New Eileen O'Connor School

Subject: Objection to access of the Proposed Eileen O’Connor Special Needs School – Keefers Glen,
Mardi NSW 2259

Dear Sir/Madam

I am writing to formally object to the proposed development of the Eileen O’Connor Special
Needs School on Keefers Glen, Mardi. While I acknowledge the importance of providing
facilities for children with additional needs, I am deeply concerned that the current proposal
fails to take into account the significant impact this development will have on the surrounding
residential community.
1. Traffic and Safety Concerns
Keefers Glen and the surrounding streets in Cobbs Village were designed for a small residential
community and are already narrow and constrained. Introducing a school with 71 teachers
plus auxiliary staff, yet only 61 allocated car spaces, will inevitably lead to overflow parking
and congestion throughout the village. The increased traffic from staff, parents, service
vehicles, and buses will create serious safety risks for residents, including children and the
elderly, who regularly use these streets.
2. Infrastructure Unsuitability
The local road network is not designed to handle the high volume of traffic that a school of this
scale will generate. Unlike larger thoroughfares, the streets in Cobbs Village cannot safely
accommodate frequent pick-ups, drop-offs, and delivery vehicles without causing significant
disruption to residents.
3. Impact on Residential Amenity
This development will seriously affect the quality of life for residents in the immediate area.
Increased traffic noise, congestion, and reduced street accessibility will diminish the peaceful
residential character of the village. Furthermore, such congestion will likely deter potential
buyers, potentially leading to a negative impact on house values within the community.
4. Lack of Consideration by the Diocese
It is disappointing that the Diocese has not adequately considered the impact on the existing
community. While the educational goals of the proposed school are commendable, the chosen
site is entirely unsuitable from an urban planning and community well-being perspective.
For these reasons, I respectfully urge Council to reject the current proposal or, at minimum,
require the Diocese to reassess and identify a more appropriate location that can adequately
support the scale and traffic demands of the school.
Thank you for considering this objection. I trust Council will act in the best interests of the
existing residents of Cobbs Village and the wider Mardi community.

OVERVIEW

As a Mardi resident, I fully endorse this vital special education facility whilst raising serious concerns about the proposed vehicle access arrangements via Keefer's Glen. I urge NSW Planning to approve the school development but require access through Gavenlock Road as advised by Central Coast Council.

ENDORSEMENT OF THE SCHOOL PROJECT

This development represents a crucial advancement in special education provision for the Central Coast. The facility will serve 200 students with disabilities, eliminating the current need for families to travel to Sydney or Newcastle for specialist services. The project delivers on key NSW Government commitments to educational excellence and supporting disadvantaged communities. I wholeheartedly support this important community infrastructure.

TRAFFIC CONCERNS - INAPPROPRIATE KEEFER'S GLEN ACCESS

Traffic Generation Analysis

Transport assessment data reveals concerning vehicle volumes:

213 vehicle movements/hour during morning school peak (8-9am)
156 vehicle movements/hour during afternoon peak (2:30-3:30pm)
Complete vehicle dependency for all students (85% ASTP transport, 15% private cars)
71 staff members requiring vehicle access
This represents unprecedented traffic loading for a narrow residential lane currently serving just 16 homes.

Direct Impact on Our Street

Traffic surveys document current Brickendon Avenue volumes of 93 vehicles/hour (AM) and 77 vehicles/hour (PM). As the primary connection between Woodbury Park Drive and Keefer's Glen, our residential street faces potential traffic increases of 200-300% during school operating hours.

Council's Professional Assessment

Central Coast Council has categorically rejected the Keefer's Glen access proposal, stating:

"Council will not support this proposal"
"The proposed special needs school will generate considerably higher passenger vehicular movements"
"Residents amenity will be severely affected"
"Keefers Glen was not constructed to facilitate traffic loading associated with a traffic generating development"
"All access to the new school is to be provided via the existing driveway on Gavenlock Road"
This represents authoritative technical assessment that the proposed access is fundamentally inappropriate.

