Residential development with infill affordable housing, 59-63 Trafalgar Avenue 1A&1B Valley Road Lindfield

I support additional housing supply. However, I oppose the proposed development, which is not suitable for the site on which it is proposed. My key reasons for opposing the development include:
• its height, bulk and density;
• its adverse impact in terms of overshadowing and loss of solar access and privacy on adjacent and other neighbouring properties;
• the lack of transition, in terms of height and density, to the neighbouring residential properties;
• the loss of tree canopy and biodiversity that will result;
• its likely adverse impact from a heritage perspective on adjacent heritage items and properties in the Middle Harbour Heritage Conservation Area (HCA), of which the site forms part, and on properties in the Trafalgar Avenue HCA;
• conflict with the character and streetscape of the neighbourhood, including the adverse visual impacts of such large, angular buildings and dense construction being located in that neighbourhood;
• its likely adverse impact on traffic and parking in surrounding streets;
• its likely adverse impact on infrastructure including local roads; and
• it is inconsistent with a good planning outcome and in conflict with the alternative planning scheme (TOD Alternate Preferred Scenario) proposed by Kuring-Gai Council (Council), which Council has reported has widespread community support.

Additional comments on some of my objections follow.
HEIGHT, BULK AND DENSITY; CONSEQUENTIAL OVERSHADOWING, LOSS OF SOLAR ACCESS AND LOSS OF PRIVACY:
• The heights and bulk proposed are in my view entirely inappropriate for this location. The maximum number of storeys is 11 – this on a site where the Transport-Oriented Development SEPP (TOD) currently provides for 6 and which is outside the area covered by the TOD Alternate Preferred Scenario (which, once implemented, would have the result that the site would be covered by the Low and Mid Rise Housing Policy (LMR)).
• The proposal says that the proposed development has a maximum height of 33.07m at its highest point, exceeding the maximum building height by 4.47m (15.6%). No variation should be approved to permit the proposed height. The application says that ‘No habitable floor space is located above the permitted height’. That is not relevant. The proposed additional height would, whatever is inside it, exacerbate the adverse effects the development would have even without the additional height. It would exacerbate overshadowing and contribute to a mass and bulk that is entirely inappropriate for the location and its elevation. The elevation of, and the slope on, the site should not be a reason for building height that exceeds the relevant TOD planning controls.
• The three dimensional diagrams that appear in one of the documents on exhibition demonstrate the grossly disproportionate size of the development relative to the existing surrounding properties. The size (height, bulk and density) is also grossly disproportionate relative to the zoning under the LMR that applies to adjacent properties, and is disproportionate even relative to the R4 zoning for properties on the other side of Trafalgar Avenue that is proposed in the TOD Alternate Preferred Scenario.
• The shadow diagrams that are included in the proposal indicate a degree of shadowing that is unacceptable, particularly for adjacent properties in Middle Harbour Road which the shadow diagrams indicate would start to lose the sun on their northern aspect from 9 am and would be essentially completely overshadowed by noon, which overshadowing would continue and become deeper over the rest of the day.
• Neighbouring properties that were overlooked by the buildings would suffer a substantial loss of privacy.
• The solar access for apartments in the development is in my view sub-standard - 39 apartments with no solar access is unacceptable. Many of these are the ‘affordable housing’ apartments. It is not a good social outcome to provide ‘affordable’ housing with no solar access.
• Similarly many of the apartments, including many of the ‘affordable housing’ apartments, have no cross ventilation. Again this is something that is not a good social outcome.
• The site is among the highest elevations in Lindfield east of the railway line, particularly at the Russell Lane end. The proposed buildings would dominate the neighbourhood and the skyline. They would be visible from many directions and from some distance.

