I am writing as a local resident to lodge a strong objection to the proposed development at 100 Edinburgh Road, Castlecrag.
The proposal represents a clear case of overdevelopment. It is fundamentally inconsistent with the established planning framework, the character of the locality, and the reasonable expectations created by the previously council-approved scheme for the site. That approved scheme demonstrated that an appropriate, well-resolved development is achievable. This current proposal departs significantly from that benchmark and does so to the detriment of the surrounding area.
The scale of the development is excessive. In terms of height, bulk, and overall massing, it materially exceeds the prevailing built form and fails to respond to its context. Castlecrag is characterised by low-density housing, a strong landscape setting, and carefully integrated architecture. The proposal disregards these defining qualities and would present as visually dominant, intrusive, and out of character. This is contrary to the fundamental planning principle that new development must respect and respond to its surroundings.
The proposal is inconsistent with key planning objectives, including:

Ensuring built form is compatible with its context
Minimising visual bulk and protecting the landscape setting
Avoiding unreasonable impacts on neighbouring properties
Maintaining or acknowledging the established historical character of the suburb
On any objective assessment, the proposal fails to meet these requirements.
Traffic and access impacts are a critical concern and have not been adequately resolved. The local road network, including Edinburgh Road, is already operating under pressure during peak periods. The scale of this development would generate a substantial increase in vehicle movements that the existing road hierarchy is not designed to accommodate. There is no credible evidence that the surrounding infrastructure can absorb this increase without unacceptable impacts.
The proposal will:
Intensify congestion on constrained local roads
Increase conflict between vehicles, pedestrians, and cyclists, creating safety risks
Place additional pressure on already limited on-street parking
Public transport in the area is limited and does not provide a realistic alternative capable of offsetting this increase in traffic demand. As such, the proposal is car-dependent and incompatible with the capacity of the existing transport network.
The development also fails to deliver any meaningful public benefit that might justify its impacts. In particular, it does not provide genuine housing affordability outcomes or a diversity of housing that responds to identified local needs. Increased density alone is not a planning merit—especially when it is achieved at the expense of character, amenity, and infrastructure capacity.
There are also serious concerns regarding the adequacy and integrity of the community consultation process. The applicant’s engagement appears to have been largely procedural rather than substantive. Feedback from the community has not resulted in any meaningful design changes, with the proposal instead increasing in intensity. This calls into question the weight that should be given to any claims of community consultation.
In summary, the proposal:
Constitutes overdevelopment of the site
Is incompatible with the established character of Castlecrag
Results in unacceptable traffic and safety impacts
Places unreasonable pressure on local infrastructure
Fails to deliver commensurate public or community benefit
Does not adequately respond to community feedback
For these reasons, the application should be refused. At a minimum, it would require a fundamental redesign to reduce its scale and intensity and to align with the previously approved scheme and the applicable planning controls.
Thank you for considering this submission.
Yours sincerely,
Castlecrag Resident

I object to this development for these reasons:
- The scale height and design is completely out of character with the village atmosphere of Castlecrag and its history.
- Its height and size will dominate and overshadow the remaining shops and houses at and near the Edinburgh Rd entry point
- The traffic it will generate will increase enormously the already serious Edinburgh Rd traffic and parking congestion.
- The previously approved DA for the site avoided these serious problems and had community support.
- A development of that scale and design would be a better balance between the housing objective and Castlecrag's character.

