The height of the proposed building is too high and not compatible with the surrounding developments. This will bring congestion to the roads nearby, especially in the morning school runs, which I see daily. Whoever did the consulting omitted this fact. Homebush train station will also get busier, with peak hour services already crowded. Local schools might not be able to cater for the influx of people. This area is being over-developed at present, with at least 3 residential towers already under construction. Once completed the problems mentioned previously will get exacerbated.

I have major concerns for the traffic reprot and utiltiy and flood reports.

1. Traffic and Infrastructure Concerns Regarding Appendix O – Transport Impact Assessment
I strongly object to the conclusion of the Traffic Impact Assessment (TIA) that the existing road infrastructure can accommodate the proposed development without capacity upgrades. My concerns are outlined below:

A. Morning Peak Traffic Conditions
The TIA indicates only minor increases in delays (1–2 seconds) at major intersections; however, this analysis relies on average delays and Level of Service (LOS), which do not reflect the worst-case scenarios or the experience of local drivers.
Key arterial intersections (Parramatta Rd/Bridge Rd and Parramatta Rd/Knight St) are projected to operate at LOS C/D by 2035—technically “satisfactory,” but close to capacity. Any incident or signal fault could result in significant delays.
The analysis fails to account for future adjacent developments, including the proposed 75m building at 21 Loftus Crescent and 136m building at 12 Loftus Crescent.

B. Trip Generation Assumptions
Residential trip rates (0.19 trips/unit/hr in AM) are at the lower end for Sydney, assuming high public transport uptake. If actual car usage is higher—due to school runs, shift workers, or limited public transport—traffic volumes will exceed forecasts.
Retail trip estimates are modest; however, if a high-turnover retail outlet operates, these figures may be underestimated.

C. Loftus Lane Usage
Loftus Lane must not be used for construction vehicles. It is a one-way road, yet the swept path analysis (Page 135 of Appendix O) shows dual-direction vehicle movements, which is unacceptable.

D. Pedestrian and Cyclist Impacts
Pedestrian LOS at signals is LOS E (54-second delay), which is poor.
No upgrades are proposed to improve pedestrian or cyclist safety at intersections expected to experience increased traffic.

2. Appendix II – Utilities Infrastructure
The report does not confirm whether the existing utilities infrastructure can adequately support the proposed development. Key authorities, including Ausgrid, Jemena, and Sydney Water, have not been contacted, and no formal confirmation has been obtained. A Section 73 Feasibility Application should be lodged with Sydney Water to verify water and sewer capacity before proceeding.

3. Appendix M – Flood Impact Risk Assessment
Shelter in place - the floor level shall be higher than the PMF, not only to the relative FPL. Also the PMF level should also consider climate change factor (20%).

This submission is on behalf of the landowners (The Trust Company (Australia) Limited as trustee for the Keppel REIT (Australia) Sub-Trust 6) of the neighbouring property at 6 Giffnock Avenue, Macquarie Park (Lot 103 DP1267452).

We would like to raise the following key concerns with the proposal -

- Engagement – as landowners of the neighbouring site, Keppel REIT were not consulted during the pre-lodgement phase for the SSDA. Keppel REIT would invite Holdmark and the project team to engage directly to discuss key aspect of the proposal.

- Amenity – the proposal seeks substantial variations over the height and FSR controls. Consequently, overshadowing, visual impact, privacy and other impacts from the built form are of concern. Further analysis is required to further mitigate visual impact, privacy and overshadowing impacts.

- Affordable housing – the proposal seeks to reduce the affordable housing component of the development compared to the required 10%. By reducing the affordable housing component, there is concern that this will increase the burden on other development sites to carry the deficit to achieve the government’s target of affordable housing provisions within the Macquarie Park Precinct.

- Drake Avenue – there are proposed works to widen Drake Avenue. It is unclear from the Traffic Impact Assessment whether there will be any traffic and access impacts to 6 Giffnock Avenue and other neighbouring sites during the construction of the road widening works. Further detail should be provided.

- Child-care centre – market demand for the proposed childcare centre – the economic impact assessment provided as part of the SSDA package does not provide an assessment of the demand for the quantum of childcare spaces proposed. Question is raised regarding the appropriateness of the scale of the childcare centre provided.

Keppel REIT intend to provide a more detailed submission regarding the above matters under separate cover. In the meantime, we thank the Department for providing the opportunity to make this submission.

Please find attached submission.

I support the project but think the 10% AH charge should be maintained.