SCEGGS Darlinghurst Concept and Stage 1

Dear Prity


SCEGGS DARLINGHURST CONCEPT AND STAGE 1 DA - OBJECTION

We object to the proposed SCEGGS Concept and Stage 1 development
application and make the following submission for the consent
authority's consideration under the Environmental Planning &
Assessment Act.

RATIONALE FOR RE-DEVELOPMENT AND INCREASED CAPACITY OF THE SCHOOL

The proposed concept plan does not make the case that the significant
development is necessary, with all the inherent constructions risks,
demolition of heritage buildings and loss of amenity to the
neighbourhood. The assessment has also not properly considered the
likely impacts which will almost certainly result from the increased
size and capacity of the school facilities which will be authorised by
this concept proposal.

The EIS and the expert reports which inform the EIS conclusions rely
upon a "statement of present intent" that the proposed redevelopment
is not intended to increase the existing student population of the
School or the site area of the campus.

There are some fundamental problems with this approach. First, this
proposal does include a dramatic increase in Gross Floor Area of
3,123.3m2 over the site. This represents a 24.44% increase in GFA. In
other words, the area of the site occupied by school facilities will
be increased by almost 25%, but the precise future uses of that
additional space are not specified, nor the need for the increase
justified.

Whilst SCEGG's currently stated intent is not to increase the existing
student population of the School, once the additional `educational
establishment' and `early education and care facility' have been built
and once the overall GFA of the school site has increased in line with
the Concept proposal, the school will almost certainly seek to fund or
part fund the large cost of the development by increasing the number
of students. The deliberate decision to outline a "statement of
present intent" rather than an enforceable cap on student numbers
almost certainly means that the intent will inevitably change in the
future, by which time the opportunity to oppose a large increase in
the size of the school population will be lost to the people of
Darlinghurst and Sydney.

This concern is supported by publicly available data about the recent
trend in the SCEGGS population. The www.myschool.edu.au website
records the following enrolments:

2019 - not published (942 according to EIS)
2018 - not published (no annual or other report available at this
date)
‪2017 - 920‬
‪2016 - 917‬
‪2015 - 918‬
‪2014 - 921‬
‪2013 - 911‬
‪2012 - 911‬
‪2012 - 903‬
‪2010 - 898‬

Accepting the EIS and the myschool data, the trend between 2010 and
2019 shows an increasing number of enrolled students. If the
"statement of present intent" is to be given any weight in this
assessment, it can only be on the basis that the existing student cap
of 942 is preserved as an enforceable limit, and that this cap must
form the basis of all other assessment assumptions going forward.

In any case, when assessing the environmental impacts of this
proposal, the Department must consider the capacity of the proposed
new works, and their ability to accommodate more students. The
approach the School has adopted is not a proper basis for a valid
assessment of impact, and it should be rejected by the Department.

HEIGHT OF BUILDINGS

The proposal involves a significant exceedance of the height of
building development standard (refer to clause 8.1.1 of the EIS -
Figure 6 and Figure 7. The clause 4.6 submission).

The EIS argues that the exceedance of the height of buildings is
addressed by clause 42 of the State Environmental Planning Policy
State Environmental Planning Policy (Educational Establishments and
Child Care Facilities) 2017 (Education SEPP), which provides that for
a school classified as State Significant Development (such as this)
consent may be granted even though the proposal would contravene a
development standard imposed by an environmental planning instrument.
That may be true, but it does not allow the Department simply to
dismiss the height of buildings objectives under the LEP, which are
still relevant and must be considered by reason of section 4.40 of the
Planning Act.

Clause 4.3 of the Sydney Local Environmental Plan is in the following
terms:

4.3 Height of buildings

(1) The objectives of this clause are as follows:
(a) to
ensure the height of development is appropriate to the condition of
the site and its context,
(b) to ensure appropriate height
transitions between new development and heritage items and buildings
in heritage conservation areas or special character areas,
(c)
to promote the sharing of views,

In our opinion, the objective (a) is not met as it does take into
account the unique nature of the neighbourhood and the condition of
the site when considered in conjunction to the heritage buildings
nearby, the residential nature of the neighbourhood and the existing
height of neighbouring buildings. It is also our opinion that
objective (c) is unmet due to it clearly limiting or impacting the
view of adjacent buildings towards the harbour area. We are therefore
of the opinion that the proposed buildings that exceed the statutory
height limits be rejected under their present application.

