“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.
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.
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 Council to refuse the DA in its current form.
Yours sincerely

SUMMARY
I strongly support this essential special education facility but have serious concerns about the proposed Keefer's Glen vehicle access. I advocate for access via Gavenlock Road as recommended by Central Coast Council.

SUPPORT FOR THE SCHOOL
This facility addresses a critical need for specialised education on the Central Coast, serving 200 students with disabilities and reducing families' need to travel to Sydney/Newcastle. The project aligns with NSW priorities for inclusive education and breaking disadvantage cycles.

TRAFFIC CONCERNS - KEEFER'S GLEN ACCESS
Volume Analysis
The Transport Assessment shows extraordinary traffic loads:
213 vehicle trips/hour (morning peak 8-9am)
156 vehicle trips/hour (afternoon peak 2:30-3:30pm)
100% vehicle dependency (85% ASTP transport, 15% private vehicles)
71 staff all driving to work
This represents a massive increase for a narrow lane serving only 16 dwellings.

Impact on Brickendon Avenue
Current traffic surveys show Brickendon Avenue handles 96 vehicles/hour (AM) and 93 vehicles/hour (PM). As the direct route from Woodbury Park Drive to Keefer's Glen, our street would experience potential doubling or tripling of traffic during school peaks.

Central Coast Council's Opposition
Council has unequivocally rejected Keefer's Glen access, stating:
"Council will not support this proposal"
"The proposed special needs school will generate considerably higher passenger vehicular movements than other schools"
"Residents amenity will be severely affected"
"Keefers Glen was not constructed to facilitate traffic loading"
"All access to the new school is to be provided via the existing driveway on Gavenlock Road"
This represents expert local assessment that Keefer's Glen access is inappropriate and dangerous.

Technical Deficiencies
Narrow carriageway: Never designed for this traffic volume
Intersection capacity: Cannot support bus swept paths
No formal footpaths: Pedestrian safety compromised
Parking displacement: Eliminates resident parking

SUPERIOR GAVENLOCK ROAD ALTERNATIVE
Gavenlock Road offers:
Higher road classification with appropriate infrastructure
Existing school zone (40km/h restrictions)
Better intersection capacity connecting to Woodbury Park Drive
Direct access to Wyong Road (State Road) and Pacific Highway
Established traffic management serving St Peter's College

CONSTRUCTION IMPACTS
18-month construction via Keefer's Glen would create:
Daily heavy vehicle movements through residential area
Noise exceeding 75dB(A) "Highly Noise Affected" levels
Disruption before permanent traffic increases commence
Potential property value impacts from increased traffic and construction

PROPERTY VALUE CONCERNS
The combination of construction disruption and permanent traffic increases through our quiet residential area poses real risks to property values. The noise assessment acknowledges noise levels will exceed management standards, and the traffic volumes represent a fundamental change to neighbourhood character.

COMMUNITY RESPONSE
Residents across Mardi have rallied around this cause, recognising the need for the school whilst opposing inappropriate access arrangements. Community consultation identified "desire for wider Keefer's Glen" - but widening to 6m cannot address fundamental infrastructure mismatch.

FLOOD SAFETY CONSIDERATION
While applicants cite flood concerns about Gavenlock Road, this can be managed through emergency planning rather than shifting inappropriate traffic to residential streets unsuited for high volumes.

PRECEDENT CONCERNS
Approving access explicitly rejected by the traffic authority sets concerning precedent for prioritising applicant preferences over technical safety assessments.

RECOMMENDED SOLUTION
Approve the school development - essential community facility
Require primary access via Gavenlock Road per Council recommendation
Emergency access only via Keefer's Glen if required
Comprehensive traffic monitoring post-opening
This delivers educational benefits whilst protecting residential amenity and safety.

CONCLUSION
This important school deserves support, but not at residential safety expense. Central Coast Council's technical assessment demonstrates Keefer's Glen cannot safely accommodate proposed traffic volumes.
The documented concerns about road infrastructure, intersection capacity, residential amenity, and property values are well-founded and evidence-based.
I urge NSW Planning to approve this valuable school whilst requiring appropriate access via Gavenlock Road. This balanced approach advances educational objectives whilst protecting community safety and amenity.
Technical references: SSD-67173718 EIS, Transport & Accessibility Impact Assessment (Traffix), Preliminary CTMP, Central Coast Council Pre-DA advice September 2023 & July 2024.

