Just as a further addition to submission already made I would like to add that in addition to our concern regarding vibrational weakening of supports to raised / elevated carport of Heritage-listed 36A Park Avenue, we would also like to raise the concern of vibrational damage to the cliff itself that this building is built into (the potential for weakening of the rock face immediately behind our building and dislodgement, causing rock fall or landslide).
This of course would not only affect our building, but multiple other homes on Park Avenue, also (32 Park Avenue, 34-36 Park Avenue and 38 Park Avenue) whose homes are also in front of the development zone.
We do not believe that potentially years of heavy demolition & construction literally two lanes across the road from this cliff would not cause referred / vibrational damage to this cliff, and we want our concerns formally recorded well ahead of any future calamity caused by the proposed development.

The following reasons are why I object to this project.

Traffic congestion
The surrounding streets (Holt Avenue, Rangers Avenue and connecting roads) are already heavily congested, especially during school and peak periods. A 91-car basement will substantially increase vehicle movements in an area with limited road capacity.

Pedestrian and cyclist safety risks
These streets are narrow, steep and used frequently by pedestrians, schoolchildren and cyclists. The proposed vehicle volumes intensify collision risks and worsen existing safety issues.

Significant view loss for Holt Avenue residents
The proposed height and bulk would remove long-established city skyline and Harbour Bridge views from numerous homes, replacing them with the facade and mass of a seven-storey apartment block.

Overdevelopment and neighbourhood impact
The scale is inconsistent with the surrounding low-rise residential character, resulting in overshadowing, loss of privacy, and a sense of enclosure for nearby properties.

Local infrastructure constraints
The cumulative strain goes beyond traffic, with limited public transport, insufficient street parking, constrained pedestrian pathways, sewage and water concerns and no capacity in the immediate area to absorb a development of this scale.

Inadequate visual, view-loss and heritage assessments
The Visual Impact Assessment omits any analysis from Holt Avenue and the Holt Estate Heritage Conservation Area, even though these sit directly north of the site. The Department requested a detailed view-loss and view-sharing assessment, which has not been provided. As a result, impacts on Sydney Harbour views, natural landform and the heritage character of the streetscape have not been properly evaluated.

No built-form transition to protected C4 and scenic areas
The development proposes maximum height and bulk directly beside C4 Environmental Living land and areas within the Scenic Protection Area. These zones were intentionally excluded from LMR due to their scenic and environmental value, yet the design provides no meaningful transition in scale.

Misalignment with SSD policy intent
Although labelled as an “affordable housing” SSD, the project primarily delivers luxury apartments, with the affordable component serving to unlock the SSD pathway rather than meeting genuine affordable-housing need.

Submission Objecting to State Significant Development
Residential Development at 11–23 Rangers Avenue, Mosman NSW

Submitted by:
Residents of Mosman NSW

Introduction
We are residents of Mosman living in close proximity to the proposed development and formally object to the State Significant Development at 11–23 Rangers Avenue.
We recognise the importance of increasing housing supply across New South Wales and are not opposed in principle to higher-density housing, having lived in apartment buildings for the majority of our adult lives. However, after carefully reviewing the application documentation, we are concerned that this proposal applies broad, state-wide planning settings to a site with very specific local constraints. In doing so, it introduces impacts that are out of proportion to the public benefit offered and that would permanently alter the character of this part of Mosman.
Approval of this proposal would also set a benchmark for future redevelopment in surrounding streets, regardless of cumulative impacts, infrastructure capacity or the area’s established character.

Height, Scale and Clause 4.6 Variations
The proposed scale of the development depends heavily on variations to both building height and wall height controls. These departures are not peripheral refinements but are necessary to achieve the building envelope, massing and yield proposed.
The justification for these variations relies largely on broad housing objectives and asserted strategic benefits, rather than on environmental planning grounds that arise from the specific attributes of this site. In particular, it is not evident why a site that is elevated, highly visible and adjacent to lower-scale and heritage-sensitive areas warrants additional height rather than a more conservative approach.
Height and wall height controls play an important role in managing visual impact and neighbourhood scale, especially on a ridgeline site. Treating these controls as flexible in order to maximise development yield risks undermining their purpose. The documentation does not adequately demonstrate that a compliant scheme could not deliver a reasonable outcome with fewer impacts.

