Residential flat building with in-fill affordable housing - 27-29 Tryon Road, Lindfield

I strongly object to the project in its current form on practical grounds. 1. Traffic Flow on Tryon Lane. Tryon Lane is a narrow 1 vehicle Lane and is the ONLY vehicle access for ALL the apartments from 1-25 Tryon road and Garages of Units on Russell Avenue are also located on Tryon Lane. Adding at least another 120+ vehicles from the new development would cause chaos, not to mention possible total blockage (during bdg construction) of the only access for cars of current Tryon & Russell Ave residents. 2, Important Loss of privacy and winter sunlight. The proposed 27-29 Tryon Rd development sits at the East North East end of Tryon Road. Many current apartments face this direction and benefit as the sun rises in this winter position. A high rise development will rob current residents of this important health benefit and also their privacy . 3. 25 Tryon road and (I've been told by RE agents) units on East of Havilah Road have been affected by significant ground water flows. A deep garage pit for in 27-29 could have damaging consequences. In conclusion the proposed 8 Level residences at 27-29 Tryon road would cause unacceptable traffic problems in the critical Tryon Lane and may result in major water issues. So the building height should be restricted to 5 levels and unit numbers lowered.

objection based on height and bulk of the project in the context of Tryon Road. The Seldon is only 4.6 (?) floors in height and will be semi dwarfed by the project. Its unlikely that the Seldon will be redeveloped in the foreseeable future in order to become more harmonious with this project at a later date, as there are 76 owners who would all have to agree (ie. contains 76 apartments), Also, the neighbouring small block at 31 Tryon Rd may not be able to be redeveloped either, as in bulkier form it may have to take in account the very beautiful neighbouring heritage item, ie. church next door. Also, The view of the church from Tryon Road, and especially that from Valley Lane will be negatively compromised by the height and bulk of the future building. in my own humble opinion such bulk and height are not fully justified considering the fact that a number of the apartments are vastly oversized, with internal lifts and internal staircases adding to their enormity. With alternative consideration of the sizes of a number of the apartments, the total count of dwellings in the project could have been greater , and so house a larger number of families/ couples/singles so close to Lindfield facilities.

Council objects to the proposed SSD - 78669234 for the reasons contained the attachment.

My comments are provided in the attached pdf file.

I am in shock by knowing this project, that will build a 9 levels of high rise not far to my home
my questions are
1, why we are not informed ? our neighbourhood should be respected and informed, it is Australian tradition and culture.
2, why it reaches to a high 9 levels? have your seen any higher rise around lindfield? and have you thought the scale will certainly worsen the already congested traffic?
3, it is close to Church, being my faith, it is not good thought to build a higher rise next church, despite I respect believers and non believers.
God bless the world.
Lian Zhao

I object to the proposed 7-9 storey development at 27-29 Tryon Rd Lindfield. At a height of around 30 metres this is excess in height and almost double planned under the alternative Kuringgai housing plan causing significant overshadowing and disrupting sight-lines with inadequate transition zones and set-backs to adjacent homes and streets reducing the privacy of numerous residents .
The demolition of a nursing home without alternative care for the elderly in the area demonstrates shortsightedness of the demographics.

As the owner of the penthouse unit 16, 25 Tryon Road, I make this submission objecting to State-significant development application SSD-78669234 for a 7 to 9 storey residential flat building at 27-29 Tryon Road, Lindfield.

1. The proposed 7-9 Storeys building will block sunlight to my apartment, especially during winter months. The application must be modified to a lower building of 5 storeys as Seldon and No.33.
2. The proposed roof garden directly overlooks my apartment which is unacceptable and invade my privacy. The application must delete that roof garden or move it somewhere else.
3. The proposed vehicle access to the development applied is via Tryon Lane which is already congested. The application must reduce the number of vehicles using this lane in the future by reducing the number of carspaces. Therefore, one single level basement should be excavated instead of 4.
4. The proposed excavation to 4 levels of basement is an unacceptable risk to my apartment which will be subject to significant subsidence risk.
5. The proposed removal of mature trees next to my apartment will adversely affect my living environment, privacy and setting.
6. The proposed development will make living in my apartment untenable, especially during the construction.

Overall, the application in its present form will cost me to lose your privacy, healthy environment, and property value.

I support the TOD and the building of residential apartments up to and including 6 storeys/20m as per the TOD. Any higher than this will result in overshadowing, privacy, solar access , conflicting with local amenity. I do not support additional heights requested.

