As a resident who will be significantly and directly impacted by the proposed development (which is within meters of the proposed development), I strongly object to the proposed development and/or SSD-94409457 and request that the consent authority refuse the application and do not rezone the proposed site to the proposed building height level for following reasons.
This objection is made under the Environmental Planning and Assessment Act 1979 (EP&A Act) and the Environmental Planning and Assessment Regulation 2021 (EP&A Regulation). Under section 4.15(1) of the EP&A Act (applied to State significant development through section 4.40 and the assessment process under Division 4.7), the consent authority must consider the likely impacts of the development on the built and natural environment and on the locality, the suitability of the site, any submissions made, and the public interest. The grounds below go directly to those mandatory considerations.

A. Inadequate impact assessments in the EIS
A1. Overshadowing and loss of solar access to properties on Bertram St
The EIS overshadowing assessment (§8.4.1) addresses one control only: clause 6.15(3) of WLEP 2012, which prohibits consent where a dwelling in the South Chatswood Conservation Area would receive less than 3 hours of winter sunlight. The EIS concludes only that the proposal complies with that specific clause and asserts, in general terms, that the tower “will not result in any unreasonable overshadowing impacts to existing development.”
The assessment is deficient and incomplete as:
-No property-specific analysis of surrounding dwellings on Bertram St which will be most significantly impacted. The EIS does not identify properties on Bertram (or other dwellings on the opposite side of Archer Street) as a receiver, does not state how many hours of winter sunlight my property currently receives, and does not state how many hours it would retain after construction. The conclusion of “no unreasonable” impact is therefore an assertion unsupported by any receiver-specific measurement in the exhibited text.
-The solar figures in the EIS measure the wrong thing. The solar access figures at §8.3.2 (79% of apartments receiving 2 hours; 6 apartments receiving none) measure sunlight to the proposal’s own apartments under Part 4A of the ADG. They say nothing about sunlight lost by existing neighbouring dwellings. [Cross-ref: EIS §8.3.2 “Solar and Daylight Access”.]
-A 45-storey tower of this height casts a materially longer shadow than the conservation-area test alone captures. The EIS itself describes the shadow as arising from a tower on a podium and relies on the shadow being “fast moving” to characterise it as acceptable — but “fast moving” is a qualitative descriptor, not a measured retained-sunlight figure for my dwelling.
Impact on residents in Bertram St, including those directly opposite the proposed site: loss of direct winter sunlight to my property’s dwelling (and other Bertram St residents’) living areas and private open space, loss of daylight amenity and roof-mounted solar panels — a reduction in solar generation and therefore a direct financial loss. Because the EIS does not quantify the shadow on my property, the consent authority cannot be satisfied under s4.15(1)(b) that the solar impact is acceptable. I request that refusal follow.

