Residential Development with infill affordable housing - 25-27 Rosedale Road and 1 and 1A Edward Street, Gordon

Dear Sir/Madam,

I am writing as a resident of the Gordon area / concerned community member to express my strong concerns and opposition to any proposed high-density apartment developments within Gordon. While I acknowledge the importance of increasing housing supply across New South Wales, I believe that concentrating large-scale developments in Gordon is not appropriate without sufficient infrastructure upgrades and comprehensive planning.

1. Traffic congestion and transport infrastructure limits

Gordon already experiences significant traffic congestion during peak hours, particularly around Pacific Highway and surrounding arterial roads. Public transport, including Gordon Station and local bus services, is frequently under pressure. Introducing a large number of new apartment dwellers will further strain an already congested transport network, resulting in longer commute times, increased road safety risks, and reduced overall liveability.

2. Insufficient supporting infrastructure and services

The existing infrastructure in Gordon, including schools, childcare facilities, healthcare services, and community amenities, is already operating near capacity. A sudden increase in population density without parallel investment in infrastructure expansion will lead to overcrowding and reduced service quality, negatively affecting both new and existing residents.

3. Loss of neighbourhood character and heritage value

Gordon is known for its low to medium-density residential character, green surroundings, and peaceful suburban environment. High-rise apartment developments would significantly alter the visual landscape and identity of the area, reducing privacy, increasing overshadowing, and diminishing the established neighbourhood character that residents value.

4. Environmental impact and green space reduction

Increased urban density without adequate planning can contribute to the urban heat island effect, increased stormwater runoff, and reduced tree canopy coverage. Gordon’s existing green spaces and tree-lined streets are important environmental assets that should be preserved, not compromised by excessive densification.

5. Lack of meaningful community consultation

Many residents feel that current planning proposals do not adequately reflect genuine community consultation or transparency. Major redevelopment decisions should involve meaningful engagement with local residents to ensure that planning outcomes reflect long-term community needs rather than short-term housing targets alone.

6. Preference for balanced and distributed development

I am not opposed to housing development in principle. However, I strongly believe that growth should be distributed more evenly across areas with stronger infrastructure capacity, rather than concentrating high-density developments in established low-density suburbs such as Gordon.

Conclusion

In summary, I respectfully urge the NSW Government to reconsider any plans for high-density apartment developments in Gordon. The current infrastructure, environmental capacity, and community structure do not support such intensive redevelopment. A more balanced and carefully planned approach to housing growth would better serve both existing residents and the broader needs of Sydney’s future development.

Thank you for your time and consideration.

To: The Assessing Officer
NSW Department of Planning, Housing and Infrastructure
Submitted via: NSW Planning Portal (EXH-122525738)




Dear Sir/Madam’

I write to formally object to State Significant Development Application SSD-85549710, proposing two residential flat buildings of 8–9 storeys (119 apartments, including 24 affordable) with basement parking at 25–27 Rosedale Road and 1 & 1A Edward Street, Gordon.

While I do not oppose residential development in principle near Gordon Station, the proposal as submitted is excessive in scale, inconsistent with the planning framework now applicable to this precinct, and inadequately supported by technical assessments. I respectfully urge the Department to refuse or substantially modify the application.


1. INCONSISTENCY WITH THE KU-RING-GAI TOD ALTERNATIVE PLAN

The NSW Government formally adopted Ku-ring-gai Council’s Transport Oriented Development (TOD) Alternative Plan on 14 November 2025, following extensive community consultation and Council’s submission to the Department of Planning in June 2025. That plan was specifically designed to deliver required housing targets while providing stronger protections for heritage, the environment, tree canopy, and transitions between densities.

The subject site sits on low-scale residential streets — Rosedale Road and Edward Street — away from the Pacific Highway town centre core where the greatest height and density uplift is appropriate under the Alternative Plan. Buildings of 8–9 storeys on this location are inconsistent with the stepped-height transitions envisaged in the adopted Alternative Plan. Approving this application at the heights proposed would undermine the very framework that both the NSW Government and Ku-ring-gai Council negotiated in good faith and which is now the gazetted planning instrument for this precinct.

The Department should assess this application against the current planning controls, not the superseded original TOD SEPP provisions that were in force at the time of lodgement.





2. EXCESSIVE HEIGHT, BULK AND SCALE

The proposal seeks 8–9 storeys — equivalent to a roofline of approximately 27–29 metres — on a predominantly low-density residential street. This is significantly out of character with the surrounding neighbourhood context and imposes an unreasonable transition in scale between the development and adjacent lower-density dwellings.

The site’s 5,931 sqm area does not justify two towers of this massing side by side. The resulting bulk will cause substantial amenity impacts on neighbouring properties, including overshadowing, loss of privacy, and visual intrusion. The EIS does not adequately demonstrate that the Apartment Design Guide objectives for building separation, solar access, and visual privacy are met for affected neighbouring homes — not merely for future residents within the development itself.

The application should be redesigned to achieve appropriate setbacks and a genuine transition in height at the site’s boundaries with adjoining residential properties.


3. HERITAGE AND CHARACTER IMPACTS

Gordon is characterised by significant built heritage and tree-lined streetscapes that contribute to Ku-ring-gai’s distinct identity. The Gordon Heritage Conservation Area and a number of individually listed heritage items are located in close proximity to the subject site. The proposal has not adequately assessed its visual impact on the heritage setting, including view corridors, streetscape continuity, and the cumulative effect of this development alongside other nearby SSD applications in the same precinct (including SSD-85838457 at 29–33 Rosedale Road).

I request that the Department require a comprehensive Heritage Impact Statement prepared by a suitably qualified heritage specialist, assessing the cumulative visual impact of this and adjacent SSD proposals on the Gordon heritage streetscape.


4. INADEQUATE TRAFFIC AND PARKING ASSESSMENT

The Traffic Impact Assessment in the EIS does not adequately account for the cumulative traffic generation of multiple simultaneous SSD applications in the Gordon precinct — including proposals at Rosedale Road, Edward Street, McIntosh Street, Stanhope Road, and Park Avenue. Each application has been assessed in relative isolation, ignoring the compound effect on local street network capacity.

Rosedale Road and Edward Street are local residential streets with limited carriageway widths. The introduction of up to 119 dwellings plus basement parking access on these streets will materially worsen congestion at intersections that already experience peak-hour queuing. I request the Department commission an independent cumulative traffic assessment for the entire Gordon TOD precinct before determining this application.

5. INFRASTRUCTURE CAPACITY CONCERNS

The EIS does not provide adequate evidence that existing water supply, sewerage, stormwater, and electricity infrastructure can absorb the cumulative demand from this development alongside the numerous other SSD applications already lodged or approved in Gordon. Sydney Water’s and Ausgrid’s capacity to service the precinct as a whole has not been independently verified.

Given the scale of concurrent development proposed across the Gordon precinct, the Department should require written confirmation from relevant utility providers — not merely referrals — that adequate infrastructure capacity exists before any consent is granted.


6. TREE CANOPY AND LANDSCAPE IMPACTS

The subject site currently contains mature trees that contribute to Gordon’s significant urban tree canopy. The EIS proposes the removal of a number of trees to accommodate the development footprint, underground parking, and landscaping. The cumulative loss of canopy across the TOD precinct is significant and conflicts with Ku-ring-gai’s Urban Forest Strategy.

Any consent should require: retention of all feasible existing trees; an independent arboricultural assessment; and replacement canopy planting at a ratio of no less than 3:1, using locally endemic species of appropriate size.