I oppose SSD-78669234 as exhibited. The nine-storey, four-level-basement scheme is out of scale with its 4- to 5-storey neighbourhood, intensifies traffic in the narrow Tryon Lane, removes and threatens mature canopy trees and heightens uninsurable subsidence risk to adjoining properties. A reduced envelope—five storeys, single-level basement, compliance with the 15 % deep-soil guideline and strict lane-way traffic controls—would deliver housing without sacrificing neighbourhood amenity or the heritage setting of the Korean Community Church. My full submission, uploaded as a PDF, details these impacts and the specific amendments required.

Ku-ring-gai’s built heritage holds unique value, and as such, should be treated to acknowledge that value.

Ku-ring-gai as a whole is of national and state heritage significance because of the outstanding quantity, quality, depth and range of its twentieth century housing, including examples by many of Australia’s prominent twentieth century architects; and the evidence it provides of twentieth century town planning and conservation philosophies.
In 1997 this led to the National Trust recommending that 27 precincts be classified as Urban Conservation Areas (UCAs) (now called Heritage Conservation Areas) – more than any other local government area in NSW.

I object to the proposed 7-9 storey development at 27-29 Tryon Rd Lindfield. At a height of around 30 metres, 62 apartments, 136 car spaces and basement parking, nothing appears to be “State Significant” about this proposal. There is a lack of modulation, excessive and overbearing size, overshadowing and total inconsistency with the heritage architecture and historical values of Lindfield.

I object on the following grounds:

Inconsistent with Ku-ring-gai Council’s Preferred Scenario: The proposal ignores key planning principles and is inconsistent with Council’s Preferred Scenario (which supports new housing without sacrificing our heritage and natural environment, determined following consultation with the community).

Excessive Height and Poor-Quality Design: At a height of 7-9 storeys, this may well be the tallest structure in Lindfield, causing significant overshadowing and disrupting sight-lines with inadequate transition zones and set-backs to adjacent homes and streets whilst reducing the privacy of numerous residences.

Devastating tree canopy and wildlife impact: This development alone will involve the destruction of many established trees, impacting the natural landscape and destruction of the habitats of native species such as Kookaburras, Rosellas, Galahs, and Echidnas.

Traffic and Infrastructure overload: With 62 apartments in this single development, this development will compound an already traffic choke point entering the Pacific Highway plus local streets. Further our already strained stormwater, sewerage, transport systems, and parking will suffer further.

No community benefits: This project offers nothing to the community, instead, it only serves to destroy Lindfield's heritage and natural environment with the size and scale of the development. The demolition of a nursing home without alternative care for the elderly in the area demonstrates shortsightedness of the demographics.

Please do not allow the development to proceed without full re-assessment and consideration of the infrastructure.

