Pathways Rose Bay Seniors Housing

1. The Pathways project over-develops the site and is out of character with the medium-sized developments typical of the area. The proponents of this project seek to leverage the current "neighbourhood" allure of the Rose Bay precinct whilst doing their utmost to destroy it with their over-sized development plan.

2(a) Neighbouring properties of the project and properties in the Rose Bay Settlement Area face significant, irreversible adverse impacts due to significant geotechnical and hydrological risks acknowledged by Douglas Partners in their "Report on Geotechnical Investigation", which admits that only limited bore hole testing was undertaken and that the risks can only be adequately assessed after the site is cleared and monitoring of excavation outcomes commences. In particular, the proposed deep two-level basement, excavation and dewatering pose serious risks to nearby buildings (foundations and walls), infrastructure and groundwater conditions during and after construction. The occupants of the Pathways complex also face the real risk that their aged accommodation units will experience cracking due to the uncertainty surrounding hydrostatic pressure caused by fluctuating groundwater levels and the impact on the basement "tanks" which may not be capable of withstanding the subterannean forces which occur post-construction. The NSW Government should be particularly mindful of the fact that the occupants of the Pathway buildings (aged and possibly infirm) could need to be rehoused or offered alternative emergency accommodation whilst remedial building works are undertaken. The last place the NSW Government wants another "Mascot Towers debacle" is in an aged care facility.

2(b). As the approving authority, the NSW Government should consider who bears the financial risk for damage as a result of the geotechnical and hydrological risks associated with this project. Rose Bay residents and occupants of the proposed development deserve to know what financial protection is in place for those who suffer proven development-related damage. In the wake of the recent Barthla collapse, it is clear that:
(i) the use of special purpose vehicles by developers which shield them and their financial backers;
(ii) "no liability" clauses in expert reports commissioned by developers and relied upon by approving authorities;
(iii) the inability of purchasers / neighbours to obtain insurance cover for builder-related damage; and
(iii) the limited impact to date of the Building Commission NSW,
means the NSW Government has a building liability / regulatory problem which needs to be urgently addressed.

3. The project fails Woollahra Council LEP and DCP controls, has no regard for the amenity of those living nearby, exacerbates local traffic and parking problems, and does not adequately address landscape, drainage or waste-management requirements.

4. The applicant and its expert advisers seek to have the merits of this project considered without reference to the many large Rose Bay development projects already approved or at the application stage. Rose Bay residents rightly expect the NSW Government and Woollahra Council to see the "big picture" of Rose Bay / Eastern Suburbs development and not be fooled by applicants who urge government officials to adopt a myopic, project by project, approach.

5. Setbacks and visual dominance: Basement and side setbacks are inadequate, increase excavation risk, fail ADG separation expectations, and would create a visually oppressive wall-like impact for an urban landscape that borders and overlooks the Rose Bay Primary School.

6. Overshadowing and amenity: The height, bulk and proximity of the Pathways buildings would significantly reduce sunlight, outlook, natural ventilation, warmth, garden amenity and solar viability for neighboring properties.

7. Privacy and noise: The project creates unacceptable overlooking from balconies, rooftop terraces and upper levels. There will also be construction and operational noise impacts. The truck movements and parking for tradies etc for this and other nearby approved Rose Bay projects will also add to the existing traffic mayhem in Wilberforce Avenue and Dover Road, especially around school pick-up times at Rose Bay Primary and McCauley Catholic Primary. [Note that there is no traffic-light controlled intersections to facilitate access to/from Wilberforce Avenue.]

8. Traffic and parking: The TTPA "Traffic and Parking Assessment" substantially underestimates existing congestion, future cumulative traffic impacts of Rose Bay / Eastern Suburbs development, public transport capacity issues, construction disruption, lack of visitor parking and increased demand for scarce on-street parking.

9. Landscaping and public areas. The project provides inadequate landscaping and public areas (especially gardens) to occupants. This is a real-estate, profit-making venture. It will not create a caring, peaceful environment for the aged where relatives and visitors can spend quality time with loved ones.

10. Drainage and stormwater: Both Woollahra Council and Sydney Water should be concerned about the substantial amount of pumped groundwater during excavation and the sand and acids it may contain.

We strongly object to SSD-100912708 (20-30 Wilberforce Avenue & 33-39 Dover Road, Rose Bay).

Main reasons:

1. I have learnt that this area is within a "high-risk settlement area", which means that deep excavations (for two-level basements for 140 car spaces) into saturated loose marine sands here would be very hazardous, resulting in e.g. altered groundwater movement, drainage, inundation risks & pedestrian hazards. We know that damages have already occurred beside much smaller excavations in the immediate Rose Bay area!.
2. I have also learnt that cumulative risk assessments for this and for the other five major developments proposed on the single Wilberforce Avenue/Dover Road block have not been carried out, which we find to be a serious omission.
3. If damage occurs while multiple other major excavations are occurring in close proximity, it will be challenging which developments caused the damage. This raises important questions about liability and insurance. So, will the NSW Government provide an indemnity or other compensations for residents who suffer proven development-related damage.?
4. We have also learnt that a total of 94 trees will be removed to give way for this and for the other five huge construction. In this day and age, it is appalling that this would be approved, as this would result in loss of shade, causing increased heat in the spring, summer and autumn months.
5. The Dover Road/Ian Street/NSH Rd interactions & the Wilberforce Avenue/Newcastle Street/NSH Rd intersections are very congested and busy, especially in peak hour times. The large increase in traffic (as a result of many more cars in the area, with the planned 500 basement car spaces across the six developments) will undoubtedly cause further congestion, with grave pedestrian safety concerns. And school-children drop off/and pickups for the Rose Bay Public School will be an absolute nightmare for parents and children, and for everyone who needs to will drive on Wilberforce Avenue.

And, very importantly, I also would like to express that I feel that new LMR rules and regulations implemented by the NSW government not only would greatly destroy the current amenity of Rose Bay, it will also, much more importantly, not provide any affordable housing in the Rose Bay area.

Thank you in advance for your consideration.

Yours sincerely,
Bengt Peder Martin Kastengren
3/9 Wilberforce Avenue, Rose Bay
0415 556 260
[email protected]

I am strongly opposed to proposed development SSD - 100912708

If the development proceeds as described, a high level of risk will be generated for exisiting property owners along Wilberforce Avenue, and in nearby streets. This is due to the site consisting of 25–30m of highly permeable marine sands before sandstone is encountered, and the high level of the water table.

The site covered by this proposal, along 20-30 Wilberforce Ave is one of 5 proposed adjacent development sites stretching from the council carpark in the west, to Spencer Lane in the east, all involving deep excavations.

Were these developments to proceed, an impermeable subterranean wall would be built along Wilberforce Ave, and another covering the same width along Dover Rd.

Over time, properties along the northern Dover Rd side would see their properties impacted by rising water, blocked by the subterranean wall. Properties along the southern Wilberforce side would be impacted by a lowering of the water table.

These outcomes are not just theoretical. Recent developments in neighbouring streets with just one level of basement excavation have seen 9 documented instances of impact to adjacent properties. Owners at 60 Wilberforce Ave suffered a collapse caused by an adjacent single level excavation.

Three of the highest regarded geotechnical and hydrological engineers in NSW have assessed the adjacent site of 12-18 Wilberforce Ave and the probable impacts of that development and cumulative impacts of development proposals along Wilberforce Ave including SSD-100912708. They conclude:

Even if each individual proposal predicts "acceptable" drawdown, the combined effect of multiple simultaneous or sequential excavations may produce groundwater lowering substantially greater than that predicted for any single development. This cumulative risk appears to warrant regional assessment rather than reliance on individual site-based modelling alone.
Jeremy Murray 
Senior Geotechnical Engineer | Director
Fortify Geotech Pty Ltd

Unfortunately, the recommendations in the Douglas Partners geotechnical report are overly generic and do not fully address the risks, further heightening the residents' concerns. As a result, a more likely solution is to limit the excavation depth to above the groundwater table, which, according to the geotechnical report, would be approximately 3m or a single basement level.
The assessment presented in this document indicates that there is likely to be an adverse impact on the surrounding properties and infrastructure.
Dr David Oliveira
 Chartered Professional in Civil and Structural Engineering

Dewatering for the proposed development during excavation and basement construction should be discouraged.
Kim Chan 
Geotechnical Consultant


In addition to my concerns for the impact on neighbouring properties supported by the experts quoted above, I have major concerns for congestion in already congested streets.

