New Eileen O'Connor School

Dear Sir/Madam,
I am writing to object to the proposed development of a three-storey school at 84
Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and its technical appendices, I submit that the development is fundamentally flawed, legally non-compliant, and unsafe, and should be refused in its current form.
1. Traffic and Road Safety
Impacts
Underestimated Traffic
Generation: The Transport & Accessibility Impact Assessment (Appendix R, pp. 31-42) fails to model school peak periods.
Queuing and congestion on
Keefers Glen and Gavenlock Road are ignored, contrary to SEPP (Transport & Infrastructure) 2021 cl. 2.111, which requires safe and efficient transport outcomes for educational facilities.
Inadequate Road Capacity
Assessment: Keefers Glen is a narrow residential cul-de-sac.
Benchmarking against regional arterial roads is misleading and and breaches DCP 2022 Ch. 3.1 (Car Parking & Access), which requires context-based assessment.
Pedestrian & Cyclist Safety
Ignored: No safe crossing points or separated foot/cycle paths are proposed, breaching the
Austroads Guide to Road Design (Part 6A) and exposing children to risk.

parking falls short of DCP 2022 minimum ratios, ensuring overspill into Keefers Glen.
Construction Traffic Deferred:
The Preliminary CTPMP
(Appendix T, p. 6) defers
construction traffic planning until a builder is appointed, breaching EP&A Regulation 2021 Sch 2, cl.
6.
Cumulative Impacts Ignored: The report does not assess traffic interaction with St Peter's Catholic College, in breach of EP&A Act s.4.15(1) (b).
Ground for refusal: Unsafe and inadequate traffic planning, inconsistent with statutory and local planning controls.
2. Noise and Acoustic Amenity
Baseline Monitoring Deficient:
The Noise & Vibration
Assessment (Appendix U, pp. 17-
18) is based on short-term monitoring, not the 7-day standard required by the EPA Noise Policy for Industry 2017 (NPfl).
Outdoor Noise Underestimated:
Intermittent, high-level
playground and PA system noise was ignored, contrary to EPA guidance.

After-Hours Use Excluded: The report concedes that evening/ weekend use of facilities (sports, assemblies, community hire) has not been assessed (Appendix U,
p. 26), breaching EP&A Act s.4.15(1) (b).
Vague Mitigation Measures:
Generic references to barriers provide no enforceable design, breaching DCP Ch. 3.3 Noise & Vibration.
Construction Noise Ignored: No modelling against the Interim Construction Noise Guideline
(DECC 2009), contrary to regulatory standards.
Cumulative Noise Ignored: Noise from St Peter's College has not been combined with the proposal.
Ground for refusal: Noncompliance with NPfl 2017 and
ICNG 2009, leading to unacceptable amenity loss.
3. Flood Risk and Emergency
Access
The Flood Impact Assessment (Appendix EE, p. 21) and Flood
Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut durina 1% AEP and PMF events. isolating the site.
The NSW Floodplain
Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
The school is designed for children with disabilities, who may require assisted evacuation.
Approval without proven
evacuation safety risks breach of the Disability Discrimination Act 1992 (Cth) and the EP&A Act s.4.15(1) (b).
Ground for refusal: Unsafe flood evacuation and non-compliance with statutory floodplain management guidelines.
4. Bushfire Emergency
Management
The Bushfire Emergency
Management Plan (Appendix RR) confirms reliance on Keefers Glen as the sole access route.
Planning for Bushfire Protection 2019 (PBP) requires dual safe evacuation routes for vulnerableuses.
The interaction of flood and bushfire risks has not been assessed, contrary to NSW RFS

Details of hydrant access, defendable space, and APZs are incomplete.
Ground for refusal: Noncompliance with PBP 2019 and failure to ensure life safety in concurrent hazard scenarios.
5. Architectural Design, Height, and Privacy Impacts The Architectural Design Report (Appendix I) describes the school as "predominantly two-storey" but in reality introduces three-storey built form at the northern ends of the wings. These sections will appear as full three-storey blocks when viewed from Keefers Glen and Brickendon Avenue, creating an imposing institutional bulk inconsistent with the surrounding one- to two-storey residential neighbourhood.
This bulk and scale directly conflicts with the planning intent of the Central Coast Local
Environmental Plan 2022 and Development Control Plan 2022, which require new development to respect and integrate with the prevailing low-density residential character of Mardi.
Furthermore, the upper-level verandahs and learning spaces will enable direct overlooking into neighbouring backyards and homes, resulting in a significant loss of residential privacy. This impact breaches both the residential amenity provisions of the DCP and the broader objectives of the EP&A Act requiring protection of neighbourhood character and amenity.
Ground for refusal: Excessive building height, visual bulk, and overlooking, contrary to the LEP and DCP provisions for residential interface areas.
6. Social Impact
The Social Impact Assessment (Appendix KK, p. 12) is biased towards benefits and fails to assess negative impacts, including:
Loss of residential amenity and neighbourhood character, Increased noise and traffic danger,
Reduced property values, Cumulative stress on local infrastructure.
This omission breaches EP&A Act s.4.15(1) (b) and (d), which require full consideration of social and economic impacts.

Ground tor retusal: Incomplete and unreliable assessment of social impacts.
7. Legal and Policy NonCompliance Summary
The proposed development fails to comply with:
EP&A Act 1979 s.4.15(1) (b) - inadequate consideration of environmental, traffic, safety, and social impacts.
Central Coast LEP 2022 - inconsistent with local character and amenity objectives.
Central Coast DCP 2022 - breaches in traffic (Ch. 3.1), noise (Ch. 3.3), privacy, and rural-residential character (Ch. 5.51).
SEPP (Transport & Infrastructure)
2021 cl. 2.111 - inadequate traffic and safety outcomes.
EPA NPfI 2017 & ICNG 2009 - flawed acoustic assessment.
NSW Floodplain Development
Manual 2023 - unsafe evacuation provisions.
Planning for Bushfire Protection
2019 - inadequate bushfire evacuation and APZ design.
Requested Outcome
I respectfully request that Council refuse the DA in its current form on the grounds of serious non- compliance and unacceptable risk.
Should approval be contemplated, Council must at minimum require:
Independent peer review of traffic, noise, flood, and bushfire reports;
Strict conditions limiting building height to two storeys along
Keefers Glen;
Enforceable acoustic barriers and restrictions on PA/bell usage;
A prohibition on after-hours/ weekend use unless subject to a separate DA;
Proof of dual safe evacuation routes for flood and bushfire;
Full compliance with DCP car parking ratios and additional onsite parking.
Conclusion
This proposal represents a serious threat to safety, amenity, and local character. It fails multiple statutory tests under the EP&A Act and associated instruments. I therefore urge Council to refuse the DA in its current form.
Yours sincerely,

I totally object to this project - the Eileen O'Connor School. The very small, very tight streets of Keefers Glen and Deloraine Glen especially cannot cope with the huge increase in traffic, if this proposed new special needs school goes ahead. It would be total chaos. The streets are so tight, that two cars cannot pass each other now . I have huge safety concerns for local adults and children walking to the bus stops of Woodbury Park Drive to go to work or their local public school. There are no footpaths and cars on nature strips, as there is no way you can park on the street.

