Waterloo Estate (South) Concept

Re: Waterloo Estate (South) Concept SSDA – SSD-93222706
Proponent: Homes NSW (Land and Housing Corporation) and Stockland

FORMAL SUBMISSION: OBJECTION

I am the owner and permanent resident of 7 Kensington Street, Waterloo NSW 2017 – a 125-year-old Victorian workers' cottage within the Heritage Conservation Area under the Sydney LEP 2012, directly adjacent to the southern boundary of Block 9. I formally object to the Concept SSDA on the following grounds under the Environmental Planning and Assessment Act 1979.

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1. STRUCTURAL INTEGRITY – NO GEOTECHNICAL ASSESSMENT LODGED

Having reviewed the full suite of technical appendices lodged with this application, no dedicated geotechnical assessment exists. The assessment of ground settlement and vibration risk to adjoining heritage masonry from Block 9 basement excavation has been deferred to detailed design with no binding conditions to protect existing residents.

Demand: A precinct-wide Zone of Influence analysis must be conducted prior to determination. Independent Pre-construction Dilapidation Reports for all Kensington Street properties must be a mandatory condition of consent, funded by the developer.

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2. SOLAR ACCESS – INADEQUATE SHADOW DIAGRAMS

Block 9 reaches RL 126.4m (approximately 33 storeys) directly to my north. The EIS shadow diagrams focus on public parks and do not assess overshadowing of the Victorian streetscape to the south. For a property with a westerly rear aspect south of Block 9, maximum overshadowing occurs between 12:00 PM and 2:00 PM on the Winter Solstice, not at 3:00 PM as assessed.

Demand: Winter Solstice shadow diagrams at 10:00 AM, 12:00 PM, 1:00 PM and 2:00 PM must be provided, specifically assessing impact on private open space and habitable rooms on Kensington Street.

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3. WIND MICROCLIMATE

Appendix O lodges an Environmental Wind Report. The Department must confirm this report specifically assesses pedestrian comfort at the Kensington Street southern interface. Towers of 33 storeys at the northern boundary of a low-rise heritage streetscape will generate significant downdraft and channelling at pedestrian level.

Demand: If the wind assessment does not address the southern precinct boundary, a supplementary assessment must be required prior to determination, with adverse findings addressed as mandatory conditions of consent.

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4. PRIVACY AND OVERLOOKING

The EIS does not assess direct sightlines from Block 9 lower floors into rear gardens and habitable rooms of Kensington Street heritage cottages.

Demand: The proponent must demonstrate how building orientation, setback and screening will protect the privacy of adjoining properties. Minimum separation distances and screening must be mandatory conditions of consent.

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5. STATEMENT OF HERITAGE IMPACT – ADEQUACY

The Department must confirm whether Appendix X specifically assesses the impact of Block 9's height, visual bulk, overshadowing and construction vibration on the adjoining Victorian heritage streetscape and Heritage Conservation Area under the Sydney LEP 2012.

Demand: If the Statement of Heritage Impact does not address Kensington Street properties specifically, a supplementary heritage impact assessment must be required before determination.

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6. EDUCATION INFRASTRUCTURE

My daughter attends Alexandria Park Community School. The EIS labels education impacts as "High Positive" without quantifying student yield from 3,300 dwellings – including social and affordable housing tenures, which generate above-average student yields – against the school's actual enrolment capacity.

Demand: An independent school catchment capacity audit must be required demonstrating existing capacity or funded infrastructure upgrades can absorb projected student yield without compromising current students.

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7. CONSTRUCTION IMPACT: HAULAGE, PEDESTRIAN SAFETY AND NOISE

The 10–15 year construction timeline spans my child's entire schooling. Appendix BB lodges only a Preliminary Noise Vibration Impact Assessment. A preliminary assessment is not an adequate basis for a 15-year construction programme adjacent to heritage masonry.

Demands: (a) A Construction Haulage Plan prohibiting heavy vehicles on Kensington and Wellington Streets, with a signalised pedestrian crossing at their intersection installed before works commence. (b) A final Construction Noise and Vibration Management Plan specifying maximum thresholds at the boundary of Kensington Street heritage properties, independent monitoring and a complaints and remediation process must be a mandatory condition of consent.

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8. CUMULATIVE IMPACT AND INTERFACE BUILDING HEIGHTS

No cumulative assessment of the combined construction and operational impacts of the Waterloo Metro Quarter, Waterloo North and Waterloo South redevelopments has been provided. The southern interface heights are inconsistent with Heritage Conservation Area transition requirements under the Sydney LEP 2012.

Demands: A cumulative impact assessment must be required. Building heights on Blocks 9 and 10 must be reduced to a maximum of 6–8 storeys at the southern interface to provide an appropriate scale transition to the adjoining heritage streetscape.

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CONCLUSION

The EIS has not met the assessment standard required under the EP&A Act 1979. Critical geotechnical assessment is entirely absent from the lodged documents. The noise and vibration assessment is preliminary only. These are not minor deficiencies for a 15-year construction programme directly adjacent to irreplaceable heritage properties.

I request that the Department:
- Require Homes NSW and Stockland to address all deficiencies identified above before making a determination;
- Impose the conditions demanded above as mandatory requirements of any Concept Approval; and
- Notify me in writing of the determination and of any right of review or appeal available to me as an affected adjoining owner.

I am prepared to provide further information or attend any public hearing convened by the Department.

I have not yet had a chance to read all thr project documents, but I see no discussion of investigating adding a station to the long straight section of the T8 that runs under George Street at Waterloo South. This massive redevelopment seems like the perfect opportunity to investigate adding a station here, which could support further density. Even were it not added immediately, it would surely be a good time to complete works that would enable its future addition.
I think the social/affordable/market housing split is good, but there should be slightly more housing overall, and the above would help enable that.
I don't think there should be any on-street parking, except accessible parking as required. and parking in general should be severely limited. There should also be better provisions for busses, walking and cycling than there is in the current designs. The designs should also take into account possibility of future light rail. The project should also address the discontinuity in the bike way between Raglan Street and Phillip street, even though this is outside of the boundary, as it would increase demand for bike access to the city in exactly the place where that discontinuity would be most impactful. A solution can and must be found that provides safety and convenience to each residents, people walking, and people riding. That cannot wait until that section is later redeveloped, and should best be done first, before construction begins. It would also be great if existing residents could be provided with safe and secure bicycle parking so that they may more easily make use of it, and be made aware that it may also be used by mobility devices.
Please also incentivise against "luxury" buildings with private ammenities such as swimming pools and gyms, and ensure that instead public facilities are built. I don't know if between the pools at Gunyama Park and Prince Alfred Park there would be need for another, but there should be analysis to that end and some funding provided if found that there is. There should also be zoning to encourage public access gyms and maybe evem privately owned public access pools over strata/hotel private gyms and pools.
There should likely also be a library. I don't know if there would be need for more schools, but that needs to be carefully considered as well, and space allocated if it seems likely it would be needed in future.