PROPOSED CONSTRUCTION
Excavation
Four basement levels containing 136 car parking spaces will require deep excavations. There is a significant flow of storm water that passes through 25 Tryon Road in an easterly direction. The creation of a four-level underground car park creates a very significant possibility of subsidence and cracking of the neighbouring properties i.e. 25 and 31 Tryon Road is a real risk.
Recommendation:
• Modification to the overall design of the project by reducing its size to 5 levels would enable limiting basement level parking to one level (as exists at 9-25 Tryon Road). This would substantially reduce the risk of subsidence etc.
• Reduction in the size of the project to 5 levels will significantly reduce the level of demolition, site preparation, bulk earthworks and stormwater works associated with the proposed project.
Access
It has to be borne in mind that Tryon Lane is the ONLY vehicle access available to existing developments at 9, 15, 25 Tryon Road; also, the townhouses on Russel Avenue have their garage and vehicle access via the Lane. In addition, there are residences that back onto Tryon Lane. To add construction vehicles to utilise Tryon Lane would result in chaos. The lane is also a designated bike lane as well as providing pedestrian access to the station. Ballet school on the corner of the lane sees many children darting in and out as well as parent drop offs and pick-ups. (See photo: Tryon Lane from Lindfield Avenue-photo 4)
Due to the crucial nature of Tryon Lane, there cannot be any blockages or restrictions of traffic flow within Tryon Lane at ANY time.
Building works will cause considerable disruption to the neighbourhood, increased noise and dust.
Recommendation:
• Utilisation of Tryon Lane should not be permitted to heavy vehicles during the construction phase. Access for such vehicles should be via Tryon Road only; with all heavy vehicles being required to enter and exit the site from Tryon Road.
• Building works be permitted only between the hours of 7.00am to 4.00pm on week days.
• The cost of remedial cleaning of neighbouring properties should be borne by the developer.
SIZE AND DESIGN OF THE PROJECT
9-25 Tryon Road (Seldon) is a residential block occupied by residents 95% of whom are over 70 years of age. The same applies to the properties on Russell Street that have rear access via Tryon Lane.
The construction of a building of 9 floors is totally out of character with the neighbourhood. See photos of properties adjacent to the proposed development: 1 (25 Tryon) and 2 (31 Tryon Road). Properties opposite the proposed development are depicted in photo 3. The development should be reduced to 5 levels only. The reduced size will reduce the demand on the existing infrastructure.
The construction of a 9-level development will create overshadowing to 25 and 21 Tryon Road. To avoid this, modification of the design of the property is required.
Reducing the size of the project will also enable landscaping to enhance and soften the mass and bulk of the proposed development.
Recommendation:
• The height of the project should be limited to 5 levels, commensurate with existing buildings. Not only would this be more aesthetic but the reduced size will significantly reduce the pedestrian and vehicle traffic load in the area.
• Consistent with 25 Tryon Road, the levels of the building should also be layered so that floors 4 and 5 (of the 5-floor building) are set back from the frontage.
The roof garden proposed on Building C is designed to provide recreational space for the Project. This is unacceptable as it is in close proximity to the property at 25 Tryon Road. It would both overlook 25 Tryon Road impacting on the privacy that exists now and would also create the potential for noise (from parties and celebrations in the space) to disturb both 25 Tryon Road residents and those residents on the other side of Tryon Lane. A reduction in the overall size of the buildings to 5 levels would create a resultant reduction in the number of residents and thus demand for such a facility.
The development will cause removal of significant trees and gardens that will detract from the aesthetics of the area.
Recommendation:
• Remove the proposed roof garden.
• The removal of existing trees and vegetation needs to be assessed to ensure that the streetscape and curtilage are complemented.
IMPACT OF PROJECT
Traffic
Tryon Road is already congested because of the present car parking facilities (on both sides of the street) which are continuously utilised by commuters accessing the train station and shops. The addition of 63 new apartments (60 of which are 3-bedroom apartments) will only result in additional congestion. Tryon Lane is a one-way lane which already serves as the ONLY entrance and exit point for a number of properties. Additional traffic load will not be able to be accommodated without posing a traffic hazard, traffic congestion and danger to pedestrians who use this lane to access the train station.
It is important to note that the current entry to Tryon Lane is next to the Masonic Hall at which a Ballet School operates. Here young children and teenagers regularly attend. Parents frequently park their vehicles in Tryon Lane or thereabouts when collecting their children. (See photo 4)
Russell Lane currently allows traffic to flow in northerly and southerly direction. It is a very narrow lane and accidents and near accidents regularly occur there. It should be restricted to one way access to only allow vehicles to exit Tryon Lane to then enter either Russell Avenue or Trafalgar Road. See photos 5 and 6).
Recommendation:
• Tryon Lane to remain one-way only.
• Traffic entering and exiting the development should be via Tryon Road only and not Tryon Lane.
• Traffic flow in Tryon Lane to be unrestricted 24/7 to enable unrestricted flow so as to permit 24/7 access to all properties that currently utilise Tryon Lane-e.g. emergency vehicles
• Confine Russell Lane to ONE direction of traffic flow to only permit vehicles to use Russell Lane to exit onto either Russell Avenue or Trafalgar Road.
Korean Church
• The adverse impact on the heritage significance of the Sydney Korean Community Church at 33 Tryon Road, Lindfield needs to be considered.
Cromehurst
Cromehurst School caters for students from the age of 4 to the completion of year 12 in the moderate to severe range of intellectual disability.
Recommendation:
• The potential adverse impact a project, the size of the development, has on the important function this school provides to the community must be considered.

I would like to express my strong objections to the proposed development on 27-29 Tryon Rd, Lindfield (SSD-78669234).

Bulk and Scale – once built, the development will be the furthest from Lindfield station on the block, and yet at 9 storeys, will be the tallest. This completely goes against best practice town planning and design principles whereby the highest point of development should be the closest to the town centre/train station then gradually stepping down away from town centre. As this site is the only remaining site on the block, a 9-storey building is completely at odds with all the surrounding apartment which at are all at the 4-5 storey height. Rather than complimenting neighbouring apartment buildings, this development stands to destroy the street scape. It will overshadow neighbouring apartments as well as negatively impact on their privacy.

