Subject: Objection to SSD-90134958 – 100 Edinburgh Road, Castlecrag
I am writing to formally lodge my objection to the proposed State Significant Development at 100 Edinburgh Road. While I understand the need for housing, the scale of this specific proposal is completely unsuitable to this location. It represents a massive overdevelopment that ignores local planning rules and will cause long-term damage to the character and safety of Castlecrag.
1. Excessive Height and Scale
The developer is asking for a "radical departure" from what is currently allowed on the site. To put this in perspective:
• Floor Space: They are asking for is roughly 2.5 times the current limit.
• Height: They are proposing towers that are roughly 3 times the current limit.
This is not a small adjustment; it is an attempt to build something more than double the allowed height in an area that is simply does not have the infrastructure to support it.
In attempting to justify this uplift they have referred to the National Housing Accord but the supporting documents show no evidence based justification for the uplift.
It should be noted that even for NSW government targeted development sites under the TOD (which this is not) the allowable uplift is only 1.3 times the height and FSR limits and for this uplift the developer needs to provide 15% affordable housing.
Given that given they are only offing about 6% affordable housing (for 15 years) when the NSW governments own requirements is a 10 % minimum to access any uplift indicates this is not a development seeking to support the states housing goals but one seeking to profiteer from the situation.
2. Failure to Follow Mandatory Planning Rules
The current planning rules for this site (the Willoughby Local Environmental Plan 2012) require that at least 20% of the building be used for non-residential purposes, like shops or offices. This proposal only provides 16.5% non-residential space. The developers have not filed the necessary legal paperwork (a "Clause 4.6 Variation") to address the noncompliance.
3. Traffic and Safety Risks
Castlecrag is a peninsula with only two ways in and out: the intersections of Eastern Valley Way with Edinburgh Road and Sunnyside Crescent. Both of these are already failing (rated "Level of Service F").
• Unrealistic Traffic Data: The developer's traffic report assumes many residents will use a rail network that doesn't exist in Castlecrag and that 75% of shoppers won't need to cross the main road. These assumptions are not based on reality.
• Emergency Access: Adding hundreds of extra car trips to a "fragile" road system risks "locking" residents and emergency vehicles in or out of the suburb during peak times if a single accident occurs.
4. Damage to Heritage and Character
Castlecrag is world-famous for the vision of Walter Burley Griffin, who designed the area so that
buildings would be "subordinate to the landscape."
• Visual Dominance: Instead of being hidden by trees, these 14-storey towers will stick out eight storeys above the tree canopy.
• Gateway Impact: This site sits at the "gateway" to the Griffin Heritage Conservation Area. Placing two bulky high-rise towers here destroys the intended relationship between nature and architecture that makes our suburb unique.
5. Overshadowing and Loss of Privacy
The height of these towers will cause significant overshadowing for neighbours to the south. Some homes risk losing meaningful sunlight for up to six months of the year. Even the internal design is poor, with 45 of the proposed apartments receiving zero direct sunlight on the shortest day of the year.

Conclusion: This proposal prioritizes developer profit over the safety, heritage, and livability of our community. It seeks a massive increase in building size without providing the infrastructure or public benefit to match. I urge the planning authority to refuse this application.