Bulk, Visibility and Ridgeline Impacts
It is acknowledged throughout the application material that the site sits on a ridgeline and that the proposed development will be visible from a broad surrounding area. Despite this, the implications of that visibility are consistently minimised.
Visual impact assessments place significant weight on assumptions about how the area may evolve over time under Low- and Mid-Rise planning policies. At the same time, those assessments accept that the proposal will be significantly larger than surrounding development for many years to come. From a practical perspective, this means the impacts will be immediate and long-lasting, rather than transitional.
Established planning principles caution against justifying excessive scale on the basis of speculative future character, particularly where impacts involve skyline interruption and visual dominance. The proposal’s height, mass and ridgeline position create impacts that are permanent in nature and not capable of being moderated through incremental future change.

Heritage Context and Local Character
The site forms part of the visual setting of nearby heritage conservation areas, including the Holt Avenue and Spencer Street precincts.
The Heritage Impact Statement adopts a constrained methodology that places emphasis on whether the site itself is within a conservation area, rather than assessing how the proposal affects heritage significance at a precinct scale. Mitigation measures focus largely on architectural articulation and material selection, without addressing the primary driver of impact, namely excessive height and bulk in a visually sensitive location.
A building of this scale on an elevated site will function as a dominant backdrop to nearby heritage streetscapes. This alters the established relationship between built form, topography and heritage character in a manner that cannot be meaningfully mitigated and has not been satisfactorily addressed in the assessment.

Traffic, Construction and Infrastructure
Traffic and construction impacts are addressed largely through high-level modelling assumptions, generic mitigation measures and deferred management plans.
Operational traffic assessments focus on average conditions and do not adequately address localised peak-stress periods or existing choke points within the surrounding road network. Construction traffic and haulage management remain preliminary, with critical matters such as timing, staging, enforcement and interaction with existing congestion deferred.
Given the constrained geometry and existing traffic pressures on Rangers Avenue, Spofforth Street and surrounding residential streets, the level of uncertainty accepted in the documentation is disproportionate to the scale and duration of the proposed works.

Cumulative Impacts and Deferred Resolution
Across multiple technical reports, impacts are assessed individually rather than as part of a combined picture. Mitigation is frequently deferred to future management plans covering matters such as construction impacts, vibration, waste servicing, stormwater and accessibility.
While some level of deferral may be appropriate for minor technical detail, the extent of reliance on future detail in this case suggests that important issues remain unresolved at the approval stage. The Environmental Impact Statement largely aggregates consultant conclusions without a critical examination of whether, when considered cumulatively, the residual impacts remain acceptable.
This approach leaves the consent authority reliant on future resolution of matters that go to the core acceptability of the proposal.

Public Benefit and Proportionality
The public benefit cited in support of the proposal, including the affordable housing component, is limited relative to the scale of non-compliance and the permanent impacts created. The affordable housing provision relies on time-limited management arrangements rather than securing a durable public outcome.
The permanent consequences of increased height, bulk, visual dominance and infrastructure demand are not matched by a commensurate or enduring public benefit. This imbalance is particularly relevant where significant departures from development standards are relied upon.

Transparency, Consultation and Exhibition Period
A central concern is the lack of transparency in the pathway by which proposals reach public exhibition. It has become increasingly common for large development sites to be assembled and planned privately well in advance of formal exhibition, at times involving confidentiality arrangements. The practical effect is that affected communities often become aware of major proposals only once they are formally lodged, at which point opportunities for early understanding or input have already passed.
When this approach is combined with a 14-day public exhibition period, a clear imbalance arises between proponents, who may have spent months or years developing proposals, and residents, who are expected to rapidly absorb extensive technical documentation and assess long-term impacts. This timeframe is objectively insufficient for a development of this scale and complexity and does not support informed or meaningful community participation.
Regardless of the specific arrangements associated with this site, the broader reliance on shortened exhibition periods for large, complex developments undermines confidence in the consultation process. A minimum 28-day exhibition period would provide a more reasonable opportunity for residents to understand proposals, engage constructively and contribute to a transparent and well-considered assessment process.

