Opal Healthcare Bayview

I live opposite the proposed construction site and wish to express my grave concern about the planned building works, which will affect those directly opposite the site in Annam Road and at its junction with Utingu Place, not to mention our neighbours. While the original nursing home was operating, with staff coming and going, not to mention service vehicles at all hours, parking was already a problem - even now we have to endure the Northern Beaches issue of illegally parked boats, trailers and caravans. An underground car park for the estimated 66 staff, let alone service vehicles, will not mitigate that problem.

We are also very concerned about the impact the proposed construction of this new 3-storey + building will have on the environment, including the presence for the last 5 years or so of nests of the endangered square-tailed kites, not to mention numerous sea eagles. It would be a tragedy if these are impacted and more wildlife is lost around us.

Most importantly, I am also aware the proposed development fails to comply with council and government planning frameworks - so how can it possibly proceed legally?

I am all for the provision of beds in aged care - these are essential as the population ages and grows - but who will be able to afford this premium accommodation? Not those who need it.

Three years of excessive construction noise and dust pollution, nowhere to park, and the loss of important wildlife habitats - the ruin of a beautiful, peaceful and community-minded enclave - all to fill the pockets of overseas developers, investors and shareholders. Please at least reconsider the size and lengthy timeframe of this proposed construction.

I object to the Opal Healthcare Bayview development for the following reasons

Obtrusive Scale:

The scale of the proposed development is highly inconsistent with the existing character of the area, both in terms of aesthetic compatibility and logistical impact.

Safety Concerns:
The substantial increase in traffic volumes and the presence of heavy construction and service vehicles present a significant hazard to both residents and workers.
Key concerns include:
Loading Dock Vehicle Egress: Large vehicles exiting the loading dock will directly obstruct oncoming traffic, necessitating traversal onto the opposing lane for access. This is particularly hazardous near the crest of the steep hill, where visibility is restricted for traffic traveling downhill towards Cabbage Tree Road or entering Annam Road from Utingu Place.
Bus Stop Location: The positioning of the bus stop creates a potential for head-on collisions as vehicles attempt to overtake a stopped bus while navigating parked cars.
Roundabout Access: The entrance to the proposed roundabout drop-off area is situated directly opposite Utingu Place, which is positioned on a blind crest, raising significant safety concerns.
Peak Hour Traffic Increase: Peak period traffic entering and exiting Annam Road from Cabbage Tree Road is projected to increase considerably. The Traffic and Transport Peer Assessment (TTPA) review observed no heavy vehicles between 4 and 5 pm, with minimal observations at other times. Upon commencement of construction and post-development completion, the frequency and type of heavy vehicles entering and exiting will escalate exponentially. This will lead to traffic congestion and heighten the risk of accidents, particularly for vehicles queuing to access Annam Road from the east (Appendix P, page 58).

Sensitive Fauna:
The Australian square-tailed kite (Lophoictinia isura), listed as Vulnerable, nests annually in a tree located at the rear of 101a Annam Road. The species utilizes the surrounding trees for perching and foraging. This observation has been omitted from the predicted fauna table (Table 11) in the Biodiversity Development Assessment Report (BDAR).
In addition, white-bellied sea eagles (Haliaeetus leucogaster) have been regularly observed perching in the canopy above the existing Bayview Gardens driveway opposite Utingu Place (refer to attached photographs). The proposed construction work is anticipated to have a detrimental effect on the hunting and perching opportunities available to this Vulnerable species which has also been omitted from the BDAR.
Further to this, no owl species are currently listed in the BDAR table. Powerful Owls (Ninox strenua), listed as Vulnerable, are regularly heard calling at night in the canopy situated above the entrance to Utingu Road.

Loss of Trees:
Appendix X indicates that 38 healthy trees will require removal, which represents almost 50% of the trees within the development envelope. This is considered ecologically and aesthetically unacceptable.

Noise and Dust Impact on Residents:
Having purchased property in this area four years ago for the peace and tranquility it offers, we are deeply concerned that this development is under consideration. Residents face detrimental impacts from noise and dust during the three-year construction period, which is likely to result in adverse mental health outcomes and compromise opportunities for working from home.
According to Appendix R: NOISE AND VIBRATION IMPACT ASSESSMENT FOR SSDA, there is a predicted increase of 2 vehicles per hour. This is considerably lower than one would anticipate for a 177 bed facility and definitely not representative of the 3 years during construction.

Inadequate Parking Facilities During Construction
The project plans indicate a significant shortfall in parking and access for construction workers over the estimated three-year construction period. With an anticipated 103 full-time equivalent (FTE) construction workers (as stated on page 29 of the Environmental Impact Statement), the document must clearly detail where these workers will park.

Parking on completion of construction:
It is noted that there will be a provision of an additional 11 spaces above the SEPP Housing (Residential Care Facilities) guidelines for parking allocation. However, as this will be a “high care” facility providing specialised care to high dependency residents, this ratio of parking spaces to residents and staff seems insufficient, given that many of the staff will be highly trained health care professionals who may undertake shiftwork elsewhere and thus will be unable to rely on the limited public transport on offer.
Street parking will therefore increase which, in turn will pose a road safety risk and congestion for residents.

Misrepresentation of public transport usage to final destination:
In appendix P, Transport and Parking Assessment, the primary mode of transport to the Bayview area is started to be by train (31%) which is anticipated to increase to 35% after 3 years. This does not account for the final leg of the workers’ journeys as there are no train stations in this locality and limited bus services. Workers will either travel by public bus (15% after 3 years), by car (40%), or by Opal minibus from transport hubs, the frequency of which has not been determined in appendix P and will contribute to the impact on traffic and noise generation.

In Summary:
Whilst provision of facilities for our aging population is a high priority for the state government, it should not be at the risk of losing precious natural habitat and endangering multiple vulnerable species. Nor should it transform residential areas into healthcare precincts with limited infrastructure to support developments of this scale and impact.