During construction, safe through bicycle and pedestrian access must be maintained or a proper safe temporary (or permanent additional) alternative provided, with separation of pedestrians, bicycles, and general traffic essential.

I am a top-floor resident of 266 Pitt Street, Waterloo — immediately west of Waterloo Oval and approximately 98.5 metres south of the proposed 33-storey Building 10A on the Pitt Street/McEvoy Street corner. I formally object to this concept application on four grounds.

1. Confirmed midday shadow loss. The applicant's own shadow diagrams (Appendix E, Urban Design Report) confirm Building 10A will cast a new shadow on my balcony from 12:00 PM to 1:30 PM on 21 June. My balcony already loses afternoon sun at approximately 2:00 PM due to an existing building. Building 10A removes the warmest and most usable 1.5 hours of my winter solar window — a real reduction of approximately 30% of my effective winter access, far exceeding the "modest 1–12%" the EIS claims for southern neighbours.

2. Fragmentation of solar access. The shadow does not merely reduce my sun hours — it fragments them. What is currently a continuous morning block of light (9:00 AM to ~2:00 PM) becomes two broken windows: 9:00 AM–12:00 PM and 1:30 PM–2:00 PM. A 30-minute afternoon remnant has no practical value for balcony use or plant growth. This fragmentation is not captured by the EIS analysis.

3. The applicant's own design principle is breached. The Urban Design Report states a specific principle: buildings on McEvoy Street must "minimise overshadowing of neighbouring properties to the south." Building 10A is the tallest building in the development, positioned at the southern boundary, and its shadow demonstrably falls on my property at midday. The EIS does not explain how this is consistent with that principle.

4. The Visual Impact Assessment is procedurally inadequate. In viewpoints VP7 and VP8 — the primary renders for my area — Building 10A's massing extends beyond the top of the photographic frame. Two-thirds of its vertical mass is not shown. No viewpoint was taken from the south side of McEvoy Street looking at the Pitt Street frontage of Block 10, despite this being the perspective of the most directly affected residents.

I request that the Department: (a) confirm that 266 Pitt Street is specifically modelled in the solar access analysis at hourly intervals on 21 June; (b) require full-height renders from the south side of McEvoy Street; and (c) impose a condition on any concept approval requiring that the Block 10 detailed design provides a continuous minimum of two hours of direct solar access to 266 Pitt Street on 21 June.

Block 10 is Stage 5 of a 10–15 year program. There is ample time to require redesign without affecting Stage 1 housing delivery. A detailed submission with geometric calculations and references to the applicant's documents is attached.

The current submission surrounds 110 Wellington Street - a private block - all with social and affordable housing, lumping us in with this clump, which have all been lumped together. We have had to live with the trash created by the lack of cleaning and care by Homes NSW and Housing for 23 years which has affects our property prices over time and still you seek to surround us with this instead of putting new private residencies with private. I disapprove completely of this layout and feel housing needs to be scattered more not lumped altogether around this private property, effectively choking it. Also the social housing building on the corner of George and Wellington Street, which is now to be a sky scraper, will totally block our garden and kill it with lack of light. Also our pathways will be affected as if they cannot dry in the sun after rain they become slippery and mossy over time, creating more issues for residents. In addition the other social housing tower, albeit not so big, behind 110 Wellington Street and close to it - currently just a car park - will further overshadow the property and create a dark space for those with units at the back.

For the time I have lived here, which is since the property was built, the positives we do have, ie no overshadowing will be taken away, we will still be subjected to the lack of mainteneance and cleaning - which results in garbage continually along West Street and Reeve streets - plus dumping of rubbish and goods on a weekly basis. Now you seek to just subject our home to more of the same and a complete overshadowing and choking of our building of light. This will reduce our property value even more - real estate agents now telling us our property is at the bottom of the pile because of this redevelopment and we have no chance of seeing an increase in value for 15 years or more because of this redevelopment. I do not object to the refreshing of Waterloo but I do object to 110 Wellington Street being surrounded by sky srapers, people who have no respect for their neighbours (we are frequently, our lives and gardens destroyed by lack of light and a feeling of claustrophbia. Also currently with not so many people we at least have some quiet most of the time - unless the brawling and screaming starts - however with an increase of people in the area will feel more targeted. We have had tomotoe sauce thrown over our walls by locals and a brick smashed a stairwell window the other day, plus locals jumping the fence and stealing mail and bikes... plus more. The list goes on. So instead of improvement for us, it will be worse. So please consider 110 and make some of those buildings private and put some social housing in another part of the development so it is more equally spread out. Why should we have to suffer so the developer makes more money by having the private buildings for sale NOT surrounded by social housing?

Last there is a beautfiul gum tree on housind property that is by 110 Wellington Street - it is the most magnificent tree but I see you have it marked to be murdered. Please do not do this. Let this tree live.

Thank you and please consider this.

Overall, I support the redevelopment of the Waterloo Estate. However, it is difficult to understand why the tallest buildings and highest-density areas are proposed furthest from the metro station. I believe the plan should be significantly reconsidered to better leverage the world-class public transport network, ensuring residents can access it easily and without unnecessary barriers.
Also, do we really need another massive park in the heart of this development (in its best place for a higher density / commercial / multi-use zone), given there are already a number of parks in this part of the city just behind a corner?

To: NSW Department of Planning, Housing and Infrastructure
Re: Waterloo South Concept SSDA — Application No. SSD-93222706
Development Waterloo South Precinct — Blocks 2 and 3, Waterloo NSW 2017
Proponent: Land and Housing Corporation (LAHC)
Adam Sharp— Individual Lot Owner
LOT 29 Unit 1 of 123 Cooper Street,
Waterloo NSW 2017
[email protected]
0412288721
Strata Scheme: SP79210 — 233-237 Cope Street & 123 Cooper Street, Waterloo NSW
2017
Date: 28/5/2026

. My Standing to Object
I am the owner of Lot 29 within SP79210 at 233–237 Cope Street & 123
Cooper Street, Waterloo NSW 2017. I am a directly affected party under the Environmental
Page 6Planning and Assessment Act 1979 (EP&A Act). My property is immediately adjacent to and sharing
boundary fences with Blocks 2 and 3 of the proposed development.
I have a direct and ongoing interest in the outcome of this application. The development, if approved
in its current form, will permanently alter the built form environment immediately adjoining or directly
facing my home.

2. I Object to This Application
I formally object to the Waterloo South Concept State Significant Development Application SSD-
93222706, and in particular to the approved building envelope for Blocks 2 and 3 (SJB Architects
drawings BL02&3-AR-2300 to BL02&3-AR-2303, Rev A, 30 March 2026).
My objection is made on the following grounds:
-Direct overshadowing of private open spaces and living areas from a 22-storey tower on Lot
2D (RL +73.06m) positioned metres from the northern boundary of 233 Cope Street
-Loss of privacy: elevated towers at RL +73.06m (Lot 2D), RL +51.86m (Lot 3B) and RL
+69.76m (Lot 3B) will provide direct overlooking into private bedrooms, living rooms and
courtyards
-Void walls up to 8 storeys high proposed immediately adjacent to Units 3–10 of 237 Cope
Street, with no windows, greenery or design articulation
-Construction impacts over a projected multi-year programme including noise, vibration, dust,
loss of access and disruption to residential amenity during LAHC construction works
-A 22-storey tower positioned within metres of the northern boundary wall of 233 Cope Street
will create a permanent sense of enclosure inconsistent with any reasonable residential
amenity standard
-No notification was received by the Owners Corporation as a legal entity, nor by non-resident
lot owners whose postal address differs from the Cope Street property.

