Residential development with infill affordable housing- 16-20 Middle Harbour Road, Lindfield

I object to SSD-83431958 at 16–20 Middle Harbour Road, Lindfield. The proposal has been designed on the assumption that surrounding sites, particularly along Russell Avenue, will remain low scale, which risks unfairly constraining their future redevelopment potential. At nine storeys and nearly 100 units, the building represents overdevelopment, with bulk and density out of character for the area. The widened solar access assessment window masks overshadowing impacts, and the proposal will generate significant traffic and strain on local infrastructure. This application undermines coordinated precinct planning and should not be approved in its current form.

Submission on SSD 83431958

As an owner/occupier for the last 24 years of a property on Middle Harbour Road, approximately 270 metres from the proposed development site, I recognise the need for more housing in the Lindfield area. That being said, I object to the proposed development in its current form for the following reasons:

Lack of Engagement:
The Proponents have neither consulted with Council nor carried out engagement with the local community other than “informal discussions as required” with neighbouring landowners, mostly about potential site amalgamation. Rather, they rely on the promise of “continued engagement” post-lodgement, with a proposed mail-out covering only the block bordered by Middle Harbour Road, Trafalgar Avenue, Russell Avenue and Lindfield Avenue, and the South side yof Middle Harbour Road between Trafalgar Avenue and Lindfield Avenue. Given that these properties are within the TOD zone, and that most of them are the subject of current or proposed future development applications, this lack of community engagement has limited the number of existing residents likely to continue living in the area who have been made aware of the proposed development in time to submit an objection. This is unacceptable.

Overshadowing:
The proposed development will cause overshadowing of properties including 14 Middle Harbour Road and properties on the Southern side of Middle Harbour Road (which are not the subject of development applications) for significant portions of the day.

Failure to consider cumulative impact on traffic and parking:
The proposed development is one of four current proposals on Middle Harbour Road between Lindfield Avenue and Trafalgar Avenue. This section of Middle Harbour Road is used daily as parking by commuters using Lindfield Station. The Traffic and Parking Assessment Report fails to consider the cumulative impact of all proposed development on traffic and parking, especially during construction, when delivery trucks will be blocking the road, while vehicles belonging to demolition and construction workers will be occupying the parking spaces currently used by commuters.

Removal of trees:
The Proposal includes the removal of 29 trees from the site, including one 18 metre tall, high-retention value, Turpentine tree in the centre of the site, with a large root system and 16 metre crown spread, which is in good health. The proposed removal of this tree in the interests of being able to develop is justified on the basis that it is isolated from other Turpentines or large trees and does not contribute to the streetscape due to its location, it is not an attractive tree, and the proponent cannot keep this tree and get an economical basement car park layout or efficient apartment layout. This tree can be seen from both Middle Harbour Road and Russell Avenue, as well as the Lindfield Tennis Club, and is not unattractive, and there is little evidence that the proponents have made any attempt to achieve a design which would retain this tree. Further, only 20 existing trees are proposed to be retained. The proposed planned Tree Canopy Coverage of 42.6% is unlikely to be achieved, as it includes roof gardens and communal open spaces without deep soil to support large canopy trees. In any event, it will take years for proposed new plantings to grow sufficiently to replace the canopy destroyed by the removal of the Turpentine and other trees.

Insufficient Deep Soil Zone:
The EIS argues that as Council’s Alternate TOD Scenario does not apply, there is no requirement for the Deep Soil Zone to occupy 50% of the site area, and that in fact the 50% requirement would significantly limit development of the site. The size of the Deep Soil Zone is limited by the size of the Basement levels below. While the EIS emphasises that the “landscaped area” is 30.2%, this includes communal open space and rooftop terraces with no deep soil. The EIS does not quantify the Deep Soil Zone. The Architectural Plans and Design Report show a proposed Deep Soil Zone of 24.6% (939sqm). However, the Additional Landscape Report and Crime Prevention Report show Deep Soil at only 884sqm, while the Design Statement says the proposal has provided only 821sqm (21.5%). This inconsistency needs to be resolved. Even at 24.6%, the proposed Deep Soil Zone will be inconsistent with the future character of the area which is highly likely to be 50% under Council’s Alternate TOD.