I am a resident of Bayview. I am deeply upset by this proposal and the way it has been presented to our community. I object to the Opal Healthcare Bayview development (SSD-77240466) because, in its current form, it is not appropriate for this neighbourhood, it is not in keeping with the local character, and it will cause long-term harm to the amenity, safety and environmental integrity of our community.
This proposal represents a significant intensification of built form and activity in what is fundamentally a low-rise, green residential area. Under the Environmental Planning and Assessment Act 1979 (NSW), the consent authority must consider the likely impacts of development, including environmental, social and economic impacts, and whether the proposal is in the public interest (EP&A Act s 4.15). The State Significant Development (SSD) Guidelines also require that an Environmental Impact Statement clearly assess impacts, be transparent and respond to community concerns.
In my view, the exhibited Environmental Impact Statement does not demonstrate that:
- The development is compatible with the environmental character and scale of Bayview.
- The surrounding residential streets can safely accommodate the scale and duration of construction and operational traffic.
- Pollution impacts (light, noise, stormwater and ecological impacts) have been properly addressed.
- Traffic and parking impacts will not overwhelm Annam Road and nearby streets.
- The applicant has engaged with the community in a transparent and ethical manner.
As a resident of this small Bayview community, I object to this proposal based on:
- Environmental character and bulk/scale – not in keeping with Bayview.
- Construction and neighbourhood disruption – Annam Road and surrounding streets cannot cope.
- Pollution and ecological impacts – light, wildlife and environmental harm.
- Traffic, parking and road safety – substantial increase with inadequate mitigation.
- Conduct, transparency and public interest concerns.
I respectfully request that the Department defer determination and require substantial redesign and further information. If these matters cannot be resolved to an assessment-ready standard, the application should be refused.
ENVIRONMENTAL CHARACTER, BULK AND SCALE
Bayview is a low-rise, leafy residential suburb defined by two-storey homes, mature trees and a quiet environment. This proposal introduces a large three (or possibly four) storey institutional building with significant length and bulk. Regardless of terminology, this is a major built form for this locality.
Tokenistic gestures have been made to “match” materials to surrounding trees, yet insufficient effort has been made to retain the actual green environment provided by mature canopy. The concern is not simply height. It is the length, visual dominance and institutional scale that is incompatible with surrounding homes.
The applicant relies on Clause 4.6 variations to development standards. Clause 4.6 requires the consent authority to be satisfied that compliance is unreasonable or unnecessary and that sufficient planning grounds justify the departure. In a suburb defined by openness and greenery, bulk and scale that materially alter the streetscape cannot be justified purely by operational efficiency or bed numbers.
This proposal would permanently change the feel of the neighbourhood: reduced openness, increased built mass, institutional presence replacing residential character and loss of canopy. The EIS understates this character shift. It appears no meaningful attempt has been made to step down mass toward boundaries, reduce bed numbers, maximise tree retention or respect the existing streetscape rhythm. The design appears driven by yield. Bayview deserves better.
CONSTRUCTION IMPACT – SMALL RESIDENTIAL STREETS CANNOT COPE
The EIS indicates a construction program exceeding a year. Realistically, with staging and delays, disruption may extend to two or three years. Even one year of heavy construction is overwhelming for a small residential street.
Annam Road and nearby streets already experience parking pressure. During construction, trades will park locally, delivery vehicles will queue and heavy vehicles will manoeuvre on constrained roads. There is no credible, enforceable workforce parking strategy.
Annam Road is steep and constrained, with limited visibility. Buses already struggle up the hill, creating noise and congestion. Introducing construction trucks, waste trucks and increased vehicle movements raises serious safety concerns. Construction noise, vibration and heavy traffic over a prolonged period fundamentally affect residents’ ability to live peacefully in their homes.
This is not short-term inconvenience. It is long-term disruption. A project of this scale demands a shortened build program, reduced footprint, strict workforce parking controls, defined truck routes and enforceable monitoring. The EIS does not provide confidence this will occur.
POLLUTION AND ECOLOGICAL IMPACT
Light pollution is already an issue in parts of the existing Aveo site. Residents on Annam Road have experienced glare and night illumination that has not been adequately addressed. This proposal introduces basement entry lighting, security lighting, pathway lighting and internal spill from a large building. In a previously low-light environment, this materially alters night amenity. Without strict controls and shielding, the night character of Bayview will change permanently.
Noise pollution is also a concern. Operational sources include constant vehicle movements, staff shift changes, ambulances, waste collection, visitors and vehicles climbing the steep hill. The cumulative impact is understated.
Bayview is home to wildlife. Residents have observed bush turkeys nesting on the site near the proposed driveway, an active red kite nest across the street and echidnas near neighbouring properties. These are part of our lived environment. Vegetation removal and prolonged disturbance affect nesting, feeding and movement patterns. The biodiversity assessment must be site-specific and seasonal. Loss of mature canopy affects habitat, stormwater infiltration, urban heat and biodiversity resilience. Replacing mature trees with saplings is not equivalent mitigation.
TRAFFIC, PARKING AND ROAD SAFETY
A 177-bed facility with peak staffing of over 60 per shift inevitably generates significant vehicle movements. Even with proposed parking, demand is unlikely to accommodate staff, visitors, specialists, servicing vehicles and ambulances. On-street parking is already constrained.
We are also concerned that the proposed turning arrangements at the crest of a hill is inadequate for waste trucks, emergency vehicles and deliveries. In constrained conditions, unsafe reversing or manoeuvring may occur. Also Annam Road’s steep gradient amplifies engine noise from buses and other vehicles. With side street intersections, limited visibility, kerbside parking and pedestrian movement, this development intensifies risk. The Department must ensure road safety is not compromised.
CONDUCT, TRANSPARENCY AND PUBLIC INTEREST
Planning decisions must consider the public interest. Community trust matters.
Current healthcare residents have reported that representatives suggested promises of an improved clubhouse (which we believe is unrelated to this development), assurances of limited construction noise and encouragement not to object. If accurate, this conduct is concerning. Planning consent must not be influenced by private inducements.
“Vacant site” narrative: The applicant has described parts of the site as vacant. We understand some dwellings have been allowed to remain uninhabited (with a view to encourage this building plan- dishonest). This framing presents the land as underutilised, when in reality it sits within an established community context.
The SSD Guidelines require transparent engagement and documentation of community issues and responses. Many residents feel their concerns have been minimised or dismissed. We’ve only had one community zoom call and none of our questions or concerns have been taken into consideration. Public confidence in the process is critical.
In closing, this proposal is not in keeping with Bayview’s low-rise, green character. It introduces excessive bulk, overwhelms residential streets during prolonged construction, increases traffic and parking pressures, creates under-assessed light and ecological impacts and raises transparency concerns.
I respectfully request that the Department require substantial redesign, reassess traffic, biodiversity and pollution impacts, impose enforceable construction management measures, re-exhibit any material amendments and refuse the application if these issues cannot be resolved.
Bayview is a quiet, green residential community. This development, as proposed, is simply too big for this place. We are not opposing aged care. We are opposing inappropriate scale and harm to our neighbourhood.
Thank you.

Department of Planning, Housing and Infrastructure
NSW Government
Submission regarding State Significant Development Application
Opal Healthcare Bayview – SSD-77240466
36–42 Cabbage Tree Road, Bayview
Submission Type: OBJECTION
I formally object to the proposed State Significant Development Application SSD-77240466 for the Opal Healthcare Bayview redevelopment at 36–42 Cabbage Tree Road, Bayview.
While the need for quality aged care facilities is acknowledged, the current proposal raises serious concerns regarding safety, access design, traffic impacts, and the scale of development relative to the surrounding area.
1. Unsafe Driveway Design and Non-Compliance with AS2890.2
The proposal includes a new driveway connection to Annam Road where the road has an approximate 17.5% longitudinal grade. Due to this steep grade and site constraints, the proposed driveway design results in a crossfall that exceeds the 5% maximum limit specified under AS2890.2 for commercial vehicle access.
The applicant attempts to justify this departure from the national standard using a performance-based engineering assessment. This justification relies on several operational assumptions, including:
• Garbage trucks limiting their speed to approximately 5 km/h
• Restricting vehicle movements to left-in and right-out only
• Assuming the driveway crossfall will act as superelevation during turning movements
• Incorporating a localised transition to reduce the crossfall effect
However, this approach raises significant concerns.
Firstly, the design relies heavily on assumed driver behaviour and operational controls, such as maintaining very low speeds. In practice, these conditions cannot be guaranteed over the long term, particularly where waste contractors, service providers, delivery vehicles or emergency vehicles may change.
Secondly, the reliance on crossfall functioning as superelevation assumes consistent vehicle paths and ideal driving behaviour. Real-world conditions such as driver error, wet road surfaces, vehicle load variations, or larger vehicle types may increase the risk of instability.
Thirdly, the proposal explicitly acknowledges that the driveway geometry does not comply with the prescriptive requirements of AS2890.2. These standards exist to ensure safe access for heavy and commercial vehicles. Departures from these standards should only occur where there is clear evidence that risks are fully mitigated.
While the applicant claims that modelling indicates Load Transfer Ratio (LTR) and lateral acceleration remain below rollover thresholds, such modelling relies on assumptions and controlled conditions. The presence of high-centre-of-gravity vehicles such as garbage trucks using an access point on a steep road grade with excessive crossfall presents an inherent safety concern.
Given that this access will be used by waste collection vehicles, service vehicles, ambulances and other large vehicles servicing a 177-bed aged care facility, the risk associated with a non-compliant driveway design is unacceptable.
2. Traffic and Access Impacts
A facility accommodating 177 residential care beds will generate significant traffic movements from staff, visitors, contractors, service vehicles and emergency vehicles. The redevelopment of the Annam Road driveway and the introduction of additional heavy vehicle movements may increase traffic volumes on local streets not designed for frequent heavy vehicle access.
This may create congestion, safety risks and reduced amenity for local residents.
3. Insufficient Parking Provision
The proposal provides 68 basement car parking spaces, which appears insufficient for a development of this size when considering staff, visitors, contractors and service vehicles. Insufficient on-site parking is likely to result in overflow parking in surrounding residential streets.
4. Overdevelopment of the Site
The scale of the proposed three-storey development accommodating 177 beds represents a substantial intensification of use compared with the existing development. The bulk, density and institutional scale of the proposal may negatively impact the character of the surrounding residential environment and neighbouring properties.
5. Construction and Community Impacts
The demolition of existing buildings and construction of a large aged care facility will result in significant construction impacts including noise, dust, heavy vehicle movements and disruption to nearby residents and the neighbouring retirement community.
Conclusion
For the reasons outlined above, I strongly object to the proposed development.
In particular, the proposed driveway design represents a significant departure from the safety requirements of AS2890.2 and relies on operational assumptions rather than compliant design to manage heavy vehicle access on a steep road grade. This creates unnecessary and avoidable safety risks.
I respectfully request that the Department of Planning, Housing and Infrastructure refuse the application in its current form or require substantial redesign to address the safety, traffic and scale concerns identified above.
Thank you for the opportunity to provide comment on this proposal.
Sincerely,
Simon Copeland
48 Cabbage Tree Road Bayview, NSW 2104