LOSS OF TREE CANOPY AND BIODIVERSITY; INADEQUATE NEW PLANTING:
• Many mature trees will be removed if the application is approved. Boundary and other planting will take many years to grow, and will not be an effective substitute for the trees removed. Given the shadow from the buildings, planting on the southern side of the development, in particular, is highly unlikely to thrive.
• 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 overshadowing to the south of the development is likely adversely to affect the plants and trees in the backyards of the properties on Middle Harbour Road adjacent to the development.
ADVERSE IMPACT ON HERITAGE ITEMS AND HCAs:
• The Site is adjacent to 4 heritage items.
• It is essential that heritage items are not stranded. Leaving them stranded and largely surrounded by development, as would be the case for 1 Valley Road, would materially diminish the heritage value of these properties.
• If the development was to proceed:
o the heritage value of all the adjacent heritage items would be substantially diminished;
o the amenity of those living in the heritage items would be substantially reduced; and
o the financial value of the heritage items would be adversely affected, which would be inequitable to the owners of those properties.
• The site, and the properties in Valley Road and Middle Harbour Road that are adjacent to the site, are all in the Middle Harbour HCA. The properties on the other side of Trafalgar Avenue from the site are all in the Trafalgar Avenue HCA. The heritage value of those two HCAs will effectively be undermined and substantially diminished if the development proceeds.

THE PROPOSED DEVELOPMENT WOULD NOT BE A GOOD PLANNING OUTCOME:
• The site is on the very edge of the TOD zone, and outside the area covered by the TOD Alternate Preferred Scenario.
• If approved this development would be entirely inconsistent with the TOD Alternate Preferred Scenario and with the key objectives of Council that underpin the TOD Alternate Preferred Scenario. The TOD Alternate Preferred Scenario has been the subject of extensive community consultation and very careful consideration by Council (and I understand that Council staff have in developing the TOD Alternate Preferred Scenario consulted with NSW Planning staff). In particular, the proposed development is contrary to the following principles, which I endorse:
o there should be a graduated shift down in height as buildings radiate out from the train station (not a ‘donut’ effect);
o impact on heritage items should be minimised;
o transition impacts should be managed effectively, with zoning/density changes that are ‘mid-block’ or along property boundaries avoided and an acceptable interface between areas of different density;
o building heights should be appropriate; and
o impact on tree canopy should be minimised.
The proposed development would undermine achievement by Council of these objectives and, on the site for which it is proposed, be a very poor planning outcome.

I object to the Lindfield development for 220 units on the following grounds:
1. The footprint of the building is excessive and imposes on neighbouring properties.
2. The development is not in keeping with the surrounding neighbourhood.
3. The development will contribute to excessive traffic congestion.
4. The area does not need a large development in such a leafy suburb.

I wish to formally object to the proposed State Significant Development (SSD) for residential development with infill affordable housing at 59–63 Trafalgar Avenue and 1A–1B Valley Road, Lindfield. The scale and nature of this proposal represent a significant overreach, disregarding local heritage, planning priorities, and community expectations.

Premature and Inappropriate Timing
This application is premature and undermines ongoing negotiations between Ku-ring-gai Council and the NSW Department of Planning, Housing and Infrastructure (DPHI). Council's "Preferred Scenario," developed in response to the NSW Government's Transport Oriented Development (TOD) reforms, proposes balanced, sustainable growth that aligns with infrastructure capacity, heritage conservation, and the values of the local community.
By submitting this application before the TOD framework is finalised, the proponent sidesteps democratic planning processes and meaningfully excludes residents from having a say. This raises concerns about transparency and procedural fairness and disregards the critical role of local governance in shaping Lindfield’s future.

Key Objections
1. Misuse of Affordable Housing Provisions
This proposal includes 220 apartments, but only 46 are designated as "affordable." That’s just over 20%, yet the entire proposal is framed around its contribution to housing affordability. In reality, the majority of units will likely be sold for in excess of $800,000, catering to higher-income buyers and accelerating gentrification, not solving the housing crisis. The only clear beneficiaries of this development are the developers and a handful of property owners.

2. Excessive Building Height
The proposed height of 33.07m exceeds the local planning control limit of 28.60m by 15.6%. A 9+ storey building is completely out of context with the surrounding low-density homes and will have significant impacts including:
• Overshadowing of neighbouring properties
• Loss of privacy
• Reduced solar access
• Visual dominance incompatible with the established streetscape
No meaningful transition in scale has been proposed, which further highlights the lack of respect for the area’s character.

3. Bulk and Scale
The development consists of buidings of up to nine storeys. This bulk is excessive and out of character for Lindfield. It would overwhelm the local built environment and exacerbate the same concerns raised under height, especially in terms of scale, visual impact, and neighbourhood compatibility.

