Susan Wittenoom
Object
Susan Wittenoom
Object
REDFERN
,
New South Wales
Message
As the owner of a unit in Crescent Street Redfern, and a unit in Hunter Street Waterloo, I strongly object to the proposed additional building height, additional residential units and increase in gross floor area for 903-921 Bourke Street Waterloo.
Reasons for objection
1. This site is the subject of an approved master plan and development consent that is already increasing the supply of well-located housing.
This site is making a substantial contribution of 347 units to assist in meeting housing targets in the City of Sydney LGA which will work to address the housing crisis in NSW. The City of Sydney's track record in urban renewal at Green Square is exemplary and their responsibility for this development should not be upended by the HDA pathway. The existing approval made a considered assessment of neighbourhood amenity and transport impacts. This HDA application will undermine the quality of the built environment for everyone in Waterloo, and most directly for all new residents in the combined Bourke Street sites.
2. This site is not a transport oriented development (TOD): "sky-rise" and "high-rise" towers belong over a train station, not in Bourke Street where everyone catches a bus to get to a train station.
The site falls outside the 10 minute walking zones for both Waterloo Metro and Green Square Station as shown in UNSW City Futures TOD atlas:
https://www.unsw.edu.au/research/city-futures/cityviz/transport-oriented-development-atlas-sydney
This location is not "exceptional access". Current residents rely on the Bourke Street bus routes for station access. The reports attached to this application contain numerous errors regarding the provision of bus services - there are no buses in McEvoy street and list bus routes that no longer operate.
3. The proposed towers are too high for Redfern/Waterloo/Green Square and will destroy the inner city character: the successful precedent in this neighbourhood is densification through 10 storey street walls with "episodic" towers of 20 storeys - not 40 storeys.
This uplift proposal is compromised by timing; the application is made while the previous masterplan is under construction. Simply extruding the approved footprints will not "retain the core architectural strategy", it is a mockery of the design excellence process. The additional 36 levels across the two towers more than double the original number of storeys. The public realm around the heritage buildings on the site will be shaded and dwarfed by towers that belong in a central business district.
4. The grass won't cope with the increased population: additional residents in the uplift design will destroy the viability of the one public green space provided to the combined Danks Street masterplan. This lawn will not be able to cope with increased daily dog traffic and will be constantly fenced off to pets and people for turf recovery.
The combined Danks Street masterplan sites are already providing social, affordable, rental and market housing. This application is an overblown opportunistic claim for development yield which sacrifices amenity for future residents and their neighbours. It should be rejected.
Reasons for objection
1. This site is the subject of an approved master plan and development consent that is already increasing the supply of well-located housing.
This site is making a substantial contribution of 347 units to assist in meeting housing targets in the City of Sydney LGA which will work to address the housing crisis in NSW. The City of Sydney's track record in urban renewal at Green Square is exemplary and their responsibility for this development should not be upended by the HDA pathway. The existing approval made a considered assessment of neighbourhood amenity and transport impacts. This HDA application will undermine the quality of the built environment for everyone in Waterloo, and most directly for all new residents in the combined Bourke Street sites.
2. This site is not a transport oriented development (TOD): "sky-rise" and "high-rise" towers belong over a train station, not in Bourke Street where everyone catches a bus to get to a train station.
The site falls outside the 10 minute walking zones for both Waterloo Metro and Green Square Station as shown in UNSW City Futures TOD atlas:
https://www.unsw.edu.au/research/city-futures/cityviz/transport-oriented-development-atlas-sydney
This location is not "exceptional access". Current residents rely on the Bourke Street bus routes for station access. The reports attached to this application contain numerous errors regarding the provision of bus services - there are no buses in McEvoy street and list bus routes that no longer operate.
3. The proposed towers are too high for Redfern/Waterloo/Green Square and will destroy the inner city character: the successful precedent in this neighbourhood is densification through 10 storey street walls with "episodic" towers of 20 storeys - not 40 storeys.
This uplift proposal is compromised by timing; the application is made while the previous masterplan is under construction. Simply extruding the approved footprints will not "retain the core architectural strategy", it is a mockery of the design excellence process. The additional 36 levels across the two towers more than double the original number of storeys. The public realm around the heritage buildings on the site will be shaded and dwarfed by towers that belong in a central business district.
4. The grass won't cope with the increased population: additional residents in the uplift design will destroy the viability of the one public green space provided to the combined Danks Street masterplan. This lawn will not be able to cope with increased daily dog traffic and will be constantly fenced off to pets and people for turf recovery.
The combined Danks Street masterplan sites are already providing social, affordable, rental and market housing. This application is an overblown opportunistic claim for development yield which sacrifices amenity for future residents and their neighbours. It should be rejected.
Andrew Lowe
Object
Andrew Lowe
Object
REDFERN
,
New South Wales
Message
I wish to raise a strong objection against the development proposed for 903-921 Bourke St, Waterloo, arguing that it constitutes an overdevelopment that should be refused as it is not in the public interest. The site already has an approved development, with construction commenced, which was based on carefully developed, democratic controls and provided a reasonable balance between increased housing supply and protecting liveability and amenity.
The proposed development is fundamentally different, imposing unreasonably on current and future residents through a massive increase in bulk and scale. The proposal increases the height from 21 to 38 storeys and raises the Floor Space Ratio (FSR) from 2:1 to 3.2:1, yet it improperly relies on the site structure designed for the much smaller, approved development.Unreasonable Impacts and Inadequate Assessment
The significant likely impacts of the proposal have not been fully assessed, with the existing assessment indicating the site is not suitable. The excessive bulk and scale will create negative solar, wind, privacy, visual, and social impacts on neighboring properties and the public domain.
Social Impacts and Infrastructure: The proposal will unreasonably strain already-at-capacity local infrastructure. Statements in the Environmental Impact and Rezoning Statement claiming the site is well-served by public transport are misleading; walks to Green Square or Waterloo metro stations take 20 minutes or more, and local buses are already full, making morning boarding impossible. Local schools are also under significant pressure, leading to frequent adjustments and reductions in catchment sizes. The Social Impact Assessment recognizes this increased demand but acknowledges the proposal will not address many of these needs.
Failure to Assess: The applicant's failure to properly assess and mitigate impacts from the massive scale increase is evident, particularly when the Environmental Impact and Rezoning Statement asserts that the proposal will not result in any significant adverse impacts. This failure means the requirements of s 4.15(b), (c), and (e) concerning impact assessment, site suitability, and public interest are not satisfied.
Visual Impact: The Visual Impact assessment is inadequate because it primarily assesses public views from points deemed to be of "negligible significance," while sites of "moderate significance," such as parks and lookouts, have not been assessed, further violating s 4.15(b).
