busy as well.

Fifthly, with parents trying to drop off and pick up their kids from school along with having more units around the same area trying to get in and out will cause a great deal of congestion to the area.

Furthermore there are other open areas and opportunities for the Salvation Army to develop elsewhere in the Shire away from an already crowded premises especially so close to Westfield Miranda.

I completely object to this development along with other owners, tenants and people in the community that I’ve spoken to. Some are looking at compensation and this is something that I’ll be seriously considering as we don’t deserve to be disadvantaged for other people’s enjoyment.


ISSUES
Height of building - 60 metres- 116 units

* Sun shadowing

* Increased traffic - specifically vehicles on the busy intersection of Kiora Road and Willock Avenue

* Significant change to current planning

* The effect on the general amenity of the area

* Reduced outlook
AND MANY MANY MORE.

Re: Objection to Proposed 16‑Storey Residential Development at 2-6 Willock ave, 23 Kiora Rd.
I am writing to formally object to the proposed 16‑storey residential development comprising 116 units at the corner of Kiora Road and Willock Avenue. While I understand the need for thoughtful growth within our community, this proposal poses several significant issues that will negatively impact local residents, infrastructure, and urban amenity.
1. Existing Traffic Congestion on Kiora Road and Willock Avenue
The intersection of Kiora Road and Willock Avenue is already heavily congested, particularly due to its proximity to the Westfield Shopping Centre. Traffic builds up routinely during peak periods, weekends, and shopping events.
A development of this scale will significantly increase vehicle movements, worsening congestion and creating additional safety risks for pedestrians, cyclists, and local residents.
2. Additional Construction Traffic, Noise, and Air Pollution
The demolition and extended construction phase required for a project of this magnitude will inevitably generate substantial heavy‑vehicle movement. This will exacerbate current traffic issues and introduce prolonged noise and air pollution.
Residents and vulnerable groups—including children and older people—will be exposed to unnecessary health and safety risks across what may be years of construction activity.
3. Excessive Building Height and Overshadowing
A 16‑storey tower is incompatible with the surrounding residential neighbourhood, which is predominantly low‑rise. The proposal will result in extensive overshadowing of neighbouring homes, reducing natural light, diminishing privacy, and affecting overall quality of life.
Such a tall structure will also impact the visual character of the area and set a concerning precedent for future developments.
4. Parking Pressure and Damage to Local Infrastructure
Parking in the area is already at crisis point. Residents routinely witness cars parking on nature strips, which has caused visible damage to footpaths and public landscaping.
An additional 116 units—regardless of on‑site parking provisions—will place enormous strain on already inadequate street parking. This further increases the risk of damage to public assets and obstructs pedestrian pathways, especially for people with prams, mobility aids, or disabilities.

Conclusion
For these reasons, I strongly oppose the current proposal. I respectfully request that Council reconsider the appropriateness of this development in its present form and recognise the significant negative impacts it will have on the local community.
Thank you for considering my submission.

I strongly object to the proposed development.

My partners family live very close to this proposed project. I have serious concerns about the impacts that large-scale excavation and construction may have on surrounding buildings.

A development of this height will require deep excavation and significant foundation works. Construction vibration, ground movement and settlement have the potential to affect nearby buildings.

Residents should not be exposed to the risk of structural damage or prolonged disruption caused by an excessively scaled project built so close to existing homes.

This proposal also appears disproportionate to the stated community benefit and should be carefully reconsidered.

I strongly support the Salvation Army's proposal for this site, especially as it addresses the clear shortage of community housing and shortages in the Sutherland Shire. As a representative of a large real estate agency in the Sutherland Shire, I can confirm the requests for housing, from the likes of Domestic Violence Victims, escaping dangerous living arrangements is very high and rarely available.
This is a community must in my opinion.