HERITAGE IMPACTS

The demolition of Barham additions (1907-1922), Chapel Building
additions (1909-1926), Old Gymnasium (1925), Wilkinson House (1926)
and the Science building does not respond to and enhance the positive
qualities of their setting, landscape and heritage listing and will
not meet the objectives of clause 5.10(1) of Sydney Local
Environmental Plan:

The objectives of this clause are as follows:
(a) to conserve the environmental heritage of the City of Sydney,
(b) to conserve the heritage significance of heritage items and
heritage conservation areas, including associated fabric, settings and
views,
(c) to conserve archaeological sites,
(d) to conserve Aboriginal objects and Aboriginal places of heritage
significance.


The SCEGGS Darlinghurst site is identified as a local heritage item
(no. I301) within the C13: East Sydney Conservation Area. It is also
located within the vicinity of a number of local and state significant
heritage items.

The EIS's Heritage Impact statement purports to address the LEP
objectives as follows:

The proposed Stage 1 redevelopment design for Wilkinson House achieves
the objectives of this clause through the:
- retention of views through Forbes Street and St Peters Street

- establishment of a building of a similar height and mass to
the preceding Wilkinson House 
- establishment of a building
which reinforces the street alignment of Forbes Street and St Peters
Street

These documents do not demonstrate how the proposal conserves the
environmental heritage of the City of Sydney, or achieves any of the
LEP objectives. Far from conserving heritage, this proposal will
result in its destruction.

Some of the buildings to be demolished are over 100 years old. The
buildings in question are all in good order, and not only have
heritage significance within the listed site, but also contribute to
the heritage character of the surrounding items and the heritage
conservation area. Given the comments above about the need for the
project, and that the precise specific future school uses of the
proposed new building envelopes remains unclear, there has been no
robust assessment of whether the proposed demolition of heritage
buildings, and the significant loss of our heritage, is justified.

Wilkinson House is to be demolished. The 1920s Wilkinson Building
which is located at the corner of Forbes street and St Peters Street
was designed by the renowned architect Emil Sodersten and makes a
highly significant visual contribution to defining the heritage
streetscape of this section of Forbes Street. Insufficient attempts
have been made to adapt the building for re-use, to explained why the
buildings are unsafe or unsound and why they cannot be adaptively
reused. The starting point of this application is that the heritage
buildings should be demolished, but that proposition is not properly
justified.

The existing 1830's John Verge designed 'Barham' which is located
within the school site only has limited public views available from
the Forbes Street. The proposed Masterplan desires to further reduce
these public views by constructing an inappropriate modern building on
the Forbes Street side of the Barham building, which will then
effectively block all meaningful public views of the historic building
from the Forbes Street and overwhelm the historically important house.

To allow this demolition to proceed on the information provided in the
EIS would be inconsistent with the clear principles established by the
Land and Environment Court (see
https://www.caselaw.nsw.gov.au/decision/549f84273004262463abec2e).


LOSS OF VIEWS


The height of the proposed new Multipurpose Building is approximately
2.8 metres higher than the existing heritage listed Old Gym Building
(which will be demolished) with the inherent loss of views and light.
Some residents in Forbes Street and Liverpool Street will lose
entirely their iconic Harbour Bridge views. Others will lose their
city views, including of the Centrepoint tower. None of these impacts
have been properly assessed and justified in accordance with the `view
sharing' principles outlined by Land and Environment Court planning
principles. The statutory non-compliance with height limits
immediately indicates that the significant view loss impacts are
unacceptable, if the relevant Court precedents are correctly applied
(see: https://www.caselaw.nsw.gov.au/decision/549f893b3004262463ad0cc6).

OVERSHADOWING

The EIS states:
"the proposed buildings have been designed to limit overshadowing of
adjacent properties and view impacts are reasonable in the
circumstances of this particular site (Refer Section 8.1.2 of this
EIS). Where impacts to properties to the south are unavoidable from a
reasonable built form due to site orientation and existing setbacks we
note these impacts are largely resulting from a compliant building
height in that location." 

To a certain extent this is
true, but the shadows cast by the additional height of buildings above
15m do further reduce solar access to additional properties further
south of the site. The 19th century terraces at the end of Thomson
Street will lose a large amount of northern light and some western
light.

BULK

The proposed 7 storey multifunction building is too high and not set
back from the existing two storey 19th century terraces that are
adjacent to the building on both Thomson and Bourke Streets. The bulk
and scale of the building is inappropriate for context of the
surrounding heritage conservation zone. The non-compliance with the
LEP is not justified in the circumstances.