Submitted by: Jim Gaha
Date: 6 May 2026

I am a local resident and write with qualified support of SSD‑90134958, the proposed mixed‑use development at 100 Edinburgh Road, Castlecrag.
This proposal should be considered in the broader context of years of planning paralysis, missed opportunities, and an urgent need to deliver housing and revitalise the Castlecrag town centre.
It is important to understand the recent history of the site. The Quadrangle redevelopment has been subject to myriad redesigns, resubmissions, and ownership changes, alongside extensive consultation without resolution. The result has been significant delays that have left the community without a thriving centre.
The more modest scheme led by Dr Stanley Quek underwent detailed design and consultation yet was slowed by process and opposition. The outcome has been prolonged stagnation rather than new houses, retail offerings and community facilities.
This demonstrates that agitation by a minority of local residents has not protected the status quo, instead it has actively degraded it by preventing renewal and prolonging uncertainty.
In this context, the State Significant Development pathway is appropriate, and a very necessary step taken by the Planning Minister.
The earlier Quek redevelopment offered a balanced outcome including housing and revitalised retail. However, despite extensive effort, it became caught in process and delay, driven by the aforementioned minority of residents who put self-interest before community benefit.
And it can now be clearly illustrated that where positive change is repeatedly resisted, pressure for development does not disappear. Instead it accumulates. The current proposal is part of a longer trajectory shaped by earlier decisions, and those who had influence in the earlier decisions must take responsibility for the current situation.
It is widely recognised that increasing density in established suburbs is inevitable if Sydney is to meet future housing needs. The alternative is continued sprawl at the city’s edges, with higher infrastructure and environmental costs.
Castlecrag does not have the right to remain static while other suburbs pull their weight.
I will now outline the reasons for my qualified support of the proposal:

1. Housing access in a tightly held suburb
Castlecrag has very limited housing diversity, with an absolute dominance of detached dwellings. This has made it challenging for younger people, downsizers, and key workers to access the suburb.
The Conquest proposal has the capacity to introduce new dwelling types and improves accessibility, enabling a wider range of people to live in Castlecrag.
2. A more inclusive and balanced community
Castlecrag’s exclusivity has created a relatively narrow demographic profile. Increasing housing diversity will contribute to a more inclusive and balanced community and foster a stronger culture of shared public space.
3. Revitalising the village centre
The site is an important local hub. That it has been not much more than a boarded-up hole for some years has been a terrible outcome for local residents. The proposal will deliver new retail, dining, and commercial opportunities, increase activity throughout the day and evening, and restore vibrancy and become a feature of the suburb.
4. Appropriate location
The site sits outside the Griffin Heritage Conservation Area, making it a suitable location for increased density where impacts can be managed and balanced with design quality. DPHI must have strong influence over the design in this regard.
5. Economic and public benefits
The development will create jobs during construction and operation, improve services, and support better use of existing infrastructure. It aligns with broader planning goals to locate housing in established areas rather than expanding outward. The significant increase in retail footprint will also lead to more ongoing jobs in the neighbourhood.

It is important to acknowledge that repeated opposition to successive proposals has contributed to the current situation. Earlier, more moderate schemes encountered resistance, which have helped shape the scale and nature of what is now proposed. The ongoing resistance and ‘Not In My Backyard’ approach have led us to this outcome.
All that said, the next stage of the SSD process must give careful consideration and attention to the following:
• Built form and architectural quality
• Traffic and parking impacts. This is of high importance to ensure that the Edinburgh Rd-Eastern Valley Way intersection does not become a complete mess.
• Public domain design
• Amenity considerations such as privacy and overshadowing
I strongly encourage DPHI to address these matters very strongly through the conditions of consent and the development of the detailed design.

SSD‑90134958 represents a necessary step forward, and one that the Castlecrag NIMBYs must take some responsibility for. It addresses NIMBY-driven planning stagnation in the area and, at the same time and importantly, improves housing accessibility and restores necessary community facilities.
It also reflects the broader reality that well-located suburbs such as Castlecrag must embrace support Sydney’s growth, rather than be islands of retreat for wealthy and self-interested Boomers. Lower the drawbridge.
For these reasons, I support this application.

I object to the proposed development as its height, scale and intensity are not consistent with the established planning framework and would give rise to unacceptable impacts on local character, heritage setting, and surrounding infrastructure. In its current form, the proposal should be significantly scaled back to better align with the approved scheme for the site.

A development consent (DA-2024/13) already exists for a lower-scale mixed-use outcome of approximately 3–5 storeys. That approval demonstrates that the site can accommodate development in a way that is responsive to its environmental and heritage context. By contrast, the current proposal at 12 to 14 storeys represents a substantial intensification that departs from that established and more appropriate built form outcome.