Main objection is that Cabbage Tree Road cannot support heavy vehicles currently involved in local building projects. The road develops holes unsafe for traffic and traffic congestion (observed during a recent sewer upgrade which only lasted 2 months). Unless upgraded these problems would only intensify during a 3 year project. Similar problems in Annam Rd would seriously compromise the safety for local traffic and pedestrians as the proposed entrance is next to a key intersection in close proximity to a blind corner. I contend that a 160 bed aged care facility does not warrant the high cost and attendant safety problems which would occur.

I write to formally object to the proposed development of a 160-bed aged care facility in Bayview, New South Wales.

While the provision of aged care accommodation is important, the scale and location of the proposed development raises several significant concerns regarding environmental impact, traffic, and suitability of the site for a high-density aged care facility.

1. Impact on Natural Landscape and Wildlife Habitat

The proposed development site is located within an area of significant natural landscape value that provides important habitat for native wildlife. Of particular concern is the presence of the Square-tailed Kite, which is recognised as a threatened species in New South Wales and has a known nesting site within the locality.

Large raptors such as the Square-tailed Kite are highly sensitive to disturbance, particularly during breeding and nesting periods. Development activity, increased human presence, construction noise, vegetation removal, and ongoing operational disturbance may have a detrimental effect on the species’ breeding success and long-term habitat viability.

Given the ecological significance of this species, it is essential that the proposal demonstrates strict compliance with the NSW Biodiversity Assessment Method (BAM) requirements, including any mandatory species-specific buffer zones designed to protect nesting sites. It is not clear from the available documentation whether the development can meet these requirements without compromising the existing habitat.

The loss or disturbance of critical habitat for a threatened species should be treated as a matter of serious environmental concern.

2. Vegetation Loss and Landscape Character

The Bayview area is valued for its natural bushland setting and relatively low-density development. The scale of a 160-bed facility represents a substantial intensification of land use that may result in significant vegetation clearing and alteration of the natural landscape.

Such changes risk undermining the environmental character that defines the locality and provides habitat connectivity for a range of native species.

3. Traffic and Local Infrastructure Impacts

A development of this scale will inevitably generate a substantial increase in traffic due to:

Staff commuting to and from the facility

Visitor traffic

Service and delivery vehicles

Medical and transport services

It is unclear whether the surrounding road network and local infrastructure can adequately accommodate this increased traffic volume. Have appropriate traffic surveys been undertaken?

The planning assessment should include a detailed and transparent traffic impact analysis demonstrating that local roads can safely manage the additional traffic load without creating congestion, safety hazards, or negative impacts on nearby residents.

4. Suitability of the Location for an Aged Care Facility

Another important consideration is whether the proposed site is appropriate for a large aged care facility housing vulnerable residents.

Aged care residents often include individuals with mobility limitations or cognitive conditions such as dementia. Locating a large facility on or near a busy road raises legitimate concerns regarding:

Resident safety

Noise impacts on elderly residents

Overall suitability of the environment for individuals requiring a calm and secure setting

A quieter, less traffic-intensive location may be more appropriate for residents who require a safe and peaceful environment.

5. Scale and Density of the Proposal

The size of a 160-bed facility represents a significant intensification of land use within a relatively low-density and environmentally sensitive area. Consideration should be given to whether a smaller scale development or an alternative site would be more appropriate and compatible with the surrounding environment.

Conclusion

For the reasons outlined above, I respectfully request that the consent authority carefully consider the environmental, traffic, and suitability concerns associated with this proposal.

In particular, the potential impacts on the habitat of the threatened Square-tailed Kite, compliance with the NSW Biodiversity Assessment Method, the capacity of local infrastructure to support the increased traffic, and the appropriateness of the site for a large aged care facility should all be rigorously assessed before any approval is granted.

Given these unresolved concerns, I urge the consent authority to either refuse the application or require substantial revisions and further environmental and traffic assessment before proceeding.

I would like to object to the proposed development of a 160-bed aged care facility in Bayview, New South Wales.

While the provision of aged care accommodation is important, the scale and location of the proposed development raises several significant concerns regarding environmental impact, traffic, and suitability of the site for a high-density aged care facility.

1. Impact on Natural Landscape and Wildlife Habitat

The proposed development site is located within an area of significant natural landscape value that provides important habitat for native wildlife. Of particular concern is the presence of the Square-tailed Kite, which is recognised as a threatened species in New South Wales and has a known nesting site within the locality. This birds active nesting site is within 300m of the proposed development and the species credit has not been recognised in the ecological studies conducted at this time.

Large raptors such as the Square-tailed Kite are highly sensitive to disturbance, particularly during breeding and nesting periods. Development activity, increased human presence, construction noise, vegetation removal, and ongoing operational disturbance may have a detrimental effect on the species’ breeding success and long-term habitat viability.

Given the ecological significance of this species, it is essential that the proposal demonstrates strict compliance with the NSW Biodiversity Assessment Method (BAM) requirements, including any mandatory species-specific buffer zones designed to protect nesting sites. It is not clear from the available documentation whether the development can meet these requirements without compromising the existing habitat.

The loss or disturbance of critical habitat for a threatened species should be treated as a matter of serious environmental concern.

2. Vegetation Loss and Landscape Character

The Bayview area is valued for its natural bushland setting and relatively low-density development. The scale of a 160-bed facility represents a substantial intensification of land use that may result in significant vegetation clearing and alteration of the natural landscape.

Such changes risk undermining the environmental character that defines the locality and provides habitat connectivity for a range of native species.