AMENTIY IMPACTS

The real impacts of the development have not been properly assessed by
this application. Before the consent authority (and the community) can
assess and comment on this development, these impacts must be
transparently assessed and reported having regard to:
the additional capacity of 3,123.3m2 in GFA. There has been no
assessment whatsoever of the impacts which will result from a 24.44%
increase in the capacity of SCEGGS to accommodate students;
the breach of the Height of Building provisions of the Sydney Local
Environmental Plan;
the breach of the Heritage Conservation Objectives of clause 5.10 of
Sydney Local Environmental Plan; and
principle 1 of the Schedule 4 of the Education SEPP: " Schools should
be designed to respond to and enhance the positive qualities of their
setting, landscape and heritage"

TRAFFIC AND PARKING

Appendix K Traffic Impact Assessment to the EIS dismisses any traffic
or parking impacts as follows:

In summary of the Concept
Masterplan, there will be a net increase of 3,123.3m2 GFA but
importantly, no increase in either staff or student numbers, with the
new facilities focussed on the delivery of improved functionality,
efficiency and amenity.(p.29)

"In summary for Stage 1,
there will be a net increase of 163.1m2 GFA but importantly, as with
the Concept Masterplan, there will also be no increase in either staff
or student numbers for Stage 1.(p.30)

"The Development
Application will not seek to change the number of students or staff
and as such an assessment on the trip generating potential of the
school is not considered warranted.(p.53)

The additional
GFA of 3,123.3m2 proposed in this development is able to accommodate a
significant increase in capacity for the student population and
teacher population. This will inevitably result in a dramatic increase
in traffic which has not been properly or transparently assessed.

INAPPROPRIATE CONSULTATION

The school has never held one meeting where all stakeholders have been
present to hear the concerns of others. The school has carefully
designed the process to avoid opposition to its plans. Where they have
documented consultations, they have actively misrepresented the
discussions, for example, East Sydney Neighbourhood Association (ESNA)
were NEVER "indifferent' to the proposed demolition of the historic
Wilkinson House. The consultation process is illegitimate and does not
comply with reasonable expectations of public participation.

NOISE

The acoustic report in the EIS make no reference to the number of
students which are assumed for the purposes of the assessment. The
assessment of noise impacts should have been made on the basis that
the net increase of 3,123.3m2 GFA must necessarily increase the
capacity of the school to accommodate students, and that this must
inevitably have an effect upon noise impacts on neighbours.

Your sincerely

Tariq Scherer & Erin Fairs-Scherer

Unit 28/200 Forbes Street,
Darlinghurst
NSW 2010

I do not object to reasonable, sympathetic redevelopment or re-purposing
of buildings on the SCEGGS site, but the current proposal represents a
direct challenge to the heritage conservation area of which it is a
part.

I have seven specific objections.

1. The proposal does not include any rationale for the extraordinarily
large increase in floor space. Given the growth in student numbers
(currently 942) over the past decade, and the proposal to enrol 90
children in the short term in the early learning/child care centre,
the only reasonable conclusion is that enrollments are intended to
grow considerably.

2. Any increase in enrollments would exacerbate traffic problems that
exist currently in the morning and afternoon drop-off and pick-up
times.

3. The planned partial external restoration of the 1830s Barham
building seems commendable, but is negated by the inappropriate modern
structure between it and Forbes Street.

4. I see no great problem with changing the interior of Wilkinson
House, but the local-heritage listed 1920s building's demolition would
be sheer vandalism. Not only is it a key part of the area's heritage
at the William Street end of Forbes Street, damaged already by the
forty-three storey Horizon building, but it is an example of the work
of Emil Sodersten, co-architect of the Australian War Memorial in
Canberra, and the architect of Birtley Towers in Elizabeth Bay and the
Reid Building at St Andrew's College at the University of Sydney.

5. The bulk of the proposed general-purposes building of up to seven
storeys is significantly non-compliant with rules applying to the
surrounding heritage conservation area, particularly in relation to
the neighbouring terrace houses.

6. It appears from the plans that some residents of Forbes Street and
Liverpool Street would lose their iconic Harbour Bridge views.

7. Although I am not an expert on overshadowing, I understand that
several houses in Thompson Street would lose all northern light and
some western light.

I am making an objection to the SCEGGS Darlinghurst DA on the basis of
concerns over the impact of the newly constructed site on increasing
traffic around the school area which will impact residents of The
Horizon.

I am horrified that this proposal by SCEGGS school proposes to demolish
the heritage listed Wilkinson House, and to overshadow and overcrowd
the historic 1830's Barham building with a 7-storey general-purpose
building.

