Re: Objection to the Proposed Development — Eileen O’Connor Catholic School, 84 Gavenlock Road, Mardi (SSD 67173718)
Dear Sir/Madam,
I am writing to object to the proposed development of a three-storey school at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and its technical appendices, I submit that the development is fundamentally flawed, legally non-compliant, and unsafe, and should be refused in its current form.
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1. Traffic and Road Safety Impacts
• Underestimated Traffic Generation: The Transport & Accessibility Impact Assessment (Appendix R, pp. 31-42) fails to model school peak periods. Queuing and congestion on Keefers Glen and Gavenlock Road are ignored, contrary to SEPP (Transport & Infrastructure) 2021 cl. 2.111, which requires safe and efficient transport outcomes for educational facilities.
• Inadequate Road Capacity Assessment: Keefers Glen is a narrow residential cul-de-sac. Benchmarking against regional arterial roads is misleading and breaches DCP 2022 Ch. 3.1 (Car Parking & Access), which requires context-based assessment.
• Pedestrian & Cyclist Safety Ignored: No safe crossing points or separated foot/cycle paths are proposed, breaching the Austroads Guide to Road Design (Part 6A) and exposing children to risk.
• Parking Deficiency: On-site parking falls short of DCP 2022 minimum ratios, ensuring overspill into Keefers Glen.
• Construction Traffic Deferred: The Preliminary CTPMP (Appendix T, p. 6) defers construction traffic planning until a builder is appointed, breaching EP&A Regulation 2021 Sch 2, cl. 6.
• Cumulative Impacts Ignored: The report does not assess traffic interaction with St Peter’s Catholic College, in breach of EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe and inadequate traffic planning, inconsistent with statutory and local planning controls.
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2. Noise and Acoustic Amenity
• Baseline Monitoring Deficient: The Noise & Vibration Assessment (Appendix U, pp. 17-18) is based on short-term monitoring, not the 7-day standard required by the EPA Noise Policy for Industry 2017 (NPfI).
• Outdoor Noise Underestimated: Intermittent, high-level playground and PA system noise was ignored, contrary to EPA guidance.
• After-Hours Use Excluded: The report concedes that evening/weekend use of facilities (sports, assemblies, community hire) has not been assessed (Appendix U, p. 26), breaching EP&A Act s.4.15(1)(b).
• Vague Mitigation Measures: Generic references to barriers provide no enforceable design, breaching DCP Ch. 3.3 Noise & Vibration.
• Construction Noise Ignored: No modelling against the Interim Construction Noise Guideline (DECC 2009), contrary to regulatory standards.
• Cumulative Noise Ignored: Noise from St Peter’s College has not been combined with the assessment.
Ground for refusal: Non-compliance with NPfI 2017 and ICNG 2009, leading to unacceptable amenity loss.
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3. Flood Risk and Emergency Access
• The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.
• The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
• The school is designed for children with disabilities, who may require assisted evacuation. Approval without proven evacuation safety risks breach of the Disability Discrimination Act 1992 (Cth) and the EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe flood evacuation and non-compliance with statutory floodplain management guidelines.
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4. Bushfire Emergency Management
• The Bushfire Emergency Management Plan (Appendix RR) confirms reliance on Keefers Glen as the sole access route. Planning for Bushfire Protection 2019 (PBP) requires dual safe evacuation routes for vulnerable uses.
• The interaction of flood and bushfire risks has not been assessed, contrary to NSW RFS guidelines.
• Details of hydrant access, defendable space, and APZs are incomplete.
Ground for refusal: Non-compliance with PBP 2019 and failure to ensure life safety in concurrent hazard scenarios.
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5. Architectural Design, Height, and Privacy Impacts