3. How it affects my home
I strongly object to this development due to the serious and irreversible impacts it would have on the liveability, residential amenity and wellbeing of my home. I have lived at this address for 2 years and specifically purchased this property because of its access to natural daylight, sunlight, openness and sense of space. These qualities were fundamental to my decision to buy and invest in this home.
My balcony and loft bedroom currently overlook an existing 3-storey development, which provides an appropriate and human-scale separation between buildings and allows consistent natural light, airflow and visual openness throughout the day. The current built form supports a comfortable and healthy living environment and provides an acceptable balance between density and residential amenity.
The proposed development would permanently and dramatically alter these conditions. The height, scale and proximity of the proposed towers would create an overwhelming sense of enclosure and visual domination directly opposite my home. Instead of an open outlook and access to daylight, my home would face a substantially taller and bulkier building at extremely close range. This would result in significant overshadowing, reduced daylight penetration, loss of sky view, reduced airflow and an unacceptable loss of privacy into my bedroom, living areas and balcony.
The loss of natural daylight is a major concern for me, both practically and psychologically. Access to sunlight and daylight is critical to basic residential liveability, mental health and overall wellbeing. My loft bedroom and balcony are highly dependent on direct and indirect natural light, and the proposed development would materially reduce the comfort, usability and enjoyment of these spaces. Reduced daylight would make the apartment feel darker, more enclosed and less liveable on a daily basis. This is not a minor inconvenience — it represents a substantial degradation of the quality of my home and living conditions.
The proposal would also expose residents to years of unreasonable construction impacts including constant noise, vibration, dust, heavy vehicle movements and ongoing disruption associated with a large-scale State Significant Development immediately adjoining existing homes. Residents would effectively be forced to endure a prolonged construction zone while simultaneously facing the permanent loss of privacy, outlook and amenity once construction is complete.
I am particularly concerned that the proposed building envelope fails to provide adequate setbacks or a reasonable transition in scale between the new towers and the existing low and medium-density residential buildings surrounding the site. The proposal prioritises excessive density and building yield at the expense of existing residents’ access to sunlight, privacy, outlook and liveability. In my view, the impacts on neighbouring residents are unreasonable and disproportionate.
This development would fundamentally and permanently change the character, comfort and liveability of the home I deliberately chose to purchase because of its light-filled environment and open outlook. The loss of these qualities cannot be adequately mitigated through conditions of consent after approval. Once sunlight, openness and privacy are lost, they are lost permanently.


4. What I Am Asking For
I ask the Department of Planning, Housing and Infrastructure and, if appointed, the Independent
Planning Commission to:
-Refuse the application in its current form, or require fundamental redesign of the building
envelope to address the amenity impacts on privately owned residential properties in the
immediately surrounding streets
-Require the proponent to commission an independent peer review of the Visual Impact
Assessment, Solar Access Analysis, and Construction Impact Management Plan with specific
regard to the impacts on my property and others in the scheme
-Ensure that any approval imposes mandatory minimum setbacks, height reductions, and
design requirements sufficient to protect the solar access, privacy, and visual amenity of
existing residents
-Appoint the Independent Planning Commission as consent authority, given the number of
objections received and the contentious nature of this proposal

5. Relationship to Owners Corporation Submission
The Owners Corporation of SP79210 has lodged (or is lodging) a separate, detailed planning
objection as the legal entity representing all lot owners within the scheme. I adopt the grounds set
out in that submission to the extent they are relevant to my individual lot, and I lodge this
submission independently to ensure my individual standing and my personal experience of the
proposed impacts are separately recorded.
This is a standalone individual objection. It is not a substitute for the Owners Corporation
submission and does not reduce the number of independent objections on the record.

Declaration
I lodge this submission as an individual lot owner with a direct interest in the outcome of this
application. The concerns expressed are genuine and relate to the amenity, privacy and character
of my own home.
Name Adam
Lot 29 SP79210
Signature
Adam Sharp
Date 28/5/2026

Although I do not live at this address, I have a genuine interest as it is my investment property I have owned since built (2007). My concern is for ongoing tenancy, the impact this will have on my tenants’ daily lives in terms of noise disruption, air quality, and how this may impact potential tenants (or lack of due to diminished conditions) moving forward. Waterloo is a lovely, tree lined suburb, it would be an absolute tragedy to see it taken over by high rise buildings taking over the green space.

I object to this project because the proposed buildings are too tall for the surrounding area. It will overshadow my property limiting my access to sunshine and light as well as fresh air. I am also concerned about noise with buildings that tall and housing that many people. In addition, my property is only a few stories and in keeping with the current buildings, with the height of the proposed buildings there will overlook ability to every room in my property. The current buildings and my property have a good amount of space between them. The proposed buildings are all very close to my property, including the south wall of my building (the old factory). Please do not build buildings too tall for the area and so close together. Some of the items I have outlined above are why I object to the current proposal.