Inadequate Biodiversity Report:
The BDAR reaches the conclusion that the area of biodiversity on the site is highly degraded Blue Gum High Forest, and that the only significant species present is the Large-eared Pied Bat. This appears to be inconsistent with almost every other BDAR written for proposed development sites in or near Middle Harbour Road which conclude the area is Sydney Turpentine Ironbark Forest. In addition, the report makes no mention of the catchment which flows east from 32 Middle Harbour Road, a mere 200 metres from the proposed development site, into Gordon Creek, or to any of the flora and fauna contained in the Riparian zone associated with this creek which may be affected by the proposed development, as stormwater flows from the proposed development site into the catchment.

Insufficient Assessment of Environmental Heritage:
The Statement of Heritage Impact is based on aerial photographs and views of the proposed development site from the public domain only. It recognises that issues that may be raised by the community during the “ongoing consultation process” are a Key Uncertainty. Given these limitations and uncertainty, the conclusion that the proposed development will have no significant impacts on Heritage Items at 9 Middle Harbour Road and 19 Russell Avenue cannot be relied upon.

Isolation of 22 Middle Harbour Road:
The EIS argues that the isolation of 22 Middle Harbour Road between the proposed development and the site at 24-28 Middle Harbour Road is acceptable, as 22 Middle Harbour Road is capable of being developed on its own. It ignores the fact that if not developed, 22 Middle Harbour Road will be significantly impacted in terms of lack of privacy, overshadowing, view loss and increased stormwater flowing into it.

I fully support the demolition of existing structures and construction of a 9-storey residential flat building including:
approximately 78 market residential units
approximately 22 affordable housing units
ground floor common facilities/communal open space.

I do believe however, that there should be more storeys and more residiential units instead of the current amount.

I do not think this development should go ahead. The old houses near this site are really special and part of our area’s history. If you build a big apartment block here, those houses will look out of place and lose their value and meaning. It feels wrong to ignore the culture and history of our street.

Our street is full of small houses, gardens and trees, and a big, tall building just does not match. It will look too big and blocky compared to everything else around it. There are already so many cars on our road, and adding even more people and cars will make it hard to drive and park safely. The development will also cut down important trees and take away the homes of birds, possums and other animals. Our street will lose its green and peaceful feel. Our drains, parking spots and public transport already struggle, and this will make things worse for everyone.

Particularly the families that remain in the area who remain in small houses, their light and views will be blocked by this large development.

I write to formally object to the proposed multi-level development at 16–20 Middle Harbour Road, Lindfield.

If approved, this development would result in my property at 22 Middle Harbour Road being effectively “sandwiched” between two large multi-storey apartment blocks — the proposed development at 16–20 Middle Harbour Road on one side, and the approved development at 24–28 Middle Harbour Road on the other. Compounding this, a third apartment block is planned across the street at 11–19 Middle Harbour Road. This would fundamentally alter the character and amenity of my property, converting it from a highly desirable single-residential home to an isolated dwelling overshadowed and dominated by dense development on all sides. The approval of such a project would signal blatant disregard for the current residents.

The impacts of this outcome are not theoretical — they would be severe, ongoing, and effectively irreversible. They include substantial overshadowing of both the front and rear of my property, a significant loss of privacy due to inadequate setbacks and poor transition zoning and increased noise and reduced air quality from intensified vehicle movements.

In addition to the above, the proposal is inconsistent with the prevailing character of the neighbourhood, which remains predominantly low-rise and includes several heritage-listed homes whose setting and significance will be compromised. The removal of established tree canopy would irreparably diminish the local environment and biodiversity. The proposed development will also exacerbate existing traffic and parking pressures and place further strain on already-stressed infrastructure, including stormwater, sewerage, and public transport.

Finally, I note that this proposal is inconsistent with Ku-ring-gai Council’s Preferred Alternative Scenario, which emphasises appropriate transition zones, preservation of heritage values, and retention of significant vegetation.