The Architectural Design Report (Appendix I) describes the school as “predominantly two-storey” but in reality introduces three-storey built form at the northern ends of the wings. These sections will appear as full three-storey blocks when viewed from Keefers Glen and Brickendon Avenue, creating an imposing institutional bulk inconsistent with the surrounding one- to two-storey residential neighbourhood.
This bulk and scale directly conflicts with the planning intent of the Central Coast Local Environmental Plan 2022 and Development Control Plan 2022, which require new development to respect and integrate with the prevailing low-density residential character of Mardi.
Furthermore, the upper-level verandahs and learning spaces will enable direct overlooking into neighbouring backyards and homes, resulting in a significant loss of residential privacy. This impact breaches both the residential amenity provisions of the DCP and the broader objectives of the EP&A Act requiring protection of neighbourhood character and amenity.
Ground for refusal: Excessive building height, visual bulk, and overlooking, contrary to the LEP and DCP provisions for residential interface areas.
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6. Social Impact
The Social Impact Assessment (Appendix KK, p. 12) is biased towards benefits and fails to assess negative impacts, including:
• Loss of residential amenity and neighbourhood character,
• Increased noise and traffic danger,
• Reduced property values,
• Cumulative stress on local infrastructure.
This omission breaches EP&A Act s.4.15(1)(b) and (d), which require full consideration of social and economic impacts.
Ground for refusal: Incomplete and unreliable assessment of social impacts.
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7. Legal and Policy Non-Compliance Summary
The proposed development fails to comply with:
• EP&A Act 1979 s.4.15(1)(b) — inadequate consideration of environmental, traffic, safety, and social impacts.
• Central Coast LEP 2022 — inconsistent with local character and amenity objectives.
• Central Coast DCP 2022 — breaches in traffic (Ch. 3.1), noise (Ch. 3.3), privacy, and rural-residential character (Ch. 5.5.1).
• SEPP (Transport & Infrastructure) 2021 cl. 2.111 — inadequate traffic and safety outcomes.
• EPA NPfI 2017 & ICNG 2009 — flawed acoustic assessment.
• NSW Floodplain Development Manual 2023 — unsafe evacuation provisions.
• Planning for Bushfire Protection 2019 — inadequate bushfire evacuation and APZ design.
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Requested Outcome
I respectfully request that Council refuse the DA in its current form on the grounds of serious non-compliance and unacceptable risk.
Should approval be contemplated, Council must at minimum require:
• Independent peer review of traffic, noise, flood, and bushfire reports;
• Strict conditions limiting building height to two storeys along Keefers Glen;
• Enforceable acoustic barriers and restrictions on PA/bell usage;
• A prohibition on after-hours/weekend use unless subject to a separate DA;
• Proof of dual safe evacuation routes for flood and bushfire;
• Full compliance with DCP car parking ratios and additional on-site parking.
Conclusion
This proposal represents a serious threat to safety, amenity, and local character. It fails multiple statutory tests under the EP&A Act and associated instruments. I therefore urge Council and NSW Planning & State Development to refuse the DA in its current form.
Should Council nevertheless contemplate approval of this DA despite the serious concerns raised, I respectfully request that conditions of consent be imposed to mitigate direct impacts on my property, including, but not limited to:
• Relocation or redesign of the proposed driveway opposite my residence to prevent unsafe traffic conflicts;
• Installation of screening measures (fencing, landscaping, acoustic barriers) at the proponent’s expense to protect the privacy, safety, and amenity of my property;
• Any other works Council deems necessary to offset the adverse impacts of the proposed development.
Yours sincerely,
Dr. Shannon Bosshard

