Mixed use development with in-fill affordable housing, 25 Moss Vale Road Bomaderry

Mrs. W K
Residents of Tartarian Crescent
Bomaderry 2541


Date: 5 April 2025


To / Department of Planning, Housing and Infrastructure



Reference : 25 Moss Vale Road, Bomaderry NSW 2541
SSD-69257218


To whom it may concern:


Following the notification letter received for the development application in the above address, I , together with the rest of the residents in Tartarian Crescent as well as Elvin Drive, would like to oppose the building of multiple housing in our neighbourhood.

We are astonished when we received the exhibition notification as we were never notified in the past that there will be such application in our neighbourhood. It proved that the developers seemed to bypass the necessary steps.

Regardless, we totally disagree with the massive housing development at our backyard for many reasons.

First of all, it is very closed to the Bomaderry round about where the Moss Vale Road meets the Princess Highway. This roundabout itself now is always is very dangerous due to Northbound cars in the traffic hours. It is very difficult to get out from Moss Vale Road towards the Prince’s Highway and vice versa to enter from Princess’s Highway Moss Vale Road due to Southbound cars.

The construction in 25 Moss Vale Road will make the traffic worse. In addition, it is situated at the entrance to the Elvin Drive which directly affects our traffic.

Our houses are situated in the very quiet part of Bomaderry and the did not have much capacity and infrastructure to absorb massive housing development. The noise pollution, air pollution, dust, waste and chemical pollution that arise from the construction will impact our quite environment and wildlife.

In addition, we absolutely dislike the idea of mass allocation of all homeless people in one place. We support and agree the government’s idea of affordable housing and council housing. However, this should be spreading and allocated in multiple areas. This will let the homeless, vulnerable people to blend in the community and less social trauma of being from the one housing spot.

In addition, the massive group of housing for homeless population can also be associate with increase crimes in the neighbourhood.

Moreover, our area is low density residential zone. Therefore, this massive housing allocation should never be happened from the beginning.

Therefore, we strongly oppose the idea of allocation of group homes, homeless allocation in one spot, 25 Moss Vale Road, Bomaderry NSW 2541.



Regards,

W K and the residents of Tartarian Crescent.

Adam Beaven
2 Elvin Drive
Bomaderry NSW 2541
[email protected]
0416229594
2 April 2025
Planning Secretary
Department of Planning and Environment
GPO Box 39
Sydney NSW 2001
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RE: Objection to SSD-69257218 – Mixed-Use Development with In-fill Affordable Housing at 25 Moss Vale Road, Bomaderry
Dear Sir/Madam,
I am writing to formally object to the proposed State Significant Development (SSD-69257218) at 25 Moss Vale Road, Bomaderry, which seeks approval for a large-scale mixed-use development comprising 196 dwellings, a boarding house, affordable housing, childcare centre, medical centre, and retail/commercial tenancies.
While I acknowledge the importance of delivering diverse and affordable housing options, this development — in its current form — presents significant planning, social, infrastructure, and public safety concerns. These are especially pronounced when considered in the context of the Moss Vale Road North and South Urban Release Areas, where coordinated growth, infrastructure delivery, and community consultation are yet to occur.
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1. Development Precedes Strategic Urban Release Planning
The site lies within the Moss Vale Road South Urban Release Area, which has been earmarked for future development through structured planning, infrastructure staging, and community integration.
The proposed development proceeds in isolation of this process, undermining the intended strategic framework and setting a precedent for ad hoc, fragmented urban growth.
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2. Inappropriate Density and Built Form
The inclusion of six residential flat buildings, shop-top housing, a 52-room boarding house, and attached dwellings results in a density vastly inconsistent with the surrounding semi-rural and low-density character of Bomaderry.
Approving such an intensive form of development ahead of the necessary infrastructure and community support services is premature and ill-considered.
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3. Boarding House and Affordable Housing – Risk of Increased Crime and Social Impacts
While the intent to provide affordable housing is supported in principle, the proposal clusters vulnerable populations in a single, high-density location without clear safeguards or service provision. Research shows such clustering, particularly where boarding houses are involved, may lead to:
• Increased anti-social behaviour
• Higher police call-outs and crime rates
• Community safety concerns, especially in areas without visible police presence
There is no detailed management plan or ongoing oversight mechanism provided. Without these, the development risks creating a social hotspot for crime and disadvantage, rather than a safe, inclusive community.
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4. Traffic, Access and Parking – Severe Implications for Local Roads and Safety
The development is expected to generate several hundred daily vehicle movements, which will:
• Exacerbate congestion on Moss Vale Road and nearby intersections
• Strain narrow residential roads never designed for high traffic volumes
• Increase the risk of traffic collisions without proposed upgrades to intersections or pedestrian crossings
Public transport in the area is infrequent and unreliable, meaning the development will rely almost entirely on private vehicles. Parking provision is also inadequate, likely resulting in overflow parking on neighbouring streets, affecting safety and amenity.
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5. Strain on Local Services and Incomplete Amenity Provision
While a childcare centre and medical centre are proposed, they do not meet the demands of potentially 500+ new residents. The proposal lacks:
• Schools
• Recreational spaces
• Community centres
• Employment or transport linkages
This burden will fall to existing services, which are already near or over capacity.
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6. Environmental and Cumulative Impacts
The proposal risks:
• Vegetation loss
• Poor stormwater management
• Habitat fragmentation
In the absence of integrated planning across the wider release area, these cumulative impacts could cause irreversible environmental degradation.
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7. Community Consultation and Transparency
The community has not been adequately consulted on this proposal. A development of this size, with far-reaching implications for Bomaderry, must be subject to genuine community input, detailed social impact assessments, and transparent planning processes.
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8. Impacts on Emergency Services – Capacity and Response Concerns
This development will place unacceptable pressure on already stretched emergency services:
a. Police Services
Nowra Police Station services a large catchment, and response times in Bomaderry are already slow. Adding a large boarding house and affordable housing cluster will likely increase demand on police resources without additional resourcing or local presence. Any complaint raised has to be served by the single officer in Kangaroo Valley.
Bomaderry is already experiencing unsocial behaviour with yahoos invading the service area with the Elephant Car Wash at all hours of the night and revving their engines with loud music and fighting, not to mention the racing along the Princes Highway, which we have approached police, council and our state member all of which have failed to curb the activity
b. Ambulance Coverage
Bomaderry has a dedicated ambulance station and is primarily covering Nowra with three ambulances. The overflow is taken up by the Berry crews. Response times are already delayed, and this development will exacerbate the situation.
c. Fire Services
Fire and Rescue NSW and the Rural Fire Service (RFS) have limited capacity in the area. With Bomaderry’s bushfire vulnerability and the proposed development's density, the lack of detail on bushfire response planning, hydrant infrastructure, and emergency egress is deeply concerning.
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9. Retail Occupation
The recent announcement by council to revitalise the Nowra town centre has come about as there are many retail premises that are for lease or sale due to the large number of businesses that have not survived our cost of living crisis. Adding additional premises would only serve the estate and as such how has the viability been measured?