Infrastructure Inadequacy

Multiple technical deficiencies exist:

Substandard carriageway width for proposed traffic volumes
Intersection design limitations preventing safe bus movements
Absence of pedestrian infrastructure creating safety hazards
Parking capacity issues displacing essential resident access
GAVENLOCK ROAD - THE APPROPRIATE SOLUTION

Gavenlock Road provides superior infrastructure characteristics:

Proper road classification with adequate design standards
Existing school zone infrastructure including 40km/h speed restrictions
Proven traffic management successfully serving adjacent St Peter's College
Superior intersection design connecting to Woodbury Park Drive collector road
Direct access to State Road (Wyong Road) and Pacific Highway networks
CONSTRUCTION PERIOD IMPACTS

The 18-month construction timeline presents additional concerns:

Heavy vehicle movements through residential streets unsuited to such traffic
Noise impacts exceeding 75dB(A) "Highly Noise Affected" thresholds
Extended disruption preceding permanent traffic increases
Potential negative impacts on residential property values from construction activity and permanent traffic changes
RESIDENTIAL AMENITY AND PROPERTY VALUES

The combination of construction disruption and significant permanent traffic increases poses genuine risks to our neighbourhood's character and property values. The acoustic assessment acknowledges noise will exceed acceptable management levels, whilst traffic volumes represent a fundamental change to our quiet residential environment.

COMMUNITY MOBILISATION

This issue has galvanised residents throughout Mardi, who recognise the school's importance whilst rejecting inappropriate traffic arrangements. The community consultation process identified residents' desire for "wider Keefer's Glen" - however, simply widening to 6 metres cannot address fundamental infrastructure inadequacy for such traffic volumes.

FLOOD RISK MANAGEMENT

While proponents cite flood concerns regarding Gavenlock Road access, emergency management planning can address these issues without forcing inappropriate traffic through residential infrastructure designed for minimal volumes.

POLICY IMPLICATIONS

Approving access explicitly rejected by the responsible traffic authority establishes problematic precedent for prioritising developer convenience over community safety and technical expertise.

RECOMMENDATIONS

I urge NSW Planning to:

Grant approval for this important educational facility
Mandate primary vehicle access via Gavenlock Road per Council recommendation
Restrict Keefer's Glen to emergency access only if any access required
Implement comprehensive traffic monitoring following school opening
This approach delivers essential special education services whilst protecting residential community safety and amenity.

CONCLUSION

This valuable school deserves approval as vital community infrastructure. However, approval must not compromise residential safety through inappropriate traffic arrangements that contradict professional traffic engineering advice.

Central Coast Council's comprehensive technical assessment demonstrates that Keefer's Glen cannot safely accommodate the proposed traffic volumes. Their documented concerns regarding infrastructure capacity, intersection performance, residential amenity, and community safety are well-founded and evidence-based.

Requiring appropriate access via Gavenlock Road ensures this important educational facility can operate successfully whilst maintaining community safety and residential amenity. This represents sound planning that balances competing interests appropriately.

I urge approval of this essential school with mandated access via appropriate infrastructure that can safely accommodate the proposed traffic volumes.

Technical documentation referenced: SSD-67173718 Environmental Impact Statement, Transport & Accessibility Impact Assessment (Traffix Group), Preliminary Construction Traffic Management Plan, Central Coast Council Pre-Development Advice (September 2023, July 2024).

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 assessment.
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. 5.5.1).
• 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 Planning & State Development to refuse the DA in its current form.
Should Council nevertheless contemplate approval of this DA despite the serious concerns raised, I respectfully request that conditions of consent be imposed to mitigate direct impacts on my property, including, but not limited to:
• Relocation or redesign of the proposed driveway opposite my residence to prevent unsafe traffic conflicts;
• Installation of screening measures (fencing, landscaping, acoustic barriers) at the proponent’s expense to protect the privacy, safety, and amenity of my property;
• Any other works Council deems necessary to offset the adverse impacts of the proposed development.
Yours sincerely,
Kaylie Bosshard