• I am writing to formally lodge my objection to the proposed residential flat building at the above-mentioned address. While I understand the need for housing, the scale of this 16-story development is incompatible with the current infrastructure and environmental character of Willock Avenue and its surrounds.
• My objections are based on the following grounds:
• 1. Impact on Local Fauna and Biodiversity
• The proposed site and its immediate surroundings serve as a vital corridor for local birdlife and urban mammals.
• Nesting and Feeding: Large-scale construction will permanently displace native birds that utilize the existing canopy for nesting and feeding their young.
• Displacement of Fauna: Noise and light pollution, alongside the removal of vegetation, will force local possum populations to flee, likely leading to high mortality rates as they compete for dwindling territory.
• Ecological Balance: The loss of green space for a structure of this magnitude disrupts the local "stepping stone" ecology essential for urban biodiversity in Miranda.
• 2. Acoustic Impact and "Wind Tunnel" Effect
• Willock Avenue possesses a specific topography that currently acts as a natural funnel.
• Acoustic Amplification: The height of a 16-story building will create a "canyon effect," where construction noise—and eventually traffic noise—is amplified and bounced between facades.
• Work from Home & Health: With the rise of remote work, the years of high-decibel construction will cause significant mental fatigue and loss of productivity for residents. More importantly, it poses a risk to the health and sleep patterns of young children in the immediate vicinity.
• Wind Microclimate: A structure of this height will likely create significant wind shear at street level, making the sidewalk unpleasant and potentially hazardous for elderly residents.
• 3. Overshadowing and Loss of Solar Access
• The height and bulk of the proposed building will result in severe overshadowing of Willock Avenue and neighbouring properties.
• Loss of Sunlight: Sunlight is a fundamental right for residential amenity. By blocking natural light, the council is effectively cutting off a source of Vitamin D and increasing the heating costs for existing residents during winter months.
• Amenity and Value: The transition from a sunlit street to a permanently shaded corridor significantly diminishes our quality of life and negatively impacts the long-term value of our homes.
• 4. Traffic Congestion and Road Safety
• The intersection of Kiora Road and Willock Avenue is already at, or exceeding, its functional capacity.
• Existing Bottlenecks: Adding the vehicle movements associated with a 16-story high-density block will lead to "gridlock" conditions.
• Access Issues: The increased volume will make it increasingly difficult and dangerous for current residents to safely exit their driveways or turn onto Kiora Road.
• 5. Unreasonable Parking Pressure
• Parking in Miranda is already at a breaking point due to the proximity to the shopping precinct and the station.
• Deficit of Spaces: Even if the development meets the minimum "on-site" requirements, the overflow from visitors and multi-car households will spill into the street.
• Loss of Residential Access: Currently, residents often cannot find parking on their own street. This development will render street parking non-existent, unfairly penalizing those who have lived here for years.
• 6. Additional Considerations: Infrastructure Lag
• I would also like to note that the local infrastructure (sewerage, water pressure, and school placements) has not been upgraded to match such a massive increase in density. A 16-story building is a significant departure from the established character of this pocket of Miranda and sets a dangerous precedent for future "spot rezoning."
Futhermore:
1. Non-Compliance with Height and Bulk (SSLEP 2015 Clause 4.3)
The proposed 16 stories represent a gross overdevelopment of the site. It far exceeds the Height of Buildings (HOB) map limits for this precinct. This "vertical sprawl" is inconsistent with the transition between the Miranda Commercial Core and the surrounding residential streets. I understand the proposal seeks to increase the maximum height and this would destroy the character and feel of this part of the Shire and significantly effect its property value and appeal. It would also be heart breaking for those who live there.

2. Impact on Biodiversity and Urban Heat Island Effect
The loss of vegetation and the replacement of green space with a massive concrete structure will exacerbate the Urban Heat Island Effect on Willock Avenue. The displacement of local fauna (possums and nesting birds) is not just a nuisance; it is a failure to meet the biodiversity objectives of the Sutherland Shire DCP 2015, which requires developments to "respond to the unique ecology of the Shire."

3. Solar Access and Public Amenity (ADG Objective 3B-2)
The Apartment Design Guide (ADG) requires that developments do not "unreasonably" overshadow neighbors. This 16-story tower will cast a permanent winter shadow over Willock Avenue. This is not just a loss of light; it is a public health issue, removing the ability for residents to gain natural Vitamin D and reducing the thermal efficiency of existing homes.

4. Traffic and "Cumulative Impact"
The Traffic Impact Statement provided by the developer likely looks at this building in isolation. I request the Council consider the cumulative impact of all current DAs in the Miranda area. The Kiora Road/Willock Avenue junction is already a bottleneck; adding hundreds of additional daily vehicle movements will result in a total failure of the local road network.

5. Insufficient Setbacks and Wind Tunneling
The "Wind Tunnel" effect I noted previously is a direct result of inadequate side and front setbacks. A 16-story wall of glass and concrete will create downdrafts that make the street-level environment hostile for pedestrians, particularly the elderly and children.


Conclusion For the reasons of environmental preservation, human health, and urban functionality, I urge the Council to refuse this application in its current form or require a significant reduction in height and density.