4. Traffic Congestion
Lindfield already experiences heavy traffic, especially during peak periods. Havilah road is often backed up with cars trying to access Pacific Highway. Local roads such as Trafalgar Avenue, Russell Lane, and Valley Road are quiet residential streets, not designed to accommodate the increased vehicle load this development would generate. The developement will further congest these streets and increase the risk of accidents and delays.

5. Parking Shortfall
The development includes 367 parking spaces, which equates to one guest parking spot for every seven apartments. This is clearly inadequate and will significantly worsen parking pressure in an already congested area.

6. Heritage Impacts
The development adjoins four heritage-listed homes and proposes the demolition of five houses within the Lindfield Conservation Area. The scale, massing, and design are incompatible with the area’s heritage character, undermining longstanding efforts to protect and preserve Lindfield's unique architectural and historical identity.

Concerns About Community Consultation
I am also deeply concerned about the lack of transparent and inclusive community consultation. I have not received direct notification of this development or information about information drop-in sessions. The absence of outreach undermines public trust in the process and calls into question the integrity of stakeholder engagement efforts.

Conclusion
This proposal is fundamentally inappropriate for Lindfield. It is oversized, out of character, and out of step with the current infrastructure, heritage values, and road network. The development appears to be timed to exploit transitional planning conditions, sidelining both Council’s vision and the voices of local residents.
The current TOD framework does not adequately reflect Lindfield’s unique context. I strongly urge the NSW Department of Planning to reject or defer this application until Council’s Preferred Scenario has been finalised and properly considered.
Thank you for the opportunity to make this submission.

Portal

The 220 units proposed for 5 suburban blocks on Trafalgar Avenue would be a massive overdevelopment of a site surrounded by low density settlement. The development would tower over the surrounding detached housing.

One of the Ku-ring-gai planning principles is that developments be sympathetic with the style of surrounding housing. The boxy style and bulk would be overwhelming and completely out of character with the style of housing in Lindfield.

Another of the Ku-ring-gai planning principles is protection of heritage and heritage conservation areas (HCA). This proposed development would be highly detrimental for heritage as it would be across the road from the Trafalgar Heritage Conservation Area. Heritage conservation entails retention of the context. High rise in the immediate surrounds of a heritage conservation area would have adverse effects on the HCA in terms of outlook, being overlooked, loss of privacy, overshadowing and loss of street amenity. A further planning principle is to ensure a gradual transition between highrise and HCAs. A street is not a gradual transition.

There has been a total absence of consideration of consequences for traffic, environment and infrastructure. These studies are fundamental to the success of planning. A building such as proposed does not work in isolation. Its success depends on many services as well as its surrounds. Ignoring these does not bode well for the proposed building’s success. Construction of this building would seem to be negligent without renewal and addition of infrastructure. Lindfield has frequent blackouts, regular Sydney Water leaks and traffic jams. One noteable nearby traffic hotspot is Lindfield Avenue and Balfour Street just two blocks from the proposed structure with multiple flow incidents every day. Local feeder roads including Lady Game Drive (Lindfield), Stanhope Road (Killara), Grosvenor Road (Lindfield), Werona Avenue (Gordon), Tryon Road (Lindfield) especially at the Eastern Arterial Road intersection, Hill Street (Roseville) and Clanville Road (Roseville) already present flow problems for Lindfield residents attempting to reach or exit arterial roads.

I fear the consequences of such a massive proposal for Lindfield. It would contribute to serious loss of neighbourhood stability, social cohesion and peaceful amenity so valued by Lindfield residents. It is not that we don't wish to share it but rather with the imposition of such massive developments it will be destroyed.

As a 45 year resident of the Kuringai region I feel that this development goes against so much of what this municipality is about. The SEARS documents require a 'high level of environmental amenity from any surrounding residential or other sensitive land uses' however this proposal fails to do anything other than reduce the environmental amenity, particularly given its location with respect to the local HCA and Conservation areas.
The development is actually outside of the TOD and therefore should not even be being considered with respect to these regulations, and as a council preferred scenario is hopefully imminent, it should be considered as part of these.
The height of the buildings as planned will have such significant sunlight impacts on the surrounding properties that it in fact contravenes planning and design guides.
The setback and therefore direct impact on the properties on Middle Harbour Road is lower than considered reasonable for residential living and therefore also does not adhere to the apartment design guide. This must be considered as to how the privacy of the surrounding properties is going to be severely and detrimentally affected.
Furthermore, the proposal is surrounded on many aspects by heritage homes, that have been loved and preserved for many generations. Once gone it's gone and it is astonishing to think that the planning committee would want to be held accountable for such an impact. Whilst it is well known that we need to create more housing, this location is not appropriate.
I would also like to personally question how it is realistic to think that properties such as this are truly going to provide affordable housing, given the cost that the developers will need to pay for these locations. I feel that this is a smoke screen, and an attempt to get through loop holes. I trust the that reasonable and intelligent individuals on any planning committee would see through this.
I suspect that when the preferred scenario becomes adopted, this development would literally stick out like a sore thumb, yet forever have harmed the long term amenity, infrastructure and environmental beauty of the area.