Inconsistencies with Planning and Feedback
The development fails to align with key planning objectives and feedback:
Better Placed Objectives: Despite being far larger than the current approval, the proposal only "maintains the previously approved deep soil provision, street setbacks and building footprints, and public domain," provisions that are inadequate for the increased scale. Furthermore, the ESD features are standard, and describing BASIX—a minimum requirement—as "best practice sustainability" is inaccurate. The development contributes little to sustainability or community support beyond mandated open spaces.
SDRP Recommendations: The applicant did not adequately respond to feedback from the State Design Review Panel (SDRP). Recommendations ignored include increasing separation between the Young Street Tower and the Plaza Building, demonstrating ADG compliance (as non-compliances like solar access remain), and ensuring natural light to corridors. Instead of avoiding negative impacts on residential amenity, impacts were merely described as "not unreasonable".
EPA Act Objects: The proposal is inconsistent with the objects of the EPA Act because it does not promote social and economic welfare or a better environment (a), nor good design and amenity (g). The rezoning and scale increase of a project already under construction is not considered the orderly and economic use of land (k).
Community Engagement
Community engagement has been "woefully inadequate". The new proposal is being rushed through without the support of the community or elected representatives in the City of Sydney. The consultation (one webinar, some calls/emails) and the distribution of leaflets to a "tiny" catchment are insufficient compared to the extensive consultation that produced the site's original controls, failing the EPA Act object (h).
The proposed development is fundamentally different, imposing unreasonably on current and future residents through a massive increase in bulk and scale. The proposal increases the height from 21 to 38 storeys and raises the Floor Space Ratio (FSR) from 2:1 to 3.2:1, yet it improperly relies on the site structure designed for the much smaller, approved development.Unreasonable Impacts and Inadequate Assessment
The significant likely impacts of the proposal have not been fully assessed, with the existing assessment indicating the site is not suitable. The excessive bulk and scale will create negative solar, wind, privacy, visual, and social impacts on neighboring properties and the public domain.
Social Impacts and Infrastructure: The proposal will unreasonably strain already-at-capacity local infrastructure. Statements in the Environmental Impact and Rezoning Statement claiming the site is well-served by public transport are misleading; walks to Green Square or Waterloo metro stations take 20 minutes or more, and local buses are already full, making morning boarding impossible. Local schools are also under significant pressure, leading to frequent adjustments and reductions in catchment sizes. The Social Impact Assessment recognizes this increased demand but acknowledges the proposal will not address many of these needs.
Failure to Assess: The applicant's failure to properly assess and mitigate impacts from the massive scale increase is evident, particularly when the Environmental Impact and Rezoning Statement asserts that the proposal will not result in any significant adverse impacts. This failure means the requirements of s 4.15(b), (c), and (e) concerning impact assessment, site suitability, and public interest are not satisfied.
Visual Impact: The Visual Impact assessment is inadequate because it primarily assesses public views from points deemed to be of "negligible significance," while sites of "moderate significance," such as parks and lookouts, have not been assessed, further violating s 4.15(b).
Inconsistencies with Planning and Feedback
The development fails to align with key planning objectives and feedback:
Better Placed Objectives: Despite being far larger than the current approval, the proposal only "maintains the previously approved deep soil provision, street setbacks and building footprints, and public domain," provisions that are inadequate for the increased scale. Furthermore, the ESD features are standard, and describing BASIX—a minimum requirement—as "best practice sustainability" is inaccurate. The development contributes little to sustainability or community support beyond mandated open spaces.
SDRP Recommendations: The applicant did not adequately respond to feedback from the State Design Review Panel (SDRP). Recommendations ignored include increasing separation between the Young Street Tower and the Plaza Building, demonstrating ADG compliance (as non-compliances like solar access remain), and ensuring natural light to corridors. Instead of avoiding negative impacts on residential amenity, impacts were merely described as "not unreasonable".
EPA Act Objects: The proposal is inconsistent with the objects of the EPA Act because it does not promote social and economic welfare or a better environment (a), nor good design and amenity (g). The rezoning and scale increase of a project already under construction is not considered the orderly and economic use of land (k).
Community Engagement
Community engagement has been "woefully inadequate". The new proposal is being rushed through without the support of the community or elected representatives in the City of Sydney. The consultation (one webinar, some calls/emails) and the distribution of leaflets to a "tiny" catchment are insufficient compared to the extensive consultation that produced the site's original controls, failing the EPA Act object (h).
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
I strongly oppose the proposal requesting major modifications and changes the existing development plans for 903-921 Bourke Street, Waterloo (SDD-95997711) for the following reasons:
1. Public transport: routes 343, 320, 304 all seem to be currently reaching passenger capacity during peak hours.
Has the government, the council, DASCO or neighbouring developer Coronation, conducted any reporting to identify how the additional number of apartment residents would impact our public transport services? Or identified what an increase to future resident numbers would mean/cost for the need to schedule bus services during peak hours.
2. Pedestrian safety: Bourke Street is a shared path (bicycles and foot traffic) - all along this section of footpath is already dangerous as bikes speed past pedestrians. What, if any, safety measures for pedestrians have been proposed by DASCO? EG road widening, bridges, zebra crossings?
3. Council: increase in residents, increase in amount of garbage, increasing strain on garbage collection trucks.
4. Emergency Services strain: increase in situations that may require police, fire and ambo.
5. Health: increased strain on local medical centre services.
6. Green spaces: any green spaces within this site will need sunshine to grow and establish, the extra height will substantially minimise the amount of sunlight any plantings receive each day.
7. Shadowing: the added height will detract from the whole site, creating wind tunnels and shade throughout. This will potentially affect the mental health for residents living in the lower levels as natural light and sunlight will be obstructed.
8. Character: buildings as high as 31 and 38 storeys are severely out of character for this immediate area. Considering the terraces to the north, the terraces to the west. Even the apartment buildings to the east and south are not as high as this modification proposal.
The City of Sydney has approved the original plans. It is the original plans that should be kept.
Who pays for more:
Bus services
Council garbage collections
Policing and fire brigade call outs
Local residents and the future residents who will choose to move into the new buildings (at 12 and 21 storeys) have a right to enjoy peaceful living, community safety and clean surroundings.
I can accept the need for housing, am happy to see the site being developed, happy to welcome new residents into the area and understand the growth that is occurring in most Sydney suburbs however, DASCO and Coronation have both submitted major modifications and scaled-up changes and neither should be approved.
Both the site and the surrounding local area should be respected, by blending these new buildings into the area, at an appropriate height.