SSD - 100912708 is a proposal for 140 car spaces. More than 500 additional car spaces are proposed for all developments along Wilberforce Ave alone. Even now, before additional cars are brought into the area, roads are full and at times intersections are totally blocked with long lines of cars unable to move.

I am also concerned about the proposed loss of 94 trees, including Tree 18, a mature Eucalypt 18m assessed as having high landscape significance and high rendition value.

SSD - 100912708 is a proposal for a tree-deprived over-built car-jammed hell with high risk of property damage into the endless future for exisiting property holders. The site is unsuitable for the proposed development and it should not proceed.

Reasons for objection
1. Groundwater and settlement
The proposed 2 level very large basement will require major excavation in an area with shallow groundwater and settlement sensitive ground. I am concerned that not enough investigation has been done on this particular site regarding these problems. Wilberforce avenue in particular has a shallow water table, and the depth varies between sites. Further studies are needed on this particular site to determine settlement, groundwater displacement, excavation induced ground movement and impacts beyond the boundary. Serious damage has ocurred in Wilberforce avenue after a much smaller excavation.
2. Flooding
In even moderate rain, Wilberforce avenue tends to flood, and many much smaller basements than the one proposed here flood and have water pumps to prevent flooding. The applicants own Flood Emergency Response Plan across the Wilberforce frontage is identified as H6. The highest flooding classification. The scale of this development is completely inappropriate given this areas flood risk.
3.There are 6 major developments proposed for this large block of land between Wilberforce Ave and Dover road. The impact of all developments has to be considered in total, not each individual development. Combined impacts on groundwater and settlement need to be considered.
4. Insurance.
It will be difficult to decide which development caused damage, if any damage occurs during building. It will be difficult to decide who carries the risk re causation, liability , insurance and the ultimate financial risk. In the past building companies have been known to declare insolvency and then re open using another name and continue to work, avoiding all liability and compensation costs.
5. Traffic
Vehicle access to this building is proposed via Wilbeforce Ave. This street is already beyond peak traffic capacity due to the school traffic at drop off and pick up time. We are often unable to leave our garage due to cars parked across our garage and /or traffic buildup in the street. This problem will be magnified enormously by the added traffic (heavy construction vehicles and vehicles of the workmen) during the building of this development and once the development is complete. Over 500 basement parking spaces are proposed over the whole development site. The roads, already at capacity, cannot support this increased amount of traffic. There is ongoing major water work in Dover road at the moment. The road is partially blocked. Traffic at school time is horrendous, and this is a relatively small operation.
6. Trees
94 trees are propsed to be removed during this development. Tree #18 is a huge tree proposed to be removed due to the basement excavation. This of course can never be replaced. the environmental impact is enormous
I trust these important considerations will be taken into account when the development application is considered.

I am writing to formally register my strong objection to the proposed development / excessive density pressures in Rose Bay. As a local community member, I hold serious concerns regarding the adverse impacts this scale of development will have on our local character, infrastructure, and unique coastal environment.
1. Traffic Congestion, Parking, and Infrastructure Capacity
• Road Network Strains: Major arterial corridors—such as New South Head Road and Old South Head Road—are already operating at peak capacity. We have seen traffic build over the years to the point where traffic is at a standstill in the morning and afternoon peaks all the way into the city. As an effective peninsula, this development plus the recently announced other 11+ storey developments in Rose Bay (Conway Ave and Ian St up to 11 storeys, 11-31 Hamilton St and 36-56 Dover Road 8 to 12 storys) will only add to this congestion. Adding high-density residential units will severely exacerbate local traffic gridlock and make the movement of emergency services even more difficult and taking even longer to arrive at and address incidents. There are a number of schools in the area which add to the congestion.
• Inadequate On-Site Parking: Off-street parking provisions fail to account for true vehicle usage, which will spill over into already congested residential side streets, including many with long term boats parked in residential streets impacting available car parking.
• Overburdened Public Infrastructure: Local networks (drainage, stormwater, and power) and public services and public transport, are not scaled to absorb this cumulative increase in density. This will become even worse when the new Woollahra development changes occur. Rose Bay, and Vaucluse drivers will become trapped on the peninsula with no flowing exit routes given both New South Head Road and Old South Head Road will be impacted by the significant increase in cars merging onto these roads. Buses are already trapped by this gridlock at peak periods. St Vincent Hospital Emergency, already has huge waiting times and is at breaking point. Where will patients be treated, when they actually do get to the hospital?
2. Severe Geotechnical, Groundwater, and Environmental Risks
• Groundwater & Subsidence: Rose Bay sits on a sensitive, tidally influenced groundwater platform and loose marine sands. Deep excavation and basement dewatering pose severe risks of ground settlement, structural cracking, and instability for neighbouring properties.
• Excavation Limits: Deep multi-level excavation creates drawdown cones that exceed safe environmental limits, putting nearby structures and natural drainage at risk.
• Contamination, Acid Sulfate Soils & Runoff: Deep soil disturbance risks exposing acid sulfate soils and increasing contaminated runoff into Rose Bay harbour. Rose Bay Beach already is cited as having amongst the poorest quality water in NSW. Contamination comes from urban stormwater drains, sewer chokes, and low tidal flushing in the harbour.
3. Inappropriate Bulk, Scale, and Loss of Local Character
• Streetscape Character: The excessive height, bulk, and scale far exceed the established low-to-medium density context of Rose Bay. Traditional Australian-style single family houses have been replaced with high rise apartments, reducing the sense of community amongst residents.
• Amenity & Overlooking: The proposed massing will cause significant overshadowing, loss of solar access to adjoining private open spaces, and an unreasonable loss of privacy through direct visual overlooking.
• Enclosure: The insufficient setbacks create a visual sense of enclosure and overbuilding, contrary to the objectives of the Woollahra Development Control Plan (DCP).
4. Cumulative Impact and Urban Planning Integrity
• Precedent for Hyper-Density: Approving developments of this scale setting aside local DCP provisions undermines local strategic planning and encourages speculative site amalgams.
• Loss of Deep Soil & Canopy Cover: The over-development depletes critical deep soil zones required for mature canopy trees, contradicting urban greening goals and damaging the natural harbour setting.

Subject: Objection to Pathways Rose Bay Seniors Housing – SSD-100912708
Dear Mayor, Councillors and NSW Department of Planning,
I am writing as the owner of Made on Earth, a long-standing Rose Bay business, to express my strong concerns about the proposed Pathways development at 20–30 Wilberforce Avenue and 33–37 Dover Road.
I support appropriate seniors housing and aged care in our community. My concern is the scale, location and cumulative impact of this particular development, and what it could mean for the safety, amenity and character of Rose Bay.
The proposal includes approximately 74 independent living apartments, 39 aged-care rooms, three new eight-to-nine-storey buildings and a two-level basement containing 140 car spaces.
As a local business, I am particularly concerned about:
• The extensive deep excavation and two-level basement, and the potential impacts on groundwater, ground movement, settlement and neighbouring properties.
• The fact that this is not an isolated development. There are multiple major developments proposed in the surrounding Wilberforce Avenue/Dover Road area, many involving significant basement excavation. I believe the cumulative impact of these projects needs to be properly assessed rather than considering each site independently.
• Traffic and safety, particularly given the proposed 140 basement car spaces and vehicle access from Wilberforce Avenue, and the proximity of Rose Bay Public School.
• The potential impacts of groundwater movement and flooding in this low-lying part of Rose Bay.
• The proposed removal of a substantial number of established trees and the resulting loss of mature vegetation and amenity.
• The height, bulk and scale of an eight-to-nine-storey development in an established residential neighbourhood.
• The very real possibility of prolonged construction activity, including excavation, heavy vehicles, noise, dust and disruption to residents, businesses and the local school community.
I am also concerned about the question of who bears the risk if excavation or groundwater management contributes to damage to neighbouring properties, particularly when several major excavations may occur in close proximity.
These are not simply concerns about one development. They are concerns about the cumulative transformation of this part of Rose Bay and whether the existing infrastructure, streets and surrounding community can safely accommodate development of this scale.
Rose Bay is a wonderful community in which to live, work and operate a business. As someone who has been part of the local business community for many years, I care deeply about its future. I believe development should be thoughtful and appropriate to its surroundings, and that potential environmental, structural, traffic and safety risks must be properly understood before approval is given.
I respectfully ask Council and the NSW Department of Planning to carefully consider these issues, including the cumulative impact of the surrounding developments, before determining this application.
Thank you for considering my submission.
Yours sincerely,
Brenda H
Owner
Made on Earth
712 New South Head Road
Rose Bay NSW 2029

