I write as a long-term resident of Leura/Katoomba.I am an active member of the community in the areas of arts and events and have served on the Winter Magic Festival Committee, Footbeat Festival, RubyBloomers Womens Circus and Katoomba Sustainability and Regeneration Groups, as well as many others.
To ensure my objections are clear, I am confining my comments on this proposal to areas I understand through my 20 years of living in the local area through fire, flood, drought, COVID-19.
I will comment on the documentation submitted by the consultants who have prepared reports for this development. I note that while an Aboriginal heritage impact statement has been provided, there have been no direct conversations with Deerubbin Local Aboriginal Land Council, or with representatives of Gundungurra people. I also note the Community and Stakeholder Engagement Report recorded strong opposition from local residents who replied to a letterboxed survey but makes no mention of Blue Mountains City Council's opposition to this project, or the concerns of the Blue Mountains Conservation Society about this assessment. I believe there has been a lack of serious community consultation with any groups other than close neighbours to the site. This site is adjacent to the former golf course which is used by the wider community for outdoor recreation.
The proposal attempts to position a large number of buildings into a site in a quiet residential area. The proposed buildings are of a scale and size that are unlike any others in the area and clash with the visual landscape.
Hydrologically, the Blue Mountains is a wet and highly temperamental landscape, over which water flows rapidly and dangerously. All this water drains into the catchment for Sydney's drinking water, and any work done on this site risks polluting the water we all need to live. Over the last 10 years we have witnessed the runoff and environmental damage caused during the construction of the much smaller complexes at 'The Escarpments' next door. It is impossible to imagine the developers of this proposal could mitigate the flow of high volumes of water during a classic Blue Mountains flooding event, especially given the level of excavation required.
Geologically, the sandstone in this the region is prone to movement that triggers road collapes, as evidenced by the current closure of the Great Western Highway route over Mount Victoria and, right next to this site, the access road to Narrow Neck. In the last six weeks we have had three earthquakes, the most recent of which emanated from Orange, NSW and exceeded 4 on the Richter scale. Sandstone cliff faces close to Narrow Neck and Cliff Drive are calving and collapsing at a dramatic rate that will no doubt be increased by the heavy excavation required for this project.
The other defining feature of this site is its extremely poor location. It cannot meet the requirements of Transport Oriented Developments or the definition of walkable suburbs, or meet the needs of the aged or disabled. It is a full 3 kilometres or 50-minute walk from Katoomba Station, over undulating country. It is the same distance from the nearest state high school, primary school, and TAFE, so students will need transport to access their education. Public transport is limited to one bus (686G) that runs every 30 minutes but only between 6am and 8pm. As a result, residents will be entirely car-dependent and, in the current fuel crisis, that has a significant impact on the cost of living.
When you consider that Narrow Neck Road is narrow and winding, unsafe for high volumes of traffic, and is 'one way in, one way out', the risks of the movements of 215 households and their visitors to and from the site are obvious.
The poor transport access to this site will matter most during bushfire events. Fires along Narrow Neck Road are a regular occurrence, with the most recent in 2019 impacting properties and access along Narrow Neck Road and Cliff Drive. If you add the pressure of 215 households who must evacuate by car, the ability of fire services to act to protect properties and life will be greatly restricted.
The proponents have stated they will meet government-mandated levels for 'affordable' housing in this development, but do not explain what that may mean for affordability in our community. The current definition of affordable housing is rents set at 75–80% of market rates or capped at 30% of gross household income for 10–15 years. There is no equivalent property in Katoomba to determine market rents, as apartments are rare. The median weekly income for households in Katoomba–Leura at the 2021 Census (https://www.abs.gov.au/.../quickstats/2021/124011452...) was $1238 per week, but 34% of residents (median age 50) live on less than $800 per week. More than half of Katoomba-Leura residents already spend more than 30% on housing and the median rent locally is just $380.
Importantly, affordable housing improves social outcomes when it is located close to jobs. The only major employer close to this site is Scenic World (1.5km distance), which employs around 100 people, often in casual and part-time roles. The hospitality and retail venues on Katoomba Street are located 3km from this site and Blue Mountains City Council, which is another major employer, is more than 3km distance.
Essential workers need work that is within walking distance from their homes, but schools and childcare facilities are at least 3km distant, and Blue Mountains District Anzac Memorial Hospital is more than 5kms away. The proposed shop, restaurant and gallery are unlikely to employ residents from this site, and any workers from Katoomba who come to the site will need to travel 3km to get to it (on the same narrow, winding road, using the same buses that do not run during the hours of most shift and late night workers).
In summary, this proposal is wholly wrong for this location and I urge the panel to reject it, in its entirety.