It is hard to see what justification there is for such a large
building that would be non compliant with rules applying to the
surrounding heritage conservation area.

The neighbouring terrace houses in Thomson Street and Forbes Street
are one of the most attractive remaining examples of their type, and
would not be allowed to reach the heights proposed for this 7-storey
building, but would be subject to over shadowing, and loss of iconic
views from its construction.

SCEGGS has an enormous school site, why should they be permitted to
cause historic terrace houses to lose their northern sun and views?

How can SCEGGS be permitted to argue that the only increase in school
enrollments will be 90 children in the early learning child centre? If
this was so, what need is there for such a monstrously large general
purpose building?

The increase in school population that is implied by the proposed size
of this general purpose building may have major effects on the already
problematic traffic issues around arrival and departure times in
Forbes and Bourke Streets.

Last but certainly not least, is the over bearing effect this building
would have on the very historic Barham building. Residents in the
surrounding areas would like to see more of this building, not less.

Demolition of Wilkinson House - loss of a significant local heritage
item, impact on the Heritage Conservation Area and impact on the
streetscape;
Failure of Master Plan and address current significant traffic
management issues - these are of particular concern with school
traffic already very bad in Forbes Street;
Inadequacy of the Traffic Report included in the submission - see
above;
Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
Impact of staging and construction on residents of Forbes Street.

* Already traffic is a nightmare on Forbes Street and the proposed
development will simply exacerbate the problem
* I don't agree with the demolition of Wilkinson House which is a
significant local heritage icon. Its demolition would impact on the
Heritage Conservation Area and impact on the streetscape;
*The Master Plan fails to address current significant traffic
management issues;
*The Traffic Report included in the submission is deficient;
*Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
*Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
*Impact of staging and construction.

To Whom It May Concern.

I would like you to consider an OBJECTION to the proposal above, in
particular the demolition of Wilkinson House, and the increase in
traffic to the local area.

WILKINSON HOUSE. My apartment FT9 is situated on Forbes St almost
directly opposite Wilkinson House. In my opinion this heritage
building is integral to the eclectic nature of Darlinghurst, part of
the history of the area, and as an important heritage building should
be retained.

INCREASED TRAFFIC FLOW FROM ADDITIONAL BUILDINGS.
As noted above, my apartment in the low rise section of The Horizon on
Forbes St and my bedroom window overlooks Wilkinson House. School
busses frequently park on Forbes St opposite my bedroom window both
early in the morning and at weekends. For long periods the busses wait
for school girls to board, their motors are kept running, presumably
to keep the air conditioning running on the bus, causing both air and
noise pollution.
At school drop-off and pick-up time the traffic in Forbes St is
horrendously congested. There is always a long queue of cars down
Forbes St with parents dropping girls off. Many parents have no regard
for road rules and simply double park while waiting for a parking spot
in the drop off zone outside SKEGGS so there is no possibility of
by-passing the queue of cars to enter Horizon car park (note - mainly
teenage girls are being dropped off, not small children who need
parental care). Also many parents continue to use the Horizon driveway
into the car park as an area to do a three point turn and go back up
Forbes St, causing more congestion.

An increase in size of SKEGGS buildings would surely mean in increase
in scholars in the future, and the traffic problems noted above would
also increase.

I object to this concept and stage one proposal on the following grounds:

1. it will result in the demolition of several significant heritage
items within the listed SCEGGS site. This demolition is inconsistent
with the heritage conservation objectives under the applicable
provision of the Sydney Local Environmental Plan, and it is not
justified having regard to the well- rehearsed planning principles
applied by the Land & Environment Court. The proposal does not
conserve heritage but will rather destroy it. It will also negatively
impact the nearby listed items as well as the heritage conservation
zone, to the value of which the SCEGGS buildings slated for demolition
make a positive contribution. The buildings to be demolished are all
in good order and could readily be repurposed for other school uses,
and the EIS assessment of this issue does not put forward a robust or
reasoned case for demolition which would survive scrutiny in the Land
& Environment Court. The Department should also reject it.

2. the impacts of the large increase in gross floor area which the
Concept and stage 1 DA propose will inevitably create a larger
capacity which will likely result in an increase in student numbers,
but the proposal simply side-steps this increase by asserting the
school has a "present intention" not to increase student numbers. This
proposition beggars belief, and it cannot be used as the underlying
assumption which informs the assessment of impact.