I am lodging an objection to SSD 100912708 (Pathways Rose Bay). My concerns are set out below.
1. Groundwater, Settlement and Suitability of the Land
A substantial portion of the site is within Rose Bay’s mapped Settlement Area, where shallow groundwater and settlement sensitive soils are already documented. The proposal involves a very large two level basement excavation beneath four buildings, which represents a major excavation in its own right.
Before approval is granted, DPHI should be satisfied that an excavation of this scale is suitable for this particular land. This includes demonstrating that groundwater levels, flows, displacement and settlement can be safely managed, and that excavation induced ground movement will not adversely affect neighbouring properties or public infrastructure.
Serious excavation related damage has already occurred beside much smaller basements in the immediate Rose Bay area. In this context, it is important that DPHI has clear, independent evidence that the Pathways basement can be constructed safely in a groundwater and settlement sensitive location without unacceptable impacts beyond the site boundary.
2. One Very Large Basement — A Major Excavation in Its Own Right
Pathways proposes a single, shared basement beneath four buildings, spanning almost the entire site. This is not a typical seniors housing basement — it is a major excavation requiring careful scrutiny.
DPHI should independently assess groundwater drawdown, groundwater displacement or damming, settlement and ground movement, dewatering impacts, retaining systems and impacts beyond the site boundary. These matters should be demonstrated before approval, not deferred to post consent plans.
3. Damage Has Already Occurred Beside Smaller Excavations
Multiple examples of excavation related damage have already occurred in the immediate Rose Bay settlement area, including partial collapses, retaining wall failures, basement flooding and multiple Stop Work Orders.
If smaller excavations have caused damage, what evidence demonstrates that the much larger Pathways excavation can be undertaken safely?
4. Six Developments on One Block — Cumulative Impacts
Pathways cannot be assessed in isolation. There are now six major developments proposed on the single Wilberforce/Dover block, several involving deep basements side by side.
DPHI should assess their combined impacts on groundwater, settlement, ground movement, dewatering, flooding, construction impacts, traffic and neighbouring buildings. Residents need to understand not only “What will Pathways do?” but also: What happens if multiple deep excavations are constructed around the same block?
5. Insurance, Liability and Who Carries the Risk
If damage occurs while multiple major excavations are underway, establishing which development caused the damage may be extremely difficult.
DPHI should clarify what protection exists for surrounding owners in the zone of influence, how causation will be determined if multiple basements are dewatering at the same time, and whether the NSW Government will provide indemnity or compensation if liability is disputed or insurance recovery is unavailable.
6. Environmental Impacts on the Wider Catchment
Groundwater does not stop at a property boundary. This development involves major excavation and groundwater management within a low lying coastal catchment draining towards Rose Bay and Sydney Harbour. The applicant’s documentation also identifies acid sulfate soils requiring management.
DPHI should consider the potential individual and cumulative effects of excavation, dewatering and altered groundwater movement on the wider catchment, drainage, soils and the receiving environment.
7. Infrastructure Capacity (Electricity, Water, Sewer, Stormwater)
The cumulative scale of development on the Wilberforce/Dover block raises legitimate concerns about infrastructure capacity. Multiple deep basements and high density developments will place pressure on electricity supply, stormwater drainage, sewer capacity and water pressure. The Pathways EIS does not assess cumulative infrastructure impacts across the block, nor does it address Council’s previously identified electricity infrastructure constraints in the precinct. DPHI should consider whether existing infrastructure can safely and reliably support the combined scale of development proposed.
8. Residential Amenity and Open Space Pressure
The Wilberforce/Dover block already has limited open space, and the Pathways proposal removes 94 trees, including high value canopy. When combined with the other developments proposed on the block, the cumulative impacts on residential amenity are significant. These include overshadowing, noise, traffic, construction impacts, loss of privacy and increased pressure on local parks and public spaces. DPHI should assess whether the combined effect of six developments on one block is compatible with maintaining residential amenity in the surrounding neighbourhood.
9. School Capacity and Social Infrastructure
While Pathways is an aged care development, several of the other proposed developments on the Wilberforce/Dover block are not, and will introduce additional families and children into the area. Local schools are already at or near capacity, and to my knowledge there are no plans to increase the availability of places or expand school infrastructure. The cumulative effect of multiple high density developments on a single block will place further pressure on already stretched education facilities. DPHI should consider whether the combined population increase associated with these developments can be supported by existing school capacity and social infrastructure.
10. Construction Fatigue and Overlapping Construction Periods
The cumulative effect of multiple deep basements and high density developments on the Wilberforce/Dover block will result in prolonged and overlapping construction periods. This includes excavation trucks, concrete pours, lane closures, vibration, noise, dust and traffic control. Residents, school families and local businesses will experience construction fatigue over several years, not months. DPHI should assess the cumulative construction impacts and consider whether the scale and timing of these developments are compatible with maintaining safe and reasonable access for the community.
11. Emergency Vehicle Access
Given the existing congestion, the proposed increase of more than 500 basement car spaces across the block, the narrow street network, school traffic and the H6 flood hazard classification, emergency vehicle access is a significant concern. Reliable access for ambulances, fire services and police is essential, particularly as Pathways is an aged care facility. DPHI should consider whether the cumulative traffic and construction impacts will impede emergency response times and whether appropriate mitigation measures have been identified.
12. Traffic, Road Congestion and Public Transport
Pathways proposes 140 basement car spaces, and across the six developments on this single block the potential cumulative scale exceeds 500 basement car spaces. Current peak hour travel times from Dover Road to the Cross City Tunnel are already around 30 minutes, demonstrating that the local road network is operating at or beyond capacity. Adding hundreds of additional vehicle movements without any corresponding infrastructure upgrades will significantly worsen congestion.
The Dover Road/New South Head Road intersection is already documented as operating over capacity. Additional traffic from multiple basements will increase queue lengths, turning movements and congestion, and will affect bus reliability on key public transport routes. Rose Bay Public School is directly across the road, meaning construction trucks, driveway movements and increased traffic volumes pose significant safety risks for children and families.
DPHI should assess the cumulative impact of these developments on traffic, congestion, pedestrian safety and public transport, rather than assessing Pathways in isolation.
13. Flooding — H6 Hazard Classification
The applicant’s own Flood Emergency Response Plan identifies H6 flood hazard across the full Wilberforce Avenue frontage during the Probable Maximum Flood (PMF). H6 is the highest hazard classification and is defined as: “Not suitable for people, vehicles or buildings.”
The applicant proposes shelter in place as the emergency response. DPHI should consider whether the scale of development, access arrangements and emergency response are appropriate given the site’s flood context.
14. Loss of 94 Trees — Including Tree 18
The proposal removes 94 trees. Tree 18 — a mature Lemon scented Gum with high retention value — is proposed for removal solely because of the basement footprint. DPHI should consider whether the basement can be redesigned to retain high value trees, and the cumulative impact of losing 94 trees in an area already short on open space.
Conclusion
Given the scale of excavation, the site’s groundwater and settlement sensitivity, the cumulative impacts of multiple basements on the same block, the flood hazard classification, traffic and school safety issues, environmental considerations, infrastructure constraints, residential amenity impacts, school capacity pressures, emergency access concerns, prolonged construction impacts and the loss of mature trees, I do not support approval of this SSD.
Thank you for considering these concerns.

I object to the proposed Pathways Rose Bay Seniors Housing development at 20-30 Wilberforce Avenue and 33-39 Dover Road, Rose Bay.

As a nearby resident, I am concerned that the Department has not adequately considered the site-specific risks associated with this development, particularly when viewed alongside the unprecedented scale of redevelopment proposed across the broader Wilberforce Avenue and Dover Road precinct.

My concerns relate to geotechnical impacts, groundwater management, cumulative development effects, traffic, flooding, environmental consequences, neighbourhood character, and the potential risk imposed on surrounding property owners.

1. Groundwater and Geotechnical Risks
The proposed development includes an extensive two-level basement beneath multiple buildings. The site is located within an area known to be affected by groundwater and settlement issues.

Before any approval is granted, I request that the Department be satisfied that the excavation can be undertaken without causing adverse impacts on neighbouring land, structures, groundwater movement, or long-term ground stability.