I live on the approach streets on the corner of Deloraine Glen and Wagners Place, Mardi. At the moment cars have trouble passing each other and I have seen many near accidents on this corner. This corner outside of our house is very steep and is a difficult corner even now. With the massive increase of cars and buses, traffic will bank up to Woodbury Park Drive and cause traffic chaos.

There is NO way a school for 200 special needs children can be built facing on to these tiny streets in Mardi. The idea is just ridiculous!. It will not only affect the residents quality of life and the devaluing of their property value but also the children attending this special school and the people that transport them, as they will all be in a queue everyday to unload or load, as it will all take so much time and the ongoing traffic build up on to the surrounding streets will be horrendous. Catholic Schools Broken Bay should find a new site for this school.

I have concerns about flooding, it floods down that end of Keefers Glen and there is a big natural dam. In the DA is says that they are just going to fill it in. Dams have a purpose and this will make the flooding far worse. There already is seepage on to Keefers Glen and Brickendon Ave. Looking at the site, you do not realise there is a dam there, as it is surrounded by tall trees and shrubs. This is a big environmental concern. If you search for Keefers Glen, Mardi on Google Maps you can see how big this dam is.

A development application for this school first went to Central Coast Council a few years ago and the Council said definitely NO to the proposal. They looked at traffic numbers and traffic flow etc and they said NO the Council would not support the DA. I and my wife thoroughly agree with this. The Council describes Keefers Glen as no more than a little laneway. I attach this to my submission.

There is no way a school should be built facing on to Keefers Glen, it is the tiniest of streets and really is just a laneway. The Central Coast Council a few years ago, looked into another DA to them of the same school and totally said NO to the proposal. I attach a page out of this report.

As well as Keefers Glen, Deloraine Glen, Wagners Place and Brickendon Avenue do not have anywhere to park or even to just pull over. Quite a few residents cars park on the nature strip as it is, as there is nowhere to park. With hundreds of new vehicles arriving at the start of school and when it finishes, this will cause chaos and be extremely dangerous for the local children, attending local schools, walking to or from their bus stops on Woodbury Park Drive at the same time. This will be a huge safety concern. As special needs children take much more time to be unloaded from their special needs community buses, the traffic in the proposed entrance and exit on Keefers Glen will bank up in that street and then onto the approach streets. Residents will not be able to pull out of their driveways to go to work, drive their children to local schools etc.

In summary, I completely OBJECT to this project.

Re: Objection to the Proposed Development – Eileen O’Connor Catholic School, 84 Gavenlock Road, Mardi (SSD 67173718)
Dear Sir/Madam,
I am writing to object to the proposed development of a three-storey school at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and its technical appendices, I submit that the development is fundamentally flawed, legally non-compliant, and unsafe, and should be refused in its current form.
1. Traffic and Road Safety Impacts
Underestimated Traffic Generation: The Transport & Accessibility Impact Assessment (Appendix R, pp. 31–42) fails to model school peak periods. Queuing and congestion on Keefers Glen and Gavenlock Road are ignored, contrary to SEPP (Transport & Infrastructure) 2021 cl. 2.111, which requires safe and efficient transport outcomes for educational facilities.
Inadequate Road Capacity Assessment: Keefers Glen is a narrow residential cul-de-sac. Benchmarking against regional arterial roads is misleading and breaches DCP 2022 Ch. 3.1 (Car Parking & Access), which requires context-based assessment.
Pedestrian & Cyclist Safety Ignored: No safe crossing points or separated foot/cycle paths are proposed, breaching the Austroads Guide to Road Design (Part 6A) and exposing children to risk.
Parking Deficiency: On-site parking falls short of DCP 2022 minimum ratios, ensuring overspill into Keefers Glen.
Construction Traffic Deferred: The Preliminary CTPMP (Appendix T, p. 6) defers construction traffic planning until a builder is appointed, breaching EP&A Regulation 2021 Sch 2, cl. 6.
Cumulative Impacts Ignored: The report does not assess traffic interaction with St Peter’s Catholic College, in breach of EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe and inadequate traffic planning, inconsistent with statutory and local planning controls.
2. Noise and Acoustic Amenity
Baseline Monitoring Deficient: The Noise & Vibration Assessment (Appendix U, pp. 17–18) is based on short-term monitoring, not the 7-day standard required by the EPA Noise Policy for Industry 2017 (NPfI).
Outdoor Noise Underestimated: Intermittent, high-level playground and PA system noise was ignored, contrary to EPA guidance.
After-Hours Use Excluded: The report concedes that evening/weekend use of facilities (sports, assemblies, community hire) has not been assessed (Appendix U, p. 26), breaching EP&A Act s.4.15(1)(b).
Vague Mitigation Measures: Generic references to barriers provide no enforceable design, breaching DCP Ch. 3.3 Noise & Vibration.
Construction Noise Ignored: No modelling against the Interim Construction Noise Guideline (DECC 2009), contrary to regulatory standards.
Cumulative Noise Ignored: Noise from St Peter’s College has not been combined with the proposal.
Ground for refusal: Non-compliance with NPfI 2017 and ICNG 2009, leading to unacceptable amenity loss.
3. Flood Risk and Emergency Access
The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.
The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
The school is designed for children with disabilities, who may require assisted evacuation. Approval without proven evacuation safety risks breach of the Disability Discrimination Act 1992 (Cth) and the EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe flood evacuation and non-compliance with statutory floodplain management guidelines.
4. Bushfire Emergency Management
The Bushfire Emergency Management Plan (Appendix RR) confirms reliance on Keefers Glen as the sole access route. Planning for Bushfire Protection 2019 (PBP) requires dual safe evacuation routes for vulnerable uses.
The interaction of flood and bushfire risks has not been assessed, contrary to NSW RFS guidelines.
Details of hydrant access, defendable space, and APZs are incomplete.
Ground for refusal: Non-compliance with PBP 2019 and failure to ensure life safety in concurrent hazard scenarios.
5. Architectural Design, Height, and Privacy Impacts
The Architectural Design Report (Appendix I) describes the school as “predominantly two-storey” but in reality introduces three-storey built form at the northern ends of the wings. These sections will appear as full three-storey blocks when viewed from Keefers Glen and Brickendon Avenue, creating an imposing institutional bulk inconsistent with the surrounding one- to two-storey residential neighbourhood.
This bulk and scale directly conflicts with the planning intent of the Central Coast Local Environmental Plan 2022 and Development Control Plan 2022, which require new development to respect and integrate with the prevailing low-density residential character of Mardi.
Furthermore, the upper-level verandahs and learning spaces will enable direct overlooking into neighbouring backyards and homes, resulting in a significant loss of residential privacy. This impact breaches both the residential amenity provisions of the DCP and the broader objectives of the EP&A Act requiring protection of neighbourhood character and amenity.
Ground for refusal: Excessive building height, visual bulk, and overlooking, contrary to the LEP and DCP provisions for residential interface areas.
6. Social Impact
The Social Impact Assessment (Appendix KK, p. 12) is biased towards benefits and fails to assess negative impacts, including:
Loss of residential amenity and neighbourhood character,
Increased noise and traffic danger,
Reduced property values,
Cumulative stress on local infrastructure.
This omission breaches EP&A Act s.4.15(1)(b) and (d), which require full consideration of social and economic impacts.
Ground for refusal: Incomplete and unreliable assessment of social impacts.
7. Legal and Policy Non-Compliance Summary
The proposed development fails to comply with:
EP&A Act 1979 s.4.15(1)(b) – inadequate consideration of environmental, traffic, safety, and social impacts.
Central Coast LEP 2022 – inconsistent with local character and amenity objectives.
Central Coast DCP 2022 – breaches in traffic (Ch. 3.1), noise (Ch. 3.3), privacy, and rural-residential character (Ch. 5.51).
SEPP (Transport & Infrastructure) 2021 cl. 2.111 – inadequate traffic and safety outcomes.
EPA NPfI 2017 & ICNG 2009 – flawed acoustic assessment.
NSW Floodplain Development Manual 2023 – unsafe evacuation provisions.
Planning for Bushfire Protection 2019 – inadequate bushfire evacuation and APZ design.
Requested Outcome
I respectfully request that Council refuse the DA in its current form on the grounds of serious non-compliance and unacceptable risk.
Should approval be contemplated, Council must at minimum require:
Independent peer review of traffic, noise, flood, and bushfire reports;
A location change of the entry of the school to Gavenlock Road where the road is built for a higher amount of traffic;
Strict conditions limiting building height to two storeys along Keefers Glen;
Enforceable acoustic barriers and restrictions on PA/bell usage;
A prohibition on after-hours/weekend use unless subject to a separate DA;
Proof of dual safe evacuation routes for flood and bushfire;
Full compliance with DCP car parking ratios and additional on-site parking.
Conclusion
This proposal represents a serious threat to safety, amenity, and local character. It fails multiple statutory tests under the EP&A Act and associated instruments. I therefore urge this proposition to be refused by the DA in its current form.
Yours sincerely, Chris Bondin