We object to the Waterloo Estate (South) Concept State Significant Development Application in its current form due to the significant and inadequately justified impacts on surrounding residents, local amenity, privacy, traffic conditions, biodiversity, heritage setting and urban character. A detailed submission is attached and summarised below:
1. Excessive Height and Incompatible Built Form
The proposed tower forms are excessive relative to the surrounding context, which includes lower-scale residential buildings, heritage terraces and light industrial uses. The abrupt transition in scale is unreasonable and inconsistent with appropriate urban design principles.
2. Loss of Privacy, Overlooking and Residential Amenity,
It is clear that the proposed tower configuration would result in substantial and direct overlooking into adjoining residential properties, including along Elizabeth Street opposite Waterloo Park and Oval.
3. Limitations of Earlier Consultation and Community Awareness
There are serious concerns regarding whether the practical impacts of the proposal were adequately communicated to the local community, including those in surrounding areas and understood during the earlier strategic planning and consultation process.
4. Inconsistent Transit - Oriented Development Logic
The proposal repeatedly relies on proximity to Waterloo Metro Station as justification for increased density and building height. However, the tallest towers will not be located immediately next to the metro station itself, in contradiction of this principle.
5. Overshadowing and Public Domain Impacts
The scale of the proposed towers adjoining public open space is inconsistent with maintaining high-quality public amenity outcomes for existing and future residents
6. Traffic and Cumulative Infrastructure Impacts
McEvoy Street already functions as a heavily trafficked arterial corridor connecting the M5/M8 and broader WestConnex network with the eastern suburbs and inner Sydney. The Transport Impact Assessment accompanying the proposal confirms that discussions regarding access arrangements and traffic outcomes remain unresolved and subject to further assessment.
This is particularly concerning given Transport for NSW’s earlier Alexandria to Moore Park Connectivity Project, which identified the need for major upgrades along the McEvoy Street corridor to accommodate increasing traffic associated with urban renewal and motorway-related traffic growth. Those transport investigations occurred prior to the current proposal’s substantial increase in scale to towers of up to 33 storeys.
7. Inadequate Biodiversity Assessment, Flying Fox Impacts and other native Fauna
The proposal area adjoins mature tree canopy and habitat associated with Waterloo Park, including a known flying fox colony located within the Morton Bay Fig trees adjoining the park. Despite the ecological sensitivity of the area, the documentation appears to rely on a Biodiversity Development Assessment Report waiver request rather than a comprehensive biodiversity assessment. This situation is completely unacceptable. A development of this scale adjoining established urban habitat should adopt a precautionary approach to biodiversity protection, particularly where vulnerable species are known to exist within the immediate locality.
8. Community Consultation Concerns
The proposal documentation refers to extensive community consultation. However, neither we nor many other adjoining residents appear to have been meaningfully consulted regarding the practical impacts associated with the substantial increase in building heights and tower placement. Many residents have only now become fully aware of the extent of the impacts through the current Concept SSDA material and community information sessions.
This raises serious concerns regarding the effectiveness and legitimacy of the consultation process undertaken to date.
Conclusion
While urban renewal and additional housing supply are important objectives, the current proposal imposes excessive impacts on surrounding residents and public spaces without sufficient justification or mitigation.
We respectfully request that the Department:
• reconsider the proposed tower placement and building envelopes adjoining Waterloo Park and existing residential properties;
• require demonstrable resolution of privacy and overlooking impacts at the Concept SSDA stage rather than deferring these matters to future design phases;
• reduce tower scale adjacent to existing residential areas and Waterloo Park;
• concentrate greater density closer to Waterloo Metro Station;
• undertake further independent assessment of privacy, overlooking and overshadowing impacts;
• require a comprehensive biodiversity assessment addressing the flying fox colony, native birdlife, ecological corridors and impacts associated with light pollution;
• undertake updated cumulative traffic modelling incorporating the increased development scale and broader WestConnex-related traffic impacts;
• provide greater transparency regarding the ecological impacts of the proposal and how these align with the stated Designing with Country principles; and
• undertake genuine consultation with directly affected residents before determination of the application.
The current proposal does not achieve an appropriate balance between housing delivery, environmental protection, urban design quality, cultural responsibility and community amenity.

To whom it may concern,

I am writing in support of the redevelopment of Waterloo South. I understand there is strong opposition from tenants who will need to relocate during the process, and I appreciate that this can be difficult and emotional. However, as someone who lives around the estate, I believe this redevelopment is necessary and long overdue.

Many local residents support this project because the current estate is no longer serving the community well. The area feels neglected, unsafe, and poorly maintained. Public spaces are often dirty, including human waste being left in common areas, which creates serious hygiene and health concerns.

There are also ongoing safety issues. It is common to encounter people who are heavily intoxicated or affected by substances in and around the estate. Many people using the Waterloo Metro station feel unsafe walking through the area, especially at night. I have personally experienced harassment while simply walking on the sidewalk, including being verbally abused by a stranger.

Waterloo is located next to Sydney CBD and has enormous potential to become a vibrant, safe, and welcoming urban community. The redevelopment is an opportunity to create better public spaces, improved housing, more greenery, recreational facilities, shops, cafes, and spaces for families and dog parents. The current layout is also an inefficient use of valuable inner-city land that could better serve both existing residents and the wider community.

I strongly support investment into modern, mixed-use neighbourhoods that encourage safety, accessibility, and community connection. This redevelopment can help transform Waterloo into a cleaner, safer, and more liveable area for everyone.

Thank you for considering my submission.

I OBJECT to the proposal.OPPOSE & Object to this, Whilst respecting & appreciate work put in by all involved :- ITS WRONG. REFURBISHING of PUBLIC Housing- I.e. The Fixed Assets already existing should be fixed 🆙 and maintained properly by the relevant government departments and agencies : eg , per plans submitted by organisations such as , OFFICE, . In a time of both housing and environmental crisises, it is illogical to demolish homes of vulnerable people in a community. There is available public land , at say , 600 Elizabeth Street, Redfern Nsw 2016 that could have 💯 % PUBLIC <not, social> housing. This was the information provided and PROMISED to OUR COMMUNITY by the current government, their ministers and members. As 🆎ove , also should be the direction that the Federal Government, in their promises and plans, should be taking to overcome homelessness and enhanced greenhouse gases emissions; which the current plan would worsen. ILLPAH , the traditional name of the Unceded Gadigal Lands of the Eora Nation should be used as a true reference for any refurbishment, NOT DEMOLITION, of Waterloo South PUBLIC HOUSING COMMUNITY :- of which I am a proud member of.
A better way to go would be to maintain the public housing for which we are appreciative . In addition , the required Human Resources and Social Services that all levels of government have promised should be provided to assist OUR PEOPLE. We are grateful ☺️ for the support given by fantastic people such as Counterpoint Community Services , et al : if the government provides the necessary support that we need, that would be the BEST & only TRUE option provided. This would also be what was promised. The total cost, time and resources put into this illogical plan would be better in MAINTAINING PUBLIC HOUSING. It makes no sense to kick these people off the public housing system and expose them to the pitfalls that will befall us. If the government truly believes in this proposal:- then start from scratch in a new area to proof it ; YET also provide the many still waiting on PUBLIC HOUSING WAITING LIST FIRST! So in summary, I OBJECT and am opposed to the Waterloo Estate (South) Concept . If money 💰 is necessary for the REFURBISHMENT,.. NOT DEMOLITION of OUR COMMUNITY; we should abandon the toxic, dangerous NUCLEAR ☢️ Submarines; And spend the $368 Billion on what has been flawed concept that won’t benefit the State and Nation. I would appreciate a response to the PO BOX provided. Thank you 🤩 for taking the time to read and reply. Also genuinely appreciate the effort provided by ALL- just wished you would ASK and LISTEN to what OUR COMMUNITY NEEDS! Regards and best wishes to ALL.

I am a resident of 222 Botany rd Alexandria 2015.
I object to the 33 story tower that will cause all of the apartments in 222 botany road to be in shade until 11.30am or so.
The only sunlight that comes into the units is at that time. The sun then moves towards the west so then all balconies are in shade .

I very much object to the loss of sunlight which is the only sun that gets to the units. I request the 33 stories to be made less than 7 stories or move somewhere that else. Residents need sunlight and these towers will reduce and put all the units into permanent shade. The best thing about the units is the daylight that comes into the balcony in 222 botany rd.

I wish to lodge an objection to the Waterloo South Concept Development Application.