The scale of excavation proposed is significant and may alter groundwater flows, create settlement issues and affect surrounding properties well beyond the site boundaries.

2. Scale of Basement Excavation
While attention is often focused on the buildings above ground, the basement component represents one of the most significant engineering elements of the proposal.

The excavation, retaining walls, dewatering requirements and associated construction activities warrant rigorous independent assessment. I am not convinced that sufficient evidence has been provided to demonstrate that the excavation can proceed safely within the local geological conditions.

Any approval should only occur once the Department is satisfied that impacts on adjacent properties and public infrastructure can be avoided.

3. Evidence of Previous Local Damage
The Rose Bay area has already experienced instances where excavation works associated with development have reportedly contributed to damage to neighbouring properties.

Given these experiences, it is reasonable for residents to question whether a substantially larger excavation can be undertaken without similar consequences.

The Department should require a higher level of scrutiny and assurance before permitting works of this scale.

4. Failure to Properly Assess Cumulative Impacts
A major concern is that the Pathways proposal is being considered largely in isolation.

The Wilberforce Avenue and Dover Road block is subject to multiple significant development proposals. These projects collectively involve extensive basement excavation, construction traffic, dewatering activities and increased density.

The cumulative impacts of multiple developments occurring simultaneously or sequentially must be assessed comprehensively, including effects on:

Groundwater behaviour
Soil settlement
Structural impacts on neighbouring properties
Traffic generation
Construction activity
Flooding and drainage
Environmental outcomes
Public safety
A project of this scale should not be assessed without considering the broader redevelopment context.

5. Risk, Liability and Protection of Neighbouring Owners
If adverse impacts occur as a result of large-scale excavation works, it may be difficult for affected owners to determine responsibility where several developments are taking place within the same locality.

I am concerned about how liability would be established and how residents would be compensated should property damage occur.

The Department should clearly identify what protections, insurance arrangements and dispute-resolution mechanisms will be available to affected residents before any approval is granted.

6. Environmental Concerns
Excavation and groundwater management can have consequences extending beyond individual property boundaries.

The proposal involves substantial underground works within a coastal catchment that ultimately drains towards Rose Bay and Sydney Harbour. The management of groundwater, drainage, soils and any acid sulfate soil risks requires careful and transparent assessment.

I request that the Department fully evaluate both the direct environmental impacts of this proposal and the combined effects arising from nearby developments.

7. Traffic and Safety Impacts
The development proposes a substantial amount of on-site parking and vehicle access via Wilberforce Avenue.

When considered together with other planned developments in the area, the cumulative increase in vehicle movements is likely to place additional pressure on local roads and intersections.

Of particular concern is the proximity of Rose Bay Public School. Increased construction traffic, service vehicles and future resident traffic have the potential to affect pedestrian safety and school drop-off and pick-up periods.

The Department should require a comprehensive cumulative traffic assessment before determining the application.

8. Flooding and Emergency Management
Project documentation identifies significant flood hazards affecting the site during extreme flood events.

This raises legitimate questions regarding emergency access, evacuation procedures and the suitability of the proposed development intensity in a flood-prone location.

I request that the Department critically evaluate whether the proposed scale of development is appropriate given the site's flood characteristics and whether the proposed emergency response measures provide an acceptable level of safety.

9. Loss of Established Trees and Landscape Character
The proposal involves the removal of a substantial number of mature trees, including specimens assessed as having high landscape significance.

Mature canopy trees provide important environmental, visual and community benefits that cannot be quickly replaced.

The Department should require stronger justification for the removal of significant trees and explore alternatives that would allow greater retention of existing vegetation.

Conclusion
For the reasons outlined above, I respectfully request that the Department refuse the application in its current form or require substantial modifications and further independent investigation before any determination is made.

In particular, I request further assessment of groundwater impacts, excavation risks, cumulative development effects, traffic impacts, flooding risks, environmental consequences and the protection of neighbouring property owners.

The scale and complexity of development proposed for this area warrant a cautious approach to ensure that the interests of existing residents, local infrastructure and the environment are adequately protected.

Yours faithfully,

Ben Senes
60 Wilberforce Avenue
Rose Bay NSW 2029

We strongly object to SSD-100912708 (20-30 Wilberforce Avenue & 33-39 Dover Road, Rose Bay).

Main reasons:

1. I have learnt that this area is within a "high-risk settlement area", which means that deep excavations (for two-level basements for 140 car spaces) into saturated loose marine sands here would be very hazardous, resulting in e.g. altered groundwater movement, drainage, inundation risks & pedestrian hazards. We know that damages have already occurred beside much smaller excavations in the immediate Rose Bay area!.
2. I have also learnt that cumulative risk assessments for this and for the other five major developments proposed on the single Wilberforce Avenue/Dover Road block may not have been carried out.
3. If damage occurs while multiple other major excavations are occurring in close proximity, it will be challenging which developments caused the damage. This raises important questions about liability and insurance. So, will the NSW Government provide an indemnity or other compensations for residents who suffer proven development-related damage.?
4. We have also learnt that a total of 94 trees will be removed to give way for this and for the other five huge construction. In this day and age, it is appalling that this would be approved, as this would result in loss of shade, causing increased heat in the spring, summer and autumn months.
5. The Dover Road/Ian Street/NSH Rd interactions & the Wilberforce Avenue/Newcastle Street/NSH Rd intersections are very congested and busy, especially in peak hour times. The large increase in traffic (as a result of many more cars in the area, with the planned 500 basement car spaces across the six developments) will undoubtedly cause further congestion, with grave pedestrian safety concerns. And school-children drop off/and pickups for the Rose Bay Public School will be an absolute nightmare for parents and children, and for everyone who needs to will drive on Wilberforce Avenue.

And, very importantly, I also would like to express that I feel that new LMR rules and regulations implemented by the NSW government not only would greatly destroy the current amenity of Rose Bay, it will also, more importantly, not provide any affordable housing in the Rose Bay area.

Thank you in advance for your consideration.

Yours sincerely,
Diana Kastengren
3/9 Wilberforce Avenue, Rose Bay
0404 021 498
[email protected]