I object to the proposed development on the grounds outlined in the attached.

OBJECTION
Re: Objection to Proposed Residential Development – SSD 79276958
59–63 Trafalgar Avenue and 1A & 1B Valley Road, Lindfield
To Whom It May Concern,
I, Thomas B. Jambrich of 27 Oliver Road, Roseville, wish to formally object to the proposed residential development at 59–63 Trafalgar Avenue and 1A & 1B Valley Road, Lindfield.
As a resident of this area for over 30 years, I have developed a deep appreciation for its unique character, strong community spirit, and rich environmental quality. I submit the following key concerns regarding the proposed development:
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1. Height and Scale of the Proposal
The proposed buildings—exceeding nine storeys—are completely out of scale with the existing low-rise residential fabric of the neighborhood. Lindfield is defined by quiet, leafy streets and modest homes. The introduction of a high-rise complex of this magnitude would dominate the streetscape and drastically alter the area's character.
From personal experience living in both low-rise and high-rise environments, I can attest that high-density, high-rise developments often lack the social cohesion and sense of community that have long defined suburbs like Lindfield.
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2. Impact on Community Character
The proposed 220-unit development would impose a substantial and abrupt change to the community's fabric. Its scale and visual bulk are inconsistent with the existing architectural identity of the suburb. Transitioning from heritage homes and green corridors to a large-scale development of this nature risks eroding the social and visual character that residents have carefully preserved over decades.
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3. Traffic and Transport Implications
The local road network—particularly Trafalgar Avenue and Russell Avenue—already experiences significant congestion, due largely to commuter parking around Lindfield railway station. Adding hundreds of new residents and their vehicles will exacerbate these issues, increasing travel delays, commuter frustration, and the likelihood of traffic incidents. The knock-on effects will also impact surrounding suburbs, including Roseville.
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4. Environmental Impact
The proposed construction will necessitate the removal of mature trees and established vegetation that form an essential part of the local ecosystem and the suburb's visual character. Such natural assets take decades to establish and cannot be quickly replaced.
Furthermore, a development of this size will place added pressure on waste management services currently provided by the local council. A realistic population increase of over 450 residents would significantly strain local infrastructure, including waste collection, parking availability, and street access—contributing to a noticeable deterioration in quality of life.
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Conclusion
While I fully acknowledge and support the need for increased affordable housing in Sydney, it must be pursued through context-sensitive, community-aligned planning. This proposal, in its current form, is not that.
It represents a retrograde step that threatens to undermine the character, livability, and environmental sustainability of Lindfield. The adverse impacts of the proposed development—on traffic, environment, community cohesion, and local infrastructure—cannot be overstated.
I urge the NSW Government and relevant planning authorities to instead support the Ku-ring-gai Council’s Transit-Oriented Development (TOD) strategy, which offers a more thoughtful and balanced approach to meeting housing needs without sacrificing local identity.
For these reasons, I strongly object to the proposed development and respectfully request that it be rejected.
Thank you for considering my submission.
Sincerely,
Thomas B. Jambrich
27 Oliver Road, Roseville