For these reasons, I respectfully submit that this development, if approved, would have an unacceptably detrimental impact on the liveability, value, and character of the neighbourhood and in particular 22 Middle Harbour Road. I urge Council to refuse this application.

I object to the above proposed development in Lindfield as follows:

Isolation of Heritage Homes
The development will adversely impact the heritage values and culture of the heritage listed homes nearby the proposed development site.

Impact on Local Character
The height, scale and design of the proposed development are excessive and out of keeping with the surrounding low-rise streetscape and heritage context.

Make my current property a “Sandwich Block”
As I am the owner of the house at 22 Middle Harbour Road, Lindfield, the proposed development will have serious adverse implications for me including without limitation: shadowing, visual and other privacy implications; unbearable noise, worsened air quality and overshadowing of my house, front-yard and backyard.

My property will become a “sandwich block”, sandwiched between two large multi-storey apartment blocks on both sides of my house (ie the proposed multi-storey apartment block development at 16-20 Middle Harbour Road, Lindfield; and the above proposed development at 24-28 Middle Harbour Road, Lindfield). Further, there is the proposed multi-storey apartment block development at 11-19 Middle Harbour Road, Lindfield which is across the street from my property. Therefore, my property amongst these proposed developments will change from a highly desirable property to become unattractive. This will also impact the value of my property negatively and considerably.

The setbacks and transition zones are grossly inadequate and reduce the privacy of numerous nearby residences.

Traffic and Parking Concerns
The proposed development will worsen traffic congestion for the area.

Environmental Impact
Precious tree canopy and vital wildlife habitats will be destroyed. Many trees will be destroyed.

Infrastructure Strain
As current infrastructure including stormwater, sewer, transport system and parking are already strained, the proposed development could cause further problems.

Inconsistent with Ku-ring-gai Council’s Preferred Alternative Scenario
The proposal ignores the Council’s key planning principles and ignores the surrounding heritage significance and value of the area, together with the site’s specific biodiversity value.

I object to the above proposed development in Lindfield as follows:

Isolation of Heritage Homes
The development will adversely impact the heritage values and culture of the heritage listed homes nearby the proposed development site.

Impact on Local Character
The height, scale and design of the proposed development are excessive and out of keeping with the surrounding low-rise streetscape and heritage context.

Creation of a “Sandwich Block”
The proposed development will have serious adverse implications for the residents including without limitation: shadowing, visual and other privacy implications; unbearable noise, worsened air quality and overshadowing of my house, front-yard and backyard.

22 Middle Harbour Road, Lindfield will become a “sandwich block”, sandwiched between two large multi-storey apartment blocks on both sides of the house (ie the proposed multi-storey apartment block development at 16-20 Middle Harbour Road, Lindfield; and the above proposed development at 24-28 Middle Harbour Road, Lindfield). Further, there is the proposed multi-storey apartment block development at 11-19 Middle Harbour Road, Lindfield which is across the street from the property. Therefore, 22 Middle Harbour Road amongst these proposed developments will change from a highly desirable property to become unattractive.

The setbacks and transition zones are grossly inadequate and reduce the privacy of numerous nearby residences.

Traffic and Parking Concerns
The proposed development will worsen traffic congestion for the area.

Environmental Impact
Precious tree canopy and vital wildlife habitats will be destroyed. Many trees will be destroyed.

Infrastructure Strain
As current infrastructure including stormwater, sewer, transport system and parking are already strained, the proposed development could cause further problems.

Inconsistent with Ku-ring-gai Council’s Preferred Alternative Scenario
The proposal ignores the Council’s key planning principles and ignores the surrounding heritage significance and value of the area, together with the site’s specific biodiversity value.

There doesn't seem to be enough thought given to the capacity of the area to cope with significantly more cars, waste and need for services. As a young person I'm all for development and affordable housing, but let's think about how many of these units will be empty or foreign owned, before we go ruin our few remaining beautiful suburb to line the pockets of politicians and developers. Australian culture is being eroded by the day it seems!