Thank you
1. Public transport: routes 343, 320, 304 all seem to be currently reaching passenger capacity during peak hours.
Has the government, the council, DASCO or neighbouring developer Coronation, conducted any reporting to identify how the additional number of apartment residents would impact our public transport services? Or identified what an increase to future resident numbers would mean/cost for the need to schedule bus services during peak hours.
2. Pedestrian safety: Bourke Street is a shared path (bicycles and foot traffic) - all along this section of footpath is already dangerous as bikes speed past pedestrians. What, if any, safety measures for pedestrians have been proposed by DASCO? EG road widening, bridges, zebra crossings?
3. Council: increase in residents, increase in amount of garbage, increasing strain on garbage collection trucks.
4. Emergency Services strain: increase in situations that may require police, fire and ambo.
5. Health: increased strain on local medical centre services.
6. Green spaces: any green spaces within this site will need sunshine to grow and establish, the extra height will substantially minimise the amount of sunlight any plantings receive each day.
7. Shadowing: the added height will detract from the whole site, creating wind tunnels and shade throughout. This will potentially affect the mental health for residents living in the lower levels as natural light and sunlight will be obstructed.
8. Character: buildings as high as 31 and 38 storeys are severely out of character for this immediate area. Considering the terraces to the north, the terraces to the west. Even the apartment buildings to the east and south are not as high as this modification proposal.
The City of Sydney has approved the original plans. It is the original plans that should be kept.
Who pays for more:
Bus services
Council garbage collections
Policing and fire brigade call outs
Local residents and the future residents who will choose to move into the new buildings (at 12 and 21 storeys) have a right to enjoy peaceful living, community safety and clean surroundings.
I can accept the need for housing, am happy to see the site being developed, happy to welcome new residents into the area and understand the growth that is occurring in most Sydney suburbs however, DASCO and Coronation have both submitted major modifications and scaled-up changes and neither should be approved.
Both the site and the surrounding local area should be respected, by blending these new buildings into the area, at an appropriate height.
Thank you
Julian Talarico
Object
Julian Talarico
Object
WATERLOO
,
New South Wales
Message
To whom it may concern,
I am a resident of the Waterloo community and I write with regards to the proposed major amendments to the development at 903-921 Bourke Street Waterloo. I strongly oppose the proposed changes, and ask that the proposed amendments not be approved, leaving the project at the scope that was originally approved.
It is unclear how the proposed amendments provide additional benefits to the development, community and local area. The previous approved development (DA/2012/1415) provides an acceptable, considered and balanced response to development of the site, which increases density in the area in meeting housing and affordability needs while being sensitive to the local environment and character of the area.
The current proposed amendments add height to six buildings on the site with an increase of 203 apartments (54% increase) and 57% increase in Gross Floor Area from the approved development. Considering these numbers, it becomes immediately evident how significant a deviation this is from the original approved proposal. It is concerning that these proposed changes are not supported by commensurate increases in the amount of communal spaces, amenities and parking spaces. While the proposal pushes to increase density, I would suggest that this ill-considered and inadequately supported by mitigations in the development proposal.
Beyond the development itself, such an increase in the scale of the development, will place more pressure on local infrastructure including roads, access to community resources, public transport. As a local resident, my experience is that these are already stretched.
To achieve these increases, the proposed amendments focus on two buildings - Bourke Street North and Young Street Tower - and increases their height 31 and 38 floors respectively (a 158% and 81% increase, respectively). In absolute terms, these are far too tall for this area, and not in keeping with the character of the locality. These proposed towers will be visually overbearing and taller than any other buildings in the area. They will also contribute to overshadowing of nearby homes and public spaces. They have the potential to significantly detract from the visual character of the Waterloo area and surrounds and to continue to do so into the distant future.
The local community has seen in developments such as Surry Hills Village that sensitively designed architecture and development can enhance and revitalise areas. Conversely, as in parts of Green Square, we see how excessive building height and a focus on maximising density can detract from the character and lived experience of an area.
I was dismayed to read some of the assessments accompanying this proposal. The Social Impact Assessment for SSD Housing prepared by Sarah George Consulting appears to over-report potential benefits, minimise impacts and suggests inadequate mitigations. This assessment relies heavily on existing parts of the approved development and utilises these as if they were novel justifications and mitigations for the significant proposed changes. It does not adequately describe how the proposed changes will cause social impact, and highlights that meaningful additional mitigations are lacking.
Likewise, the Visual Impact Assessment concludes a multitude of negligible and low impacts but utilises viewpoint locations with elevations, existing vegetation and built environment that minimise the proposed towers' rendered appearance. Furthermore, in location photos, wide landscape images are used, which crop out the vertical aspect, where the bulk of the proposed height changes would be apparent. Whether by methodological or selection limitations, I believe this report significantly under-represents how these 31- and 38-story towers would impact the local landscape and be affect the lived experience of Waterloo residents.
For all of the above reasons, I express my significant concern for the proposed major amendments to the development at 903-921 Bourke Street and ask that these are not approved. The development, community and residents will be better served by allowing the development to be completed as already approved.
I am a resident of the Waterloo community and I write with regards to the proposed major amendments to the development at 903-921 Bourke Street Waterloo. I strongly oppose the proposed changes, and ask that the proposed amendments not be approved, leaving the project at the scope that was originally approved.
It is unclear how the proposed amendments provide additional benefits to the development, community and local area. The previous approved development (DA/2012/1415) provides an acceptable, considered and balanced response to development of the site, which increases density in the area in meeting housing and affordability needs while being sensitive to the local environment and character of the area.
The current proposed amendments add height to six buildings on the site with an increase of 203 apartments (54% increase) and 57% increase in Gross Floor Area from the approved development. Considering these numbers, it becomes immediately evident how significant a deviation this is from the original approved proposal. It is concerning that these proposed changes are not supported by commensurate increases in the amount of communal spaces, amenities and parking spaces. While the proposal pushes to increase density, I would suggest that this ill-considered and inadequately supported by mitigations in the development proposal.
Beyond the development itself, such an increase in the scale of the development, will place more pressure on local infrastructure including roads, access to community resources, public transport. As a local resident, my experience is that these are already stretched.
To achieve these increases, the proposed amendments focus on two buildings - Bourke Street North and Young Street Tower - and increases their height 31 and 38 floors respectively (a 158% and 81% increase, respectively). In absolute terms, these are far too tall for this area, and not in keeping with the character of the locality. These proposed towers will be visually overbearing and taller than any other buildings in the area. They will also contribute to overshadowing of nearby homes and public spaces. They have the potential to significantly detract from the visual character of the Waterloo area and surrounds and to continue to do so into the distant future.