I object to this project and the high potential of massive increase to traffic flow through a local area

I object to the project in its current form, in particular, the entry proposed at Keefers Glen, Mardi.

My reasons for objecting to the new school development are based on the proposed traffic movements into and out of the school.

The Transport & Accessibility Impact Assessment has only used single dimension overhead view photos of all associated streets, intersections and roundabouts and there no written description explaining that the suburb of Mardi was built into a 400+ meter hillside.

Nor is there mention that Woodbury Park Drive from the Wyong Road entry initially winds around the lower part of the suburb before having to aggressively continue to wind up to the top of the hill elevation where Wagner Place is located and from the Gavenlock Road entry a similar path is taken however with not as aggressive elevation to some 75% of the hill elevation where Brickendon Avenue is located.

N.B. Numerous speedhumps have had to be installed in an effort to reduce the local traffic's speed up and down the aggressive elevation between Wyong Road and Wagner Place.

From the Cobs Village feeder road of Wagner Place there is an aggressive downhill elevation to Deloraine Glen and from Deloraine Glen there is a steep downhill elevation to 75% of Keefers Glen before meeting up with Brickendon Avenue.

From the only other Cobs Village feeder road of Brickendon Avenue there is a reasonable winding traffic island installed downhill elevation to Keefers Glen.

These Cobs Village feeder roads of Wagners Place, Deloraine Glen, Brickendon Avenue and Keefers Glen have been determined by the Central Coast Council to be under engineered for the proposed use of all forms of construction vehicles and busses and for the major increase of traffic the school would attract.

Where are all of the construction vehicles going to be parked during the construction period, how are the larger cement, pumper,
ridged and semi trucks going to navigate into and around the roads of Mardi and then the under engineered roads of Cobs Village?

N.B: In the recent pass there has been incidences in Cobs Village involving motor vehicles and pedestrians, including children, resulting in the latter's hospitalization recovery. The majority of these incidences were caused by the narrowness of the streets and resident's cars that have to straddle the grassed footpath and street when parked so as to keep a thoroughfare, all of which reduces everyone's visibility.

The current site, before any sub-division, totals some 12 hectors of land, the proposed development site totals some 1.3 hectors, approximately 10% of the total site, surely there is a more appropriate area within the total of 12 hectors for the development’s sub-division and development to take place.

For example, I note an area of land to the proposed site, starting at the adjoining property’s south western corner at 100 Gavenlock Road towards the east to the estimated PMF flood level line, an area that has an existing roadway within the total site leading back to Gavenlock Road.

I believe this area to all parties be a far more partible less costly option for this development.

Dear Sir/Madam,

I am writing to formally object to the proposed development of the Eileen O’Connor Catholic School in its current form, particularly in relation to the planned access from Keefers Glen, as well as the broader impacts outlined in the Environmental Impact Statement and technical appendices.

My family moved into the neighbourhood in late 2023 and were not part of the initial consultation process. Since living here, we have already observed significant school-related impacts and are concerned that the proposed development will increase these negative effects.

1. Traffic and Road Safety
Currently, high school students frequently park along our street during school hours, and parents are already using Keefers Glen to drop off students. We have been advised by neighbours that this entrance was originally intended as a service access point, not a main school entrance, and its current use is unauthorised.

Keefers Glen is a narrow residential cul-de-sac, not designed for high volumes of traffic. The proposal to formalise it as a dedicated school entrance poses serious risks for children and pedestrians. Our own children attend Tuggerah Public School and use the bus, which requires them to cross Wagners Place at Deloraine Glen — an already unsafe crossing with no zebra markings. Additional traffic associated with the proposed school will heighten these dangers and create an unacceptable safety risk.

2. Noise and Amenity
Our home runs parallel to Keefers Glen, and even with windows closed we already experience noise impacts from the nearby school, including the PA system during the day. While some school-related noise is to be expected, the scale and proximity of the proposed development will significantly increase these disturbances, diminishing the quiet residential amenity of the neighbourhood.

3. Alternative Access
From reviewing the plans, it appears that access via Gavenlock Road — already zoned and established for school use — would provide a safer and more practical solution for students, staff, parents, and local residents alike. This entrance offers more space for queuing, parking, and managing traffic flows within school property, rather than funnelling vehicles through local neighbourhood streets.

If the school is designed to support up to 200 students, even with half travelling by public transport, the neighbourhood cannot safely accommodate the resulting traffic of more than 130 vehicles twice daily. A narrow residential street such as Keefers Glen is simply not appropriate for this scale of activity.

4. Support for a Special Needs School
I want to be clear that I am supportive of a new special needs school in our local area, and even on these particular school grounds. I recognise the importance of providing purpose-built facilities for children with disabilities and believe the community would benefit from such a development. However, more careful planning is required to ensure the impacts on surrounding residents are properly addressed and mitigated.

Conclusion
In its current form, this proposal represents an unsafe and unsuitable development for our neighbourhood. The use of Keefers Glen as a main school access point will significantly worsen traffic congestion, pedestrian safety, noise, and local amenity, contrary to planning objectives and community expectations.