As a representative of SuccessNavigator, I am writing in support of The Salvation Army’s proposed development at Kiora Road, Miranda.

Through our work across the Sutherland Shire, we see the important role the Salvos play in supporting vulnerable members of the community. A modern, purpose-built facility will strengthen their ability to deliver these services, and the housing component will provide meaningful benefits to both those in need and the wider community.

SuccessNavigator strongly supports this proposal.

I completely support the development of 2-6 Willoak Ave, Kiora Road, Miranda by the Salvation Army.
Having a functional and inviting Community facility where multiple organisations can come together to support the community can only benefit the area, and having the Salvation Army coordinating and providing services is a major boost to people in need.
The development also provides for housing, including affordable housing, which can only be a good thing in the current housing situation.
The development of community facilities and housing is also ideally located - near public transport, medical services, retail and other government and community services, plus security from the police station over the road.
I understand that this development will enable the Salvation Army to expand its social services across not just Miranda, but across the Shire, being a resource for, and linking it with its other facilites at Menai, Engadine, Heathcote and Panania.
I fully support this development application.

We have partnered with the Salvation Army for a number of years providing essential services to the local community. The good work that the Salvation Army do in the are will be significantly improved by this development and help meet the need of those they already work with and the broader community. The housing component is essential With the high cost of living in the Sutherland Shire this project is one that is essential for the local area to be able to support the community better and provide housing and essential services in an accessible location close to transport and shops. This project will ensure that more people are housed close to their support networks and keep local people local.

My wife and myself live next door to 2-6 Willock Avenue Miranda, NSW 2228 in the Wilshire Apartment complex in
8-14 Willock Avenue, Miranda, NSW 2228.
The Wilshire to Towers at the east and western boundaries Buildings A and B respectively. Each of these Buildings are 10 stories high and in addition there is Building C which faces north along Willock Avenue, Miranda and is 4 stories high.
All of these buildings are built of brick in a Faux Art Deco style and all of pedestrian foyers are decorated in a compatible style. The furnace for building B is situated on the ground floor near the entrance to the Garage next to where the proposal will sit.
In regard to the height of 16 stories of the complex, I should point out that around 6 years ago a tornado came in from the sea of at Kurnell causing windows in Buildings A and B causing a number of windows being torn and landing on patios below. This caused a lot of damage as other windows, although not drawn out but, a lot of them had to be reseated and set.
That wind was created as Wilshire currently sits.
I am currently the Chair of the Strata Committee but am making this submission as a private owner.
In my view the height of the proposal at 1 16 stories is too tall compared to the local community as a whole but your real problem is the construction type of the Wilshire (Brick) and the very risk the builder runs in damaging our home beyond repair, during construction.
The Builder has a duty of care to everyone who owns and rents in Wilshire and in the very least they should fund the residents or their Strata Committee to have Wilshire audited by qualified Building Engineer to ensure their home are protected in structure and value during construction.
This complex was built about 40 years ago and recently had to upgrade our fire system to comply the latest regulations. This work cost at least $1.5M this was the minimum cost as it was raised by levy and other amounts were utilised from bank savings.
From information available to me Buildings A and C will virtually abuts the proposed building in various degrees.
I might add that the rear of Building C gets very little sun during the summer solstice if current plans go ahead living there will hold a problem in health terms.
This whole complex, as indicated is completely of brick construction with internal walls being concrete of Besser Block Construction.
In my view the proposed new construction poses a distinct threat to the integrity of our homes in that once excavation work commences with large plant items it is inevitable tremors will be sent through the sub-strata into the foundations with the result being the brick work will vibrate and diminish the integrity of the whole complex.
In addition, this complex and our neighbouring complex have swimming pool which also could be at risk to ground movement. I might add, the fire escapes in Buildings A and B are also of brick construction.
Recent history in Sydney indicates that numerous incidents have occurred where next door buildings have suffered major damages to a degree that houses have become uninhabitable. In my view due to the construction type of Wilshire the Builder should finance the employment of a Building Engineer by the Strata Committee to identify possible problems which may cause damage to Wilshire.
There is a Duty of Care issue here which need to be identified and acted upon by the builder who I understand may well be the Certifier.

This project has the potential to cause great harm to:
- The traffic, since Kiora Road already suffers from heavy traffic in peak hours.
- Network and broadband providers.
- The aesthetic of the street (even impacting the view of multiple existing buildings)
- The power grid, since the region already suffers from occasional outages

It is a terrible idea overall and would open the way for other unsustainable projects that would do nothing but harm Miranda in the long term.