The project is oversized , I raise concerns in relation to the environmental impact at the site proposed , also the bush fire risk is high plus the highway impasses at this time ie Victoria Pass is closed indefinite time frame . Basically one way out. This sets a dangerous precedent for overdevelopment . the visual aspect on the escarpment would be detrimental to this world heritage site given to the Blue Mountains. Thank you for your attention. Vivienne Kennedy

I am writing you as a concerned resident of Katoomba. The proposed construction would be injurious to precisely those environmental conservation values that make it a World Heritage Area. It would also endanger the community who live here now. It is an improper application of the HDA, that will not result in an increase in affordable housing or benefit the local economy, but will instead increase pollution and traffic and put unnecessary pressure on emergency services. See attached.

This project has excluded the Blue Mountains Council ie the ratepayers and residents from making a determination on this matter. We therefore have a secondary chance to have our concerns and opinions counted. We do not consider this process fair and consider that the state government is forcing this major development project to fruition for grandisement and to assist in achieving a state wide quota on infill housing and development.
As so many have said and will say there are several reasons why this proposed development is inappropriate in this location:
* It is much too big a development 4 & 5 storeys high up to 15.6metres. This is out of character with any new development in the Katoomba area. The height should be the same limit in the existing relatively new dwellings in the Escarpment that is is within 500 metres of the proposal.
*. The proposed 9 buildings contains several hundred dwellings plus hotel, cafe etc etc would be an eyesore on the landscape. For the proponents of the project to say it "has been carefully designed ensure a built form that is not dominant within the streetscape or landscaped setting of the locality" is fictitious! Look at adjacent Esacarpemt streetscape ... not 4 or 5 storey buildings there. This should be the limit of any future development in this locality. The other adjoining property adjacent is the old Golf Course which is now Council owned recreational land for the community. This is a major part of "the locality" so how can 9 buildings of of up to 5 storeys be not "dominant" within the "setting of the locality"???

*. It is very unusual and decidedly suspect that "the site has been reclassified as non bushfire prone". Look at the recent history of fires in this area and see what a farce this "reclassification" is. This is a bushfire prone area and as such the infrastructure cannot cope with evacuation and rescue vehicles if such a major development goes ahead. It would be embarrassing for State government if/when there is a fire in this area and there is loss of life, injuries, major property largely because of inadequate access and egress. Is State willing to take this risk?

*. Blue Mountains Council is currently exceeding its housing targets so why is this inappropriate development being forced on the residents? Is it kudos for state government? Of course it results in lots of profit for the developers.

* This area is adjacent to to a major World Heritage site. Recent statistics showed that the Blue mountains National Park was the most visited of N Ps in Australia. It is unbelievable that any government could consider such a development on this site. Millions of visitors do not come to this site to see high rise developments. High rise buildings are not part of the character of the local area.

* As tax and ratepayers we pay $ to all 3 tiers of government. All those employed by government have a duty to listen to and make decisions that represent the majority of its citizens.

* The proposed development is inappropriate for this site and needs major alterations before the community would consider it "appropriate".

I have lived in, loved and called Katoomba home since 1992. I enjoy being part of a distinct community that has gradually grown and thrived and maintained character over those decades.
I strongly oppose this development at 142-150 Narrow Neck Rd Katoomba by the HDA on these grounds;
-our community infrastructure and sensitive environment cannot support such a development without causing significant and irreversible harm.
-The HDA is completely bulldozing and ignoring critical LEP protections that have taken 30 years to develop to safeguard the Blue Mountains environment and heritage for current and future generations.
-I witnessed the 2019 bush fires and others, the environmental harm and terror they caused the Blue Mountains community. I recall people I knew leaving before they got trapped on our ridge line of towns with only two directions to get out- east or west. I remember a family I know saying goodbye to friends when they evacuated as they weren't sure if we'd all make it. I knew elderly people who remember the 1950s fires when the town of Leura was destroyed. One older friend is always traumatised when there's fires as her son died in Katoomba in early 2000s just as ending a long hard day with the RFS fighting fires. Loval people I know and work with who have joined the RFS regularly practice their fire drills etc and participate in Hazard reduction burning to keep our vulnerable communities safe.
Are the occupants in the additional proposed 266 apartments going to add to that load that volunteer groups such as the RFS need to educate and protect? Of course they are, significantly.
-I object on environmental grounds as this development is way too huge to not place major strain on our sensitive World heritage National Park.
-On visual grounds- it us completely out of character with our town!