The site is located immediately adjacent to the Griffin Conservation Area, a place of recognised heritage value. The proposed tower form is inconsistent with the Griffin design philosophy, which seeks buildings that sit within and respond to the landscape rather than dominate it. A development of this height and bulk would undermine those principles and diminish the established character of the precinct.

There is also a clear misalignment with relevant planning controls and strategic direction. Height expectations in the locality are generally in the order of three storeys above Edinburgh Road, and the site is not identified as a strategic housing growth area under state or local planning strategies. It is also located outside the Low and Mid-Rise Housing Policy area, being more than 800 metres from the Northbridge local centre, and is not within a transport-oriented development precinct. Public transport options are limited, particularly outside peak periods, and the site has no reasonable proximity to a rail station.

Given this context, the proposed scale would place additional pressure on local infrastructure. In particular, it would generate increased traffic movements within an already constrained road network, contributing to congestion, reduced safety, and potential delays for emergency access.

The broader planning implications are also significant. Approval of a high-rise form in this low-rise suburban setting would risk establishing an undesirable precedent, weakening the intent and effectiveness of existing planning controls. In addition, the proposal does not appear to deliver a clear public benefit in terms of housing affordability, with indications that it is directed toward higher-end market housing.

In summary, the proposal is not well matched to its context, exceeds the intended planning envelope, and would create avoidable transport and heritage impacts. It should be revised downwards in height and massing to a form more consistent with the approved 3–5 storey development and the surrounding area.

I write to formally object to the proposed development for 100 Edinburgh Road, Castlecrag. I grew up in Castlecrag and spent the first 26 years of my life in the area, and I raise the following substantive planning and amenity concerns as echoed by many concerned community members. These issues, in my view, warrant refusal of this proposal in its current form.
1. Bulk, scale and heritage impact
• The proposal’s bulk, massing and scale are not in keeping with the character, heritage and conservation values of Castlecrag. Castlecrag is a low-rise, landscape-driven precinct with a strong heritage and conservation overlay. The proposed development would dominate the streetscape and surrounding neighborhood, eroding the visual and historical character that the conservation area is intended to protect. The scale is inconsistent with the existing rhythm of houses, local topography and the precinct’s planned outcomes.
2. Inadequate public transport and unsustainable car-dependency
• Castlecrag is not well serviced by public transport: there is no rail or metro service, and bus services are already under pressure in frequency and capacity. Given this limited public transport availability, the scale of the proposed development would substantially increase car-dependency and traffic within a precinct that lacks realistic alternatives to private vehicles.
3. Road network constraints — single access route
• There is effectively one primary road in and out of Castlecrag. That single access route cannot safely or efficiently absorb the additional vehicular movements generated by a building containing approximately 150 apartments. The proposal would exacerbate congestion, increase travel times for residents, and create safety concerns for emergency access and local traffic circulation.
4. Insufficient provision and design of affordable housing
• While any contribution to affordable housing is welcome, the proposal includes only 10 apartments designated as affordable housing — an amount that is inadequate given the development’s scale. Additionally, the proposed affordable units are sited and designed with poor solar access and lack adequate sunlight, raising legitimate concerns about liveability standards and compliance with best-practice amenity guidelines.
5. Misleading and materially incorrect statements in the developer’s submission
• The applicant, Conquest, has made statements in their submission that are misleading and materially incorrect. In particular, the assertion that this proposal is merely a “modification” of an existing approved scheme is not supported by the substantial changes to scale, footprint, built form and outcomes. There are numerous planning, design and environmental differences that confirm this is a new and materially different proposal, not a minor modification. This mischaracterisation prevents proper public scrutiny and appropriate assessment against current planning controls.
6. Lack of genuine community consultation
• The developer has not engaged in genuine, transparent community consultation and has not meaningfully taken on board the clear and consistent feedback from local residents and interest groups. Community consultation must be more than a formal requirement — it must be substantive, responsive and demonstrably reflected in design changes. That has not occurred.
For the above reasons I request that the proposal be refused in its present form. The previously approved DA was an appropriate scale and size for Castlecrag and the site, I request that nothing larger be entertained.