Heritage value – it was stated in the Heritage Impact Statement that 29 Tryon Rd is of local historical significance and that the dwelling positively contributes to the residential character of Tryon Rd. However, the developer tried to justify the proposal to demolish the house by claiming “there are numerous other examples of this style of construction in the local area that are conserved within the LGA's Heritage Conservation Areas, particularly the neighbouring Crown Blocks, Trafalgar Avenue and Middle Harbour Road Conservation Areas”. Sadly, this is no longer a valid argument. None of the conservation areas mentioned will be conserved as numerous development proposals are being put forward under SSDA. To name a few, 1-5 Nelson Rd in the Crown Blocks HCA, 59-63 Trafalgar Ave in the Trafalgar Ave HCA, 5-7 Middle Harbour Rd, 11-19 Middle Harbour Rd, 16-20 Middle Harbour Rd, and 24-28 Middle Harbour Rd, the Middle Harbour Rd HCA. How will the heritage characteristics of the area being conserved if hundreds of apartments are to be built within these HCAs? All these SSDAs were lodged under SSDA at the time this HIS was submitted. Therefore, I do not believe the report demonstrated an honest, objective assessment of the heritage impact of such development.

The HIS also failed to acknowledge the fact that Sydney Korean Community Church is two doors down from the development site and is a heritage listed item. Under the design guideline for Heritage, it is stated that “New infill buildings should generally be no higher than neighbouring heritage buildings or the predominant scale of the streetscape.” To construct a 9-storey contemporary building in such proximity to a heritage item demonstrates a complete lack of regard to the invaluable and irreplaceable heritage value of the church.

Congestion – Tryon Rd is a main arterial road in Lindfield. It is highly congested in the morning in three sections. One, being the T Junction where Tryon Rd meets Lindfield Ave. Two, Cromehurst School across the road from the proposed development. Cromehurst School caters for special needs children where majority of the children need to be transported in purpose fit vehicles. As such, there are quite a number of minibuses queuing along Tryon Rd during school pick up/drop off times. Three, the intersection between Tryon Rd and Nelson Rd is often at gridlock during peak hours. It is highly dangerous for pedestrians to cross the road as there is no traffic light, no pedestrians crossing and they need to look out for cars from four directions. As the development is proposing to have 136 car parking spaces, Tryon Rd simply cannot cope with this number of additional cars unless some forms of road changes are made. The congestion caused by additional cars from the development poses a real wellbeing risk to the children from Cromehurst School as their medical conditions do not give them the tolerance to cope with long travel delay.

Community consultation – there was a lack of genuine effort to consult and engage with the community. As a resident who lives less than 3-minute walk from the development site, no communication in any shape or form was received. Give the bulk and scale of the proposal, all the residents within close proximity of the site within a reasonable radius should have been notified as all the residents would be impacted by issues such as loss of views, overshadow, noise and pollution, just to name a few. There is no active community engagement effort, rather, notices were only given out to 166 residents on one side of Tryon Rd who are mostly apartment residents. The fact that only 2 submissions were received is an indication that most of the surrounding neighbours were not aware of the proposal.

In summary, the proposed development is out of character to the street scape and does not follow the design principle of gradual reduction in height from town centre. Affordable housing is not a satisfactory justification for allowing a 9-storey building being build on Tryon Rd. When the average price of a 3-bedroom apartment right next to the proposed development is around $3.5 to $4 million dollars, one would question how truly affordable can these new apartments be? Therefore, the SSDA should not be approved in this current form.

my comments are highlighted in bold on the submission from SP7724

Personally this development will block all my sunlight, I will lose my privacy and the noise will have a hefty impact on me as I am mostly housebound. The proposed 9 storeys development is not suitable for this part of Tryon Roads streetscape. Please read the attached letter for more detail on the impact to our community and the structure of my building at 25 Tryon Road.

Refer to attachment provided

Submission to NSW Department of Planning, Housing and Infrastructure

Re: Residential flat building with in-fill affordable housing - 27-29 Tryon Road, Lindfield. 19 May 2025


I wish to put forward objections to the above project, as a resident of the Northwood apartment complex at No. 25 Tryon Rd. Lindfield. I have studied the proposal documents put forward by its proponents and made available during the period of Exhibition. Several of these documents are referred to in these comments and selected pages are attached.

