Mixed Use Development - 903-921 Bourke St Waterloo

Subject: Objection to the Proposed New Development
Dear Sir/Madam,
I am writing to formally express my strong objection to the proposed new development at this site.
As a resident living near the site, I have invested in this neighbourhood with the intention of building a stable, long-term home for my family. I value the community, its character and the sense of belonging that has developed here over many years. I am concerned that the proposed development, in its current form, would have a significant and lasting impact on the liveability, character and sustainability of the neighbourhood.
I want to make clear that my objection is not to additional housing or development in principle. I understand that Waterloo is growing and that additional housing is needed. My concern is with the scale, design, affordability and lack of demonstrated community benefit of this particular proposal.
The proposal for approximately 580 apartments, including apartments reportedly starting at close to $1 million for a one-bedroom unit, does not appear to meaningfully address the housing needs of families, essential workers, older residents or people seeking genuinely affordable and long-term housing in the area. Increasing density should also come with appropriate community benefits, infrastructure and housing diversity. In my view, this proposal has not demonstrated that balance.
My concerns are as follows:
1. Important evidence and assessment gaps
I am concerned that the contamination assessment is not yet sufficiently complete to support a development of this scale.
The proposal includes two new basements in areas where vapour risks have been identified, yet important information regarding final floor levels and the full modelling of potential contamination impacts remains outstanding. These matters should be properly resolved before any approval is considered.
I am also concerned about the wind assessment. The modelling appears to rely on the shielding effect of a neighbouring development that has not been approved. A development assessment of this scale should be based on developments that are actually approved and reasonably certain to proceed. A revised wind assessment should therefore be required.
2. Removal of important planning and community protections
The proposed development is substantially larger than the development previously approved, including a significant increase in height and apartment numbers.
Despite this increase, the applicant is seeking to remove or bypass mechanisms intended to provide independent design scrutiny and community benefit, including the competitive design process and relevant planning provisions.
For a development involving a 126-metre tower on a heritage-sensitive site, I believe independent and transparent design assessment is particularly important.
The VPA was negotiated in the context of a considerably smaller development. If the number of apartments has increased by approximately 55%, the community benefits and infrastructure contributions should be reconsidered accordingly. The community should not be expected to accept substantially more development while receiving essentially the same level of infrastructure and public benefit.
3. Affordable housing needs to result in actual homes
I am particularly concerned about the proposed 12% affordable housing contribution.
If this contribution is not secured through a binding obligation, there appears to be a possibility that the contribution could instead be provided as a financial payment, potentially resulting in no affordable housing being delivered on the site.
For a project of this size, this is a significant concern.
The local community needs actual affordable homes — including homes suitable for families, older residents and essential workers — rather than an arrangement where the affordable housing component can ultimately be replaced by a financial contribution.
Any affordable housing commitment should be clearly defined, legally secured and protected for the long term.
4. Lack of a cumulative transport assessment
I am also concerned that the transport impacts of this proposal have not been adequately considered in the context of other major developments occurring or proposed within the surrounding precinct.
The impact of one development cannot always be assessed in isolation when several large projects are adding population, traffic and pressure to the same roads and public transport network.
A proper cumulative transport assessment should be undertaken before this proposal is considered for approval.
My request
For these reasons, I respectfully ask the Department to:
• Require complete contamination investigations and vapour modelling before any approval is considered.
• Require a revised wind assessment based only on approved and reasonably committed surrounding developments.
• Retain the relevant design review requirements and require independent design assessment for a development of this scale and height.
• Retain the relevant community infrastructure contribution requirements, or secure an equivalent and legally binding contribution.
• Renegotiate the VPA to properly reflect the substantially increased apartment yield and development scale.
• Require affordable housing to be delivered as actual on-site dwellings, secured through a binding agreement and protected for the long term.
• Require a cumulative transport assessment that considers the combined impact of major developments across the precinct.
• Provide an opportunity for the community to be heard through a public hearing.
I respectfully ask that the Department consider not only the additional number of apartments being proposed, but also what kind of neighbourhood this development will create for the people who already live here and for those who will live here in the future.
Waterloo should continue to be a diverse and inclusive community where people can build long-term lives, not simply a place where increasingly expensive apartments are added without a corresponding increase in community infrastructure, affordability or public benefit.
I therefore strongly object to the proposed development in its current form and ask that the outstanding issues above be properly addressed before any approval is granted.
Yours sincerely,

Subject: Objection to the Amended Development
Dear Sir/Madam,

(I wish to thank the original creator of this objection material set out hereunder, to which I have added my comments. I fully endorse the objection material).
I am writing to firmly oppose the amended development proposal.
I live near the site and have invested in this neighbourhood with the intention of building a stable, long-term home for my partner and myself. I care deeply about the future of this area and the kind of community we leave for both current and future residents.
My objection is not to additional housing. I understand that Waterloo needs more housing as the population grows. My concern is with the type, scale and impact of the housing being proposed, and whether this development provides a fair and meaningful benefit to the existing community.
The proposal is for approximately 580 high-priced apartments, reportedly starting at nearly $1 million for a one-bedroom apartment. This does little to address the housing needs of families, essential workers, older residents or long-term residents who need housing they can realistically afford and remain in as their circumstances change.
In my view, this is increased density without a corresponding level of community benefit.
I am also concerned that this proposal represents another example of a development model where planning mechanisms appear to be used primarily to maximise the development yield and, ultimately, the developer's financial return. There is a fundamental difference between building more housing for a growing community and maximising the number and value of apartments that can be extracted from a site.
The proposed increase in height and apartment numbers, together with attempts to reduce or remove important planning and community obligations, gives the impression that the primary consideration is how much more can be built and sold, rather than what kind of place is being created.
What concerns me most is that the developer will ultimately complete construction, sell the apartments and move on, while the surrounding community will live with the consequences of the development for decades. The developer's financial interest is therefore relatively short-term, whereas the impact on residents, neighbours and the character of Waterloo is permanent.
I do not believe planning decisions should facilitate developments that maximise private gain while leaving the broader community to absorb the long-term costs.
Waterloo deserves development that creates a genuine sense of place — buildings that contribute positively to the neighbourhood, provide meaningful housing diversity and affordability, respond sensitively to their surroundings and deliver infrastructure and public benefits proportionate to their scale.
It should not become a collection of expensive, interchangeable apartments with little connection to the community around them — a soulless development created primarily as a financial product rather than as a lasting part of the neighbourhood.
My concerns fall into four key areas:
1. Critical evidence gaps
The contamination assessment remains incomplete. Two new basements are proposed in areas where vapour risks have been identified, yet final floor levels and full modelling have not been provided.
A development of this scale should not be approved until the potential contamination and vapour risks have been properly assessed and demonstrated to be safe.
I am also concerned that the wind assessment relies on shielding from a neighbouring development that has not been approved. If that development does not proceed, the assumptions underpinning the wind modelling may no longer be valid.
A revised wind assessment should therefore be required, based only on developments that are approved and reasonably certain to proceed.
2. Removal of important community protections
The proposal seeks to remove or bypass both the competitive design process and the community infrastructure levy, despite the reasons these requirements were put in place.
The proposed building is now nearly twice the height of the previously approved development, yet the applicant is seeking to rely on its own assessment of design excellence.
For a 126-metre tower on a heritage-sensitive site, I believe independent design review is essential. A development of this scale should be subject to the highest level of transparency and independent scrutiny.
The VPA was negotiated for a substantially smaller development. The community is now being asked to accept approximately 55% more apartments while receiving essentially the same infrastructure and community benefits.
That does not appear to represent a fair or reasonable exchange.
3. Affordable housing that may deliver nothing
I am particularly concerned about the so-called 12% affordable housing contribution.
As I understand the proposal, this contribution is not currently secured as a binding commitment. The applicant has also stated that it is not subject to the policy from which the 12% figure is derived.
Without a binding VPA or equivalent legal mechanism, there appears to be a possibility that the contribution could instead be paid as a financial contribution, resulting in zero affordable dwellings being delivered on the site.
That is not what this community needs.
We need actual affordable homes for families, older residents and essential workers who contribute to and sustain the local community. Financial offsets should not be treated as an equivalent substitute for delivering affordable housing within the development itself.
Any affordable housing commitment should be legally secured, delivered as actual on-site dwellings and protected in perpetuity.
4. No cumulative transport assessment
The proposal will add significant additional demand to the local transport network, yet there does not appear to be an adequate assessment of the cumulative impact of this development together with other major developments occurring or proposed within the precinct.
The transport impact of a project of this scale should not be assessed in isolation.
A cumulative transport assessment is necessary to understand the combined impact on roads, public transport, pedestrian movement and the broader infrastructure network.
I ask the Department to:
• Require complete contamination assessments and vapour modelling before any approval is considered.
• Require a revised wind assessment based only on approved developments.
• Reject the removal of Clause 6.21D and require independent design review.
• Reject the removal of Clause 6.14, or secure an equivalent legally binding community infrastructure contribution.
• Renegotiate the VPA to properly reflect the substantially increased development yield.
• Require affordable housing to be provided as actual on-site dwellings, secured through a binding agreement and protected in perpetuity.
• Require a comprehensive cumulative transport assessment.
• Hold a public hearing and provide the local community with a meaningful opportunity to be heard.
This proposal will have a long-term impact on the character, liveability and future of Waterloo.
As someone who lives near the site and has made a long-term commitment to this neighbourhood, I want to see Waterloo remain a diverse, inclusive and liveable community — one where families, essential workers, older residents and long-term residents can continue to live and belong.
The planning system should not become a mechanism through which development yield and private profit are continually increased while community protections and public benefits are progressively reduced. If the scale of the development is increased, then the obligations to the community must increase with it.
Additional housing should contribute to the strength of the community, not simply increase density and private returns while leaving the neighbourhood to deal with the long-term consequences.
I therefore strongly object to the amended development in its current form and respectfully urge the Department to require the outstanding issues above to be properly addressed before any approval is considered.

Formal Objection to SSD-95997711 - Response to Submissions Package

Dear Assessment Team,

I am writing to formally lodge my objection to the amended State Significant Development Application (SSD-95997711) for 903–921 Bourke Street and 3 McEvoy Street, Waterloo.

Having reviewed the September 2026 Response to Submissions (RtS) and the updated Architectural Design Response, I acknowledge the minor massing reductions made since the original exhibition (e.g., reducing the Young Street Tower from 38 to 34 storeys and Bourke Street North from 31 to 30 storeys). However, I maintain that the proposal’s fundamental flaw—an extraordinary and unmitigated increase in height, bulk, and density compared to the existing approved development—remains completely unresolved.