I currently reside in Raeburn Avenue, Castlecrag. This is the closest street located to the new proposed development. The original approved DA was for 3 storeys above Edinburgh Road. My reasons for my oblection to the current proposal is as follows:
1) The current proposal is for 11 - 14 stories. This proposal does not fit into the current landscape of the suburb which was designed by Walter Burleigh Griffin. The proposed design is bulkier and and harmful to the local character and heritage values. The development would cause irreversible harm to the character and heritage of the area. Because of the bulkier building this will cast shadows to many residents surrounding the site. The bulkier building will create a tunnel effect when driving into the suburb as the site is located at the entry into the suburb.
2) Castlecrag is is an unique suburb and the site is next to the Griffin Conservation Area which is internationally renowned.
3) The proposal does not meet the intentions of what Walter Burleigh Griffin envisaged for the suburb.
4)There currently only 1 major road in and out of the suburb. The new proposed development will bring in more significant traffic which will put strain on the road network. Incraesed traffic to the area could restrict access for resident and emergency services.
5)Castlecrag is not situated in the transport-orientated development zone and there are limited bus services which service the suburb. This is especially on weekends and nightime.
6)The goverment has not identified Castlecrag as a housing growth area in state or local strategies.
7)There is no train station close to the suburb.
8) As Castlecrag is more than 800m from Northbridge local centre and hence the site is not subject to the Low & Mid Rise Housing Policy.
9)Should this development be approved it will risk setting a precedent for high-rise developments in low-rise suburban areas.
10) The developer has not addressed the issue of the only 1 lane left turn from Edinburgh Road onto Easten Valley way and visa versa. There is already major congestion during morning and eavining peak hours.
11) I am concern that the development will create a parking issue for residents that live close to the development eg: Raeburn and Rutland Road.
12) The developemnt does not alighn with the Willoughby Council planning frameworks or heritage persevation priorities.
13) The proposal is for circa 155 units with only 10 affordable units. This is targetted as a high-end development and does not address the housing affordability.
Please consider my objects when reviewing the proposed development.
Thank You

Hi there
I’m writing in support of the proposed residential and retail project in Castlecrag.
A healthy suburb needs a mix of housing options. Right now, Castlecrag lacks modern apartments, creating a lack of supply where people can’t easily move as their needs change. Adding well-designed, higher‑density homes in the village helps unlock this for our younger people
It allows older residents to downsize into more manageable homes, while freeing up family houses for the next generation like myself.
Us younger people need to be able to come into great areas and this will help us
Thanks for considering my support.

The applicant's own Transport Impact Assessment shows the Edinburgh Road / Eastern Valley Way intersection is already at Level of Service F — failure — even before a single new vehicle is added, and concedes its own modelling cannot predict the outcome. This application should be refused until the infrastructure exists to support it, or scaled down.

My family has lived in Castlecrag since the 1950s. I know the Edinburgh Road / Eastern Valley Way intersection well. In my youth, a friend and long-time local resident, was struck by a vehicle there while rushing for a school bus and suffered a lasting injury. I understand the danger of using this intersection as a transit hub. I have followed urban transport policy for nearly thirty years and I am strongly pro-development: I would support a building far taller than this one if the transit infrastructure existed. Tram lines connecting the Castlecrag peninsula north–south and westward would change my position entirely: I would withdraw this objection and support much larger developments. What I object to is car-dependent density on a peninsula with a single primary access point whose key intersection is already failing.

The Edinburgh Road / Eastern Valley Way intersection is the gateway to the Castlecrag peninsula and the site's immediate front door. The Transport Impact Assessment (TIA) prepared by ptc. (Parking and Traffic Consultants) shows in Table 16 (TIA p.24) that this intersection already operates at Level of Service (LoS) F in the morning peak, with a degree of saturation (volume-to-capacity ratio) of 1.122. The TIA's own definitions table (Table 15, TIA p.23) states that LoS F means: "Extra capacity required. Extreme delay, major treatment required." This is the existing condition, before any development traffic is added.
With development traffic included, Scenario 3A (TIA Table 21, p.31) records LoS F, an average delay of 136.5 seconds, and a 95th-percentile queue of 455.3 metres. Extending to a ten-year future scenario with background growth, Scenario 4A (TIA Table 22, p.32) projects: LoS F, average delay 201.7 seconds, degree of saturation 1.305, 95th-percentile queue 622.2 metres. This extraordinary finding suggests that, on the busier days, the neighbourhood's main thoroughfare could host a giant traffic jam.
Worse, on page 24 of the TIA, the applicant's consultant then concedes: "any figures produced by SIDRA related to delay or queue length should not be considered representative, as SIDRA model intersections can become unstable in LoS F condition." This is a frank admission that the model cannot reliably predict congestion outcomes at the one intersection that matters most and cannot tolerate failure for e.g. emergency services. Note that the Eastern Valley Way / Sunnyside Crescent intersection is not a release valve: the TIA also records it at failure (LoS F) in the existing morning peak (Table 16, TIA p.24), with a ten-year projection of 675.5 seconds average delay and a degree of saturation of 1.455 (Table 22, TIA p.32) — the most extreme traffic delays in the entire assessment.