The local community has seen in developments such as Surry Hills Village that sensitively designed architecture and development can enhance and revitalise areas. Conversely, as in parts of Green Square, we see how excessive building height and a focus on maximising density can detract from the character and lived experience of an area.
I was dismayed to read some of the assessments accompanying this proposal. The Social Impact Assessment for SSD Housing prepared by Sarah George Consulting appears to over-report potential benefits, minimise impacts and suggests inadequate mitigations. This assessment relies heavily on existing parts of the approved development and utilises these as if they were novel justifications and mitigations for the significant proposed changes. It does not adequately describe how the proposed changes will cause social impact, and highlights that meaningful additional mitigations are lacking.
Likewise, the Visual Impact Assessment concludes a multitude of negligible and low impacts but utilises viewpoint locations with elevations, existing vegetation and built environment that minimise the proposed towers' rendered appearance. Furthermore, in location photos, wide landscape images are used, which crop out the vertical aspect, where the bulk of the proposed height changes would be apparent. Whether by methodological or selection limitations, I believe this report significantly under-represents how these 31- and 38-story towers would impact the local landscape and be affect the lived experience of Waterloo residents.
For all of the above reasons, I express my significant concern for the proposed major amendments to the development at 903-921 Bourke Street and ask that these are not approved. The development, community and residents will be better served by allowing the development to be completed as already approved.
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
Mixed Use Development – 903 to 921 Bourke Street, Waterloo
I write to formally object to the proposed mixed use development at 903 to 921 Bourke Street, Waterloo.
The proposed increase in height and scale from approximately 12 storeys to buildings of up to 31 and 38 storeys is excessive and fundamentally inconsistent with the existing and emerging character of the surrounding area. The scale of the proposal represents a dramatic departure from the prevailing built form and is not compatible with the established low to mid-rise mix that currently defines the suburb.
Incompatibility with Local Character
Waterloo is characterised by a varied but generally moderate built form, with a strong residential street scale and nearby heritage items that reflect the area’s historical and social significance. The proposed building heights and density are out of proportion with surrounding development and will overwhelm the local streetscape. This level of intensification is not supported by the existing character of the suburb and risks permanently altering its identity.
Impacts on Heritage and Overshadowing
There are heritage-listed properties located only one street away from the proposed site. The scale of this development raises serious concerns regarding overshadowing, loss of amenity and visual dominance over these heritage buildings. Such impacts are inconsistent with sound planning principles, which require the protection of heritage values and appropriate transitions in scale and height.
Infrastructure and Transport Constraints
While proximity to public transport is often cited to justify increased density, the Metro station remains a significant distance from the site. The development therefore cannot reasonably be characterised as transit-oriented. In addition, there is currently insufficient supporting infrastructure to accommodate the level of population increase proposed, including public transport capacity, local roads, community facilities and essential services.
Overdevelopment and Parking Impacts
The proposal forms part of a broader wave of development that is expected to deliver approximately 4,000 new apartments in the area. This level of development, combined with limited parking provision, is likely to result in significant pressure on already constrained street parking, increased congestion and reduced residential amenity for existing residents.
Conclusion
The proposed development represents an excessive and unjustified increase in height and density that is not aligned with the character of Waterloo, fails to adequately protect nearby heritage properties, and is not supported by the necessary infrastructure or transport accessibility. For these reasons, the application should not be supported in its current form.
I respectfully request that the consent authority give serious consideration to these concerns and refuse the application, or require substantial reductions in height, scale and density to better align with the surrounding area and community expectations.
Yours sincerely,
I write to formally object to the proposed mixed use development at 903 to 921 Bourke Street, Waterloo.
The proposed increase in height and scale from approximately 12 storeys to buildings of up to 31 and 38 storeys is excessive and fundamentally inconsistent with the existing and emerging character of the surrounding area. The scale of the proposal represents a dramatic departure from the prevailing built form and is not compatible with the established low to mid-rise mix that currently defines the suburb.
Incompatibility with Local Character
Waterloo is characterised by a varied but generally moderate built form, with a strong residential street scale and nearby heritage items that reflect the area’s historical and social significance. The proposed building heights and density are out of proportion with surrounding development and will overwhelm the local streetscape. This level of intensification is not supported by the existing character of the suburb and risks permanently altering its identity.
Impacts on Heritage and Overshadowing
There are heritage-listed properties located only one street away from the proposed site. The scale of this development raises serious concerns regarding overshadowing, loss of amenity and visual dominance over these heritage buildings. Such impacts are inconsistent with sound planning principles, which require the protection of heritage values and appropriate transitions in scale and height.
Infrastructure and Transport Constraints
While proximity to public transport is often cited to justify increased density, the Metro station remains a significant distance from the site. The development therefore cannot reasonably be characterised as transit-oriented. In addition, there is currently insufficient supporting infrastructure to accommodate the level of population increase proposed, including public transport capacity, local roads, community facilities and essential services.
Overdevelopment and Parking Impacts
The proposal forms part of a broader wave of development that is expected to deliver approximately 4,000 new apartments in the area. This level of development, combined with limited parking provision, is likely to result in significant pressure on already constrained street parking, increased congestion and reduced residential amenity for existing residents.
Conclusion
The proposed development represents an excessive and unjustified increase in height and density that is not aligned with the character of Waterloo, fails to adequately protect nearby heritage properties, and is not supported by the necessary infrastructure or transport accessibility. For these reasons, the application should not be supported in its current form.
I respectfully request that the consent authority give serious consideration to these concerns and refuse the application, or require substantial reductions in height, scale and density to better align with the surrounding area and community expectations.
Yours sincerely,
Gundula Brown
Object
Gundula Brown
Object
WATERLOO
,
New South Wales
Message
I am writing to express my strong opposition to the amended proposal. I live approximately 450 metres from the former Sydney Water site on Bourke Street, and I chose this neighbourhood deliberately to have a home for our family, to live in a community with safe footpaths and parks, and to build a long‑term home. This development, in its current form, threatens the very qualities that make this area liveable, particularly for families, older residents, and those who are already vulnerable.
My concern is not about adding more housing. It is about ensuring that the housing delivered here is genuinely accessible, supports people to age in place, and keeps essential workers, families, and long‑term residents connected to their community. The proposal for 580 apartments starting at nearly $1 million for a one‑bedroom unit does not meet those needs. It delivers density without delivering affordability.
My objections fall into three key areas:
(1) critical gaps in the evidence base,
(2) the removal of community protections without any binding replacement, and
(3) an “affordable housing” offer that may result in no affordable homes being delivered at all.
1. The evidence base is incomplete
Contamination risks have not been properly assessed.