I respectfully request that Council and the Department refuse the Development Application in its current form. At minimum, school access should be restricted to Gavenlock Road, ensuring traffic and parking are managed within school grounds rather than spilling into residential streets.

Attached, one of our neighbours have helpfully provided documented objections in relation to NSW Planning Guidelines. I would like to submit their evidence with my own objection for consideration, as we support their stance and objection points.

Thank you for considering my submission.

I object to the above proposed development of the Eileen O’Conner due to the entrance and exit of the school being at Keefers Glen, a small little residential back street in Mardi.
That street and the streets surrounding it are not large enough to support something of that scale.
It also poses safety risks not only to the students of the school but the children and family’s already living around the area.
The infrastructure is not built for that scale of activity, there are barely and side walks in the area and with flooding the amount of children that walk on the road to get to the bus stops on Woodbury park drive is unsafe as it is, with the increase of school buses, speciality taxis and parent drop offs, not to mention construction trucks that will be traveling in the area it will increase those safety issues tenfold.

Council has already refused this proposal on the basis that that small back street and this area is not built for the increased traffic flow this will bring to the area.

The main entry and exit points should be on Gavenlock road where St Peter’s already is, that road is 100x more suited to increased traffic than Keefers Glen is.

There is also not enough car parking onsite in the proposed development for the full time teachers, multiple support staff that would be needed for disabled children and visitors so does this mean Keefers Glen (which already has little to no off street parking) and the surrounding small streets will bear the brunt of the parking issues.

I do not believe that proper assessment of the traffic impact has been carried out. The extra traffic that this entry and exit point in Keefers Glen will generate will overflow into the streets around it especially Brickendon Ave, Delorraine Glen and Wagners Ave then flowing onto the only entry, exit road Woodbury Park Drive.
Keefers Glen is a residential street with limited width especially if anyone dare to park outside their own home. Brickendon Ave has the same problem. If residents or visitors park on the road outside their homes then it becomes a one lane road.
The streets have no footpaths so on bad wet days other school children need to walk on the road because of the mess on the ground. Many families using prams or strollers walk on the road because again the ground outside is not suitable. Older people using walking aids also need to walk on the road again as the footpath is not safe. So my conclusion is that these people should be put in danger so that another private school can be advanced. The entry/exit should be at its location address of 84 Gavenlock Road Mardi not a small residential enclave with limited ability to take on the demolition ,earthworks and construction of this application. There are no considerations for the real people that this extremely impacts; traffic, noise, building debris, safety for our children and our right to live in a safe environment. We already have been blooded by some of the parents from St Peters by parking over private driveways and speeding down our streets. The application doesn't address the fact that there isn't enough parking spots in their design to accommodate all staff or any extra visitors. Absolutely no consultation has been had with the residents only a letter in the mail. You have no right to dismiss us. No one I have spoken to is against the school itself but we are against the ridiculous idea that we have to be sacrificed for it. Upgrades to the roads will not make any difference they are residential streets built for the residents not increased traffic for school drop off and pick ups. You need to re-examine their application. I do believe that if you allow it to go ahead as is then there will be a terrible backlash from the residents towards the school.

Re: Objection to the Proposed Development – Eileen O’Connor Catholic School, 84 Gavenlock Road, Mardi (SSD 67173718)

Dear Sir/Madam,
I am writing to object to the proposed development of a three-storey school at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and its technical appendices, I submit that the development is fundamentally flawed, legally non-compliant, and unsafe, and should be refused in its current form.
1. Traffic and Road Safety Impacts
Underestimated Traffic Generation: The Transport & Accessibility Impact Assessment (Appendix R, pp. 31–42) fails to model school peak periods. Queuing and congestion on Keefers Glen and Gavenlock Road are ignored, contrary to SEPP (Transport & Infrastructure) 2021 cl. 2.111, which requires safe and efficient transport outcomes for educational facilities.
Inadequate Road Capacity Assessment: Keefers Glen is a narrow residential cul-de-sac. Benchmarking against regional arterial roads is misleading and breaches DCP 2022 Ch. 3.1 (Car Parking & Access), which requires context-based assessment.
Pedestrian & Cyclist Safety Ignored: No safe crossing points or separated foot/cycle paths are proposed, breaching the Austroads Guide to Road Design (Part 6A) and exposing children to risk.
Parking Deficiency: On-site parking falls short of DCP 2022 minimum ratios, ensuring overspill into Keefers Glen.
Construction Traffic Deferred: The Preliminary CTPMP (Appendix T, p. 6) defers construction traffic planning until a builder is appointed, breaching EP&A Regulation 2021 Sch 2, cl. 6.
Cumulative Impacts Ignored: The report does not assess traffic interaction with St Peter’s Catholic College, in breach of EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe and inadequate traffic planning, inconsistent with statutory and local planning controls.
2. Noise and Acoustic Amenity
Baseline Monitoring Deficient: The Noise & Vibration Assessment (Appendix U, pp. 17–18) is based on short-term monitoring, not the 7-day standard required by the EPA Noise Policy for Industry 2017 (NPfI).
Outdoor Noise Underestimated: Intermittent, high-level playground and PA system noise was ignored, contrary to EPA guidance.
After-Hours Use Excluded: The report concedes that evening/weekend use of facilities (sports, assemblies, community hire) has not been assessed (Appendix U, p. 26), breaching EP&A Act s.4.15(1)(b).
Vague Mitigation Measures: Generic references to barriers provide no enforceable design, breaching DCP Ch. 3.3 Noise & Vibration.
Construction Noise Ignored: No modelling against the Interim Construction Noise Guideline (DECC 2009), contrary to regulatory standards.
Cumulative Noise Ignored: Noise from St Peter’s College has not been combined with the proposal.
Ground for refusal: Non-compliance with NPfI 2017 and ICNG 2009, leading to unacceptable amenity loss.
3. Flood Risk and Emergency Access
The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.
The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
The school is designed for children with disabilities, who may require assisted evacuation. Approval without proven evacuation safety risks breach of the Disability Discrimination Act 1992 (Cth) and the EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe flood evacuation and non-compliance with statutory floodplain management guidelines.
4. Bushfire Emergency Management
The Bushfire Emergency Management Plan (Appendix RR) confirms reliance on Keefers Glen as the sole access route. Planning for Bushfire Protection 2019 (PBP) requires dual safe evacuation routes for vulnerable uses.
The interaction of flood and bushfire risks has not been assessed, contrary to NSW RFS guidelines.
Details of hydrant access, defendable space, and APZs are incomplete.
Ground for refusal: Non-compliance with PBP 2019 and failure to ensure life safety in concurrent hazard scenarios.
5. Architectural Design, Height, and Privacy Impacts
The Architectural Design Report (Appendix I) describes the school as “predominantly two-storey” but in reality introduces three-storey built form at the northern ends of the wings. These sections will appear as full three-storey blocks when viewed from Keefers Glen and Brickendon Avenue, creating an imposing institutional bulk inconsistent with the surrounding one- to two-storey residential neighbourhood.
This bulk and scale directly conflicts with the planning intent of the Central Coast Local Environmental Plan 2022 and Development Control Plan 2022, which require new development to respect and integrate with the prevailing low-density residential character of Mardi.
Furthermore, the upper-level verandahs and learning spaces will enable direct overlooking into neighbouring backyards and homes, resulting in a significant loss of residential privacy. This impact breaches both the residential amenity provisions of the DCP and the broader objectives of the EP&A Act requiring protection of neighbourhood character and amenity.
Ground for refusal: Excessive building height, visual bulk, and overlooking, contrary to the LEP and DCP provisions for residential interface areas.
6. Social Impact
The Social Impact Assessment (Appendix KK, p. 12) is biased towards benefits and fails to assess negative impacts, including:
Loss of residential amenity and neighbourhood character,
Increased noise and traffic danger,
Reduced property values,
Cumulative stress on local infrastructure.
This omission breaches EP&A Act s.4.15(1)(b) and (d), which require full consideration of social and economic impacts.
Ground for refusal: Incomplete and unreliable assessment of social impacts.
7. Legal and Policy Non-Compliance Summary
The proposed development fails to comply with:
EP&A Act 1979 s.4.15(1)(b) – inadequate consideration of environmental, traffic, safety, and social impacts.
Central Coast LEP 2022 – inconsistent with local character and amenity objectives.
Central Coast DCP 2022 – breaches in traffic (Ch. 3.1), noise (Ch. 3.3), privacy, and rural-residential character (Ch. 5.51).
SEPP (Transport & Infrastructure) 2021 cl. 2.111 – inadequate traffic and safety outcomes.
EPA NPfI 2017 & ICNG 2009 – flawed acoustic assessment.
NSW Floodplain Development Manual 2023 – unsafe evacuation provisions.
Planning for Bushfire Protection 2019 – inadequate bushfire evacuation and APZ design.
Requested Outcome
I respectfully request that Council refuse the DA in its current form on the grounds of serious non-compliance and unacceptable risk.
Should approval be contemplated, Council must at minimum require:
Independent peer review of traffic (including a change of entry point to the school via Gavenlock Road) , noise, flood, and bushfire reports;
Strict conditions limiting building height to two storeys along Keefers Glen;
Enforceable acoustic barriers and restrictions on PA/bell usage;
A prohibition on after-hours/weekend use unless subject to a separate DA;
Proof of dual safe evacuation routes for flood and bushfire;
Full compliance with DCP car parking ratios and additional on-site parking.
Conclusion
This proposal represents a serious threat to safety, amenity, and local character. It fails multiple statutory tests under the EP&A Act and associated instruments. I therefore urge Council to refuse the DA in its current form.
Yours sincerely,