The original plans for this project would have been appropriate for the site however the increased number of apartments and height of the ‘towers’ in the new submission are completely wrong for the area.
I do not believe residents in Castlecrag and surrounding suburbs are anti development however it needs to be in harmony with the environment which the lower rise option would be. The proposed new development with higher towers will look completely out of place and further set a very concerning precedent for the future.

Mr AA and Mrs SJ Kelton
353 Edinburgh Road
Castlecrag NSW 2068
4 May 2025
NSW Independent Planning Commission
NSW Department of Planning, Housing and Infrastructure
Lodged via NSW Planning Portal — Major Projects
Project: Mixed-Use Development — 100 Edinburgh Road, Castlecrag
FORMAL OBJECTION — SSD-90134958
Castlecrag mixed used development
Proposed 13–14 Storey Towers at 100 Edinburgh Road, Castlecrag
Dear Members of the Commission,
We write as long-standing residents of Castlecrag, residing at 353 Edinburgh Road —
within the immediate vicinity of the proposed development at 100 Edinburgh Road — to
formally and strongly object to the State Significant Development application submitted by
Conquest for the construction of two residential towers of 13 to 14 storeys on this site.
We wish to be unequivocal: we are not opposed to development in Castlecrag. Our
community previously supported and welcomed a thoughtfully designed 3-storey proposal
for this very site, which had been endorsed by Willoughby Council. What we strenuously
oppose is this profoundly inappropriate, grossly oversized proposal which bears no
relationship to the scale, character, heritage, or environment of our suburb.
GROUNDS FOR OBJECTION
1. Scale and Built Form — Grossly Disproportionate to the Locality
The proposal to replace an approved, community-endorsed 3-storey development with
twin towers of 13 to 14 storeys represents an increase of more than four times the
previously acceptable scale. This is not incremental densification — it is a fundamental
and irreversible transformation of the built environment of our suburb. There is no
precedent anywhere in the Castlecrag streetscape for development of this scale, and
nothing in the surrounding residential context that could absorb or justify it. The towers
would dominate the ridgeline, cast significant shadow across neighbouring properties and
public reserves, and permanently alter the visual landscape of one of Sydney's most
cherished and carefully designed suburbs. It isn’t even with in keeping with the
surrounding buildings along Eastern Valley Way!
2. Heritage Significance — A National Treasure at Risk
Castlecrag is renowned for being heritage listed and having eco-conscious architecture
designed by Walter Burley Griffin and his wife Marion Mahoney Griffin and is a suburb of
world significance, home to 35 heritage-listed items and widely recognised as one of the
earliest and most important examples of integrated landscape and residential planning
anywhere in the world.
Towers of 13 to 14 storeys sited on the ridgeline would be entirely incompatible with this
extraordinary heritage setting. They would overshadow, dominate, and permanently scar
the Griffin legacy that generations of Castlecrag residents — and many thousands of
visitors — have cherished. We respectfully urge the Commission to give the fullest
possible weight to the cultural, architectural, and historical significance of this landscape
when assessing this application.
3. Traffic and Infrastructure — A Suburb Not Built for High-Density Living
Castlecrag is served by a single-lane-in, single-lane-out road network that was deliberately
designed to limit through-traffic in keeping with Walter Griffin's vision. The nearest train
station is 4 kilometres away. The road infrastructure, public transport access, and
community services in Castlecrag are entirely inadequate to support 150 additional
apartments and the vehicle movements they would generate. We already feel the build up
of congestion during peak hours on Edinburgh rd. With Castlecrag being in a bushfire zone
this also adds to the concern of exiting safely. We have experienced a bushfire situation in
Castlecrag and if the wind had picked up it would have ravaged many houses quickly. This
proposal has not been assessed against any genuine transport impact study appropriate
to the locality, and we are concerned that the designation of this site as State Significant
Development — when it does not appear to meet the government's own criteria — sets a
precedent that circumvents proper local planning controls.
4. Public Benefit — Luxury Apartments Do Not Address Housing Need
We note that this proposal offers only 10 below-market-rate apartments from a total of 150
— less than 7% of the development, and available below market rate only for a limited
period. The remaining 140 apartments are luxury dwellings designed to generate profits for
a private equity firm headquartered overseas. This development will do nothing meaningful
to address Sydney's housing affordability crisis. The Commission should weigh carefully
whether the granting of State Significant Development status — a mechanism intended to
facilitate projects of genuine public benefit — is appropriate for a development whose
primary purpose is the enrichment of offshore investors.
5. Process and Consultation — The Community Has Not Been Heard
There has been no meaningful community consultation by the developer at any stage of
this proposal. Residents who made direct contact with Conquest received no response. A
development of this scale and significance — on a site in a heritage suburb with no
comparable precedent — demands genuine, transparent, and good-faith engagement with
the community it will most directly affect. The absence of any such process is deeply
troubling and should weigh heavily against approval.
CONCLUSION
Castlecrag is an irreplaceable part of Australia's cultural, architectural, and natural
heritage. The Griffin legacy does not belong to any one generation of residents — it
belongs to all Australians, and to the world. We call on the NSW Independent Planning
Commission and the Department of Planning to refuse this application in its current form.
If a revised application is to be considered in future, we urge the government to require
that it respects the 3-storey scale previously approved and endorsed by the community,
incorporates genuine heritage assessment, provides independent ecological and traffic
impact studies, and is subject to meaningful community consultation from the outset.
We respectfully request that this submission be recorded in full and given due weight in
the assessment of this application. We are happy to provide further information or attend
any hearing in support of this objection.
Yours faithfully,
Mr AA Kelton & Mrs SJ Kelton
353 Edinburgh rd, Castlecrag NSW