The TIA claims the site enjoys "Level 6 — very high accessibility with public transport" (TIA Figure 14, p.14), citing nine bus routes. In practice, the actual bus frequencies (documented in TIA Table 8 pp.11–12) show: Route 203 (Castlecrag to North Sydney) offers just two morning services, then resumes at 2:17pm — a nine-hour midday gap; Route 194 carries no morning peak service at all, starting at 9:37am; Route 275 runs at 30 to 60 minute intervals on weekdays and hourly on weekends. Counting route numbers is not the same as demonstrating service quality. Bus-service frequencies on Eastern Valley Way may already be constrained by existing traffic conditions; adding more buses is likely not a simple remedy. Residents who cannot catch a suitable bus at 8am will drive, and those cars pass through the intersection analysed above.
The closest train station is 2,560 metres away. The TIA's Cycling sections (sections 7.7.2 and 3.2.2) admit: "The site has poor surrounding cycling infrastructure, being bound by a major road with no dedicated cycling facilities, combined with undulating and steep grades." Having conceded that cycling is not easily accessible from this site, and that bus services are sparse and gapped, the applicant offers no credible basis for any mode-shift aspirations. Residents will default to private cars, vehicles that have one way in and one way out.

Despite all this, the TIA's Executive Summary concludes that the development will have "low impact to the existing road network conditions", a conclusion that cannot be sustained on the applicant's own evidence. The pedestrian position compounds this: all four pedestrian crossing movements at Edinburgh Road / Eastern Valley Way already register LoS F, with average delays of 60 to 62 seconds per crossing. The people the Green Travel Plan (GTP) hopes will walk to the bus stop are queued at a failed intersection. Moreover, the TIA's summary (p.32) states: "No change to the Level of Service of any modelled intersection is found as a result of development traffic…" This sounds reassuring until you realise it appears to be true only because the intersection is already at failure, LoS F: and you cannot go lower than an F.

Relief sought
I ask the Minister to refuse this application. Consent should not issue until the site is close to a metro or tram stop. If such a connection were constructed, I would withdraw this objection and support the development — or an even larger one. Until this is done, I object to this development in the strongest terms.

I object to Edinburgh Group Investments Pty Ltd (“Conquest”) proposed development of twin 13 – 15 storey Towers on the old Castlecrag shopping centre site at 100 Edinburgh Rd, Castlecrag and ask that the development application be rejected. My principal grounds are traffic, inappropriate height and bulk for the suburb and its visual impact on the Castlecrag Conservation Area, and the fact that the development fails to meet the goals of the State Significant Development site.

Traffic
150 additional units with 376 car spaces will bring many additional vehicles, increasing parking demand, but principally adding significantly to traffic movements. Castlecrag has only one entry/exit that can handle traffic volume, being the Edinburgh Rd/ Eastern Valley Way intersection. It is already under strain particularly exiting the suburb 8am to 9.30am when the traffic banks up to the Rutland Ave roundabout. It also is a hindrance to emergency services (fire and ambulance) entering the suburb, though the emergency services with sirens and flashing lights would have a better chance of using the Sunnyside Crescent exit than regular traffic. Regular traffic can only safely use a left turn into, and a left turn out of Sunnyside Cres due to the risk of collision trying to cross traffic lanes.

