New Eileen O'Connor 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 and State Development NSW 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 and NSW State Planning to refuse the DA in its current form.
Yours sincerely,
Concerned resident

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 and NSW STATE planning to refuse the DA in its current form.

The current plan to use residential streets for access to the project will create significant problems for the local community around Keefers Glen. The streets are too narrow to safely manage the high volume of traffic the project will generate, which will heavily impact residents near the construction site. The residential streets behind the school are particularly unsuitable for this purpose.
A far better solution is to designate Gavenlock Road as the sole entry and exit point. This road is already an industrial and business access route, as demonstrated by its use for the Catholic college. Using Gavenlock Road would be a safer and more appropriate choice that avoids disrupting residential neighbourhoods.

I fully support the development of a school dedicated to serving students with special disabilities. It is crucial that we provide better educational opportunities for these students, and I am wholeheartedly in favor of such an initiative. However, my concern lies with the proposed entry and exit point for the school along Keefers Glen Mardi.
The primary issue I want to emphasize is that the current plan to redirect school traffic through Keefers Glen Mardi is not only impractical but could significantly disrupt the quality of life for the residents in this area, including myself. I believe that the school should retain its entry through Gavenlock Road, as it currently serves all other students, and I propose that a separate driveway or alternative route be created specifically for the new school. This solution would address the school's unique needs without causing unnecessary inconvenience to the surrounding neighborhood.
There are several key reasons why the proposed entry via Keefers Glen Mardi would be detrimental:
1. Increased Traffic Congestion:
We have already observed how the traffic during pick-up and drop-off times has a severe impact on the local area. The roads, particularly in the vicinity of Keefers Glen Mardi, are not equipped to handle the volume of traffic associated with a school of this scale. Many residents, including myself, have had to wait in long lines just to enter our own driveways. The increased congestion would make it more difficult for residents to navigate their own streets and access their homes, which is an untenable situation for those who live here.
2. Safety Concerns:
With the added traffic, there are real concerns about safety—especially for pedestrians, cyclists, and young children who live in the area. The street was never designed with school traffic in mind, and attempting to adapt it to serve as a main entry point for the school could create hazards for residents and visitors alike.
3. Practicality and Road Design:
While the proposal includes road widening, this does not address the fundamental issue that Keefers Glen Mardi was not designed to serve as an entry point for a large-scale school. Even with widening, it would still remain an unsuitable route, and simply adding more lanes will not solve the broader issue of accessibility for residents. The back roads surrounding the school were not built for this kind of traffic, and any attempt to accommodate it will likely lead to more disruptions, not fewer.
4. Impact on Surrounding Streets:
The ripple effect of increased traffic along Keefers Glen Mardi will undoubtedly extend to the surrounding streets, including those that lead directly to the school. Residents on those streets will also face greater difficulty in accessing their homes, and the added traffic flow could reduce the overall quality of life for everyone in the neighborhood. The street system is simply not designed to handle the proposed traffic volume.
5. The Need for a Separate, Dedicated School Entrance:
The solution seems simple: create a dedicated entry and exit point for the school through Gavenlock Road, which would keep the flow of traffic separate from the surrounding residential areas. This would alleviate concerns about congestion, safety, and access while ensuring that the school has a proper infrastructure to handle the needs of its students and their families.
In conclusion, while I fully support the mission of the new school and its benefits for students with special disabilities, the proposed entry through Keefers Glen Mardi is a major flaw in the plan. The current infrastructure cannot accommodate such a large volume of school traffic without causing significant disruption to the local community. I urge the decision-makers to reconsider the proposed entry point and explore the possibility of an alternative route via Gavenlock Road, which would serve both the school’s needs and the well-being of the surrounding neighborhood.
Thank you for considering this critical concern.