I am writing to formally object to the proposed development project located at 59-63 Trafalgar Avenue 1A&1B Valley Road Lindfield.
As a long-standing resident of this community, I have serious concerns regarding the potential negative impacts this development will have on the surrounding area. The reasons for my objection include the following:
Loss of Privacy: The development would significantly encroach on the privacy of neighboring homes. Multi-story buildings or increased housing density will allow views directly into the backyards and living spaces of current residents, undermining our sense of personal space and comfort.
Increased Traffic Congestion: The addition of new housing or commercial units will inevitably lead to a noticeable increase in traffic on roads that are already operating at or near capacity. This poses a risk not only to the convenience of current residents but also to their safety.
Excessive Noise: More residents and vehicles, along with potential construction work and commercial activity, will create a sustained rise in noise levels. This disrupts the peace and tranquility of the neighborhood, particularly affecting those who work from home, retirees, and families with young children.
Inadequate Infrastructure: The existing infrastructure—including roads, drainage, and public amenities—is not equipped to handle the scale of the proposed development. Without significant upgrades, the strain on these systems will degrade the quality of life for all residents.
Safety Concerns for Children and Elderly Residents: Increased vehicle movement in residential areas, particularly near parks, schools, and walkways, raises serious safety concerns for vulnerable groups such as children and the elderly. Our community has long valued its walkability and safety—both of which would be jeopardized by the proposed development.
Devaluation of Property: The cumulative effect of these changes—loss of privacy, noise, congestion, and reduced safety—will diminish the overall appeal of our neighborhood and negatively impact property values. For many residents, their home represents their most significant investment, and this development threatens that stability.
I respectfully urge the planning committee to reconsider or significantly revise this proposal in a way that meaningfully addresses these concerns. The character and integrity of our neighbourhood must be preserved for current and future residents alike.

Please see attached document .

My husband and I have owned and resided at 36A Middle Harbour Road, Lindfield (Southeast of the proposed development site) since September 2001, and together with our two sons have always enjoyed its privacy, the quiet nature of the area, the views of open sky and the green leafy tree canopy for which Lindfield is renowned.

Although I acknowledge the need for new and affordable housing in the Lindfield area, I OBJECT to this development proposal for the reasons set out in the Attachment to this submission.

The project is outside the TOD limit of 400 m from Lindfield Station.
The height, density and bulky are above the maximum building height limits.
The project does not consider transition to low density houses
The project will result in excessive traffic and use up what little parking is available in surrounding streets
The visual impact is excessive and will result in overshadowing of adjoining properties
The project will have detrimental effects on local heritage and Heritage Conservation Areas. It creates a significant negative impact on local neighbourhood amenity, character and streetscape.
The project should be rejected.

Please find attached my detailed submission objecting to this Proposal.
The visual impact of the bulk and height of this development will dominate the whole area as its location is also a high point for the suburb. The visual impact on the surrounding area will be immense as the design does not attempt to fit into the local character of low-density homes, heritage items and the Heritage Conservation Areas in which it is located.
The immense negative impacts on surrounding residents in terms of sunlight, privacy and amenity, the loss of heritage and the removal of dwellings from the Trafalgar Road HCA, the destruction of the mature tree canopy all support the need to reject this Landmark application.
In terms of all aspects of the SEARs program this Landmark proposal has produced inaccurate and misleading information with regard to the Visual Impact Assessment, and has not engaged in community consultation in any meaningful manner. The Heritage Assessment has many gaps and fails to assess the impact of removing contributing dwellings on the two HCAs, in which this development is centrally located, nor has it assessed the impact of this development on 5 neighbouring heritage items, 4 of which abut the development.
I strongly urge you to reject this application as it will have irreversible and devastating consequences in its current form. The proposed development is patently inappropriate for the location in question given the topography and its impact on adjacent HCAs and heritage items.