I have lived in Castlecrag for over 20 years and raised my family here. My husband and I were drawn to the suburb because of its heritage, beautiful bushland setting and the shared open spaces and walkways. I’m horrified by the current DA submitted by Conquest and have outlined my main objections below:
I love Walter Burley Griffin’s philosophy for Castlecrag. He had a strong respect for the natural environment and wanted to develop a sustainable, community-oriented suburb where the built form took a back seat to the landscape. His vision was to integrate homes into the bushland setting of Middle Harbour, using shared open areas, eliminating fences, and relying on natural materials to encourage a unified and peaceful living environment.
The Conquest DA does not respect Burley Griffin’s philosophy nor that of the Castlecrag residents, the majority of whom have chosen to live in this special suburb because of Burley Griffin’s insightful vision. In my opinion the current DA could permanently damage Castlecrag’s historic character and heritage value.
A few years ago the community approved a DA for a lower-scale, mixed use project that was 3-5 storeys. The design nestled into 100 Edinburgh Road and respected the surrounding area. Most specifically the Griffin Conservation area, which is right next door. The community understand there is a need for more housing in Sydney and importantly affordable housing. We are not NIMBYs. We approved Dr. Quek’s DA and everyone was excited to have a development that was in keeping with the surrounding heritage and streetscape. It was an award-winning design that did not dominate the ridgeline, respected Griffin’s philosophy, had minimal impact on the surrounding residents’ homes (which, under the Conquest design, will be shrouded in shade all day).
I would like the Planning Minister to review the setback requirements for the proposed Conquest development. I fail to understand how you can allow the residents on the southern side of the building (on Eastern Valley Way) to live in an environment that is in constant shade for long periods throughout the year. People need sunlight for their well-being and mental health. These poor residents will have that luxury taken away from them.
Please tell me how a bulky, overwhelming construction of 13-15 storeys, proposing 150 apartments has achieved any kind of compliance. I can list several areas where there has been non-compliance and no disclosure from Conquest.
• Have Conquest met the zoning and statutory controls. No! The proposal exceeds E1 Local Centre expectations.
• Castlecrag is not a hub for any kind of transport except for the bus services which are limited, infrequent and quite often arrive at my bus stop full, so I am unable to get on.
• Castlecrag’s zoning structure is explicitly non-growth and heritage-sensitive.
• Conquest plan to remove 19 live trees! Nearly half of all live trees on the site.
• Castlecrag is not identified as a housing growth area in state or local planning strategies.
• My family and I live at 22 Sunnyside Crescent. This narrow street is already a rat-run for early morning tradies and local traffic trying to avoid the current congestion on Edinburgh Road. There is no footpath on either side of the street, so mums with prams and young children riding bikes are forced to walk/ride on the street. The current proposal will see an enormous uplift in the number of cars travelling along the street and will create significant safety risks.
I'm distressed by the current DA put forward by Conquest. Please contact me if you need any further clarification of my concerns. I hope the DA will be reviewed taking into account my concerns, and those of my fellow residents.
Ingrid Graham
22 Sunnyside Crescent
Castlecrag
Mobile: 0401 733 830