I am a keen user of bus services into the City, but still find myself driving to Artarmon station to connect with rail, to Chatswood for large shopping. The exit from Castlecrag will be seriously impacted by the additional traffic from this oversized development.

Height and Bulk
The proposed development of twin 13 – 15 storey Towers is out of all proportion to existing buildings in Castlecrag. It is not sympathetic to the existing Griffin Heritage Conservation Area. Castlecrag is world famous in architecture circles for the residential buildings of the American architects Walter Burley Griffin and Marion Mahony Griffin who laid out the plan for Canberra. The height towers over and shades the adjoining residences, and dwarfs the native bushland that extends down the nearby Sailors Bay Ck.

The proposed towers are over 5x the current maximum allowable height, and over 4x the current maximum floor space ratio set out in the Willoughby Local Environmental Plan 2012. They are also more than double a Willoughby City Council proposal for increased height and floor space ratio, but which remains a proposal and does not yet replace the LEP restrictions.

Goals of State Significant Development sites
While not set out in defined SSD objectives, I believe SSD sites are ideally within walking distance of transport hubs, with railway stations preferred. This is not the case with 100 Edinburgh Rd. There are bus lines stopping on the Edinburgh Rd/ Eastern Valley Way intersection (203 to North Sydney, 205/206/207/194 to the City), but other lines included by Conquest in their traffic report do not stop at all there as they sweep by from the North Shore/ Northern Beaches into the City.

Affordable Housing is only 10 of 150 apartments, and that only for 10 years, not in perpetuity. This is risible, given the high property values in the area and acute shortage of affordable rentals for police, ambulance, fire, teaching, aged care and child minding personnel.

Trust in Conquest
It is admirable that Conquest admits to failing to satisfy many requirements. For example:
- The site is 850 to 900 metres from Northbridge town centre, which is outside the 800 metre walking-distance radius that triggers Low and Mid-Rise Housing (LMR) eligibility. But then Conquest attempts to muddy the waters by walking back this non compliance by suggesting it applying to nearby land implying it applies to 100 Edinburgh Rd: “Land surrounding the subject site, as well as land between the subject site and Northbridge Town Centre are subject to the Housing SEPP’s ‘Infill Housing 30%’ provisions as well as the ‘LMR’ provisions”
- As to the site adjoining the Griffin Heritage Conservation Area - the choice of words “There will be some visual contrast due to the scale disparity between the new building and the lower-scale heritage dwellings” is minimising the disparity and barely amounts to an admission
- Conquest’s Apartment Design Guide (ADG) Compliance document admits that 30% of apartments will receive no direct sunlight at the winter solstice, which is 2x the permitted maximum of 15%. (The site is not rail-accessible by ADG standards)
- The Wind Report admits that the safety criteria (not merely comfort criteria) of the Australasian Wind Engineering Standards are exceeded un-mitigated at three locations: the ground-floor south-east corner, Level 1 between the towers, and Level 4 corner terraces
- the Willoughby Development Control Plan 2023 Part L caps the Castlecrag Local Centre at 4 storeys above Eastern Valley Way and 3 storeys along Edinburgh Road. The applicant’s own statutory compliance table admits, in plain English:
- “The proposed development will exceed the maximum number of storeys prescribed” in the Willoughby Development Control Plan 2023. Part L caps the Castlecrag Local Centre at 4 storeys above Eastern Valley Way and 3 storeys along Edinburgh Road. The admission does not quantify the excess factor of over 4times!!