3. it follows from 2 that the serious likely amenity impacts (traffic,
noise, parking) are not adequately or transparently assessed. The
cumulative impact of this proposal must be considered against the
exiting environment of the school and its surrounding where there are
already significant traffic and noise impacts resulting from the
existing school. The likely impacts of this proposal will add
significantly to these amenity issues, but they have not been assessed
in a transparent or orthodox manner.

4. The proposal exceeds the hight of building limits in the LEP, but
this issue has not been properly assessed or justified in terms of the
objectives of the LEP or the mandatory requirement of the principles
set out in schedule 4 of the State Environmental Planning Policy
(Education). This proposal does not withstand scrutiny against those
matters, and it is insufficient for SCEGGS to argue that height limits
can be ignored by reason of SEPP Education, and because this proposal
is "state significant development".
5. The capital investment value of this project must be subjected to
scrutiny by the Department, given that it falls just short of a $50
million threshold. In any case, it does not satisfactorily address the
design excellence requirement of the LEP.

6. The proposal will have a serious impact on the Forbes Street
frontage, by introducing a new building to replace the exiting
heritage listed building and take up open space along Forbes st. This
is out of character with the local area and will impact on locally
listed items outside the site and in the nearby heritage conservation
area. It will change the character of the street, which retains its
19th and early 20 th Century character.

7. The proposal will result in loss of iconic views from various
residents in Forbes St, but these impacts have not been tested agains
the planning principles for view sharing which have been set out by
the Land & Environment Court.

I oppose the project as proposed. No demolition to a Herritage
Building. Street is too small for large construction. Owner and
tenants in the Horizon must be able to get in and out of the
building with major delays. The site is already over built.

Please take a more detailed review of the project before approving it.

Thank you,
Zelko Simoni

I object to the application. I do not want a Heritage building
demolished. The street is too small for this large construction
project. Too much traffic already. Owners and tenants of the
Horizon building must get in and out of the building without
major delays. The site is already over built.

Please take a more detailed review and deny the application.
Thank you,
Renee

The concerns include:
Demolition of Wilkinson House - loss of a significant local heritage
item, impact on the Heritage Conservation Area and impact on the
streetscape;
Failure of Master Plan and address current significant traffic
management issues;
Inadequacy of the Traffic Report included in the submission;
Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
Impact of staging and construction.

I want to hereby lodge an objection to the SCEGGS development proposal.

Darlinghurst is one of Australia's most significant historic
neighbourhoods, recognised by community, and the heritage provisions
in clause 5.10 of the Sydney Local Environmental Plan 2012.

Darlinghurst significant ribs are along the ridge line, Darlinghurst
Rd, Victoria St, its hill climbing streets, Liverpool and Burton St,
and then Forbes St which runs from Taylor Square, past the National
Art School, which is a historic precinct, the Christian Science
Church, Beaufort Court, one of Sydney's oldest apartment buildings
down to the sandstone stairs that access William St.

Darlinghurst is also domicile to a collection of significant
institutions, including St Vincents Hospital, SCEGGS, and the Jewish
Museum.

Balancing the significant power these institutions have in reshaping
the landscape against the need to preserve the historic value of the
area is an essential responsibility of the planning process.

Considering this policy objective, SCEGGS has undertaken a process
that has been designed with intent to limit engagement with community
concerns, and fails to address the fundamental heritage issues of the
area whatsoever.

The plan's consequences are;
* the expansion of SCEGGS not just in terms of built capacity, but
also it seems clear, ultimately through the increase in number of
children beyond the specified cap
* demolishing buildings of historic value
* the construction of new buildings not consistent with the scale of
surrounding structures

In permitting this specific development, which is of itself contrary
to the heritage strategy for this significant area, a precedent is
also set for future development applications making the preservation
of the heritage character significantly more difficult. The heritage
question is about more than just specific buildings, but also the
human experience in walking through the neighbourhood. If planning
objectives are to have meaning, I would suggest, SCEGGS has an
obligation to show how its development supports if not strengthens the
character of Forbes St. In the absence of that I want to lodge my
objection to the Sceggs Development Proposal.

Regards

Christopher Selth

I own an investment property in the Horizon building at 184 Forbes
Street, Darlinghurst 2010.
I OBJECT strongly to this Concept Development Application being
approved for the following reasons:
* Demolition of Wilkinson House - loss of a significant local heritage
item, impact on the Heritage Conservation Area and impact on the
streetscape;
* Failure of Master Plan and address current significant traffic
management issues;
* Inadequacy of the Traffic Report included in the submission;
* Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
* Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
* Impact of staging and construction.