7. DESIGN QUALITY

The proposed architectural treatment, as represented in the submitted documents, does not achieve a high standard of design quality commensurate with a prominent residential development in an established garden suburb. The façade articulation and materiality appear generic and fail to respond to the local vernacular or the character of Rosedale Road. I request that the Department impose a condition requiring design review by the NSW Design and Review Panel, with design changes made prior to any construction certificate being issued.


8. AFFORDABLE HOUSING

I acknowledge the inclusion of 24 affordable housing units as a positive element of the proposal. However, the benefits of affordable housing inclusion must be weighed against the overall scale and impact of the scheme.






CONCLUSION

For the reasons set out above, I object to the grant of development consent for SSD-85549710 in its current form. I respectfully request that the Department:

1. Refuse the application in its current form, or require redesign with appropriate setbacks, scale and height transitions;

2. Commission an independent cumulative traffic and infrastructure assessment for the Gordon TOD precinct;

3. Require an independent Heritage Impact Statement addressing cumulative visual impacts;

4. Refer the revised design to the NSW Design and Review Panel

5. Assess the application against the current Ku-ring-gai TOD Alternative Plan controls gazetted in November 2025.

I request to be kept informed of any amendments to the application and to be notified of the Department’s determination.




Yours faithfully,

James Scott

26 May 2026

The Assessing Officer
Department of Planning, Housing and Infrastructure
NSW Government
Via: NSW Major Projects Planning Portal


SUBJECT: OBJECTION – State Significant Development Application SSD-85549710 - Site: 25-27 Rosedale Road & 1 and 1A Edward Street, Gordon

Dear Assessing Officer,

I write to formally object to the State Significant Development (SSD) application SSD-85549710 proposing a high-density residential development with in-fill affordable housing at 25-27 Rosedale Road and 1 and 1A Edward Street, Gordon.

As a local resident, together with my family who have resided in Gordon during the past 42 plus years, who will be directly impacted by the scale and nature of this development, I strongly oppose the current proposal based on the following planning grounds:

• Excessive Bulk, Scale, and Height: The proposed built form is entirely out of character with the low-density, leafy suburban streetscape of Gordon. The height, bulk, and setbacks are excessive and fail to provide an appropriate visual transition between the high-density footprint and adjoining low-rise residential properties.
• Loss of Amenity and Privacy: The proposed design causes unreasonable overshadowing of neighbouring properties, directly violating solar access requirements. Furthermore, the positioning of balconies and windows will cause severe overlooking and a complete loss of visual privacy to adjoining homes and private open spaces.
• Traffic, Congestion, and Parking: Rosedale Road and Edward Street already experience localised congestion. The significant increase in traffic volumes generated by this development will exacerbate existing bottlenecks, create pedestrian safety hazards (especially around local schools and the transport interchange), and spill over into already constrained street parking.
• Inadequate Infrastructure Capacity: The local infrastructure, including stormwater management, waste services, and public transport capacity, has not been appropriately scaled to absorb the sudden population increase this development would introduce.

Conclusion

The proposed development represents an overdevelopment of the subject site. It fails to protect the established neighbourhood character and imposes an unacceptable reduction in residential amenity.

I respectfully request that the Department of Planning, Housing and Infrastructure refuse this application in its entirety or require a substantial redesign that complies with established local planning controls.

Thank you for considering my submission and for your role in ensuring appropriate development outcomes for our community.

Yours sincerely,
Diane Scott

NSW Department of Planning, Housing and Infrastructure
Submitted via the NSW Major Projects Planning Portal
OBJECTION SUBMISSION
Application Reference: SSD-85549710
Address: 1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon NSW 2072
Proposal: Construction of residential flat buildings containing 119 apartments and 135 car parks accessed via Edward Street.

Dear Assessment Officer,

I am writing to register my strongest possible objection to application SSD-85549710. This proposal is a gross overdevelopment that I believe must be refused under Section 4.15 of the EP&A Act 1979, with the most critical and dangerous flaw being the catastrophic impact on local traffic and public safety.
Traffic and Access Inadequacy on a Dead-End Street
The applicant proposes routing all vehicular ingress and egress for 135 car parking spaces directly onto Edward Street. Edward Street is a highly constrained, narrow, residential dead-end street. It completely lacks the carriage width, structural capacity, and turning geometry required to safely absorb the heavy traffic flows generated by 119 apartments. In addition the visibility to exit north onto Rosedale Road is poor. Entering Edward St is also impacted if a large car/truck is entering with cars often needing to give way to incoming traffic.
Funnelling high-volume basement parking traffic into a tight cul-de-sac will cause immediate gridlock during peak hours. It creates severe, highly dangerous vehicle conflict points and presents an unacceptable hazard to pedestrian safety. The proposal completely fails to comply with the safety and environmental capacity thresholds mandated by the Transport for NSW (TfNSW) Guide to Transport Impact Assessment. This planning proposal should also be considered together with the proposal at 2A – 4 Edward St and 29-33 Rosedale Rd ( approx. 230 apartments that would also see entry /exit via Edward St) which I believe would lead to a gridlocked street.
Additional Planning Failures:
• Height Issue: The proposed 30.8-metre height seems to violate Section 18 of the Housing SEPP, which caps the maximum permissible affordable housing bonus at 28.6 metres (a 30% uplift on the 22-metre TOD baseline).
• Strategic Conflict: The November 2025 gazetted Ku-ring-gai TOD Alternative Map explicitly excluded Edward Street from high-density zoning to preserve it as a low-density buffer zone.
• Environmental Destruction: The wholesale removal of 51 mature canopy trees violates Section 3D of the Apartment Design Guide (ADG) and permanently destroys the local biodiversity corridor. The area also sits within the Roberts Connservation Area, and the large scale development will likely affect the bat colony.
Edward Street cannot physically support the traffic this massive development would introduce. I strongly urge the Department to protect our local community from this hazardous proposal and refuse the application.

I wish to lodge a formal objection to the State Significant Development Application (SSDA-85549710) for the construction of two residential flat buildings comprising 119 apartments on 25-27 Rosedale Road and 1 and 1A Edward Street, Gordon.

This proposal is inappropriate for the following key reasons:

1. Excessive Height and Bulk
The proposal seeks 8–9 storey buildings on a site previously zoned R2 Low Density Residential with a maximum height limit of 9.5 metres. Even with the TOD and Housing SEPP bonus, this represents a massive overdevelopment. The height and bulk are completely out of character with the surrounding low to medium density neighbourhood.

2. Poor Quality Design
The architectural response is generic and fails to deliver high-quality design. The rendered elevations and repetitive balcony modules lack meaningful articulation, innovation, or genuine contextual response. Materials appear bland and institutional rather than sympathetic to Gordon’s garden suburb character. This is not the high standard of design expected in a prominent corner location within a heritage conservation area.

3. Disregard for the Heritage Conservation Area & Cumulative Impact with Opposite Development
The site is located within the Roberts Grant Heritage Conservation Area. While the Design Report acknowledges this, the proposal fails to provide a sympathetic response to the established character of heritage homes and bungalows that define Gordon.

Importantly, this application must be assessed in conjunction with the approved or proposed development directly opposite at 29-33 Rosedale Road and 2A-4 Edward Street (SSD-85838457).

Together, these two large-scale 8–9 storey developments will result in the near-total transformation and DESTRUCTION of the entire eastern side of Rosedale Road. This cumulative impact will irreparably damage the character and amenity of the Roberts Grant Heritage Conservation Area. The combined bulk, height and contemporary built form will overwhelm the streetscape and erode the garden-suburb character that the conservation area seeks to protect. This is not incremental change — it is wholesale redevelopment that should not be approved without a comprehensive precinct-wide masterplan.