142-150 Narrow Neck Road residential flat buildings

Does Katoomba need this type of residential development? Where is the demand for this type of residential development in Katoomba?

Katoomba is located over 100km west of the Sydney CBD and is surrounded by the World Heritage listed Blue Mountains National Park. Katoomba is an iconic town, known the world over for its amazing views and stunning bushwalks that straddle the cliff edge and extend down into the temperate rainforest below. Preserving the character of one of the most visited and valuable tourist towns in Australia must surely be a priority for both the New South Wales and Federal governments.

Unfortunately the opportunities for employment within the local area are limited and much of the local populous travel long distances to work. Only limited jobs will be provided by this development beyond the construction phase, so their is little argument to support this development on job creation grounds. If people seeking employment are to be housed by this development they will invariably need to travel long distances to work and will mainly rely on private transport to do so. There is a bus route that services this part of Katoomba, but the development sits more than three (3) kilometres by foot or vehicular transport from Katoomba Railway Station. Katoomba Railway Station has extremely limited park and ride facilities with very few car parking spaces available. The train trip from Katoomba to Central Station takes around two (2) hours making commuting from Katoomba to the Sydney CBD a more than four (4) hour per day commitment.

There also seems to be little argument that this development will help, in some small way, to curb the current housing affordability crisis as only 15% of the apartments are designated as affordable housing. Affordable housing is an issue in the Blue Mountains, as it is in most parts of Australia, but there is no evidence in the current development application that addresses these concerns in any meaningful way.

What does this development threaten beyond the impact on current residents living along Narrow Neck Road itself and the nearby streets? This part of Katoomba is already subject to congestion due to the world famous Scenic World, the Katoomba Christian Convention and the world renowned Ultra-Trail Australia running festival held in May each year. This is an area of Katoomba that is already accommodating a number of the commercial endeavours within the Upper Blue Mountains, with limited amenity in place to deal with the periodic influx of huge numbers of visitors.
This area also contains two of the most dramatic and well frequented lookouts in the whole Blue Mountains, Cahills Lookout and Narrow Neck Lookout. In recent years, both these lookouts have supported ever increasing numbers of tourists during the day, and particularly at sunset. The increase in traffic due to the popularity of these lookouts has been noticeable. This area is one of the most important tourist locations in the Blue Mountains and should be protected and preserved as such. This development puts more cars on the road in this area, contributing to congestion and reducing safety for pedestrians and cyclists trying to access and enjoy the beauty of this special part of Katoomba.

Does Katoomba need a large cluster of four storey buildings along with another restaurant and an art gallery? I suspect the restaurant and the art gallery are included largely for window dressing or compliance reasons. Neither will provide meaningful employment opportunities and may not be sustainable in the longer term, as neither is located in a precinct surrounded by similar businesses.

The drawings of the buildings in the submission make then look attractive, but will that actually be the case once they are completed? The adjacent Escarpments development is an imposing eyesore in parts, and many of the residences remain unoccupied, and I suspect unsold, many years after completion. I suspect the cluster of apartment blocks proposed would be much more appropriately placed in countless other locations across the Sydney Metropolitan area where they are closer to public transport and employment opportunities, and where there are less concerns about visual and local impacts so close to one of the most beautiful parts of the Blue Mountains.

The cluster of buildings located so close together suggests that the profitability of this proposal is reliant on placing as many apartments as possible on the smallest possible site, a type of housing unprecedented across the city of the Blue Mountains. Significant infrastructure will need to be built to accommodate these buildings in an a world where building costs have skyrocketed and the financial viability of building apartments has become a concern. Will these apartments be sold? What is the ongoing commitment to maintaining and servicing these apartments? What if financial potential falls short of reality and Katoomba is left with nine white elephants dominating the south-west skyline of the town? The developer won’t be able to command Upper North Shore or Inner-West Sydney prices for these apartments.

The gut reaction of most people when first made aware of this development is one of amazement & disbelief. On closer inspection there does seem to be merit in providing apartment style living in the Blue Mountains. No LGA in New South Wales or Australia should be immune from this type of development because they deem themselves as exceptional or special, but in this case the developer could not have picked a more inappropriate site in one of the most beautifully located towns in Australia.