The core grounds of my objection are detailed below:

1. The Flawed Baseline: Assessment Must Compare Against the Approved Scheme (D/2021/1415), Not the Excessive Original Exhibition
The applicant’s justification relies heavily on incremental reductions from their initial, wildly overdeveloped 38-storey proposal. However, a minor reduction from an already extreme baseline does not demonstrate appropriateness. The true and relevant baseline for assessment is the existing approved scheme (D/2021/1415):

Apartment Yield: Increases from 347 to 580 apartments (+67% / +233 dwellings). 

Gross Floor Area & FSR: GFA increases from 37,268 sqm to 57,460 sqm (+54%), pushing the FSR from 2.0:1 to 3.08:1. 

Building Heights: The Young Street Tower escalates from 21 to 34 storeys, and the Bourke Street North building surges from 12 to 30 storeys. 

This is not a minor refinement; it is a complete transformation of the precinct's built form that severely departs from the competition-winning design approved under D/2021/1415.

2. DPHI’s Own Expressed Concerns Regarding Height, FSR, and Bulk Remain Unaddressed
DPHI previously raised significant concerns that the proposed height (~125m) exceeded key local uplift sites and that the FSR of ~3.2:1 resulted merely from vertically extruding existing approved floorplates rather than a rigorous urban design analysis.

Marginally trimming the FSR to 3.08:1 does nothing to address the fact that the FSR remains vastly overinflated compared to the approved 2.0:1. 

Trimming four storeys from the Young Street Tower fails to explain why a 34-storey tower paired with a 30-storey tower is an urbanistically sound response for this specific site. The building remains excessively wide and tall, creating unacceptable visual bulk. 

3. Rejection of the "Tall-Building Datum" Precedent (881–885 Bourke Street)
The proponent repeatedly cites the recently approved development at 881–885 Bourke Street (SSD-80441462) to justify establishing a 34-storey "tall-building datum". This rationale is fundamentally flawed from an urban design and planning perspective:

Different Planning Baseline: The approved scheme for 903–921 Bourke Street (D/2021/1415) was directly established through a Design Competition to ensure an appropriate scale (21/12 storeys). An approval on an adjacent site does not invalidate the design integrity or statutory weight of the approved baseline on this site. 

Unacceptable Cumulative Environmental Impact: The approval of 826 apartments at 881–885 Bourke Street has already consumed a vast proportion of the precinct's environmental, traffic, and infrastructure capacity. Adding another 34-storey and 30-storey complex directly adjacent will create an overbearing "wall of towers", compounding shadow and wind impacts on neighboring residents and public spaces. 

Failure of Urban Transition: Proper urban design requires height step-downs and transitions towards heritage items (Pump House) and lower-scale streetscapes, rather than domino-effect density matching. Density on an adjoining site should strictly constrain, rather than justify, excessive height on neighboring parcels. 

4. Cumulative Solar Access and Overshadowing Impacts
While individual shadow diagrams attempt to show incremental technical improvements, overshadowing must be evaluated cumulatively across the surrounding residential network (including Hunter St, McEvoy St, Bourke St, Sam Sing St, and Lachlan St) and key public open spaces. The massive vertical profiles of 34- and 30-storey towers continue to cause prolonged solar loss during critical mid-winter hours, diminishing the liveability and thermal efficiency of neighbouring residences.

5. Built-Form Induced Wind Microclimate Issues
The applicant’s reliance on secondary, heavy mitigation measures—such as 1.8-metre high solid glass wind screens across communal terraces (Levels 3, 4, 11, and 26–32)—is direct evidence that the fundamental massing and height generate an unfavourable microclimate. High-rise down-drafts will compromise pedestrian comfort in internal laneways and public plazas. Wind mitigation should be achieved through primary built-form reduction, not perimeter glass walls.

6. Visual Dominance Over Heritage Curtilage
The site directly encloses the heritage-listed Pump House and Valve House. While podium setbacks at Bourke Street South are noted, the overwhelming sheer verticality of the adjacent 30- and 34-storey towers creates a harsh "canyon effect". This visual dominance fundamentally alters and degrades the contextual setting and historic character of these heritage assets.

7. Architectural Expression Cannot Substitute for Urban Scale & Design Excellence
While the proponent’s efforts in landscaping, materials, and "Connecting with Country" are acknowledged, high-quality façade treatment cannot compensate for an excessively large urban form. True Design Excellence requires an appropriate urban structure, balanced skyline, reasonable street transitions, and respect for site capacity—criteria which this over-scaled massing fails to meet.

8. Disproportionate Strain on Public Infrastructure & Traffic
A 67% increase in residential density (adding 233 dwellings) without a proportionally expanded public benefit framework or Voluntary Planning Agreement (VPA) places an unreasonable burden on the community. Local traffic congestion along Bourke, McEvoy, and Lachlan Streets, along with public transport, social infrastructure, and parklands, cannot absorb this population surge alongside other major developments in the immediate area.

Conclusion & Requested Actions
While I support housing delivery within appropriate renewal precincts, additional density must be balanced against residential amenity, heritage, microclimate, and infrastructure capacity. The RTS package fails to resolve the core issue: the uplift requested is excessive and unjustifiable.

I respectfully request that DPHI:

REJECT the proposal in its current form. 

Require the proponent to reassess overall height, FSR, and massing against the approved baseline of D/2021/1415 (FSR 2:1, 21/12 storeys), rather than comparing against the original 38-storey proposal. 

Reject the argument that adjacent high-rise approvals (SSD-80441462) justify matching height on this site. 

Require a genuine reduction in tower floorplates and vertical scale to restore reasonable solar access, mitigate wind impact, protect heritage character, and deliver a human-scale streetscape for Waterloo. 


Thank you for considering my submission.

I am a resident living in close proximity to the proposed development and wish to formally object to SSD-95997711.

Whilst I support the provision of additional housing and urban renewal within the Waterloo precinct, I believe this proposal represents an excessive increase in scale and density that will have unacceptable impacts on existing residents, local infrastructure and neighbourhood amenity.

Overshadowing and Loss of Solar Access

The proposed increase in building height and bulk will result in additional overshadowing of surrounding residential buildings, streets and public open spaces.

Access to natural sunlight is a fundamental component of residential amenity and contributes significantly to residents' health and wellbeing. Existing communities in Waterloo, Zetland and Alexandria have already experienced substantial reductions in solar access due to ongoing urban renewal projects. Further increases in height should not be approved unless it can be clearly demonstrated that impacts have been minimised and are reasonable.

The cumulative overshadowing effects of multiple high-density developments within the precinct appear to have been underestimated.

Traffic Congestion and Road Network Impacts

Local roads throughout Waterloo and nearby suburbs already experience significant congestion, particularly during weekday peak periods.

The proposed increase in residential population will generate additional vehicle movements, rideshare activity, delivery services and service vehicles. This will place further pressure on intersections and road corridors that are already approaching capacity.

Residents are increasingly experiencing delays accessing local roads and arterial routes. The proposal does not appear to adequately address how these additional impacts will be mitigated.

Parking Overflow into Surrounding Streets

Parking availability within the surrounding area is already constrained.

Even where developments provide reduced parking rates on the basis of public transport accessibility, experience across the precinct demonstrates that many residents continue to own vehicles. Insufficient onsite parking can result in increased demand for surrounding public streets, creating inconvenience for existing residents and local businesses.

The Department should carefully assess whether the proposed parking provision is realistic and whether overflow parking impacts have been appropriately considered.

Pressure on Local Infrastructure and Community Services

Waterloo is undergoing one of the largest urban transformation programs in New South Wales.

The cumulative population growth resulting from this and other approved developments will place additional pressure on:

Public transport services.
Local schools.
Healthcare facilities.
Community centres.
Childcare services.
Recreational facilities.
Public open space.

Residents are entitled to confidence that supporting infrastructure will be delivered in step with population growth. It is unclear whether the long-term infrastructure capacity exists to accommodate the additional residents generated by this proposal.

Wind Impacts and Pedestrian Amenity

Increased tower heights can create adverse wind conditions around buildings and public areas.

Given the concentration of high-rise development in the Waterloo precinct, additional height and bulk may worsen pedestrian comfort at street level and reduce the usability of public spaces.

The Department should ensure wind impacts are rigorously assessed and that the proposal achieves acceptable outcomes for pedestrians, cyclists and local residents.

Heritage and Character Impacts

Waterloo contains significant industrial, cultural and community heritage that contributes to the area's identity.

The continued escalation in building scale risks diminishing the visual prominence and setting of heritage items and contributing to a loss of neighbourhood character. Future growth should respect the established urban context rather than creating an increasingly uniform high-rise environment.

Loss of Views and Residential Amenity

Many existing residents have made significant financial commitments based on the amenity of their homes and surrounding environment.

The increased building heights proposed under SSD-95997711 will likely result in further loss of outlook, sky views and visual amenity for neighbouring residents.

While private views are not necessarily protected under planning legislation, the cumulative impact of continual increases in approved building heights should be considered when assessing the broader public interest.

Cumulative Development Impacts

A key concern is that this application appears to assess impacts in isolation.

The Department should consider the cumulative effect of all approved, under-construction and proposed developments in Waterloo and surrounding precincts. The combined effect on traffic, public transport, open space, infrastructure and residential amenity is likely to be substantially greater than that identified by assessment of this proposal alone.

Conclusion

For the reasons outlined above, I respectfully request that SSD-95997711 be refused in its current form or substantially amended to:

Reduce building heights and overall bulk.
Minimise overshadowing impacts.
Improve setbacks and separation distances.
Limit pressure on local roads and parking.
Demonstrate adequate infrastructure capacity.
Better protect neighbourhood amenity and character.

The Department must ensure that growth within Waterloo is balanced, sustainable and supported by the infrastructure and services required to maintain a high quality of life for both existing and future residents.

Thank you for considering this submission.

I strongly object to this application and request it be referred to the Independent Planning Commission for independent determination rather than decided under departmental delegation.

This is the same scheme with storeys added, not a redesigned proposal. The amendments made since the first exhibition — reducing the Young Street tower from 38 to 34 storeys and adjusting the Bourke Street North tower's height — have not touched the substance of the objections raised. The footprint, site planning, non-residential floor space and communal space provision are essentially unchanged from the scheme that was already found deficient. This is height and yield engineering, not genuine amenity-led design.