4. Traffic Overload and Parking Impacts
The addition of 119 dwellings (combined with the opposite development) will generate excessive additional traffic on Edward Street and Rosedale Road. A single vehicle access point is inadequate and will create safety and congestion issues on an already constrained local road network.

5. Devastating Impact on Tree Canopy and Wildlife
The Arboricultural Report confirms the removal of 51 trees (including 1 high-category tree) and transplantation of 15 others. When combined with likely tree losses from the opposite development, the cumulative impact on Gordon’s tree canopy and local wildlife will be severe and long-lasting.

6. Current Infrastructure Cannot Support the Development
Gordon’s existing infrastructure (stormwater, sewerage, roads, electricity, schools and open space) is already strained. The combined pressure from both this proposal and the opposite development will place unsustainable demand on local services and ageing infrastructure.

Conclusion
This proposal, particularly when considered together with the development directly opposite (SSD-85838457), represents unacceptable overdevelopment that will destroy the character of Rosedale Road and the Roberts Grant Heritage Conservation Area. I strongly urge Council and the Department of Planning to refuse this application.

A much smaller, lower-scale and more sympathetic design is required if any redevelopment is to be considered on this site.

The proposal represents an excessive and poorly integrated form of development that would result in unacceptable impacts on traffic safety, pedestrian amenity, heritage values, biodiversity, tree canopy and neighbourhood character.
Should the Department nevertheless consider approval, the proposal should first be substantially redesigned to reduce height and bulk, retain significant trees, preserve heritage values, improve traffic outcomes and demonstrate a genuinely balanced planning outcome. Attached is my submission.

This proposed development is surely far in excess of what the existing infrastructure can support. A building of four storeys would surely be far more reasonable than the proposed 9 storeys. If all 119 apartments become occupied, and with each household owning two vehicles (which is normal) the impact on traffic density will be horrendous. Also, the existing sewerage system is probably 100 years old and will not be able to cope with with the discharge from 119 homes, where currently there are only 4 residences. I respectfully suggest that the development be scaled down to something more appropriate to the location.

I write as a lifelong resident of this street to formally object to the proposed residential apartment development. My objection is grounded in direct, lived experience of this neighbourhood with an understanding of the consequences attributed to developments such as that of the proposal submitted.


Having lived on this street my entire life, I have witnessed first-hand what a genuinely close-knit and peaceful residential community it is. As children, neighbours would ride bikes up and down the street together without concern . A reflection of the safe, low-traffic, community-oriented environment that residents have long valued and worked to preserve. It is precisely this character that the proposed development threatens to permanently and irreversibly erode.

This street has already borne a disproportionate burden of development disruption. During the construction of a nursing home on the street, residents endured years of heavy vehicle traffic, excessive noise, air pollution, and genuine safety hazards on what had previously been a quiet residential street. Throughout that period, construction vehicles and workers' cars consumed the overwhelming majority of available street parking, displacing homeowners and commuters who had relied on it.
The consequences did not end with construction. The completed facility brought a sustained and permanent increase in street traffic, with visitors and staff occupying parking spaces and disturbing the peace of the neighbourhood on an ongoing basis. This precedent is directly relevant to the current proposal. The harm caused was not temporary, it was structural and lasting. A further development of 9 stories with 119 residential apartments will compound these impacts across every dimension.

The proposal provides 135 car spaces for 119 apartments. Applying a conservative average of 1.7 vehicles per household (modest by the standards of the Upper North Shore). The obvious shortfall will inevitably be absorbed by the surrounding street network, further eroding parking availability for existing residents and accelerating the traffic and amenity issues already experienced.

The proposed development is out of scale with the established built form of the street and surrounding area. This area of the Upper North Shore is characterised by low-density residential housing and a streetscape that prioritises liveability over density. The introduction of a multi-storey apartment building of this scale represents a fundamental departure from that character.

Ultimately, I strongly urge the NSW State Government to reject this development proposal.

We are writing regarding the SSD submission that has been lodged for the Residential Development - 25-27 Rosedale Road & 1 - 1a Edward Street Gordon.

I am 58 years of age, and have personally grown up in this area with my parents and grandparents and seen a lot of exiting housing development, whilst protecting the heritage and history of the north shore. We are not against planning for more affordable housing, but my wife & I are fully against this proposal that seems to have been proposed without any council consultation, especially after all the work the council has done with all the Ku-Ring-Gai community with all the planning alternatives to the initial TOD to provide NSW Government with the same outcomes, but more in line with fairness to the area.

This proposed SSD that has slipped through is NOT in keeping with the agreed amendment to the final TOD Ku-Ring-Gai submitted plans, which have now been approved with all community feedback.

We also find it very concerning knowing this proposal apart from going against the final TOD approved plans will be destructive to our community. Park Ave SSD Gordon was approved, that alone will create traffic nightmare given the location, at least it’s closer to where the agreed TOD zones were finally approved.

We will have a bigger issue at 25-27 Rosedale Road & 1 - 1a Edward Street Gordon.

We already have the nursing home and village in that vicinity, putting another 119 apartments 9 story's high, on a crest of a hill, will be a disaster as we all know. This is a prominent location of Gordon and the proposed height of 30.8m is extremely excessive and we understand exceeds the planning guidelines, not to mention being totally out of character for the existing streetscape. We also understand an additional 51 trees will be removed to make way for these proposed High-rise, again not appropriate for our ecosystem and will also impact the local flying fox colony nearby. We are also concerned about the shadowing over all the existing residents and what that will do, another reason the TOD came up with appropriate alternative options.

We also know this will cause all sorts of infrastructure concerns, especially around this eastern side where many heritage houses exist and have done for many years. Apart from Heritage, what this will do on the tree removal, biodiversity, environmental & local bush land impact, traffic and storm water is unimaginable, let alone provision for schools, street parking and community facilities.

My wife and I strongly oppose this, and hope alternative arrangements can be made to proceed with new affordable housing developments in more appropriate areas within the final TOD that was agreed by NSW state govt. our local council, and community.

Tim & Prue Wedlock
Nelson Street Gordon - Local residents

Submission Objecting to SSD-85549710
1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon
Proposed Development: Two 9-Storey Residential Flat Buildings (119 Apartments, 135 Car Spaces)

To Whom It May Concern,

I am a resident of Edward Street, Gordon, and wish to lodge a formal objection to SSD-85549710 for the proposed development at 1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon.

While I support well-planned housing growth in appropriate locations, I strongly object to this proposal because of its excessive height, bulk and scale, heritage impacts, traffic consequences, environmental impacts and inconsistency with local strategic planning.

1. Inconsistency with Ku-ring-gai Council’s Preferred TOD Planning Framework

A significant deficiency of the Environmental Impact Statement (EIS) is its failure to properly consider Ku-ring-gai Council’s adopted preferred Transport Oriented Development (TOD) scenario.

The EIS relies heavily upon the State Government TOD controls and associated saving provisions while failing to acknowledge or assess the Council’s award-winning preferred TOD planning framework. There is no meaningful discussion of whether the proposal complies with, departs from, or undermines the Council’s adopted strategic planning vision for Gordon.

This omission prevents a balanced assessment of the proposal and deprives decision-makers and the community of an understanding of how the development compares against the locally developed and publicly consulted planning framework.

The Department should require a detailed assessment against the Council’s preferred TOD scenario before determining this application.

2. Excessive Height, Bulk and Scale

The proposal seeks approval for two 9-storey residential buildings reaching approximately 30.8 metres in height.

This scale is fundamentally inconsistent with the existing and established character of Edward Street, Rosedale Road and the surrounding residential precinct. The proposal exceeds the scale anticipated by existing planning controls and would introduce a dominant built form that overwhelms neighbouring properties.