Conclusion
This proposal represents a substantial intensification of development on a prominent and sensitive site. It relies on significant departures from established controls, understates cumulative impacts and leaves many important matters to be resolved after approval.
Combined with limited transparency and an unreasonably short exhibition period, this raises serious concerns about whether the proposal has been appropriately tested against local conditions and long-term outcomes.
For these reasons, consent should be refused. At a minimum, the proposal would require substantial redesign to reduce height and bulk, respond more appropriately to its ridgeline and heritage context, address infrastructure and construction impacts with greater certainty, and allow for a more robust and participatory assessment process.

Yours sincerely,
Residents of Mosman

I was shocked and disappointed when I reviewed the plans for this development. The proposal is completely out of character with the heritage area it sits adjacent to, and it fails to respect the established architectural rhythm and scale of the Holt Avenue Conservation Area.
Appendix M – Design Report 1, Section 1.3, clearly outlines the local architectural character of this neighbourhood and the apartment buildings in the surrounding streets. None of the buildings referenced in Section 1.8 are located within or immediately adjoining the conservation area. As such, they do not currently impose any negative impact on the heritage significance or visual integrity of Holt Avenue. This development, however, would.
In addition to the heritage concerns, the traffic implications are extremely troubling. Traffic in this area is already at gridlock most days of the week — from approximately 7:30–10:00am and 3:00–5:00pm on weekdays. On weekends, depending on weather, traffic flow slows significantly from around 9:00am–6:00pm.
Due to the topography of the site, with a cliff on one side, all vehicles must funnel along Rangers Avenue before reaching any feeder road. This development will inevitably worsen congestion, creating further bottlenecks and delays for existing residents.
There is also no indication that additional public transport services will be provided to support the increased population density. Buses and ferries are already at capacity, and it is often extremely difficult to board services during peak periods. Without commitments to expanded routes, increased frequency, or new services, this development will place unsustainable pressure on already overstretched public transport infrastructure.
For these reasons — heritage incompatibility, traffic impacts, and inadequate transport planning — I strongly oppose the development in its current form.

The Canyonleigh BESS is being advanced despite unresolved questions regarding long-term environmental impacts, poison, battery degradation, disposal requirements and emergency management.
Precaution should come before approval. Once environmental damage occurs, it cannot be fixed.

WE ABSOLUTELY OBJECT TO X-ELIO’s CANYONLEIGH BESS BOMB - THE ASBESTOS OF THE FUTURE!


👉🏻Lack of Diligent Risk Research and Futility of Zero Carbon

To NSW Parliament House on June 4, 2026 Macquarie Street, Sydney

Dear Legislative Assembly Member,
As an expert in risk assessment and mitigation at the University of Sydney I was endowed with the status emeritus, recognising these skills in 2011 by The University of Sydney Senate.
Since then, I have been amazed at the unnecessary speed of introduction of renewable wind and solar power stations with almost complete lack of due diligence regarding the huge environmental risks involved.
Given its scale and capability of even changing the climate as our published research shows, this negligence of future risks to farming in hot and often dry, Australia should be found legally culpable, as it would be for normal commercial and industry corporation research.