Two new basements are proposed in areas where previous assessments identified potential soil vapour contamination. The applicant’s own documentation acknowledges that key information — including final floor levels and full vapour intrusion modelling — is missing. Approving a development of this scale without complete contamination data is unsafe and unacceptable.
The wind assessment relies on an unapproved neighbouring development.
The modelling assumes the construction of another project that has not been approved. If that development does not proceed or is altered, the wind assessment becomes invalid. A revised assessment based solely on approved developments is essential.
2. Community protections are being removed with nothing binding in return
The original planning controls required both a competitive design process and contributions to community infrastructure. These safeguards recognised the scale of the site and the pressure additional residents would place on local services.
The amended proposal seeks exemption from both obligations while nearly doubling the approved height. A 126‑metre tower on a heritage‑sensitive site cannot be left to self‑assessment by the developer’s own consultants. Independent design review is essential.
At the same time, the proposal removes the requirement to contribute to community infrastructure — despite the applicant’s own Social Impact Assessment acknowledging that Waterloo is already under strain in childcare, schools, recreation, and aged care. The public is being asked to accept a 55% increase in apartments with no additional community benefit.
The existing VPA was negotiated for a much smaller development. The same public infrastructure cannot be presented as adequate compensation for a significantly larger project.
3. The affordable housing offer is not guaranteed to deliver any affordable homes
The proposal references a 12% affordable housing contribution, yet the applicant also states they are not bound by the City of Sydney’s Affordable Housing Program — the very policy from which the 12% figure is drawn. Without a binding VPA, this commitment has no enforceability.
Both the mandatory 3% and the proposed 12% contributions can be satisfied through cash payments rather than actual dwellings. This means the development could proceed with zero affordable homes delivered on site.
This neighbourhood needs real, long‑term affordable housing — homes that allow families to stay near schools, older residents to remain connected to their community, and essential workers to live within reach of their jobs. Financial contributions alone do not achieve that.
The proposal also reduces car parking but shifts the transport burden onto public transport, which has not been assessed in a cumulative way. Multiple major developments in the precinct are being evaluated in isolation, despite their combined impact being significant. A comprehensive, precinct‑wide transport assessment is required.
I respectfully ask the Department to:
Require complete contamination assessments, including final floor levels and vapour intrusion modelling
Require a revised wind assessment based only on approved developments
Refuse the exclusion of Clause 6.21D or require an independent design review
Refuse the exclusion of Clause 6.14 or secure an equivalent contribution through a binding VPA
Renegotiate the VPA to reflect the 55% increase in apartment yield
Require affordable housing to be delivered as actual on‑site dwellings, managed in perpetuity by a community housing provider
Require a cumulative transport assessment across all concurrent developments
Hold a public hearing
What happens on this site will shape the future of Waterloo — whether it remains a diverse, connected community where people of all ages and incomes can stay, or becomes a place accessible only to those who can afford premium apartments. I urge the Department to consider these impacts carefully and require a development that genuinely serves the community.
Yours sincerely,
Gundula Brown
My concern is not about adding more housing. It is about ensuring that the housing delivered here is genuinely accessible, supports people to age in place, and keeps essential workers, families, and long‑term residents connected to their community. The proposal for 580 apartments starting at nearly $1 million for a one‑bedroom unit does not meet those needs. It delivers density without delivering affordability.
My objections fall into three key areas:
(1) critical gaps in the evidence base,
(2) the removal of community protections without any binding replacement, and
(3) an “affordable housing” offer that may result in no affordable homes being delivered at all.
1. The evidence base is incomplete
Contamination risks have not been properly assessed.
Two new basements are proposed in areas where previous assessments identified potential soil vapour contamination. The applicant’s own documentation acknowledges that key information — including final floor levels and full vapour intrusion modelling — is missing. Approving a development of this scale without complete contamination data is unsafe and unacceptable.
The wind assessment relies on an unapproved neighbouring development.
The modelling assumes the construction of another project that has not been approved. If that development does not proceed or is altered, the wind assessment becomes invalid. A revised assessment based solely on approved developments is essential.
2. Community protections are being removed with nothing binding in return
The original planning controls required both a competitive design process and contributions to community infrastructure. These safeguards recognised the scale of the site and the pressure additional residents would place on local services.
The amended proposal seeks exemption from both obligations while nearly doubling the approved height. A 126‑metre tower on a heritage‑sensitive site cannot be left to self‑assessment by the developer’s own consultants. Independent design review is essential.
At the same time, the proposal removes the requirement to contribute to community infrastructure — despite the applicant’s own Social Impact Assessment acknowledging that Waterloo is already under strain in childcare, schools, recreation, and aged care. The public is being asked to accept a 55% increase in apartments with no additional community benefit.
The existing VPA was negotiated for a much smaller development. The same public infrastructure cannot be presented as adequate compensation for a significantly larger project.
3. The affordable housing offer is not guaranteed to deliver any affordable homes
The proposal references a 12% affordable housing contribution, yet the applicant also states they are not bound by the City of Sydney’s Affordable Housing Program — the very policy from which the 12% figure is drawn. Without a binding VPA, this commitment has no enforceability.
Both the mandatory 3% and the proposed 12% contributions can be satisfied through cash payments rather than actual dwellings. This means the development could proceed with zero affordable homes delivered on site.
This neighbourhood needs real, long‑term affordable housing — homes that allow families to stay near schools, older residents to remain connected to their community, and essential workers to live within reach of their jobs. Financial contributions alone do not achieve that.
The proposal also reduces car parking but shifts the transport burden onto public transport, which has not been assessed in a cumulative way. Multiple major developments in the precinct are being evaluated in isolation, despite their combined impact being significant. A comprehensive, precinct‑wide transport assessment is required.
I respectfully ask the Department to:
Require complete contamination assessments, including final floor levels and vapour intrusion modelling
Require a revised wind assessment based only on approved developments
Refuse the exclusion of Clause 6.21D or require an independent design review
Refuse the exclusion of Clause 6.14 or secure an equivalent contribution through a binding VPA
Renegotiate the VPA to reflect the 55% increase in apartment yield
Require affordable housing to be delivered as actual on‑site dwellings, managed in perpetuity by a community housing provider
Require a cumulative transport assessment across all concurrent developments
Hold a public hearing
What happens on this site will shape the future of Waterloo — whether it remains a diverse, connected community where people of all ages and incomes can stay, or becomes a place accessible only to those who can afford premium apartments. I urge the Department to consider these impacts carefully and require a development that genuinely serves the community.