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 assessment.
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. 5.5.1).
• 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 Planning & State Development to refuse the DA in its current form.
Should Council nevertheless contemplate approval of this DA despite the serious concerns raised, I respectfully request that conditions of consent be imposed to mitigate direct impacts on my property, including, but not limited to:
• Relocation or redesign of the proposed driveway opposite my residence to prevent unsafe traffic conflicts;
• Installation of screening measures (fencing, landscaping, acoustic barriers) at the proponent’s expense to protect the privacy, safety, and amenity of my property;
• Any other works Council deems necessary to offset the adverse impacts of the proposed development.
Yours sincerely,
Dr. Shannon Bosshard

I am not against the school, I am against the idea of the entry and exit being on Keefers Glen. That street is not designed for the heavy machinery that will be required for this kind of construction let alone the buses that will be required for the school,
The traffic report is that was put in the proposal is incorrect that counter was installed at the end of school term and start of school holidays therefore not offering true representation of traffic flow and came undone from the road days after being installed so there is no way that report is true and should not be taken into account. What about the pedestrians and kids that play in the street? Has any of that been taken into account other than a section of foot path and widening part of Keefers Glen? I don’t believe this is a safe and viable option for the current residents of the surrounding streets when they could use Gavenlock rd as the entry and exit to the new school. What about the residents homes that will potentially be devalued by the entry and exit being put on Keefers Glen? No one can predict how this will affect home prices nor is anyone offering a reimbursement.
I really hope the entry and exit to this school is reconsidered for Gavenlock Rd as the Central coast council proposed. Again I’m not against the school I’m against the entry and exit point on Keefers Glen as are many of the Mardi local residents.
Yours sincerely, Another Keefers Glen resident.

Dear Sir/Madam,
I am writing to object to the proposed development of the Eileen O’Connor School at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and supporting documents, I consider the proposal to be fundamentally flawed in terms of traffic planning, drainage, and neighbourhood impact. On these grounds, I believe the development should not proceed in its current form.
1. Traffic and Road Safety Impacts
The most serious issue is the proposed school access from Keefers Glen, a narrow residential street that is not designed to handle high volumes of daily school traffic. This will inevitably funnel traffic into Brickendon Avenue, a street that already experiences heavy on-street parking. Vehicles are frequently forced onto the wrong side of the road to pass, which will only worsen with school pick-up and drop-off activity.
The situation becomes more dangerous at the intersection of Brickendon Avenue and Woodbury Park Drive, where visibility is already compromised by parked vehicles. Adding concentrated school traffic to this intersection poses a significant safety risk to both motorists and pedestrians.
The school site is directly accessible from Gavenlock Road, a much larger road designed for higher capacity traffic movements. It is strongly preferred by residents that this be used as the primary school entry point. Locating the access on Gavenlock Road would avoid overwhelming Keefers Glen and Brickendon Avenue, and would provide a safer and more appropriate solution consistent with planning requirements for context-sensitive traffic management.
The Transport & Accessibility Impact Assessment has not properly accounted for these realities, nor the cumulative traffic impacts of St Peter’s Catholic College located nearby. The current traffic plan therefore fails to meet the requirements of SEPP (Transport & Infrastructure) 2021 cl. 2.111, which demands safe and efficient transport outcomes for educational facilities.
Ground for refusal: The traffic design is unsafe and inappropriate for the residential setting, with an alternative (Gavenlock Road), available but ignored.
2. Flooding, Drainage and Loss of Dam Capacity