Objection to State Significant Development Application SSD-90134958 – 100 Edinburgh Road,

Mr Kieran Thomas,
Director, Housing Delivery Assessments,
4 Parramatta Square
PARRAMATTA, NSW, 2124

Dear Mr. Thomas,

I am writing to formally and strongly object to the proposed State Significant Development (SSD-90134958) at 100 Edinburgh Road, Castlecrag. As a local resident directly impacted by this proposal, I urge the consent authority to refuse this application.

The proposal represents a severe overdevelopment of the site that is fundamentally incompatible with the established character, heritage, and environmental constraints of Castlecrag.

My objection is grounded in established planning principles and precedents where the Independent Planning Commission (IPC) and the Land and Environment Court have refused SSD applications due to incompatibility with the site, and adverse social and environmental outcomes.

1. Incompatibility with Site
The proposed 11-to-12-storey structure is grossly disproportionate to its surroundings. Positioned prominently on the ridge at the top of the hill, it will be the highest building within a 2.6km radius, towering over eight times the height of all existing residential dwellings, and situated on the highest point in Castlecrag. This massive scale will create a severe visual eyesore, dominating the skyline and destroying the subservient relationship between the built environment and the natural landscape that defines Castlecrag.

The community had reasonably anticipated a 4 storey development, consistent with the original Development Application (DA) and the historical 2-storey scale of the site. All surrounding developments on Eastern Valley Way have been constrained to a 3 storey limit, which raises the question of fairness.
The current proposal disregards this context entirely. Precedents such as the refusal of the *Rocky Hill Coal Mine* and the *Crookwell 3 Wind Farm* demonstrate that unacceptable visual impacts on a scenic and cultural landscape, combined with incompatibility with existing land uses, are robust and independently sufficient grounds for refusal.

2. Destruction of Unique Heritage
Castlecrag is a unique, historic peninsula suburb designed a century ago by Walter Burley Griffin. His visionary town planning ensured that buildings followed the steep, rocky contours of the land, allowing every dwelling access to sunlight and views. This SSD directly contravenes these foundational principles.
The sheer bulk of the building will cause severe overshadowing of the residences below and cast intrusive night lighting over the adjacent nature-scape, and appear like a lighthouse to all residents within 2.6kms.
Approving this development would set a dangerous precedent, encouraging further high-rise development along Eastern Valley Way and permanently dismantling the conservation values of the precinct.

3. Inadequate Infrastructure and Severe Congestion
The proposal fails to account for the severe infrastructural limitations of Castlecrag. The suburb relies on a single set of traffic lights, creating a well-known choke point on Edinburgh Road — the area's only major arterial route. The local road network, characterised by narrow streets and a near-total absence of pedestrian footpaths, is already under immense pressure.
The addition of hundreds of new residents, alongside delivery vehicles and visitors, will exacerbate existing traffic blockages at key intersections: including The Postern and at Sortie Port, which already impose right-of-way constraints on residents living in The Parapet, The Rampart, The Battlement, The Citadel, The Scarp and surrounding streets.
The KU Pre-school at 10 The Postern with 50 young children enrolled adds further daily pedestrian and vehicle movement to this already strained network.
With no train or metro stations between Crows Nest and Palm Beach, and limited bus services, the area cannot support the traffic generation of an 11-storey high-rise. The failure to provide adequate parking and the resulting pressure on local amenity constitute a significant and unacceptable social impact — a factor heavily weighted in previous SSD refusals.