I am not against the school, I am against the idea of the entry and exit being on Keefers Glen. That street is not designed for the heavy machinery that will be required for this kind of construction let alone the buses that will be required for the school,
The traffic report is that was put in the proposal is incorrect that counter was installed at the end of school term and start of school holidays therefore not offering true representation of traffic flow and came undone from the road days after being installed so there is no way that report is true and should not be taken into account. What about the pedestrians and kids that play in the street? Has any of that been taken into account other than a section of foot path and widening part of Keefers Glen? I don’t believe this is a safe and viable option for the current residents of the surrounding streets when they could use Gavenlock rd as the entry and exit to the new school. What about the residents homes that will potentially be devalued by the entry and exit being put on Keefers Glen? No one can predict how this will affect home prices nor is anyone offering a reimbursement.
I really hope the entry and exit to this school is reconsidered for Gavenlock Rd as the Central coast council proposed. Again I’m not against the school I’m against the entry and exit point on Keefers Glen as are many of the Mardi local residents.
Yours sincerely, Another Keefers Glen resident.

Dear Sir/Madam,
I am writing to object to the proposed development of the Eileen O’Connor School at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and supporting documents, I consider the proposal to be fundamentally flawed in terms of traffic planning, drainage, and neighbourhood impact. On these grounds, I believe the development should not proceed in its current form.
1. Traffic and Road Safety Impacts
The most serious issue is the proposed school access from Keefers Glen, a narrow residential street that is not designed to handle high volumes of daily school traffic. This will inevitably funnel traffic into Brickendon Avenue, a street that already experiences heavy on-street parking. Vehicles are frequently forced onto the wrong side of the road to pass, which will only worsen with school pick-up and drop-off activity.
The situation becomes more dangerous at the intersection of Brickendon Avenue and Woodbury Park Drive, where visibility is already compromised by parked vehicles. Adding concentrated school traffic to this intersection poses a significant safety risk to both motorists and pedestrians.
The school site is directly accessible from Gavenlock Road, a much larger road designed for higher capacity traffic movements. It is strongly preferred by residents that this be used as the primary school entry point. Locating the access on Gavenlock Road would avoid overwhelming Keefers Glen and Brickendon Avenue, and would provide a safer and more appropriate solution consistent with planning requirements for context-sensitive traffic management.
The Transport & Accessibility Impact Assessment has not properly accounted for these realities, nor the cumulative traffic impacts of St Peter’s Catholic College located nearby. The current traffic plan therefore fails to meet the requirements of SEPP (Transport & Infrastructure) 2021 cl. 2.111, which demands safe and efficient transport outcomes for educational facilities.
Ground for refusal: The traffic design is unsafe and inappropriate for the residential setting, with an alternative (Gavenlock Road), available but ignored.
2. Flooding, Drainage and Loss of Dam Capacity

The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.

The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
Another serious concern is the proposal to fill in the existing dam on the site. This dam currently plays an important role in local drainage and stormwater management. Removing it will increase runoff towards neighbouring homes and the local parkland, heightening the risk of flooding and waterlogging during heavy rain.
The Flood Impact Assessment does not adequately address this change, nor provide a sustainable drainage alternative that replicates the dam’s capacity. The resulting runoff will directly impact the amenity and safety of surrounding residents and public open space.
Ground for refusal: The removal of the dam undermines local stormwater management and increases flooding risks to adjacent properties and public land.
3. Other Planning Concerns
Noise impacts from playgrounds, PA systems, and potential after-hours use are understated and not properly modelled.
Building bulk and height introduce a three-storey form incompatible with the surrounding one- to two-storey residential character, resulting in overbearing visual impact and privacy loss for neighbours.
Emergency evacuation risks (flood and bushfire) are inadequately planned, with Keefers Glen again identified as the sole access route despite its clear limitations.
Requested Outcome
Given the above issues, I respectfully request that Council refuse this development application in its current form.
If Council is minded to approve the DA, I strongly urge the following minimum conditions:
Relocate the school entry and exit to Gavenlock Road rather than Keefers Glen.
Retain or replace the stormwater capacity of the existing dam to prevent downstream flooding.
Independent peer review of the traffic and drainage assessments.
Limit the building height to two storeys along the residential interface.
Provide enforceable management measures for noise and after-hours use.
Conclusion
This proposal, as currently designed, poses unacceptable risks to road safety, drainage, and neighbourhood amenity. The decision to place the school entry on Keefers Glen is a fundamental flaw when a more suitable alternative exists. For these reasons, I urge Council to refuse the DA unless substantial redesign is undertaken.
Yours faithfully,
Mardi resident