A.2 Acoustic and noise pollution
Impact on me and ground for refusal: traffic noise, construction noise, and future operational plant noise directed at dwellings on Bertram St have not been finally assessed or mitigated on the exhibited material. Deferring operational noise assessment to a later plan means the consent authority is asked to approve the development before the operational noise impact is known, which is inconsistent with the s4.15(1)(b) obligation to consider likely impacts before consent.
A.3 Overlooking and privacy
The EIS setback table (Table 18, §8.3.1) discloses that the ADG separation criteria are not met on several interfaces. Against a 9m habitable / 4.5m non-habitable requirement, the proposal provides only 3–6m on the north and south interfaces, relying on “window louvres” and “screening” to “direct views away from neighbouring development.” [Cross-ref: EIS Table 18 “Required DCP and proposed setbacks”, north and south rows, p.75.]
The concern is that reduced separation with a screening “fix” is a design response to a shortfall, not evidence that privacy is preserved. The EIS does not demonstrate the visual-privacy outcome for specific opposing windows or yards. The onus is on the applicant to justify the departure from the ADG separation criteria; a general statement that louvres redirect views does not discharge it.
A.4 Traffic and parking
The parking assessment (EIS §8.7, Tables 19–20; Appendix F) contains internal figures that do not reconcile and warrant scrutiny before any approval:
• The dwelling yield used across the tables is inconsistent — the parking table breaks down units to a total that must be tested against the 114-unit figure used elsewhere in the same EIS, and against a 57-unit figure appearing in the natural-ventilation section (§8.3.5). The consent authority cannot verify the parking calculation while the underlying unit count is stated inconsistently in the exhibited document.[Cross-ref: EIS §8.7 Tables 19–20 vs §8.3.5 (“42 out of 57 units”) vs Notice of Exhibition (“114 units”).]
• The parking provision relies entirely on the minimum rates in s22A of the Housing SEPP (as amended 24 April 2026) being the applicable standard. If that characterisation is wrong, the provision (136 spaces) may be assessed against a different requirement. The applicant should be put to proof that Chapter 2 Part 2 Division 1 applies. [Cross-ref: EIS §8.7 opening paragraphs; Table 19.]
Parking is under-provided relative to actual demand, overflow parking and additional vehicle movements which will affect the amenity and safety of Archer Street, the general public, pedestrians and residents.
Ground B — Non-compliance with planning controls
B.1 The proposal does not comply with current WLEP 2012 controls; it depends on a concurrent rezoning
The proposal does not seek a clause 4.6 variation to the existing standards. Instead, it depends on a concurrent rezoning to change the WLEP 2012 controls in its favour. the development is not permissible under the controls that currently apply. Under existing WLEP 2012, a residential flat building is not a permitted use on the site, the height limit is 90m (the proposal is a 45-storey tower far exceeding this), and the FSR limit is 5:1 (the proposal seeks 8.45:1 — roughly a 69% uplift). The proposal can only proceed if the consent authority first accepts a rezoning that rewrites every relevant control. I object to that rezoning and submit that the scale of the departure from the current controls is itself a reason to refuse.
Inconsistency in the exhibited height figure (I raise this as a reliability issue, not as proof of a particular height): the maximum height is stated four different ways across the exhibited documents — RL 242.6m AHD (EIS Executive Summary and Table 12), RL 241.3m AHD (EIS §5.2.2), 154.15m (Notice of Exhibition), and a “proposed height of 152.85m” used in the setback calculation (EIS §8.3.1). [Cross-ref: EIS Exec Summary; EIS §5.2.2; EIS §8.3.1; Notice of Exhibition.] I do not assert which figure is correct. My point is that a community member reading the exhibited material cannot ascertain the actual maximum height of the building they are being asked to comment on, which undermines the integrity of the exhibition.
B.2 SEPP 65 / Housing SEPP and the Apartment Design Guide (ADG)
The EIS discloses several ADG design-criteria outcomes that are met only marginally or by variation, and at least one internal inconsistency that prevents verification:• Communal open space — the “50% direct sunlight” criterion (Part 3D) is met at exactly the 50% threshold on the EIS’s own figures (“50% (58sqm) of the principal usable part… receiving 2 hours”), i.e. no margin.• Setbacks/building separation (Part 3F) are varied on multiple interfaces (see A.3 above), which is a departure from ADG criteria that the EIS resolves by asserting the “overarching guidelines” are met rather than the numeric criteria. • Cross-ventilation (Part 4B) is stated as “74% of units (42 out of 57 units)” — but the development is described elsewhere as 114 units. The 57-unit denominator cannot be reconciled with the 114-unit project on the exhibited material, so the stated 74% compliance cannot be verified. Where an EIS relies on ADG criteria being met but the supporting figures are internally inconsistent or sit exactly on the minimum, the consent authority cannot be satisfied that the design-quality principles are achieved. Under the Housing SEPP design-quality framework the onus is on the applicant to justify any departure; unresolved inconsistencies are a proper basis for refusal or, at least, for requiring corrected documentation to be re-exhibited.

The Visual and View Impact Analysis (Appendix Y; EIS §8.5) assessed view impact only for two neighbouring properties — 57–61 Archer Street and 34 Albert Avenue — and concluded a “minor” impact for those & those on bertram aren't assessed.
There's been inadequate consultation with local residents in bertram receiving no communications from developer about development.

I submit the consent authority should REFUSE application for this development, and refuse the concurrent rezoning proposal, on the grounds that the development is not permissible under the current WLEP 2012 controls and the exhibited EIS does not demonstrate acceptable impacts under s4.15(1) of the EP&A Act.