I strongly object to the proposed Pathways Rose Bay Seniors Housing development (SSD-100912708).
My objection is not to seniors housing itself. It concerns the scale and cumulative impacts of this proposal when considered alongside the concentration of development, basement excavation, construction activity and vehicle movements proposed within the same Wilberforce Avenue/Dover Road block.
As a local resident and parent whose son currently attends Rose Bay Public School, directly opposite this block on Wilberforce Avenue, I am particularly concerned about the cumulative impact on children’s safety, pedestrians, traffic, groundwater, neighbouring properties and the residential community.
Pathways should not be assessed in isolation. Residents experience one block, one road network, one pedestrian environment, one groundwater system and one community.
CUMULATIVE SCALE
Based on available information, development associated with this block includes:
• Pathways – 140 car spaces, 2 basement levels
• 23–31 Dover Road – 66 spaces, 2 basement levels
• 12–18 Wilberforce Avenue – 57 spaces, 2 basement levels
• 10 Wilberforce Avenue – 16 spaces, 3 basement levels
• Wilberforce Avenue Council car park redevelopment – 229 spaces total (gross capacity, not 229 additional spaces)
• Waterbrook – another substantial seniors-housing proposal on the adjoining site, with final parking yet to be confirmed.
That represents 508 car spaces associated with identified proposals before any parking is attributed to Waterbrook.
The Waterbrook site is larger than Pathways. If, purely to illustrate potential scale, it ultimately provided the same 140 spaces as Pathways, the block total would be approximately 648 spaces. I emphasise that 140 is not a published Waterbrook parking figure; it is an illustrative assumption. The Department should obtain and assess Waterbrook’s actual parking and excavation information when available.
Even without Waterbrook, 508 spaces demonstrate why cumulative assessment is essential.
TRAFFIC AND WILBERFORCE AVENUE
Pathways proposes 140 spaces across two basement levels, with vehicle access from Wilberforce Avenue.
Traffic associated with seniors housing and aged care includes residents, staff, visitors, carers, deliveries, waste collection, servicing and emergency/service vehicles.
Except for 23–31 Dover Road, vehicle access for the private developments identified above is concentrated on Wilberforce Avenue. The Council car park’s future access arrangements should also be considered when known.
The Department should assess a credible future cumulative-development scenario, not simply existing traffic plus Pathways. This should consider intersection performance, queueing, driveway conflicts, school peak periods, servicing, pedestrian movements and traffic redistribution into surrounding streets.
The issue is not simply whether one Pathways driveway operates. It is how much development, parking and vehicle activity can be concentrated around one local street before cumulative impacts become unacceptable.
ROSE BAY PUBLIC SCHOOL AND CHILDREN’S SAFETY
This issue is particularly important to me because my son currently attends Rose Bay Public School, directly opposite this block on Wilberforce Avenue.
As a parent, I regularly experience school arrival and departure times and see firsthand how busy Wilberforce Avenue and surrounding streets become with young children, parents, pedestrians and vehicles.
This is a residential neighbourhood and active school environment where children walk and cross roads every day.
The Department should assess cumulative impacts during school drop-off and pick-up, including additional resident/staff vehicles, visitors, carers, deliveries, waste vehicles, construction and spoil-removal trucks, road/footpath restrictions, worker parking and overlapping construction projects.
As a current Rose Bay Public School parent, this is not a theoretical concern. A driveway may function when assessed independently but contribute to a very different safety and congestion outcome when several major developments are concentrated around the same street.
PARKING MEANS MAJOR EXCAVATION
These are not surface car parks. They require substantial underground basement structures.
Pathways proposes 140 spaces across two basement levels; 23–31 Dover Road 66 spaces across two levels; 12–18 Wilberforce Avenue 57 spaces across two levels; and 10 Wilberforce Avenue 16 spaces across three levels.
This raises cumulative issues involving excavation, groundwater, dewatering, settlement, vibration, retaining structures, flooding and impacts on neighbouring properties.
The question should not simply be whether the Pathways basement can be engineered. It should also be:
What are the cumulative consequences of constructing multiple major basement structures in close proximity on the same block?
Groundwater does not stop at a development boundary. Neither do changes to groundwater movement, vibration or potential settlement effects.
Assessing each excavation independently risks failing to understand how multiple basement structures and dewatering systems may interact, particularly where construction occurs concurrently or sequentially.
The Department should consider whether multiple basements could alter groundwater movement, whether dewatering could interact between sites, and whether sufficient safeguards exist for adjoining properties and infrastructure. Appropriate groundwater, vibration and settlement monitoring should be required.
CUMULATIVE CONSTRUCTION
Several major developments within one block create the possibility of overlapping demolition, excavation, piling, spoil removal, concrete deliveries and heavy vehicle movements.
This could mean multiple trucks, excavators, cranes, road occupation, worker vehicles, noise, dust, vibration and pedestrian disruption within the same small area.
The Department should assess scenarios where Pathways construction overlaps with neighbouring projects rather than relying solely on a future site-specific Construction Traffic Management Plan.
How will Wilberforce Avenue operate if several developments require truck access? Where will trucks queue? How will children safely access Rose Bay Public School? What happens if multiple projects require road or footpath occupation?
These issues should be assessed before approval, not left entirely to individual construction management plans after consent.
COUNCIL CAR PARK
The Wilberforce Avenue Council car park redevelopment is also part of the cumulative picture.
The scheme provides 229 spaces in total. I acknowledge this is gross proposed capacity and does not represent 229 additional spaces, as parking already exists on the site.
Nevertheless, it represents another substantial development and construction component within the block. Its future traffic, access and construction implications should form part of cumulative assessment when sufficiently defined.
NEED FOR CUMULATIVE ASSESSMENT
Each developer may assess its own driveway. Each traffic consultant may calculate its own vehicle movements. Each geotechnical consultant may assess its own excavation.
But residents do not live in separate consultant reports. We live on one block.
The combined impacts on traffic, pedestrians, construction, groundwater, flooding and neighbouring properties need to be understood before another major development is approved.
I recognise the need for suitable seniors housing and aged-care accommodation. However, this does not remove the requirement to properly assess traffic, construction, geotechnical, environmental and neighbourhood impacts.
This is not an objection to seniors housing as a land use. It is an objection to determining a development of this scale without adequately assessing its cumulative context.
REQUEST TO THE DEPARTMENT
I respectfully request that the Department not determine SSD-100912708 until the cumulative impacts of approved, proposed and reasonably foreseeable development across the Wilberforce Avenue/Dover Road block have been adequately assessed.
In particular, I request cumulative assessment of:
• traffic and intersection performance
• Wilberforce Avenue vehicle movements and driveways
• construction traffic and overlapping construction
• Rose Bay Public School and pedestrian safety
• basement excavation and sequencing
• groundwater and dewatering
• settlement and vibration
• flooding and drainage
• servicing, deliveries, waste and emergency access
• interaction between multiple basement structures.
Where impacts are unacceptable or insufficiently understood, the Department should require further information, design changes, mitigation, staging and appropriate conditions before determination.
One block. Multiple major developments. Multiple deep basements. Hundreds of car spaces. One road network. One groundwater environment. A primary school directly opposite. One community experiencing the combined impacts.
As a local resident and current Rose Bay Public School parent, I ask the Department to properly assess these cumulative impacts before determining Pathways.

To whom it may concern,
I am writing this letter of objection regarding the Pathways Rose Bay Seniors Housing proposal on the Wilberforce Avenue/Dover Road block. The proposed gross overdevelopment of the current R3 zoned parcels of land, is extremely concerning on many fronts, not only the visually daunting tripling in height, of the new 8-9 storey buildings. The bulk and scale of the development is completely out of character with the existing local streetscape.

The precedent of a major deep excavation for double level basement parking on this mega site, poses serious risks to existing groundwater levels and the surrounding foundation material of neighbouring properties. Given a significant part of this proposed development site lies within the mapped Rose Bay Settlement Area, what assurances are there that irreparable damage will not result from the excavations? Will the NSW state government guarantee repair costs of homeowners properties as a result of damage caused by the excavations and or construction of such a massive development on potentially flood prone land? There has already been damage to Wilberforce Avenue properties as a result of smaller basement excavations on adjoining developments.

The Pathways proposal alone represents a massive site, yet it is only one of several developments earmarked for the block/land in Wilberforce Avenue/Dover Road. The thought of adjacent deep excavated developments en masse, and the potential ramifications of the diversion and displacement of groundwater presents a frightening outlook for the near future. This is unchartered territory for the local residentially zoned streets of Rose Bay. The potential risks of such oversized developments far outway the benefits.

The additional vehicular movements the Pathways development will generate, due to its proposed 140 basement car spaces, will add to the already overloaded local street traffic congestion. The proximity of the proposed development is virtually opposite Rose Bay Primary School and the increased traffic movements of Pathways & future adjoining developments, presents significant potential risk to school children navigating Wilberforce Avenue on foot.

In summary the NSW Sate Government must hear the valid concerns of residents objecting to unprecedented new developments such as Pathways, in the Rose Bay Mapped Settlement Area. Detailed analysis and assessment by Geotechnical Engineers and Hydrogeological experts must be undertaken and adhered to before developments such as Pathways are considered for approval. If not, the residents of Rose Bay will continue to bring light to the risks and dangers thrust upon us by the poor policy and rushed planning of the NSW Sate Government.

Yours Faithfully
Frank Femia.

I object to this SSDA, but I’m having no luck attaching my submission. Can I send it you via email. It’s not a very large file?!