Yours sincerely,
Gundula Brown
Kevin Fitzgibbon
Object
Kevin Fitzgibbon
Object
WATERLOO
,
New South Wales
Message
To: NSW Department of Planning, Housing and Infrastructure
Attention: Chris Eldred, Contact Planner
Re: Objection to State Significant Development Application SSD-95997711 — Waterloo Mixed Use Development, 903-921 Bourke Street
Dear Assessment Team,
I am a resident of Danks Street in Waterloo, NSW, and I am writing to formally voice my objection to SSD-95997711 in its current iteration. While I recognise and support the necessity of strategic densification in Sydney, it is my view that the current proposal is entirely incompatible with its physical environment and the existing social fabric of the neighbourhood.
1. Excessive building height and local character The inclusion of a 36-storey skyscraper, reaching an approximate height of 125 metres, represents a disproportionate increase compared to the established built form of this precinct. Most contemporary developments in the immediate vicinity range from 4 to 13 storeys, making this proposal more than double the height of its neighbours. Such an immense tower creates a discordant visual impact and lacks any meaningful transition to the surrounding scale. High-intensity towers of this magnitude are better suited to major metropolitan transport hubs rather than a mid-block location on Bourke Street.
2. Unjustified deviation from established planning controls This site is already subject to a development approval based on significantly more modest height and Floor Space Ratio (FSR) limits. The applicant is now pursuing a dramatic uplift from the approved 29-metre limit to 125 metres, and an FSR increase from 2.15:1 to 3.05:1, without providing a proportional public benefit. Local residents purchased property and made long-term life decisions based on the predictability of the previous planning envelopes. Permitting an uplift of this scale on a site with an existing scheme undermines the transparency and reliability of the state planning system.
3. Significant loss of solar access
The substantial massing and height of the proposed towers will result in a measurable loss of sunlight for established residential buildings in the surrounding streets. There appears to be a major oversight in the proponent’s Environmental Impact Statement, as the solar access reports fail to properly evaluate the shadowing impacts on several adjacent residential blocks, such as Cameo at 6 Lachlan Street and Aria at 4 Lachlan Street. Many west-facing apartments in the area risk losing essential natural light due to this oversight.
4. Establishment of a poor planning precedent Granting approval for a 36-storey tower in a location that is not adjacent to a major transit interchange and is surrounded by low-to-mid-rise buildings would set a troubling precedent for Waterloo. Such a decision would likely encourage other landowners to seek similar, disproportionate upzoning for their own sites. This fragmented approach to planning is at odds with the objectives for orderly and sustainable development as outlined in the Environmental Planning and Assessment Act 1979.
5. Overburdened public transport infrastructure The Waterloo area currently suffers from a lack of immediate high-capacity transit, with the Metro station being a significant walk away and arguably more accessible to Redfern. The existing bus network, including the 304, 392, and 348 services, is already operating at or beyond capacity during peak hours. Introducing roughly 850 new dwellings to this corridor without a guaranteed and significant increase in transport frequency will lead to a failure of local transit services for both new and existing residents.
6. Rising traffic congestion and road safety concerns Local intersections, notably at Bourke Street’s junctions with Lachlan, Danks, and McEvoy Streets, are already heavily congested. Increasing traffic volumes lead to "rat-running" through quiet residential streets, which compromises pedestrian safety and local amenity. The submitted Traffic Impact Assessment is insufficient as it fails to account for the cumulative pressure of this project alongside other major nearby developments, including the Dasco site and the broader Waterloo Estate redevelopment.
7. Strain on overstretched local services The current social infrastructure in the precinct is nearing a breaking point. Green Square Public School is at capacity, there is an absence of local public high school options, and primary healthcare providers are under immense pressure. This proposal seeks to introduce a massive influx of residents without offering any meaningful contribution or commitment to the social infrastructure required to support them.
8. Deficiencies in public open space
The central park included in the plans is inadequate as a public benefit. It is a small space enclosed by 13-to-36-storey buildings, ensuring it will receive very little sunlight during winter. Furthermore, the design lacks practical recreational utility, offering no play equipment, minimal lawn space, and no facilities for pets, meaning it cannot satisfy the needs of 850 new households and the broader community.
9. Privacy and overlooking issues
The orientation of the proposed tower’s habitable rooms and balconies creates direct lines of sight into existing low-rise residences nearby. This causes a significant loss of privacy and a sense of visual intrusion for current residents in their private homes and outdoor spaces. The application does not include sufficient setbacks or physical screening measures to mitigate these privacy impacts.
10. Cumulative impacts of construction
Our community is currently enduring prolonged disruption from multiple concurrent construction sites, leading to constant noise, dust, and heavy vehicle traffic. Adding a project of this magnitude will exacerbate these issues for years to come. If any approval is granted, it must be conditioned upon a transparent and enforceable Construction Management Plan that strictly coordinates haulage routes and noise limits with other active sites in the area.
11. Environmental impacts and wind tunnel effects The height and bulk of the proposed structures are likely to intensify wind tunnel effects throughout the precinct. This would detrimental to the comfort of pedestrians and the usability of balconies and the proposed public park. I believe the application has not sufficiently modelled the potential degradation of the local microclimate caused by these wind patterns.
12. Shortage of street parking
On-street parking is a scarce resource in Waterloo. The scale of this development will inevitably increase the competition for limited spots, leading to an overflow of parking demand into surrounding residential streets, which will negatively impact both local residents and small businesses.
13. Incompatibility with the local area
The proposed development is fundamentally out of character with the Waterloo neighbourhood. It fails to integrate with the surrounding built environment and will place unmanageable pressure on local services that are already failing to meet demand. The transport situation in particular has been poorly managed by authorities, and this project will only turn a difficult situation into a crisis.
14. Lack of community benefit
It is my view that this proposal represents an attempt to maximise developer profit at the expense of the community’s wellbeing. By taking advantage of current planning pressures, the applicant is proposing a project that offers no genuine benefit to the precinct while ignoring the legitimate planning constraints of the site.
Requested outcome
I urge the Department to refuse this application in its current form. Any approval for development on this site should be contingent on a significant reduction in maximum building height to align with the surrounding 4-to-13-storey context. I also request a requirement for a fully transparent solar access study and a strictly enforceable Construction Management Plan. I do not object to the appropriate development of this site, but I strongly oppose a proposal of this excessive scale and height under the current planning framework.
Thank you for considering my submission.
We ask you to please redact our name and personal details in any publication of this submission.