The SSD pathway is being used to concentrate an out-of-proportion cluster of super-scale towers on a comparatively small site, with limited corresponding contribution to local infrastructure. This proposal, at up to 34 storeys, sits within a short stretch of Bourke Street that also includes the approved Coronation development at 881-885 Bourke Street (up to 36 storeys/~122m across 9 buildings) and is close to further high-rise approvals in the Waterloo Metro Quarter precinct (including a 26-storey tower). Each of these applications, including this one, has been assessed largely in isolation against its own site. There is no evidence in this application of any cumulative assessment of the combined demand this concentration of towers will place on transport, open space, schools or community infrastructure across the precinct — despite the site itself being relatively modest in area, and its own contribution back to that shared infrastructure remaining limited to the matters addressed below. Approving applications of this magnitude one at a time, each as a standalone "amendment," without ever assessing their combined effect on the precinct, is not a sound basis for development of this scale.

The City of Sydney's own formal submission on this application (27 April 2026) makes this point better than I can, and I endorse and rely on it. The Council — the relevant planning authority for this site — "strongly objects to the application" and finds that the density uplift (347 to 580 units, a 67% increase) "fails to provide a proportional increase in communal spaces and non-residential... floor space," that non-residential floor space is in fact reduced, and warns of cumulative density impacts across multiple sites in the precinct. The Council also finds the proposal "undermines the operation of the executed voluntary planning agreement." None of the amendments made since April 2026 address these findings.

Parking has not scaled with the development. The applicant's own Transport Impact Assessment confirms only 376 parking spaces are proposed — 68% of the maximum allowable under the Sydney LEP 2012, and only 30 more spaces than the existing 2021 consent's 346, despite a 67% increase in dwellings. The ~2,800m² of retail floor space is provided with no on-site parking whatsoever, justified only by reference to its "localised, walk-up nature." This shortfall will be absorbed by surrounding residential streets.

The pedestrian and cycle environment on Bourke Street will not cope with this scale of additional footfall. The applicant's own Transport Impact Assessment confirms that along the site frontage, Bourke Street has only an off-road shared path — pedestrians and cyclists combined — while the same document confirms a separated, dedicated cycleway exists immediately to the north (north of Phillip Street) and provides "a high quality cycleway connection through to the Sydney CBD." Adding 580 dwellings' worth of pedestrian and cyclist traffic to a substandard shared facility, without upgrading it to the separated standard already provided elsewhere on the same street, is a genuine safety and amenity deficiency that the application does not address.

The applicant's transport assumptions materially understate walking distance to public transport. The Transport Impact Assessment describes Waterloo Metro Station as "approximately 900m... within viable walking distance" — but this is a straight-line distance. The actual pedestrian route via McEvoy Street is approximately 1.3–1.4km, around 18 minutes' walk. This is not a minor discrepancy: the applicant's traffic and parking justification depends on residents readily substituting walking and metro use for car trips, and that assumption does not hold up against the real walking distance involved. This compounds the parking shortfall above, since more residents than assumed are likely to rely on the 376 on-site spaces or overflow onto local streets. I raised this specific discrepancy in my submission during the first exhibition. It does not appear as a distinct theme in the Response to Submissions' own categorised summary of issues (Table 3), and has not been substantively addressed — it has only been folded into a general "traffic and transport" theme referencing station capacity, not the accuracy of the walking-distance claim itself. This is illustrative of a broader pattern in this process, where specific, checkable concerns raised by the community are being addressed generically rather than substantively.

Transport capacity is a live, contested technical question, not a settled one. The applicant's consultant characterises the additional peak-hour trips as negligible. The City of Sydney directly disputes this, stating that public transport serving the precinct is "already at capacity." Where the applicant's own retained expert and the responsible local planning authority reach opposite conclusions on a core technical question — and where, as shown above, the underlying walking-distance assumption itself does not withstand scrutiny — this is precisely the kind of contested matter the Independent Planning Commission exists to resolve.

Contamination on the site remains unresolved, not merely historical. The applicant's own site investigation identifies soil vapour exceedances of chlorinated solvents — including PCE, TCE, cis-DCE and vinyl chloride — together with elevated hydrocarbons and zinc in groundwater, concentrated in the northern portion of the site, sufficient to require a tanked basement design with a vapour-proof membrane. An unresolved "Hold Point" remains pending further investigation to determine whether the remediation approach itself needs to be revised, and the finished floor level for the southern basement was not even available at the time the assessment was prepared, meaning a complete risk assessment for part of the site has not yet been done. Re-exhibiting a scheme with expanded basement works of this scale before contamination and vapour intrusion risk are fully resolved is premature.

Request: I ask that the application be refused in its current form, or that consent be limited to a built form and yield genuinely proportionate to the parking, transport, pedestrian/cycle safety, cumulative precinct infrastructure demand, communal space and non-residential floor space actually provided, and only once contamination and vapour intrusion risk are fully resolved. Given the City of Sydney's formal objection, the unassessed cumulative impact of concentrated tower development in this precinct, the failure to substantively address specific issues already raised in the first exhibition, and the unresolved technical disagreement between Council and the applicant, I request this matter be referred to the Independent Planning Commission for determination.

Objection to State Significant Development Application SSD-95997711
903–921 Bourke Street, Waterloo

To the NSW Department of Planning, Housing and Infrastructure,

I am a local resident of Waterloo and I am writing to formally object to the proposed amendments to the development at 903–921 Bourke Street, Waterloo (SSD-95997711).

I am not opposed to development or additional housing in Waterloo. I understand that the area is undergoing significant growth and that additional housing is required. My objection is specifically to the extraordinary increase in the scale, height and density of this particular proposal, and the impacts that this will have on existing residents and the surrounding neighbourhood.

1. The proposed increase in height is excessive

My primary concern is the enormous increase in the height of the development.

The previously approved development had a maximum height of approximately 65 metres. The amended proposal seeks to increase this to approximately 126 metres.

This is an increase of approximately 94%, effectively doubling the maximum height of the development.

At a storey level, the change is equally significant. The Bourke Street North building is proposed to increase from approximately 12 storeys to 31 storeys, while the Young Street tower is proposed to increase from approximately 21 storeys to 38 storeys.

This is not a minor change to an existing development. It fundamentally changes the scale and visual presence of the project and its relationship with the surrounding neighbourhood.

I am concerned that a development of up to 126 metres is simply out of scale with the existing and planned character of this part of Waterloo.

2. Impact on surrounding residents and residential amenity

The additional height and bulk will have a much greater visual presence for surrounding residents.

Existing residents purchased or rented their homes in an environment where the previously approved development formed part of the planning expectations for the area. Increasing the height by almost 100% materially changes those expectations.

The proposed towers will be significantly more dominant in views from surrounding apartments, streets and public spaces. This will reduce the sense of openness and outlook currently available to residents and will fundamentally alter the character of the surrounding area.

I am particularly concerned that the additional height will create impacts that cannot be reversed once the buildings are constructed.

3. Overshadowing and loss of sunlight

The increase from approximately 65 metres to 126 metres also raises serious concerns about overshadowing.

The additional height will inevitably create a substantially larger shadow envelope than the previously approved development. This has the potential to reduce access to direct sunlight for surrounding apartments, streets and public spaces, particularly during the winter months when solar access is already limited.

This impact should be assessed not simply against the existing buildings on the site, but against the previously approved development. Residents should not be expected to accept a near doubling of height without a clear demonstration that the additional impacts on surrounding properties and public areas are acceptable.

4. The increase in density needs to be considered alongside infrastructure

The proposal also increases the number of apartments from approximately 347 to approximately 580, adding around 233 dwellings.

That represents a very substantial increase in the number of people who will live on the site.

Waterloo and the surrounding Green Square area are already experiencing substantial population growth. Local roads, parking, buses, pedestrian infrastructure, parks and community facilities are all being asked to accommodate increasing numbers of residents.

The additional population generated by this proposal should therefore be assessed in the context of the cumulative development occurring throughout Waterloo and Zetland, rather than considering this site in isolation.

I am particularly concerned about the additional pressure on local roads and public transport during peak periods.

5. Parking and traffic impacts

The additional 233 apartments also raise concerns about parking, vehicle movements, deliveries, waste collection, visitor parking and general kerbside demand.

Even residents who do not own cars are affected by these issues because increased vehicle movements and competition for kerbside space affect the surrounding streets and pedestrian environment.

I believe the assessment should properly consider the cumulative impact of this development together with the other major developments already approved or proposed in the immediate area.

6. This is a fundamental change to the approved development

What concerns me most is the scale of the departure from what was originally approved.

Increasing the maximum height from approximately 65 metres to 126 metres, increasing towers from 12 to 31 storeys and 21 to 38 storeys, and increasing the number of apartments from approximately 347 to 580 fundamentally changes the nature of the development.

I question whether a change of this magnitude should be treated simply as a modification to an existing approval rather than being subjected to the level of scrutiny that would normally be expected for a substantially different development.

The community should have confidence that significant changes to the planning framework are being made for sound planning reasons and not simply because a greater development yield can be achieved on an already approved site.

7. Cumulative impact and precedent

I am also concerned about the precedent this proposal would establish.

If a development that was planned and approved at approximately 65 metres can subsequently be increased to 126 metres, this raises legitimate questions about the effectiveness of the existing planning framework and the expectations that existing residents can reasonably have about future development.

Waterloo is already undergoing enormous change. Further increases in building height and density should be considered as part of a coherent precinct-wide planning strategy rather than through substantial site-specific increases.

Conclusion

I respectfully request that the Department carefully reconsider the proposed amendments to SSD-95997711.

I support appropriate housing growth and renewal in Waterloo, but I do not believe that this requires an almost doubling of the approved maximum building height or such a substantial increase in density on this particular site.

The proposed increase from approximately 65 metres to 126 metres, together with the increase from approximately 347 to 580 apartments, represents a fundamental change to the development and has significant potential consequences for surrounding residents, sunlight access, visual amenity, traffic, parking, public transport and local infrastructure.

I therefore object to the proposal in its current form and request that the proposed increase in height and density not be approved.

At a minimum, I request that any increase in scale be substantially reduced and that the Department require a comprehensive assessment of the cumulative impacts on surrounding residents and infrastructure before any decision is made.

Thank you for considering my submission.