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.
Another serious concern is the proposal to fill in the existing dam on the site. This dam currently plays an important role in local drainage and stormwater management. Removing it will increase runoff towards neighbouring homes and the local parkland, heightening the risk of flooding and waterlogging during heavy rain.
The Flood Impact Assessment does not adequately address this change, nor provide a sustainable drainage alternative that replicates the dam’s capacity. The resulting runoff will directly impact the amenity and safety of surrounding residents and public open space.
Ground for refusal: The removal of the dam undermines local stormwater management and increases flooding risks to adjacent properties and public land.
3. Other Planning Concerns
Noise impacts from playgrounds, PA systems, and potential after-hours use are understated and not properly modelled.
Building bulk and height introduce a three-storey form incompatible with the surrounding one- to two-storey residential character, resulting in overbearing visual impact and privacy loss for neighbours.
Emergency evacuation risks (flood and bushfire) are inadequately planned, with Keefers Glen again identified as the sole access route despite its clear limitations.
Requested Outcome
Given the above issues, I respectfully request that Council refuse this development application in its current form.
If Council is minded to approve the DA, I strongly urge the following minimum conditions:
Relocate the school entry and exit to Gavenlock Road rather than Keefers Glen.
Retain or replace the stormwater capacity of the existing dam to prevent downstream flooding.
Independent peer review of the traffic and drainage assessments.
Limit the building height to two storeys along the residential interface.
Provide enforceable management measures for noise and after-hours use.
Conclusion
This proposal, as currently designed, poses unacceptable risks to road safety, drainage, and neighbourhood amenity. The decision to place the school entry on Keefers Glen is a fundamental flaw when a more suitable alternative exists. For these reasons, I urge Council to refuse the DA unless substantial redesign is undertaken.
Yours faithfully,
Mardi resident

Dear Sir/Madam,
I am writing to object to the proposed development of the Eileen O’Connor School at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and supporting documents, I consider the proposal to be fundamentally flawed in terms of traffic planning, drainage, and neighbourhood impact. On these grounds, I believe the development should not proceed in its current form.
1. Traffic and Road Safety Impacts
The most serious issue is the proposed school access from Keefers Glen, a narrow residential street that is not designed to handle high volumes of daily school traffic. This will inevitably funnel traffic into Brickendon Avenue, a street that already experiences heavy on-street parking. Vehicles are frequently forced onto the wrong side of the road to pass, which will only worsen with school pick-up and drop-off activity.
The situation becomes more dangerous at the intersection of Brickendon Avenue and Woodbury Park Drive, where visibility is already compromised by parked vehicles. Adding concentrated school traffic to this intersection poses a significant safety risk to both motorists and pedestrians.
The school site is directly accessible from Gavenlock Parade, a much larger road designed for higher capacity traffic movements. It is strongly preferred by residents that this be used as the primary school entry point. Locating the access on Gavenlock Parade would avoid overwhelming Keefers Glen and Brickendon Avenue, and would provide a safer and more appropriate solution consistent with planning requirements for context-sensitive traffic management.
The Transport & Accessibility Impact Assessment has not properly accounted for these realities, nor the cumulative traffic impacts of St Peter’s Catholic College located nearby. The current traffic plan therefore fails to meet the requirements of SEPP (Transport & Infrastructure) 2021 cl. 2.111, which demands safe and efficient transport outcomes for educational facilities.
Ground for refusal: The traffic design is unsafe and inappropriate for the residential setting, with an alternative (Gavenlock Parade) available but ignored.
2. Flooding, Drainage and Loss of Dam Capacity
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.
Another serious concern is the proposal to fill in the existing dam on the site. This dam currently plays an important role in local drainage and stormwater management. Removing it will increase runoff towards neighbouring homes and the local parkland, heightening the risk of flooding and waterlogging during heavy rain.
The Flood Impact Assessment does not adequately address this change, nor provide a sustainable drainage alternative that replicates the dam’s capacity. The resulting runoff will directly impact the amenity and safety of surrounding residents and public open space.
Ground for refusal: The removal of the dam undermines local stormwater management and increases flooding risks to adjacent properties and public land.
3. Other Planning Concerns
Noise impacts from playgrounds, PA systems, and potential after-hours use are understated and not properly modelled.
Building bulk and height introduce a three-storey form incompatible with the surrounding one- to two-storey residential character, resulting in overbearing visual impact and privacy loss for neighbours.
Emergency evacuation risks (flood and bushfire) are inadequately planned, with Keefers Glen again identified as the sole access route despite its clear limitations.
Requested Outcome
Given the above issues, I respectfully request that Council refuse this development application in its current form.
If Council is minded to approve the DA, I strongly urge the following minimum conditions:
Relocate the school entry and exit to Gavenlock Parade rather than Keefers Glen.
Retain or replace the stormwater capacity of the existing dam to prevent downstream flooding.
Independent peer review of the traffic and drainage assessments.
Limit the building height to two storeys along the residential interface.
Provide enforceable management measures for noise and after-hours use.
Conclusion
This proposal, as currently designed, poses unacceptable risks to road safety, drainage, and neighbourhood amenity. The decision to place the school entry on Keefers Glen is a fundamental flaw when a more suitable alternative exists. For these reasons, I urge Council to refuse the DA unless substantial redesign is undertaken.
Yours faithfully,
Mardi Resident