I do not agree to my details being released to public.

I strongly object to the proposed development and consent should be refused for below reasons:

1. Non-compliance with planning controls
The concurrent rezoning seeks to increase permitted building height from RL 90m to RL 242.6m AHD and FSR from 5:1 to 8.45:1 (Notice of Exhibition; EIS p.9). This is not a marginal variation — it is a near-doubling of FSR and a ~2.7× height increase. The application relies on a rezoning to authorise these figures rather than a properly justified departure, which means the numeric bulk is not yet a lawful control. If assessed against the existing WLEP 2012 standards, the proposal grossly exceeds them.

2. it will permanently result in below significant negative impacts to the community and neighbours surrounding this proposed development – particularly the existing residential houses opposite the proposed development on Bertram Street as per below.

3. proposed development is far too high at 45 levels and will result in significant overshadowing, loss of solar access, daylight and views of the sun and sky for surrounding neighbourhood properties including residential properties in Bertram Street across from the proposed development. This will consequently result in loss of amenity, privacy and use and enjoyment of surrounding properties including residential properties on Bertram Street which are directly opposite the proposed development.

4. The EIS concedes that solar-access verification is directed almost entirely to the development's own communal open space and apartments — e.g. "79% of apartments … receive a minimum of 2 hours direct sunlight … at mid-winter" (EIS §Executive Summary) — and to the South Chatswood Conservation Area, not to private dwellings opposite the proposed development.

The overshadowing conclusion rests on the assertion that shadow impacts are "fast moving, within acceptable limits" (EIS Overshadowing section, p.10–11), which is a characterisation, not a property-specific demonstration. Figure 34 (Shadow Diagrams, p.80) does not establish that the residential properties on Bertram St opposite the proposed development retains the DCP-mandated minimum winter sunlight (typically 3 hours, 9am–3pm on 21 June). A 45-storey tower directly opposite will cause material loss of daylight and of rooftop solar-panel generation — an impact the EIS does not quantify for surrounding residential owners.

5. Noise: The EIS relies on the Stantec Noise and Vibration Assessment (Appendix AA) via mitigation measures; it does not demonstrate acceptable noise transference to opposite dwellings on Betram Street and there will be a permeant and significant increase to noise above required levels.

6. Traffic/parking: this development will create additional noise and pedestrian and vehicle traffic which will further detrimentally impact the surrounding residential neighbours by way of increased noise, less privacy due to those in the proposed development being able to look into or down onto residential properties as well as significant loss of amenities, parking, services and increased traffic and safety risks to the surrounding neighbours.
The local area cannot possibly support this level 45 development particularly in the context of the other numerous very high multi-storey mixed developments which are being proposed mere meters away from other very large multi-storey development on Archer Street and in the surrounding area of Chatswood. The local area will not be able to cope and residential traffic and parking particularly in the back surrounding residential streets of Bertram Street will be negatively impacted by the scale and totality of this development and even more significantly impacted in the context of other multistorey developments in Archer Street and Chatswood.

Submission regarding 51–55 Archer Street, Chatswood
Submitted on behalf of: Owners Corporations of 45–49 Archer Street, Chatswood (SP 97641 and SP 83955)

Privacy request: The individual submitter’s name, Tommy Liao, is requested to be withheld from publication. The names/details of the Owners Corporations may be disclosed and published.