I want to oppose the construction of the new disability school in the middle of our residential suburb because it will significantly disrupt the quiet and safety of our local community. The increased traffic from staff, students, and parents, especially during peak hours, will lead to congestion, noise, and a greater risk for accidents on roads that were not designed for such heavy use. While I fully support inclusive education and the need for disability services, I believe this development would be better suited to a location with infrastructure that can safely handle the volume of vehicles without negatively impacting residents' daily lives.

To Whom It May Concern,

I am writing in response to the proposed development of the New Eileen O'Connor School (heavily affecting Mardi residents). As a parent of a child who has attended multiple support classes (and still does), I wholeheartedly support the need for this kind of educational facility. I know firsthand how valuable these schools are to the families they serve. However, I am strongly opposed to the proposal to use Keefer’s Glen—a small, quiet residential street—as the school’s main entrance and exit.

⸻

🔹 Keefer’s Glen Is Entirely Unsuitable as a School Entry

Keefer’s Glen is a short, tightly-curved street not designed for heavy through traffic, let alone the daily flow of vehicles a large K–12 support school will generate. The proposal would:
    •    Strip all on-street parking currently used by residents and their visitors (as shown in Figures 36–38 of the development plan).
    •    Introduce heavy, daily traffic to a suburban street where young children currently play and ride bikes.
    •    Turn a peaceful, family-oriented street into a noisy, high-risk drop-off zone.
    •    Increase safety concerns for residents, particularly those with small children or family members with disabilities. My self and my neighbour have houses filled with children with disabilities, RIGHT opposite THE entrance site, and proposed truck delivery site on Keefers Glen. This will heavily impact our children's mental welfare and quiet safe-place. No considerate consultation has been done with neighbours to understand the impact on individuals. The irony is, the two families who will be most impacted by this entrance site are the ones with disabled children directly across from the main access point.

⸻

🔹 There Is Zero Benefit to Keefer’s Glen Residents

It must be made very clear: the residents of Keefer’s Glen gain nothing from this proposal. There is no parking offered for residents or our visitors in return, no upgrades to infrastructure, and no consideration for the disruption we will experience.

Instead:
    •    Our homes lose value.
    •    Our daily lives are impacted by congestion and noise.
    •    Our safety is compromised.
    •    Our privacy is removed.
    •    Our infrastructure (stormwater, footpaths, traffic flow) is stressed beyond its limits.


This is not a collaborative community project. It is a developer-driven plan that disregards the residents of Keefer’s Glen entirely.

⸻

🔹 Major Traffic Congestion Will Affect All of Mardi

This is not an isolated issue. The impact of this entrance will ripple across Mardi:
    •    Significant congestion during peak times on Keefers Glen, Brickedon Avenue, Deloraine Drive, Woodbury Park Drive, Wagner Place, and Hawthorne Place.
    •    Parents avoiding the official entrance will instead drop off in surrounding streets, worsening traffic and reducing road safety.
    •    Bottlenecks and delays will become routine, impacting hundreds of homes and commuters daily.

⸻

🔹 Gavenlock Road Is the Safer, Smarter Alternative

A dedicated entrance from Gavenlock Road solves nearly every issue:
    •    No residential street is disturbed.
    •    Access is safer for the many students who rely on assisted or private transport.
    •    Resident parking and property access remain untouched.
    •    Traffic flows more efficiently along a road that is designed to handle it.

Additionally, the belief that students in support classes need a main road entrance for inclusion is misguided. My own child has attended multiple support units, none of which required this to foster belonging. These students value consistency, calm, and support—not curb appeal. They don't want to be seen as different, they want to be included.

⸻

🔹 Infrastructure & Environmental Oversights

It is unacceptable that:
    •    All stormwater from the new school is to be directed to Keefer’s Glen without any infrastructure upgrade.
    •    Construction is planned six days per week, with no mitigation offered for noise, parking, or disruption.
    •    The plan offers no improvements, considerations, or benefits to current residents—only imposition and disadvantage.