However, there are enough examples of Conquest insincere efforts to communicate with the local population and getting their facts wrong that leads to a Trust deficit already at the beginning of these proceedings
- sham consultation efforts on 12.11.25 and 18.3.26 – presenting no plans in the 1st session, and then little more than a few artist drawings in the 2nd with illegible shadow diagrams.
- claiming “no objections from community groups” would have been due to the non presentation of detail by Conquest – Community fear that giving a response would appear to give validation to the sham exercise
- characterising express bus services stopping at Edinburgh Rd/ Eastern Valley Way intersection when they do not
- “LEP standards are superseded by concurrent rezoning” which is incorrect – the LEP is still the prevailing legal requirement on height and floor space and is massively overtrumped by this proposal

In summary, I request that the development application be rejected. My principal grounds are traffic, inappropriate height and bulk for the suburb and its visual impact on the Castlecrag Conservation Area. I would like to see the current approved DA for 100 Edinburgh Road proceeding. I would even consider an uplift of 2 storeys to that plan, seeing a working up from that plan rather than a working down from the current proposal to be most realistic.

Although I have lived in Castlecrag for 29 years, I have previously lived in the Inner West of Sydney, and in Manchester, Copenhagen, Hamburg and Zurich, so am no stranger to higher density and apartment living.

I was a resident of Castlecrag for 10 years 2007-2017 living at 79 Sunnyside crescent Castlecrag and feel strongly about objecting to the project 100 Edinburgh Rd. Castlecrag.

Castlecrag is recognised heritage significance with Walter Burley Griffin architecture in such close proximity to the site. This would be like a scar on the landscape in a neighbourhood such as this.

The neighbourhood would not be able to cope with such a huge amount of traffic. And there is not mass transport to alleviate the issue either.

Many thanks
Simone Kopkas

I wish to formally object to the proposed development at 100 Edinburgh Road, Castlecrag.

The scale of the proposal represents clear overdevelopment in a low-rise, residential and historically significant suburb. Two 14-storey towers are entirely out of character with the existing built form and far exceed what is appropriate for this site.

Castlecrag holds recognised heritage significance, closely associated with Walter Burley Griffin. The integrity of this unique planning and architectural legacy would be materially diminished by a development of this height and bulk.

Traffic and access are a major concern. There is already congestion at the intersection of Edinburgh Road and Eastern Valley Way, particularly during peak periods. The addition of two towers of this scale will significantly increase vehicle movements, placing further strain on an intersection that is already under pressure.

There is no realistic capacity to upgrade or reconfigure this intersection to safely accommodate such an increase in traffic. Castlecrag has limited entry and exit points, and delivery and service vehicles rely on a constrained road network. This raises genuine concerns around safety, emergency access, and day-to-day functionality for residents.

Public transport infrastructure is also inadequate to support this level of density. Eastern Valley Way is already a key bus corridor into the city, yet existing bus stops are limited in size and capacity. There is little physical room to expand these stops or improve pedestrian access without further impacting traffic flow. Importantly, there is no rail line servicing this location, and limited ability to materially expand the public transport network in the future.

More broadly, it is difficult to understand why development of this scale is being directed to Castlecrag at all. There are already designated growth corridors along major transport routes, particularly near rail lines and highways, where increased height and density are both planned for and supported by infrastructure. These locations are far better suited to high-rise development.

By contrast, Castlecrag has constrained access, limited transport infrastructure, and a well-established low-density character. Placing a project of this scale in such a setting is inconsistent with sound planning principles. It is not required, nor is it appropriate, given the availability of more suitable sites elsewhere.

It is also important to note that a development has already been approved for this site at a significantly lower scale. That approval reflects a more appropriate balance between development and context and should represent the reasonable upper limit for the site.

In its current form, this proposal is excessive, out of scale, poorly located, and unsupported by the necessary infrastructure. It is difficult to see how it meets the threshold of State Significant Development when more appropriate locations for such density clearly exist.

I respectfully request that the application be rejected.