1. Introduction
We write on behalf of the Owners Corporations and owners of 45–49 Archer Street, Chatswood (SP 97641 and SP 83955), immediately adjoining the proposed development at 51–55 Archer Street.
We support the increased scale and density of the proposal, particularly the delivery of additional apartments and affordable housing to assist in meeting the Government’s housing objectives through to 2029.
Our concern is not the proposed increase in height or density. Rather, it is the cumulative effect of the developments at 37 Archer Street and 51–55 Archer Street on the reasonable future redevelopment of 45–49 Archer Street, which is situated between them.
This is particularly important because 45–49 Archer Street is only approximately 29 metres wide. If our site is required to absorb substantial tower setbacks on both boundaries, the remaining tower envelope could become impractically narrow, potentially making redevelopment commercially unviable or unattractive to developers.
Given that 37 Archer Street, 45–49 Archer Street and 51–55 Archer Street are strategically located within the Chatswood CBD and collectively have significant potential to provide additional apartments and affordable housing, we respectfully submit that the Department should consider the three sites together rather than individually to achieve the intended strategic planning and housing outcome.
2. South elevation and visual privacy
We refer specifically to the South Elevation on page 30 of the Architectural Plans for the SSDA Submission, Revision C, dated May 2026, for the proposed development at 51–55 Archer Street.
The SSDA Revision C Architectural Plans demonstrate the use of screening and façade treatments at portions of the lower levels of the southern elevation, including metal mesh and other façade elements
However, from approximately Level 7 upwards, the southern residential tower façade becomes substantially more open, with windows and openings directed towards 45–49 Archer Street.
The plans also indicate that affordable housing is concentrated on Levels 1–6, with the premium-apartment component commencing at Level 7.
We therefore request that the Department require a detailed visual privacy assessment of the southern elevation, having regard not only to the existing development at 45–49 Archer Street but also to its reasonable future redevelopment as a higher-density residential tower.
Where direct sightlines would occur, appropriate measures could include angled or offset windows, privacy fins, fixed screening, louvres, altered window orientation or equivalent architectural treatments that direct views away from 45–49 Archer Street while maintaining reasonable daylight and outlook for residents.
The proposal already demonstrates that façade screening and architectural treatments can be successfully incorporated into the building design. We therefore consider it reasonable for similar design principles to be applied to the upper residential levels where necessary to address direct overlooking.
We are not seeking the removal of south-facing windows. We seek a practical architectural response that allows both sites to achieve appropriate residential amenity and reasonable development outcomes.
3. ADG separation and the 29-metre site constraint
The Apartment Design Guide (ADG) establishes building-separation principles to protect visual privacy and residential amenity.
For taller residential buildings, the ADG can require approximately 24 metres of separation between opposing habitable rooms and balconies, which may effectively involve approximately 12 metres being provided by each adjoining site.
51–55 Archer Street proposes approximately a 12-metre tower setback towards 45–49 Archer Street.
However, 45–49 Archer Street is only approximately 29 metres wide and is also affected by the proposed development at 37 Archer Street on the opposite side, which incorporates a reduced setback towards our site.
It is therefore not practical to assume that a future development at 45–49 Archer Street can simply provide substantial setbacks towards both adjoining towers.
Doing so could leave an impractically narrow and inefficient tower floorplate, substantially reducing development yield and commercial viability, with the potential to effectively sterilise the future redevelopment of the site.
The ultimate consequence could be that 45–49 Archer Street is not redeveloped at all, despite its strategic location within the Chatswood CBD and its capacity to contribute additional apartments and affordable housing.
Privacy and separation should therefore be addressed, at least partly, through appropriate architectural treatments on the adjoining developments rather than transferring a disproportionate setback burden to the narrow site between them.
4. The three sites should be considered together
45–49 Archer Street sits between 37 Archer Street and 51–55 Archer Street, both significant redevelopment sites.
While the setback and privacy arrangements of each adjoining development may appear reasonable when considered individually, their cumulative effect could substantially constrain the future redevelopment of the approximately 29-metre-wide site between them.
Given that all three sites occupy a strategic location within the Chatswood CBD and have significant potential to provide additional apartments and affordable housing, it is particularly important that the Department consider their development potential together.
Decisions regarding tower setbacks, window orientation and privacy treatment on one site directly affect what can reasonably be achieved on the adjoining sites.
A coordinated assessment of the three sites would allow the Department to achieve an outcome that:
provides appropriate tower separation and visual privacy;
preserves practical and commercially viable development envelopes for all three sites;
avoids unnecessarily constraining or sterilising the redevelopment potential of 45–49 Archer Street; and
maximises the collective delivery of additional apartments and affordable housing in support of the Government’s housing objectives through to 2029.
Allowing the adjoining sites to maximise their development potential while inadvertently making the narrower site between them commercially unviable would not achieve the intended strategic planning or housing outcome.
5. Requested amendments
We respectfully request that the Department:
Require a detailed visual privacy assessment of the southern elevation of 51–55 Archer Street, particularly from approximately Level 7 upwards, having regard to both the existing and reasonable future redevelopment of 45–49 Archer Street.
Require appropriate angled or offset windows, privacy fins, screening, louvres, altered window orientation or equivalent architectural treatments where necessary to minimise direct lines of sight towards 45–49 Archer Street.
Have regard to the fact that the proposal already incorporates screening and façade treatments at the lower levels, demonstrating that such measures can form part of the architectural design.
Consider 37 Archer Street, 45–49 Archer Street and 51–55 Archer Street together, rather than individually, when assessing tower separation, privacy, setbacks and future development envelopes.
Recognise that 45–49 Archer Street is only approximately 29 metres wide and cannot reasonably absorb substantial tower setbacks towards both adjoining developments without materially compromising a future tower floorplate.
Ensure that the planning and design outcome preserves the reasonable redevelopment potential of all three strategically located sites and maximises their collective capacity to deliver additional apartments and affordable housing.
6. Conclusion
The owners of 45–49 Archer Street support increased density and the delivery of additional apartments and affordable housing within this strategically important part of the Chatswood CBD.
Our concern is the cumulative effect of the developments at 37 Archer Street and 51–55 Archer Street on the approximately 29-metre-wide site situated between them.
If 45–49 Archer Street is required to absorb substantial setbacks from both adjoining developments, the resulting tower envelope could become impractically narrow and commercially unviable, potentially sterilising the site’s future redevelopment and preventing the delivery of additional apartments and affordable housing that the site could otherwise provide.
Given the strategic location and housing potential of all three sites, we respectfully submit that the Department should consider them together rather than individually to achieve the intended planning and housing outcome.
Appropriate privacy treatments to the adjoining elevations — including angled windows, screening and other architectural measures — would reduce the burden placed on 45–49 Archer Street while maintaining appropriate residential privacy and amenity.
This approach would allow the increased density and housing proposed at 51–55 Archer Street to proceed while preserving the reasonable future development potential of 45–49 Archer Street, thereby maximising the overall opportunity for additional apartments and affordable housing across all three sites through to 2029.

