Residential Flat Building with Infill - Affordable Housing-24,26 &28 Middle Harbour Rd

I'd like to submit concerns and comments regarding the proposed development at 24, 26 & 28 Middle Harbour Road, Lindfield (SSD – 82548708), in the context of broader planning considerations affecting the surrounding precinct.

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

The proposed development at Middle Harbour Road must be assessed in the context of the anticipated higher-density development of 15–27 Russell Avenue & 54-50 Trafalgar Avenue, which lies immediately to the north. The Russell Avenue site is expected to support a greater building height and residential yield, consistent with the principles of the TOD SEPP and its proximity to key transport infrastructure.

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

Requested Actions:
1. Undertake an integrated precinct-level assessment encompassing both the Middle Harbour Road and Russell Avenue land parcels.
2. Ensure any approval at 24–28 Middle Harbour Road includes overshadowing analysis with respect to the future redevelopment of 15–27 Russell Avenue & 54-50 Trafalgar Avenue.
3. Apply equitable FSR and planning controls to enable 15–27 Russell Avenue & 54-50 Trafalgar Avenue to realise its full potential under the TOD SEPP, including the soon-to-be-included 19 Russell Avenue.

Thank you for your consideration. I trust the Department and Minister will take into account the strategic importance of this location and ensure fair and future-proofed planning decisions are made in line with broader State Government objectives.

Yours sincerely,


Rui Wang
23 Russell Ave, Lindfield NSW 2070

I refer to SSD-82548708 at 24,26 and 28 Middle Harbour Road and object to the project on the following grounds;
- The development height, bulk and limited setbacks are incompatible with conservation principals and undermine the intact heritage streetscape. The Developer has not shown transition to surrounding low-density, garden suburb character housing.
- Development is situated at least 550mtr from Lindfield Train Station (outside the 400m zone)
- The developer has not provided accurate or comprehensive visual perspective drawings to assess the full impact on the streetscape, particularly The Trafalgar Avenue and Middle Harbour Road Heritage Conservation Area’s.
- ⁠The proposal involves the removal of 18 mature trees, including STIF-protected Turpentine trees (PCT3262)
- ⁠The site partially lies within the Trafalgar Ave HCA (C31) and directly impacts heritage listed properties.
- It is very important that the site is within an identified overland flood path, flowing NW to SE across the property and into Gordon Creek Riparian Zone. Many times over my ten years at Lindfield I have seen flooding on the tennis court and leading down to the roundabout at Trafalgar Rd, this development will allow greater run off and flooding downstream. The developer will have to take this into account with storage tanks due to the loss of natural ground water absorbtion. I would strongly encourage the planning assessment to review stormwater management, flood risk during peak rainfall and long term impacts on riparian ecosystems.
- ⁠Deep soil coverage is only 27.8%, well below the 50% minimum required by Council.
- The main outdoor area and pool is on the roof. The noise from the premises will affect approximately 200 houses because it sits in a valley.
- I believe the developer has shown poor Community Engagement with no community workshops or forums. The only reason I found out about this project was from a friend and residents in the nearby vicinity have had no letters from the developer and nothing from NSW Planning. I believe if a project is to be classified as a major project at least nearby residents say within 500m-1km should be notified.

This development is very well located, as it is close to residential amenities in Lindfield and to Lindfield station. The proposal also includes 20 affordable units, which will increase the amount of more affordable housing stock within an incredibly expensive area of Sydney. Without more affordable housing, younger people will continue to be driven out of the area. The applicants' concern about the impact of the additional demand on the T1 North Shore line is unfounded. The T1 North Shore line now has ample capacity for the additional residents who will move into the upper north shore TOD areas as a result of the opening of the Sydney Metro City section. Between Jan 2024 and May 2024, the T1 line as a whole had an average monthly patronage of 8.18 million people, but between Jan and May 2025, this had fallen to 5.9 million people a month. Considering the data at the link below, there is a considerable drop in patronage on the T1 North Shore line following the opening of the Sydney Metro City section.
https://www.transport.nsw.gov.au/data-and-research/data-and-insights/public-transport-trips-all-modes
The proposal also has a good amount of deep soil (28.9%), which enables the high canopy cover (39%), which reduces the impacts of urban heat and improves residential amenity. The proposal has flood constraints, particularly in the PMF scenario, which may require extra flood prevention. However, this project provides much needed housing in a well located area, and as a result it should be approved.