The existing DA-2024/13 had extensive and vigorous consultation and support from local residents. It is appropriate in scale and quality, adjoining the Griffin Conservation Area. Although it would place strain on local traffic and public bus transport, it was a long-overdue improvement to the heart of the retail part of Castlecrag and the gateway to this historic suburb. The new proposal, being 12-14 storeys higher than the existing approved DA, seeks to try to justify this massively inappropriate increase in scale, bulk and volume by somehow suggesting that it is helping to solve the chronic shortage of affordable housing for NSW. It will do none of that, as so few of these new apartments will be anything close to affordable. This is all about developer seeking to maximise profits from an hugely inappropriate bulk and scale of development totally out of keeping with the surrounds. It is patently obvious that is the key driving force behind the application - it has nothing to do with helping the NSW housing shortage for those who really need it - key workers, healthcare professionals, those in essential services for example. None of them can afford the likely $2m plus starting prices for these apartments. The only beneficiaries will be well-paid private owners, or worse still, very wealthy investors who are doing nothing for the local community and are only interested in making capital gains and earning income to be spent elsewhere.

Of equal importance is the adverse implications for local traffic and already over-congested and time limited public transport by bus. This is not a TOD zone, there is only one method of public transport which is already significantly time limited to peak hours. The thought of hundreds of new road and public transport users moving into the huge proposed apartment development on the 'one route in and one route out' Edinburgh Road, which already serves the vast bulk of local residents in Castlecrag, is laughable. The developer is not going to provide extra finance for improvements to the bus service, nor is it able to adequately address the significantly impaired traffic movements for all those already living in Castlecrag. I am a daily bus user travelling to work in the City and I can already that the service is massively under strain, cramped, slow and with the majority of buses coming from an outdated bus fleet. Bus useage has reverted to pre-Covid volume of passengers in peak hours in particular, but has led to an increase in the hours of use which has not been met with an increase in service times to levels that others on the Metro line or train links would be used to having. There will be traffic chaos in the whole suburb and beyond on all points before and after Castlecrag bus stops, once hundreds of new uses in the proposed development start travelling either by bus or (even more likely) by car. The bulk and density of the proposed development is madness, when considering the constraints on the public purse in trying to address this huge increase in use. The problem would persist in perpetuity without any obvious ability to mitigate, given the existing road layouts, traffic light configurations and inability to build new roads or improve the 'one in one out' nature of Edinburgh Road. It cannot be done in the same way that proposed TOD solutions can do elsewhere in NSW.

This proposal does not align with exiting planning framework controls or planning and design policies. If it were to get approval, which I strongly urge you not to do, it will set precedent for future high-rise buildings in low-rise suburbs which are not appropriate for development of this scale. I am very supportive of the considered and sympathetic approved development in DA-2024/13 which I feel will add significantly to the Castlecrag suburb without irreversibly damaging and causing harm to this heritage area of such significance for NSW.