I object to the SCEGGS Darlinghurst Concept and Stage 1 DA for the
following reasons:

1) Loss of heritage character with the proposed demolition of existing
Wilkinson House. The development application should conserve the
existing facade and heritage character facing Forbes St.

2) The traffic impact assessment doesn't recognize the considerable
disruption to residents of The Horizon such as traffic jams during
peak times, idle buses and noise pollution to residents, as well as
cars using our private property to turn around (given Forbes St is a
dead end and St Peters St is not open 24/7). The assessment doesn't
address how these existing issues are going to be addressed over the
longer term, including increased student numbers or more weekend
traffic.

3) There is not enough visibility on the timing and staging in the
application, as noise from excavation and construction will be a major
disturbance to local residents. More visibility is required on how
impact on local residents will be minimized and what consultation /
complaints handing process will be implemented.

4) The application says there will not be an increase in total
staff/student numbers but this is inconsistent with the suggestion of
a childcare centre as part of the 2040 masterplan. This also impacts
the issue of traffic congestion and noise disturbance. The traffic
impact assessment does not appear to be consistent with the approved
use of a childcare facility in the concept plan.

5) The department should consider the impact of any changes to the
roof material to minimize reflection / glare that impact residents of
The Horizon

Objection

LACK OF RATIONALE FOR RE-DEVELOPMENT

The proposed Masterplan does not make the case that the significant
development is necessary, with all the inherent constructions risks,
demolition of heritage properties and loss of amenity to the
neighbourhood.



The proposed new "early learning/child day care" use at the site with
90 proposed "student" places is a clear breach of the existing cap of
942 students by the school. These additional early learning/day care
places at the site will actually have a greater per student impact on
the already significant school traffic and parking congestion on the
local streets surrounding the site as the parents of these children
will be even less likely to walk or use public transport and will
therefore have a higher car usage rate than for the parents of the
other school students. None of these issues are considered in the
Masterplan.



DESTRUCTION OF HERITAGE

The plan involves the demolition of a number of heritage items,
without any regard for their importance to the wider community. Some
of those buildings are over 100 years old. The buildings in question
are all in good order, and contribute to the heritage character of the
area. Given the comments above about the need for the project, and
that the specific future school uses of the proposed new building
envelopes remains unclear, there has been no robust assessment of
whether the proposed demolition, and the significant loss of our
heritage, is justified. To allow this demolition to proceed would be
inconsistent with the clear principles established by the Land and
Environment Court.



Wilkinson House is set for immediate demolition as the first step in
SCEGGS over-development. The 1920s Wilkinson Building which is located
at the corner of Forbes street and St Peters Street was designed by
the renowned architect Emil Sodersten and makes a highly significant
visual contribution to defining the heritage streetscape of this
section of Forbes Street. No changes to the facades of this building
should be permitted in order to retain the existing heritage character
of this section of Forbes Street. Insufficient attempts have been made
to adapt the building for re-use, to explained why the biodiversity
are unsafe or unsound and why they cannot be adaptively reused. The
starting point of this application is that the heritage buildings
should be demolished, but that proposition is not justified.



The existing 1830's John Verge designed 'Barham' which is located
within the school site only has limited public views available from
the Forbes Street. The proposed Masterplan desires to further reduce
these public views by constructing an inappropriate modern building on
the Forbes Street side of the Barham building, which will then
effectively block all meaningful public views of the historic building
from the Forbes Street and overwhelm the historically important house.


The significant and unjustified heritage impacts of this proposal mean
that the project is inconsistent with the objectives of the heritage
provisions in clause 5.10 of the Sydney Local Environmental Plan 2012.
Far from ensuring the conservation of our heritage, this proposal will
completely demolish the entire, beautifully preserved fabric of
significant items within the school and will also have a significant
and unacceptable impact on nearby items outside the school, as well as
on the surrounding heritage conservation zone.



LOSS OF VIEWS

The height of the proposed new Multipurpose Building is approximately
2.8 metres higher than the existing Old Gym Building with the inherent
loss of views and light. Some residents in Forbes Street and Liverpool
Street will lose entirely their iconic Harbour Bridge views. Others
will lose their city views, including of the Centrepoint tower. None
of these impacts have been properly assessed and justified in
accordance with the `view sharing' principles outlined by Land and
Environment Court planning principles. The statutory non-compliance
with height limits immediately indicates that the significant view
loss impacts are unacceptable, if the relevant Court precedents are
correctly applied.



OVERSHADOWING

The 19th century terraces at the end of Thomson Street will lose all
northern light and some western light. They will be completely in
shadow.