Particular concern arises from the visual prominence of the site, which occupies the crest of a hill. The EIS does not adequately assess the true visual impact of the proposal when viewed from surrounding streets and public spaces.

The development site at 27 Rosedale Road sits approximately 124 metres above sea level. By comparison:

7 Nelson Street is approximately 106 metres above sea level.
3 Rosedale Road is approximately 102 metres above sea level.
Rosedale Road Bridge is approximately 102 metres above sea level.
Accordingly, from the immediate low points along Rosedale Road, the top of the proposed development would present a relative height exceeding 52 metres above surrounding viewpoints. This would create an imposing and highly visible structure that would dominate the skyline and significantly alter the visual character of the locality.

The visual impact assessment contained within the EIS is inadequate for a site of such prominence and fails to properly communicate the extent of the building’s visibility from surrounding streets and residential properties.

3. Flawed Streetscape Analysis

The height, bulk and scale assessment within the EIS appears to rely upon the assumption that a separate proposed SSD development on the opposite side of Edward Street forms part of the existing streetscape context.

This approach is inappropriate and misleading.

A proposed development cannot reasonably be treated as part of the existing built environment when assessing the visual and character impacts of another proposal. The current streetscape should be assessed based on the existing approved and constructed environment, not by reference to other unbuilt developments.

This methodology artificially normalises excessive scale and understates the extent of change that this proposal would introduce.

4. Heritage Impacts and the Roberts Grant Conservation Area

The site is located within the Roberts Grant Conservation Area and contains buildings that contribute to the significance and character of the heritage precinct.

The proposal would result in the demolition of contributory heritage fabric and introduce built forms that are incompatible with the established heritage character of the area.

The proposed height, bulk and massing would diminish the significance of the conservation area by replacing a landscape characterised by detached dwellings, mature vegetation and generous garden settings with large-scale apartment blocks.

The Department should give substantial weight to the cumulative and irreversible heritage impacts of this proposal.

5. Traffic and Access Impacts

The proposal includes 135 parking spaces accessed from Edward Street.

Edward Street is a local residential street that already experiences high traffic pressures associated with nearby residential uses, commuter movements and the Anglicare aged care facility.

The introduction of 119 apartments and associated vehicle movements will substantially increase traffic volumes, turning movements and vehicle conflicts.

Particular concern exists regarding:

Increased congestion on Edward Street.
Vehicle interactions with residents, pedestrians and cyclists.
Conflicts with vehicles entering and exiting the Anglicare aged care facility.
Increased safety risks for elderly residents and visitors.
Additional traffic impacts at nearby intersections.
The EIS does not adequately demonstrate that the local road network can safely accommodate these impacts.

6. Environmental and Biodiversity Impacts

The proposal involves the removal of approximately 51 trees within a municipality renowned for its urban forest and environmental values.

The loss of this vegetation will significantly reduce local canopy cover, diminish habitat values and undermine broader objectives to preserve and enhance Ku-ring-gai’s distinctive landscape character.

The site is located in proximity to the Ku-ring-gai Flying-fox Reserve at the end of Edward Street. The EIS acknowledges the presence of Grey-headed Flying-foxes; however, the biodiversity assessment and proposed mitigation measures are inadequate.

Appendix M identifies the species but does not provide convincing evidence that the proposed mitigation measures will adequately address the impacts arising from:

Removal of mature vegetation.
Increased lighting.
Increased human activity.
Construction noise and disturbance.
Long-term habitat fragmentation.
Given the ecological significance of the Grey-headed Flying-fox and the proximity of an established flying-fox camp, a more rigorous assessment is required.

7. Cumulative Impacts

The Department should also consider the cumulative impacts of this proposal when combined with other recent and proposed high-density developments in Gordon.

The cumulative effects on traffic, heritage character, visual amenity, tree canopy, biodiversity and infrastructure have not been adequately addressed. Assessment of this proposal in isolation understates its true impact on the surrounding community.

Conclusion

For the reasons outlined above, I respectfully request that the Department refuse SSD-85549710.

The proposal is excessive in height, bulk and scale, inconsistent with the established character of the locality, detrimental to the Roberts Grant Conservation Area, likely to worsen traffic and safety issues on Edward Street, and would result in unacceptable environmental impacts including the loss of significant tree canopy and impacts on Grey-headed Flying-fox habitat.

Submission Objecting to SSD85549710
(1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon)
I strongly object to State Significant Development Application SSD85549710 for the proposed development at 1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon.
While I understand additional housing is needed in appropriate locations, this particular proposal represents overdevelopment of the site and is inconsistent with the character, environmental values, heritage significance and infrastructure capacity of the surrounding area.
The proposal for 119 apartments, 135 parking spaces and the removal of approximately 51 trees would significantly increase the intensity of development within a sensitive residential and heritage setting. In its current form, the proposal would adversely affect neighbourhood character, traffic conditions, biodiversity and local amenity.

1. Excessive Height, Bulk and Scale
The proposed buildings, reaching approximately 30.8 metres in height, are excessive and out of scale with the surrounding neighbourhood.
The development would introduce a level of visual bulk and density that is inconsistent with the established character of this part of Gordon. The proposal would dominate nearby properties, create an imposing built form and significantly alter the character of the locality.
The scale of the development is not justified by the site's context and would establish an undesirable precedent for future redevelopment.

2. Inconsistency with Good TOD Planning Principles
Transport-oriented development should provide additional housing while respecting local environmental constraints, heritage values and neighbourhood character.
In this case, the proposal appears to prioritise development yield over balanced planning outcomes. Its scale exceeds what is reasonably necessary to support housing objectives and fails to provide an appropriate transition between higher-density built form and the surrounding residential areas.
Good urban design requires taller buildings to transition sensitively to adjoining neighbourhoods. This proposal does not achieve that outcome.

3. Heritage Impacts
The site is located within the Roberts Grant Conservation Area and contains buildings that contribute to the heritage significance of the precinct.
Demolition of contributory heritage buildings would result in the permanent loss of historic character and diminish the integrity of the conservation area. The proposal does not adequately respect the established heritage streetscape or the significance of the surrounding heritage context.

4. Loss of Tree Canopy and Environmental Values
The removal of approximately 51 trees is a matter of significant concern.
Ku-ring-gai is renowned for its tree canopy and bushland character. Mature trees provide important environmental and community benefits, including habitat for native wildlife, urban cooling, stormwater management, carbon storage and neighbourhood amenity.
The loss of such a substantial number of trees would significantly reduce these benefits and contribute to the continuing decline of urban tree canopy.

5. Biodiversity Impacts
The site is located near important bushland and ecological areas, including the Ku-ring-gai Flying-fox Reserve.
Potential impacts on biodiversity, habitat connectivity, wildlife movement and threatened species should be subject to rigorous assessment. More attention should be given to cumulative impacts arising from multiple developments within the Gordon area.

6. Traffic and Road Safety
The proposal includes 135 parking spaces accessed from Edward Street. A development containing 119 apartments will generate substantial daily vehicle movements and place additional pressure on local roads and intersections.
The Edward Street and Rosedale Road intersection already experiences traffic and safety challenges due to traffic volumes, restricted sight lines (particularly in the north direction) and pedestrian activity. Additional traffic generated by the development is likely to increase congestion, reduce pedestrian safety and create further pressure on local road infrastructure.
Particular concerns include:
• Increased congestion at the Edward Street/Rosedale Road intersection.
• Reduced pedestrian safety.
• Increased pressure on on-street parking.
• Additional traffic conflicts associated with nearby residential and aged-care facilities.
• Potential cumulative impacts when considered alongside other developments in the area.
The traffic assessment should be independently reviewed to ensure that it accurately reflects peak-period conditions and cumulative development impacts.