3. Traffic and Local Infrastructure Impacts

A development of this scale will inevitably generate a substantial increase in traffic due to:

Staff commuting to and from the facility

Visitor traffic

Service and delivery vehicles

Medical and transport services

It is unclear whether the surrounding road network and local infrastructure can adequately accommodate this increased traffic volume. Have appropriate traffic surveys been undertaken?

The planning assessment should include a detailed and transparent traffic impact analysis demonstrating that local roads can safely manage the additional traffic load without creating congestion, safety hazards, or negative impacts on nearby residents.

4. Suitability of the Location for an Aged Care Facility

Another important consideration is whether the proposed site is appropriate for a large aged care facility housing vulnerable residents.

Aged care residents often include individuals with mobility limitations or cognitive conditions such as dementia. Locating a large facility on or near a busy road raises legitimate concerns regarding:

Resident safety

Noise impacts on elderly residents

Overall suitability of the environment for individuals requiring a calm and secure setting

A quieter, less traffic-intensive location may be more appropriate for residents who require a safe and peaceful environment.

5. Scale and Density of the Proposal

The size of a 160-bed facility represents a significant intensification of land use within a relatively low-density and environmentally sensitive area. Consideration should be given to whether a smaller scale development or an alternative site would be more appropriate and compatible with the surrounding environment.

Conclusion

For the reasons outlined above, I respectfully request that the consent authority carefully consider the environmental, traffic, and suitability concerns associated with this proposal.

In particular, the potential impacts on the habitat of the threatened Square-tailed Kite, compliance with the NSW Biodiversity Assessment Method, the capacity of local infrastructure to support the increased traffic, and the appropriateness of the site for a large aged care facility should all be rigorously assessed before any approval is granted.

Given these unresolved concerns, I urge the consent authority to either refuse the application or require substantial revisions and further environmental and traffic assessment before proceeding.

Submission Objecting to Development Application SSD-77240466

To: NSW Department of Planning, Housing and Infrastructure

We write to formally object to the proposed development (SSD-77240466). This submission is made in accordance with the public exhibition provisions of the Environmental Planning and Assessment Act 1979.

Under section 4.15 of the Act, the consent authority must consider the likely environmental, social and amenity impacts of the development, the suitability of the site, and the public interest. For the reasons outlined below, the proposal raises significant concerns that appear inconsistent with these statutory considerations.

1. Traffic safety impacts on Annam Road
The proposal will significantly increase vehicle movements on Annam Road, a narrow residential street with existing safety constraints including:
- steep grades and multiple hills
- blind crests and restricted sightlines
- parked vehicles narrowing the carriageway
These conditions already create hazardous driving situations and limited reaction time for drivers. Increased traffic volumes associated with the development would materially increase the risk of accidents and pedestrian conflict.

Annam Road functions primarily as a local residential street, not a distributor road designed to accommodate higher traffic volumes. Increased development-generated traffic is therefore inconsistent with the intended function of the road network.

Under section 4.15 of the Environmental Planning and Assessment Act, developments must demonstrate that they do not result in unacceptable impacts on the safety and efficiency of surrounding infrastructure. The increased traffic associated with this proposal raises significant concerns regarding:
- pedestrian safety
- child and elderly resident safety
- vehicle conflict at blind crests and constrained sections of the road
Unless substantial traffic mitigation measures are introduced and independently verified, the development risks creating unacceptable safety outcomes for local residents.

2. Excessive building height and incompatibility with local character
The proposed building heights appear excessive relative to the surrounding built environment and landscape context.

The locality within the Northern Beaches Council area is characterised by:
- low-density residential housing
- modest building scale
- strong bushland and natural landscape character
The scale and massing of the proposed buildings are inconsistent with this established character and would create a visually dominant built form that is out of scale with the surrounding neighbourhood.

Planning controls within the Northern Beaches Local Environmental Plan 2018 and the Northern Beaches Development Control Plan 2018 emphasise that development should:
- respond sensitively to the existing landscape setting
- maintain compatibility with the surrounding built form
- protect the natural bushland character that defines the Northern Beaches
The proposed height and bulk risk degrading this character and setting an undesirable precedent for over-development in an area that is valued for its low-density, bushland setting.

3. Prolonged construction impacts on residential amenity
The proposed construction timeline of between one and three years represents a prolonged period of disruption for surrounding residents.

Major construction activity over this timeframe is likely to result in:
- persistent noise and vibration
- dust and air quality impacts
- increased heavy vehicle movements
- safety risks associated with construction traffic

These impacts will materially reduce residents’ ability to enjoy their homes and neighbourhood in peace, privacy and safety.

Under section 4.15 of the Environmental Planning and Assessment Act, the consent authority must consider impacts on residential amenity and the broader public interest. Extended construction of this duration in a quiet residential area would impose a disproportionate burden on nearby residents.

If the development were to proceed, significantly stronger conditions would be required to minimise construction impacts, including stricter construction hours, traffic management measures, and staged delivery to reduce disruption.

Conclusion
For the reasons outlined above, the proposal raises serious concerns regarding:
- traffic safety on Annam Road
- incompatibility with the established low-density bushland character of the area
- prolonged and unreasonable impacts on residential amenity during construction

These impacts call into question whether the proposal satisfies the statutory considerations under the Environmental Planning and Assessment Act 1979 and whether it is consistent with the planning objectives for the Northern Beaches area.

Accordingly, we request that the NSW Department of Planning give substantial weight to these concerns and either:
- refuse the application in its current form, or
- require significant design and traffic modifications to address the impacts identified.

Dear Sir/ Madam

OBJECTION TO DA – Proposed 177‑Bed Opal Aged‑Care Facility, Bayview
Submitted by residents of 109 Annam Road


I, David Tocquer, the residents of 109 Annam Road, wish to lodge a strong objection to the proposed 177‑bed Opal aged‑care development at Bayview. Our home is directly impacted by the traffic, safety, biodiversity, environmental, and construction risks associated with this proposal. We have lived with, observed, and endured the consequences of even small‑scale nearby construction, and we can therefore speak with firsthand experience about the dangers and disruptions this project will create.
This submission outlines our objections based on personal lived experience, verified NSW planning policies, and environmental protections that apply to this Conservation‑zoned area.

1. The Site Is in an Environmental Protection / Conservation Zone – High Ecological Value
NSW Planning has confirmed that former Environmental Protection zones (E2, E3, E4) have been formally renamed as Conservation Zones C2, C3 and C4, and that this renaming did not change the purposes, sensitivity, or stringent environmental protections that apply. The zones remain specifically intended for land where conservation of biodiversity, ecological systems, scenic values, and natural landscapes is the primary purpose.
This location forms a critical biodiversity buffer between:

-the Mona Vale Road high‑density corridor,
-the Mona Vale commercial and residential centre, and
-the Ku‑ring‑gai / Pittwater National Park.

We live each day surrounded by protected species that, frankly, we are surprised still remain given the scale of surrounding urbanisation. Their continued presence demonstrates the importance of maintaining continuous habitat corridors — one of the core reasons C‑zones exist. NSW ecological criteria for conservation zoning include threatened species habitat, endangered ecological communities, riparian corridors, wetlands and fauna movement pathways. These must be verified and protected using robust environmental evidence before any development is considered.
A 177‑bed institutional facility, operating 24/7 with heavy traffic and servicing, is fundamentally incompatible with the Environmental Conservation (C2) and Environmental Management (C3) objectives, which require low‑impact land uses only and prioritise environmental protection as the primary land use purpose.