As residents of the area, we formally object to the proposed development of the Eileen O’Connor Catholic School. While we support the principle of inclusive education, this project is fundamentally inappropriate for the chosen site.

The scale and placement of the development will cause unacceptable impacts on the immediate community. Our concerns include:

Loss of privacy, amenity, and neighbourhood character due to a large institutional building located within metres of family homes.

Severe traffic and parking issues, compounded by the existing congestion from St Peter’s Catholic College, with council itself having raised concerns about the proposed access route.

Years of disruptive and unsafe construction activity directly beside residential properties, posing health, safety, and wellbeing risks for families and children.

Misrepresentation of the need for this facility, given that specialist schools and programs already exist across the Central Coast.

Long-term financial harm, including diminished property values, for residents most affected.

Misleading documentation, with the school described as fronting Gavenlock Road, when in fact all access is via the narrow residential street of Keefers Glen.

This proposal represents an institutional-scale development being forced into a quiet suburban cul-de-sac. The Environmental Impact Statement fails to adequately mitigate or justify the impacts, leaving local families to shoulder the costs of noise, traffic, pollution, and loss of livability.

For these reasons, we strongly urge that the application be rejected, or at the very least, relocated to a more suitable site where the educational benefits can be delivered without sacrificing the health, wellbeing, and amenity of neighbouring residents.

This site is not appropriate, and this development should not proceed here. the attached document goes into detail on our objection of the proposed school

Gavenlock Rd for entry & exit point!

I am in support of the school, but against the entrance through Keefers Glen & surrounding streets.
This street is full of small children playing. There is no safety measures in this plan. No zebra crossing. No 40km school zone. No footpath or cyclist area.
No slow down with flashing lights for the support children or residents to feel safe.
In fact there is no consideration for the residents AT ALL.

My grandchild attends a primary school support class, and would feel horrible being made to come through the small back streets, like he is hidden and different.

I own a house on keefers Glen where my grandchild lives with his disabilities.
The 7 day per week traffic noise is the worst thing for an autistic child with disabilities. You are taking away his peace & tranquil neighbourhood: the very reason why we bought the house in this street. You are taking away his safe place.
My neighbour has 3 children on the spectrum & this will also affect their living conditions dramatically.
It is cruel.
Where is the compensation for the disruption you are putting on these children & families?

Where is the compensation for taking away our peaceful weekends which will now be replaced by a community hall with 7 day per week traffic & noise?

The plan provides no protection, it takes away ALL street parking, it is NOT supported by council, there are no environmental considerations, there is no consideration to the already full storm water on Keefers Glen, the extremely tight bends of Keefers, Deloraine & Brickedon are not suitable for this traffic AT ALL. Small cars already find it difficult to navigate these streets, so buses & high traffic will cause accidents, road deterioration, congestion and massive noise & health implications for all residents.

The impact on safety includes high fire danger risk to residents and supper children & staff. This includes structure fires & bush fires.

keefers Glen can not take the traffic during an emergency.

The perfect solution (supported by council) is an entrance/exit via Gavenlock Road.
This is what the community wants & see’s as needed for the school & makes no sense to put anywhere else.

The value of my house will now drop due to no privacy, high traffic, high noise & safety concerns.
Where is the compensation for a massive decrease in my house value?

The council and traffic engineers DO NOT support the use of Keefers Glen as the entry & exit to the school.
That is crucial information that is being ignored!