7. Cumulative Impacts
This proposal should not be assessed in isolation.
The cumulative impact of multiple transport-oriented developments across Gordon has the potential to significantly alter the character and functioning of the suburb. The Department should carefully consider the combined impacts on roads, public spaces, biodiversity, tree canopy, drainage, infrastructure and community amenity.

8. Public Interest
The public interest requires that housing growth be balanced with environmental protection, heritage conservation and community liveability.
In its current form, SSD85549710 does not achieve that balance. The proposal would result in excessive height and bulk, significant tree loss, adverse heritage impacts and increased pressure on local infrastructure while providing insufficient community benefit to justify those impacts.

Conclusion
For the reasons outlined above, I respectfully request that the Department of Planning, Housing and Infrastructure refuse SSD85549710.
Should the Department nevertheless consider approval, the proposal should first be substantially redesigned to reduce height and bulk, retain significant trees, protect heritage values, minimise traffic impacts and achieve a more balanced planning outcome.
Thank you for considering my submission.

Yours sincerely,
Stephanie Vickers

To Whom It May Concern,

I object to SSD85549710. While I support well-located housing growth in principle, this proposal is not an appropriate outcome for this site due to its excessive scale, poor contextual integration, and unresolved environmental, heritage, traffic, and strategic planning impacts.

The proposal does not represent a balanced planning response when considered against local site constraints and the surrounding established residential context.

Planning Context and Strategic Alignment

The proposal does not adequately demonstrate alignment with Ku-ring-gai Council’s Transport Oriented Development (TOD) approach or its broader strategic planning framework for managing growth around transport corridors.

Ku-ring-gai Council has publicly highlighted its alternative approach to housing growth, including recognition by the Planning Institute of Australia for its strategic planning framework. This reinforces the importance of properly testing proposals against locally derived planning strategies that emphasise context-sensitive transition, rather than applying broad State-based density assumptions in isolation.

In this context, the proposal does not sufficiently demonstrate a graduated or sensitive transition in built form intensity and appears inconsistent with the intended character of surrounding residential interfaces.


Built Form, Height and Visual Impact

The proposed two 9-storey buildings (approximately 30.8 metres) are excessive for this location and do not reflect the existing or prevailing residential character.

Due to the site’s elevated position, the development would be visually dominant from surrounding streets and properties. The transition between the proposed scale and lower-density surrounding development does not appear to be adequately resolved.


Visual Impact Assessment

The visual impact assessment does not, in my view, adequately reflect the likely real-world outcomes of the proposal.

Concerns include:
• Limited representation of key viewpoints
• Insufficient consideration of cumulative visual impacts
• Potential reliance on future or proposed developments as part of the existing context baseline

As a result, the assessment may understate the overall visual impact of the proposal.


Heritage Impacts

The site is located within the Roberts Grant Conservation Area, which requires careful and incremental change to maintain its significance.

The proposal involves demolition of contributory elements and introduces a scale and form that is not consistent with the established heritage character. This raises concerns about the long-term erosion of the conservation area’s integrity.


Traffic and Access

Edward Street is a dead-end residential street that already experiences significant commuter parking demand.

Given that primary access to the development is via Edward Street, the proposal would intensify pressure on an already constrained local access point, resulting in:
• Increased congestion and reduced manoeuvrability
• Higher pedestrian and residential safety risks
• Additional pressure near the adjacent aged care facility
• Traffic levels that are not consistent with the function or capacity of the street network

Tree Removal and Environmental Impacts

The proposal includes removal of approximately 51 mature trees, resulting in a substantial loss of established canopy.

This raises concerns regarding:

• Reduced urban tree cover and streetscape quality
• Impacts on local biodiversity corridors
• Potential effects on nearby flying fox habitat
• Insufficient mitigation measures relative to the scale of vegetation loss

Conclusion

Overall, I consider the proposal to be insufficiently justified in its current form. It does not adequately respond to site constraints or achieve an appropriate balance between housing delivery and environmental, heritage, traffic, and contextual impacts.

I respectfully request refusal of the application on the basis that these impacts are not adequately resolved.

I object to such a tall building being built in a heritage conservation area. I understand more housing needs to be built but such a tall building at the top of the hill is not consistent with the surroundings. The traffic congestion on Rosedale Rd is a concern especially considering the aged care facility. The building at that height would overlook so many neighbours and is inconsistent councils preferred housing for the TOD. Building heights should consider the topgraphy of the area. I also don’t agree with so many trees being lost. The foot print of the building is inconsistent with other developments in the vicinity.

Objection to SSD85549710
Proposed Development at 1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon
I wish to object to SSD85549710, the proposed redevelopment of 1 & 1A Edward Street and 25 & 27 Rosedale Road, Gordon.
Although increased housing supply is an important planning objective, development must be appropriate to its location and should not come at the expense of environmental values, heritage significance, neighbourhood character or public safety. In my view, this proposal places excessive emphasis on development intensity while failing to adequately address the impacts that such a large project will have on the surrounding community.
Development Scale Is Excessive
The proposal involves two buildings of approximately 30.8 metres in height containing 119 apartments. This level of development is out of proportion with the surrounding residential environment and would introduce a scale of built form that is not characteristic of this part of Gordon.
The height and bulk of the buildings would have a substantial visual impact and would overwhelm nearby properties. Rather than complementing the existing character of the area, the proposal would fundamentally alter it.
Poor Response to TOD Principles
Transport-oriented development should encourage housing growth while maintaining the qualities that make neighbourhoods attractive and liveable.
In this case, the proposal appears to pursue the maximum development yield achievable on the site rather than a balanced outcome. The design does not provide a satisfactory transition between larger developments closer to transport infrastructure and the lower-scale residential areas that surround the site.
A successful TOD outcome should integrate with its surroundings. This proposal does not adequately achieve that objective.
Unacceptable Heritage Impact
The site lies within the Roberts Grant Conservation Area, an area valued for its historic character and contribution to Gordon's heritage.
The demolition of contributory buildings within the conservation area would result in an irreversible loss of heritage significance. Heritage conservation areas derive much of their value from the collective contribution of individual buildings and landscape elements. The removal of these structures would weaken the integrity of the precinct and diminish its historical character.
Significant Loss of Trees and Landscape Character
One of the most concerning aspects of the proposal is the removal of approximately 51 trees.
Ku-ring-gai's identity is closely linked to its extensive tree canopy and bushland setting. Mature trees provide shade, moderate temperatures, support biodiversity, improve stormwater outcomes and contribute significantly to the visual quality of the area.
The loss of such a large number of established trees would have long-term environmental consequences and would further reduce the green character that residents value. Removal of trees adds to the increasing urban heat absorption problem and underpins the importance of developments to embrace appropriate landscaping design which this proposed development lacks.
Biodiversity Concerns
The site is located close to important ecological areas, including the Ku-ring-gai Flying-fox Reserve.
Given the proximity of these environmental assets, it is essential that impacts on wildlife habitat, habitat connectivity, threatened species and broader ecological values are assessed thoroughly. The cumulative effect of ongoing development throughout Gordon also requires careful consideration, as individual losses may collectively result in substantial environmental degradation.
Traffic and Safety Impacts
The development proposes 135 car parking spaces accessed from Edward Street. A project of this size will inevitably generate a significant increase in vehicle movements throughout the day.
The Edward Street and Rosedale Road intersection already experiences operational and safety constraints. Additional traffic associated with more than one hundred apartments is likely to worsen congestion, increase delays and create additional conflict points for both vehicles and pedestrians.
Particular concerns include:
• Increased traffic volumes on local streets. Many streets are already too narrow to allow traffic flow to occur when a school bus is attempting to navigate them with cars parked either side of the street.
• Greater congestion at the Edward Street and Rosedale Road intersection.
• Reduced pedestrian safety.
• Additional demand for on-street parking.
• Increased conflicts with vehicles accessing nearby residential and aged-care facilities. On a daily basis elderly residents from the Anglicare aged care home use Edward Street for exercise. Many are pushing walkers or are in wheelchairs. Their safety would be compromised if this proposed development goes ahead.
The configuration of the intersection, existing traffic levels and pedestrian activity already create challenges. Additional development-related traffic is likely to compound these issues and should be independently assessed.
Cumulative Effects Must Be Considered
This proposal should not be assessed as a standalone project.
Gordon is currently experiencing substantial development pressure through various transport-oriented development initiatives. While each proposal may appear acceptable in isolation, their combined impact on roads, infrastructure, public spaces, tree canopy, biodiversity and neighbourhood character may be considerable.
The Department should ensure that cumulative impacts are fully assessed before any decision is made.
Public Interest Considerations
Planning decisions should strike an appropriate balance between housing delivery and the protection of environmental, heritage and community values.
In its current form, this proposal fails to achieve that balance. The combination of excessive height and density, significant tree removal, heritage impacts and increased pressure on local infrastructure results in a development that is not in the public interest.
Conclusion
For the reasons outlined above, I respectfully request that SSD85549710 be refused.
Should the Department consider approving redevelopment of the site, the proposal should first be substantially redesigned to reduce its height and bulk, minimise tree loss, better protect heritage values, address traffic and safety concerns and provide a more appropriate response to the character of the surrounding area.
Thank you for considering this submission.
Yours sincerely,
Margaret Vickers