Dear Sir/Madam,
I am writing to object to the proposed development of the Eileen O’Connor School at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and supporting documents, I consider the proposal to be fundamentally flawed in terms of traffic planning, drainage, and neighbourhood impact. On these grounds, I believe the development should not proceed in its current form.
1. Traffic and Road Safety Impacts
The most serious issue is the proposed school access from Keefers Glen, a narrow residential street that is not designed to handle high volumes of daily school traffic. This will inevitably funnel traffic into Brickendon Avenue, a street that already experiences heavy on-street parking. Vehicles are frequently forced onto the wrong side of the road to pass, which will only worsen with school pick-up and drop-off activity.
The situation becomes more dangerous at the intersection of Brickendon Avenue and Woodbury Park Drive, where visibility is already compromised by parked vehicles. Adding concentrated school traffic to this intersection poses a significant safety risk to both motorists and pedestrians.
The school site is directly accessible from Gavenlock Parade, a much larger road designed for higher capacity traffic movements. It is strongly preferred by residents that this be used as the primary school entry point. Locating the access on Gavenlock Parade would avoid overwhelming Keefers Glen and Brickendon Avenue, and would provide a safer and more appropriate solution consistent with planning requirements for context-sensitive traffic management.
The Transport & Accessibility Impact Assessment has not properly accounted for these realities, nor the cumulative traffic impacts of St Peter’s Catholic College located nearby. The current traffic plan therefore fails to meet the requirements of SEPP (Transport & Infrastructure) 2021 cl. 2.111, which demands safe and efficient transport outcomes for educational facilities.
Ground for refusal: The traffic design is unsafe and inappropriate for the residential setting, with an alternative (Gavenlock Parade) available but ignored.
2. Flooding, Drainage and Loss of Dam Capacity
The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.
The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
Another serious concern is the proposal to fill in the existing dam on the site. This dam currently plays an important role in local drainage and stormwater management. Removing it will increase runoff towards neighbouring homes and the local parkland, heightening the risk of flooding and waterlogging during heavy rain.
The Flood Impact Assessment does not adequately address this change, nor provide a sustainable drainage alternative that replicates the dam’s capacity. The resulting runoff will directly impact the amenity and safety of surrounding residents and public open space.
Ground for refusal: The removal of the dam undermines local stormwater management and increases flooding risks to adjacent properties and public land.
3. Other Planning Concerns
Noise impacts from playgrounds, PA systems, and potential after-hours use are understated and not properly modelled.
Building bulk and height introduce a three-storey form incompatible with the surrounding one- to two-storey residential character, resulting in overbearing visual impact and privacy loss for neighbours.
Emergency evacuation risks (flood and bushfire) are inadequately planned, with Keefers Glen again identified as the sole access route despite its clear limitations.
Requested Outcome
Given the above issues, I respectfully request that Council refuse this development application in its current form.
If Council is minded to approve the DA, I strongly urge the following minimum conditions:
Relocate the school entry and exit to Gavenlock Parade rather than Keefers Glen.
Retain or replace the stormwater capacity of the existing dam to prevent downstream flooding.
Independent peer review of the traffic and drainage assessments.
Limit the building height to two storeys along the residential interface.
Provide enforceable management measures for noise and after-hours use.
Conclusion
This proposal, as currently designed, poses unacceptable risks to road safety, drainage, and neighbourhood amenity. The decision to place the school entry on Keefers Glen is a fundamental flaw when a more suitable alternative exists. For these reasons, I urge Council to refuse the DA unless substantial redesign is undertaken.
Yours faithfully,
Mardi Resident

As residents of the area, we formally object to the proposed development of the Eileen O’Connor Catholic School. While we support the principle of inclusive education, this project is fundamentally inappropriate for the chosen site.

The scale and placement of the development will cause unacceptable impacts on the immediate community. Our concerns include:

Loss of privacy, amenity, and neighbourhood character due to a large institutional building located within metres of family homes.