This is not how you solve the real estate crisis.

I am writing in support of The Salvation Army's proposed development at Kiora Road, Miranda. The area is in a prime location to provide the Sutherland Shire community with a central support hub.
I attended the Salvation Army's Music and Play sessions with my children over several years and saw on many occasions the support and guidance they provided to the community. A new facility will be able to support more of the community with modern and up to date housing and much needed facilities.

116 units will significantly challenge existing infrastructure in the area. Kiora is a two lane street leading up to Willock, and Willock is already a narrow street that's impacted by the police station. Also there are no traffic lights.
Traffic will be backed up constantly between Kingsway and Kiora because of increased number of cars moving to and from the new high rise complex. This is inconvenient and also dangerous. Views and sunlight will be blocked for all complexes between Kingsway and Kiora.
A high rise is not suitable, low or mid rise should be considered instead to help with housing supply. There have been plenty of developments around the area in recent years.

1. Introduction and Standing

I am the owner/resident of Unit 14/25-27 KIORA RD Miranda NSW 2228 – a unit located directly next to the proposed development site and is among the properties severely impacted by this application.

I formally OBJECT to State Significant Development Application SSD-80438964 for a 17-storey, 60-metre mixed-use tower at 2-6 Willock Avenue and 23 Kiora Road, Miranda. My objection is grounded in multiple serious planning, amenity, traffic, and urban design concerns, each addressed in detail below. This development, as proposed, represents an unconscionable imposition on the amenity, liveability, and property rights of immediately surrounding residents. It massively exceeds applicable planning controls and has not adequately assessed or mitigated its impacts on neighbouring properties, including mine.

2. Gross Non-Compliance with Existing Planning Controls

The proposal seeks amendments to both the maximum building height and floor space ratio (FSR) permissible on this site under the Sutherland Shire Local Environmental Plan 2015 (SSLEP 2015).

The scale of departure from existing controls is extraordinary and should weigh heavily against approval.

Control LEP Maximum Permitted Proposed (Excess)

Maximum Height 25 metres 60 metres (+140% above limit)

Maximum FSR 2:1 5.5:1 (+175% above limit)

Number of Storeys ~7-8 storeys (at 25m) 17 storeys (more than double)

A departure of this magnitude – requiring concurrent rezoning to even be permissible – should not be approved without demonstrable, overwhelming public benefit. No such benefit has been established. The modest affordable housing contribution of approximately 5 units (4.3% of 116) is wholly inadequate to justify the permanent and devastating impacts on surrounding residents. The surrounding residential context is characterised by 2-7 storey buildings. The proposed tower would be more than twice the height of any nearby building and would permanently alter the character and skyline of this neighbourhood in an irreversible way.

3. Devastating and Unmitigable View Loss

Adjacent units currently enjoy significant views that are central to its amenity and value. These include:

• Expansive water views

• Views of the Sydney city skyline

• Open sky and sunlight from the northern aspect

• Visual connection to the open landscape beyond the development site

The proposed 60-metre, 17-storey tower will completely and permanently obliterate all of these views. Because the tower rises to 60 metres – nearly two and a half times the 25-metre LEP limit –there is absolutely no view corridor that can be preserved. This is a total view loss, not a partial or minor impact.

Under the principles established in Tenacity Consulting v Warringah Council [2004] NSWLEC 140, the courts have identified the following factors relevant to assessing view loss by owners of units:

• The value of the view being impacted (water and city views are among the most highly valued)

• The extent of the impact (total obliteration is the most severe possible outcome)

• The nature of the view loss (from a private residence, not a public space)

• Whether the viewing opportunity was reasonable and long-standing (yes, it pre-dates this application)

Applying these principles, the view loss to dozens of adjacent units which current enjoy the panorama and increased property value represents the most serious category of impact. The applicant's Environmental Impact Statement does not adequately address this impact, and no mitigation is possible given the proposed building envelope. This ground alone warrants refusal of the application.

4. Catastrophic Loss of Solar Access and Sunlight

Many units currently receive full sunlight throughout the day. This is not merely a lifestyle amenity, it is a fundamental aspect of residential liveability recognised in NSW planning policy, including the Apartment Design Guide (ADG).

A 17-storey, 60-metre tower directly to the East of my property will cast an enormous shadow over my unit. A key impact - The Apartment Design Guide requires that at least 70% of apartments in a development receive a minimum of 2 hours direct sunlight between 9am and 3pm on the winter solstice. This standard has been designed to protect future residents, but equivalent protection must extend to existing residents.