I should state at the beginning that my objections are not to the Government’s goal of increasing the stock of housing in NSW, nor to new housing in Lindfield. They are to specific features of this proposal that will have adverse impacts on neighbouring residents as well as future residents of the new complex, and which I believe could be corrected without serious difficulty by changes to the design.

My concerns are about two matters of importance to neighbours of the project: preservation of trees; and waste management.

(1) Preservation of trees.

The first concern is that aspects of the planned landscaping need to be modified on the grounds that there has not been sufficient effort made to preserve important trees on the Western boundary of the development, with consequential adverse impact on the residents of the apartments living in the neighbouring property No. 25 Tryon Road, which are close to the Western boundary of the proposed buildings A and C. I and other residents in No. 25 live in apartments which face eastward toward the new complex and will be directly affected by the project, as two of its four buildings which will be in close proximity—some 3 to 6 metres away from the fence.

With such a large, tall building planned, we are anxious to preserve as much of the natural habitat as possible. Yet only 3 trees on the side boundaries of the entire proposed development are to be retained. This is an enormous reduction of the vegetation and canopy currently enjoyed by residents and visitors to the Lindfield area, as well as the future residents of the complex. The planned landscaping of the property cannot replace the loss of fine established trees (See attached selected pages from the proposal’s Design Report and Arboricultural Report).

In particular, there are two large trees located inside number 27 just a metre from the boundary, towards the southwest end of the property, where they provide a natural and leafy landscape as well as screening and privacy at this end of the existing building. They are close to Tryon Lane, where the vehicle entrance to the new development’s garage will be, and if they are kept, would provide some shielding from traffic movement and noise.

The larger of the trees is a Cupressus, a very healthy tree 18 metres high, which the arborist Andrew Scales assessed as “A1 High” and “worthy of being a constraint.” But it is indicated on the plan as “to be removed”. This is not the arborist’s recommendation: he says it is worth preserving even at the cost of being a constraint. It is my belief that this tree could be preserved without much difficulty.
The other tree is a Phoenix Canariensis or Canary Island Date Palm, 9 metres high, with spreading branches and typical palm fronds. It is rated by the arborist as Z12, “unacceptably expensive to retain”. The tree is that it is quite healthy and would be worth keeping for its attractiveness at this end of the new development, which will be lacking established trees.
A third large healthy tree in the middle of the western boundary is a Chamaecyparis (or false cypress), providing screening and canopy in the middle of the western boundary of the development.

It is deeply concerning that these valuable and beautiful trees are planned to be removed, with considerable loss of amenity and green canopy. Removal would be a significant loss not only to residents of No. 25, but also to those who will own apartments in building C the new complex. The design plan (see Proposed Canopy Coverage, page 34) shows that this south-west corner of the property will have practically no ground-level vegetation. Keeping these trees would be a simple way of enhancing this part of the new complex for the new residents, while preserving the green canopy which provides tranquillity and protection to us residents of No. 25. Adding other trees along the boundary would further enhance the area.

Proposal 1.

It is proposed that the three large trees of importance identified above be retained and that others be planted in the area currently planned for waste collection.


(2) Waste Management & Environmental Impact

The plans for collecting garbage and waste from the development are to have waste collection trucks picking up bins at an open, ground level service area located in the south-west corner of the apartment complex. They will back into that open area from Tryon Lane to pick up bins brought up in a service lift from the garage. (See attached LANDSCAPING & WASTE MANAGEMENT document with relevant diagrams).

This will further adversely affect the well-being of residents of No. 25 due to noise, odours, and congestion for residents and passing traffic in narrow Tryon Lane. It will also prevent landscaping in that area of the property. It will also adversely affect the future residents of the new development who will own apartments close to the service area, as well as residents of other properties backing onto Tryon Lane. It will degrade the area in the southwest corner of the development, creating a less attractive and “underprivileged” section of the complex. For apartment owners in Building C that will reduce their enjoyment of their apartments and adversely affect their value.

An alternative would be to do all waste collection on the Basement Level 1, below where the bins will be located. This would eliminate the problem and enable the southwest corner of the site to be enhanced with landscaping and enjoyed by residents for residents of Building C, with less impact on neighbouring residents.

Another alternative would be to place the entrance to the garage at the south-east corner of the site, under Building D, with waste collection on the Basement Level 1.