4. Unacceptable Environmental and Biodiversity Impacts
The Environmental Impact Statement details the removal of a significant number of established canopy trees. Willoughby City Council has spent decades protecting this tree canopy, which serves as a vital wildlife corridor connecting to Garigal National Park. The local ecosystem supports a rich diversity of native fauna, including echidnas, water dragons, lace monitors, wallabies, bower birds, mopokes, powerful owls and lyrebirds. The destruction of this habitat for a high-rise development is unacceptable and directly contradicts the principles of ecologically sustainable development (ESD). The IPC has consistently refused projects where the environmental impacts of land clearing and habitat destruction were deemed unacceptable and inadequately assessed.

5. Lack of Social Licence and the Public Interest Test
This proposal appears to be driven by private equity interests with no long-term stake in the Castlecrag community. If approved, it would reward speculative overdevelopment at the direct expense of the local community's amenity, privacy, and quality of life — transferring the benefits entirely to external investors while the costs of noise, overshadowing, traffic and visual intrusion are borne permanently by residents.
This is precisely the kind of inequitable distribution of costs and benefits that the IPC and the Land and Environment Court have identified as contrary to the public interest. The local community has already endured extended noise and dust pollution from the stalled excavation of the originally approved 4-storey DA over the past 6 months.
Delaying the much-needed reopening of the local shopping centre to accommodate an unjustified additional 8 storeys of luxury apartments — with no demonstrated community benefit — is entirely contrary to the public interest. The Land and Environment Court and the IPC have established that overwhelming community opposition and the absence of social licence are critical factors in assessing social impact and determining whether a development should proceed.

Conclusion

The natural and built environment of Castlecrag is a carefully maintained legacy that deserves protection from opportunistic overdevelopment.
This SSD application fails on multiple planning fronts: it is visually obtrusive, incompatible with the local heritage character, environmentally destructive, unsupported by local infrastructure, and serves the financial interests of private equity at the community's expense.

I respectfully request that the consent authority refuse SSD-90134958 in its entirety and require the developer to proceed with the originally approved, community-appropriate development.

I am formally objecting to the State Significant Development Application for a mixed-use building on the corner of Edinburgh Road and Eastern Valley Way, Castlecrag. This proposal completely ignores the current building rules, is totally out of place for our heritage area, and will cause serious problems for local traffic and our quality of life. I believe the Minister must refuse this application because it breaks the law, will cause major negative impacts, and is not in the community's interest. I object based on the legal grounds of non-compliance, likely impacts, and public interest.
1. Building Height is Way Too Tall and Breaks the Rules

The plan for two 11-story towers (13 stories high in total, 48.96 metres) is way too tall and violates the current height rules.
Rule Breaking: The proposal is 5.4 times higher than the legal 9-metre limit in the Willoughby Local Environmental Plan (LEP) 2012. Our local rules (DCP 2023) say the local centre should be capped at just 3 stories along Edinburgh Road.
Legal Loophole: Approving a building 5.4 times the height limit, based on a zoning change that hasn't even been finalized or properly discussed with the community, is a misuse of power.
Applicant’s Admission: “The proposed development will exceed the maximum number of storeys prescribed”.1

2. Intersection is Already Failing and Traffic Impact is Unknown

Adding 150 new apartments and 376 parking spots will make the already terrible traffic at the Edinburgh Road / Eastern Valley Way intersection much, much worse.
Gridlock: The intersection is already completely jammed up (it operates at a failing level in the morning peak).
Uncertain Impact: The developer failed to measure the full impact of 150 new homes on this struggling intersection because their traffic model couldn't handle the existing level of failure.
Applicant’s Admission: The SIDRA traffic model output “is not representative” at LoS F.1