2. Incompatibility With the Buffer Function of This Sensitive Area
With the planned intensification under the Mona Vale Place Plan, this pocket of Bayview becomes even more critical for biodiversity protection. High‑density proposals around Mona Vale Road make this green corridor the only remaining natural buffer between urban intensification and the national park.
Introducing what is effectively a hotel‑scale, high‑visitation, high‑traffic institutional complex in the middle of a Conservation zone is environmentally irresponsible and contradicts the purpose of these zones.

3. Cumulative Impact With Existing 262‑Dwelling “Aveo Bayview Gardens”
It is unclear whether DPHI or the proponent have seriously considered the cumulative environmental and traffic impact of this proposal given that the site sits immediately adjacent to the 262‑dwelling Aveo Bayview Gardens retirement complex.
The presence of this large, existing development already places significant pressure on the local environment and road network. NSW conservation‑zone guidance explicitly states that any additional development in C‑zones must not intensify land use, must protect ecological values, and must avoid fragmentation of habitat.
Adding a second major aged‑care facility directly beside the first is inconsistent with these requirements.

4. Traffic Generation – Documented NSW Standards Show Severe Impacts
The scale of this proposal will generate 200–300 vehicle movements per day, with peak‑hour surges during staff shift changes, deliveries and ambulance operations. NSW traffic assessment requirements specify that developments generating 50+ vehicles per hour may trigger formal roads‑authority review obligations under the Environmental Planning & Assessment Regulation 2021 (Reg 128).
The NSW Guide to Integrated Transport Assessments (Austroads Part 12 + TfNSW GTIA 2024/25) confirms that large institutional developments must be assessed against road safety, environmental effects, network capacity, and parking impacts due to their major transport footprint.
Furthermore, the Transport & Infrastructure SEPP 2021 requires TfNSW consultation for traffic‑generating development categories listed in Schedule 3, and councils must consider impacts on safety, congestion, access and parking before approval is granted.

Given the narrow, constrained, poorly visible and heavily parked nature of Annam Road, the increased traffic poses unacceptable safety risks.

5. Personal Road Safety Experience at 109 Annam Road
As residents at 109 Annam Road, we experience daily road safety dangers, especially during school pickup times:

Our children must cross the lower section of Annam Road after getting off the school bus.
Visibility is extremely limited due to parked cars, utes, boats, trailers and buses.
Vehicles frequently travel down the hill at high speed, creating dangerous conditions for pedestrians, cyclists and other vehicles.
There is no room for error — sightlines are almost non‑existent, and the road is already at de‑facto traffic capacity.

Adding hundreds of additional daily vehicle movements, including shift‑time peaks, service trucks, and ambulances, will push this fragile road system beyond safe limits.

6. Construction Impacts – Evidence From the Recent Community Hall Renovation
The proponent suggests construction impacts will be minor. This is demonstrably false based on our lived experience.
A few months ago and still ongoing, the simple renovation of the community hall, directly opposite our home, resulted in:

High noise levels from early morning until late afternoon
Significant traffic disruption
Parking saturation, including contractors parking:

-in the bus stop,
-on both sides of the road,
-on grassed verges,
-in ways obstructing visibility


Buses forced to pick up schoolchildren in the middle of the road
Contractors moving in and out with no visible management
No sign of council oversight or enforcement
A general sense of risk and unmanaged hazard

This was a tiny project, yet it severely affected community safety and amenity.
A three‑year institutional‑scale construction program involving excavation, concrete pours, cranes, heavy vehicles and contractor fleets will be far worse and is entirely unsuitable for a narrow environmental corridor road.
Conservation zone guidance explicitly requires minimisation of disturbance, noise, vibration and ecological harm during development, which is simply not feasible at this scale in this location.

7. Environmental Effects: Noise, Lighting, Habitat Fragmentation
An aged‑care facility of this scale includes:

24/7 lighting
Continuous staff movements
Ambulance arrivals day and night
Waste, medical, linen and food service trucks
Large sealed parking areas (60–90+ spaces)

These create light spill, noise pollution, vibration, and habitat fragmentation — all of which conflict with the core purpose of Conservation zones. NSW environmental guidance states that fauna disturbance, vegetation loss and environmental noise must be avoided or strictly minimised in C‑zones, particularly at night when nocturnal species are active.

8. Seniors Housing Restrictions in Sensitive or Bushfire‑Prone Areas
NSW Planning identifies that seniors housing and “special fire protection” facilities face specific location restrictions in environmentally sensitive and bush‑fire prone lands, requiring rigorous safety and evacuation justification. This may further constrain the feasibility of the proposed development in this area. [planning.nsw.gov.au]

Conclusion
Based on our firsthand experience at 109 Annam Road, combined with NSW Planning’s own environmental and transport policies, this site is inherently unsuitable for a 177‑bed aged‑care facility.
The proposal:

Contradicts the purpose of Conservation zones
Threatens rare biodiversity and habitat continuity
Creates dangerous traffic and road safety risks
Adds cumulative impacts to the already large Aveo Bayview Gardens
Introduces severe, prolonged construction harm
Fails key transport, environmental and planning requirements

For these reasons, we respectfully request that DPHI rejects the proposal in its current form.

Regards
David Tocquer

Richard Juracich
101 Annam Rd Bayview.
11/3/26

To Whom it May Concern,
Opposing Opal Healthcare Bayview SSD 77240466
I wish to formally oppose the proposed Opal Healthcare Bayview development (SSD 77240466). I also reserve the right to add an addendum to this submission at a later date should further information become available.
1. Sewage System Capacity and Environmental Risk
The existing sewage infrastructure in the area is already unable to cope with current demand. The Warriewood Sewage Treatment Plant is operating beyond its effective capacity, as evidenced by the regular sewage flooding at the Bayview Golf Club. This is not a hypothetical concern—it is an ongoing, documented issue.
Adding a development of this scale, with additional toilets and wastewater load, will place further pressure on a system that is already failing. It is reasonable to expect:
• Increased frequency of sewage overflows
• Greater risk of untreated sewage entering local waterways and the ocean
• Direct impacts on swimmers, marine life, and the broader coastal environment
The current sewage system cannot support the proposed development, and proceeding without major infrastructure upgrades would be irresponsible and unsafe.
2. Transport and Infrastructure Limitations
The transport network surrounding the proposed site is already inadequate. Existing roads experience congestion, limited public transport options, and constrained access points. Introducing a high density development will worsen traffic flow, reduce safety, and place additional strain on an already stretched transport system.
No evidence has been provided to demonstrate that the transport network can support the increased demand.
3. Lack of Privacy Planning and Consideration for Existing Residents
There has been no privacy plan presented, nor any meaningful consideration of the impact on neighboring residents. The scale and height of the proposed development will significantly affect the privacy, amenity, and daily lives of those living nearby.
4. Ambient Light and Noise Impacts
The proposal fails to address the impacts of 24 hour ambient lighting and noise, which will affect residents’ wellbeing, mental health, and the ability of children to study and sleep. These are not minor concerns—they directly affect quality of life.
5. Safety, Driveway Access, and Parking Issues
The development raises serious concerns regarding:
• Driveway safety
• Increased traffic entering and exiting the site
• Insufficient parking provisions
These issues will create hazards for residents, visitors, and road users.
6. Request for Panel Site Visit
Given the scale of the concerns and the real world impacts already visible in the community, we invite the panel to visit the site, meet with local residents, and observe firsthand the constraints, risks, and environmental pressures that this development would exacerbate.
In summary, this submission is based on the clear and demonstrable fact that the current sewage, transport, and local infrastructure cannot cope with a development of this scale. The proposal fails to address environmental risks, resident privacy, safety, and amenity impacts. For these reasons, I strongly oppose SSD 77240466.
Regards,

Richard Juracich

I write to formally object to the proposed development of a 160-bed aged care facility in Bayview, New South Wales.