While I acknowledge the need for additional housing and urban renewal within Sydney, I have significant concerns regarding the scale, height and positioning of the proposed development and its impacts on the surrounding established residential community.

The proposed tower forms are excessive in scale and are not appropriately integrated with the existing urban context. The development represents a substantial departure from the character and built form of surrounding neighbourhoods and creates an overdevelopment outcome that prioritises density at the expense of residential amenity.

Of particular concern is the relocation and concentration of several high-rise towers closer to existing residential properties than originally envisaged. This will result in significant adverse impacts on neighbouring residents, including:

Loss of Solar Access:
The height and bulk of the proposed towers will increase overshadowing of nearby homes, apartments, communal open spaces and public areas. Access to natural sunlight is fundamental to residential amenity, health and wellbeing. The proposal risks reducing solar access for existing residents, particularly during winter months when sunlight is most valued.

Loss of Views and Visual Amenity:
The scale and positioning of the towers will obstruct existing views currently enjoyed by surrounding residents. Many neighbouring properties will experience a significant loss of outlook and visual connection to the wider urban landscape. The resulting sense of enclosure created by the tower walls will diminish the quality of life for existing communities.

Excessive Bulk and Density:
The proposal appears to maximise development yield without sufficient regard for its impacts on neighbouring properties. The cumulative height, density and massing of the towers create an imposing built form that is disproportionate to the surrounding area and inconsistent with good urban design principles.

I respectfully request that the NSW Government and assessment authorities require substantial revisions to the proposal, including:
Reductions in tower 33 storey heights and overall density.
Increased setbacks from existing residential developments.
Reconfiguration of tower locations to minimise overshadowing and view loss.
Stronger protection of solar access and residential amenity for surrounding communities.
A more balanced built-form outcome that better reflects the character and scale of the area.

The Waterloo South renewal presents an important opportunity to deliver new housing while creating a high-quality, liveable neighbourhood. However, this objective should not come at the expense of existing residents through excessive building heights, overshadowing and loss of views.

I urge the consent authority to reject the proposal in its current form and require significant amendments before any approval is considered.

INDIVIDUAL PLANNING OBJECTION

Waterloo South Concept SSDA – SSD-93222706



To: NSW Department of Planning, Housing and Infrastructure

Application: SSD-93222706 – Waterloo South Concept SSDA

Proponent: NSW Land and Housing Corporation (LAHC) / Stockland



I am the owner/occupier of 2/123 Cooper Street, Waterloo NSW 2017 (PT 30, SP79210).



My apartment is accessed via the common entry at 123 Cooper Street and includes a private open-air courtyard confirmed under the registered strata plan, with a stratum limited to 2.5 metres above the paved terrace surface.



As a directly affected resident and property owner, I have standing to object under the Environmental Planning and Assessment Act. This submission is my individual objection and is lodged in addition to the combined submission made by the Owners Corporation of SP79210.



A. Loss of Solar Access and Daylight



My apartment receives its primary natural daylight through my private open-air courtyard.



The proposed development would effectively enclose 123 Cooper Street on both sides of Cooper Street through:



Lot 2D (9 storeys, RL +51.86m) to the south-west; and

Lots 3A (22 storeys, RL +91.50m) and 3B (15 storeys, RL +69.76m) directly opposite on the eastern side.



These building envelopes will substantially reduce the visible sky angle from my courtyard and are likely to eliminate direct solar penetration for significant periods.



No solar access analysis has been undertaken for privately owned properties at 123 Cooper Street despite the clear potential impacts on residential amenity.



B. Mould and Building Health Risks



My courtyard is completely open to the sky and has no overhead cover.



Reduced access to direct sunlight in enclosed courtyard environments can increase moisture retention, condensation and the risk of mould growth in adjoining internal rooms. I am concerned that the combination of reduced daylight, reduced drying capacity and rainfall exposure will create conditions conducive to mould and dampness within my home.



These foreseeable building health impacts do not appear to have been assessed in the Environmental Impact Statement.



C. Privacy and Overlooking



The proposed tower envelopes will introduce direct overlooking from elevated residential floors into my private courtyard.



This courtyard is an open-air living space that I currently use with a reasonable expectation of privacy. No privacy assessment or overlooking analysis appears to have been undertaken for the private courtyards of 123 Cooper Street.



D. Car Park Traffic and Pedestrian Safety



The proposed Block 2 vehicle entry on Cooper Street will introduce additional vehicle movements across the narrow footpath used to access my home.



Given the limited separation between the building boundary and the roadway, this proposal raises pedestrian safety concerns that have not been adequately assessed.



E. Construction Impacts



The projected 10–15 year construction program will expose my home to prolonged dust, noise and vibration from demolition and construction activities associated with Blocks 2 and 3 immediately adjacent to my property.



Because my courtyard is open to the sky, my apartment is particularly vulnerable to dust penetration and associated amenity impacts.



No detailed Construction Environmental Management Plan addressing impacts on privately owned residences at 123 Cooper Street has been provided.





I respectfully request that the Department:



Require supplementary solar access and daylight modelling specifically assessing impacts on the internal apartment courtyards of 123 Cooper Street, including consideration of mould and building health risks.

Require a detailed privacy and overlooking assessment for the open-air private courtyard spaces at 123 Cooper Street.

Require demonstration of Apartment Design Guide (ADG) separation compliance for Lot 3B (15 storeys, 1.5m setback) opposite the habitable rooms of 123 Cooper Street.

Require a Construction Environmental Management Plan addressing dust, noise and vibration impacts on privately owned properties along Cooper Street before any demolition, excavation or major construction works commence.

Refer the application to the Independent Planning Commission for determination, having regard to the number of objections and the contentious nature of the proposal.

Declaration



I lodge this submission as an individual objection from an owner/occupier of a residence directly affected by the proposed development.



I also support the separate submission lodged by the Owners Corporation of SP79210.

Submission Details
To NSW Department of Planning, Housing and Infrastructure
Application SSD-93222706 — Waterloo South Concept SSDA
Proponent NSW Land and Housing Corporation (LAHC) / Stockland
My address 19 John Street Waterloo NSW 2017

My name Tony Milne
My email [email protected]

My phone 0419279644
Date 31/5/2026
1. My Standing to Object
I am the occupier of 19 John Street, Waterloo NSW 2017. My property is directly opposite the proposed Waterloo South development site on the western side of Cope Street. I am a directly affected party under the EP&A Act. This is my individual objection, lodged in addition to the combined Owners Corporation of Strata Plan SP79210 submission.
2. My Property and Its Relationship to the Proposed Development
YOUR PROPERTY — John ST Waterloo

19 John St Street is a two one storey terrace. We face east toward the proposed development site. The proposed Lot 2D (Cope Street face, 9 storeys, RL +51.86m) will block morning eastern solar access. The proposed Lot 3B (John Street face, RL +69.76m, 15 storeys) will block southern sky access. No solar access or shadow analysis has been conducted for XX Cope Street or any of the street-fronting residences.