Department of Planning, Housing and Infrastructure
Attention: Keiran Thomas, Director, Housing Delivery Assessments
Application No.: SSD-94409457
Project: 51, 53, 53A & 55 Archer Street, Chatswood – Residential Flat Building
Date: 28 July 2026

Dear Mr Thomas,

I am writing to formally lodge my objection to State Significant Development Application SSD-94409457, submitted by AB Chatswood Pty Ltd for a 45-storey residential tower at 51–55 Archer Street, Chatswood, and to the concurrent rezoning proposal seeking amendment of the Willoughby Local Environmental Plan 2012.

I am a long-term local resident residing just two blocks east of the site. While I acknowledge the broader state policy objective of increasing housing supply, and note the 51 affordable housing dwellings included in the proposal, these benefits do not justify the scale of this overdevelopment, nor the permanent and cumulative detrimental impacts it will impose on this residential precinct and adjacent properties, including my own.

First and foremost, this application seeks to substantially override the established planning controls for the site. The current LEP prescribes a maximum building height of 90 metres and a Floor Space Ratio of 5:1; the proposal seeks to raise the height limit to 154.15 metres – an increase of more than 70 per cent – and the FSR to 8.45:1. This is not an incremental adjustment; it represents a fundamental departure from the intended density and built form character of this residential stretch of Archer Street.

There is no precinct-wide master plan to substantiate this spot rezoning, and no committed upgrades to pedestrian infrastructure, public open space or local road networks to accommodate the expanded development footprint. If approved, this decision will set a damaging precedent for adjacent landholdings along Archer Street to seek comparable height and density uplifts, progressively eroding the low-to-medium density residential character that defines this part of Chatswood, in the absence of any coordinated strategic planning framework.

Local infrastructure is already operating near saturation point, and the addition of 114 new dwellings will push it well beyond sustainable capacity. Archer Street and surrounding side streets experience significant congestion during morning and evening peak periods, and on-street parking is already severely constrained on weeknights and weekends. This development will generate a substantial increase in private vehicle movements, delivery traffic and multi-year construction-related heavy vehicle access, with no committed upgrades to local road networks or public transport services to mitigate the added demand. The outcome will be protracted congestion, heightened pedestrian and road safety risks, and a measurable decline in residential amenity for existing occupants.