Submission: OBJECTION
Application: SSD-100912708, Amara Rose Bay seniors housing development
Site: 20–30 Wilberforce Avenue & 33–39 Dover Road, Rose Bay
To the Department of Planning, Housing and Infrastructure,
I object to the proposed Amara Rose Bay development (SSD-100912708) for the reasons below.
1. Excavation, groundwater and settlement. The proposal includes a very large, shared two-level basement beneath four buildings of 8–9 storeys, with 140 car spaces. The site lies within a mapped Settlement Area with shallow groundwater and settlement-sensitive ground. I ask the Department to require independent scrutiny of groundwater drawdown, dewatering, ground movement, retaining systems and impacts beyond the site boundary. Serious damage has already occurred beside much smaller excavations in this area, and the applicant has not shown that an excavation of this scale can be built safely here.
2. Cumulative impact. Six major developments are proposed on the single Wilberforce/Dover block, including Council's car park. The Department should assess their combined impacts on groundwater, settlement, dewatering, flooding, traffic and neighbouring buildings, not this project in isolation. If damage occurs during overlapping excavations, establishing liability and insurance recovery could be extremely difficult for neighbours.
3. Environment. The site is in a low-lying coastal catchment draining to Rose Bay and Sydney Harbour, and the applicant's own documents identify acid sulphate soils as an issue requiring management. The cumulative effects of excavation and dewatering on the wider catchment must be considered.
4. Flooding. The applicant's Flood Emergency Response Plan identifies H6 flood hazard, the highest classification, across the Wilberforce Avenue frontage in the Probable Maximum Flood, and nominates shelter-in-place as the preferred response. I question whether this is appropriate for a seniors housing and aged-care development, where many residents have limited mobility.
5. Traffic and Rose Bay Public School. The development proposes 140 basement car spaces, with access from Wilberforce Avenue. Across the six proposals, the block could have over 500 car spaces, plus overlapping heavy construction traffic. Rose Bay Public School is diagonally opposite, so pedestrian safety and school drop-off/pick-up conditions are a serious concern. Street parking is a premium for local residents and workers, we don't need the additional demand.
6. Trees. 94 trees are proposed for removal, including Tree 18, an 18-metre mature Lemon-scented Gum that the applicant's arborist rates as having high landscape significance and high retention value. It is proposed for removal because of the basement.
The applicant has not demonstrated that this excavation can be safely constructed on this site without unacceptable impacts. I ask that the application be refused or, at a minimum, not determined until the cumulative impacts of all six proposals have been independently assessed.
Yours faithfully,
A concerned local resident of Newcastle Street.

Dear Ms Hawell,

I would like to lodge an objection to SSD-100912708.

As a long term resident of Rose Bay, directly impacted by this proposed new development, I am deeply concerned about the lack of proper expert consideration of the cumulative impacts of the number of SSDs and other LMR developments being proposed in the area. This development - SD-100912708 - cannot be meaningfully assessed in isolation. The applicant's limited acknowledgment of other developments proposed in the neighbourhood is inadequate for the task at hand.

Given the geotechnical and hydrogeological conditions in the area, the site specific and cumulative impacts of excavation must be assessed by qualified independent experts. The deep basement excavations being proposed on this site, and adjacent sites, present unacceptable and known risks of structural damage to nearby properties, not just those directly adjacent to the proposed development. Numerous expert reports have been commissioned, including by Woollahra Council, demonstrating that the particular conditions of this site and the surrounding area make it ill-suited to developments of this type. The risks associated with foreseeable damage cannot be fairly transferred to home owners.

The traffic report provided with the application does not adequately assess the cumulative impacts on the road network and public transport services. The modelling does not properly reflect the increased volume of traffic associated with the operation of the facility being proposed (including deliveries, service providers, emergency vehicles etc) or the cumulative traffic impacts of all the proposed neighbouring developments. Cumulative traffic studies should be completed by Transport for NSW before the proposal can be fairly assessed. Relying on the guideline suggesting that only 'approved' projects need to be considered is inappropriate in this context. The evidence provided about the operation of intersections is inconsistent with the Woollahra Council's independent traffic reports. The proximity of the proposed development to the local public school introduces safety risks associated with increased traffic in a school zone.

There are also beautiful, 'high value' trees marked for removal in order to allow for basement excavation.

I am not at all opposed to the provision of additional seniors housing in the neighbourhood (another such facility is being proposed on the site adjacent to this one) but the scale and nature of the developments must reflect the geotechnical, hydrogeological, infrastructural and green & open space constraints of the neighbourhood.

I respectfully request that this project not be approved.

thank you.
Amy Denmeade

🌊 GROUNDWATER + SETTLEMENT: A substantial part of this site sits within Rose Bay's mapped Settlement Area. Is an excavation of this unprecedented scale and depth suitable - or safe - for this particular ground?
🏗 ONE HUGE DEEP BASEMENT: Even before considering the other developments, this is a major excavation in its own right. What could it do to groundwater, ground movement and surrounding properties in the zone of influence?
⚠️ SIX DEVELOPMENTS — ONE BLOCK: What happens if multiple large deep basements are excavated side-by-side? The cumulative impacts need to be considered.
🏚 LOCAL DAMAGE: Serious damage has already occurred beside much smaller excavations in the immediate Rose Bay area. What evidence demonstrates this much larger excavation can be undertaken safely?
💰 WHO CARRIES THE RISK? If property damage occurs while several developments are under construction, what happens if responsibility is disputed? What protection will residents have?
! THE PUBLIC INTEREST: These risks of deep excavation are not hypothetical — they are known and documented in this area. Why should residents be asked to carry the risk to their homes and financial security, and HOW is that in the public interest? The public interest is a mandatory consideration that should not be glossed over.
🌊 FLOODING: In the most extreme flood scenario assessed by the applicant, Wilberforce Avenue outside the site reaches the highest flood-hazard category - "Not suitable for people, vehicles and buildings". The applicant's emergency plan is therefore for residents to shelter inside rather than evacuate..
🌳 TREES: 94 trees are proposed for removal. This includes Tree 18 — a mature 18-metre-high tree with a canopy about 16 metres wide, which the applicant's arborist gives HIGH landscape significance and HIGH retention value - but to accommodate the basement means it must be removed.
* THE ENVIRONMENT - Groundwater movement does not stop at a property boundary. This development involves major excavation and groundwater management within a low lying coastal catchment draining towards Rose Bay and Sydney Harbour. The applicant's documentation also identifies acid sulphate soils as an issue requiring management.
🚗 500+ BASEMENT CAR SPACES + SCHOOL SAFETY: Pathways alone proposes 140 basement car spaces, with access from Wilberforce Avenue. Across the six developments proposed on this single block, the potential cumulative scale is over 500 basement car spaces — as well as multiple driveways, service vehicles and potentially overlapping construction traffic. Not only does that mean unprecedented underground excavation to house these carspace's in a known hydrogeologically sensitive area
- Rose Bay Public School is diagonally opposite the block. Ask NSW Department of Planning, Housing and Infrastructure to consider what all of this could mean for Wilberforce Avenue and the local community — not just Pathways in isolation. The traffic - and safety- impacts will not be limited to the construction period on this residential street.

Dear Sir/Madam,

I wish to object to the proposed Pathways seniors housing development in Rose Bay.

I recognise the need for appropriate seniors housing and aged-care facilities. However, I am concerned that the scale and design of this proposal, particularly the extensive two-level basement excavation, create significant risks to surrounding properties, the local environment, traffic safety and the broader Rose Bay community.

My principal concerns are:

1. Deep excavation, groundwater and ground movement

The proposal includes a substantial two-level basement extending beneath all four buildings and accommodating approximately 140 car spaces. A significant portion of the site is within Rose Bay's mapped Settlement Area.

Given the known ground and groundwater conditions in this part of Rose Bay, I am concerned about the potential for groundwater drawdown, ground movement, settlement and impacts on neighbouring properties. These risks are particularly concerning given the scale and depth of the proposed excavation.

There have already been instances of significant property damage associated with excavation in the immediate Rose Bay area. The assessment should therefore clearly demonstrate, with independent geotechnical and hydrogeological evidence, that this excavation can be undertaken without unacceptable risk to surrounding properties.

2. Cumulative impact of six major developments

The Pathways proposal should not be assessed in isolation.

There are reportedly six major development proposals on this single Wilberforce/Dover block, several involving substantial deep basement excavation. Collectively, these projects could involve more than 500 basement car spaces, multiple large excavations and overlapping construction activity.

Groundwater and ground movement do not respect property boundaries. The potential interaction between multiple deep excavations occurring within close proximity must therefore be properly assessed.

I request that the Department consider the cumulative geotechnical, hydrogeological, traffic and construction impacts of all proposed developments in this area, rather than assessing each proposal independently.

3. Risk to neighbouring properties

The potential consequences of settlement, ground movement or changes to groundwater are significant for surrounding homeowners.

If damage occurs while several major developments are being constructed simultaneously, determining which development is responsible could become extremely difficult. The assessment should therefore address what practical protections are available to existing property owners and who bears responsibility if damage occurs.

Residents should not be expected to carry an uncertain financial and legal risk arising from large-scale development occurring around them.

4. Flooding and emergency management

I am also concerned about the site's flood risk.

In the most extreme flood scenario assessed by the applicant, Wilberforce Avenue outside the site reaches the highest flood-hazard category — described as "Not suitable for people, vehicles and buildings."

The proposed emergency response reportedly relies on residents sheltering within the development rather than evacuating.

Given that this is proposed seniors housing and includes aged-care residents, I believe the suitability of this emergency strategy warrants particularly careful and independent assessment. The ability of elderly and potentially mobility-impaired residents to safely shelter in place during an extreme flooding event should be considered alongside the accessibility of emergency services and surrounding roads.