Yours sincerely,
Chris
Local resident, Waterloo

Objection to SSD 95997711 – 903–921 Bourke Street, Waterloo

I object to the amended State Significant Development application for 903–921 Bourke Street, Waterloo.

While I recognise the need for additional housing in Sydney, Waterloo is already accommodating an exceptionally high level of residential development and population growth. Further substantial increases in density should not be considered in isolation from their cumulative impact on existing residents and the infrastructure and amenity of the surrounding area.

My principal concern is that development in Waterloo is continuing at a pace that is not being matched by improvements to transport infrastructure, road capacity, public open space and community infrastructure. The result is a progressive deterioration in the living environment for existing residents.

Traffic and road congestion

Bourke Street and the surrounding road network already experience substantial traffic pressure. Waterloo has undergone major residential intensification, with numerous large developments completed, under construction or proposed. Each additional development adds vehicles, deliveries, service traffic, rideshare movements and construction activity to a road network with finite capacity.

The assessment of this proposal should therefore consider cumulative traffic impacts rather than simply the incremental traffic generated by this development in isolation. The relevant question is not whether one development can theoretically be accommodated, but whether the collective scale of development being approved across Waterloo can be accommodated without materially worsening congestion, road safety and residential amenity.

Insufficient public transport

The level of density being permitted in Waterloo is not supported by a corresponding level of convenient public transport across the suburb. While Waterloo Metro has improved public transport access for parts of the area, it does not eliminate the need for adequate bus services or address the distance many residents must travel to reach high capacity public transport.

Increasing residential density without ensuring that residents have genuinely convenient alternatives to private vehicles inevitably increases pressure on local roads and parking. Further density should be linked to demonstrated improvements in public transport capacity and accessibility.

Lack of public open space

Waterloo already has limited public open space relative to its rapidly increasing population. Large apartment developments introduce hundreds or thousands of additional residents who depend heavily on public parks, streets and community spaces because they generally have little private outdoor space.

Increasing residential density without delivering substantial additional public open space means that existing parks and recreational areas must serve an ever increasing population. Providing communal space within an individual development is not an adequate substitute for genuine, publicly accessible green and recreational space.

The Department should consider the amount of usable public open space available per resident across Waterloo and how that ratio has changed, and will continue to change, as already approved and proposed developments are completed.

Cumulative impact on residential amenity

Existing residents should not be treated as though the amenity of the area at the time they chose to live in Waterloo is irrelevant simply because further development is possible.

Increasing building bulk and population density has cumulative consequences including increased traffic, noise, construction disruption, pressure on parking, reduced privacy, increased overshadowing, greater demand on local services and infrastructure, and greater competition for limited public open space.

Individually, each development may be assessed as having an acceptable impact. Collectively, however, the effect can be a significant reduction in residential amenity and quality of life. This cumulative effect needs to be given substantially greater weight in the assessment process.

Scale of development occurring across Waterloo

Waterloo is already making a very substantial contribution to Sydney’s housing supply. Major redevelopment is occurring throughout the suburb, including significant additional density associated with Waterloo Metro and the redevelopment of the Waterloo estate, together with numerous private developments.

There must be a point at which additional density produces diminishing benefits because the infrastructure and physical environment cannot support the resulting population without compromising living standards.

Housing targets should not become a justification for repeatedly increasing density in suburbs that are already undergoing extraordinary population growth. Development needs to be accompanied by proportional investment in transport, roads, open space, community facilities and other infrastructure.

The amended proposal

I acknowledge that the amended proposal includes reductions in the height of the towers. That is preferable to the original proposal, but it does not resolve the broader concerns associated with the development. The fundamental issue remains the cumulative addition of a substantial residential population to an area already experiencing intense development.

The Department should not assess the reduction in height merely against the previous proposal. It should assess whether the resulting development is appropriate for Waterloo when considered alongside existing development, projects already approved, projects under construction and other major planned developments.

Conclusion

I therefore object to SSD 95997711 in its current form.

I request that the Department undertake a genuine cumulative assessment of development across Waterloo, particularly in relation to traffic and road capacity, public transport accessibility, public open space per resident, community infrastructure and the overall effect on residential amenity.

If the Department is nevertheless minded to approve the application, the development should be further reduced in scale and any approval should include meaningful measures to mitigate its cumulative impacts and contribute to additional infrastructure and public open space for the Waterloo community.

Waterloo can and should accommodate additional housing, but there must be a reasonable balance between increasing housing supply and maintaining a liveable neighbourhood for the people who already live here. Continually increasing density without corresponding infrastructure and open space ultimately reduces the quality of life that good urban planning is supposed to protect.

I am a resident of Danks Street in Waterloo, and I am writing to formally lodge my objection to the current proposal for 903 Bourke Street.
While I accept the necessity of urban density in this part of Sydney, the scale and form of the new proposal represents an overdevelopment of the site that will adversely impact public transport, recreational facilities, and road congestion.
1. Disproportionate height and negative visual impact
The plan is grossly out of scale with the surrounding precinct. Most contemporary developments in this immediate area range from 4 to 13 storeys, meaning the proposed structure would be more than double the height of its neighbours. A tower of this magnitude is well suited to a primary transport hub, but it is fundamentally inappropriate for a mid-block location on Bourke Street.
2. Significant pressure on public transport
The Waterloo Metro requires a walk up a hill - not great in Summer or the rain, and not adequately lit at night.
Green Square station there is a 20 min walk - hot in summer with little shade on the route
On Bourke Street, the 304, 320 and 392 bus routes are at capacity during commuter hours. Cyclists - those riding to work or parents cycling their kids to Bourke Street Primary School - are forced onto footpaths, clashing with groups of commuters waiting at bus stops.
On Cleveland Street, bus route 352 to Bondi Junction is also at capacity at peak hour.
And the nearest buses to get to the beaches - bus 374 to Coogee and Bus 333 to Bondi Beach - are at capacity.
The introduction of approximately 580 new dwellings (in addition to the other development proposals along Bourke Street) will lead to a surge in demand that the current transport network cannot sustain without confirmed and significant upgrades to service frequency.
4. Worsening traffic and safety concerns
The local road network, particularly key intersections at Lachlan, Danks, and McEvoy Streets, is congested. We are seeing more motorists and motorcyclists using residential side streets as shortcuts. The provided Traffic Impact Assessment appears to overlook the cumulative effect of this project when combined with other major works nearby which will collectively overwhelm local road capacity.
5. Deficiency in local social infrastructure
Our local community facilities are struggling to cope with the existing population. There are only two pools in the area, tennis courts and other sporting facilities are at capacity. This proposal adds a significant volume of new residents without offering any tangible contributions toward the social infrastructure required to support a healthy and functional community.
6. Limitations of proposed public space
This space will be shadowed for much of the winter and offers very little in the way of utility. Without dedicated play areas or versatile green space, it cannot meet the recreational requirements of all the new households along Bourke Street, let alone provide a meaningful amenity for the broader Waterloo community.
7. Increased competition for street parking
The scarcity of on-street parking is a major point of friction in this precinct. A residential project of this density will inevitably lead to increased competition for the few available spots, as visitor and overflow parking will wash into the surrounding streets. This will negatively impact the quality of life for long-term residents and limit accessibility for those wishing to patronize local businesses on Danks and Bourke Streets.
Requested outcome
I urge the Department to refuse this application or insist on fundamental changes to the scheme. Specifically, I request a substantial reduction in the maximum building height to align with the surrounding built environment and a transparent, updated solar access review. Furthermore, any approved works must be subject to a strict and enforceable Construction Management Plan. I wish to clarify that I do not oppose the principle of developing this site; however, I strongly oppose the current scale and form of the proposal, which sits outside the reasonable limits of the current planning framework.

Thank you for considering my submission.

Yours sincerely,

Elizabeth Warner
Danks Street, Waterloo NSW

Attn: Chris Eldred, Key Sites Assessments Department of Planning, Housing and Infrastructure GPO Box 39, Sydney NSW 2001

Application: SSD-95997711 Project: 903–921 Bourke Street, Waterloo Submission: Objection

I live at 5 Sam Sing Street, Waterloo, and I object to the proposed amendments.

I support more housing in Waterloo. I do not support nearly doubling the approved height from 65 metres to 126 metres, lifting the floor space ratio from 1.5:1 to 3.2:1, and increasing the yield to about 580 apartments. That is a different project from the one already approved, and it should not be treated as a modification.

The streets around this site are narrow, mostly one lane and one way, and they already carry steady traffic. Extra apartments will add cars, rideshare, deliveries, and service vehicles to roads that were not built for a precinct of towers. About 20 extra parking spaces will not absorb those trips.

The closest metro and train stations are about a 20-minute walk. Most new residents will use the Bourke Street buses, which already arrive full in the morning and skip stops. A general promise of future services is not a committed upgrade. This increase should not be approved until the buses can actually carry the extra passengers, assessed together with the other large projects nearby.

A tower of this height will stand beside much smaller buildings and will dominate the street. The jump from the approved envelope will block outlook, reduce winter sun, and worsen wind at street level. It is not a reasonable transition to the existing neighbourhood.

Residents relied on the approved height, density, and planning controls. Setting aside the competitive design process and community infrastructure contributions, while offering the same public benefits for a much larger building, is not a fair exchange. Schools, parks, and other local amenities are already under strain. This application adds population without showing how those services will grow with it.

I ask the Department to refuse the application in its current form. If it is considered further, please keep the approved height and density unless the streets, buses, and amenities are shown to cope; require design review and infrastructure contributions scaled to the extra dwellings; and require a cumulative traffic and transport assessment before any increase is approved.