Development proposal for 59-63 Trafalgar Ave and 1A & 1B Valley Road, Lindfield
SSD 79276958
I am opposed to this development
From the outset I wish to make it crystal clear that I am totally supportive of the goals of the TOD policy. We need to increase supply of dwellings if we are ever going to address the “housing crisis”. But proper town planning must be undertaken to get this right and not what I would describe as the wild west approach now occurring with developers rushing about frantically trying to secure sites. The following reasons are why I am opposed to the development proposal for 59-63 Trafalgar Ave and 1A & 1B Valley Road, Lindfield.
Sits outside Ku-ring-gai Preferred TOD
A significant proportion of the proposed development sits outside the 400m walking distance of the Lindfield Train Station. While there must be some latitude in the definition of these borders when there is no naturally defined border, in this case there are clearly roads that neatly define the southeastern side of the “circle 400m from Lindfield Station”. It comes as no surprise that Ku-ring-gai Councils Preferred TOD uses these roads to define this border in this location as it is the logical thing to do. Under the Ku-ring-gai Council’s Preferred TOD, this development would be rejected as it is outside the zone.
Ku-ring-gai’s Preferred TOD has received widespread community approval and delivers on the dwelling goals of the State Government in a way that is significantly more considered with significant advantages over the crude State Government TOD. Given this, no developments should be approved prior to Ku-ring-gai Council and the State Government agreeing to the preferred TOD. From my observations, this process is in the final stages, so having this site rushed through the approval process is unreasonable.
Unsuitability of the Site
The proposed site is surrounded by heritage listed properties and to the south a creek which is protected by a riparian policy. I note that the environmental impact study by the developer incorrectly defines the starting point of the creek at 38 Middle Harbour Road. The Creek and the Riparian Zone actually begin 6 houses further to the West, towards Trafalgar Avenue, at 32 Middle Harbour Road. In effect, they actually affect most of the properties on the southern border of the proposed development. The developer also states that it is largely a dry creek bed. This is completely false. I have lived at 36A Middle Harbour Road for 24 years and the creek always has water flowing down it, even in periods of drought. There is a very active ecosystem in this creek, supporting frogs, water dragons, possums, brush turkeys and numerous bird species.
Critically, given the creek and the numerous heritage items surrounding this development there will be no possible transition from this massive 9 storey development to the 2 storey houses surrounding it. This is obviously poor town planning.
Furthermore, the site sits on top of the hill overlooking all of the properties on the southern and southeastern sides of the site. The low point on the southern side of the site is Middle Harbour Road, and the existing 2-3 storey houses that will be demolished for this development are visible from this street. Therefore a 9-storey development would dominate the skyline.
It is important to highlight that the developers’ Visual Impact Assessment does not even consider the southern aspect of the site. In the EIS there is a map with 8 view points highlighted and yet the actual VIA has 6 viewpoints with all of the southern viewpoints removed. The conclusion of the VIA references a location not even in Lindfield so appears to be a cut and paste from another report. This is unacceptable and the credibility of the VIA must be questioned.
It should also be noted that on the Northwestern side of the proposed development there are a church and existing multi-dwelling units, which are extremely unlikely to be further developed in the foreseeable future.
As such this proposed development will forever stand out from everything around it. Clearly poor town planning.
Parking
All of Russell Ave and Trafalgar Ave down to the roundabout at Middle Harbour Road (i.e. all of the available street parking surrounding the development) is parked out by commuters using the Lindfield Train Station every workday. While parking is available in the development itself, inevitably more street parking will be required and it is already at capacity.
Composition of the Proposed Development
The goal of the TOD is to increase the number of dwellings along train corridors to help address the housing crisis. The Lindfield area is a family area, according to the latest Census 69.4% of households in Lindfield are 3 bedrooms or more (39.0% are 4 bedrooms or more).
In this proposed development only 26.4% have 3 bedrooms, and excluding the penthouses 23.2%. None of the affordable housing options are 3 bedrooms. Of the affordable housing options 54.3% are 2 bedrooms and the remainder 1 bedroom. This composition of dwellings is inconsistent with the existing urban environment.

I object to the project because it will increase traffic and make parking more difficult in my local area as well as impact on the heritage and Heritage Conservation Area.

I object to the project because it is above the maximum building height limits and will overshadow and impact on the privacy of my neighbours.

I OPPOSE the Project
Re: Residential development with infill affordable housing, 59-63 Trafalgar Avenue 1A&1B Valley Road Lindfield (SSD-79276958)
I am a resident on Trafalgar Avenue in Lindfield, and I am making this submission to object to SSD-79276958.

EIS is submitted under NSW TOD zoning and FSRs, which will likely be soon altered if NSW and Council agree on an alternate TOD boundary and zoning. There is no reason for these SSDs to be saved.
Under the Kuring gai Council Preferred Scenario which will be presented to NSW in early June, the dwelling increase numbers set by NSW will be attained without any of the currently lodged SSDs (weather in EIS or SEAR stage). There is no reason to ‘save’ these SSD applications (leading to adverse impacts on heritage, environment, traffic and runoff inconsistent with the local community’s preference) as NWS desired dwelling outcomes will already have been met. In presenting the alternate Preferred Scenario via Council, the local community has voiced its preferences as to where this additional dwelling numbers can be built so that it adversely affects these environmental factors as little as possible. There is no justification to additionally approve SSD on top of this (Council has calculated that an additional 1569 dwellings (on top of NSW dwelling targets) will come out of the SSDs currently lodged or on exhibition) especially such inappropriate ones as SSD-79276958, which would lead to the demolition of homes in a protected HCA leading to adverse impact on the rest of the HCA and heritage items, including inappropriate transition and overshadowing, and furthermore creating an untenable traffic congestion for Lindfield.