I have added a submission of objection.

I object to the proposal at 24, 26, 28 Middle Harbour Rd on the basis of:

1) biodiversity impact
2) size and bulk of the proposal and the impact this will have on the nearby HCA and the overall amenity of the area
3) the impact this will have on the Council's preferred plan, most notably the intention to reduce the size of development as it moves down Middle Harbour Rd in order to reduce the impact of the HCA and other homes and to be more sympathetic with the overall street scape.

I make the following more detailed points:

The proposal involves the removal of many mature trees, including vegetation classified as Sydney Turpentine Ironbark Forest (PCT 3262), a critically endangered ecological community under the Biodiversity Conservation Act 2016.

The removal of critically endangered vegetation and reliance on offsetting (ecosystem credits) does not adequately mitigate the ecological loss. Retaining only 0.03 ha of PCT 3262 will result in significant biodiversity degradation. The loss of mature trees will reduce habitat for species like the grey-headed flying fox, which is listed as vulnerable under the Environment Protection and Biodiversity Conservation Act 1999. he replacement planting of 30 new trees will take decades to mature and cannot immediately compensate for the ecological services provided by the existing mature trees.

The site is flood-prone and includes an overland flow path, which is proposed to be diverted around the perimeter of the site. Diverting the natural overland flow path and relying on artificial flood mitigation measures risks increasing downstream flooding and altering hydrological patterns in adjacent areas.

The removal of mature trees and construction of a nine-storey building will significantly increase impervious surfaces and contribute to the urban heat island effect. While the proposal claims a 39% tree canopy coverage, this includes immature replacement trees, which will take years to provide meaningful shade and cooling.

The construction phase involves demolition, bulk earthworks, and excavation that will generate significant noise, dust, and traffic disruptions. While mitigation measures are proposed, the bulk of the development will inevitably result in soil erosion, sediment runoff, and air quality degradation, impacting nearby ecosystems and residential areas.

The proposal undermines the heritage significance of the Trafalgar Avenue Conservation Area by introducing a building that is out of scale and character with the surrounding low-density suburban environment.

The Council's preferred plan for Middle Harbour Rd envisages a reduction in the size of development as it moves down the North side of Middle Harbour Rd. This is to reduce the impact on the HCA and the heritage items in Russel Ave and Middle Harbour Rd. It also ensures a more sympathetic merging of the new developments with the exisiting street scape more generally. This proposal will seriously undermine the intended benefits of the Council's plan and could be said to effectively render it inoperable for Middle Harbour Rd. This would place the amenity of those residences that are not able to be converted into mid-level apartments at serious risk and entail lasting loss in terms of quality of life to the inhabitants of those residences.

I have lived in Middle Harbour Road for the past 10 years. My home has Gordon Creek and the Riparian zone running through our backyard. This is a unique “green corridor” that supports endangered remanent a broad range of native fauna and flora.

I oppose this proposal and refute the statement that it is “sensitive to the surrounding environment”. It fails to meet the requirements of Chapter 5(b) of Transport Oriented Development. It is not: i. well designed, ii of appropriate bulk and scale. Instead it delivers negative economic, environmental and social impacts on the community.

Major areas of concern include the Built environment including design quality, built form and urban design. The excessive height, bulk, size and scale, of this development is inappropriate for the site and the locality. Impacts to these have not been minimised, in fact ever opportunity to maximise the bulk, size and scale have been employed.

Stating that it will only “Generally comply with requirements” in relation to building separation, height, floor space is not acceptable. The proposal should be rejected automatically as it does not fully comply with all requirements. In my opinion there should be no justification to obtain additional building height that exceeds the maximum due to the slope of the site – instead this should be the very reason the current proposed height should be rejected.