I do not and cannot support the plans submitted for the New Eileen O'Connor School. I see the need for such a school and in the right place would add great value to families in our community. However, the current location for the school is completely inappropriate and dangerous. I work daily with children with disabilities and I am extremely fearful of the entry/exit points at Keefers Glen. It is a matter of when not if a fatality will occur in a small road designed for light local traffic. I know the amount of time it takes to get children in and out of cars, a child's awareness of traffic surrounding them etc. Keefers Glen IS NOT SUITABLE OR SAFE for a development of this size. The feeding roads such as Brickendon Avenue is already oversaturated with traffic and parking is a chronic problem. The intersection from Brickendon Avenue onto Woodbury Park Drive has always been an issue with poor visibility when making a right turn. The likelihood of serious accidents with the traffic volume increasing is something the NSW Government should be greatly concerned with. Planning should not have made it to this point based on the quality of feeding roads to the school and the volumes of traffic and lack of parking already in these spaces.
Flooding is another major issue in the local area and the development impacts a water catchment area with no plans disclosed as to where this water will now go with the filling in of areas on the block.
The lack of other essential accessibility infrastructure such as footpaths/bike paths in the roads surrounding the new school entry/exit will put every person, mostly children who walk from the adjoining streets up to the bus stops on Woodbury Park Drive in harm's way. The increased flow of traffic, cars parked on nature strips, many so close to existing traffic islands that force cars to drive in the wrong side of the road to get through will no doubt cause a serious accident endangering the children. All roads in the area are full of major potholes that are frequently filled in but never repaired. The poor quality of surrounding roads, along with increased traffic, especially of large vehicles during the construction phase will cause traffic chaos and car/property damage.
I have read many of the documents sent to home owners and reports from the Central Coast Council who have all objected the build mostly due to the traffic and safety concerns. It saddens me that for the sake of 200 new enrolments this school plans to cater for, the NSW Government are happy to endanger the lives of countless more by creating this development in such an unsafe, careless and ignorant way.
Even the school itself is aware of how much it will affect the local community in a negative way with the strategic locking of the gates in recent weeks to stop the double parking, gridlock traffic that occur every weekday morning and afternoon. A deceptive move from the school to coincide with the opening of the online submissions.
Local community members have been very vocal in their concerns for safety during floods and bushfire seasons. There is no capacity for the large volumes of traffic these catastrophic events will create.
Communities need schools, of course they do, but they need them to be positioned in a suitable area. They need to ensure the safety of the students the school is built for and the safety of the members of the community it is situated within.
I fully disagree with the plans to build the school in its current proposed location.

I support this project ONLY if the traffic management for entry is from Gavenlock Road and NOT Keefers Glen at Mardi. The local streets around this area are quiet, residential access streets and they are narrow. They shouldn't have buses and multiple cars going there. I believe the school is a great development, but I would only support it if the entry to the school is from Gavenlock Road. This area in Gavenlock Road already has school entry, signage and traffic is aware of the 40 km school zones.
I have lived on Woodbury Park Drive for many years and this road is getting very busy. Living on a corner in Woodbury Park Drive is already difficult to reverse from the driveway safely and the added traffic which would be on Woodbury Park Drive during school drop off and pick up times would escalate the dangers of residents trying to leave their driveways. The other issue would be cars turning right from Woodbury Park Drive. If this occurs from Wagners Place, cars have the sun shining directly in their face as they approach this intersection. The increased traffic will likely result in increased car accidents. If cars are turning right from Woodbury Park Drive into Brickendon Avenue, there is also an increased risk of car accidents as cars are travelling downhill and suddenly have vehicles making a right turn.
I don't agree with the access to the school being from such a quiet street. These narrow streets already have parked cars and the road is not wide enough to accommodate buses and increased traffic. If the development was changed to have the entry to the school via Gavenlock Road at Tuggerah, I would have no opposition to the project. I think Gavenlock would be a safer, more appropriate location to have the entry to the school.

Re: Objection to the Proposed Development – Eileen O’Connor Catholic School, 84 Gavenlock Road, Mardi (SSD 67173718)
I am writing to formally object to the project for the following reasons.
There are a few senior citizens in this community as per myself who will be greatly impacted by the increased traffic of this proposed school. The daises is aware as they had St Peters close access to their school via Keefers because of the damage, traffic and chaos that was being caused by only a few people. You know want to increase that by over 200. A Number of us in the street have had to replace their storm water drains because people kept driving on our lawns to pick up their kids and damaged it.
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.
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 Council and NSW STATE planning to refuse the DA in its current form.

I regularly visit to this small locality and often have witnessed the traffic around school drop off time.
I object to the access plans for this new school due to the already very narrow, small roads in the direct adjacent space.
The school would appear to fit within the space available but the proposed access point is clearly unwise.
The Council’s strong objections are well founded and would be best heeded.

Dear Council Members,
I am a Professional Registered Surveyor having delt with many Development Applications over many years and I am writing to offer my full support for the proposed development of the Eileen O’Connor Catholic School in Mardi—a specialised school designed to meet the needs of children with disabilities and additional learning requirements.
This school represents a significant and much-needed step forward for our community. At present, the Central Coast has very limited schooling options for students with special needs. The establishment of this facility will provide families with greater choice and ensure that more children have access to education tailored to their individual needs.
Beyond the educational benefits, this development would also bring lasting value to Mardi by creating new local employment opportunities and attracting skilled professionals to the area. Teachers, support staff, therapists, and administrators will all contribute to a more vibrant and inclusive local economy.
Importantly, a school like this sends a powerful message—that our community values inclusion, compassion, and opportunity for all. I believe the Eileen O’Connor Catholic School would be a positive and welcome presence in our suburb, and I would be proud to see it become part of Mardi’s future.
A great deal of local objection appears to be related to additional traffic flow. I am confident the traffic studies will clearly support this development.
I strongly support this proposal and urge the Council to approve the development.
Kind regards,
Phillip Orr
Registered Surveyor

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 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.
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 Council & NSW development planning to refuse the DA in its current form.

Yours sincerely,
Melissa and John Weatherall.