(2) Proposal 2.

It is proposed that no waste collection operations be undertaken at ground level, but that the waste collection operations be done on Level 1 inside the garage, and possibly at the Eastern end of the complex under Building D.

I oppose the project for the following reasons:
* the height and scale of the project is completely out of character for the area and will devalue all surrounding properties. Specifically our building will be overlooked with sunlight and sky views restricted.
* The extensive construction period of 24 months and long working hours (until 6pm each day and 1pm on Saturday) will create an unacceptable level of disturbance to the surrounding residents by both the noise and continual dust. Residents will not be able to enjoy being outside.
* Continual trucks and trade vehicles will create extreme congestion in both Tryon Road and Tryon Lane.
* The development proposes parking access from Tryon Lane which will create a dangerous situation for both cars and pedestrians.
* From research performed it is not clear what sort of proven track record the developer has with such a significant building including actual completion, within stated timeframes and compliance with laws and regulations.
As elderly residents we feel exceptionally concerned and devastated about the interruption to what should be our golden years of retirement. We will not be able to feel safe in our own suburb and definitely not able to enjoy our balcony or garden in our apartment which drew us to this area in the first instance. At our age (> 80 years old) options to move away from this inappropriate development and extreme interruption are very limited which is devastating and frankly frightening.

I am objecting to this development for the following reasons:
1. Significantly increase the pressure on the current infrastructure particularly transport which is barely viable given the past development to date. This is particularly the case where there are many multiple SSDs around this area.
2. The multiple SSDs in this area are not necessary to meet the housing targets. The housing targets have been addressed in the current proposed TOD. Hence the only observable benefit is one-sided (that is, the developer) at the expense of existing residents.
3. Reduce privacy and sunlight on surrounding homes
4. Increase noise and traffic
5. Significantly reduce the flora and fauna, as well as the heritage characteristics which we pride living in this area.

I strongly support this proposal.
The reason as to why are the following
1. I support this proposal as it is close to public transportation and shops. We need more housing supply as we are in a housing crisis.
2. It is excellent to see what seems to be an all electric building, saving future residents money & also reducing dependency and use of fossil fuels.

PLEASE REFER TO THE ATTACHEMENT FOR FULL INFORMATION. THANK YOU.

Submission: 27-29 Tryon Road, Lindfield NSW 2070
State Significant Development
15/05/2025

Dear Sir/Madam
I am writing in relation to the proposed State Significant Development application SSD-78669234 – Residential flat building with in-fill affordable housing – 27-29 Tryon Road, Lindfield. This building falls within the LGA I reside in, and I request that the concerns in this submission alongside other similar submissions will be considered and addressed to ensure a more than optimal outcome for the local community and the environment.

Though I may be providing comments, I object to the project in its current form until the issues presented in this submission are resolved. If the issues presented are resolved, I will support the project accordingly.

Deep soil
The deep soil provided for this site is not sufficient and will result in negative impacts on the environment. Deep soil plays an extremely important role in minimising environmental impacts. Due to Ku-ring-gai’s proximity to national parks and endangered forests, this is vital for the LGA as impervious surfaces negatively impact the surrounding environment.
Impervious surfaces, such as concrete, have been linked to the cause of the urban heat island effect. This phenomenon results in increased temperatures in developed areas, particularly where there is little tree canopy cover to provide shade and cool the surrounding area through transpiration. Recent studies have shown that despite the cooling effects of tree canopy cover, there is a close relationship with the surface shaded. Due to the high thermal mass of concrete, it absorbs and retains heat longer than bare soil or bark mulch. As a result, it reduces the effectiveness of tree canopy cover as the heat is retained even after sunset – leading to higher surface air temperatures during the night (Kaluarachichi, Tjoelker, & Pfautsch, 2020; Pfautsch, & Tjoelker, 2020). Additionally, impervious surfaces prevent rainfall from infiltrating into the ground, leading to excessive surface runoff. This runoff contributes to stormwater pollution, disrupting local ecosystems and affecting nearby national parks. Stormwater also accelerates soil erosion, which affects soil fertility, weakens plant growth, and alters the natural landscape. Over time, this degradation impacts biodiversity, reduces water quality, and increases the risk of flooding, further stressing both built and natural environments. Due to this, reducing the amount of impervious surfaces and increasing deep soil area is vital to maintain environmental health.