To Whom It May Concern,

My name is Elaine Purches and I live in Cobbs Village, Mardi (1/22 Keefers Glen, Mardi). I wish to formally object to the proposed Eileen O’Connor School at Keefers Glen, 84 Gavenlock Road.

The road network in and around Cobs Village is already unsuitable for the level of traffic we currently have. Streets are narrow, cars have to be parked halfway across the footpath just to let others through, and this has already led to safety issues and accidents involving pedestrians. Adding construction trucks, trades, and later the daily movement of staff, students, and service vehicles will put even more pressure on roads that simply cannot cope.

Beyond traffic, the project also raises other concerns for local residents. These include construction noise and dust, the impact of taller buildings on privacy, and the likelihood of a negative effect on property values.

At this stage, there has been little opportunity for genuine consultation with residents. Given the scale of the impact, the community should have a much stronger voice before any approval is granted.

Yours faithfully,
Elaine Purches

To Whom It May Concern,

My name is Monty Muhl and I live in Cobbs Village, Mardi. I’m writing to object to the proposed special education school at Keefers Glen (St Peter’s site, 84 Gavenlock Road).

The main issue is traffic. Our streets are already narrow and difficult to get through, with cars often parked partly on the footpath just so people can pass. We’ve already had incidents in the village with pedestrians being hit and injured because of poor visibility. Adding heavy construction trucks, service vehicles, staff cars, and daily school drop-offs will make it dangerous and unworkable.

Other concerns are the noise and dust from construction, the height of the buildings affecting privacy, and the likely hit on property values for residents here.

There are much better options than using Keefers Glen for access. Gavenlock Road is built for heavier traffic and would make far more sense. Extending the existing St Peter’s driveway from Gavenlock Road through to the new site would also solve most of the issues. If that’s not possible, then at the very least there should be restrictions such as:

Making Keefers Glen one-way,

A no-drop-off zone, or

No school traffic entering via Keefers Glen at all.

Any of those options would help keep our community safe while still allowing the project to go ahead. Right now it feels like residents haven’t been properly consulted, and I think that needs to change before this moves forward.

Regards,
Monty Muhl

To whom it may concern,

We are an owner/occupier In Mardi, residents recently received a letter from the NSW planning and development regarding the proposed development of the new Eillen O'Connor school on the grounds of St peters.

The proposed three storey school is to be built in the back corner overlooking Keefers glen with the entry and exit to be in Keefers Glen and not through the already existing school grounds entry on Gavenlock Rd.

The school is a K-12 and will cater for 200 hundred students and over 70 school andauxiliary staff. Parking for the proposed site is inadequate as the allocated spots only come to 61. Being a special needs school, all students will need assistance either by private car or buses. The proposed site also includes a Multi-purpose centre to be used after hours and weekends.

Central coast council has already opposed the entry and exit on Keefers Glen. They have said the entry and exit needs to be off Gavenlock road due to many reasons but the main one being the street and surrounding streets will not cope with the increase of traffic that this will bring and buses being unable to navigate the roads safely.

The schools governing body(CSBB)recently undertook a safety audit of the gate that leads from the school into Keefers Glen and as of Term 3 the gate has been locked as they deemed it unsafe for students to use for pick up and drop off.

The community has been submitting their objects to the proposed entry and exit to the NSW planning and Development in hopes that this will be rectified.

Being a strata community is there any laws or by laws that could help in this situation? And if so, could we please have access to this to be able to submit.

And for your consideration does any potential lose in property values effect strata costs and fees ? A local resident has gone through the whole proposal and has found a number of legal flaws. They have posted on the community Facebook page which we can send if you would like to read. Also, please find attached Council document.

We are not against a school Being built but a three-storey building overlooking backyards on Brickendon and overlooking Keefers people lose all privacy, we are against the entry and exit on Keefers glen and it should be constructed from the Gavenlock entrance. We understand that community's go through change, but this is on a very large scale and impacts all residents.
The development fails to consider any impact on the small local community that we are.

Any information would be greatly appreciated.

My name is Peter McKenna, I own and reside at a strata managed property located in Cobbs Village Mardi and I'm currently a committee member of the strata management team.

I have reached out to you before in regards to the continue flooding of my business premises located in Ace Crescent Tuggerah, your advise and suggested contact person at the council at that time was a great help to the commencement of solving our problem.

FYI, I have also reached out to David Harris MP in regards to these matters and awaiting a reply.