Please see the attached submission setting out my reasons for objecting to this project.

I object to the project in its current form, but with some small changes it could be vastly more suitable for the community and environment. These are:
- The site is at the top of a hill, so 9 storeys will tower over the surrounding areas for a great distance in each direction. There is no transition or blending in to the height of neighbouring properties. This blocks solar access and invades privacy for a large number of residents.
- Tree canopy: 42 trees are to be removed, which is a huge impact to tree canopy. There must be sufficient set-back on Trafalgar Avenue to allow deep soil for large trees to grow on the perimeter of this construction to avoid the building becoming a 'heat island' and to regenerate the tree canopy. This has impacts for sustainability. The crepe myrtles to be planted on the street do not grow tall, do not provide material shade or offer habitat for native wildlife. Larger native trees should instead be selected.
- The footprint of this building breaches the TOD boundary (i.e. it goes beyond 400m from Lindfield station).
- the architecture of this block of flats has no regard for the architectural features of housing in this immediate community or indeed the north shore generally. It is not sympathetic to the heritage styles that give the north shore is character, charm and liveability. Height and density can be achieved with more appropriate architecture that is sympathetic to its surroundings. These considerations have not been taken into account.
- No consideration for traffic management and substantial increase in road congestion in this area

Subject: Formal Objection to State Significant Development (SSD) Application SSD-79276958 Residential development with infill affordable housing, 59-63 Trafalgar Avenue 1A&1B Valley Road Lindfield

To Whom It May Concern,

I wish to strenuously object to State Significant Development (SSD) Application SSD-79276958 Residential development with infill affordable housing, 59-63 Trafalgar Avenue 1A&1B Valley Road Lindfield.

In my opinion, this proposal represents a severe overreach that contravenes established planning controls, disrespects heritage protections, and fails to align with the values and expectations of the local community.

1. Denial of Procedural Fairness
This application pre-empts ongoing negotiations between Ku-ring-gai Council (Council) and the NSW Department of Planning, Housing and Infrastructure (DPHI) regarding a more suitable Transport Oriented Development (TOD) framework for Lindfield. My understanding of Council’s “Preferred Scenario”, endorsed in response to the NSW Government’s Low and Mid-Rise Housing Reforms, proposes measured growth that aligns with local infrastructure capacity, heritage conservation, and community expectations.

In my opinion, the lodging of this SSD application – prior to the finalisation of the TOD framework – undermines democratic planning processes and denies residents the opportunity for genuine input. It represents a failure of procedural fairness and community input, and an unacceptable sidelining of local governance.

In my opinion, this SSD application, as lodged under the TOD planning controls, should NOT be progressed further or determined until Council’s Preferred Scenario is resolved. The TOD planning controls were introduced without public consultation and are to be set aside when the Council's Preferred Scenario is adopted.

I fully support Council’s Preferred Scenario given that it recognises the unique character of Lindfield having regard to the existing built form in and around the proposed development.

2. Lack of Community Consultation by the Developer
From my perspective, there has been a complete lack of appropriate and meaningful engagement and consultation by the developer with the local community. I have received no information from the developer, nor have I been invited to a community session where the merits or otherwise of this development have been presented and debated.

3. Non-Compliance with Planning Controls and Excessive Height
It is my understanding that the development proposes a nine-storey structure exceeding 30 metres (33m), flagrantly breaching the existing Ku-ring-gai Local Environmental Plan 2015 (KLEP 2015) and Ku-ring-gai Development Control Plan (KDCP), which impose a maximum building height of 22 metres in the area. Even factoring in the State Environmental Planning Policy (Housing) 2021, the scale of this development vastly exceeds what might be reasonably allowed under any bonus provision.