Keefers Glen was NOT built to withstand heavy traffic such as the proposed. It is a narrow lane & can not take ongoing traffic.
We do not need another street constantly filled with pot holes.

In conclusion,
Council, as do Mardi residents, support the entry & exit via Gavenlock road only. This is the easiest & most sensible solution.
The DA is flawed with many inconsistencies, underestimating the massive impact to residents, which include young children (both neurodivergent & neurotypical) and the elderly.

To ignore the advice of the council would be a disgrace.

Council support the entry/exit via Gavenlock Rd, as do the people who actually live in this very tiny & quiet street, which was built for low impact residential traffic only.

Consider the children with disabilities & families who look after them who already live in this tiny street.
It would be cruel to disrupt their lives even further.

I am writing to express my strong support for the proposed development of the Eileen O’Connor Catholic School in Mardi—a state-of-the-art educational facility designed to meet the needs of children with disabilities and additional learning requirements.

The community of Mardi is incredibly fortunate to have such a specialised school located so close. This development will provide a vital service to families across the Central Coast who are seeking high-quality, tailored educational support for their children. At present, there are very limited options for students with additional needs, and many families are desperate for an alternative to mainstream public schools that cannot fully meet their child’s individual learning and behavioural needs.

The Eileen O’Connor Catholic School will not only provide much-needed choice in education but will also contribute to a stronger, more inclusive community. It will bring local employment opportunities and attract dedicated professionals—teachers, therapists, and support staff—who are passionate about helping every child thrive.

I believe this school will be a tremendous asset to our region and a source of hope for many families. I fully support the proposal and encourage the Council to approve the development.

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 road with single vehicle access and minimal off street parking. 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. Keefers Glen has no footpaths and due to the narrow street (and surrounding streets Deloraine Glen) pedestrians are required to walk on the road as there is no safe footpaths and cars are parked on kerbs to allow single vehicle access through the roads

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 that the proposal in its current form is not supported

Yours sincerely,

I am writing to express my strong support for the proposed development of the Eileen O’Connor Catholic School in Mardi—a specialised school dedicated to supporting children with disabilities and additional learning needs.

This school would mark a significant and much-needed advancement for our community. Currently, the Central Coast has limited educational options for students with diverse learning needs. The introduction of this facility would give families greater choice and ensure more children can access individualised, inclusive education in a setting that truly supports their potential.

Beyond the educational benefits, this development would bring lasting value to the suburb of Mardi—creating employment opportunities and drawing skilled professionals such as teachers, therapists, and support staff to the area. This would not only strengthen our local economy but also foster a more inclusive and supportive community.

Most importantly, a school like this sends a clear message: that our community values dignity, equity, and opportunity for all learners. It would be an honour and privilege for Mardi to host a school with such a strong mission and vision for inclusion.

I fully support this proposal and respectfully urge the Council to approve the development. The Eileen O’Connor Catholic School would be a positive and welcome presence in our suburb, and I would be proud to see it become part of Mardi’s future.

“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

SUMMARY
I strongly support this essential special education facility but have serious concerns about the proposed Keefer's Glen vehicle access. I advocate for access via Gavenlock Road as recommended by Central Coast Council.

SUPPORT FOR THE SCHOOL
This facility addresses a critical need for specialised education on the Central Coast, serving 200 students with disabilities and reducing families' need to travel to Sydney/Newcastle. The project aligns with NSW priorities for inclusive education and breaking disadvantage cycles.

TRAFFIC CONCERNS - KEEFER'S GLEN ACCESS
Volume Analysis
The Transport Assessment shows extraordinary traffic loads:
213 vehicle trips/hour (morning peak 8-9am)
156 vehicle trips/hour (afternoon peak 2:30-3:30pm)
100% vehicle dependency (85% ASTP transport, 15% private vehicles)
71 staff all driving to work
This represents a massive increase for a narrow lane serving only 16 dwellings.