3. Maximum Size Sought for Minimal Affordable Housing Benefit

The developer chose a loophole that lets them build as big as possible (4.2 times the maximum size allowed by the LEP Floor Space Ratio) in exchange for a tiny, temporary affordable housing contribution.
Not Enough Affordable Homes: The proposal offers only 10 affordable apartments out of 150 (a small 6.67 per cent) and only for 10 years. The commitment is 5 years short of the 15-year minimum required for this kind of bonus density, and the units revert to high-priced luxury homes after that time.
Public Interest: It is unfair to grant permission for a building 5.4 times the height and 4.2 times the size allowed by law in exchange for such a small, short-term community benefit.
Applicant’s Admission: “Option 4: Proceed with HDA scheme which includes greater density than that which would have been allowed under Infill Affordable housing provisions, as well as a lower affordable housing component”.1

4. Developer’s Own Survey Confirms Community Opposition

The developer's own public survey proves that the community is overwhelmingly against this plan, which completely shuts down any claim that the proposal is supported or acceptable.
Survey Results: The developer’s own 66-respondent survey found:
89 per cent were worried about height and size.
83 per cent were worried about traffic.
83 per cent were worried about local character.
Community Distress: The developer’s social consultant warned that residents felt "disenfranchisement" (ignored) as a “Very high negative” social impact and observed “significant frustration and distress” at the community session.
Applicant’s Admission: “89 per cent were concerned about height and scale”.1
How the development affects me

[I am young adult desperate to get into the property market and even i see the breach of power and the unrighteousness present in this case. I commute to university daily and have to endure the poor intersection and this development will only ruin it further. the building height is unacceptable and in breach and should not be approved.

Relief Sought

I ask the Minister to refuse the application. Alternatively, I ask that the application be put on hold until a proper Planning Proposal is exhibited and that the matter is sent to the Independent Planning Commission for a public hearing.

As a resident of Castlecrag, I would like to strongly oppose this proposal in its current format.
Whilst I acknowledge that development of the 100 Edinburgh site is needed and welcomed by myself, this new proposal is completely out of character with the surrounding community in its sheer size, magnitude and bulk. There is nothing of its kind as far as the eye can see and I don’t believe that Castlecrag is the spot for something of such enormity particularly as it sits at the top of a ridge.
Castlecrag is not a town centre, it is a village. One road in and out, low rise, low density housing, abundant flora and fauna, large areas of bush land, no footpaths and it is not set up to support the additional 150 dwellings proposed by Conquest.
It’s is not a transport hub, nor is it supported well by public transport. No train, light rail nor metro lines, not even bike lanes. Existing bus services are minimal, already nearly at capacity by the time they get to us (heading into the city) in the mornings and scant at weekends. There is not enough public transport options for the additional numbers of units being proposed, nor is there schooling or health infrastructure in the local area where all local schools are at capacity, hospitals have massive wait times already and gp’s don’t have appointments for weeks.
The current intersection at eastern valley way and Edinburgh road is already failing with lines of traffic backed up at peak hour and I am already taking my life into my own hands trying to turn right out of my street (Raeburn Ave - directly opposite the proposed development) in the morning to get to work without the added pressures of construction traffic and additional residential and commercial traffic. It is a safety concern and an accident waiting to happen. It does not appear that there has been any consideration of this when these plans were made.
Shadow diagrams indicate huge areas of the village will be affected by these looming towers casting the area into darkness.
There are perfectly acceptable plans already approved of for this site (which we were told would be “upheld” by Conquest when they purchased the site). Proposing something four times as large is not an “amendment” to the existing plans it is a complete abuse of the system. “Community consultations” have consisted of one limited ticket event with minimal information and a second (requested by NSW planning) held out of the area and at which participants were actually told it was a “tick box exercise” and “nothing would be changed” There has been no consideration of the local community who are keen to get development of this site underway - the right development, not development at any cost and not development that is not going to improve this local area but merely line the pockets of greedy developers.