I strongly object to SSD-85549710 for two residential flat buildings containing 119 apartments (including 24 affordable) on this prominent corner site within the Roberts Grant Heritage Conservation Area (C13).
This proposal, combined with the adjacent SSD-85838457 (233 apartments), represents an unacceptable scale of redevelopment that will irreversibly damage the heritage significance, character, and setting of the conservation area.

1. Irreparable Harm to the Roberts Grant Heritage Conservation Area (C13)
The Roberts Grant Conservation Area is of high historical and aesthetic significance. It represents an intact portion of William Roberts’ 1856 25-acre land grant, with boundaries clearly defined by Nelson Street, Melkin End, and Rosedale Road. It demonstrates the fine residential development of Gordon in the late 19th and early 20th centuries following the North Shore rail line, featuring intact Federation and Inter-war houses set within substantial gardens and complemented by significant native and introduced trees.
Key heritage values that will be destroyed or severely compromised include:
• Intact low-density subdivision pattern and garden-suburb character with generous setbacks and mature tree canopy.
• Aesthetic contribution of the collection of heritage-style dwellings that create a cohesive streetscape rhythm.
• Historical layering evidencing early subdivision by James George Edwards (Langfrother Estate 1892 and Gordon Railway Station Estate 1893).
The proposed 8–9 storey buildings (as shown in the Design Report) will dominate the streetscape, appearing as oversized “white elephants” on the eastern side of Rosedale Road. Their bulk, scale, modern materials, and height will overwhelm the low-rise, landscaped context and cause significant visual intrusion into views within the conservation area. The Design Report’s contextual response is inadequate and fails to respect the core heritage values of C13.
Ku-ring-gai Council’s DCP Part 19 (Heritage Items and Conservation Areas) requires new development in HCAs to conserve and enhance the heritage significance, streetscape, and landscape character. This proposal directly contravenes those objectives.

2. Conflict with Council’s Alternative TOD Framework and Heritage Protections
The sites on the eastern side of Rosedale Road should benefit from stronger protections under Ku-ring-gai Council’s alternative TOD plan (formally adopted November 2025). This plan was specifically designed to:
• Provide better transitions to low-density and heritage areas.
• Deliver stronger protection for heritage conservation areas.
• Avoid inappropriate high-density development in sensitive locations.
Approving these two large-scale SSDs undermines Council’s alternative planning framework, which was negotiated to balance housing supply with local character and heritage preservation. These developments appear to exploit transitional rules and should be refused or substantially scaled back to align with the intent of the updated controls.

3. Cumulative Impacts with Neighbouring Development
Together with SSD-85838457, over 350 new apartments will be introduced into this sensitive corner of the conservation area. This level of intensification is incompatible with the area’s identified heritage values and will set a damaging precedent for further erosion of C13.

4. Inadequate Traffic and Parking Assessment
The Transport Impact Assessment (prepared by TRAFFIX) for SSD-85549710 is deficient because it:
• Does not properly account for cumulative traffic impacts when combined with SSD-85838457.
• Fails to address the reality that out-of-area residents and visitors frequently use Edward Street for on-street parking, which will be severely impacted by the additional demand from hundreds of new residents and their visitors.
• Underestimates peak-period pressures on local streets (Edward Street, Rosedale Road, and connections to Pacific Highway) and intersections.
The combined effect of both developments will generate significant additional traffic, parking overflow, and safety issues in an already established residential area with narrow streets and high on-street parking demand.

5. Other Significant Concerns
• Loss of mature trees and garden settings critical to the conservation area’s aesthetic significance.
• Adverse impacts on streetscape rhythm, overlooking, overshadowing, and amenity for existing residents.
I respectfully urge the Department to refuse SSD-85549710 in its current form. The proposal fails to conserve the environmental heritage of Ku-ring-gai as required under the LEP and is inconsistent with both the heritage values of the Roberts Grant Conservation Area and the objectives of Council’s alternative TOD framework.
Gordon’s unique garden-suburb heritage must be protected. Additional housing should be directed to locations that better respect these established planning and heritage constraints.

I am writing to formally register my strong objection to the proposed residential development. While I support appropriate housing growth within the Ku-ring-gai Local Government Area (LGA), this specific proposal represents significant overdevelopment that threatens resident safety, violates planning controls, and compromises the local environment.
The grounds for my objection are detailed below:
1. Severe Traffic Safety Risks to Adjacent Aged Care Residents (Primary Concern)
The proposed development is located directly adjacent to the Anglican aged care facility. The substantial increase in traffic volume generated by a development of this scale poses an unacceptable safety risk to the vulnerable elderly residents of this facility. Many of these residents suffer from mobility, visual, or cognitive impairments. Introducing high-volume residential and construction traffic immediately adjacent to their living environment increases the risk of accidents and impedes the safe movement of residents, emergency vehicles, and service staff.
2. Inconsistency with Council’s Preferred TOD Housing Scenario
The proposal directly conflicts with Ku-ring-gai Council’s award-winning preferred housing scenario for Transport Oriented Development (TOD). Council’s strategy was carefully designed to balance density with local infrastructure capacity and community character. By failing to align with this established vision, this development undermines Council’s strategic planning framework and sets an adverse precedent for future developments in the area.
3. Excessive Height and Non-Compliance with Planning Guidelines
The height of the proposed building significantly exceeds all relevant planning guidelines and Local Environmental Plan (LEP) standards. There is no valid planning justification for a deviation of this magnitude. The excessive height will result in severe visual bulk, overshadowing of neighbouring properties, and a loss of privacy, completely disrupting the existing streetscape.
4. Destruction of Heritage Character
The proposed project is located within/adjacent to a recognised heritage area. The scale, density, and design of the development are incompatible with the preservation of this heritage fabric. Approving this development would cause irreversible damage to the historical character and identity of the local area.
5. Severe Environmental Damage and Loss of Tree Canopy
The proposal seeks to remove 51 mature trees in close proximity to the Flying-fox reserve. This reserve supports a vulnerable species protected under state and federal legislation. The removal of these trees will degrade critical buffer habitat, reduce the local urban canopy, and negatively impact local biodiversity. This is in direct conflict with Council’s environmental and tree preservation policies.
Conclusion
The proposed development is unsuitable for this site. It presents a clear safety hazard to vulnerable members of our community, disregards established planning and height guidelines, and threatens both our heritage and ecological assets.
I urge Council to refuse this development application in its current form.
Thank you for considering this submission.