Of major concern is the issue of land suitability and negative environmental impacts. This is “Flood prone land” yet the flood assessment report does not take into account culumative effect of built surfaces and lose of natural ground drainage from this and the other 500+ additional units currently submitted as proposals for consideration in close proximity. Flood assessment needs to be redone, taking into account combined impact. This proposal is directly upstream of the C42 Middle Harbour Road Conservation area. I have a very real fear that my property and at least another 6-8 other properties along Middle Harbour Road HCA Gordon Creek and Riparian zone will be adversely affected by the increase in threat of regular flooding/stormwater events. Beyond economic impact of damage to property, the increase in rate and volume of water going into Gordon Creek is likely to have a significant adverse effect on what is a fragile, ecologically significant environment, destroying native flora and displacing the many native birds and animals that live in its surrounds.

The proposed loss of tree canopy is also unacceptable. In addition to the natural environment, this proposal demonstrates a complete lack of respect for the built form of the surrounding Heritage conservation area. It totally devalues the heritage buildings that both directly abut it or will end up sitting within its shadow, destroys their visual amenity and robs the community of part of its history and what makes this suburb unique. It also does not in any way make appropriate consideration of transition, proposing a 9 story mass along side single and low density housing.

Insufficient road and traffic infrastructure is a further issue. The exit points from Middle Harbour Road into Lindfield avenue are already at capacity in peak hours and the entire suburb of Lindfield, East Lindfield and Roseville will effectively come to a standstill every week day morning and afternoon if such large density developments such as these are approved without adequate off street parking and council infrastructure investment.

I support the objective of delivering affordable housing in an appropriate manner and in line with SEARS guidelines which state that it is to be sensitive to local character and environment. This proposal is not that. Ku-ring-gai Council has committed to meeting its affordable housing targets and has outlined how it would do that. The Council’s affordability housing feasibility analysis report February 2025 identified other more suitable locations in Lindfield on the west side of the highway for affordable housing closer to railway and with better road access points.

This development of 9 stories with such height and bulk, on the outer edge of the Government TOD, nestled within pre-war and heritage homes should be rejected.

I strongly object to this proposed development due to its negative impact on local heritage, environmental sustainability, and infrastructure.
Heritage and Local Character: The scale and design of the development are excessive and incompatible with the surrounding low-rise, heritage-rich streetscape, undermining the area’s established character.
Traffic and Infrastructure Strain: Increased residential density will worsen traffic congestion and parking shortages, further burdening an already strained transport system and essential infrastructure.
Environmental Consequences: The project will lead to significant tree loss and destruction of wildlife habitats, diminishing biodiversity and green space within the community.
Failure to Align with Planning Principles: The proposal disregards key urban planning strategies, providing inadequate setbacks and transition zones that compromise residential privacy and diminish quality of life.
This development does not align with responsible urban planning and poses long-term risks to the community. I urge the council to reject the proposal to protect the area's heritage, livability, and sustainability.

I strongly object to this development. The development will isolate particular houses making an ugly mixture of low and high rise. Certain houses will not have the opportunity to develop due to the layout, such as 22 Middle Harbour Road which is planned to be between two apartments and is too small to develop an apartment by itself. This change is unfair for the existing residents who are left with devalued houses which have lost their character.

The house at 22 Middle Harbour Road will be sandwiched between apartments without the capacity to develop. This residential development will negatively affect the character of the suburb. The leafy appearance of the street which is also good for the environment will be demolished. This area does not have the infrastructure to support it.

Thank you for notifying Sydney Water of SSD-82548708 at 24-28 Middle Harbour Road, Lindfield.
Please see attached response and information sheet for the applicant.
If this response raises any enquiries, please do not hesitate to contact Sydney Water at [email protected]

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

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

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

Creation of a “Sandwich Block” and issues for neighbours
The proposed development will create a “sandwich block” between two large multi-storey apartment blocks on both sides of 22 Middle Harbour Road, Lindfield (ie the proposed multi-storey apartment block development at 16-20 Middle Harbour Road, Lindfield; and the above proposed development).