Impact on Brickendon Avenue
Current traffic surveys show Brickendon Avenue handles 96 vehicles/hour (AM) and 93 vehicles/hour (PM). As the direct route from Woodbury Park Drive to Keefer's Glen, our street would experience potential doubling or tripling of traffic during school peaks.

Central Coast Council's Opposition
Council has unequivocally rejected Keefer's Glen access, stating:
"Council will not support this proposal"
"The proposed special needs school will generate considerably higher passenger vehicular movements than other schools"
"Residents amenity will be severely affected"
"Keefers Glen was not constructed to facilitate traffic loading"
"All access to the new school is to be provided via the existing driveway on Gavenlock Road"
This represents expert local assessment that Keefer's Glen access is inappropriate and dangerous.

Technical Deficiencies
Narrow carriageway: Never designed for this traffic volume
Intersection capacity: Cannot support bus swept paths
No formal footpaths: Pedestrian safety compromised
Parking displacement: Eliminates resident parking

SUPERIOR GAVENLOCK ROAD ALTERNATIVE
Gavenlock Road offers:
Higher road classification with appropriate infrastructure
Existing school zone (40km/h restrictions)
Better intersection capacity connecting to Woodbury Park Drive
Direct access to Wyong Road (State Road) and Pacific Highway
Established traffic management serving St Peter's College

CONSTRUCTION IMPACTS
18-month construction via Keefer's Glen would create:
Daily heavy vehicle movements through residential area
Noise exceeding 75dB(A) "Highly Noise Affected" levels
Disruption before permanent traffic increases commence
Potential property value impacts from increased traffic and construction

PROPERTY VALUE CONCERNS
The combination of construction disruption and permanent traffic increases through our quiet residential area poses real risks to property values. The noise assessment acknowledges noise levels will exceed management standards, and the traffic volumes represent a fundamental change to neighbourhood character.

COMMUNITY RESPONSE
Residents across Mardi have rallied around this cause, recognising the need for the school whilst opposing inappropriate access arrangements. Community consultation identified "desire for wider Keefer's Glen" - but widening to 6m cannot address fundamental infrastructure mismatch.

FLOOD SAFETY CONSIDERATION
While applicants cite flood concerns about Gavenlock Road, this can be managed through emergency planning rather than shifting inappropriate traffic to residential streets unsuited for high volumes.

PRECEDENT CONCERNS
Approving access explicitly rejected by the traffic authority sets concerning precedent for prioritising applicant preferences over technical safety assessments.

RECOMMENDED SOLUTION
Approve the school development - essential community facility
Require primary access via Gavenlock Road per Council recommendation
Emergency access only via Keefer's Glen if required
Comprehensive traffic monitoring post-opening
This delivers educational benefits whilst protecting residential amenity and safety.

CONCLUSION
This important school deserves support, but not at residential safety expense. Central Coast Council's technical assessment demonstrates Keefer's Glen cannot safely accommodate proposed traffic volumes.
The documented concerns about road infrastructure, intersection capacity, residential amenity, and property values are well-founded and evidence-based.
I urge NSW Planning to approve this valuable school whilst requiring appropriate access via Gavenlock Road. This balanced approach advances educational objectives whilst protecting community safety and amenity.
Technical references: SSD-67173718 EIS, Transport & Accessibility Impact Assessment (Traffix), Preliminary CTMP, Central Coast Council Pre-DA advice September 2023 & July 2024.