5. Removal of significant trees

The proposal involves the removal of approximately 94 trees.

Of particular concern is Tree 18, identified by the applicant's arborist as an approximately 18-metre-high mature tree with a canopy of around 16 metres and high landscape significance and high retention value.

The fact that this tree must apparently be removed to accommodate the basement raises questions about whether the proposed basement footprint and overall development have been designed with sufficient regard to the existing environmental character of the site.

6. Groundwater and environmental impacts

The site is located within a low-lying coastal catchment draining towards Rose Bay and Sydney Harbour. The proposed excavation and associated groundwater management therefore have the potential to affect groundwater movement beyond the site itself.

The applicant's documentation also identifies acid sulphate soils as an issue requiring management.

These environmental risks should be assessed not only in relation to the development site but also in terms of their potential cumulative impacts with the other major excavations proposed in the immediate area.

7. Traffic and school safety

The proposal includes approximately 140 basement car spaces, with vehicle access from Wilberforce Avenue.

Rose Bay Public School is located diagonally opposite the development site. Wilberforce Avenue is already a residential street used by children, parents, pedestrians and local residents.

The traffic implications should therefore be considered beyond the construction period. The completed development will generate ongoing vehicle movements, while construction will introduce heavy vehicles, deliveries, excavation traffic and construction workers over an extended period.

When the potential traffic generated by all six proposed developments is considered together — including more than 500 basement car spaces, multiple driveways and construction activity — the cumulative impact on Wilberforce Avenue and the surrounding residential area could be substantial.

I request that the Department specifically assess the cumulative traffic and pedestrian safety impacts, particularly during school drop-off and pick-up periods.

I support the provision of suitable seniors housing and aged care in appropriate locations. My objection is to the scale, excavation requirements and cumulative impacts of this particular proposal and its relationship with the other major developments proposed in the immediate area.

The risks associated with deep excavation, groundwater, settlement, flooding, tree removal and traffic are not merely theoretical considerations in this location. They require careful assessment, particularly where multiple large developments are proposed within the same relatively confined area.

The relevant consideration should not simply be whether the Pathways development can theoretically be constructed in isolation, but whether the combined impact of this development and the other proposed developments can be accommodated safely and sustainably by this particular part of Rose Bay.

I respectfully request that the Department give these matters full consideration and that the proposal not be approved unless there is clear, independently verified evidence that the identified risks to existing residents, properties, the environment and public safety can be appropriately managed.

Yours faithfully,

Kim Louey-Gung
Rose Bay, NSW

I object to the proposed Pathways Rose Bay Seniors Housing development (SSD-100912708).

I live directly across the road from the proposed development and am extremely concerned about both the scale of the proposal and the impact it will have on the surrounding neighbourhood, during construction and permanently once completed.

Traffic, access and construction impacts

Dover Road, Wilberforce Avenue and the surrounding Rose Bay streets already carry significant traffic and are frequently congested. The local road network has very limited capacity to absorb additional vehicles, particularly around school drop-off and pick-up times.

I do not believe sufficient consideration has been given to how a development of this scale can realistically be constructed without creating major disruption to residents and the wider community.

This is not an abstract concern for residents. Sydney Water works currently taking place in the immediate area have already been underway for much of the year and have caused substantial traffic disruption, road closures, noise and difficulties accessing properties.

The proposed development would involve demolition, excavation for a very substantial two-level basement and construction of buildings up to eight or nine storeys. This would inevitably mean a lengthy period of heavy vehicle movements, deliveries, excavation, construction traffic and associated disruption.

The assessment should clearly establish how this traffic will be accommodated, where construction vehicles will wait and load, how residential access will be maintained and how conflicts with pedestrians, school traffic and existing road users will be managed.

The cumulative impact is particularly important. This proposal should not be assessed as though it exists in isolation when several major developments are proposed for the same block. The combined construction and eventual traffic impacts need to be properly considered.

Flooding, groundwater and excavation

Flooding is already a genuine concern in this low-lying part of Rose Bay. The scale of the proposed basement excavation, together with the site’s location in an area susceptible to flooding and groundwater issues, makes this particularly concerning.

I would like the Department to be satisfied that the proposal will not worsen flooding, groundwater movement or drainage conditions for surrounding properties.

Again, this needs to consider the cumulative effect of other major developments and basement excavations proposed within the same block. Groundwater and flooding do not operate according to individual development boundaries.

There should be clear, independently verified mitigation measures and monitoring arrangements in place before a development of this scale is approved.

Building height, bulk, light and neighbourhood character

As a resident directly opposite the site, I am also concerned about the effect buildings of eight to nine storeys will have on sunlight, daylight, outlook, privacy and the general amenity of neighbouring properties.

This represents a substantial change in scale for this part of Rose Bay. The Department should carefully assess overshadowing throughout the year, rather than treating impacts on neighbouring properties as secondary to achieving the proposed development yield.

More broadly, the cumulative redevelopment of this block risks fundamentally changing the character and amenity of what is currently a predominantly residential neighbourhood.

I am not opposed to appropriate development or additional housing in Rose Bay. However, development needs to be proportionate to its location and supported by infrastructure capable of accommodating it.

My concern is that the scale and intensity proposed here, particularly when considered alongside the other developments proposed for this block, exceeds what the surrounding road network, drainage infrastructure and neighbourhood can reasonably absorb without significant adverse impacts.

I ask the Department to give particular consideration to:

* the cumulative traffic impact of all proposed developments on the Wilberforce Avenue/Dover Road block;
* a realistic construction traffic and access assessment reflecting existing congestion and current infrastructure works;
* pedestrian and school safety;
* flooding, drainage and groundwater impacts, including cumulative impacts from multiple basement excavations;
* potential settlement and impacts on surrounding properties;
* overshadowing, loss of natural light and privacy for neighbouring residents;
* the height, bulk and scale of the proposed buildings and their relationship with the existing streetscape; and
* the cumulative duration and severity of construction impacts on residents.

Given the number and scale of developments proposed within such a concentrated area, I do not believe the impacts of this proposal can reasonably be assessed in isolation.

I therefore object to the development in its current form and ask that these issues, particularly the cumulative impacts on traffic, flooding, groundwater, construction disruption and residential amenity, are properly addressed before any approval is considered.

Submission: OBJECTION
Application: SSD-100912708, Pathways Rose Bay (Amara Rose Bay), 20-30 Wilberforce Ave & 33-39 Dover Rd, Rose Bay
Name: Sheridan Hopkins Suburb: Vaucluse

I object to this application. My concerns are the geotechnical and groundwater risk of the proposed basement, the traffic the development would add to Rose Bay, and flood safety for aged-care residents. Under section 4.15 of the Environmental Planning and Assessment Act, the consent authority must consider the suitability of the site and the likely impacts of the development. On each count I submit the application has not been shown to be acceptable.

1. Groundwater and geotechnical risk

The proposal includes a large two-level basement across four buildings, in an area affected by shallow groundwater and settlement-sensitive ground. A substantial part of the site lies within Rose Bay's mapped Settlement Area.

That development is permissible does not make every basement suitable for the land. I ask the Department to be satisfied, before any approval and on independent scrutiny, that an excavation of this scale can be built here without unacceptable impacts beyond the site boundary, including:

• groundwater drawdown, and displacement or damming of groundwater flow
• settlement and excavation-induced ground movement
• dewatering and the adequacy of retention systems
• effects on neighbouring properties

Damage has already occurred beside much smaller excavations in this part of Rose Bay which your department is aware of from the Building Commissioner. If that can happen at that scale, the applicant must demonstrate why a two-level basement is safe here.

I also object to these questions being left to conditions of consent. Conditions requiring later sign-off do not show that the excavation is feasible. Neighbours are asked to accept the risk now on the promise of assurance later. If the risk is real, it should be resolved before approval, when the design can still change.

2. Cumulative impact

This is one of six major proposals on the Wilberforce/Dover block, including Council's own car park, with several deep basements planned side by side. There has never been excavation in this area before. Assessing Pathways alone cannot show how these excavations will behave together. If damage occurred, it might be impossible to establish which excavation caused it, leaving owners without a clear path to compensation. I ask the Department to assess the combined effects on groundwater, settlement and ground movement, and to explain what protection will exist for surrounding owners.

