Attention: Jude Urbanik, DPHI Senior Planner

I am a significant commercial property owner of Lot 1 in St Leonards Square
I have reviewed material related to this proposal and believe the DPHI should REJECT it entirely. I summarise my reasons for this below:
Current planning controls as previously approved by Lane Cove Council and DPHI permit a 30 level build to rent tower with an RL of 175m and an FSR of 15:1 to be built on this site. A building of this scale constructed on such a constrained site located with little separation from neighbouring large residential towers surely represents its maximum development potential. It will already be overly dominant to properties to its south and west. To increase the maximum height of this structure by 22m, or 6-7 equivalent levels, represents gross over development and cannot be supported given the context of this site.

It is easy to see that a structure of any height on this site will have significant view, light and privacy impacts on residents in St Leonards Square (separated by merely 23m) and the other large residential towers which are situated in close proximity around the site. These impacts will have been considered by planners in previous decisions to limit height to RL175m. Any increase above that height will level by level have devastating further impacts on resident apartments above RL175m, and even below that level as canyons between buildings become deeper and darker. Specifically, the proposed new height approximates the height of the highest residential floor in St Leonards Square (level 35). Total blockage of this building’s SW facade by the proposed taller building represents a planning outcome that is impossible to justify as fair and equitable for that community.

I recognise that additional well located housing supply is required in Sydney and that the St Leonards/Crows Nest area has been designated for considerably higher density than it supports today. However urban planning principles which promote supply growth must also be acceptable to the community, and endeavour to avoid or place limits on direct harm to existing residents. This proposal by increasing height above that which has previously been seen as the limit directly and catastrophically harms so many neighbouring properties that it must be rejected as not being in the public interest. There are an abundance of development sites in this area where such a level of deliberate damage is not required to provide needed additional housing.

I trust you will look on my submission favorably.
Regards,
Christopher Danks

Please see attached submission rejecting the application with major attention required to solar impacts.

Please see attached objection on behalf of Lane Cove Council.

Sincere regards

Chris Shortt

I'm writing with respect to Appendix R Traffic Impact Assessment. I have concerns over section 7 traffic and transport impact, as it is considered collecting outdated data when assessing potential impact in the future.

Under section 7.2 existing intersection performance, the report mentioned "Intersection surveys were conducted... on 6 April 2022" at a number of intersections, and section 7.4 traffic distribution mentioned "The residential traffic distribution was based on Journey to Work Data rom the 2016 Census".

Firstly, using intersection surveys dated 2022 is entirely outdated, given since 2022 to 2025 (this year), there are a number of newly known development in the area, namely:
- (under construction) 24 Berry Road: Waterstone is a residential sanctuary featuring 207 apartments across five buildings
- (under construction) 27-47 Berry Road: Park Avenue is a development of 306 apartments across four mid-rise buildings
- (under construction) 2 Canberra Avenue: Prologue is an apartment complex
- (under consturction) 8 Marshall Avenue: Landmark Quarter is a high-rise development complex
- (under construction) 13-19 Canberra Avenue: Audrey is a 12-level apartment building
- (under construction) 21-41 Canberra Avenue: The Newlands is a residential community

All these known development will have traffic impact in the future. Application SSD-81941461 traffic impact assessment failed to take these into consideration by using 2022 intersection surveys. With the above missing traffic, the TIA report already demonstrates Pacific Highway, Berry Road and Reserve Road intersection will have a Level of Service "B" (close to average delay 30) when completed. It is highly likely Level of Service will be "C" or worse in the future, traffic near capacity with accident study required.

Secondly, the TIA only studied 3 intersections, namely at Holdsworth Avenue and Marshall Avenue, at Berry Road and Marshall Avenue, and at Pacific Highway, Berry Road and Reserve Road. Application SSD-81941461 failed to include the intersection at River Road and Duntroon Avenue, which is in proximity of the development area and traffic is likely to be impacted as well.

Thirdly, section 7.4 traffic distribution mentioned "residential traffic distribution was based on Journey to Work Data (f)rom the 2016 Census". Application SSD-81941461 is submitted in 2025, and the latest available Journey to Work Data should be 2021 Census, which the report failed to deploy.

Given this application failed to address aspects outlined above, I am providing this submission to object the project and would like to have a revised traffic impact assessment carried out in this regard.

Thank you.

Traffic and Vehicle Access Concerns – Holdsworth Avenue

We object to the proposed vehicular access arrangements associated with this development.

Including this proposal, there will be 8 to 10 buildings with a total of six separate car park entries along Holdsworth Avenue. This level of concentrated vehicular access will materially worsen traffic congestion, create vehicle stacking, and increase safety risks for pedestrians, cyclists, and local residents.

Holdsworth Avenue is a local residential street and is not designed to accommodate multiple high-density development access points. The cumulative traffic impact has not been adequately addressed, particularly during peak hours, drop-off / pick-up periods, and service vehicle movements.

Berry Road is a more appropriate and higher-capacity frontage to accommodate vehicular access for a development of this scale. Relocating the primary car park entry to Berry Road would significantly reduce conflict points, improve traffic flow, and mitigate safety and amenity impacts on Holdsworth Avenue.

We therefore request that the Department require the applicant to relocate the car park access to Berry Road, or substantially redesign the access strategy to address the cumulative traffic and safety impacts on Holdsworth Avenue before any approval is considered.