I provide the attached submission relating to this project.
Regards,
Catherine Ong
5 Russell Ave, Lindfield NSW

I wish to raise my concerns regarding the proposed multi-level development at 16–20 Middle Harbour Road, Lindfield, as I believe it could have a number of unintended consequences for the surrounding area. One of the key issues is the potential impact on nearby heritage-listed homes, which contribute significantly to the character and cultural value of the neighbourhood—this development risks isolating them and diminishing their prominence. The scale and height of the proposal appear inconsistent with the existing low-rise streetscape, and may not sit comfortably within the heritage context that defines much of Lindfield. For residents of 22 Middle Harbour Road, the development would place them between two large apartment blocks, with another across the street, creating a sense of enclosure that could affect both amenity and property value. Privacy, noise, and overshadowing are genuine concerns, especially with limited setbacks and transition zones that don’t seem to offer sufficient buffering. The area already experiences traffic congestion, and additional dwellings could exacerbate this, along with pressure on parking and local infrastructure such as stormwater and sewer systems. There’s also the environmental aspect—many trees would be lost, which could affect local biodiversity and the tree canopy that’s so valued in this part of Lindfield. Finally, the proposal seems to diverge from Ku-ring-gai Council’s preferred planning principles, particularly in terms of respecting heritage and biodiversity. I hope these points will be carefully considered in the assessment process.

I oppose the proposed development, which is not at all suitable for the site at 16-20 Middle Harbour Rd (Site). My main reasons for opposing the development include:
• it is inconsistent with a good planning outcome and in conflict with the alternative planning scheme proposed by Kuring-Gai Council (Council), which has widespread community support (TOD Alternate Preferred Scenario)
• its height, bulk and density;
• the lack of transition, in terms of height and density, to the neighbouring residential properties;
• its adverse impact in terms of overshadowing and loss of solar access and privacy on adjacent and other neighbouring properties;
• the stranding of number 22 Middle Harbour Road (MHR) between two 9 storey developments that would result if the SSD application for 24, 26 and 28 MHR is also approved;
• its adverse impact from a heritage perspective on the Trafalgar Heritage Conservation Area (HCA);
• the loss of tree canopy and biodiversity that will result; and
• conflict with the character and streetscape of the neighbourhood, including the adverse visual impacts of such a large, angular and dense building.

This applicant did not engage in any early consultation with me notwithstanding that I live in MHR in the block between Lindfield Avenue and Trafalgar Avenue.
I expand on some of my objections as follows:
• The floor space ration of 3.16:1 substantially exceeds the FSR of 1.8:1 proposed for the Site in the TOD Alternate Preferred Scenario. The bulk and density proposed are inappropriate for the Site.
• By its own admission, the Proposal is only ‘largely compliant’ with setback requirements – it should be fully compliant.
• There is no sensitive interface with the neighbouring dwellings to the east, west and north of the Site.
• The shadow diagrams that are included in the proposal indicate a degree of shadowing that is unacceptable.
• The proposed development would dominate, and have an overbearing effect on, the surrounding streetscapes.
• Neighbouring properties that are overlooked by the buildings will suffer a substantial loss of privacy.
• Rooftop spaces will mean loss of privacy for surrounding properties and noise in the evenings (potentially late into the night).
• The Site is adjacent to number 22 MHR, which is between the Site and the site covered by SSD-82548708 (24, 26 and 28 MHR). Leaving it (a single storey residence) stranded between two SSDs of 9 storeys is neither equitable to the owner of number 22, nor a good planning outcome as that property would on its own be too small for any redevelopment taking advantage of the TOD or the TOD Alternate Preferred Scenario.
• Number 18 MHR is land with high biodiversity value that is particularly sensitive to impacts from development and clearing). Removal of a tree with high biodiversity value from number 18, and the removal of 27 other medium or low category trees indicated in the EIS, is unacceptable.
• Boundary planting will not hide the stark facades of the buildings, nor attract the bird and other wildlife that the current tree canopy on the Site attracts.
• The heritage value of the Trafalgar HCA will be undermined and substantially diminished if the development proceeds.
• The applicant has argued that the proposed development is compatible with what might be built on surrounding properties in the future under the TOD, yet it fails to take account of the cumulative effect of the proposed development and the surrounding future developments. The cumulative impact on traffic in MHR and surrounding streets during and after construction, and the cumulative impact on other facilities such as water and waste water must be considered.
• The Site is opposite number 9 MHR, which is a stranded Heritage Item. The heritage value of 9 MHR is already in danger of being significantly undermined by immediately adjacent development applications (an SSDA on one boundary and a DA on the other. The proposed development would further undermine any heritage value attributable to 9 MHR, and result in multi storey developments on three sides. This would be a very poor planning outcome.