⸻

🔹 Property Value Loss Across the Area

Turning Keefer’s Glen into a main school entrance will devalue dozens of homes. Buyers will walk away from properties on congested streets, where noise is constant and parking is non-existent.

It’s unreasonable for Mardi homeowners to shoulder this loss while a large developer proceeds without offering compensation, compromise, or direct (actually empathetic) consultation.

⸻

🔹 Emergency Access—Not Everyday Access

I understand the need for emergency planning and would support Keefer’s Glen being used as an emergency evacuation gate only. That is a reasonable and measured use of the space.

But making it the main access for daily use is not justified in any way—not practically, not safely, and not ethically.

⸻

🔹 Conclusion

I support the school building a support unit. I do not support sacrificing an entire residential community for its convenience—especially when a more suitable alternative exists. Placing the main entrance on Gavenlock Road would:
    •    Eliminate congestion and safety issues for Mardi.
    •    Preserve the value and function of Keefer’s Glen homes.
    •    Ensure student access remains safe, supported, and practical.

This is a significant development with lasting impacts. Mardi residents—particularly those directly affected—deserve to be considered with respect, not disregarded in the name of expedience.

Sincerely,
L Smith
[Lot 2005 882874]
Mardi Resident

I object to the proposal in its current form. The location of the entry and exit points of the school is a residential area. With the added traffic the danger to our community will increase. The school is located in a residential area where the roads and footpaths are not built for school traffic, and do not provide an acceptible accessible entry or exit for people with disabilities.

Assisted school transport program will increase the amount of larger veichles that will use the road throughout the day again, making the local community unsafe for the younger children that are living in the area.

A better access point for the school and the community would be Gavenlock Road which is also a boarder road of the school. This road is built for heavier traffic and would provide easy access to the school. The area surrounding the school has established, flat footpaths that could be continued to support the school. There is also multiple points to park if services are attending the school without interrupting the neighbours of the school.

As a local resident I oppose the decision to access the school from residential streets. This decision has been made by the developer despite council recommending otherwise. Brickendon Street onto Woodbury Park Drive regularly has near misses due to the the t-section. Roads are narrow and would not accommodate buses. As a local who has friends in Brickendon, I know that even the smaller club courtesy buses and limousines have had difficulty negotiating those streets. Residents should be considered first in a residential area
Regards
Dellean

It seems to me that the traffic situation has not been properly considered for this project. Obvious to every resident Keefer's Glen is not of adequate width to allow for two way traffic in and out of the school with buses, drop-off points etc, and does not have the infrastructure at the intersection of Woodbury Park drive to prevent unacceptable delays morning and afternoon. But also of concern is the impact on the Woodbury Park Drive / Wyong Rd intersection once the new development next to Westfield is complete. The planning document for that development anticipated traffic flows but did not take into account school traffic. My view on the expected traffic flows at the intersection, even without the school traffic, is that it was significantly underestimated. This new project will add to this and create unacceptable delays and road wear if it goes ahead. This part of Mardi is a significant residential development that relies on Woodbury Park Drive as it's only access, and should not be the location for a school unless access can be from Gavenlock Road.

I object to the project for the following reasons:
- Keefers Glen is a residential road which is narrow and would not be able to support the large amount of traffic that a special needs school will create.
- It is already difficult for two cars to pass at a time on sections of Keefers Glen and connecting roads and I have first hand experience living here locally. The proposal does not include upgrades to Keefers Glen except for extra bitumen at the front entrance of the new school. This is unlikely to be sufficient to accomodate the extra traffic creating a hazard.
- There is limited spaces for parking on Keefers Glen. The school is only providing 61 spaces for their 71 teachers and extra auxiliary staff. So there is high likelihood that Keefers Glen or other nearby roads will be used for parking creating traffic flow problems and a hazard given the roads are already very narrow.
These issues will significantly impact the experience and create additional hazards for the residents of Mardi and those attending the school. I would really appreciate the NSW Government to consider these issues.