Yours sincerely,
Kevin Fitzgibbon & Wayne Houguet
17 Danks Street, Waterloo NSW 2017
Attention: Chris Eldred, Contact Planner
Re: Objection to State Significant Development Application SSD-95997711 — Waterloo Mixed Use Development, 903-921 Bourke Street
Dear Assessment Team,
I am a resident of Danks Street in Waterloo, NSW, and I am writing to formally voice my objection to SSD-95997711 in its current iteration. While I recognise and support the necessity of strategic densification in Sydney, it is my view that the current proposal is entirely incompatible with its physical environment and the existing social fabric of the neighbourhood.
1. Excessive building height and local character The inclusion of a 36-storey skyscraper, reaching an approximate height of 125 metres, represents a disproportionate increase compared to the established built form of this precinct. Most contemporary developments in the immediate vicinity range from 4 to 13 storeys, making this proposal more than double the height of its neighbours. Such an immense tower creates a discordant visual impact and lacks any meaningful transition to the surrounding scale. High-intensity towers of this magnitude are better suited to major metropolitan transport hubs rather than a mid-block location on Bourke Street.
2. Unjustified deviation from established planning controls This site is already subject to a development approval based on significantly more modest height and Floor Space Ratio (FSR) limits. The applicant is now pursuing a dramatic uplift from the approved 29-metre limit to 125 metres, and an FSR increase from 2.15:1 to 3.05:1, without providing a proportional public benefit. Local residents purchased property and made long-term life decisions based on the predictability of the previous planning envelopes. Permitting an uplift of this scale on a site with an existing scheme undermines the transparency and reliability of the state planning system.
3. Significant loss of solar access
The substantial massing and height of the proposed towers will result in a measurable loss of sunlight for established residential buildings in the surrounding streets. There appears to be a major oversight in the proponent’s Environmental Impact Statement, as the solar access reports fail to properly evaluate the shadowing impacts on several adjacent residential blocks, such as Cameo at 6 Lachlan Street and Aria at 4 Lachlan Street. Many west-facing apartments in the area risk losing essential natural light due to this oversight.
4. Establishment of a poor planning precedent Granting approval for a 36-storey tower in a location that is not adjacent to a major transit interchange and is surrounded by low-to-mid-rise buildings would set a troubling precedent for Waterloo. Such a decision would likely encourage other landowners to seek similar, disproportionate upzoning for their own sites. This fragmented approach to planning is at odds with the objectives for orderly and sustainable development as outlined in the Environmental Planning and Assessment Act 1979.
5. Overburdened public transport infrastructure The Waterloo area currently suffers from a lack of immediate high-capacity transit, with the Metro station being a significant walk away and arguably more accessible to Redfern. The existing bus network, including the 304, 392, and 348 services, is already operating at or beyond capacity during peak hours. Introducing roughly 850 new dwellings to this corridor without a guaranteed and significant increase in transport frequency will lead to a failure of local transit services for both new and existing residents.
6. Rising traffic congestion and road safety concerns Local intersections, notably at Bourke Street’s junctions with Lachlan, Danks, and McEvoy Streets, are already heavily congested. Increasing traffic volumes lead to "rat-running" through quiet residential streets, which compromises pedestrian safety and local amenity. The submitted Traffic Impact Assessment is insufficient as it fails to account for the cumulative pressure of this project alongside other major nearby developments, including the Dasco site and the broader Waterloo Estate redevelopment.
7. Strain on overstretched local services The current social infrastructure in the precinct is nearing a breaking point. Green Square Public School is at capacity, there is an absence of local public high school options, and primary healthcare providers are under immense pressure. This proposal seeks to introduce a massive influx of residents without offering any meaningful contribution or commitment to the social infrastructure required to support them.
8. Deficiencies in public open space
The central park included in the plans is inadequate as a public benefit. It is a small space enclosed by 13-to-36-storey buildings, ensuring it will receive very little sunlight during winter. Furthermore, the design lacks practical recreational utility, offering no play equipment, minimal lawn space, and no facilities for pets, meaning it cannot satisfy the needs of 850 new households and the broader community.
9. Privacy and overlooking issues
The orientation of the proposed tower’s habitable rooms and balconies creates direct lines of sight into existing low-rise residences nearby. This causes a significant loss of privacy and a sense of visual intrusion for current residents in their private homes and outdoor spaces. The application does not include sufficient setbacks or physical screening measures to mitigate these privacy impacts.
10. Cumulative impacts of construction
Our community is currently enduring prolonged disruption from multiple concurrent construction sites, leading to constant noise, dust, and heavy vehicle traffic. Adding a project of this magnitude will exacerbate these issues for years to come. If any approval is granted, it must be conditioned upon a transparent and enforceable Construction Management Plan that strictly coordinates haulage routes and noise limits with other active sites in the area.
11. Environmental impacts and wind tunnel effects The height and bulk of the proposed structures are likely to intensify wind tunnel effects throughout the precinct. This would detrimental to the comfort of pedestrians and the usability of balconies and the proposed public park. I believe the application has not sufficiently modelled the potential degradation of the local microclimate caused by these wind patterns.
12. Shortage of street parking
On-street parking is a scarce resource in Waterloo. The scale of this development will inevitably increase the competition for limited spots, leading to an overflow of parking demand into surrounding residential streets, which will negatively impact both local residents and small businesses.
13. Incompatibility with the local area
The proposed development is fundamentally out of character with the Waterloo neighbourhood. It fails to integrate with the surrounding built environment and will place unmanageable pressure on local services that are already failing to meet demand. The transport situation in particular has been poorly managed by authorities, and this project will only turn a difficult situation into a crisis.
14. Lack of community benefit
It is my view that this proposal represents an attempt to maximise developer profit at the expense of the community’s wellbeing. By taking advantage of current planning pressures, the applicant is proposing a project that offers no genuine benefit to the precinct while ignoring the legitimate planning constraints of the site.
Requested outcome
I urge the Department to refuse this application in its current form. Any approval for development on this site should be contingent on a significant reduction in maximum building height to align with the surrounding 4-to-13-storey context. I also request a requirement for a fully transparent solar access study and a strictly enforceable Construction Management Plan. I do not object to the appropriate development of this site, but I strongly oppose a proposal of this excessive scale and height under the current planning framework.
Thank you for considering my submission.
We ask you to please redact our name and personal details in any publication of this submission.
Yours sincerely,
Kevin Fitzgibbon & Wayne Houguet
17 Danks Street, Waterloo NSW 2017
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
I object to the proposed development at 903-921 Bourke St Waterloo on planning and public‑interest grounds. As an architect and designer, I wholeheartedly support urban infill and sustainable development, but this dramatic increase is an unsustainable, profit making proposal by the developer. As a local resident to the site, I find the proposed height and bulk are excessive for the neighborhood and will impose unacceptable impacts. Specifically, the additional height is incredibly out of character. I request that this be carefully considered and refuse the application in its current form or require substantial amendments to height and FSR so that development closer aligns with planning controls and more so to maintain the neighbourhood quality and character.