3. Traffic and road infrastructure

The basement holds 140 car spaces with access from Wilberforce Avenue. Across the six proposals on the block, the potential total is over 500 basement spaces, with multiple driveways, service vehicles and possibly overlapping periods of heavy excavation traffic. Rose Bay Public School is diagonally opposite the block. Traffic is already gridlocked in Rose Bay at peak times.

I ask the Department to assess the combined impact on Wilberforce Avenue, including construction trucks, traffic movements, pedestrian safety and school drop-off and pick-up, rather than Pathways in isolation. If the road network cannot absorb this, the answer is to reduce or stage the development, not to ask the community to absorb the cost.

4. Flood risk and evacuation of aged-care residents

The applicant's own Flood Emergency Response Plan identifies H6 flood hazard, the highest classification, across the Wilberforce Avenue frontage in the Probable Maximum Flood and relies on shelter-in-place. The proposal includes 39 aged-care rooms whose residents cannot be expected to evacuate unaided. Before determining the application, I ask the Department to assess whether occupants can be safely evacuated or supported through a major flood, and to publish that assessment.

I also ask it to consider how a large basement and dewatering affect flood behaviour and access, and whether the flood provisions that apply to this land have been met, including [clause 5.21 and, if it applies, clause 5.22 of the Woollahra LEP]. If frail residents cannot be shown to be safe, the site or the scale is unsuitable.

Request: that the application be refused, or at minimum not determined until independent geotechnical and hydrogeological peer review, a cumulative traffic assessment covering the whole block, and a flood evacuation assessment for the aged-care residents have been completed and made public.

Sheridan Hopkins

I object to the proposed Pathways Rose Bay development due to its scale, the extent of the proposed basement excavation, and the significant risks it presents to neighbouring properties, the local environment, and the wider Rose Bay community.
Groundwater and Settlement Risks
A substantial portion of the site lies within Rose Bay's mapped Settlement Area, where shallow groundwater and settlement-sensitive ground conditions are well known. The proposal involves a large two-level basement excavation that has the potential to alter groundwater flows, cause land movement and impact neighbouring properties.
The Department should require clear evidence that an excavation of this scale can be undertaken safely and without adverse effects before any approval is granted.
Major Basement Excavation
The proposed basement extends beneath four buildings and should be assessed as a major excavation project in its own right. Particular scrutiny should be given to groundwater drawdown, dewatering, settlement, excavation-induced ground movement, retaining structures and impacts beyond the site boundaries.
Given the site's known constraints, the applicant should be required to demonstrate that these risks can be managed to an acceptable standard.
Lessons from Local Experience
These concerns are not theoretical. Property damage has reportedly occurred in the Rose Bay area in connection with smaller excavation projects. It is therefore reasonable to question whether a significantly larger excavation can proceed without similar consequences.
A precautionary approach should be adopted where uncertainty remains.
Cumulative Impact of Six Developments
This proposal cannot be considered in isolation. It is one of six major developments proposed within the Wilberforce Avenue and Dover Road precinct, many involving substantial basement excavations.
The Department should undertake a comprehensive cumulative impact assessment addressing groundwater, settlement, flooding, construction activity, traffic and impacts on surrounding properties. Residents deserve to understand the combined consequences of multiple large-scale excavations occurring within the same block.
Liability and Financial Risk
If damage occurs while several major projects are underway, proving which development is responsible may be difficult. This creates uncertainty around liability, insurance and compensation for affected residents.
The Department should clarify what protections will be available to neighbouring property owners and how claims for development-related damage will be addressed.
Environmental Concerns
The site is located within a low-lying coastal catchment that drains towards Rose Bay and Sydney Harbour. The proposal involves extensive excavation, groundwater management and the presence of acid sulfate soils.
The potential impacts on groundwater systems, drainage patterns, soils and the broader receiving environment should be thoroughly assessed, both individually and cumulatively.
Traffic and Public Safety
The development proposes 140 basement car spaces, with access from Wilberforce Avenue. When combined with the other proposed developments within the precinct, the cumulative increase in traffic could be substantial.
This is particularly concerning given the proximity of Rose Bay Public School. Increased construction traffic, vehicle movements and congestion may adversely affect pedestrian safety, including children travelling to and from school.
A cumulative traffic and safety assessment should be undertaken before any decision is made.
Flooding Risk
The applicant's own flood documentation identifies H6 flood hazard conditions along the Wilberforce Avenue frontage during a Probable Maximum Flood event. H6 represents the highest flood hazard classification and is considered unsuitable for people, vehicles and buildings.
Given these findings, the suitability of the proposed development, its access arrangements and its proposed emergency response strategy warrant careful reconsideration.
Retention of Tree 18
The proposal includes the removal of 94 trees, including Tree 18, a mature Lemon-scented Gum identified by the applicant's own arborist as having high landscape significance and high retention value.
Mature canopy trees are increasingly valuable community assets that contribute to neighbourhood character, biodiversity, shade and urban cooling. Every effort should be made to redesign the development to retain this significant tree.
Conclusion
While additional seniors housing is important, development should not proceed at the expense of community safety, environmental protection and the long-term stability of surrounding properties.
Given the site's groundwater and settlement constraints, the unprecedented scale of the proposed excavation, the cumulative impacts of multiple nearby developments, the flood risks, traffic impacts and the loss of significant trees, I respectfully request that the Department either refuse the application or require substantial redesign and further independent assessment before any approval is considered.
Yours faithfully,
Georgina Senes

I am a long-time resident of Rose Bay having lived here since 1988. I object in the strongest way possible to this proposal on the grounds of proximity to the local primary school, loss of amenity, total lack of infrastructure, inordinate increase in population and cars, enormous overshadowing, loss of important trees and loss of so many trees, loss of district and iconic views, water table vs basements issues and the obliteration of the local community and the village atmosphere.
This proposal seeks to replace 9 dwellings with 74 +39 = 113 individual dwellings. The current dwellings on this amalgamated site are a mix of single and 2 storeys homes with leafy gardens and many trees. Most house young families. These current dwellings include approximately 40 people and 18 cars in total. The development will house about 200 people plus the staff to run the facility. Rose Bay Public School is across the road. What will be the impact of all the proposed developments just in this strip and their combined 500 basement car spaces on the little kids' primary school?
This proposal alone will include 140 cars which is 122 extra vehicles. Where is the infrastructure to support these 122 extra vehicles and 100's of extra residents and workers? Old South Head Rd is already nick-named ' the car park' as it is perpetually extremely congested. Old South Head Rd cannot be widened. New South Head Road is even worse, mornings are a complete grid-lock disaster. How will the currently totally congested roads cope with the extra traffic to be generated by this proposal and the 6 other major developments proposed on the single Wilberforce/Dover residential block plus the many more in the immediate vicinity? How many extra buses will be put on per hour to cope with the huge population increase? Won't they also further affect the awful traffic situation? How many extra ferries will be put on per hour for all the extra people? Does the NSW Government even have any spare/extra ferries? If the roads are clogged and the public transport is unable to be adequate how will the kids get to and from school? How will the residents get to the train stations at Edgecliff and Bondi Junction?
A substantial portion of the site is in the Rose Bay mapped Settlement Area. It includes a large, shared basement under 4 huge buildings. Ground water does not stop at the property boundary! It is extremely close to the water table without the proposed basements. We already see regular local flooding in Rose Bay during big storms. We saw during a recent build in Wilberforce Avenue that the house next door lost a substantial part of its front due to the subsidence caused by the basement construction. This house had to eventually be demolished as a result.
94 Trees are to be removed! What an environmental disaster, how can that be? Some of these trees are noted as having high retentions value and high landscape significance, yet even these are proposed for removal. If I want to cut back a branch of a tree in my garden, I need to seek expensive and time-consuming Council approvals, yet this development is losing 94 trees from one site!
Why are the buildings 9 storeys? Is not 8 storeys the limit? What will they overshadow? Everything around them? The street, including the street trees, the neighbors and the school will most certainly lose light and sunshine.
District views including stunning iconic views are to be had from the hillsides surrounding Rose Bay. These will certainly be adversely impacted by walls of 8 and 9 storey buildings.
Rose Bay shopping centres both on Old and New South Head Roads are a mix of small local cafes, small supermarkets, boutiques etc. There is always a warm community environment with neighbours chatting on the streets and in the cafes in the sunshine in winter and under the shade of the many trees in the summer. The entire existing community and our school, will be hugely adversely impacted by this monster proposal and the very many more planned for the neighborhood.