Yours sincerely, Andrzej Gawron 5 Sam Sing Street, Waterloo NSW 2017

I am writing to maintain my objection to the amended proposal for this site.
I appreciate that the developer has made some changes since the original proposal was exhibited, including reducing the Young Street tower from 38 storeys to 34 storeys. However, I still believe the development is far too large compared with what was originally approved.
For me, the key comparison is not 38 storeys versus 34 storeys. The important comparison is that the Young Street tower was originally approved at 21 storeys and is now proposed at 34 storeys. That is still an additional 13 storeys.
The same issue applies to the overall development. The approved scheme had 347 apartments, while the current proposal still has 580 apartments — an increase of 233 apartments. Even after the changes, the overall size and density of the project remain significantly greater than what was originally approved.
That is why I find it difficult to see this as simply an amendment to the existing development. In practical terms, it feels like a major intensification of the site.
I am also concerned that the proposal requires substantial changes to the existing planning controls in order to allow this additional height and density. In my view, if a development needs the planning controls to be changed so significantly to accommodate it, there should be a very strong case for why that extra height and density are appropriate for this particular site.
I do not think that case has been made.
It is also worth noting that concerns about the height and bulk of the towers were not only raised by local residents. The Department itself raised concerns about the height, FSR, visual bulk and overall design of the proposal. In particular, concerns were raised about the Young Street tower being too tall and wide, the relationship between the tower and surrounding buildings, and the impact of the additional bulk.
The developer has responded by reducing the tower by four storeys and making some other design changes, but I do not believe those changes go far enough.
There are also ongoing concerns around overshadowing, wind, privacy, traffic, pressure on local infrastructure and the impact on the character of the area. I acknowledge that the developer has carried out further technical studies and made some improvements in these areas, but improving some of the impacts does not necessarily mean that the additional scale of the development is appropriate in the first place.
I am particularly concerned that the additional height and density appear to have largely been retained despite the objections. The number of apartments remains at 580, and the development is still substantially larger than the approved scheme.
I also think the level of community opposition should be taken seriously. The overwhelming majority of public submissions were objections. While I understand that planning decisions are not made simply by counting submissions, the scale of the opposition shows that these concerns are widely shared and are not just the views of a small number of neighbours.
I am not opposed to development or to additional housing in Waterloo. This site already has approval for a substantial development, and I accept that the area will continue to grow.
My objection is to the extent of the additional uplift now being proposed.
In my view, changing the Young Street tower from an approved 21 storeys to 34 storeys, while increasing the development from 347 to 580 apartments, is too significant a change.
The reduction from 38 to 34 storeys is a step in the right direction, but it does not address the main concern.
I therefore ask that the proposed height of the Young Street tower and the overall scale and density of the development be reduced further, with much greater regard given to the development that was originally approved and to the impact on the surrounding community.
For those reasons, I continue to object to the amended proposal.

I am writing to object to the proposed modification application SSD-95997711 for 903-921 Bourke Street, Waterloo. As a resident of 1 Danks Street, I have significant concerns regarding the scale of the proposed increase in density, the cumulative impact of development across the Waterloo precinct, and the continued failure to deliver the infrastructure necessary to support the population growth already approved. The application seeks to increase the approved development from 376 apartments to approximately 580 apartments, representing a substantial increase in residential density on the site.

My primary concern is that this proposal comes shortly after approval was granted for the existing scheme and appears to be another attempt to increase the development yield of a project that has already undergone extensive assessment and community consultation. Many residents previously raised concerns regarding height, density, traffic, infrastructure capacity and neighbourhood amenity. It is therefore disappointing that Dasco Property Development Services Pty Ltd is now seeking approval for a further 250 apartments. This approach creates a perception that the approved scheme was not the final outcome intended by the developer, but rather a stepping stone toward securing a significantly larger project. Such an approach undermines community confidence in the planning process and devalues the time and effort residents have invested in previous consultation processes.

Equally concerning is the ongoing lack of investment in supporting infrastructure. Waterloo and Green Square continue to absorb thousands of additional residents, yet there appears to be little accountability from Dasco Property Development Services Pty Ltd, Sydney Water, the City of Sydney or the NSW Government for delivering the infrastructure required to support this growth. Existing residents are repeatedly told that infrastructure issues are being considered, but there is little visible evidence that key concerns such as stormwater drainage, local road capacity, public open space, community facilities and utility infrastructure are keeping pace with the rate of development.

Stormwater infrastructure is a particular concern. Residents have observed ongoing drainage issues throughout the precinct, yet major residential developments continue to be approved with increasing density. It is difficult to understand how further population growth can be justified when there is no clear commitment to upgrading the infrastructure needed to service existing residents, let alone thousands of additional occupants. The burden of growth cannot continue to fall on the community while responsibility for infrastructure delivery is effectively passed between developers, government agencies and utility providers.

This application must also be assessed in the context of the significant development occurring across Waterloo. The Department should not consider SSD-95997711 in isolation. The cumulative impacts of this proposal, combined with the proposed Coronation Property Build-to-Rent development in Waterloo and the recently lodged application for 923-935 Bourke Street (D/2024/1208), which proposes a building of approximately 35 storeys, will fundamentally change the scale and character of the area. Together, these developments will introduce thousands of additional residents into an already densely populated precinct.

The planning assessment should therefore consider the combined pressure that these projects will place on public transport, roads, drainage infrastructure, parks, community facilities and local services. While individual developments may each claim their impacts are acceptable, residents experience the cumulative effect of all developments combined. It is this cumulative impact that is increasingly being overlooked in planning assessments.

Waterloo has already made a substantial contribution to Sydney's housing supply and will continue to do so. However, housing growth should not come at the expense of liveability. There comes a point where continued increases in density begin to erode the very qualities that make a community desirable to live in. The concentration of high-density developments throughout Waterloo risks creating an overcrowded and under-serviced neighbourhood where infrastructure, public amenity and open space lag well behind population growth.

For these reasons, I respectfully request that the Department refuse the proposed modification application SSD-95997711. At a minimum, the Department should require a comprehensive cumulative impact assessment that considers this proposal alongside the Coronation Property development, D/2024/1208 at 923-935 Bourke Street, and other approved developments in the Waterloo and Green Square precincts. The Department should also require clear and enforceable commitments for upgrades to stormwater infrastructure, drainage systems, public open space and community facilities before any further increase in residential density is approved.

Waterloo residents deserve confidence that growth is being managed responsibly and that the infrastructure required to support existing and future communities will be delivered. In its current form, this proposal fails to provide that confidence and should not be approved.

I strongly object to the proposed changes to the development at 903–921 Bourke Street, Waterloo.

I have reviewed the response to submissions and the additional information provided. The response does not adequately address the concerns raised during the first public exhibition about the scale and density of the proposed development and its impact on the surrounding area. In particular, it does not address the fundamental concern that the proposal represents a very substantial increase over the development that was previously approved.

I understand that Waterloo is changing and that more housing is needed. My objection is to the scale of the increase proposed for this particular site and the resulting impact on existing residents and the surrounding area. Having considered the response to submissions, I continue to strongly object to the proposed changes.

Scale and density

The biggest issue remains the scale of the proposed increase. The approved development has 376 apartments, while the proposed changes would increase this to 580 – an additional 204 apartments, or around 54% more.

The response points to changes to the design and reductions in some building heights. However, these changes do not alter the fundamental scale of the proposal or the fact that it is substantially larger than what was approved.

I support the Government’s objective of increasing affordable housing. However, only 22 of the 204 additional apartments are identified as affordable housing. This should not be used to justify the overall increase in the scale and density of the development. The response does not adequately demonstrate why this level of increase is appropriate for the site or how the resulting impacts on existing residents and the surrounding area will be managed.

The fact that the surrounding area is undergoing redevelopment does not, by itself, justify such a substantial increase on this site.

Public transport and traffic

The response places considerable emphasis on the small increase in vehicle movements compared with the approved development, describing this as negligible.

This does not adequately reflect the overall transport impact of adding a substantially larger number of apartments.

The approved development provides 346 car spaces, compared with 376 under the proposal. This is a relatively small increase in parking compared with the substantial increase in apartments, meaning many of the additional residents will rely on public transport.

The assessment itself forecasts significant additional demand for train, metro and bus services. The response points to nearby public transport as evidence that this demand can be accommodated, but simply having services nearby does not demonstrate that there is sufficient capacity to accommodate the additional demand, particularly when other major development in the area is taken into account.

The response therefore focuses too narrowly on additional car movements and does not adequately address the broader transport impact of the proposed increase.

Cumulative impact

I am also concerned about the combined effect of this development with the other major developments taking place in Waterloo and Zetland.

The response states that cumulative impacts have been considered and concludes that they are acceptable. However, it does not adequately demonstrate how the combined increase in population and demand will affect the area as a whole.

The additional residents will place further demand on public transport, public open space, local services and community infrastructure. The response states that existing social infrastructure has sufficient capacity, but this does not adequately address the cumulative effect of this proposal together with the significant amount of other development occurring nearby.

There are also cumulative concerns around visual bulk, overshadowing, wind, noise and the general experience of living in an area undergoing rapid and substantial redevelopment. These impacts should be considered together, rather than primarily assessing whether each individual impact can be managed in isolation.

Impact on existing residents

I am particularly concerned about the very significant visual and amenity impact the proposed development will have on people who already live around the site.

There are no existing buildings immediately surrounding the site that are comparable in height to the proposed development. The proposal would therefore introduce a substantially greater building height and visual presence into the immediate area, with a significant change to the outlook of neighbouring apartments.

For residents whose apartments currently have open views towards the city and surrounding greenery, the proposed buildings would result in the loss or substantial obstruction of those views. This is not simply a change to what can be seen from the street; it would directly affect the outlook and amenity that residents experience from their homes every day.

The response itself acknowledges concerns about outlook loss and overbearing scale, but largely responds by referring to building separation distances and visual privacy. This does not adequately address the separate issue of the loss of outlook and the visual dominance of a development of this scale. Meeting separation distances may address privacy, but it does not mean that the loss of views or overbearing visual impact is acceptable.

The visual material provided also does not adequately demonstrate the impact on residents living closest to the site. The photomontages are largely taken from street level or locations further away and do not show the experience from the balconies and windows of nearby apartments, where the loss of views and increased visual presence would actually be experienced.

The loss of established city and greenery views and the introduction of substantially larger buildings would represent a significant reduction in residential amenity for affected properties and may also affect their value.

For a development of this height and scale, the impact on the existing outlook of nearby residents should be properly demonstrated and considered. The response does not adequately address this concern.

Sunlight and overshadowing

The response states that changes to the design have reduced overshadowing compared with the earlier proposal. While this may reduce the impact, it does not mean that the resulting impact is acceptable.

The proposal remains substantially larger than the approved development, with increased height and density resulting in more built form and additional shadow.

I remain concerned about the effect on surrounding homes and public areas, particularly during winter, and about the combined effect with other development in the area. The response does not adequately address these concerns.

Public benefits and local infrastructure

Adding 204 apartments will result in a substantial increase in the number of people living on the site.

The response states that the proposed public benefits and infrastructure arrangements meet the relevant requirements. However, this does not address whether they are sufficient or proportionate to such a substantial increase in the size of the development.