3. Grounds of Objection
I object to SSD-93222706 on the following grounds:
• Loss of solar access: The proposed Lot 2D (9 storeys, RL +51.86m, 3m setback from Cope Street) is positioned directly opposite my residence. The EIS Urban Design Report confirms Cope Street receives between 0 and 1.75 hours of winter solstice sunlight under the proposed envelopes. No solar access analysis has been conducted for privately owned properties on the western side of Cope Street in breach of SEAR 7.
• Heritage impact: My building contributes to the Waterloo Heritage Conservation Area. The applicant's own heritage consultant has assessed Design Guide Principle 4 as not being met. The proposed envelopes — 9 to 33 storeys on a 4 to 6-storey heritage streetscape — will overwhelm every element of the western Cope Street heritage fabric.
• Visual privacy and overlooking: The proposed towers will look into occupied rooms of my proerty. No privacy or overlooking assessment has been conducted for privately owned properties on Cope Street.
• Removal of two-storey height protection: The applicant is seeking to amend the Design Guide to remove a specific two-storey height protection for properties on the western side of Cope Street (Principle 2(4)) — without providing any comparative assessment of the impact on affected owners. This is a direct breach of SARP Study Requirement Item 3.
• Construction impacts: The 10–15 year programme will expose my property to sustained demolition, excavation, noise, dust and structural risk immediately adjacent. No Construction Environmental Management Plan for Cope Street properties has been provided.
4. How This Development Affects My Home
The overshadowing from the east
The likely huge congestion from the building process and loss of street parking
5. What I Am Asking For
• Require supplementary solar access analysis modelling overshadowing of my property at hourly intervals between 9am and 3pm as required by SEAR 7
• Require a supplementary Visual Impact Assessment with viewpoints from within my property and other privately owned properties on Cope Street
• Require the proponent to provide the comparative analysis of the two-storey height protection removal required by SARP Study Requirement Item 3
• Require a Construction Environmental Management Plan addressing impacts on privately owned properties on Cope Street prior to demolition or excavation
• Appoint the Independent Planning Commission as consent authority
Declaration
I lodge this as an individual objection from a residen directly affected by this application. — this individual submission records my personal amenity impacts.
Name Tony Milne
Address 19 John Street, Waterloo NSW 2017
Lot

Signature

Date 31/5/2026

I support the project in principle but cannot support it in any practical sense when the procedures and protocols to obtain planning consent are not being administered in a fair and equitable manner. There are too many ways in which the private residents of the area are being disadvantaged with no view to our lived environment through a prolonged build, not to mention the financial impact. I would find it an easier project to support in a practical sense if there was genuine consideration being given to those of us who will be most heavily impacted

Submission on Waterloo South Concept Application and Rezoning Proposal
Concern regarding building heights, overshadowing and solar access impacts on 792 Elizabeth Street, Waterloo NSW 2017

To whom it may concern,

I am writing to make a submission on the Waterloo South Concept Application and Rezoning Proposal.

I live at 792 Elizabeth Street, Waterloo NSW 2017, close to the Waterloo South renewal area. I support the renewal of ageing social housing and recognise the need for more social, affordable and market housing in well-located areas. However, I am concerned that the proposed building heights, building envelopes and tower locations may reduce sunlight to my property and affect the amenity of nearby existing residents.

My submission is not an objection to renewal itself. My concern is that the proposal should not be approved unless the Department and the applicant properly assess, disclose and, where necessary, mitigate the impact of the proposed height and massing on surrounding properties, including 792 Elizabeth Street.

1. My property and the nature of my concern
My property at 792 Elizabeth Street currently receives important natural sunlight. This sunlight contributes to the liveability, warmth, natural light, garden use, outdoor amenity and overall enjoyment of my home.
If new buildings or towers are placed in front of my property, depending on their exact location, height and orientation, they may affect sunlight reaching my home, private open space, windows, garden areas and roof area. A material reduction in solar access would be a significant amenity impact for an existing resident.

2. Concern about proposed building heights
The public exhibition material states that the Waterloo South Concept Plan includes buildings ranging from 2 storeys up to 33 storeys. The height diagram also shows several taller buildings, including tower elements, within the precinct.

I understand that the Concept Application is a “big picture” plan and that detailed applications will follow later. However, this makes it even more important that solar access impacts are properly tested now. Once the concept building envelopes and rezoning controls are approved, the distribution of height, bulk and massing may become difficult to revisit.

I am particularly concerned about the taller elements shown in the southern and eastern parts of the plan, including the proposed 22-storey and 33-storey elements and any other tall tower forms. These should be specifically tested for their impact on existing homes outside the Waterloo South estate boundary, including 792 Elizabeth Street.

3. Concern that the exhibited solar access material does not clearly assess my property

The public information material refers to solar performance being assessed for surrounding open spaces and existing residences south of McEvoy Street. However, I have not seen a clear property-specific assessment showing the impact of the proposed building envelopes on 792 Elizabeth Street.

This is a significant gap. The assessment should not only consider future parks, courtyards and new apartments within the development. It should also demonstrate that existing surrounding residents are not unreasonably affected by the proposed height and massing.

I request that the Department require the applicant to confirm whether 792 Elizabeth Street has been specifically modelled in the solar access and overshadowing analysis. If it has not, I request that the assessment be updated before any approval is granted.

4. Request for property-specific shadow diagrams

I request that the applicant be required to prepare and publish property-specific shadow diagrams for 792 Elizabeth Street, Waterloo, showing existing and proposed shadow impacts.

At a minimum, the diagrams should show the impact of the proposed concept envelopes at:

- 21 June, being the winter solstice;
- 21 March / 21 September, being the equinox period; and
- 21 December, being the summer solstice.

The diagrams should show hourly impacts from 9:00am to 3:00pm. Where relevant, the summer analysis should also consider early morning and late afternoon impacts, given the orientation of my property and the way sunlight currently moves across it.
The analysis should clearly show the impact on:
• private open space;
• living room and bedroom windows;
• garden and outdoor areas;
• roof areas that may be used for solar panels;
• existing solar access before the development; and
• proposed solar access after the development.

The assessment should not be limited to general precinct diagrams. It should clearly identify 792 Elizabeth Street and show whether the proposed building envelopes reduce sunlight to my property.

5. Request to compare the 2022 planning controls against the lodged Concept Plan

The exhibition material indicates that the 2022 planning rules formed the starting point for the Concept Plan, and that the rezoning is intended to make the planning rules match the Concept Application.

I request a clear comparison of overshadowing impacts between:

1. the approved 2022 planning controls / design guide envelopes;
2. the lodged Concept Plan envelopes; and
3. any amended proposal prepared after public exhibition.

This comparison is important because even if the total amount of development is not increasing, the location and shape of building height still matters. A redistribution of height can create new or greater impacts on particular neighbouring properties.

6. Request for cumulative and staged impact assessment

The Waterloo South renewal will be delivered in stages. I request that the assessment consider both the impact of individual buildings or stages and the cumulative impact of the full Concept Plan once all stages are delivered.