BULK

The proposed 7 storey multifunction building is too high and not set
back from the existing two storey 19th century terraces that are
adjacent to the building on both Thomson and Bourke Streets. The bulk
and scale of the building is inappropriate for context of the
surrounding heritage conservation zone. The non-compliance with the
LEP is not justified in the circumstances.



INAPPROPRIATE CONSULTATION

The school has never held one meeting where all stakeholders have been
present to hear concerns of others. The school has carefully designed
the process to avoid opposition to its plans. Where they have
documented consultations, they have actively misrepresented the
discussions, for example, East Sydney Neighbourhood Association (ESNA)
were NEVER "indifferent' to the proposed demolition of the historic
Wilkinson House. The consultation process is illegitimate and does not
comply with reasonable expectations of public participation.

Dear Sirs,
I wish to object to SCEGGS Darlinghurst Concept and Stage 1 (SSD 8993)
Development Application.
I object to the destruction of heritage buildings including Wilkinson
House, the Library and science building and the old gym building at
the northern end of Thomson Street.
These building all have an intrinsic purpose in relation to the other
Victorian or Victorian styled buildings in the neighbourhood.
They should be refurbished and repurposed and not destroyed.
The buildings to replace them are all a gross over development of the
sites, being too large in both height and bulk, overshadowing their
near by neighbours and in effect turning their back on the
Darlinghurst neighbourhood.
Not only do they not relate to their surrounding, they seek to block
off the school in relation to the rest of the community, in effect
creating Fortress SCEGGS, an elite school too elitist to want to be
part of their right- next-door neighbours.
These new building also intend to be used by extra numbers of students
and this is in breach of the existing regulations that limit the
number of students due to the small amount of land the school stands
on and the very limited open space.

These extra student numbers, combined with a yet to be built drop area
and extra car parking spaces will only increase the school already
high level of petrol pollution that occurs every school day, morning
and evenings. SCEGGS should be reducing the number of cars it draws to
the neighbourhood, not increasing them.

SCEGGS has already destroyed many old buildings and terrace house in
their care; they should not be allowed to destroy any more of this
unique and historic neighbourhood

I object to the proposal for a couple of reasons:

1. There appears to be ambiguity in the proposal as they state there
will be no increase in student numbers however they are proposing an
Early Learning Centre with 90 spaces. This would result in a
tremendous number of cars needing to park to drop off, take children
inside, pick up, again necessitating parking and going inside. The
traffic management issues at SCEGGS are already very precarious, which
they have not addressed satisfactorily up to now, and this will only
multiply the problem. Cars and buses regularly double park on Forbes
Street. The school keeps the boon gates down at St Peter's Lane most
of the time. (Why do they get to regulate that anyway?) This
necessitates the school traffic and any other traffic having to do a
three point turn on the narrow Forbes Street or to use the Horizon
driveway to turn around in which is very disruptive and dangerous.
2. They propose to pull down Wilkinson House which is a local Heritage
listed building. Surely they should be able to retain the facade and
rework the space inside to a more usable space. We have lost so many
of our Heritage buildings. It would be a shame to lose another.

Thank you for your consideration,
Pamela Davis

I want to make an objection to the project. My main concerns are the
following:

* I do not approve of the demolition of the Wilkinson House - which is
an heritage building and should be preserved in our neighborhood. This
will have an impact on the heritage conservation area and on the
general look of our street. We should learn lessons from the past and
not demolish heritage buildings.
* As a resident of the street, I do not believe that the traffic
issues have been sufficiently understood and addressed. The congestion
at drop-off and pick-up times is intense on Forbes Street.
* I find suspicious that the stated capital investment value falls
just below the threshold at which a design competition is required. I
suspect that some of these numbers and estimates have been manipulated
in order to avoid a design competition.
* I am worried by the implications of an early education and care
centre for up to 90 children, and have the feeling these have not been
sufficiently assessed and anticipated.

For all these reasons I strongly object to the project as it is
currently described.

Thanks

I object to the development proposed by SCEGGS for the following reasons:

*the proposed multi purpose building is much closer to the end of
Thomson Lane than the existing structures. At present Thomson Lane is
an open space between rows of terrace houses used by the residents of
Thomson Lane and Forbes Street. It will lose its open feel with a 7
storey building looming very close to one end. It will feel closed in
as the 7 storey multi purpose building looms large above. Thomson
Street and Forbes Street are residential and the preservation of open
space is important to the amenity of the residents.

*the proposed multi purpose building will reduce the light available
to the upper level rooms of my residence at 225 Forbes Street.