SUBMISSION LETTER TEMPLATE: ****

After reviewing 68 documents and finding legal flaws within all of them, please see attached letter which you can use as a template for your submission to oppose the school.

I do NOT oppose the special needs school, I think it needs to be built in a more adequate location to protect both residents AND the special needs children.

LETTER; ****

“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,”
Taryn Fuller

I am writing a submission to object to the proposal as it stands. I frequently visit the area as it is where my partner lives as it stands now it is difficult navigating the streets with just he typical residential and visitor traffic as the streets are very narrow, frequently requiring cars to pull as far to one side of the road as they can to allow other cars a safe passage as it difficult/impossible to go through side by side

My concern is with increased traffic in the area as well as transportation to get school children in and out of the area this simply cannot be accommodated with the size of the streets as it already extremely difficult as outlined above. This will be extremely inconvenient not only for residents and visitors, but also just would not e suitable for area for parents and other school transportation as it would cause massive traffic logs in the areas and could eve be potentially unsafe for students, parents and residents as the streets are not designed to accommodate to facilitate this kind of project, in particular Keefers Glen is extremely narrow allowing for only one car at a time and is dog legged in one section and was constructed as a residential street and not for heavy amounts of traffic.

I submit that the development is fundamentally flawed, legally non-compliant, and unsafe and should be refused in it current form

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,

I strongly object to this project as currently presented, and am asking for the proposal to be changed so that this school can be built WITHOUT the significant burden placed on residents that is proposed in this Development Application.

This school lists 84 Gavenlock Road as the area of development, which (although the school may technically be on that lot) is highly deceptive, as the main development will impact Keefers Glen, a tiny, narrow road that is effectively a one-way lane if two cars are driving on it. To get to Keefers Glen, you need to drive down similarly narrow streets, which all end in cul-de-sacs or dead-ends. There is no way for traffic to flow through. The cul-de-sacs that exist have to be turned around in using a three-point turn with current residential traffic that already park there.

Of greatest concern is the impact to traffic flow, and the fact that this school has a much more highly suitable solution to develop the already existing entrance via Gavenlock Road. This entrance already has a school zone and ample street parking. The only reason residents can see as to why the school instead wants to use Keefers Glen and put burden on residents is due to the fact that developing the Gavenlock Road entrance would reduce the ample green space of the school grounds. This is not good enough, and should be found as an unacceptable reason to allow the development of an entrance/exit via Keefers Glen. By the schools own admission, there is not enough parking on the proposed site, meaning they are aware that the development is going to severely impact residential streets throughout the day (not just at pick up/drop off), but they apparently do not care.

I would like to bring attention to the Council's comments on the proposed development:
-The proposed special needs school will generate considerably higher passenger vehicular movements than other schools of similar size
-Residents amenity will be SEVERELY AFFECTED by traffic and parking generated by the proposal
-Keefers Glen was not constructed to facilitate traffic loading associated with a traffic generating development
-The western boundary of the sit is fully fenced, partly to prevent parents and students accessing the existing school via Keefers Glen
-The existing intersections in the vicinity of Keefers Glen will NOT SUPPORT the swept path of buses
-All access to the new school IS TO BE PROVIDED BY THE EXISTING DRIVEWAY ON GAVENLOCK ROAD

The above only heightens the insult of the Development being proposed. As the council says, this isn't a matter of annoyance at pickup and drop off hours. This is a matter of the breakdown of roads (that already feature numerous potholes from residential traffic only), increased chance of collision between pedestrians and motor vehicles, and the lunacy of suggesting that local residents should 'foot the bill' and carry the burden of traffic generated instead of the school doing the right thing and following council's suggestion to develop the school on their own grounds. It is completely disheartening that they are not using their own land and resource after being informed how significantly unsuited the local roads are.