A single building may appear acceptable on its own, but the cumulative effect of multiple taller buildings may create a material loss of sunlight, outlook and sky view for nearby residents. The concept approval should therefore include a cumulative shadow impact assessment on surrounding private properties.

Future detailed applications should also be required to demonstrate that they do not create unreasonable additional overshadowing beyond the assessed concept envelope.

7. Request for mitigation measures

If the assessment identifies any material reduction in solar access to 792 Elizabeth Street or nearby existing homes, the applicant should be required to amend the proposal before approval. Possible mitigation measures include:

• reducing the height of tower elements that cause overshadowing;
• relocating taller elements further away from affected properties;
• increasing setbacks;
• changing tower orientation;
• reducing upper-level bulk;
• increasing tower separation;
• stepping down heights toward existing residential properties;
• using slimmer tower forms; and
• imposing clear conditions that future detailed applications must protect neighbouring solar access.

These issues should not be deferred entirely to future stages if the concept envelopes themselves create the risk of impact. The protection of neighbouring amenity should be built into the concept approval now.

8. Request for notification of changes

I request to be notified of any changes to the proposal after exhibition, including:

• amended architectural plans;
• amended building envelope plans;
• amended height or floor-space controls;
• revised shadow diagrams;
• the Response to Submissions Report;
• future detailed State Significant Development applications;
• any modification applications; and
• any design changes affecting height, massing, setbacks, solar access, overshadowing or tower location.

As a nearby resident who may be directly affected, I should have a fair opportunity to review and respond to changes before decisions are made.

9. Requested conditions or changes before approval

I request that the Department not approve the Concept Application or associated rezoning unless the following matters are addressed:

1. The applicant confirms whether 792 Elizabeth Street has been specifically assessed in the solar access and overshadowing analysis.

2. Property-specific shadow diagrams are prepared and published for 792 Elizabeth Street.

3. The assessment includes 21 June, 21 March / 21 September and 21 December, with hourly diagrams and clear identification of impacts to my property.

4. The assessment compares the 2022 planning controls against the lodged Concept Plan and any amended proposal.

5. The assessment identifies whether the proposed 22-storey, 33-storey and other taller building forms create additional overshadowing of my property.

6. If material overshadowing is identified, the building envelopes should be amended to reduce the impact.

7. Future detailed applications should be required to demonstrate that they do not create unreasonable additional overshadowing beyond the assessed concept envelope.

8. The applicant should consult directly with affected surrounding residents before finalising any changes to height, tower form or massing.

10. Conclusion

I support the renewal of Waterloo South in principle, particularly the delivery of improved social housing, affordable housing, public spaces and community facilities. However, this must be achieved in a way that protects the amenity of existing surrounding residents.
The proposed building heights of up to 33 storeys, and the distribution of taller buildings within the precinct, create a reasonable concern about overshadowing and loss of solar access. At this stage, the material I have seen does not give me confidence that the specific impact on 792 Elizabeth Street has been clearly assessed or disclosed.
I request that the Department require further property-specific solar access and overshadowing analysis before determining the Concept Application and Rezoning Proposal. I also request that any approval include clear conditions requiring future detailed applications to protect neighbouring residential amenity.

I am writing as a resident and owner-occupier of the apartment complex at 40–46 McEvoy Street / 349 George Street, Waterloo — the complex specifically modelled in Section 9.4.1 of the EIS for solar access impacts. My apartment is on the upper floor with its primary outlook to the north, directly toward Block 9 of the proposed Waterloo South development.

I have reviewed the concept SSDA documentation, including the Environmental Impact Statement (EIS), the revised Design Guide (Appendix KK – Attach B), the Concept Envelope Plans (Appendix JJ), the Visual Impact Assessment (Appendix P), the Arboricultural Impact Assessment (Appendix Q), and the Environmental Wind Report (Appendix O).

I object to the proposal in its current form and request that the tower envelope on Block 9 (Building 9AB1) be amended to reduce its impact on the existing residential complex at 40–46 McEvoy Street / 349 George Street. I support the strategic objectives of the renewal project, including the substantial uplift in housing supply, the 50% social and affordable housing commitment, the delivery of a new public park on Block 8, and the reduction of street-wall heights to a more human scale. T
My objection is not to the precinct's renewal; however, it is to a specific aspect of the built form that imposes a disproportionate, modelled and acknowledged amenity loss on my complex, in circumstances where the EIS has not adequately tested alternatives.