Severe traffic and parking issues, compounded by the existing congestion from St Peter’s Catholic College, with council itself having raised concerns about the proposed access route.

Years of disruptive and unsafe construction activity directly beside residential properties, posing health, safety, and wellbeing risks for families and children.

Misrepresentation of the need for this facility, given that specialist schools and programs already exist across the Central Coast.

Long-term financial harm, including diminished property values, for residents most affected.

Misleading documentation, with the school described as fronting Gavenlock Road, when in fact all access is via the narrow residential street of Keefers Glen.

This proposal represents an institutional-scale development being forced into a quiet suburban cul-de-sac. The Environmental Impact Statement fails to adequately mitigate or justify the impacts, leaving local families to shoulder the costs of noise, traffic, pollution, and loss of livability.

For these reasons, we strongly urge that the application be rejected, or at the very least, relocated to a more suitable site where the educational benefits can be delivered without sacrificing the health, wellbeing, and amenity of neighbouring residents.

This site is not appropriate, and this development should not proceed here. the attached document goes into detail on our objection of the proposed school

Gavenlock Rd for entry & exit point!

I am in support of the school, but against the entrance through Keefers Glen & surrounding streets.
This street is full of small children playing. There is no safety measures in this plan. No zebra crossing. No 40km school zone. No footpath or cyclist area.
No slow down with flashing lights for the support children or residents to feel safe.
In fact there is no consideration for the residents AT ALL.

My grandchild attends a primary school support class, and would feel horrible being made to come through the small back streets, like he is hidden and different.

I own a house on keefers Glen where my grandchild lives with his disabilities.
The 7 day per week traffic noise is the worst thing for an autistic child with disabilities. You are taking away his peace & tranquil neighbourhood: the very reason why we bought the house in this street. You are taking away his safe place.
My neighbour has 3 children on the spectrum & this will also affect their living conditions dramatically.
It is cruel.
Where is the compensation for the disruption you are putting on these children & families?

Where is the compensation for taking away our peaceful weekends which will now be replaced by a community hall with 7 day per week traffic & noise?

The plan provides no protection, it takes away ALL street parking, it is NOT supported by council, there are no environmental considerations, there is no consideration to the already full storm water on Keefers Glen, the extremely tight bends of Keefers, Deloraine & Brickedon are not suitable for this traffic AT ALL. Small cars already find it difficult to navigate these streets, so buses & high traffic will cause accidents, road deterioration, congestion and massive noise & health implications for all residents.

The impact on safety includes high fire danger risk to residents and supper children & staff. This includes structure fires & bush fires.

keefers Glen can not take the traffic during an emergency.

The perfect solution (supported by council) is an entrance/exit via Gavenlock Road.
This is what the community wants & see’s as needed for the school & makes no sense to put anywhere else.

The value of my house will now drop due to no privacy, high traffic, high noise & safety concerns.
Where is the compensation for a massive decrease in my house value?

The council and traffic engineers DO NOT support the use of Keefers Glen as the entry & exit to the school.
That is crucial information that is being ignored!

Keefers Glen was NOT built to withstand heavy traffic such as the proposed. It is a narrow lane & can not take ongoing traffic.
We do not need another street constantly filled with pot holes.

In conclusion,
Council, as do Mardi residents, support the entry & exit via Gavenlock road only. This is the easiest & most sensible solution.
The DA is flawed with many inconsistencies, underestimating the massive impact to residents, which include young children (both neurodivergent & neurotypical) and the elderly.

To ignore the advice of the council would be a disgrace.

Council support the entry/exit via Gavenlock Rd, as do the people who actually live in this very tiny & quiet street, which was built for low impact residential traffic only.

Consider the children with disabilities & families who look after them who already live in this tiny street.
It would be cruel to disrupt their lives even further.

I am writing to express my strong support for the proposed development of the Eileen O’Connor Catholic School in Mardi—a state-of-the-art educational facility designed to meet the needs of children with disabilities and additional learning requirements.