Please do not approve this development. Please continue to support the existing approved development, which is suitable in scale, meets certain housing demands appropriate to the suburb, will not have the same hugely negative impact on an area which does not address the worthy goals of TOD planning given the lack of any TOD in the area (and no chance of that happening in future given the topography of Castlecrag and its natural location). Please focus on supporting bulkier developments around areas which will be able to support such development with TOD services and which will assist in providing much needed affordable housing for those who need it most - not just to provide private developers who have no long-term attachment to a historic community but are only interested in opportunistically seeking to maximise profits by playing to the lack of housing in NSW for those who cannot afford it, whilst planning a very, very limited amount of so-called affordable housing (a max of 10 which we all know they will find a way to limit and obfuscate the Council and NSW State in every meaningfully being able to provide. This is all about making profit whilst not caring a jot for the problems outlined above, nor (ironically) even about those private investors and purchasers who will equally face the problems outlined above.
This is not an area identified as housing growth area in the NSW State or local planning strategies - for good reason, l given its topography and natural layout, with the resulting lack of Metro and train services ever being contemplated for this area for solid engineering and cost reasons.
Development as envisaged under exiting approval DA-2-24-13 was carefully considered by the Council and the local Castlecrag inhabitants over a long period of time. It is of appropriate scale, will lead to an improvement in local retail as well as being sympathetic to its geographical and historic location. The proposed development does none of those things, and will place an even greater strain on the limited village retail services. It will not solve the nation-wide and NSW-focused need for appropriate developments of scale to meet affordability constraints for key workers in particular, built around multiple public transport options which will l not have the hugely adverse impact that this proposed development would have in a neighbourhood which is not designed to take the bulk and volume that it proposes. There are other areas which are better suited to such bulk and volume, that already have improved TOD services and where a development such as the one proposed would fall within existing planning and design policies and which would hopefully have much greater affordability for the many people who need it.
There are very few places like Castlecrag that have the Council's current overlay of character and heritage. Why risk that, for a totally inappropriate development of such scale, bulk and volume, which is simply not suited on either practical terms nor soes it solve much needed affordable housing options for those who need it most.
I urge you not to approve the proposed development, but to continue to permit DA-2024-13 and encourage the renewal of Castlecrag village centre in an appropriately complementary way in compliance with existing planning and design policies and with the Council's laudable heritage preservation priorities.
Thank you for your time in reading my submission. I do hope you make the right decision and reject this application.

28 April 2026
The Planning Secretary NSW Department of Planning, Housing and Infrastructure Attention: State Significant Development Assessment Team
RE: FORMAL OBJECTION — State Significant Development Application, 100 Edinburgh Road, Castlecrag NSW 2068 (The Quadrangle Site)

Dear Planning Secretary,

I write to formally and strongly object to the current proposal by Edinburgh Group Developments (Conquest) for twin residential towers comprising 150 apartments at 100 Edinburgh Road, Castlecrag. The proposal involves two 11-storey towers rising above a four-storey podium — a total built form of up to 15 storeys — on a heritage-sensitive peninsula with no mass transit connections. This submission is made on behalf of myself as a concerned resident and member of the community, and I urge the Department to reject this application on the following grounds.

1. A DECEPTIVE AND BAD-FAITH APPROACH BY THE DEVELOPER
The community's opposition to this proposal is grounded foremost in the conduct of the developer. A development application for a three-to-five-storey mixed-use building comprising 38 apartments and a supermarket was approved by the Sydney North Planning Panel in December 2024. That approved scheme was the product of years of genuine community consultation, careful engagement with Willoughby City Council, and detailed planning by the previous owner. The community supported it.
Conquest purchased the approved site and, within months, discarded the approved design entirely. The developer then pursued a scheme almost four times the scale — 150 apartments in twin towers rising 11 storeys above a four-storey podium — via the Housing Delivery Authority (HDA) pathway, thereby bypassing Council oversight and the established community consultation processes. At no point did Conquest engage genuinely or transparently with the local community before advancing this dramatically expanded proposal.
The Castlecrag Progress Association has noted that Conquest's proposal "violates its stated promise to uphold Dr Quek's vision" and that the company acknowledged Castlecrag's architectural significance at the time of purchase, only to disregard it entirely in practice. This is not a minor revision. It is a wholesale abandonment of a community-endorsed outcome pursued through a process specifically designed to avoid scrutiny. Progressing this application would reward precisely the kind of planning opportunism the HDA was never intended to facilitate.