I object to the proposed State Significant Development at 25–27 Rosedale Road and 1 & 1A Edward Street, Gordon.

While I acknowledge the need for additional housing, including affordable housing, I do not believe this proposal achieves an appropriate balance between housing delivery, environmental protection, heritage conservation, neighbourhood character and residential amenity.

1. Excessive Height, Bulk and Scale

The proposal for two 8–9 storey residential flat buildings is excessive in the context of the surrounding Gordon neighbourhood. The development represents a substantial departure from the established low-density and garden-suburb character that defines the eastern side of Gordon.

The proposed building height, floor space and overall bulk would dominate the streetscape and create an overdeveloped outcome that is inconsistent with the existing built form surrounding Edward Street and Rosedale Road.

The development would establish an undesirable precedent for similarly scaled developments in nearby residential streets, leading to further erosion of local character.

2. Impacts on the Roberts Grant Heritage Conservation Area

The site is located within the Roberts Grant Heritage Conservation Area. Although some existing dwellings may be assessed as making only a limited contribution to the conservation area, the broader significance of the area derives from its collective historic character, established streetscape, mature landscape setting and traditional subdivision pattern.

The proposed buildings would overwhelm the heritage context through their height, massing and contemporary apartment form. The development would diminish the visual prominence of the heritage conservation area and undermine its significance as a cohesive residential precinct.

I am not satisfied that the proposal adequately demonstrates how the heritage values of the conservation area will be preserved or enhanced.

3. Loss of Tree Canopy and Environmental Impacts

The Environmental Impact Statement indicates that a significant number of trees would be removed from the site. Although replacement planting is proposed, replacement trees cannot compensate for the immediate and long-term loss of mature canopy.

Ku-ring-gai is recognised for its extensive tree canopy and landscape character. Mature trees provide important environmental benefits, including habitat, cooling, stormwater management and visual amenity.

The removal of established vegetation is inconsistent with maintaining the green character that residents value and which contributes significantly to the identity of Gordon.

4. Traffic, Parking and Local Infrastructure Pressures

The proposal would introduce a substantial increase in population and vehicle movements into a local road network that already experiences congestion, particularly during peak periods.

Additional traffic generated by 119 apartments would place pressure on:

Edward Street and Rosedale Road intersections;
Local pedestrian networks;
On-street parking availability;
Nearby community infrastructure and services.

The assessment should more rigorously examine cumulative impacts from other approved and proposed high-density developments in the Gordon station precinct.

5. Residential Amenity Impacts

The scale and proximity of the proposed buildings raise concerns regarding:

Loss of privacy to neighbouring properties;
Increased overlooking;
Visual intrusion;
Overshadowing;
Reduced outlook and sense of openness.

These impacts would significantly affect the amenity of surrounding residents and alter the character of what is currently a low-rise residential environment.

6. Inadequate Transition to Surrounding Development

Good planning requires an appropriate transition between higher-density development near transport nodes and established residential neighbourhoods.

The proposed development does not provide a satisfactory transition in height and scale to adjoining properties. Instead, it introduces a built form that is abrupt, visually dominant and out of character with its immediate surroundings.

7. Cumulative Impact on Gordon's Character

The proposal should not be assessed in isolation. Gordon has already experienced substantial redevelopment pressure under recent housing policies.

Approval of this development, together with other high-density proposals in the vicinity, risks fundamentally changing the character of Gordon from a leafy garden suburb to an overbuilt urban precinct without adequate regard for heritage, landscape and infrastructure constraints.

Conclusion

For the reasons outlined above, I respectfully request that the Department refuse the application in its current form. Should the Department be minded to approve the development, I request that substantial amendments be required to:

Reduce building height and bulk;
Improve heritage outcomes;
Retain a greater number of mature trees;
Reduce environmental impacts;
Improve setbacks and transitions to neighbouring properties;
Minimise traffic and amenity impacts.

I urge the Department to prioritise protection of Gordon's heritage, tree canopy, residential amenity and local character when determining this application.

Yours faithfully,

Jenevieve Zhang
2 June 2026

Dear Assessment Officer,

I am writing to formally object to SSD-85549710 for the proposed residential development at 25-27 Rosedale Road and 1 & 1A Edward Street, Gordon.
As a local resident familiar with the Gordon area and surrounding streets, I have serious concerns regarding the scale of the proposal and its impacts on neighbourhood character, traffic, infrastructure, tree canopy and residential amenity.
While I acknowledge the need for additional housing and affordable housing, I believe this proposal represents overdevelopment of the site and fails to appropriately balance growth with protection of the existing community environment.
1. Excessive Height, Bulk and Density
The proposed 8–9 storey development containing 119 apartments is excessive in scale compared with the surrounding residential environment.
The proposal would introduce significant visual bulk and an overly dense built form that is inconsistent with the established character of Gordon as a landscaped garden suburb.
The height and massing of the buildings would dominate neighbouring properties and create an abrupt and intrusive transition from surrounding residential development.
2.Tree Canopy and Environmental Concerns
The likely removal of mature trees and vegetation is deeply concerning.
Tree canopy within Ku-ring-gai provides important environmental benefits including:
Urban cooling;
Habitat for wildlife;
Stormwater management;
Improved air quality;
Visual amenity.
Large-scale removal of vegetation for high-density development contributes to urban heat island effects and reduces biodiversity across the area.
The long-term environmental impacts of cumulative tree loss across Gordon should be carefully considered.
3. Traffic and Road Safety Impacts
Traffic congestion in Gordon has already increased substantially in recent years, particularly during peak commuting hours and school drop-off periods.
Rosedale Road, Edward Street and surrounding local roads already experience:
Heavy traffic congestion;
Queuing at intersections;
Limited on-street parking;
Increased pedestrian safety risks.
This development would introduce a significant number of additional vehicle movements into an already strained local road network.
I am particularly concerned about:
Increased congestion near Pacific Highway connections;
Traffic impacts around Gordon Station;
Safety risks for pedestrians and school children;
Overflow parking into surrounding residential streets.
The proposal has not adequately demonstrated that local infrastructure can support this increase in density.
4. Cumulative Impact of TOD and SSD Developments
This proposal should not be assessed in isolation.
Numerous large-scale TOD and SSD developments are currently proposed throughout Gordon and nearby suburbs.
The cumulative impact of these developments on traffic, public transport, schools, utilities, drainage systems and community infrastructure appears to have been underestimated.
There is growing community concern that infrastructure delivery is not keeping pace with the scale of proposed population growth.
5. Public Interest
Although increased housing supply is important, the scale of this proposal places excessive pressure on the existing community while delivering limited demonstrated benefit relative to its impacts.
A more balanced and lower-scale development outcome would better protect the character, environment and liveability of Gordon.
Conclusion
For the reasons outlined above, I respectfully request that SSD-85549710 be refused in its current form.

Thank you for considering my submission.

Yours faithfully,
Zhenhui Yang

The proposed development at Rosedale Road and Edward Street is situated outside the revised Transit-Oriented Development (TOD) boundary for Gordon, as put forward by Ku-ring-gai Council and endorsed by the NSW Government.