You may be aware of the proposed new development for a 200 student special educational school at Keefers Glen Mardi.
My reason for contacting you at this time is in an effort to promptly encourage consultation between the NSW Department of Planning and Environment and the property owners of Cobbs Village and the greater Mardi suburb.

Currently we are one and a half weeks into a four week period offered to the Cobs Village property owners by the Department of Planning and Environment to lodge any objections to the proposed development, a process that many property owners are now undertaking.

N.B: In the recent pass there has been incidences in Cobs Village involving motor vehicles and pedestrians, including children, resulting in the latter's hospitalization recovery. The majority of these incidences were caused by the narrowness of the streets and resident's cars that have to straddle the footpath and street when parked so as to keep a thoroughfare, all of which reduces everyone's visibility.

FYI, to date the main concerns that the property owners have are in regards to our village sized streets leading into the heart of Cobs Village, in that of Keefers Glen, that are going to be subjected to firstly all of the construction vehicles ranging from semi and ridged trucks, cement mixers and pumpers and all associated trade vehicles during the construction period and secondly once the project is completed all of the students, teaching staff, school management, school maintenance, service, trades people and suppliers vehicles adding addition movements throughout each day.

These village streets are accessed from the main Woodbury Park Drive Mardi, as you would know, a winding up elevated before down again road that has had to have numerous speed humps installed in an effort to reduce the local traffic's speed, that would be subjected to all of the above noted additional types of vehicle's daily movements.

The development proposal is addressed as '84 Gavenlock Road Mardi' being St Peters College, from overhead viewing on Google Maps, it is obvious to us that there are more simple and suitable entry routes that could be taken from the main industrial grade designed Gavenlock Road to the proposed development site rather than subjecting all of Mardi let alone the unsuitably sized Cobs Village roads and Keefers Glen to these additional daily vehicle movements.

The other property owner concern's that have been raised relate to such as the additional noise and dust generated during the construction period, the height of the above single story buildings of the development reducing the level of privacy to their properties, the suitable types of screening and/or vegetation that would be used in an effort to possibly overcome these privacy issues and the local real estate industry advised of potential devaluation of their properties.

Alternatively, if the proposed building site was situated further east on the cleared land towards Gavenlock Road, starting at say in line with the end of Brickendon Avenue and vehicle access via the above noted more suitable Gavenlock Road, all of our concerns

would be greatly alleviated allowing Cobs Village, the Greater Mardi suburb and St Peter's College to continue to operate safely and harmoniously together. Under the current NSW Department of Planning and Environment arrangement there is no opportunity for the property owner's of Mardi to consultation with the department.

I object to SSD-67173718 - New Eileen O'Connor School. I object to this DA and the proposal of sub-dividing the land and building the new Eileen O’Connor School and having the entrance on to Keefers Glen, Mardi. The proposal says it is for 84 Gavenlock Road, Mardi, which I feel is wrong, as when you go to the Planning Portal the front of the new school, as well as the entrance and exit are on to Keefers Glen, Mardi. Keefers Glen is really just a tiny little laneway (which is confirmed by Central Coast Council in my attachment to this submission).

I specifically draw your attention to Central Coast Council's pre DA Advice of 20/9/2023, part of which I have attached to my submission. I can supply more of this. I 100% agree entirely with this report. The Council stated that they will not support this proposal and list the very many reasons on it.

The proposed new special needs Eileen O'Connor school will generate extremely higher traffic nd Keefers Glen and surrounding roads are unsuitable for the huge amount of traffic that a special needs school of this size will create, particularly as the majority of students are coming from out of area and arriving in community buses. This does not even include the large quantity of trucks and workers needed for to construct a project of this size (suggesting figures of 100 workers on site at one time).

Keefers Glen, Deloraine Glen, Wagners Place and Brickendon Avenue were only designed for a small amount of traffic. They are small, tight streets and cannot handle the amount of traffic. In Keefers Glen itself, two cars cannot pass each other in parts of it, Central Coast Council call it a laneway. Why would anyone plan to have this amount of traffic in a street like this! There is no parking available at all on the street or surrounding streets, parking already is a huge trouble. The new school proposal is only providing 61 car spaces, yet will have 71 teachers plus extra auxilliary staff. Where are they going to park?

There are sections of Keefers Glen, including the doglegs at the top, which cannot cope now with two passing cars at a time. The proposal does not include upgrades to Keefers Glen except for an extra bitumen section in front of the school and a short footpath from the school entrance to Brickendon Ave.

Objection due to Environmental Concern:

There is a natural dam on site and I am very concerned about this, as the proposal just says the builders are just going to fill it in. What will happen with the waterflow and underground water table. This could be a major environmental mistake, as a lot of the year it is so very wet on that block of land and Keefers and Brickendon . There is already run off from this dam into Keefers Glen and Brickendon Ave. The dam doesn't look much to the eye, as it is surrounded by trees and shrubs, but it is a big dam which can be clearly seen on Google maps. What a big environmental concern this is.

The Significant Impact on Local Residents:

The burden and disruption on a daily basis of the traffic to and from this proposed new school will be horrendous to the residents of these small, tight streets in Mardi. The traffic going up and down from the school will all finally bank back on to Woodbury Park Drive and this will be chaotic especially on the steep hill of Wagners Place and the corner of Deloraine Glen. Then when the traffic reaches the roundabout at the end of Woodbury Park Drive and Wyong Road, it will be a nightmare, as it is usually very hard to get out of this roundabout now! This new noise from this school will be bad. I know there is another school there now but none of it is facing our streets and also there is to be a community hall. which will also have things after hours and on weekends. The huge increase in traffic past our houses will severely affect our quality of lives, be a danger pulling in and out of our driveways and significantly decrease our property values.

Important Safety Concerns:

Pedestrians: It will be extremely dangerous for local pedestrians, school children and people walking their dogs. As there are no footpaths and as the streets mentioned above are so little, cars are already mostly parked on the nature strips, otherwise traffic cannot get by. It is already a big danger for children walking to school or people walking to the bus stops on Woodbury Park Drive - what will it be like with hundreds and hundreds of extra vehicles a day and at the same time as the local children are walking to the bus stop to go to the local primary and high schools. This cannot happen !! Also when people and children walk up to Woodbury Park Drive there are no footpaths there and it is dangerous walking or jogging on the nature strips and currently most people walk on the road itself. All of the above is a terrible accident waiting to happen ! This is a huge concern.

Traffic Queing and Delays and Traffic bank up:

The proposal has not taken into account that there will also be queuing of cars and special needs buses to get in and out of the school. These are not children who can get in and out of vehicles quickly, they will need a lot of help, quite a few will be in wheelchairs etc. They will take quite a long time to load and unload and the traffic will queue into and out of Keefers Glen, banking back into Deloraine Glen or Brickendon Avenue and then onto the main through road Woodbury Park Drive.