2. THE IRREPLACEABLE HERITAGE AND ARCHITECTURAL SIGNIFICANCE OF CASTLECRAG
Castlecrag is not an ordinary Sydney suburb. It is the only suburb in Sydney — and one of only a handful in Australia — conceived, master planned, and built by internationally significant architects Walter Burley Griffin and Marion Mahony Griffin. Griffin, who also designed Australia's capital city Canberra as well as the towns of Griffith and Leeton, developed Castlecrag from 1921 as a model suburb built in harmony with the Australian landscape. His philosophy — that architecture should grow from the land, not be imposed upon it — is embedded in every contoured road, every sandstone reserve, and every pathway through this peninsula.
Castlecrag is recognised internationally as an outstanding example of planning with nature. The suburb contains 35 heritage-listed items and forms part of a Griffin Conservation Area of state and national significance. The Walter Burley Griffin Society has described it as "a garden suburb possibly of world significance." This year marks the 150th anniversary of Griffin's birth, which makes the timing of this proposal particularly disrespectful.
The proposed twin towers — likened by the community to Blues Point Tower — would fundamentally rupture the low-scale, bushland character that Griffin's vision established and that heritage protections have preserved for over a century. The approved 38-apartment scheme was considered sympathetic to that heritage. Twin towers of 11 storeys atop a four-storey podium on this peninsula are not. Once Castlecrag's scale and character are compromised by a development of this magnitude, that heritage cannot be restored. The Department should give enormous weight to the permanent and irreversible nature of the harm this proposal would cause.

3. WHOLLY INADEQUATE PUBLIC TRANSPORT
The community, the Castlecrag Progress Association, and even senior planning figures have repeatedly identified Castlecrag's isolation from mass transit as a fundamental constraint on large-scale residential density. The suburb sits on a harbour peninsula with limited road access and is not served by a train station, light rail, or ferry connection. There is no realistic prospect of mass transit infrastructure being delivered to serve this location in any foreseeable timeframe.
Transport for NSW has itself acknowledged the area's transport limitations — Council recently sought and received approval to defer a related transport infrastructure project pending redevelopment of the Quadrangle site, citing the need for coordination. Increasing the residential population from 38 apartments to 150 apartments at this location will generate a substantial increase in private vehicle trips on Edinburgh Road and the surrounding road network, which is already constrained by the peninsula's topography.
The NSW Government's own stated objectives for the HDA focus on increasing housing supply near transport nodes and in well-connected locations. Castlecrag — by the Government's own criteria — does not qualify. The CPA has called on the Premier, the Planning Minister and the Heritage Minister to visit Castlecrag in person to see the transport isolation first-hand. I echo that call. Approving a development of 150 apartments at this location, without any supporting mass transit, would be a serious failure of infrastructure planning.

4. CUMULATIVE DENSITY IMPACTS — SIGNIFICANT DEVELOPMENT HAS ALREADY OCCURRED
Castlecrag and the surrounding Willoughby local government area have already absorbed substantial residential densification in recent years. The Willoughby Local Centres Strategy to 2036 was developed with extensive community consultation and adopted by Council in 2019. Planning controls were subsequently amended — through legitimate processes, including public exhibition and Council endorsement — to provide for increased residential density at the Quadrangle site. The 38-apartment mixed-use development that resulted from that process was the community-endorsed outcome of that densification.
The community accepted that increase. It was reasonable, proportionate, and the product of proper planning. The current proposal would not be a modest incremental increase upon that approved scheme; it would quadruple the apartment yield at a single stroke, in a suburb with no capacity to absorb such a population increase through public infrastructure, transport, or open space. The residents of Castlecrag have already demonstrated their willingness to accommodate appropriate growth. What they face now is not appropriate growth. It is an opportunistic attempt to extract maximum yield from a heritage-sensitive site, through a process designed to circumvent the very community consultation and Council oversight that produced the agreed outcome.

CONCLUSION
I urge the Department to reject this application. The approved 38-apartment scheme at 100 Edinburgh Road represents a genuine and proportionate response to housing need in this location. It was reached through years of proper planning, community engagement, and Council consideration. Conquest should be required to build what was approved, not rewarded for abandoning it in pursuit of a vastly larger scheme that damages heritage, ignores infrastructure constraints, and disregards the community that lives here.
The significance of Castlecrag — to New South Wales, to Australia, and to the world — demands nothing less than the highest standard of planning integrity.
Yours sincerely,