From my personal expertise in rural risk research I draw your attention to following relevant issues.
(1) My recent appearance and submissions at the Portfolio 4 Committee REZ hearing attached.
This refers to wind turbine power stations drying out their downwind wakes as a result of turbulent warming.
This is an area of my expertise, as shown in our recent publications included.
Bushfire disasters such as those on Maui in 2023, in Athens and more recently in Los Angeles may be caused in future.
Risk research is needed to resolve the issue that the weather is so affected by large wind turbines in hot, dry, Australia. Farming productivity may be reduced and bushfire risk increased.
(2) An attached preprint article to be submitted draws attention to infrasound generated by the high speed impulses of wind turbine blades, using our novel method to estimate maximum electrical power by wind turbines.
Pressure waves generated by t he rear of the blades interacting with steel turbine towers could generate impulses equivalent to infrasound exceeding 150 decibels, possibly propagated several times further than audible sound from turbines.

Risk research for humans, livestock and native animals is needed, because of neglect of this area, shown in Attachment 2 on Mitigating Risks.

(3) My personal submissions opposing the solar power stations at Muswellbrook, Tallawang and Dinawan in NSW predict that tonnes of heavy metals in solar power stations will slowly be leached into several hundred thousands hectares of prime farming soil, binding tightly and preventing their return to producing food or fibre forever. Research to prevent contamination of soil and streams is essential, particularly in extreme risk as in hailstorms: I have requested the University should do such research for the Spark Renewables power station on Arthursleigh, near Marulan.

The purpose of risk assessment is to quantify potential hazards and to develop best management practices to mitigate any serious consequences shown.
Once these aims are achieved diligently, the effectiveness of these best practices must still be checked to verify these benefits.
The almost complete lack of proper field risk research by government and environmental authorities as normally practiced for new agricultural technology is a wanton failure in these procedures.
Desk-top assessments like those conducted by the Planning Commission of NSW are no substitute for valid analyses of these field hazards, always a function of local circumstances.

Australia has many examples of such proper research being conducted with successful results. In own research experience at university, the threat of losing major international markets for months if livestock is polluted, as happened from chlorfluazuron (Helix) contamination in the mid-1990s, is just one serious example.
This tragedy resulted in the introduction of safer chemicals, confirmed by risk research and even the successful protection of crops non-chemically with natural Bt toxins in crops such as cotton; this was promoted by Rachel Carson, though by expressing genes for Bacillus thuringiensis insect toxins.

Apart from infrasound that needs more investigation, bis-phenol and PFAS represent new threats still lacking resolution, as discussed in my main submission to the Victoria Planning Panel Hexham Hearing recently.

It is recommended to the NSW Parliament that the introduction of major renewable energy to mitigate climate change should be suspended for at least 5-10 years, so that essential field risk research is funded to provide information allowing safer locations of power stations.

Suitable monitoring for land pollution by current power stations can also be provided. If climate change can be managed, that will only be achieved by trustworthy verifying research beforehand.

Considering that 91% of Australia’s needs for energy in 2025 were still met by fossil fuels, oil 41%, gas and coal, 25% each, as shown by official government data there is no reason to act with such haste hoping to control global warming.

Renewable wind and solar energy should be investigated carefully, including research on existing wind and solar installations for harmful results such as turbulent drying of landscapes or contamination of soil and livestock with heavy metals leaching from solar panels.

Furthermore, our recent published research given in the Portfolio 4 Committee attachment suggests that the quest for zero carbon may be futile, given the overall cycling of carbon dioxide in planetary terms.

There is no need for undue haste.
For verification of this futility, please consult Google AI with “Thermal calcification Kennedy” for an opinion on our research questioning the IPCC model.
Our published research shows the lability of carbon dioxide.
When the Earth is colder with a higher pH in surface seawater carbon dioxide is absorbed. When it is warming, extra calcification causes a lower surface pH, when carbon dioxide is released to the atmosphere.

Yours faithfully,
Ivan Robert Kennedy AM FRACI CChem
Professor Emeritus in Agricultural & Environmental Chemistry School of Life and Environmental Sciences
University of Sydney NSW 2006,
Mobile: 0413071796

Ivan R. Kennedy

Emeritus Professor in Agricultural & Environmental Chemistry, University of Sydney Executive Director, Quick Test Technologies

Please refer to Attachment.