Within the revised Gordon TOD structure, the intended approach concentrates the greatest development uplift within the town centre, enabling heights of up to 25 storeys while deliberately protecting surrounding low-rise and heritage-adjacent streetscapes. This forms part of Ku-ring-gai Council’s award-winning preferred TOD housing strategy, designed to balance increased housing supply with the retention of neighbourhood character and environmental values.

The subject State Significant Development (SSD) is not consistent with this established framework. It lies beyond the adopted Rosedale Road boundary and introduces building height, bulk, and scale that are incompatible with the surrounding context, with proposed heights exceeding 30.8 metres. This represents a clear departure from the planned transition of density and the principle of containing high-rise form within the designated centre.

The proposal also raises significant planning concerns, including worsening traffic congestion within an already constrained network, as well as adverse interface impacts on the nearby Anglicare aged care facility.

In addition, the site is located within the “Roberts Grant Conservation Area” and is adjacent to environmentally sensitive features, including mapped bushland, Ku-ring-gai Flying Fox habitat corridors, and established green canopy areas. The scale of the development would likely result in unacceptable environmental impacts, including canopy loss, disruption of ecological corridors, and increased pressure on local biodiversity systems.

Gordon is already accommodating the most substantial uplift across the four station precincts within Ku-ring-gai. There is limited capacity for additional intensification beyond the defined boundary, particularly given existing traffic congestion and restricted road egress options that already place pressure on the local road network.

Furthermore, the surrounding precinct lacks adequate supporting infrastructure to sustain further high-density expansion, including sufficient schools, open space, and community and recreational facilities required to support population growth at this scale.

Rosedale Road and Edward Street also hold recognised heritage and streetscape significance. These areas were intended to remain low-rise, with higher density confined to the western side of Rosedale Road in accordance with Ku-ring-gai Council’s adopted preferred TOD scenario for Gordon.

Allowing SSD approvals to extend beyond the established boundary undermines the integrity of the planning framework developed by Ku-ring-gai Council and endorsed by the State Government. The housing targets for Gordon have already been achieved through substantial uplift within the town centre, and further encroachment into East Gordon is neither necessary nor aligned with the approved planning intent.

The community supported significant intensification within Gordon Centre on the understanding that the revised TOD boundaries would be respected, ensuring the protection of surrounding low-rise neighbourhoods, heritage character, environmental assets, and overall liveability.

To the Department of Planning, Housing and Infrastructure,
I write to object to the proposed residential development at 25–27 Rosedale Road and 1 & 1A Edward Street, Gordon.

I do not believe this proposal represents appropriate development for this site. The scale, intensity and design of the development will have significant adverse impacts on neighbouring residents, the character of Gordon, local biodiversity, and the heritage values of the area.

Unacceptable Impacts on Residential Amenity

My primary concern is the significant impact that this development will have on the amenity of existing residents.
The proposal seeks to introduce two large apartment buildings of up to nine storeys into a predominantly low-rise residential neighbourhood. The scale of the development is excessive and will fundamentally alter the living environment of surrounding properties.

Residents will experience increased overlooking from numerous balconies, windows and communal areas. The elevated nature of the proposed buildings means that neighbouring homes and private open spaces will be subject to a level of surveillance and loss of privacy that does not currently exist.

The development will also create a substantial visual presence. Existing residents who currently enjoy a leafy suburban outlook will instead be confronted by large building facades, extensive glazing, balconies and rooftop structures. This loss of outlook and sense of openness will significantly diminish the enjoyment of neighbouring properties.

In addition, the height and bulk of the buildings will contribute to overshadowing of adjoining properties and gardens, reducing access to natural light and impacting the usability of private open space areas. The cumulative effect of reduced privacy, overshadowing, visual intrusion and increased activity will materially reduce the quality of life for nearby residents.

Residential amenity is a fundamental planning consideration and should not be sacrificed in pursuit of housing targets.

Excessive Height, Bulk and Density
The proposal represents an overdevelopment of the site.

Buildings of this scale are inconsistent with the established character of the surrounding streets and exceed what would ordinarily be expected within this part of Gordon. The development introduces a built form that is visually dominant and out of proportion with neighbouring development.

Rather than providing a sensitive transition between higher-density areas and established residential streets, the proposal creates an abrupt and imposing urban form that will be highly visible from surrounding properties and public spaces.

The intensity of development proposed is simply too great for a site within a heritage conservation area and established suburban neighbourhood.

Adverse Heritage Impacts
The site is located within the Roberts Grant Heritage Conservation Area, an area valued for its historic character, landscaped setting and traditional residential streetscape.

Although redevelopment may be permissible, it should respect and complement the qualities that contribute to the area's significance. In this case, the scale and massing of the proposed buildings will dominate the heritage setting rather than respond to it.

The proposal risks eroding the character of the conservation area by introducing built forms that are inconsistent with the established pattern of development. Once this character is lost, it cannot be recovered.

Loss of Tree Canopy and Biodiversity
The proposed development would result in the removal of mature trees that contribute significantly to the environmental quality and visual character of the locality.

While replacement planting is proposed, newly planted trees cannot replace the ecological, visual and environmental value of mature canopy trees for many decades.

The loss of established vegetation is particularly concerning given the role these trees play in supporting local wildlife.

Threats to Powerful Owl Habitat and Native Fauna
The area surrounding Rosedale Road and Edward Street forms part of a broader network of urban bushland and mature tree canopy that supports native wildlife, including the Powerful Owl.

The Powerful Owl is listed as a vulnerable species in New South Wales and relies on mature trees for roosting, nesting and hunting. Large canopy trees and connected habitat corridors are critical to the species' survival within urban environments.

The removal of mature vegetation and increased urbanisation of the site will further fragment habitat and reduce opportunities for native fauna to move through the landscape. Even where individual nesting trees may not be directly affected, the cumulative loss of canopy and foraging habitat contributes to the ongoing decline of biodiversity across the Ku-ring-gai area.

The environmental assessment appears to underestimate the broader ecological significance of retaining mature trees within this established wildlife corridor.

Traffic and Infrastructure Concerns
The development will generate a significant increase in traffic movements and population density within the local area.

Edward Street and Rosedale Road already experience traffic pressures associated with school traffic, commuter movements and access to Gordon town centre. Additional vehicle movements from more than one hundred apartments will exacerbate congestion and increase pressure on local roads and intersections.

There is also likely to be increased demand for on-street parking, pedestrian infrastructure, public open space and community services.

The cumulative impact of multiple developments occurring throughout Gordon should be carefully considered rather than assessing this proposal in isolation.

Gordon has long been valued for its leafy character, generous setbacks, mature gardens and heritage streetscapes. Developments of this scale risk transforming the character of the suburb and diminishing the qualities that attract residents to the area.

Housing growth should occur in a manner that respects existing communities and protects the environmental and heritage values that make Gordon unique.

Conclusion

For the reasons outlined above, I respectfully request that the Department refuse the application in its current form.

The proposal is excessive in height, bulk and density, will have unacceptable impacts on residential amenity, threatens the character of the Roberts Grant Heritage Conservation Area, contributes to the loss of valuable tree canopy and wildlife habitat, and places additional pressure on local infrastructure.

If the Department determines that the site should be developed, the proposal should be substantially redesigned to reduce its scale, retain significantly more mature vegetation, improve setbacks and privacy outcomes, better protect biodiversity, and minimise impacts on neighbouring residents.

I urge the Department to place appropriate weight on the long-term environmental, heritage and community consequences of this proposal and to protect the unique character and liveability of Gordon for current and future residents.