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Conclusion
In summary, I respectfully urge the Department to refuse the current application for the following reasons:
• It is premature and inconsistent with the strategic planning and infrastructure delivery of the Moss Vale Road Urban Release Areas.
• It introduces inappropriate density and a boarding house model that may lead to increased crime and anti-social behaviour.
• It will overwhelm existing infrastructure, emergency services, and local roads.
• It has not been developed with proper community consultation or service integration.

I strongly believe that growth in Bomaderry must be coordinated, staged, and community-led, not driven by speculative developments that risk long-term liveability.
Thank you for the opportunity to make this submission.
Yours sincerely,
Adam Beaven

Mr Andrew Watson
Project Officer
Key Sites and Regional Assessments
Department of Planning, Housing and Infrastructure
Parramatta, NSW 2324


RE: SSD - 69257218 – MASTER PLANNED COMMUNITY PRECINCT. MIXED USE DEVELOPMENT WITH IN-FILL AFFORDABLE HOUSING AND ASSOCIATED AMENITIES, LANDSCAPING AND PUBLIC DOMAIN WORKS. SUBDIVISION OF LAND INCLUDING TORRENS TITLE, COMMUNITY TITLE, AND STRATA AND A STRATUM LOT SUBDIVISION AT 25 MOSS VALE ROAD, BOMADERRY
Dear Mr Watson,
Thank you for referring the abovementioned proposal to the Department of Defence (Defence) for comment. Defence understands that the proposal is for the formulation of a master planned community precinct, various subdivisions, a mixed use development and associated works at 25 Moss Vale road, Bomaderry. The subject site is approximately 10 kilometers north of HMAS Albatross.
HMAS Albatross is of strategic importance and an enduring Defence base, being an operated and controlled airfield in close proximity to Nowra, New South Wales. Defence is planning for future development of the base, including potential for new capabilities and functions, which may be jeopardised by incompatible development on nearby properties.
Defence has assessed the proposal as presented for any possible impact on the safety of flying operations at HMAS Albatross. Defence seeks to ensure that the long term viability of HMAS Albatross is not compromised by inappropriate development on surrounding land, as this has the potential to impact on Australia’s Defence capability. On this basis, Defence would like to make the following comment.

Bird Strike
The subject site is located in an area mapped by Defence as “Birdstrike Area C”. In this area, certain land uses that have the potential to attract wildlife should be avoided, as they will potentially increase the risk for bird strike for aircraft operation from HMAS Albatross.
To mitigate potential safety issues Defence recommends that any future development complies with the National Airports Safeguarding Framework Guideline C: Managing the Risk of Wildlife Strikes in the Vicinity of Airports.

Should you wish to discuss the content of this advice further, my point of contact is Matt Williams at [email protected]

Yours sincerely,




Timothy Hogan
Director Land Planning & Regulation
Department of Defence

[email protected]
26 March 2025

Submission Regarding Proposed Mixed-Use Development in Bomaderry
I am writing to formally express my concerns about the proposed mixed-use development in Bomaderry, which includes 196 dwellings of affordable housing and a boarding house. While I acknowledge the need for affordable housing, I believe the scale, concentration, and location of this development raise significant concerns that should be considered before proceeding.