Objection:

I totally object to this development application by Catholic Schools Broken Bay as it currently stands. However, if the proposed new special needs Eileen O'Connor School has to be built on this subdivided site, which I definitely object to in its current form, then all traffic to it MUST enter through the purpose built entrance at 84 Gavenlock Rd, Mardi - which is the address given for this application. There is ample room for the existing internal road of St Peters Catholic College to continue on to this new school and have the new school back on to Keefers Glen, Mardi without any entry and exit through Keefers Glen.

It is not going to be feasible for the current proposal of this school tpo be built with inadequate parking for the staff that will be required here, let alone the private vehicles and buses that will be coming in and out of the street transporting students. This needs to be revisited to have space expanded to allow for staff as well as students.

I am writing to strongly oppose the proposed use of Keefers Glen, Mardi, as an access road for the new Eileen O’Connor Catholic School in Tuggerah. Keefers Glen and the surrounding streets of Brickendon Ave, The Sheiling, Richmond Mews, Delorain Glen, Wagners Pl, Hawthorne Pl, and Woodbury Park Dr are wholly unsuitable to accommodate the scale of traffic this development will generate. I urge the planning authority to abandon the Keefers Glen access proposal entirely and instead utilise Gavenlock Road, which is far more suitable and sustainable.

Inappropriateness of Keefers Glen as an Access Route
Keefers Glen is a narrow residential street, originally designed to service 16 homes. It cannot cope with the traffic associated with:
• Daily student drop-off and pick-up,
• Access to a 61-space staff car park,
• Construction traffic from up to 100 workers per day, and
• Long-term operations of a school of 200 students and over 71 staff.
The introduction of this volume of traffic would cause serious congestion, safety hazards for residents, and permanent loss of residential amenity.

Traffic Impacts on the Wider Road Network
The use of Keefers Glen as an access point will inevitably funnel traffic into Brickendon Avenue, Deloraine Glen, Wagners Place, and Woodbury Park Drive and the roundabouts where Wyong Road and Woodbury Park Drive meet and where Woodbury Park Drive and Gavenlock Road meet.
• This roundabout where Wyong Road and Woodbury Park Drive meet is already under pressure during peak commuting hours. The addition of concentrated school traffic — particularly during narrow drop-off and pick-up windows — will worsen congestion significantly.
• Traffic queuing from Keefers Glen will create spillback into Brickendon Avenue, Deloraine Glen, Wagners Place and Woodbury Park Drive, affecting not only local residents but also through-traffic accessing Wyong Road.
• The safety of pedestrians and cyclists using this corridor will be compromised by increased vehicle volumes, particularly larger school, and service vehicles.
• Keefers Glen, Brickendon Avenue, Deloraine Glen, and Wagners Place are not wide enough to support two-way car traffic, how can these roads be expected to safely support two-way traffic of assisted transport busses, service vehicles and construction vehicles? They cannot, and should not be burdened with the task.
This additional strain on the local road network is unacceptable and undermines broader traffic safety and efficiency in the Mardi–Tuggerah precinct.

Case Study: St Gabriel’s School, Castle Hill – A Cautionary Example
At St Gabriel’s School, Castle Hill, traffic congestion is already a major issue.
• Drop-off (8:15–9:00am) and pick-up (2:15–3:30pm) generates queues stretching 500 metres along Old Northern Road, despite the school having a 100-metre internal access road and being located on a four-lane arterial road.
• Traffic incidents and safety concerns are common, showing the severe impact even when major roads are used.
• St Gabriel’s employs over 100 staff, suggesting that the Diocese’s current staff estimate of 71 for the Eileen O’Connor School is either negligent or intentionally misleading.
If a major arterial road with dedicated stacking space cannot cope, it is unreasonable to expect Keefers Glen and its surrounding residential streets to absorb similar traffic without disastrous consequences.

Amenity, Privacy, and Planning Compliance Concerns
The proposed school includes a three-storey building, which is inconsistent with local council planning regulations that restrict building heights in this residential area. Cobbs Village Estate primarily consists of single and two-storey colonial era style houses, the planned design for this school are a modern monstrosity in comparison to the existing historic country charm.
• Loss of sunlight: Residents of Keefers Glen will experience significant amenity impacts, as the height and bulk of the building will block morning sunlight.
• Loss of privacy: The building’s height will result in classrooms and windows overlooking the backyards of Brickendon Avenue, creating an unacceptable loss of privacy.
• Visual impact: A three-storey institutional building is inconsistent with the low-rise residential character of the area and will create an imposing and oppressive presence.
This development, as proposed, does not respect council regulations or the rights of surrounding residents.

Proposed Widening of Keefers Glen – Further Unacceptable Impacts
Although the school plans emphasise the use of Keefers Glen without clear widening details, Keefers Glen and the surrounding residential streets are being considered to accommodate increased traffic volumes.
This raises immediate questions:
• What land will be reclaimed to widen Keefers Glen?
• Will this require compulsory acquisition of private residential land or reduction of footpath and green space?
• What will be the impact on existing street parking, driveways, and property access?
Any attempt to widen Keefers Glen will result in further loss of amenity, safety concerns, and disruption for existing residents. It is not an appropriate or acceptable solution.

Influence of the Catholic Diocese over Local Planning
The Diocese of Broken Bay, as proponent, appears to be leveraging its institutional and political influence to override the genuine concerns of local residents, and Council to potentially bypass Council process. This sets a dangerous precedent where the interests of a powerful religious body are placed ahead of those of the small residential community that will bear the full brunt of the disruption.
Decisions about local planning should be made in the best interests of residents and road safety, not institutional convenience and identity.

“Sense of Pride” Justification – An Insult to the Existing Community
It has been suggested that the Diocese wishes to use Keefers Glen as the school’s entry point because it provides the school with a “sense of pride and identity.” This reasoning is profoundly insulting.
• It implies that the “pride and identity” of the school is more important than the safety, privacy, and amenity of the existing residents of Cobbs Village, especially that of residents of Keefers Glen and the surrounding residential streets.
• Pride and identity for a new institution should never come at the expense of destroying the established character and liveability of a small residential community.
This justification reveals a disregard for the rights and wellbeing of residents and highlights why Keefers Glen must not be used.

Gavenlock Road: The Only Suitable Access Point
By contrast, Gavenlock Road is a logical and safe access option.
• It is wider and better equipped to handle large volumes of traffic.
• It directly connects to arterial roads such as Wyong Road, the Pacific Highway, and the M1 Motorway.
• It avoids channelling heavy traffic through residential streets, protecting the safety and amenity of existing neighbourhoods.
This alternative aligns with responsible urban planning and provides a future-proof solution.

Requested Actions
I respectfully request that:
1. The use of Keefers Glen as an access road be abandoned entirely.
2. Any widening or modification of Keefers Glen for school access be formally ruled out.
3. A revised access plan be prepared utilising Gavenlock Road as the primary entry/exit point.
4. An independent Traffic Impact Assessment (TIA) be undertaken, including modelling of Woodbury Park Drive, Wyong Road, and Keefers Glen.
5. The development be required to comply with local planning regulations on building height, bulk, and neighbourhood character.