Andrew & Nicky Laws, Katoomba, Blue Mountains

I formally object to this development. A detailed objection letter is attached as a PDF and should be read as part of this submission.
1. POLICY FRAMEWORKS ARE BEING MISUSED FOR COMMERCIAL GAIN
The proponent is using the NSW Housing Delivery Authority (HDA) pathway as a pretext to extract commercial value from a uniquely attractive site. Critically, the NSW Government's own Low and Mid-Rise Housing Policy explicitly excludes the entire Blue Mountains LGA from its scope, stating that all land within the Blue Mountains LGA is excluded due to bushfire risk, environmental constraints, and evacuation risk from the single highway entry and exit. Katoomba Station is also not among the 37 nominated TOD Program stations. The proponent cannot genuinely meet the criteria of either policy framework it purports to rely upon. The very qualities that make this site commercially attractive to a developer (World Heritage proximity, escarpment views, natural beauty) are precisely what the community is fighting to protect, and what these policies were never designed to exploit. The 15% affordable housing component is the minimum threshold, used as cover for 85% market-rate and premium serviced apartment units. This is policy capture for commercial gain, not a genuine contribution to the housing agenda.
2. INADEQUATE AND UNSAFE PUBLIC TRANSPORT
The development's transport credentials are fundamentally misleading. Route 686G, the only bus service, runs every 30 minutes and does not operate in the early morning or late evening, making it wholly inadequate for a population of 270+ dwellings. No binding commitments from Transport for NSW to improve services have been secured. The Blue Mountains rail line is infrequent, unreliable, and involves a two-hour commute to Sydney, which is unsuitable for the volume of residents this development would generate. While the site may nominally meet a walking-distance threshold to Katoomba Station, the actual walking route involves steep mountain terrain, sharp bends, absent or inadequate footpaths, and dangerous pedestrian conditions, entirely unlike the flat suburban environments for which state walking-distance benchmarks were designed. The Blue Mountains is not comparable to Sydney suburbs and standard metropolitan transport benchmarks must not be mechanically applied here.
3. UNSAFE ROAD AND PEDESTRIAN CONDITIONS
The surrounding road network consists of narrow mountain roads with steep grades, blind corners, and no adequate footpaths. It was built to serve a small number of residences and tourist pass-through traffic and cannot safely absorb the additional daily vehicle movements from 270+ dwellings, 52 serviced apartments, a restaurant, and an art gallery. Existing nearby residents already experience these roads as near capacity during peak tourist periods. During construction alone, years of heavy vehicle access will create chronically dangerous conditions for all road users. An independent traffic and pedestrian safety assessment, specifically modelling mountain road geometry, must be required before any determination is made.
4. BUSHFIRE EVACUATION RISK
The site's administrative reclassification as "non-bushfire prone" does not alter the physical reality of the surrounding landscape. The NSW Government's own Low and Mid-Rise Housing Policy states there is "an evacuation risk present throughout the local government area due to the single highway entry and exit." Narrow Neck is a peninsula formation with severely constrained evacuation geometry. Adding hundreds of new residents, including serviced apartment guests with no local knowledge of evacuation routes, materially worsens mass evacuation capacity for every existing resident. An independent NSW Rural Fire Service assessment of cumulative evacuation capacity must be required before any determination is made.
5. ENVIRONMENTAL AND ECOLOGICAL DAMAGE
134 of 206 trees on site (65% of existing canopy) will be removed, causing irreversible loss of habitat, wildlife corridors, and ecological buffering adjacent to the World Heritage Area. Native wildlife, including birds, reptiles, and marsupials using this site as habitat and movement corridor, will be directly harmed by vegetation loss, construction impacts, and ongoing light spill and domestic predator pressure from new residents. Increased stormwater runoff from impervious surfaces will damage the Katoomba Creek catchment. An independent biodiversity assessment by a qualified ecologist with no connection to the proponent is essential before any determination.
6. ADVERSE IMPACT ON TOURISM AND WORLD HERITAGE
Tourists travel from around the world to Katoomba for its outstanding natural character, not to see high-density apartment towers. Nine buildings up to 15.6 metres tall in the viewshed of Narrow Neck Lookout and the Three Sisters will permanently and irreversibly alter the landscape that underpins the entire local tourism economy. Once built, this cannot be undone. If Katoomba loses its distinctiveness, it loses its reason to visit, and the tourism economy that sustains every local business collapses. Australia also has international obligations under the UNESCO World Heritage Convention to protect the Outstanding Universal Value of the Greater Blue Mountains Area. No credible economic impact assessment has modelled this long-term damage.
7. ACCOUNTABILITY
Those who assert in this EIS that bushfire risk, traffic safety concerns, and ecological impacts are absent or manageable must be held formally accountable if those assessments prove to be incorrect. I call on the Department to ensure all technical assessments are independently peer-reviewed by parties with no commercial connection to the proponent, and that the identities of all consultants providing key risk assessments are publicly recorded as part of the determination.
8. ALTERNATIVE OUTCOME
Should the Department not refuse this application outright, I submit that any approval must require a fundamental redesign of the project to comply fully with the Blue Mountains Local Environmental Plan and Development Control Plan, including the applicable height limits, floor space ratio, setbacks, and tree retention requirements. The project, in its current form, uses the HDA pathway specifically to circumvent these local regulations. Any development on this site must be genuinely consistent with the rules that apply to every other landowner in Katoomba and must not be permitted to benefit from a regulatory exemption that serves the commercial interests of the proponent at the direct expense of the local community and environment.
REQUESTED ACTIONS
I request that this application be refused. If not refused, I request that any approval require a fundamental redesign consistent with the Blue Mountains LEP and DCP. In either case, I request: an independent RFS bushfire evacuation assessment; an independent traffic and pedestrian safety assessment; binding Transport for NSW service commitments; an independent ecological assessment; a long-term tourism economic impact assessment; formal Blue Mountains City Council involvement; and an assessment of consistency with Australia's World Heritage Convention obligations.
Please refer to the attached formal objection letter for full details on each ground of objection.