The additional residents will place further demand on public transport, public spaces and local services. The response does not adequately demonstrate that the public benefits and infrastructure arrangements have been appropriately recalibrated to reflect the additional scale of the proposal.

Construction impacts

I am also concerned about the practical impact of construction on people living nearby.

The response says that construction impacts can be managed through the existing conditions of consent. This does not adequately address the likely experience for residents of a much larger development, including construction noise, dust, heavy vehicles, deliveries, traffic disruption and impacts on pedestrians.

A development of this size is likely to involve a significant and prolonged construction period. These impacts should be properly considered rather than simply relying on existing conditions.

Conclusion

The response to submissions does not resolve the concerns raised during the first public exhibition.

The proposed development is substantially larger than the approved scheme. The response places considerable emphasis on changes to the building design and the relatively small increase in vehicle movements, but this does not adequately address the much larger increase in population, public transport demand, built form and impact on existing residents.

I remain concerned about:
- the overall size and density of the proposed development;
- the additional demand on public transport;
- the cumulative impact of this development with other development in the area;
- the loss of established city and greenery views and the resulting impact on residential amenity;
- the increased visual dominance and scale experienced by existing residents;
- additional overshadowing and loss of sunlight; and
- the scale and duration of construction impacts.

The response to submissions does not adequately address these concerns. I therefore continue to strongly object to the proposed changes at 903–921 Bourke Street and ask that the proposal not be approved in its current form.

I live on Danks Street, Waterloo, and I object to this modification. The proposal would lift the approved yield from 376 to around 580 apartments, an increase of more than 50% on a scheme that was assessed and approved only recently. I ask the Department to refuse the application for the reasons below.

1. The modification undermines the original approval
The current approval was the result of a lengthy assessment in which the community raised detailed concerns about height, density, traffic and amenity. Returning so soon with a request for roughly 200 additional dwellings suggests the approved scheme was treated as a starting point rather than a settled outcome. If approvals can be expanded this substantially through modification, the value of public consultation is diminished, and residents have little reason to trust that what is approved is what will be built.

This pattern is already established in Waterloo. The nearby Coronation Property development was recently approved with a similarly large increase in apartment numbers, despite strong and well-documented community opposition. Residents' objections appear to have had little bearing on that decision. Approving this modification on the same basis would reinforce the view that community input has no real influence on outcomes in this precinct.

2. Infrastructure has not kept pace with approved growth
Waterloo and Green Square have already absorbed a large population increase. Residents have yet to see corresponding upgrades to stormwater, local roads, open space, community facilities or utilities. Responsibility for this shortfall appears to shift between the developer, Sydney Water, the City of Sydney and the NSW Government, with no party clearly accountable for delivery.

Stormwater is of particular concern. Drainage problems are already evident across the precinct. I do not see how a further increase in density can be supported without a firm commitment to upgrade the drainage network that serves existing residents.

3. Cumulative impacts must be assessed
This application should not be considered on its own. It sits alongside the recently approved Coronation Property build-to-rent development and the recently lodged D/2024/1208 at 923–935 Bourke Street, which seeks a tower of approximately 35 storeys. Together these projects would add thousands of residents to a precinct that is already dense.

Each application may present its own impacts as acceptable, but residents live with the combined effect on public transport, roads, drainage, parks and local services. Assessments that look at sites individually consistently understate that combined effect.

4. Liveability
Waterloo has contributed significantly to Sydney's housing supply and will continue to do so. That contribution should not come at the cost of a neighbourhood where open space, services and infrastructure fall further behind each year. Beyond a certain point, additional density erodes the qualities that make the area worth living in.


I request that the Department refuse this application. If the Department is not minded to refuse it, I ask that it:
• require a comprehensive cumulative impact assessment covering this proposal, the Coronation Property development, D/2024/1208 and other approved projects across Waterloo and Green Square
• secure clear, enforceable commitments to upgrade stormwater and drainage infrastructure, public open space and community facilities before any increase in density is approved.

Residents need confidence that growth in Waterloo is being planned and serviced responsibly. This modification does not provide that confidence.

I am submitting this response to the proposed modifications to object to the development at 903-921 Bourke Street, Waterloo (SSD-95997711).

The continued variations especially in height, (from 12 to 31 storeys on Bourke Street North and from 21 to 38 storeys on the Young Street Tower), vary from the concept originally approved by the City of Sydney. These are not minor amendments. They fundamentally change the character, scale, and impact of what was agreed with the community.


Infrastructure and transport.
The area's infrastructure is already at capacity. The 304 and 343 buses regularly run full through Waterloo during peak hours . Bourke Street and Lachlan Street are both already exceedingly busy at during weekday rush hour, Saturday traffic also results in heavy congestion in local streets especially off Lachlan Street. Adding hundreds of new residents without meaningful transport and road infrastructure investment is wrong.

Built environment.
The proposed towers are between five and ten times the height of existing local apartment buildings, and will be amongst the most tallest in the Waterloo/Mascot/Zetland corridor. The visual impact, compounded by other proposals in the area, would be severe and permanent, creating a development completely out of character with the surrounding streetscape.

Sun and Shadows.
The cumulative overshadowing impact of this proposal, together with the adjacent Coronation development at 881-885 Bourke Street, would affect a large area of nearby homes and public open space, particularly during winter months.

The cumulative effect of this and other approved developments already represents an estimated 4,000 new apartments and up to 8,000 new residents in this precinct. That is an extraordinary concentration of density. This proposal adds to that burden with only 20 additional parking spaces, which is inadequate and frankly insulting to existing residents.

Amenity and liveability.
The City of Sydney has tried to balance green space, public amenities and community spaces in the area however proposed developments such as this by pass requirements that provide benefits for the community for the longer term.

There is also a serious process concern here. This proposal follows a pattern where a developer secures initial approval through community consultation, delays construction long enough to sell the approved apartments, and then applies to nearly double the height of the development, leaving residents minimal time to respond and offering nothing in return by way of additional infrastructure or amenity. That is a pattern the NSW Government should refuse to reward.

These developments are not addressing housing affordability. A two-bedroom apartment at the nearby Dank Street District starts at $1,450,000. Developments such as these are being pushed through in defiance of existing planning approvals.

Sydney's appeal is inseparable from its character, its neighbourhoods, its streetscapes and its liveability. That is not a small thing to sacrifice. Once it is gone, it does not come back. Towers of this scale are not a housing solution for ordinary Sydneysiders. They are a windfall for developers, dressed up as progress.

I strongly urge the NSW Government to decline this modification and uphold the planning controls agreed through proper community process.

To the Assessment Team,
I write to object to the proposed modifications under SSD-95997711 for the development at 903-921 Bourke Street, Waterloo.
Having reviewed the updated proposal and accompanying documentation, I remain concerned that the modifications fail to adequately address the issues raised by residents during previous consultation and assessment phases. While the applicant presents the amendments as refinement of the approved scheme, the proposal continues to seek increased building heights, additional residential yield and greater development intensity without a commensurate increase in public benefits, infrastructure capacity or protection of residential amenity.
In my view, the revised proposal does not sufficiently respond to the concerns previously raised by the community and should not be approved in its current form.
1. Failure to Address Previous Public Submissions
A significant number of residents previously raised concerns regarding excessive building height, density, overshadowing, traffic impacts and pressure on local infrastructure.
Rather than addressing these concerns, the current modification application appears to further intensify the development outcome. The proposal continues to prioritise increased residential yield and commercial returns while offering little evidence that the resulting impacts on existing residents have been reduced or mitigated.
The Department should carefully consider whether the modified proposal genuinely improves the development outcome or simply increases development capacity beyond what was originally contemplated.
2. Excessive Building Height and Density
The proposal remains excessive in height and scale compared with the surrounding urban context and exceeds what many residents reasonably understood would be delivered through the original planning framework.
The cumulative effect of taller buildings, increased floor space and additional apartments results in a more intensive urban form that fundamentally changes the character of the precinct.
While Waterloo is expected to accommodate growth, growth must occur in a manner that balances density with livability. The proposal places increasing pressure on the site without demonstrating corresponding improvements to open space, community facilities or public infrastructure.
3. Increased Population Without Matching Infrastructure
The proposal would introduce a substantial number of additional residents into an area that is already experiencing pressure on transport networks, roads, schools, childcare facilities, health services and public open space.
Local roads including Bourke Street, Elizabeth Street, Botany Road and McEvoy Street already experience significant congestion during peak periods. The proposal provides insufficient evidence that the surrounding infrastructure can comfortably accommodate the additional demand generated by the proposed increase in dwelling numbers.
If additional population is to be accommodated, meaningful infrastructure upgrades should be delivered concurrently. The current proposal does not demonstrate such a commitment.
4. Ongoing Overshadowing and Loss of Amenity
Despite revisions to the scheme, concerns remain regarding overshadowing and the loss of sunlight to neighbouring residential properties and public spaces.
The importance of solar access is well established in planning policy because of its direct impact on health, comfort, energy efficiency and quality of life. Residents should not bear a reduction in amenity merely to facilitate additional private development yield.
Particular attention should be given to the cumulative impacts of the increased building envelopes on adjacent dwellings, communal open spaces and future public domain areas.
5. Wind, Public Domain and Human-Scale Design
The increased bulk and height of the buildings risk creating a less comfortable pedestrian environment through increased wind impacts and reduced sunlight at street level.
A successful urban renewal project should prioritise the quality of public spaces and pedestrian experience. Instead, the proposed modifications risk creating an increasingly dense built environment where public spaces become overshadowed, wind affected and less inviting for residents and visitors.
The modifications appear inconsistent with the objective of creating a human-scale neighbourhood that promotes community interaction and high quality public domain outcomes.
6. Departure from the Original Planning Vision
The original planning proposal sought to balance housing delivery with amenity, sustainability and community benefit.
The current modifications represent a gradual departure from that balance. The repeated increase in height and density through successive amendments risks undermining community confidence in the planning process and the expectations established through earlier consultation.
Residents who engaged in good faith with previous consultation processes should be able to rely on the key planning parameters that were originally presented and assessed.
Requested Outcome
For the reasons outlined above, I respectfully request that the Department:
- Refuse the proposed height increases and additional density sought through SSD-95997711.
- Retain the previously proposed maximum building heights and development controls.
- Require any future amendments to demonstrate a genuine improvement in community outcomes rather than an increase in development yield.
- Prioritise residential amenity, solar access, public domain quality and infrastructure capacity in the assessment of the proposal.
The Waterloo community deserves development that is balanced, sustainable and respectful of the people who already live in the area. In its current form, the proposal fails to achieve that balance and does not adequately address concerns previously raised by residents.
Thank you for your consideration of this submission.