While the provision of aged care accommodation is important, the scale and location of the proposed development raises several significant concerns regarding environmental impact, traffic, and suitability of the site for a high-density aged care facility.

1. Impact on Natural Landscape and Wildlife Habitat

The proposed development site is located within an area of significant natural landscape value that provides important habitat for native wildlife. Of particular concern is the presence of the Square-tailed Kite, which is recognised as a threatened species in New South Wales and has a known nesting site within the locality.

Large raptors such as the Square-tailed Kite are highly sensitive to disturbance, particularly during breeding and nesting periods. Development activity, increased human presence, construction noise, vegetation removal, and ongoing operational disturbance may have a detrimental effect on the species’ breeding success and long-term habitat viability.

Given the ecological significance of this species, it is essential that the proposal demonstrates strict compliance with the NSW Biodiversity Assessment Method (BAM) requirements, including any mandatory species-specific buffer zones designed to protect nesting sites. It is not clear from the available documentation whether the development can meet these requirements without compromising the existing habitat.

The loss or disturbance of critical habitat for a threatened species should be treated as a matter of serious environmental concern.

2. Vegetation Loss and Landscape Character

The Bayview area is valued for its natural bushland setting and relatively low-density development. The scale of a 160-bed facility represents a substantial intensification of land use that may result in significant vegetation clearing and alteration of the natural landscape.

Such changes risk undermining the environmental character that defines the locality and provides habitat connectivity for a range of native species.

3. Traffic and Local Infrastructure Impacts

A development of this scale will inevitably generate a substantial increase in traffic due to:

Staff commuting to and from the facility

Visitor traffic

Service and delivery vehicles

Medical and transport services

It is unclear whether the surrounding road network and local infrastructure can adequately accommodate this increased traffic volume. Have appropriate traffic surveys been undertaken?

The planning assessment should include a detailed and transparent traffic impact analysis demonstrating that local roads can safely manage the additional traffic load without creating congestion, safety hazards, or negative impacts on nearby residents.

4. Suitability of the Location for an Aged Care Facility

Another important consideration is whether the proposed site is appropriate for a large aged care facility housing vulnerable residents.

Aged care residents often include individuals with mobility limitations or cognitive conditions such as dementia. Locating a large facility on or near a busy road raises legitimate concerns regarding:

Resident safety

Noise impacts on elderly residents

Overall suitability of the environment for individuals requiring a calm and secure setting

A quieter, less traffic-intensive location may be more appropriate for residents who require a safe and peaceful environment.

5. Scale and Density of the Proposal

The size of a 160-bed facility represents a significant intensification of land use within a relatively low-density and environmentally sensitive area. Consideration should be given to whether a smaller scale development or an alternative site would be more appropriate and compatible with the surrounding environment.

Conclusion

For the reasons outlined above, I respectfully request that the consent authority carefully consider the environmental, traffic, and suitability concerns associated with this proposal.

In particular, the potential impacts on the habitat of the threatened Square-tailed Kite, compliance with the NSW Biodiversity Assessment Method, the capacity of local infrastructure to support the increased traffic, and the appropriateness of the site for a large aged care facility should all be rigorously assessed before any approval is granted.

Given these unresolved concerns, I urge the consent authority to either refuse the application or require substantial revisions and further environmental and traffic assessment before proceeding.

As a local business owner with a shop front in Mona Vale, I wish to make an additional submission on behalf of my clients and local business community, who I have spoken at length with.

I am in opposition to the proposed Opal Healthcare Bayview development (SSD‑77240466). I also reserve the right to add an addendum to this submission at a later date should further information become available.

Sewage Infrastructure Capacity and Environmental Risk

A key issue that requires further scrutiny is whether the existing sewer infrastructure servicing the Bayview and Warriewood catchment has sufficient capacity to accommodate the additional wastewater load generated by this development.

Under NSW planning and environmental law, development consent authorities must consider whether essential infrastructure, including sewer services, has adequate capacity to support the proposed development. Where infrastructure is already constrained, approval may be inappropriate unless clear upgrades or capacity improvements are demonstrated.

There are ongoing community concerns regarding sewage overflows and capacity limitations associated with the Warriewood Sewage Treatment Plant and surrounding sewer network. Incidents of sewage flooding in nearby areas suggest that the system may already be operating under stress.

Approving a development of this scale without clear evidence of sufficient sewer capacity could increase the risk of:
-Sewage overflows during peak load events
-Discharge of untreated or partially treated wastewater into nearby waterways
-Degradation of coastal water quality and marine ecosystems
-Public health risks for swimmers and the broader community.

Given the sensitivity of the local coastal environment, it is critical that the consent authority require clear confirmation from Sydney Water that the sewer network and treatment plant have adequate capacity to support the development without increasing environmental risk.

Environmental and Biodiversity Considerations

Under the Biodiversity Conservation Act 2016 (NSW), development proposals must assess and avoid significant impacts on threatened species and ecological communities, including impacts to habitat and breeding areas. Where threatened species or important habitat may be present, the development must be appropriately assessed under the Biodiversity Assessment Method (BAM) and demonstrate that impacts can be avoided, minimised, or offset.

Given the environmentally sensitive coastal setting of Bayview and the presence of remnant vegetation and wildlife habitat in the surrounding area, it is essential that the proposal fully considers potential impacts on local biodiversity. Any disturbance to vegetation, habitat connectivity, or breeding areas should be subject to thorough ecological assessment to ensure compliance with the Biodiversity Conservation Act 2016 and to protect local wildlife populations.

In addition, the proximity of the site to coastal waterways means that the proposal must be carefully assessed to ensure it does not contribute to water pollution or degradation of marine ecosystems. Protection of coastal water quality is a critical environmental priority under NSW planning legislation, and any development that risks increasing pollutant loads, sedimentation, or sewage discharge into waterways must be rigorously assessed and mitigated.

Transport and Infrastructure Limitations

The surrounding transport network already experiences congestion and limited capacity. Local roads have constrained access points, and public transport options are VERY limited. A development of this size will increase daily vehicle traffic from employee traffic, service and delivery traffic, and visitor traffic.

It is also important to note that traffic from the development will feed onto Cabbage Tree Road which is a notoriously dangerous road and has in fact been formally identified by Northern Beaches Council as road safety blackspot.

Introducing a high‑density development will place additional strain on an already stretched transport system. Without clear mitigation measures or infrastructure upgrades, the proposal risks worsening traffic congestion and reducing road safety for residents and pedestrians.

No evidence has been provided to demonstrate that the transport network can support the increased demand. I urge NSW Planning and Northern Beaches Council to conduct detailed assessments of the current traffic flow along Annam Road and Cabbage Tree Road.

We feel it is imperative that the NSW Planning panel visits the site to meet with local residents to listen to their concerns and experience first-hand the risks the development proposes.

In summary, the proposal fails to address environmental risks, transport and infrastructure capability, and road safety impacts. For these reasons, I oppose the development.

Regards
Jen - Owner of Sôlt Haus Mona Vale

I strongly object to the project, as highlighted in the attached objection.

The scale of the proposed development is far beyond what Bayview can reasonably sustain. Its size, limited to no screening, and intensity are incompatible with the surrounding low‑density residential area, and it threatens to overwhelm local infrastructure that was never designed to accommodate a facility of this magnitude.

One of the most pressing concerns is the safety risk created by the proposed new driveway and main entry. The planned access point sits on a section of road that already experiences challenging traffic conditions. Introducing a high‑volume entryway for staff, service vehicles, and emergency transport will only increase the likelihood of accidents. Residents, pedestrians, cyclists, and school‑aged children who use these routes daily would be placed at unnecessary risk.