Keefers Glen is wholly unsuitable as an access road for the proposed Eileen O’Connor Catholic School. The street cannot safely or sustainably manage the traffic generated by a 200-student, 70+ staff school and associated construction impacts.
The proposal disregards the safety, amenity, and rights of the existing community, while privileging institutional convenience and “pride” over local liveability. The only responsible planning outcome is to abandon Keefers Glen as an access point and instead pursue Gavenlock Road as the school’s designated entry.

I live on Keefers Glen, it is not suitable road for a new school entrance, neither are the connecting streets. This proposal is ridiculous to be entering from this quiet street. The access should be from Gavenlock Rd only.

Re: Objection to the Proposed Development – Eileen O’Connor Catholic School, 84 Gavenlock Road, Mardi (SSD 67173718)
Dear Sir/Madam,
I am writing to object to the proposed development of a three-storey school at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and its technical appendices, I submit that the development is fundamentally flawed, legally non-compliant, and unsafe, and should be refused in its current form.
1. Traffic and Road Safety Impacts
Underestimated Traffic Generation: The Transport & Accessibility Impact Assessment (Appendix R, pp. 31–42) fails to model school peak periods. Queuing and congestion on Keefers Glen and Gavenlock Road are ignored, contrary to SEPP (Transport & Infrastructure) 2021 cl. 2.111, which requires safe and efficient transport outcomes for educational facilities.
Inadequate Road Capacity Assessment: Keefers Glen is a narrow residential cul-de-sac. Benchmarking against regional arterial roads is misleading and breaches DCP 2022 Ch. 3.1 (Car Parking & Access), which requires context-based assessment.
Pedestrian & Cyclist Safety Ignored: No safe crossing points or separated foot/cycle paths are proposed, breaching the Austroads Guide to Road Design (Part 6A) and exposing children to risk.
Parking Deficiency: On-site parking falls short of DCP 2022 minimum ratios, ensuring overspill into Keefers Glen.
Construction Traffic Deferred: The Preliminary CTPMP (Appendix T, p. 6) defers construction traffic planning until a builder is appointed, breaching EP&A Regulation 2021 Sch 2, cl. 6.
Cumulative Impacts Ignored: The report does not assess traffic interaction with St Peter’s Catholic College, in breach of EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe and inadequate traffic planning, inconsistent with statutory and local planning controls.
2. Noise and Acoustic Amenity
Baseline Monitoring Deficient: The Noise & Vibration Assessment (Appendix U, pp. 17–18) is based on short-term monitoring, not the 7-day standard required by the EPA Noise Policy for Industry 2017 (NPfI).
Outdoor Noise Underestimated: Intermittent, high-level playground and PA system noise was ignored, contrary to EPA guidance.
After-Hours Use Excluded: The report concedes that evening/weekend use of facilities (sports, assemblies, community hire) has not been assessed (Appendix U, p. 26), breaching EP&A Act s.4.15(1)(b).
Vague Mitigation Measures: Generic references to barriers provide no enforceable design, breaching DCP Ch. 3.3 Noise & Vibration.
Construction Noise Ignored: No modelling against the Interim Construction Noise Guideline (DECC 2009), contrary to regulatory standards.
Cumulative Noise Ignored: Noise from St Peter’s College has not been combined with the proposal.
Ground for refusal: Non-compliance with NPfI 2017 and ICNG 2009, leading to unacceptable amenity loss.
3. Flood Risk and Emergency Access
The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.
The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
The school is designed for children with disabilities, who may require assisted evacuation. Approval without proven evacuation safety risks breach of the Disability Discrimination Act 1992 (Cth) and the EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe flood evacuation and non-compliance with statutory floodplain management guidelines.
4. Bushfire Emergency Management
The Bushfire Emergency Management Plan (Appendix RR) confirms reliance on Keefers Glen as the sole access route. Planning for Bushfire Protection 2019 (PBP) requires dual safe evacuation routes for vulnerable uses.
The interaction of flood and bushfire risks has not been assessed, contrary to NSW RFS guidelines.
Details of hydrant access, defendable space, and APZs are incomplete.
Ground for refusal: Non-compliance with PBP 2019 and failure to ensure life safety in concurrent hazard scenarios.
5. Architectural Design, Height, and Privacy Impacts
The Architectural Design Report (Appendix I) describes the school as “predominantly two-storey” but in reality introduces three-storey built form at the northern ends of the wings. These sections will appear as full three-storey blocks when viewed from Keefers Glen and Brickendon Avenue, creating an imposing institutional bulk inconsistent with the surrounding one- to two-storey residential neighbourhood.
This bulk and scale directly conflicts with the planning intent of the Central Coast Local Environmental Plan 2022 and Development Control Plan 2022, which require new development to respect and integrate with the prevailing low-density residential character of Mardi.
Furthermore, the upper-level verandahs and learning spaces will enable direct overlooking into neighbouring backyards and homes, resulting in a significant loss of residential privacy. This impact breaches both the residential amenity provisions of the DCP and the broader objectives of the EP&A Act requiring protection of neighbourhood character and amenity.
Ground for refusal: Excessive building height, visual bulk, and overlooking, contrary to the LEP and DCP provisions for residential interface areas.
6. Social Impact
The Social Impact Assessment (Appendix KK, p. 12) is biased towards benefits and fails to assess negative impacts, including:
Loss of residential amenity and neighbourhood character,
Increased noise and traffic danger,
Reduced property values,
Cumulative stress on local infrastructure.
This omission breaches EP&A Act s.4.15(1)(b) and (d), which require full consideration of social and economic impacts.
Ground for refusal: Incomplete and unreliable assessment of social impacts.
7. Legal and Policy Non-Compliance Summary
The proposed development fails to comply with:
EP&A Act 1979 s.4.15(1)(b) – inadequate consideration of environmental, traffic, safety, and social impacts.
Central Coast LEP 2022 – inconsistent with local character and amenity objectives.
Central Coast DCP 2022 – breaches in traffic (Ch. 3.1), noise (Ch. 3.3), privacy, and rural-residential character (Ch. 5.51).
SEPP (Transport & Infrastructure) 2021 cl. 2.111 – inadequate traffic and safety outcomes.
EPA NPfI 2017 & ICNG 2009 – flawed acoustic assessment.
NSW Floodplain Development Manual 2023 – unsafe evacuation provisions.
Planning for Bushfire Protection 2019 – inadequate bushfire evacuation and APZ design.
Requested Outcome
I respectfully request that Council refuse the DA in its current form on the grounds of serious non-compliance and unacceptable risk.
Should approval be contemplated, Council must at minimum require:
Independent peer review of traffic, noise, flood, and bushfire reports;
Strict conditions limiting building height to two storeys along Keefers Glen;
Enforceable acoustic barriers and restrictions on PA/bell usage;
A prohibition on after-hours/weekend use unless subject to a separate DA;
Proof of dual safe evacuation routes for flood and bushfire;
Full compliance with DCP car parking ratios and additional on-site parking.
Conclusion
This proposal represents a serious threat to safety, amenity, and local character. It fails multiple statutory tests under the EP&A Act and associated instruments. I therefore urge Council to refuse the DA in its current form.
Yours sincerely,