1. The proposal results in the worst solar access outcome of any modelled neighbouring building, at my complex:
Section 9.4.1 of the EIS models solar access to three existing residential buildings on McEvoy Street. The results are:
52–54 McEvoy Street: 60.61% of dwellings receiving 2+ hours of direct winter sun
40–46 McEvoy Street: 40.95%
34–38 McEvoy Street: 57.65%
My complex records the lowest result of the three by a margin of approximately 17–20 percentage points, well below the ADG target of 70%. The EIS also acknowledges that the proportion of dwellings receiving zero hours of direct sun increases at 40–46 McEvoy Street — the only building where this happens.
The proponent argues this is acceptable because the change falls within the ADG's allowable 20% reduction (Objective 3B-2). This argument is technically correct but substantively inadequate. The ADG allowance is intended for buildings that already perform adequately; applying it to a building that already falls well short of the 70% target compounds a pre-existing amenity deficit rather than mitigating it. The revised Design Guide's own objective at Section 8.2(c) requires the proposal to "ensure heights and distribution of buildings on McEvoy Street minimise overshadowing of neighbouring properties to the south." A 40.95% outcome at the closest affected building, with an associated increase in dwellings receiving zero direct sun, is not consistent with that objective. The current EIS is the first quantified solar assessment specific to my building, and it shows non-compliance with the Design Guide's own overshadowing objective.
2. The Visual Impact Assessment identifies my building's viewer category as sensitive, identifies my building's frontage as the worst affected, and then assesses neither:
The VIA (Appendix P) contains a methodological gap that is internal to the document itself.
Section 3.9 (Private view place sensitivity) expressly identifies, as a sensitive private viewer category:
"Dwellings with north facing views on mid and upper levels in RFBs along McEvoy Street and other tall RFBs further south over intervening built form and vegetation."
This description applies directly to my apartment.
Section 5.6 (Streetscape effects) then identifies McEvoy Street as a frontage where impacts will be more pronounced than elsewhere:
"Near the project boundary, visual changes will be more pronounced where new, taller building forms interface with low rise development on local streets creating a recognisable contrast between new and existing development such as along Gibson Street and McEvoy Street where existing low-rise development will be located in proximity to new high-rise tower forms."
Despite identifying both the sensitive viewer category and the affected frontage, the VIA assesses none of the private viewers in that category. All twelve photomontage viewpoints (VP1–VP12) are public domain locations — parks, street intersections, transport corridors. The closest assessed viewpoint to my building, VP7 at the Botany Road/McEvoy Street intersection, sits approximately 80–100m to the west and looks east toward the development from a public street. There is no assessed viewpoint from McEvoy Street looking north — that is, no viewpoint representing what affected residents like me actually see from inside our homes.
The VIA's overall conclusion that visual impacts are predominantly "nil to low" is therefore based on a viewpoint sample that excludes, by selection, the sensitive viewer category it acknowledges. The assessment does not satisfy the SEARs requirement to consider visual impacts from sensitive private viewpoints, and it cannot reasonably be relied on to conclude that visual impacts on existing residents to the south have been adequately tested.
I request that the Department require the VIA to be supplemented with verified photomontages from at least one private viewpoint within each of the three buildings already modelled for solar access (34–38, 40–46 and 52–54 McEvoy Street), at mid-level (representative of the affected dwellings), assessed against the same view-sharing principles applied to public viewpoints and to the principles in Tenacity Consulting v Warringah Council [2004] NSWLEC 140.
3. The Design Guide carve-out for tall towers on the McEvoy Street frontage warrants closer scrutiny:
Section 8.5.3, paragraph (1) of the revised Design Guide states that buildings fronting McEvoy Street between Cope–George, George–Mead and Mead–Pitt "do not include tall buildings," but immediately adds: "This provision does not relate to tall towers."
This carve-out is the mechanism by which a 33-storey tower is permitted on a frontage where the Design Guide otherwise constrains height. The carve-out is not justified in the assessment material I have reviewed. I request that:
The carve-out be removed; or
It be qualified such that tall towers on the McEvoy Street frontage cannot be sited within a defined buffer distance of existing residential buildings to the south; and/or
Tower envelopes on Block 9 step down toward the McEvoy Street frontage, with the tallest mass set deeper into the block (toward John Street) rather than at the George/McEvoy corner.
4. The wind mitigation strategy depends on tree retention that the AIA does not guarantee:
The Environmental Wind Report (Appendix O) confirms that pedestrian comfort along several frontages relies on mature tree canopy and proposed landscaping for mitigation. The wind tunnel testing was conducted without landscaping in place. The Arboricultural Impact Assessment (Appendix Q), however, proposes the removal of 236 trees across the precinct, including 76 high-retention-value trees. The resulting retention rate for high-retention-value trees is 50.97%, only marginally above the 50% minimum required by the 2022 Design Guide. The revised Design Guide specifically calls out McEvoy Street fig trees as priority retention.
The wind report and the arboricultural assessment have not been reconciled. Replacement planting will take 15–25 years to deliver canopy equivalent to existing mature figs, during which time the assumed wind mitigation will not exist. I request that:
Wind comfort along the McEvoy Street frontage be re-assessed using realistic tree maturity assumptions rather than assumed full canopy from day one; and
The Tree Impact Plan for the McEvoy Street frontage between George and Mead Streets be made publicly available, and that the existing McEvoy Street fig canopy in this section be flagged as priority retention with binding effect at detailed SSDA stage.
5. The concept stage approves envelopes, not buildings:
I am aware that detailed building design occurs at subsequent SSDA stages. However, the maximum building envelope, height, tower zone and frontage location are being fixed at this concept stage. The detailed SSDA cannot remedy an envelope that allows a 33-storey tower close to the McEvoy frontage if the concept consent permits it. The mitigation measures I am requesting (tower step-down, frontage buffer, view-sharing assessment, tree retention as a binding requirement) must be embedded in the concept consent and the revised Design Guide to be effective.

Summary of requested amendments
1. Reduce the tower envelope on Block 9 (Building 9AB1) on the McEvoy Street frontage so that the tallest mass is located in the northern half of Block 9, with a stepped reduction in height toward McEvoy Street.
2. Remove or qualify the Section 8.5.3 carve-out permitting tall towers on the McEvoy Street frontage opposite existing residential buildings.
3. Require the VIA to be supplemented with verified private-viewpoint photomontages from 34–38, 40–46 and 52–54 McEvoy Street, addressing the gap between the VIA's own identified sensitive viewer category (Section 3.9) and its actual viewpoint sample.
4. Reconcile the wind report and the arboricultural assessment, lift the high-value tree retention rate above the 50% bare minimum, and make the McEvoy Street fig canopy retention a binding control rather than a "where possible" preference.
5. Require any future detailed SSDA for Block 9 to demonstrate compliance with the Design Guide objective to minimise overshadowing of neighbouring properties to the south, with reference to the modelled performance of 40–46 McEvoy Street.
Thank you for your consideration.

1. Demolition Before New Homes Are Built
Demolition of existing public housing in Waterloo is already happening — before this concept application has been determined and before the replacement housing is built. More than 130 homes in Cope Street and George Street began to be demolished in May 2026. 150 households received eviction notices in February 2026. A further 100 households received notices in April 2026. Residents are being removed from their homes, their streets and their community before there is anywhere in Waterloo for them to return to. This is the wrong order. People should not be displaced until their replacement homes are ready and their right to return is legally guaranteed.
2. Loss of Community, Neighbours and Belonging
Waterloo is not just buildings. It is people who have lived alongside each other for years — in some cases for decades. Neighbours look out for each other. They know each other’s names, check on each other, help each other. For many residents in public housing — particularly older residents, people living with disability, people who have experienced trauma, and people who are socially isolated — those community connections are not optional. They are what keeps people safe and well. When residents are moved out at different times to different temporary locations, those bonds are broken. They do not come back automatically when people return — if they return. This application has not provided an independent social impact assessment addressing the impact of that loss.
3. Mental Health and Psychological Harm
Forced relocation is one of the most stressful life events a person can experience. The evidence is clear: displacement from established communities causes measurable harm to mental health, including increased rates of anxiety, depression, grief and loss. For people with existing mental health conditions, trauma histories or complex support needs — of whom there are many in Waterloo’s public housing community — displacement carries a serious risk of acute deterioration. Cutting people off from their community, their support workers, their familiar environment and their neighbours is not a neutral act. No independent mental health impact assessment has been provided for the current residents of Waterloo South.
4. Many residents live in Waterloo because of its low-rise scale, its street trees, its parks, its sense of a neighbourhood where people know each other. The proposed development will replace low-rise public housing with towers of up to 33 storeys. For people with mobility challenges, anxiety, conditions exacerbated by high-rise living, or simply a life built around ground-level access and outdoor community space, tower living is not equivalent to what is being taken. The green spaces, tree canopy and parks that provide cooling, amenity and mental health benefits to Waterloo residents have not been adequately replaced in the proposed design. No independent assessment of whether high-rise tower living is appropriate for the social housing residents who will occupy these buildings has been provided.

I have lived at 121 Cooper Street for several years, and I deeply value the morning light and the beautiful view of the mature tree canopy from my front windows. Because my front door opens directly onto the narrow Cooper Street footpath, the proposed carpark entrance right next to my entryway poses a very real, daily safety hazard for me when leaving my home. Losing the open sky to massive 9-to-22-storey towers, combined with a decade of relentless construction dust and noise, will completely destroy the peace, safety, and livability of my ground-floor home.