The community of Mardi is incredibly fortunate to have such a specialised school located so close. This development will provide a vital service to families across the Central Coast who are seeking high-quality, tailored educational support for their children. At present, there are very limited options for students with additional needs, and many families are desperate for an alternative to mainstream public schools that cannot fully meet their child’s individual learning and behavioural needs.

The Eileen O’Connor Catholic School will not only provide much-needed choice in education but will also contribute to a stronger, more inclusive community. It will bring local employment opportunities and attract dedicated professionals—teachers, therapists, and support staff—who are passionate about helping every child thrive.

I believe this school will be a tremendous asset to our region and a source of hope for many families. I fully support the proposal and encourage the Council to approve the development.

Dear Sir/Madam,
I am writing to object to the proposed development of a three-storey school at 84 Gavenlock Road, Mardi. Having reviewed the Environmental Impact Statement and its technical appendices, I submit that the development is fundamentally flawed, legally non-compliant, and unsafe, and should be refused in its current form.

1. Traffic and Road Safety Impacts

Underestimated Traffic Generation: The Transport & Accessibility Impact Assessment (Appendix R, pp. 31–42) fails to model school peak periods. Queuing and congestion on Keefers Glen and Gavenlock Road are ignored, contrary to SEPP (Transport & Infrastructure) 2021 cl. 2.111, which requires safe and efficient transport outcomes for educational facilities.
Inadequate Road Capacity Assessment: Keefers Glen is a narrow residential road with single vehicle access and minimal off street parking. Benchmarking against regional arterial roads is misleading and breaches DCP 2022 Ch. 3.1 (Car Parking & Access), which requires context-based assessment.
Pedestrian & Cyclist Safety Ignored: No safe crossing points or separated foot/cycle paths are proposed, breaching the Austroads Guide to Road Design (Part 6A) and exposing children to risk. Keefers Glen has no footpaths and due to the narrow street (and surrounding streets Deloraine Glen) pedestrians are required to walk on the road as there is no safe footpaths and cars are parked on kerbs to allow single vehicle access through the roads

Parking Deficiency: On-site parking falls short of DCP 2022 minimum ratios, ensuring overspill into Keefers Glen.
Construction Traffic Deferred: The Preliminary CTPMP (Appendix T, p. 6) defers construction traffic planning until a builder is appointed, breaching EP&A Regulation 2021 Sch 2, cl. 6.
Cumulative Impacts Ignored: The report does not assess traffic interaction with St Peter’s Catholic College, in breach of EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe and inadequate traffic planning, inconsistent with statutory and local planning controls.

2. Noise and Acoustic Amenity

Baseline Monitoring Deficient: The Noise & Vibration Assessment (Appendix U, pp. 17–18) is based on short-term monitoring, not the 7-day standard required by the EPA Noise Policy for Industry 2017 (NPfI).
Outdoor Noise Underestimated: Intermittent, high-level playground and PA system noise was ignored, contrary to EPA guidance.
After-Hours Use Excluded: The report concedes that evening/weekend use of facilities (sports, assemblies, community hire) has not been assessed (Appendix U, p. 26), breaching EP&A Act s.4.15(1)(b).
Vague Mitigation Measures: Generic references to barriers provide no enforceable design, breaching DCP Ch. 3.3 Noise & Vibration.
Construction Noise Ignored: No modelling against the Interim Construction Noise Guideline (DECC 2009), contrary to regulatory standards.
Cumulative Noise Ignored: Noise from St Peter’s College has not been combined with the proposal.
Ground for refusal: Non-compliance with NPfI 2017 and ICNG 2009, leading to unacceptable amenity loss.