• The loss of solar access has health, wellbeing and energy cost implications for residents of my building as well as prevent the potential installation of solar panels on our Block B and C on Willock Ave

• The winter solstice shadow diagrams, if accurately prepared, will confirm the catastrophic shadow cast by a 60-metre building on properties to the south and east

The EIS does not provide adequate shadow analysis for the neighbouring residential buildings to the south, including 25-27 Kiora Road. The applicant must be required to provide comprehensive shadow diagrams showing the impact on all existing residential buildings at 9am, 12pm and 3pm on the winter solstice, and the Department must find that the impacts are acceptable before any determination is made.

5. Severe and Unreasonable Privacy Intrusion

The proposed 17-storey building will place dozens of residential balconies and habitable room windows at direct eye level or above my unit and private balcony. The impacts are severe and unreasonable:

• Residents on upper floors of the proposed tower will have a direct, unimpeded line of sight down onto my private balcony, effectively making it unusable as a private outdoor space

• The glazed façade of the proposed building will allow residents to see directly into my unit through my own windows and balcony doors

• The building contains 116 apartments, meaning potentially hundreds of residents will have a direct view into my private living spaces

• No screening or privacy measures can adequately address direct overlooking from a building 2-3 times taller than my own

• The ADG requires a minimum 9-metre separation between windows of habitable rooms and balconies of adjacent buildings to ensure adequate privacy. The proximity of the proposed tower to 25-27 Kiora Road and the extreme height differential make compliance with this intent impossible

Privacy is a fundamental right of residential amenity. The loss of privacy described above cannot be mitigated by planting, screens or design changes – it is an inherent consequence of placing a 17-storey tower immediately adjacent to lower-scale residential buildings. This impact should be a decisive factor against approval.

6. Traffic Congestion and Parking Crisis
6.1 Existing Intersection Already at Failure
The Transport Impact Assessment (Appendix I) confirms that the Kiora Road / Willock Avenue intersection is already operating at unacceptable levels of service during peak periods:
Period Level of Service Worst Movement (Right Turn to Kiora Rd)
AM Peak (currently) Level D 55.4 sec delay; 21.9m queue
PM Peak (currently) Level F (FAILURE) >70 sec delay; 78.8m queue

Level of Service F is the worst possible rating in traffic engineering – it represents total breakdown of intersection capacity. The fact that this intersection is ALREADY at Level F during the PM peak is a fundamental reason why this development should not proceed without major intersection upgrades.

6.2 The Right Turn from Willock Avenue onto Kiora Road is Near Impossible
As a daily user of this intersection, I can confirm from personal experience what the traffic data shows: the right-hand turn from Willock Avenue onto Kiora Road during peak periods is extremely difficult and often dangerous. Vehicles must cross two lanes of high-speed traffic on Kiora Road – a major arterial road – with limited sight lines and against continuous traffic flow. During school drop-off and pick-up times, with Our Lady Star of the Sea Primary School directly opposite, the situation is already dangerous.

Adding 116 residential apartments plus a community facility to a site accessed via Willock Avenue will significantly increase the number of vehicles attempting this near-impossible manoeuvre. The Transport Impact Assessment does not propose any physical intersection improvement to address this. This is unacceptable.

6.3 School Safety – Our Lady Star of the Sea Primary School
The development site is directly across Kiora Road from Our Lady Star of the Sea Catholic Primary School. During school drop-off (8:00am-9:00am) and pick-up (3:00pm-4:00pm) periods, Kiora Road and Willock Avenue already experience severe congestion from school traffic. These are the same peak periods identified in the Traffic Assessment as experiencing the worst intersection performance.
Adding 200-300+ additional daily vehicle movements from this development, including residents departing and arriving via Willock Avenue, will materially worsen conditions around a primary school. The safety of school children crossing Kiora Road during these congested periods must be weighed against the approval of this development.
6.4 Parking Shortfall
The development proposes only 155 car parking spaces against a DCP requirement of between 166 and 398 spaces. The applicant justifies the shortfall on the basis of the site’s public transport accessibility. However:
• Miranda is a major commercial centre, and the reality is that residents of 116 apartments will own cars and need to park them – the absence of parking on-site simply transfers the problem to already-congested surrounding streets
• There is virtually no available on-street parking in the immediate area around the site – existing streets around Willock Avenue and Kiora Road are already at capacity
• Residents who cannot park on-site will park in surrounding residential streets.
Too many negative points to mention and not allowing me to continue in this space. I OBJECT