This excessive height and bulk is entirely inconsistent with the fine-grained character of Lindfield, particularly on the eastern side of the railway, and would dominate the streetscape to an unacceptable degree.

4. Irreparable Heritage Impacts
It is my understanding that the subject site is in a Heritage Conservation Areas (HCA), with a number of heritage listed houses located nearby; properties protected under Schedule 5 of KLEP 2015 and the NSW Heritage Act 1977.

Furthermore, in my opinion, the proposal:
• will result in visual isolation and overshadowing of significant heritage assets, and
• makes no serious attempt to integrate or defer to the prevailing heritage streetscape, and in doing so, risks eroding the historic identity of the area.

The proposed development fails to observe Section 3.9 of the KDCP, which requires that new development adjacent to heritage items must respect established scale, roof forms, setbacks, and architectural detailing.

5. Failure of Good Urban Design Principles
In my opinion, the proposed development is incongruous with the urban fabric of Lindfield, violating core town planning principles, including those outlined in the NSW Urban Design Guide (2015) and Better Placed: An Integrated Design Policy. Notably:
• Contextual Incompatibility: The building’s scale, bulk and bland “box-like” design ignores the area’s topography, established residential character, and heritage fabric.
• Amenity Impacts: There will be significant overshadowing, overlooking, and loss of privacy to surrounding dwellings, with non-compliant setbacks and poor interface transitions.
• Public Domain Impact: The overdevelopment of the site will cause substantial visual clutter, lack of sunlight in the public domain, and degradation of pedestrian amenity.

6. Environmental Destruction and Loss of Tree Canopy
My understanding is that the application proposes the removal of many mature trees, many of which form part of the Ku-ring-gai tree canopy, a recognised ecological and visual asset. This would:
• Contravene the aims of the Ku-ring-gai Urban Forest Policy and Biodiversity Strategy 2030,
• Destroy habitat for protected and locally significant fauna, including Kookaburras, Galahs, Rosellas, Echidnas, and Ringtail Possums, and
• Accelerate heat island effects and significantly reduce the suburb’s environmental resilience.

7. Infrastructure and Traffic Overload
In my opinion, the proposed development will place unsustainable pressure on local infrastructure:
• The development adds 367 parking spaces which means there will be an additional 367 vehicles in the area,
• Traffic congestion, at the already critical Tryon Rd/Lindfield Ave, Lindfield Ave/Pacific Highway and Lindfield Ave/Havilah Rd/Pacific Highway intersections, will worsen considerably particularly during peak hour traffic,
• Local roads and street parking are inadequate and insufficient to accommodate the resulting increase in vehicle movements.,
• Existing water, stormwater, and sewerage infrastructure – not upgraded to accommodate such density – will be severely strained, contrary to planning principles that require development to match service capacity. I have lived in area for over 20 years and the water pressure at my property has been in gradual and continued decline over many years. So much so now, I can no longer run a bath in my house!
• Where are the children meant to go to childcare/school? My understanding is that all the local schools are at or above capacity.

8. Misuse of State Significant Development Pathway
There is no apparent legitimate basis for this proposal to be classified as “State Significant.” It does not demonstrate any extraordinary public benefit or strategic merit that would warrant bypassing Council oversight and community engagement mechanisms.

The use of the SSD pathway in this case appears to be a deliberate tactic by the developer to circumvent local controls, which must not be rewarded.

9. Aggregate impact of Developments
There are many developments being proposed in the area – for example SSD-79276958, SSD-81890707 and SSD-78996460 – which will have a cumulative impact on many of the issue raised above most notably traffic congestion, infrastructure overload (including sewer, water and childcare/educational institutions), and heritage impacts.

The cumulative impacts of all proposed developments must be considered when considering the merits or otherwise of any individual proposal.

10. Conclusion
In my opinion, this application fails all tests of reasonableness and fairness, as well as almost every relevant good planning principle:
• It is non-compliant with applicable height limits and planning controls,
• It inflicts severe and permanent damage to Lindfield’s heritage and character,
• It undermines public confidence in fair and transparent planning processes, and
• It disregards the environmental, amenity, and infrastructure needs of the community.

For these reasons, I urge the NSW Department of Planning to reject this application in full, and to support Ku-ring-gai Council’s evidence-based, consultative planning approach for Lindfield’s future.

Sincerely,