3. Flood Risk and Emergency Access

The Flood Impact Assessment (Appendix EE, p. 21) and Flood Emergency Response Plan (Appendix FF, p. 14) admit that evacuation routes will be cut during 1% AEP and PMF events, isolating the site.
The NSW Floodplain Development Manual (2023) requires not only raised floor levels but also safe evacuation routes. These have not been demonstrated.
The school is designed for children with disabilities, who may require assisted evacuation. Approval without proven evacuation safety risks breach of the Disability Discrimination Act 1992 (Cth) and the EP&A Act s.4.15(1)(b).
Ground for refusal: Unsafe flood evacuation and non-compliance with statutory floodplain management guidelines.

4. Bushfire Emergency Management

The Bushfire Emergency Management Plan (Appendix RR) confirms reliance on Keefers Glen as the sole access route. Planning for Bushfire Protection 2019 (PBP) requires dual safe evacuation routes for vulnerable uses.
The interaction of flood and bushfire risks has not been assessed, contrary to NSW RFS guidelines.
Details of hydrant access, defendable space, and APZs are incomplete.
Ground for refusal: Non-compliance with PBP 2019 and failure to ensure life safety in concurrent hazard scenarios.

5. Architectural Design, Height, and Privacy Impacts

The Architectural Design Report (Appendix I) describes the school as “predominantly two-storey” but in reality introduces three-storey built form at the northern ends of the wings. These sections will appear as full three-storey blocks when viewed from Keefers Glen and Brickendon Avenue, creating an imposing institutional bulk inconsistent with the surrounding one- to two-storey residential neighbourhood.
This bulk and scale directly conflicts with the planning intent of the Central Coast Local Environmental Plan 2022 and Development Control Plan 2022, which require new development to respect and integrate with the prevailing low-density residential character of Mardi.
Furthermore, the upper-level verandahs and learning spaces will enable direct overlooking into neighbouring backyards and homes, resulting in a significant loss of residential privacy. This impact breaches both the residential amenity provisions of the DCP and the broader objectives of the EP&A Act requiring protection of neighbourhood character and amenity.
Ground for refusal: Excessive building height, visual bulk, and overlooking, contrary to the LEP and DCP provisions for residential interface areas.

6. Social Impact

The Social Impact Assessment (Appendix KK, p. 12) is biased towards benefits and fails to assess negative impacts, including:
Loss of residential amenity and neighbourhood character,
Increased noise and traffic danger,
Reduced property values,
Cumulative stress on local infrastructure.
This omission breaches EP&A Act s.4.15(1)(b) and (d), which require full consideration of social and economic impacts.
Ground for refusal: Incomplete and unreliable assessment of social impacts.

7. Legal and Policy Non-Compliance Summary

The proposed development fails to comply with:
EP&A Act 1979 s.4.15(1)(b) – inadequate consideration of environmental, traffic, safety, and social impacts.
Central Coast LEP 2022 – inconsistent with local character and amenity objectives.
Central Coast DCP 2022 – breaches in traffic (Ch. 3.1), noise (Ch. 3.3), privacy, and rural-residential character (Ch. 5.51).
SEPP (Transport & Infrastructure) 2021 cl. 2.111 – inadequate traffic and safety outcomes.
EPA NPfI 2017 & ICNG 2009 – flawed acoustic assessment.
NSW Floodplain Development Manual 2023 – unsafe evacuation provisions.
Planning for Bushfire Protection 2019 – inadequate bushfire evacuation and APZ design.
Requested Outcome
I respectfully request that Council refuse the DA in its current form on the grounds of serious non-compliance and unacceptable risk.
Should approval be contemplated, Council must at minimum require:
Independent peer review of traffic, noise, flood, and bushfire reports;
Strict conditions limiting building height to two storeys along Keefers Glen;
Enforceable acoustic barriers and restrictions on PA/bell usage;
A prohibition on after-hours/weekend use unless subject to a separate DA;
Proof of dual safe evacuation routes for flood and bushfire;
Full compliance with DCP car parking ratios and additional on-site parking.
Conclusion
This proposal represents a serious threat to safety, amenity, and local character. It fails multiple statutory tests under the EP&A Act and associated instruments. I therefore urge that the proposal in its current form is not supported

Yours sincerely,