If the proposed development were to proceed, it will have serious adverse implications for the neighbours including without limitation: visual and other privacy implications; unbearable noise, worsened air quality and overshadowing.

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

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

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

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

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

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

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

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

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

My property will become a “sandwich block”, sandwiched between two large multi-storey apartment blocks on both sides of my house (ie the proposed multi-storey apartment block development at 16-20 Middle Harbour Road, Lindfield; and the above proposed development).

Should both proposed developments proceed (16-20 Middle Harbour Road Lindfield; and 24-28 Middle Harbour Road, Lindfield), my property at 22 Middle Harbour Road Lindfield will change from a highly desirable property to become unattractive. This will also impact the value of my property negatively and considerably.

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

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

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

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

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

Whilst I can appreciate that increasing housing density across Sydney, and an increase in the overall number of residential developers, is required in the longer term, the current rate of development outstrips supply of critical government infrastructure that needs to be built BEFORE any further residential properties are built in the area.

The current nearby state schools remain over capacity, many with "temporary", though now entrenched, demountable buildings that are not fit for purpose. This is particularly the case for Lindfield Public School, which is in a state of disrepair. The addition of extra dwellings, with the children that will come with it, will only overburden the current schools -- redevelopment of the current campuses, or creation of new schools (though ?? where) are essential to maintain CURRENT basic community services. Until the school situation is addressed, planning for future population growth is premature, and will only result in further deterioration of the current inadequate service.

Health care is stretched already in NSW, and particularly in Sydney. The closest tertiary hospital to the proposed campus, RNSH, is at critical capacity and has lost the room for further expansion of its campus due to the sale of sites adjacent to it for commercial interests. Whilst the RNSH building itself was rebuilt a decade ago, the actual bed capacity for the hospital has not significantly expanded in decades, despite the existing population growth that has occurred along this corridor. There is an imminent need for major investment in expanding the current hospital & critical care infrastructure just to cope with the _current_ local population. Hornsby Hospital is further away, and is going to be challenged itself by the population growth within the high density development around the station. As above, until the local public hospital system has been rectified for current needs, planning for future population growth in Lindfield, such as along Middle Harbour Raod, is premature, and will only result in further deterioration of the current inadequate government service.

The proposed TOD corridor alongside Lindfield railway station is also highly problematic from a traffic perspective. The CURRENT traffic situation is already very challenging, due to throttle points at the two access points onto the Pacific Highway - a railway bridge on Strickland avenue and a narrow tunnel on Balfour avenue. These two routes, particularly through the tunnel, have been "choke points" for _decades_. previous creation of the currently built apartments, combine with the commercial redevelopment, has created a large increase in traffic to the point that local passage along that route can be almost non-workable in peak periods. Increasing residential density along this Lindfield avenue corridor, which the current 59-63 Trafalgar Ave proposal would create, will only add to the burden the current population faces. No thought has seemingly been had to fixed the traffic issue - before any construction of higher density dwellings can start a longer term traffic solution is required.

Lastly, there is a lack of appreciation for the cultural significance of the buildings along this precinct. Unlike Europe and the UK, Australia would seem to have little appreciation for its heritage, and is very quick to demolish buildings with character and history, which one destroyed cannot be replaced. The construction of high density dwellings out-of-character with the area will tarnish the entire Heritage Conservation Area that exists within the area. Middle Harbour Road is am extremely well-preserved locale that examples the original architecture and heritage of Kuringai -- the street should ideally be preserved as is, in keeping with the stated desire to preserve Heritage within these designated council zones.

Ms Adela Murimba
Planning Officer
The Department of Planning,
Housing and Infrastructure NSW Government
4 Parramatta Square
12 Darcy Street
PARRAMATTA NSW 2150

Dear Ms Murimba
I have attached my submission to this document as I was not able to access the Planning Portal during the day.
My submission Letter is for SSD-82548708 - Proposed Residential Flat Building with Infill Affordable Housing at 24, 26 and 28 Middle Harbour Road, Lindfield.

I appreciate if you would kindly ensure that this is included in the submissions on the portal.

Regards

Resident
Middle Harbour Road, Lindfield