On social media, overwhelmingly the community is supportive of a school being built to allow more services for school children with disability. This is not about rejecting outright the needs for services, or even the school itself. What the community is overwhelmingly objecting to is the insulting suggestion that the best option is to create an entrance and exit via Keefers Glen, instead of using their own land to upgrade their already existing entrance via Gavenlock road that would stop the community feeling of ill-will. If this Development is rejected as it should be, I am sure the local community would be supportive of the school being built, as long as (and only if) the ONLY access point is via Gavenlock Road.

Although the access point is the main grievance, it is worth noting that there are suggestions that the school will be opened after school hours and on weekend as a facility to be used. Again, these are tiny residential streets. There are no through-roads. There is minimal parking as it is, and anyone parking awkwardly causes it so that residents must drive on the incorrect side of the road to get to their houses. Again, they can have their weekend hours easily if the entrance and exit is strictly via Gavenlock road, not Keefers Glen.

Please, I implore you to listen to what the community is saying. We are supportive of the school being built, but we are not supportive of the school taking advantage of residents and showing us such a blatant lack of respect by submitting the proposal as it stands. Please, they have the money and the land to be able to develop an internal entrance via Gavenlock Road. This is a simple request from the residents of Mardi. We don't want to block children from being able to attend school. We want to block a school from profiting off of tiny, unsuitable tax-payer streets, instead of utilising what they already have.

I have submitted several photos that offer a more true reflection of Keefers Glen and surrounding roads. What is not shown on the digital rendition of Keefers Glen is that there are two dog--legs in the street, both of these dog-legs mean that any traffic coming one way or the other effectively turns the street into a one-way lane, and one car has to pull over to allow passage. This is not uncommon on small streets, but demonstrates how unsuitable the street is to an increase in traffic. The curvature and the steepness of these streets further adds to blind spots and hazardous passage of traffic. Foot traffic similarly need to walk onto the road frequently to get around cars, increasing risk of pedestrian and traffic accidents, which obviously no one wants.

The other photos show that the surrounding streets have islands on them (to try to manage the residential traffic that already poses difficulty in passage on these streets). Even with these islands people park too to corners which leads to having to drive on the wrong side of the road to navigate the streets. There simply is not enough parking for the already existing residents The fact that the proposed development on Keefers Glen admits that it is short of parking by at least 20 cars is not good enough. There is not enough parking available to residents as stands now.

Please, stand with the residents of Mardi AND the potential students of the school. Increase their safety by not massively increasing risk of traffic accidents or worse, by rejecting this proposal until the school submits a proposal that has the entry and exit points via Gavenlock Road only.

I have lived in Brickendon Avenue for the past 6 years with my 2 daughters. I don't object to a school for special needs students. I do object when this school proposes to be built on paddocks that once housed St Peter's College livestock, and which backs onto houses along Brickendon Avenue. We live in a small village like suburb with streets certainly not equipped to manage the disruption caused by the huge machinery that would be needed. I also believe that a three-story high building will allow people to look into our backyards. We have very limited parking available already as lots of houses have two or more vehicles and park on the roadway, so to think we could cope with dozens of workers looking for somewhere to leave their cars is ridiculous. At the beginning and end of a school day you cannot drive down Keefers Glen because of the dozen or so cars waiting for their children who are students at existing College. It is a narrow winding lane meant only for the residents who live here.

I am concerned that the homes will suffer some degree of damage due to demolition, excavation and the removal of a large dam. What happens to the birds who live in tress that will be removed? Kookaburras, Magpies, butcher birds, small minors, lorikeets greet us every morning in our backyards. Red Belly Black snakes and the occasional Blue Tongue Lizard that slither under our fences. What happens when their habitat is bulldozed?

Busses needed to transport these students, plus parent and staff vehicles, will use a driveway that on the plans look to be only a few meters from our back fences. The proposal offers nothing to those of us who live in Cobbs Village except noise, lack of privacy, disruption to those who work from home, barking dogs who will need tranquillizers due to constant movement and noise and increased traffic on no more than lane ways that service our suburb.