I am also deeply concerned by the proposal to remove the active street frontage requirement and the minimum non-residential floor space obligation. These long-standing planning provisions are designed to maintain vibrant, permeable and safe street frontages that support pedestrian amenity. Waiving these controls purely to maximise development yield is unacceptable, and will result in a sterile, inactive street edge that diminishes pedestrian experience and compromises after-dark street safety. Setting aside well-established standard planning rules for a single site, without supporting strategic assessment, is not sound planning practice.

Beyond these community-wide planning concerns, this tower will have severe and enduring implications for my own home and quality of life. My property is situated directly to the east of the site, meaning the 154-metre building will stand due west of my dwelling.

In addition to the overwhelming visual bulk of the structure – which will dominate the view from my front entrance and replace the existing sense of openness with a pronounced sense of enclosure – the most significant impact is the permanent loss of afternoon and evening solar access. Owing to Sydney’s southern hemisphere solar trajectory, the tower will cast extensive eastward shadows across my property throughout the afternoon and evening, most acutely around the spring and autumn equinoxes when the sun sets due west.

This is not a trivial inconvenience. Our backyard is used regularly for gardening, outdoor family time and passive solar heating during the cooler months. We particularly enjoy sitting outside for dinner on summer evenings, which relies entirely on that late-afternoon sunlight. The permanent removal of late-afternoon and sunset sunlight will fundamentally alter the liveability of our home. It will reduce natural daylight penetration, diminish passive solar warmth, increase the risk of dampness within the dwelling, and severely limit the functional utility of our private outdoor space during the afternoon and evening.

The shadow modelling contained within the Environmental Impact Statement does not adequately evaluate overshadowing impacts on properties located several blocks from the site, such as my own. This is a significant gap in the assessment. Impacts that may appear acceptable within a technical report are experienced very differently by residents who will live with the loss of sunlight on a daily basis, year-round.

I also wish to raise the substantial and prolonged disruption associated with the construction phase. Demolition, deep excavation, tree removal and high-rise construction will expose nearby residents to extended periods of noise, dust, ground vibration and heavy vehicle movements on local streets. The mitigation measures outlined in the EIS are insufficient to safeguard residential amenity over the full multi-year duration of the works.

For all of the reasons outlined above, I respectfully request that this development application and the associated rezoning proposal be refused in its entirety.

Should any revised scheme be considered at a future date, it must adhere strictly to the existing 90-metre height limit and current FSR controls. Any future proposal that seeks to vary these statutory limits must be supported by independent, updated solar access modelling that comprehensively assesses impacts on properties multiple blocks from the site, and must be accompanied by a rigorous precinct-wide planning strategy and committed infrastructure upgrades.

Please provide formal written confirmation of receipt and lodgement of this objection prior to the submission closing date of 14 August 2026.

Thank you for your time and consideration of this submission.

Yours sincerely,

Please see submission attached.

I'm a student at the Queen Mary Building, which is a University of Sydney residence housing over 800 students. This construction would cause an immense amount of noise and would disrupt the studies of multiple students living in the area. We already have the RPA hospital here, so I believe there is no point of making another hospital here.

Even though the USyd colleges are disliked by the lot for their activities and what they stand for, they are part of the university community and space. If the project is to be done on the proposed land, it would heavily diminish the students’ free space that they use to express themselves (e.g. sports, arts, community gatherings…). Considering that the construction would take a while and close up strategic roads and pathways, the route to the campus for residents of Queen Mary Building will at least get 10 minutes longer. I don’t think any resident would be pleased by the noise during their finals or paying such a high rent to have to leave their “on-campus accommodation” at least 30 minutes early to catch their lectures.

Camperdown is already home to many medical facilities. It is also an increasingly unaffordable area for families to live. Building a massive private hospital will only serve to further divert attention and funding from the existing public hospital while caring only for those who can afford the cost of private care.
We do not need more private medical infrastructure. Especially not here. We need more funding and better pay for the incredible existing public hospital, which treats the community as a whole.
And if there happens to be enough spare land for a 14 story building in this area it would be far better utilised as a means to increase the availability of housing, which is sorely lacking.

I support the project.