This project is a massive overdevelopment of the site, completely out of keeping with the character of Katoomba and in no way serves our community.
Having read through the exhibition documents of this proposal, I wish to draw attention to the weakness of claims made in the ‘Community and Stakeholder Engagement Report’. The extent to which the local community was informed and consulted about this project is grossly overstated and is a misrepresentation of the efforts genuinely made by the company engaged to perform this community consultation. The report tells of a website and social media site both established in order to enable the community to provide feedback, yet the existence of both the development proposal and these websites was not made highly visible within the community. The supposed 1,600 flyers distributed within a radius of 2km of the site purposely limited knowledge of this development to the outskirts of the town of Katoomba, ignoring the broader community. Why were these leaflets not more widely distributed annd displayed? Also, those I have spoken to who reside within the inhabited section of the indicated radius (more than half this area is bush) have no recollection of these supposed flyers. The claims of community consultation within this report are entirely disingenuous.
A development of this scale is a watershed moment for development within our township and accordingly the developers ought to have sought to act in complete transparency and consultation with the community as the law requires. Why was there no full page ad in the widely read local paper?
This development intentially proceeded under a cloak of secrecy with the developers by-passing legitimate community consultation and by passing local development restrictions with a clear intention to profit from over development at the expense of the amenity of all who already live in this neighbourhood.
In the Visual Impact Assessment, at statement 2.3 a claim is made the ‘area is undergoing streetscape upgrades to improve infrastructure and public amenities, with a focus on both historical presentation and “modern urban design.”’
Was this a convenient assessment by a visiting consultant? It seems highly inaccurate as a description of either the character of the surrounding residential streets and also the heritage streetscapes of Katoomba town. There is no “modern urban design” in an area that cannot be described as “urban”. The neighbourhood that the development will loom over is predominantly single story, quarter acre (and bigger) blocks. To put these eight four story apartment blocks in this neighbourhood is truly an extraordinary proposal. 218 apartments in an area with no existing apartments is not an acceptable shift in local character.
I would further argue that this development is not within walking distance of town and is not a desirable sort of lifestyle for Blue Mountains locals. People do not live here because they want to live in apartments. Katoomba already has an adequate number of apartments within comfortable walking distance of the town. These never sell immediately when they become available for sale which indicates that apartment living is a very limited proposal in this location.
That the developers want to retain a quarter of these apartments as serviced apartments further indicates that they are not interested in benefitting the local community, but instead wanting to prioritise profits gained from the tourism market.

Put plainly, we don’t want this sort of overdevelopment in Katoomba. That the State Planning authority has allowed an entity with no ties to the Blue Mountains to come in and distort the character of our locality is unacceptable. It disregards those who do live here. We do not want this level of development in our neighbourhood. These sort of buildings belong on the Greater Sydney rail corridors, not on the edge of a UNESCO listed National Park.
The mind boggles that this development proposal was granted SSD status.