I believe there is quite a large parcel of land on Gavenlock Road that would be a better site for this school. It is an industrial area and has no homes to be inconvenienced by building at Keefers Glen. The homes along Brickendon Avenue will have many aspects of this School sitting almost on the boundaries of our properties.

Who thought building a huge school in a small residential area was a good idea? Who thought the people who live here will welcome this proposal with open arms? Who thought that causing disruption to every aspect of our lives would be met with a smile?

Please respect the residents who choose to live in Cobbs Village and build your School in an area that is not residential.

The entrance, school, driveways need to be in gavenlock road. In keefers Glen, Brickendon Avenue, doloriane Glen, streets are a pain as it is when school comes in & goes out, you cannot move in there. 3 storeys high it’s going to be an impact on everyone around with people looking into our yards & houses, not to mention all the wildlife that lives out & around there, what will happen to them? Our lives, our pets lives & everything around will be ruined & if any accidents, people/animals being bitten then it is all on you guys because you approved it & anybody or things that get hurt you will get blamed & sued! Change the damn area into gavenlock road & all the residents will be happy! Otherwise get ready to be fought all the way through the project!

This is a vital educational project for the central coast and will benefit many families and the community. We can’t wait to see the Eileen O’Connor School open and welcome its first students.

m It May Concern,

Subject: Formal Objection to the Proposed Eileen O’Connor Catholic School Development – Mardi

I am writing to express my strong objection to the proposed development of the Eileen O’Connor Catholic School at 84 Gavenlock Road, Mardi, currently under public exhibition on the NSW Planning Portal.

While I support the provision of educational facilities for students with special needs, the current proposal raises serious concerns regarding traffic, infrastructure, and community impact—particularly due to the proposed access via Keefers Glen and Brickendon Avenue.



Traffic and Infrastructure Limitations

Keefers Glen and Brickendon Avenue were never designed to accommodate high traffic volumes. These roads are narrow, with limited passing opportunities and constrained parking. The proposed development will introduce:

Significant daily traffic from community buses transporting students from outside the area.
Construction traffic, including heavy vehicles and up to 100 workers on-site at peak times.
Staff parking overflow, with only 61 spaces proposed for 71 teachers and additional auxiliary staff.
This will severely impact road safety, increase congestion, and reduce amenity for existing residents.



Lack of Suitable Access Planning

The Diocese has not adequately justified why access cannot be provided via Gavenlock Road, which is adjacent to industrial zones and far better suited to handle increased traffic. The current plan funnels all traffic through a quiet residential area, which is both inappropriate and unsustainable.



Impact on Local Amenity and Property Values

The development will disrupt the peaceful character of Cobbs Village and surrounding streets. Residents will face increased noise, reduced safety, and diminished quality of life. Furthermore, the anticipated congestion and disruption are likely to result in a significant devaluation of residential properties in the area.



Environmental Oversight

The site borders environmentally sensitive bushland zoned C2 Environmental Conservation. Increased traffic and construction activity pose risks to this area, yet the planning documents do not adequately address these concerns.



Additional Comments

As a long-term resident, I am deeply concerned that:

The proposal does not include meaningful upgrades to Keefers Glen beyond a short footpath and a widened section near the school.
The design fails to consider the existing limitations of the road network and the burden placed on residents.
The consultation process has been misleading, with many residents initially believing the school would be accessed via the industrial area.


Conclusion

I respectfully request that the Department of Planning and Environment reconsider the access arrangements and overall suitability of this development. A revised plan should include access via Gavenlock Road and a comprehensive traffic impact assessment that genuinely considers the needs of the Mardi community.



Thank you for considering this submission.

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 & NSW development planning to refuse the DA in its current form.

Yours sincerely,
Melissa and John Weatherall.