1. Overconcentration of Social Housing
Research and evidence from urban planning studies consistently show that clustering large amounts of social or affordable housing in one location leads to poor social outcomes. According to the Australian Housing and Urban Research Institute (AHURI), “concentrating disadvantage in specific locations can reinforce cycles of poverty, social exclusion, and crime.“¹ Successful affordable housing models are those that integrate housing within broader, mixed-income developments—not isolate it.

A 2018 study from the Grattan Institute also concluded that integrating social housing with private dwellings in diverse communities results in better long-term social cohesion, employment outcomes, and community safety.² Bunching 196 dwellings—plus a boarding house—into one site risks creating a pocket of disadvantage rather than a thriving, integrated community.

2. Misalignment with Moss Vale Road and this area of Bomaderry's Existing Character and Capacity
This area is a close-knit, semi-rural suburb with a unique community identity. The scale of this development is more in line with high-density urban settings—not a regional town that currently does not have the infrastructure or services to support such a concentrated influx of residents, many of whom may require additional support services.

The proposed boarding house is of particular concern, especially given its size and potential lack of on-site support services. Boarding houses, when poorly integrated or mismanaged, have been shown to experience high rates of turnover and social challenges, which can negatively impact the broader community if not carefully managed.³

3. Existing Road and Traffic Pressures

Traffic congestion is already a significant issue in this area of Bomaderry—particularly around the roundabout that connects to the Princes Highway near the development site. Local residents frequently experience delays and bottlenecks, especially during peak hours. The road network, particularly this intersection, is under considerable strain and not designed to accommodate the additional vehicle and pedestrian traffic that nearly 200 new dwellings will introduce.

There is little to no mention in the proposal of substantial upgrades to local roads or infrastructure to address this. Adding a development of this magnitude without simultaneous investment in traffic infrastructure and public transport options will further exacerbate the situation.

4. Concerns About Community Impact and Safety

Concentrating disadvantaged groups in one area without adequate social services, employment opportunities, and integration planning increases the risk of anti-social behavior and community division. Studies have shown that poorly integrated public housing developments can lead to increased calls for emergency services and reduced property values for surrounding homes.⁴

Bomaderry deserves a thoughtful, well-balanced approach to growth—one that respects the existing community, infrastructure, and identity. While I fully support the provision of affordable housing, it should be dispersed throughout the region, not concentrated in a single site that risks becoming a hotspot for disadvantage and social tension.

Conclusion

I urge the planning authorities to reconsider the scale and density of this development, and instead look at smaller, more integrated housing options that align with best-practice urban planning. The current proposal poses risks to community cohesion, road safety, infrastructure capacity, and social outcomes.

Thank you for considering this submission.
References:
1. Australian Housing and Urban Research Institute (AHURI), Spatial Concentration of Disadvantage and its Impact on Communities, 2020.
2. Grattan Institute, Housing Affordability: Re-imagining the Australian Dream, 2018.
3. City Futures Research Centre, Boarding Houses in NSW: Growth and Regulation, UNSW, 2019.
4. Productivity Commission, Public Housing and Social Mix, 2017.

Southern Cross Community Housing is a tier 1 community housing provider, who owns and manages over 2,300 dwellings which serves the community by providing safe and secure housing options. This project will seek to expand their holdings, whereby in their application they state they intend to maintain ownership of at least 50% of the housing stock which this project will provide. I recommend the panel which is assessing this application to ensure that SCCH's promise to maintain ownership of 50% of this housing stock is ensured.

This higher density form of development will be more financially sustainable for Shoalhaven council compared to other housing projects as part of surrounding urban release areas. This is due to the smaller footprint which minimises the amnount of utilities which needs to be maintained, whilst also generating more revenue for council due to the higher amount of dwellings. In recent times several councils have had to drastically increase council rates to maintain financial sustainability, including Shoalhaven council which had to raise their rates 12% for 2025-2026, which was above the 3.6% rate peg set by IPART, in order to deal with an increasing infrastructure maintenance backlog.

Although the development is not close to Bomaderry train station, I still believe the higher density form of this project is suitable for the area. This is due to the project forming a mixed used, with several key services and facilities being provided within project itself, reducing the need for individuals to travel outside the project area. I do suggest that a new bus stop be provided by the developer at the entrance of this project to facilitate public transport use. This mixed use style of development should be the future direction of development across NSW, as more detached housing will place increasing strain on government budgets, increasing the burden on tax and rate payers.

The maximum building height across the project is around 15m, which is more than suitable for a residential development. If anything, buildings up to 20m should be encouraged across the site to increase the feasibility of private companies providing services like a mini supermarket within the project area, and further decrease the need of individuals to use cars to access basic services, and thus reduce traffic. A building height of 20m, let alone 15m, does not detract from residential amenity.

The proposed parking of 341 spaces which include 257 residential, 59 for retail, and 17 for childcare is adequate for this type of mixed use development. The provision of a large portion of these houses for social and affordable purposes will mean future tenants are not likely to be in a financial position which supports them owning more than one car.

Please refer to the attached documents.