I do not and cannot support the plans submitted for the New Eileen O'Connor School. I see the need for such a school and in the right place would add great value to families in our community. However, the current location for the school is completely inappropriate and dangerous. I work daily with children with disabilities and I am extremely fearful of the entry/exit points at Keefers Glen. It is a matter of when not if a fatality will occur in a small road designed for light local traffic. I know the amount of time it takes to get children in and out of cars, a child's awareness of traffic surrounding them etc. Keefers Glen IS NOT SUITABLE OR SAFE for a development of this size. The feeding roads such as Brickendon Avenue is already oversaturated with traffic and parking is a chronic problem. The intersection from Brickendon Avenue onto Woodbury Park Drive has always been an issue with poor visibility when making a right turn. The likelihood of serious accidents with the traffic volume increasing is something the NSW Government should be greatly concerned with. Planning should not have made it to this point based on the quality of feeding roads to the school and the volumes of traffic and lack of parking already in these spaces.
Flooding is another major issue in the local area and the development impacts a water catchment area with no plans disclosed as to where this water will now go with the filling in of areas on the block.
The lack of other essential accessibility infrastructure such as footpaths/bike paths in the roads surrounding the new school entry/exit will put every person, mostly children who walk from the adjoining streets up to the bus stops on Woodbury Park Drive in harm's way. The increased flow of traffic, cars parked on nature strips, many so close to existing traffic islands that force cars to drive in the wrong side of the road to get through will no doubt cause a serious accident endangering the children. All roads in the area are full of major potholes that are frequently filled in but never repaired. The poor quality of surrounding roads, along with increased traffic, especially of large vehicles during the construction phase will cause traffic chaos and car/property damage.
I have read many of the documents sent to home owners and reports from the Central Coast Council who have all objected the build mostly due to the traffic and safety concerns. It saddens me that for the sake of 200 new enrolments this school plans to cater for, the NSW Government are happy to endanger the lives of countless more by creating this development in such an unsafe, careless and ignorant way.
Even the school itself is aware of how much it will affect the local community in a negative way with the strategic locking of the gates in recent weeks to stop the double parking, gridlock traffic that occur every weekday morning and afternoon. A deceptive move from the school to coincide with the opening of the online submissions.
Local community members have been very vocal in their concerns for safety during floods and bushfire seasons. There is no capacity for the large volumes of traffic these catastrophic events will create.
Communities need schools, of course they do, but they need them to be positioned in a suitable area. They need to ensure the safety of the students the school is built for and the safety of the members of the community it is situated within.
I fully disagree with the plans to build the school in its current proposed location.

Re: Objection to the Proposed Development – Eileen O’Connor Catholic School, 84 Gavenlock Road, Mardi (SSD 67173718)
I am writing to formally object to the project for the following reasons.
There are a few senior citizens in this community as per myself who will be greatly impacted by the increased traffic of this proposed school. The daises is aware as they had St Peters close access to their school via Keefers because of the damage, traffic and chaos that was being caused by only a few people. You know want to increase that by over 200. A Number of us in the street have had to replace their storm water drains because people kept driving on our lawns to pick up their kids and damaged it.
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.

I support this project ONLY if the traffic management for entry is from Gavenlock Road and NOT Keefers Glen at Mardi. The local streets around this area are quiet, residential access streets and they are narrow. They shouldn't have buses and multiple cars going there. I believe the school is a great development, but I would only support it if the entry to the school is from Gavenlock Road. This area in Gavenlock Road already has school entry, signage and traffic is aware of the 40 km school zones.
I have lived on Woodbury Park Drive for many years and this road is getting very busy. Living on a corner in Woodbury Park Drive is already difficult to reverse from the driveway safely and the added traffic which would be on Woodbury Park Drive during school drop off and pick up times would escalate the dangers of residents trying to leave their driveways. The other issue would be cars turning right from Woodbury Park Drive. If this occurs from Wagners Place, cars have the sun shining directly in their face as they approach this intersection. The increased traffic will likely result in increased car accidents. If cars are turning right from Woodbury Park Drive into Brickendon Avenue, there is also an increased risk of car accidents as cars are travelling downhill and suddenly have vehicles making a right turn.
I don't agree with the access to the school being from such a quiet street. These narrow streets already have parked cars and the road is not wide enough to accommodate buses and increased traffic. If the development was changed to have the entry to the school via Gavenlock Road at Tuggerah, I would have no opposition to the project. I think Gavenlock would be a safer, more appropriate location to have the entry to the school.

I regularly visit to this small locality and often have witnessed the traffic around school drop off time.
I object to the access plans for this new school due to the already very narrow, small roads in the direct adjacent space.
The school would appear to fit within the space available but the proposed access point is clearly unwise.
The Council’s strong objections are well founded and would be best heeded.