I object to SSD-95997711 for the proposed redevelopment of 903–921 Bourke Street, Waterloo.
I am not opposed to new housing or appropriate increases in density. My objection is to the scale of this proposal and the impact that such a substantial increase in height and population will have on Waterloo.
The proposal would add more than 200 apartments to an already approved development and substantially increase the height of key buildings, including Bourke Street North from 12 to 31 storeys and the Young Street tower from 21 to 38 storeys.
These are not minor changes. They fundamentally increase the scale and intensity of the development.

1. The proposed height is excessive
Increasing Bourke Street North from 12 to 31 storeys and the Young Street tower from 21 to 38 storeys is a major departure from both the approved development and the predominantly lower and mid-rise character of the surrounding area.
I am particularly concerned about what approving buildings of this scale means for the future development of Waterloo.
I understand that one approval does not automatically allow future developments to reach the same height. However, once buildings of 31 and 38 storeys become part of the local built environment, they inevitably change the context against which future proposals are considered.
There is a real risk of substantial height increases gradually becoming normalised, with each new proposal pointing to previously approved towers as justification for going as high or higher.

2. The cumulative density is becoming too great
Waterloo and Zetland have already experienced enormous residential growth.
Adding 200+ more apartments to this development means hundreds of additional residents using the same streets, public transport, parks, footpaths, services and community facilities.
This proposal also cannot reasonably be assessed in isolation. Other major residential developments are already approved, proposed or under construction nearby.
What matters to residents is the cumulative effect of all this development.
There is a point at which increasing density begins to reduce rather than improve liveability, particularly when supporting infrastructure and public space do not increase at the same rate. My concern is that Waterloo is approaching that point.
The cumulative result is a neighbourhood that becomes increasingly busy, congested and dominated by large buildings.

3. Taller and denser development will affect street-level amenity
Buildings of this scale have effects well beyond their individual sites.
Substantially increasing building height and mass can contribute to additional overshadowing, reduced daylight and more uncomfortable wind conditions around streets and public spaces.
This matters because density should not only be measured by how many apartments can physically be accommodated.
A successful high-density neighbourhood also needs pleasant streets, sunlight, trees, usable open space and places where people actually want to spend time.
I am concerned that continually increasing building height will make parts of the neighbourhood darker, windier and more enclosed, while substantially increasing the number of people using those spaces.

4. There is not enough additional public green and open space
Waterloo already needs more green and public open space.
I acknowledge that this development includes landscaping and open space within the proposal. However, that space is largely required to support the population generated by the development itself.
Adding more than 200 apartments creates substantial additional demand for parks, recreation areas and other public open spaces used by the wider community.
The important question is therefore not simply whether this development contains some open space. It is whether the neighbourhood as a whole will have enough high-quality public green and open space for the much larger population being created across Waterloo and Zetland.
I do not believe that repeatedly increasing residential density without delivering a corresponding increase in genuinely public green space is a sustainable way to develop the area.

5. Existing waste problems will be made worse
There is already a noticeable waste-management problem in the local area.
Household rubbish, furniture and other bulky items are frequently left on roadsides and footpaths, and can remain there for days or weeks. This affects the appearance, cleanliness and usability of local streets.
Adding hundreds of additional residents will also increase the amount of household and bulky waste generated in the area.
The proposal should therefore demonstrate not only that the buildings themselves have adequate waste facilities, but that local waste collection and management systems can accommodate the cumulative growth in population.
Existing problems should be addressed before substantially more residential density is added.

6. Increased housing needs to be matched by increased infrastructure and amenity
I support increasing Sydney's housing supply, but housing numbers should not be considered in isolation.
If substantially more people are going to live in Waterloo, there needs to be a corresponding improvement in public transport, public open space, community facilities, waste services, pedestrian infrastructure and the quality of the public realm.
This proposal provides a very large uplift in development capacity, including more than 200 additional apartments and very substantial increases in building height.
I do not believe the corresponding public benefit or infrastructure improvement is sufficient to justify that uplift.

Conclusion
I ask the Department to refuse SSD-95997711 in its current form and require the development to remain substantially closer to the scale already approved.
In particular, I object to the proposed increases from 12 to 31 storeys and from 21 to 38 storeys, and the addition of more than 200 additional apartments.
Waterloo can accommodate additional housing, but growth must be balanced with infrastructure, green space, community facilities, and the neighbourhood's everyday liveability.

Submission in Objection

I am a resident who has lived in an apartment complex located less than 200 metres from the site since 2022. I previously made an anonymous submission regarding this proposal and am now providing this further submission after reviewing the applicant's amended documents and responses.

After reviewing the updated material, I remain strongly opposed to the proposal. Unfortunately, it is extremely difficult to properly assess the amendments because the information presented is inconsistent across the applicant's own documents. In many instances, statements appear contradictory, key details are difficult to verify, and there is significant repetition of information that is not always consistent. This creates confusion and makes it challenging to understand what has actually changed since the original proposal.

Overall, I have not identified any meaningful amendments that adequately address the concerns raised by the community. Instead, the revised documents contain a number of inconsistencies, misleading statements and unsupported comparisons.

Building Height and Bulk Remain Excessive:

The proposal continues to present excessive building heights and bulk that are inconsistent with the surrounding context.
Furthermore, the amended documents provide conflicting information regarding building height reductions. For example, the updated Heritage Impact Statement states that buildings surrounding the pumphouse have been reduced to seven storeys to align with the previously approved scheme. However, other diagrams and figures do not clearly demonstrate this change.
The presentation of information throughout the application is confusing and inconsistent, making it difficult to determine which version is accurate.

Inappropriate and Misleading Comparisons:

The Urban Design, Bulk and Scale assessment states "The floorplate of the Young Street tower is 823 square metres which is significantly smaller than a number of recent developments approved and constructed in Sydney including Indi (302 Pitt Street, Sydney), Boomerang (3 Olympic Drive, Sydney Olympic Park) and Harbourside in Darling Harbour."

These comparisons are inappropriate and misleading. The subject site is located in Waterloo, not the Sydney CBD or major metropolitan centres such as Darling Harbour or separate suburbs with different contexs such as Sydney Olympic Park. Comparing this development to significantly different urban contexts does not justify the scale proposed for this site.
Throughout the application there are numerous examples of unrelated or selective comparisons that appear designed to support the proposal rather than provide an objective assessment of its impacts.

Selective Reliance on Previously Approved Development:

The applicant frequently refers to the previously approved development under D/2021/1415 whenever it supports its position.
However, if the approved development is considered an appropriate benchmark, it is reasonable to ask why the applicant is not simply proceeding with that already approved scheme.

The application selectively references the approved development only where it assists the applicant's arguments, while simultaneously seeking substantial increases in scale, density and development yield in other areas. This selective approach lacks consistency and undermines the rationale for the proposed amendments.

5. Transport Assessment Contains Misleading Assumptions

The updated Transport Impact Assessment continues to state that both Green Square Station and the future Metro station are within a viable walking distance of the site. While they may technically be walkable, both are approximately one kilometre away. It is unrealistic to assume that the majority of residents will routinely choose to walk these distances. The assessment therefore appears to overstate the accessibility benefits of the site's public transport connections.

In addition, the report states: "An off-road shared path is provided along Bourke Street along the site frontage (see Figure 10)."
However, Figure 10 appears to depict infrastructure located approximately 500 metres from the site rather than directly adjacent to it. This creates a misleading impression regarding cycling infrastructure immediately available to future residents.

Delays to the existing Approved Development:

A development for approximately 373 dwellings was already approved for this site in 2023 and construction activities had commenced prior to the submission of this amended proposal under the Housing Delivery Authority (HDA) pathway.
Since the amended application was lodged, progress has effectively stalled while a substantially larger proposal is pursued.
Had the applicant proceeded with the approved development, those homes could likely have been delivered much sooner. Instead, the community is being asked to accept further delays while the developer seeks to increase development yield and profitability through an alternative planning pathway.

The Housing Delivery Authority has stated that: "The Government's priority is delivering completed homes, not just approvals."
In this case, there is already an approved development capable of delivering hundreds of dwellings. Rather than advancing housing supply, this application risks delaying the delivery of already approved homes while a larger and more profitable scheme is pursued. Approving proposals of this nature may encourage developers with existing approvals to pause approved projects and seek greater development yields through alternative pathways, resulting in further delays to actual housing delivery.

For this reason, I believe this application should be rejected, and the applicant should proceed with the already approved development.

Failure to Address Community Concerns:

It is also concerning that the applicant appears to have largely disregarded anonymous or name-withheld submissions.

A significant proportion of the 262 objections submitted were anonymous or confidential. The planning merits of a submission should not be discounted simply because a submitter elected to remain anonymous. The concerns raised by those residents deserve the same consideration as all other community feedback.

Misleading Community Consultation Claims:

The previous documentation raised serious concerns regarding the accuracy of the community consultation process. The Environmental Impact and Rezoning Statement states on page 94 that: "Letter box drop: 750 notices were distributed to properties within close proximity to the site." The Engagement Report on page 13 repeated the same statement. As I stated in my previous submission, despite living approximately 200 metres from the site, I never received any such notification. Given my proximity to the development, this raised concerns regarding the accuracy of the applicant's consultation claims. The applicant has not addressed why this potentially misleading statement was included in the original documentation, nor has it responded to concerns raised about the accuracy of this claim. This undermines confidence in the credibility of the broader proposal and the reliability of the information presented throughout the application.
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For the reasons outlined above, I remain to strongly object to this proposal. The amended application fails to adequately address the concerns raised by residents regarding building height, scale, urban design, transport impacts, community consultation and housing delivery outcomes. The documentation contains numerous inconsistencies, contradictory statements and misleading comparisons that make it difficult to assess the proposal with confidence.

Most importantly, an approved development already exists for the site. Rather than accelerating housing delivery, this application risks delaying the delivery of approved homes while seeking greater development intensity through an alternative pathway.

I therefore respectfully request that the Housing Delivery Authority reject this proposal and require the applicant to proceed with the already approved development.