Equally troubling is the impact this development would have on Bayview’s fragile ecosystem. The area is home to diverse native flora and fauna, including species that rely on the existing bushland corridors for survival. Large‑scale clearing, increased noise, artificial lighting, and ongoing operational activity would disrupt these habitats irreversibly. Once this ecological balance is damaged, it cannot be restored.

Our community is not opposed to aged‑care services; we recognise their importance. However, developments must be appropriately scaled, safely designed, and environmentally responsible. This proposal fails on all three counts.

It is demonstrably not in keeping with the local area, despite the tokenistic measures taken in the submission to match colours of cladding to trees!

Further, the existing sewage infrastructure in the area is already unable to cope with current demand. The Warriewood Sewage Treatment Plant is operating beyond its effective capacity, as evidenced by the regular sewage flooding at the Bayview Golf Club. This is not a hypothetical concern—it is an ongoing, documented issue.
Adding a development of this scale, with additional toilets and wastewater load, will place further pressure on a system that is already failing.

I also reserve the right to add an addendum to this submission at a later date should further information become available.

Dear Sir/Madam,
I am a local resident living close to the proposed development site, and I wish to formally object to the proposal.
After reviewing the exhibited EIS, I am concerned that several key Housing SEARs requirements have not been addressed to an assessment‑ready standard. The proposal also appears to depend on cross‑title arrangements, yet the documentation does not demonstrate that these arrangements will be legally enforceable or reliable for the full lifespan of the development.
The projected construction period of around three years will have a significant and ongoing impact on the surrounding community. This level of disruption should be recognised and assessed as a cumulative social impact, rather than being treated as a short‑term or minor inconvenience.
I am also particularly concerned about asbestos management. Although the EIS states that no asbestos contamination has been identified, the demolition of older buildings always carries a risk. My concern is not theoretical—my father‑in‑law passed away due to asbestos exposure, and I am acutely aware of the long‑term health consequences. For this reason, I believe the project must include a clear, enforceable stop‑work and testing protocol should asbestos be discovered during demolition, to protect both workers and nearby residents.
In addition, the EIS appears to overlook the presence of a mature square‑tailed kite nest near the site. This requires proper investigation and mitigation to ensure compliance with environmental protections.
Thank you for considering my submission,

We strongly object to this development in Annam Rd. There have been several fatalities on Cabbage Tree Rd close to Annam Rd over the years given that it is a dangerous and narrow road with several blind corners, it already cannot cope with the volume of traffic that uses this road, particularly at peak hour. Increasing the population and users of roads such as this will increase the danger not to mention the congestion.
The construction of such a large dwelling DOES NOT protect the amenity of the established residential area. It is out of character with the area. Local residents and their amenity should be prioritised over corporate profits and greed!

I write to formally object to State Significant Development Application No. SSD-77240466, which seeks approval for the construction of a three-storey building for aged care services.
I am concerned that this proposal, does not adequately address its environmental, infrastructure, amenity, and community impacts. My objection is to the scale, siting, and potential consequences of this specific development.
1. Build Form, Height and Neighbourhood Character
The proposed three storey building appears inconsistent with the prevailing build form and character of the surrounding area (particularly if the locality is predominantly low-density or two-storey development).
Concerns include:
• Excessive height and bulk relative to adjoining properties.
• Visual dominance and overdevelopment of the site.
• Incompatibility with existing streetscape character.
• The proposal risks setting an undesirable planning precedent for similarly scaled developments in the locality.
2. Privacy, Overlooking and Overshadowing
The increased height and building footprint raise significant amenity concerns for neighbouring residents:
• Direct overlooking from upper-storey windows and balconies.
• Loss of privacy in private open spaces and living areas.
• Overshadowing of adjoining properties, particularly during winter months.
• Reduced solar access to neighbouring dwellings and gardens.
3. Traffic and Parking Impacts
An aged care facility generates a consistent flow of:
• Staff traffic (shift changes, including early morning and late evening periods).
• Visitor vehicles.
• Service and delivery vehicles.
• Ambulance and medical transport access.
Concerns include:
• Inadequate on-site parking provision.
• Overflow parking in surrounding residential streets, currently residential streets are being used by existing AVEO residents and staff, which is already overflowing
• Increased congestion during peak staff shift changes
• Potential safety risks for pedestrians, particularly young children and elderly residents in the area.
4. Noise and Operational Impacts
Potential concerns include:
• Mechanical plant noise (air conditioning, generators, exhaust systems).
• Early morning and late-night staff activity.
• Waste collection and service vehicle movements.
• Outdoor activity areas and communal spaces adjacent to property boundaries.
5. Site Suitability and Resident Wellbeing
The suitability of this particular site for a multi-storey aged care facility requires careful scrutiny.
Key considerations include:
• Adequate natural light and cross-ventilation.
• Emergency vehicle access and evacuation procedures.
• Proximity to compatible land uses (avoiding excessive traffic corridors or incompatible commercial activity).
6. Infrastructure and Services Capacity
The development will increase demand on local infrastructure, including:
• Water and sewer capacity.
• Stormwater management systems.
• Electricity supply.
• Local health and emergency services.
Conclusion
While I recognise the importance of aged care services, I submit that Development Application No. SSD-77240466 should be refused due to its excessive scale, potential amenity impacts, infrastructure strain, and insufficient mitigation measures.
I request that this objection be formally recorded and considered as part of the assessment process.

Lorena Millett
101 Annam Rd Bayview 2104
3/6/26

To Whom It May Concern,
I am writing to register my strong objection to the proposed Opal Healthcare Bayview development (SSD 77240466). While I appreciate the importance of aged care services, this particular proposal raises serious and unavoidable concerns regarding its impact on local wildlife, fragile ecosystems, and the long term environmental health of the Bayview area.
The site identified for this development is part of a sensitive natural corridor that supports a wide range of native species. This includes birds, reptiles, and small mammals that rely on the existing vegetation and habitat connectivity for survival. Clearing or fragmenting this land would result in the displacement of wildlife, the loss of biodiversity, and the degradation of an already pressured ecosystem. Once these habitats are destroyed, they cannot be meaningfully restored.
Beyond the direct ecological damage, development poses broader environmental risks. Increased hard surfaces and land disturbance will contribute to stormwater runoff, erosion, and reduced water quality in surrounding waterways. These impacts extend far beyond the boundaries of the site and will be felt by the wider community and local environment for decades.
Bayview residents have consistently expressed a desire to protect the natural character of the area. This proposal conflicts with those values and undermines the environmental protections that should guide responsible planning decisions. Sustainable development must balance human needs with ecological preservation, and in this case, that balance has not been achieved.
The proposed new driveway and entrance is a direct hazard to the community and our children. The proposed location is on a blind spot of the hill, and the road is not wide enough to accommodate buses, residents’ traffic, Opal staff and ambulances. This is truly a dangerous location; the government will have blood on their hands as there will defiantly be accidents and hopefully no fatalities.
As residents we approve of the use of the existing driveway and all new development to rename behind the existing tree canopy and foliage.
I respectfully request that SSD 77240466 be reconsidered, and that a comprehensive, independent environmental assessment be undertaken—one that fully accounts for the cumulative impacts on wildlife, habitat connectivity, and the broader ecosystem. Our community deserves development that enhances, rather than diminishes, the natural environment we are entrusted to protect.
Thank you for considering my concerns.
Sincerely, Lorena Millett

I am a resident of 103 Annam Road, located opposite the proposed development site.