I believe the council's alternative plan for the TOD program should be accepted by the state governemnt. The proposal for this large development in Middle Harbour Road has not been considered in the context of the area and other properties surrounding it. Those properties adjacent to the property will be completely over whelmed by the sheer size of this property. The council's alternate plan has been well thought out and delivers more dwellings in a way that is sympathic to the unique environment of Ku-Ring-Gai. Large blocks of units have been put on the west of the highway where the natural slope of the land can be used for better views, light and ventilation (ie more energy efficient). This has been done well in Gordon. Areas of historical significance on the east side can be maintained.

Please see the attached submission objecting to the project

refer to attachment.

• Its a 10storey building with excessive bulk and size.
• With another SSD for 24-28 Middle Harbour Road, it will completely isolate the single storey dwelling at number 22 MHR.
• It does not meet the required setbacks
• It has 4 areas of communal space on the roof that will generate excessive noise
• There are numerous inaccuracies and inconsistent data in the Environment Impact Statement.
• The 10 storey development will have an unacceptable impact on neighbouring properties.
• It does not fulfill the objective of the TOD controls in Chapter 5 of the Housing SEPP which is to ensure development is of an appropriate bulk and scale.
• The building design includes a long 41m façade of 10 storeys to Middle Harbour Road without any open central space to visually reduce its bulk in the context of the existing streetscape.
• The habitat of the endangered species Large-eared Pied Bat (Chalinolobus dwyeri) is cited as using this site.
• The development site is over 550 metres walking distance from Lindfield Station. At 31m this is higher than Council’s Preferred scenario limits for this site.
• The site is part of the overflow from the Highway ridgeline into Gordon Creek and then Middle Harbour. The 15 m excavation will disturb and alter the flow of water increasing the flooding in an existing flood prone area.
• More than half the existing trees will be removed.
• The proposal does not provide sufficient details of the affordable housing it includes and guarantees that it will always stay affordable housing in an affluent area.

Submission with comments attached as Word document

I write to formally submit concerns and comments regarding the proposed development at 16 - 20 Middle Harbour Road, Lindfield, in the context of broader planning considerations affecting the surrounding precinct.

1. Need for Strategic Coordination with 15–27 Russell Avenue & 54-50 Trafalgar Avenue, Lindfield
The proposed development at Middle Harbour Road must be considered in parallel with the potential future development of 15–27 Russell Avenue & 54-50 Trafalgar Avenue. This site encompasses a large, contiguous landholding which is currently under review for significant redevelopment potential, including the proactive heritage delisting of 19 Russell Avenue. This step is being undertaken specifically to enable the parcel’s integration into a cohesive TOD (Transport Oriented Development) project in alignment with the State’s strategic housing objectives.

2.Built Form Interface
The proposed development at Middle Harbour Road must be assessed in the context of the anticipated higher-density development of 15–27 Russell Avenue & 54-50 Trafalgar Avenue. The Russell Avenue site is expected to support a greater building height and residential yield, consistent with the principles of the TOD SEPP and its proximity to key transport infrastructure.
It is critical that approval of the Middle Harbour Road development does not pre-emptively constrain the future development potential of 15–27 Russell Avenue & 54-50 Trafalgar Avenue —particularly through built form transitions that may later be used to justify a reduction in permitted height or floor count on the Russell Avenue site.

To meet the State Government’s strategic housing and urban consolidation goals, 15–27 Russell Avenue & 54-50 Trafalgar Avenue must be allowed to achieve its maximum feasible height and density and should not be penalised by the timing or design of adjacent developments approved without reference to its future potential.
 

Please find attached the Friends of Ku-ring-gai Environment Inc (FOKE) submission

Please see attached objection.