I live on Morehead Street, about 280 metres from the former Sydney Water site on Bourke Street. I bought my home here to put down roots: to be close to family, to raise my child in a neighbourhood with footpaths, parks, and a real community, and to grow old here. I am writing because this proposal, as submitted, will make that harder for people like me and significantly harder for people more vulnerable than me.

My concern is not that this site should have less housing. It is that this neighbourhood needs housing that lets people age in place rather than being pushed out when their circumstances change. Housing close enough to schools and family that grandparents can do the school run and adult children can check in on parents. Housing that a nurse, a teacher, or a childcare worker can actually afford. What is proposed here is 580 apartments starting at $985,000 for a one bedroom. That is not housing for the people who need it most.

My objections cover three areas: gaps in the evidence base that should pause this application; community protections being removed without binding replacement; and an affordable housing offer that, on close reading of the applicant’s own documents, may produce no affordable dwellings at all.


The evidence base

The contamination assessment is incomplete

Two new basements are proposed that were not part of the original approved consent D/2021/1415. The Young Street North basement sits in the northern part of the site where the applicant’s own contamination consultant identified historical soil vapour contamination from the former Lawrence Dry Cleaners. The Bourke Street South basement has not been fully assessed.

The contamination cover letter (EI Australia, Appendix 13 of the EIS) states:

“While the finished floor level of the basement (BSS) in the south-eastern portion of the site is not available at the time of writing this letter… the potential of vapour intrusion risk into the proposed basement is considered unlikely.”*

I ask the Department to require finalised floor levels and full vapour intrusion modelling for both new basements before any consent is granted.

The wind assessment relies on an unapproved development

The wind report (Mel Consultants, Appendix 33) concludes that pedestrian safety standards are met, relying in part on wind shielding from the Coronation development at 881-885 Bourke Street. That project is currently under exhibition as an SSD and has not been approved. If Coronation is not built, or is built differently, this wind assessment is unreliable.

I ask the Department to require a revised wind assessment based only on approved developments.



Two community protections are being removed with nothing binding offered in return

When this site was originally rezoned and approved through the City of Sydney, two obligations applied. The first required a competitive design process, run twice for this site, providing independent scrutiny of design quality. The second required community infrastructure contributions for Green Square, recognising that a growing population needs schools, childcare, libraries, and open space.

This application seeks exemption from both.

The revised proposal is nearly double the approved height with no independent design review. At 126 metres on a heritage-sensitive site, self-assessment of design excellence by the developer’s own consultants is not sufficient.

The applicant’s own Social Impact Assessment (Sarah George Consulting, Appendix 17) acknowledges that Waterloo is already experiencing cumulative pressure on childcare, schools, recreation space, and aged care. The same application then seeks exemption from the levy that exists to fund those things.

On the Voluntary Planning Agreement: the VPA was negotiated for a development of 347-376 apartments. The same plaza, footpath widenings, and heritage square are now presented as community return for 580 apartments. The public receives identical infrastructure while the development grows 55% larger.

I ask the Department to refuse the exclusion of Clause 6.21D and Clause 6.14, and to require the VPA to be renegotiated to reflect the actual scale of what is proposed.


The affordable housing offer may produce no affordable dwellings

The planning statement (Sutherland & Associates, March 2026) presents a 12% affordable housing contribution on the uplift floor space as a significant community benefit. The same document states:

*“The City of Sydney Affordable Housing Program is an internal Council policy and the subject application is not bound by this Council policy.”*

The 12% figure comes from a policy this application is explicitly not bound by. Voluntary commitments in planning statements do not bind developers once consent is granted unless secured through a condition or Voluntary Planning Agreement. No binding VPA is proposed for the affordable housing component.

Both the mandatory 3% baseline under Clause 7.13 and the proposed 12% uplift contribution can be discharged through “an equivalent financial contribution” rather than actual dwellings. The entire affordable housing offer can be paid as cash, with no affordable dwelling built on this site.

This neighbourhood needs the family that can no longer afford the rent to stay near their children’s school. It needs the older resident who has lived here for thirty years to have somewhere to go when their circumstances change. It needs the community worker, the paramedic, the cleaner, to live within reach of the place they work.

I ask the Department to require affordable housing to be delivered as actual dwellings on this site, managed in perpetuity by a registered community housing provider, secured through a binding VPA that cannot be substituted with a financial contribution.

Cumulative transport has not been assessed

The EIS claims the proposal generates fewer vehicle trips than the approved DA by capping car parking at 376 spaces for 580 apartments. The transport burden is transferred to public transport, which is not assessed. The Coronation project, the Barings development on O’Dea Avenue, and the Waterloo Metro Quarter are each assessed individually as having negligible impact. Cumulatively, they do not.

I ask the Department to require a cumulative transport assessment covering all concurrent developments in the precinct before consent is granted.

Summary of requests

I ask the Department to:

- Require completed contamination assessments for both new basements, with finalised floor levels and vapour intrusion modelling, before consent is granted
- Require a revised wind assessment that does not rely on unapproved neighbouring development
- Refuse the exclusion of Clause 6.21D or require an independent design review
- Refuse the exclusion of Clause 6.14 or secure an equivalent contribution through a binding VPA
- Require the VPA to be renegotiated to reflect the 55% increase in apartment yield
- Require affordable housing as actual on-site dwellings, managed in perpetuity by a community housing provider, secured through a binding VPA, not dischargeable as a financial contribution
- Require a cumulative transport assessment across all concurrent developments in the precinct
- Direct that a public hearing be held

What happens on this site will shape what Waterloo becomes: whether it remains a place where people of different ages and incomes can stay and belong, or whether it becomes somewhere that only certain people can afford to enter. I am asking the Department to weigh that carefully.

I am writing to firmly oppose the amended development. I live near the site, and I invested in this neighbourhood to build a stable, long‑term home for my family. This proposal, as it stands, undermines the liveability and sustainability of the area for current and future residents.
My objection is not to additional housing — it is to the wrong kind of housing. What is being proposed is 580 high‑priced apartments starting at nearly $1 million for a one‑bedroom unit. That does nothing for families, essential workers, or long‑term residents who need housing they can actually remain in as their circumstances change. This is density without community benefit.
My concerns fall into four key areas:
1. Critical evidence gaps
The contamination assessment is incomplete. Two new basements are proposed in areas with known vapour risks, yet final floor levels and full modelling are missing. Approving a project of this scale without complete contamination data is irresponsible.
The wind assessment relies on shielding from a neighbouring development that is not approved. If that project does not proceed, the modelling collapses. A revised assessment based only on approved developments is required.
2. Removal of community protections
The proposal seeks to bypass both the competitive design process and the community infrastructure levy — obligations that existed for good reason. The building is now nearly double the approved height, yet the developer wants to self‑assess design excellence. That is unacceptable for a 126‑metre tower on a heritage‑sensitive site.
The VPA was negotiated for a much smaller development. The public is being offered the same infrastructure despite a 55% increase in apartments. That is not a fair or reasonable exchange.
3. Affordable housing that may deliver nothing
The so‑called 12% affordable housing contribution is not binding. The applicant openly states they are not subject to the policy from which that figure is drawn. Without a binding VPA, the entire contribution can be paid out as cash, resulting in zero affordable dwellings on site.
This community needs actual homes — not financial offsets — for families, older residents, and essential workers who keep this area functioning.
4. No cumulative transport assessment
The proposal shifts transport pressure onto public infrastructure without assessing the combined impact of multiple major developments in the precinct. This is a significant oversight and must be addressed before any approval is considered.
I ask the Department to:
Require complete contamination assessments and vapour modelling
Require a revised wind assessment based only on approved developments
Reject the removal of Clause 6.21D and require independent design review
Reject the removal of Clause 6.14 or secure an equivalent binding contribution
Renegotiate the VPA to reflect the increased yield
Require affordable housing as actual on‑site dwellings, secured in perpetuity
Require a cumulative transport assessment
Hold a public hearing
This decision will determine whether Waterloo remains a mixed, inclusive community or becomes a precinct only accessible to those who can afford premium apartments. I urge the Department to act in the long‑term interests of the neighbourhood.
Sincerely,
Sean Brown

To: NSW Department of Planning and Environment
Re: Submission of Objection – SSD-95997711 (903-921 Bourke Street, Waterloo)
To the Planning Officer,
I am writing to formally lodge my strong objection to the proposed modifications for the residential development at 903-921 Bourke Street, Waterloo (SSD-95997711).
As a resident living directly across the road from this site, the proposed amendments represent a gross departure from the originally approved plans and will have a direct, detrimental impact on my daily life and the broader Waterloo community.
My objections are based on the following critical concerns:
1. Significant Loss of Solar Access
Living directly opposite the site, I am highly concerned by the proposal to increase the Bourke Street North building from 12 to 31 storeys, and the Young Street Tower from 21 to 38 storeys. This massive increase in height will result in severe overshadowing of my home and the surrounding public spaces. The cumulative effect of these towers, alongside the adjacent proposal at 881-885 Bourke Street, will drastically reduce natural light during the winter solstice, affecting both my well-being and the energy efficiency of my residence.
2. Traffic Congestion and Parking Shortfall
The proposal adds 233 additional apartments over the approved plan (a total of 580 units) yet provides only 20 extra parking spaces. The local streets, particularly the intersection of Bourke and McEvoy, are already heavily congested. Adding thousands of new residents without adequate parking or road infrastructure will create a permanent traffic gridlock, making it increasingly difficult for local residents to navigate the area or find parking for essential services.
3. Infrastructure and Amenity Strain
Our local services are already at a breaking point. I frequently observe the 304 bus and Green Square trains operating at full capacity, often passing by commuters because there is no room. Adding "a small country town's worth of residents" to this specific block without a proportional increase in public transport and amenities—such as library space and seating—is unsustainable and will significantly diminish the quality of life for current residents.
4. Overbearing Scale and Wind Impacts
The proposed height is visually overbearing and entirely out of character with the existing streetscape. Furthermore, the creation of 30+ storey "walls" along these corridors poses a high risk of severe wind tunnel effects. As a pedestrian who uses these footpaths daily, I am concerned that the street-level environment will become hostile and potentially unsafe due to these downdrafts.
Conclusion
While I support sensible, sustainable growth in Waterloo, this specific proposal is excessive. The leap from 12 storeys to 31 is not a minor modification; it is a complete reimagining of the site that ignores the local context and the constraints of our infrastructure.
I urge the Department to reject these amendments and hold the developer to the scale originally approved by the City of Sydney.
Sincerely, Grant