While I recognise the importance of aged care services, the proposal for a 160+ bed (the latest proposal is for 177 beds), 24-hour facility in our neighbourhood is extraordinarily selfish and in direct opposition to local character and residential amenity.

The construction phase (potentially 3 years*) will cause prolonged disruption to myself and my neighbours – noise, traffic, road closures, dust and emissions.
*During resident engagement, concern was raised that the practical delivery timeframe may extend close to three years once demolition, excavation, staged construction, approvals, utility works, weather delays and site constraints are accounted for. The EIS presents a shorter program, and it does not demonstrate a contingency-based “worst-case” duration. Given residents bear the cumulative impacts, the assessment should include a “worst-case” scenario to give residents the full picture.

The long-term implications are also alarming:
A 160+ bed facility operating 24-hours a day will affect our safety, privacy, and lifestyles.
There will be a significant increase in traffic at all hours and an influx of staff and visitors coming and going, which will create constant noise disruption.
Light pollution is also a big concern for the residents in the immediate areas. There are at least 10 houses that face right onto the proposed development site, with main living areas and bedrooms all at the front of the house.
Placing the facility entrances directly opposite existing family homes, on a dangerous section of road (blind corner, blind crest) also poses safety risks in a neighbourhood with a high number of young children and pets.
In addition it presents concerns for privacy. For example, my home’s key living areas and kids' bedrooms face out onto the road and will be in direct sight of the facility.
It will create lasting environmental impacts from increased emissions, waste generation, noise and light pollution. Most concerningly, it will threaten our wildlife habitats - square-tailed kites (endangered), sea eagles and bush turkeys all nest within 100m of site.

I am in opposition to the development.
Please recognise the unreasonable burden (safety, privacy, lifestyle, property value) this proposal places on the residents in the area.
The planning outcome needs to balance essential aged care provision with the protection of established residential amenity and local character.

Regards
Jen

Dear Sir/Madam,
My name is Lily Juracich, and I am a 15 year old student who lives in the Bayview area. I am writing to formally object to the proposed Opal Healthcare Bayview development (SSD 77240466). Even though I’m young, this project will directly affect my daily life, my community, and my future, so I hope my concerns will be taken seriously.
🌿 1. Loss of Green Space and Environmental Impact
The Bayview area is one of the few places where young people like me can still enjoy nature without having to travel far. The proposed development will remove important green areas that local families, students, and wildlife rely on. These spaces are where many of us walk, exercise, relax, and feel safe. Losing them would make our neighborhood feel more crowded, noisy, and less connected to nature.
🚗 2. Increased Traffic and Safety Concerns
As a teenager who walks and catches public transport to school, I’m really worried about the extra traffic this project will bring. The roads around Bayview are already busy, especially during school hours. More construction vehicles and long term traffic from the facility will make it harder and more dangerous for young people to get around safely.
🏘️ 3. Impact on Community Character
Bayview has always been a peaceful, low density area. It’s one of the reasons families choose to live here. A large scale development like this doesn’t match the character of our neighborhood and will change the feeling of the community I’ve grown up in. I believe developments should respect the identity of the area and the people who live here.
💭 4. Mental Wellbeing and Youth Spaces
Young people need places that support our mental health — quiet areas, open spaces, and a sense of belonging. Replacing natural areas with a large facility reduces the limited spaces we already have. It feels like our needs as young residents aren’t being considered in the planning process.
📣 5. Lack of Youth Consultation
I also feel that teenagers and young adults haven’t been included in discussions about this project. Decisions like this shape the environment we will inherit, so it’s important that our voices are heard too.
For these reasons, I respectfully ask that the project be reconsidered or redesigned to better protect the environment, community character, and safety of young people in Bayview.
Thank you for taking the time to read my objection. I hope you will consider the impact this development will have on the next generation.
Sincerely,
Lily Juracich

Submission in Objection
State Significant Development SSD 77240466
Opal Healthcare Bayview - 36 to 42 Cabbage Tree Road Bayview NSW

My dwelling is directly opposite the proposed vehicle access and Annam Road frontage of the development. I object to the proposal on the grounds of excessive built form, significant vegetation loss and unreasonable cumulative impacts pursuant to section 4.15 of the Environmental Planning and Assessment Act 1979.

Height and Built Form
The proposal exceeds the applicable 9.5 metre height control under the Housing SEPP and the 8.5 metre height limit under the Pittwater LEP 2014. Under Clause 4.6, a variation must demonstrate that compliance is unreasonable or unnecessary and that sufficient environmental planning grounds justify the contravention. The proposed building presents as a substantial three storey institutional form across the Annam Road frontage in a streetscape characterised by detached two storey dwellings.

Under section 4.15(1)(a) and (b), the consent authority must consider the provisions of relevant planning instruments and the likely impacts of development on the built environment. The height exceedance materially alters the scale, bulk and visual dominance of development and has not demonstrated compelling environmental planning grounds. Sustainability initiatives in the ESD Report do not require exceedance of the height control.

Visual Impact and Shadowing
The architectural submission includes height plane diagrams and shadow studies. Even if minimum solar access benchmarks are technically achieved, section 4.15(1)(b) requires assessment of likely impacts on the locality. The combined effect of height exceedance and removal of mature canopy trees will increase visual enclosure and perceived bulk when viewed from 95 Annam Road. The development replaces vegetated outlook with an extended three storey façade and reduces the established landscaped character of the street.

Vegetation Loss
The Arboricultural Impact Assessment confirms removal of 38 prescribed trees including high significance canopy trees, with additional removals recommended. Under section 4.15(1)(b), environmental impacts on the natural environment must be considered. Encroachments into tree protection zones occur as a direct consequence of the building footprint and driveway works, indicating the design has prioritised built form over retention of established canopy.

Replacement planting cannot replicate the environmental and amenity value of mature trees for decades. The cumulative effect will be diminished streetscape character, reduced privacy and increased exposure to built form.

Traffic and Operational Impact
The Transport Assessment forecasts an additional 32 to 41 vehicles per peak hour added to existing peak flows of approximately 694 to 726 vehicles per hour on Annam Road. While below the statutory traffic generating threshold, section 4.15(1)(b) requires consideration of localised amenity impacts. The proposed driveway is opposite my property. Staff shift changes, visitor arrivals, service vehicles and ambulance movements will intensify activity at this frontage. Headlight glare, idling vehicles, delivery movements and concentration of access at a single point will materially affect residential amenity.

Construction and Civil Works
The civil documentation indicates substantial basement excavation, retaining structures and engineered driveway works. This level of site intervention reinforces the intensity of development relative to its residential setting. Under section 4.15(1)(c), the consent authority must consider the suitability of the site. The combination of height exceedance, extensive vegetation removal, traffic concentration and basement excavation raises legitimate concerns as to whether this site is appropriate for development of this scale.

If approved, strict conditions should be imposed including pre and post construction condition reports for 95 Annam Road, vibration monitoring during excavation, controlled truck routing and restrictions on vehicle queuing opposite residences.

Public Interest
Under section 4.15(1)(e), the consent authority must consider the public interest. While aged care provision is supported in principle, approval of a development that exceeds height controls, removes substantial established canopy and intensifies a quiet residential street would not represent balanced or context sensitive planning.


For the reasons outlined above, I submit that the proposal does not satisfactorily address the requirements of section 4.15 of the Environmental Planning and Assessment Act 1979.

I respectfully request that the consent authority require substantial modification including reduction in bulk, improved upper level setbacks, greater retention of established trees along Annam Road and strengthened traffic and operational controls. Absent such modification, the application should not be approved in its current form.