However, the current proposed deep soil that complies with the ADG is 8.5% – significantly lower than the Ku-ring-gai Development Control Plan (KDCP) minimum of 50%, and just 1.5% more than the ADG minimum of 7%. Moreover, the SEPP requires a minimum of 15% deep soil with a minimum dimension of 3m, and the proposed development does not appear to be compliant with this standard. Not only will this lead to adverse environmental effects stated above, but will impact the surrounding tree-lined character of Lindfield. The presence of vegetation has proven to produce psychological benefits – positively impacting residents and community.

Despite having some advantages, not all standards required by the KDCP are environmentally oriented – it requires a higher minimum parking standard than what the SEPP typically allows or encourages. Cars have a higher environmental impact than alternative transport modes, and the proximity of this development to Lindfield railway station is planned to reduce car usage. However in this instance, the high number of parking spaces is adversely impacting the environment differently, as it has resulted in a large basement.

The most significant factors reducing the amount of deep soil proposed are the narrow setbacks due to the large footprint of the basement. For this site, the KDCP has been used to justify the high number of parking spaces – 123 spaces for 62 dwellings. On average, this is almost two spaces per dwelling, and has resulting in a inefficient four-level basement with two different footprints. Additionally, tandem parking is an inefficient layout that increases the number of parking spaces and the footprint of the basement, for minimal advantage. This provides limited deep soil opportunities throughout the site, negatively impacting the surrounding environment. In conjunction with potential risk for increase car usage and congestion, this plan must be revised to ensure that the development maintains a low ecological impact.

Requests:
• Rearrange the basement of the building to reduce its footprint. This may require reducing the number of parking spaces to achieve this or constructing an additional level below.
• Ensure than almost all the space within the building setback is utilised as deep soil. This is possible provided that the footprint of the basement is reduced.
• Ensure that the total amount of ADG compliant deep soil satisfies the minimum 15% required by the TOD SEPP and increase the amount of deep soil to the minimum 50% required by the KDCP, or at least as close to the minimum as possible. The adjacent 5 storey building has a similar site coverage but achieved the 50% deep soil area required by the DCP, so this should not be completely unfeasible.
• Increase the building height from 9 storeys to accommodate for the loss in floor area due to potential additional setbacks. This may result in a building height of 10-12 storeys.

Setbacks
The 6m front setback and the 3m side setbacks are less than optimal for a building this size. In Ku-ring-gai Council, residential flat buildings constructed in the past have adhered to the minimum 10m front setback and 6-9m side setbacks stated on the KDCP. This practice allows increased deep soil, tree canopy cover, and vegetation to surround the building, encouraging the important environmental benefits stated in the above point, alongside providing residents with optimal views to nature and increased privacy. Additionally, the generous front setback allows the uniquely high-density building in the lower-density surrounding environment to share a similar character alongside older development or previous residential flat buildings regulated by the KDCP. This includes the tall, large trees and the open, blue sky associated with Ku-ring-gai.

However, the current proposed setbacks do not facilitate any of these benefits or qualities. The 6m setback may align similarly with adjacent developments, but at 9 storeys the proposed building is significantly taller than its 5 and 3 storey neighbours. Neither of these developments are likely to be upzoned, demolished, and rebuilt for many years due to financial viability and costs. The justification provided for the 3m side setbacks is that the responsibility of maintaining adequate building separation required by the NSW Apartment Design Guide should be passed to the future development, and that the future adjacent building must increase their setback to accommodate for this. This justification is questionable as it unfairly impacts adjacent sites.

Requests:
• Increase the front setback from 6 to 10m to allow for increased deep soil and to maintain the surrounding character for the reasons provided above. If the rare instance that 10m is deemed to be completely unfeasible, please increase the setback as much as possible to the target distance.
• Increase the side setback enough to ensure adjacent sites will not be required to increase the setback of future buildings more than the minimum requirements.
• Increase the building height from 9 storeys to accommodate for the loss in floor area due to additional setbacks. This may result in a building height of 10-12 storeys.

References
Kaluarachichi, T. U. N., Tjoelker, M. G., & Pfautsch, S. (2020). Temperature reduction in urban surface materials through tree shading depends on surface type, not tree species. Forests, 11(11), 1141. https://doi.org/10.3390/f11111141
Pfautsch, S., & Tjoelker, A. (2020). The impact of surface cover and tree canopy on air temperature in Western Sydney. Western Sydney University. https://doi.org/10.26183/bk6d-1466