*the proposed multi purpose building (being much closer to my
residence than any current structures) will give the upper rooms of my
residence a "closed in" feeling as the view out of the windows will be
of a bulky building in the immediate vicinity - rather than the
existing views of buildings in the distance.

*the proposed multi purpose building is out of character with the
other buildings in the vicinity, being 7 storeys high and being built
very close to the border of the property.

re: Name: SCEGGS Darlinghurst Concept and Stage 1 DA
Application No.: SSD 17_8993

As a local resident, I object to the proposed development on the
SCEGGS Darlinghurst campus, on the following grounds:

1. Loss of views:

The proposed 7-storey building on the southern perimeter of the SCEGGS
site is 2.8 metres taller than the existing height of the current
building. (It is noted that the released height diagrams incorrectly
implied that the height increase was only 1.1 metres taller than the
existing structure, which actually misleads residents and other
interested parties.)

Whilst my own property will not be directly affected, the new
development will lead to a loss of views by residents. This impact has
not been properly assessed prior to the design of the SCEGGS
redevelopment - during the community consultation meeting conducted by
SCEGGS, the potential for local residents to lose our views was not
even raised as a possibility. The loss of an iconic view is not in
accordance with the Land and Environment Court's principles on "view
sharing". Furthermore, the proposed 7-storey building does not comply
with current height restrictions on the site. As such, what SCEGGS is
proposing is to overdevelop the southernmost part of their site, above
current height restrictions, for maximum negative impact on
neighbouring properties, resulting in loss of iconic views (as well as
overshadowing and impacting on privacy).


2. Loss of heritage buildings:

The 1920's building on the corner of Forbes St and St Peter's St is
slated for destruction, to be replaced by a building that has no
engagement with the surrounding streets. The proposed replacement on
this site is essentially an internal-facing structure that creates a
boundary on the corner of Forbes and St Peter's streets. The proposed
structure replaces a human-scale façade that relates to the
streetscape with a monolithic form with no entranceways or
relationship to the street.

Additionally, on the SCEGGS Darlinghurst campus is one of the few
remaining Villas of Darlinghurst, dating back to the early colonial
expansion of the settlement of Sydney. The 1830's villa, Barham, will
be completely cut off from Forbes St by the proposed new building,
refusing any viewing access to the public.


3. Overshadowing and privacy concerns

As proposed, the 7-storey structure planned for the southern perimeter
of the SCEGGS site will result in the terrace houses on the northern
end of Thomson St, Darlinghurst, being completely overshadowed, with
loss of all northern light, and some loss of western light. The
northernmost terrace houses will be rendered permanently in shadow by
the proposed development.

Additionally, the excessive height of the proposed 7-storey building
will impinge on the privacy of residents in the terraces houses at the
northern end of Thomson St. Students and other users of the proposed
building will be able to look into what are currently private
courtyards and terraces.

4. Excessive bulk of the proposed 7-storey southern SCEGGS campus
building

The proposed 7-storey structure is not in keeping with the 19th
century character of Thomson, Forbes and Bourke streets, both in terms
of proposed design, but also in height and other dimensions. The
positioning of this over-sized building on the southern perimeter of
the SCEGGS campus is such that it causes maximum negative impact on
neighbouring properties, in terms of overshadowing, visual impact and
privacy.

As the elevation drawings show, the proposed 7-storey building will
form a giant multi-storey wall that transects the block bounded by
Forbes, St Peters, Bourke and Liverpool streets. As noted above, the
new barrier-like structure will doubly impact on the closest residents
in terms of light, shadow and privacy.

5. Rationale for the proposed SCEGGS development

I have concerns around the lack of rationale for the proposed
development. During the consultation meeting held at SCEGGS in late
2018, no rationale was provided for the size, bulk and height of the
proposed development. The actual intended function of this oversized
building was not clarified. Attendees at the meeting were advised that
it could be used for classrooms, or a swimming pool, or possibly other
uses. Given that the proposed structure does not meet current height
restrictions, and will cause permanent damage to the 19th century
neighbourhood in which sits, the lack of a rationale is deeply
concerning.

Attendees at the meeting asked if SCEGGS was planning to increase the
number of students, given the lack of clarity of purpose communicated
by the school at this meeting. They were advised that this was not the
case, however, I am very concerned that the proposed increase in
floorspace on the SCEGGS campus will be later used as a justification
to exceed the current cap on students.

I do not wish my details to be released to SCEGGS or parties acting on
behalf of SCEGGS.