The proposal presents an over‑scaled building envelope that conflicts with the established character of Waterloo - Danks street and South East Redfern. The additional height increase does not provide a respectful transition in height to surrounding streets and dwellings, resulting in undue visual dominance and over towering and in turn overshadowing. The scale of the proposal is likely to exacerbate overshadowing, privacy loss, and access and daylight effects for adjacent properties and public spaces, eroding amenity and walkability. A reduced height is required to achieve an appropriate human scale and streetscape.
Current public transport capacity and service coverage are insufficient to absorb the trip demand from the proposed increased yield. Without credible, funded improvements and strong travel demand measures, residents and visitors will default to private vehicles, undermining sustainability objectives. This massive proposed increase will also cause an increase in vehicular traffic to the already small, quiet immediately surrounding residential neighborhoods of East Redfern and Waterloo, without sufficient access to public transport in direct proximity.
Substantial reductions to maximum building height and bulk, with clear transitions to the surrounding neighborhood should be carefully reviewed. The solar access diagrams present an enormous change to the previous, and this impacts solar access of hundreds of nearby apartment complexes and residential terrace houses. This impact needs to be seriously considered as it will without a doubt seriously impact the local community for the worse.
I hope you understand and share my concerns with this objection. it is completely out of scale for the area and is a profit-making exercise. Please reach out with any further questions. Thank you.
The proposal presents an over‑scaled building envelope that conflicts with the established character of Waterloo - Danks street and South East Redfern. The additional height increase does not provide a respectful transition in height to surrounding streets and dwellings, resulting in undue visual dominance and over towering and in turn overshadowing. The scale of the proposal is likely to exacerbate overshadowing, privacy loss, and access and daylight effects for adjacent properties and public spaces, eroding amenity and walkability. A reduced height is required to achieve an appropriate human scale and streetscape.
Current public transport capacity and service coverage are insufficient to absorb the trip demand from the proposed increased yield. Without credible, funded improvements and strong travel demand measures, residents and visitors will default to private vehicles, undermining sustainability objectives. This massive proposed increase will also cause an increase in vehicular traffic to the already small, quiet immediately surrounding residential neighborhoods of East Redfern and Waterloo, without sufficient access to public transport in direct proximity.
Substantial reductions to maximum building height and bulk, with clear transitions to the surrounding neighborhood should be carefully reviewed. The solar access diagrams present an enormous change to the previous, and this impacts solar access of hundreds of nearby apartment complexes and residential terrace houses. This impact needs to be seriously considered as it will without a doubt seriously impact the local community for the worse.
I hope you understand and share my concerns with this objection. it is completely out of scale for the area and is a profit-making exercise. Please reach out with any further questions. Thank you.
Name Withheld
Object
Name Withheld
Object
Waterloo
,
New South Wales
Message
Submission: Objection to SSD-95997711
903–921 Bourke Street, Waterloo
To whom it may concern,
I am a resident of 810 Elizabeth Street, Waterloo and object to the proposed amendments to the approved development at 903–921 Bourke Street, including the increase in residential yield, height, and floor space ratio.
________________________________________
1. Excessive and unjustified intensification
The proposal seeks to:
• Increase apartments from 347 to 580
• Increase FSR from 1.5:1 to 3.2:1
• Increase height up to 126m
(EI&RS Summary; Section 4.1)
This represents a fundamental intensification requiring rezoning, not a minor amendment.
The justification relies on housing supply objectives (Section 8.1), however this does not demonstrate:
• Site-specific suitability
• Infrastructure capacity
• Acceptable local impacts
The proposal effectively overrides established planning controls on a site-specific basis without sufficient justification.
________________________________________
2. Transport Impact Assessment is inadequate
The TIA acknowledges the uplift:
“increase from 376 to 580 apartments” (Section 1.1)
However, it relies on previous modelling:
impacts were “previously reviewed and deemed acceptable” (Section 2.2)
Key issues:
1) Failure to reassess impacts
• Approved scheme: 34 AM / 41 PM peak trips
• No recalculation provided for 580 units
2) Overreliance on precinct modelling
• Based on earlier Danks Street South modelling
• Does not test site-specific or cumulative impacts
3) No public transport capacity analysis
• Proximity to rail/metro cited (Section 3.1)
• No evidence of available capacity
4) Optimistic mode share assumptions
• High reliance on public transport/walking
• No supporting behavioural data
Overall, the TIA does not demonstrate that the increased density can be accommodated.
________________________________________
3. Visual Impact Assessment understates impacts
The VIA states the development will be:
“a prominent new built form element… due to its vertical scale”
Yet concludes:
“overall visual impacts are generally negligible”
(VIA Executive Summary)
This is internally inconsistent.
Key issues:
• Methodology reduces impacts where views are partially obstructed
• Limited viewpoint selection within a 2km radius (Section 1.4)
• Insufficient consideration of local street-level experience
• Reliance on landscaping to mitigate bulk and height
Tree planting cannot mitigate the visual impact of 100m+ towers.
________________________________________
4. Amenity impacts framed through compliance rather than outcomes
The EI&RS acknowledges impacts including:
• Shadowing (Section 7.4.6)
• Visual privacy (Section 7.4.3)
• Wind (Section 7.4.7)
These are considered acceptable based on compliance.
However:
• Compliance represents minimum standards
• The proposal significantly exceeds baseline controls
• Cumulative impacts across Waterloo are not addressed
This approach understates the real impact on amenity.
________________________________________
5. Infrastructure capacity not demonstrated
The EI&RS states infrastructure is adequate (Section 4.3.4), however:
• No detailed capacity modelling is provided
• No binding infrastructure commitments are identified
• Reliance is placed on existing or future capacity
This creates a risk that infrastructure will not keep pace with development.
________________________________________
6. Precedent and planning integrity
The proposal requires:
• Significant height increases
• Major FSR uplift
• Site-specific LEP amendments
(Section 4.1)
Approval would:
• Set a precedent for similar uplifts
• Undermine LEP and DCP controls
• Shift planning toward ad hoc outcomes
________________________________________
7. Inconsistency with planning framework
The proposal is inconsistent with the intent of key planning controls, including the Sydney Local Environmental Plan 2012 and relevant Development Control Plan provisions.
In particular:
• The proposed FSR and height significantly exceed established controls without sufficient site-specific justification
• The scale of development is inconsistent with the intended character and staging of the Waterloo/Green Square precinct
• The proposal does not demonstrate that it achieves a better planning outcome than a compliant scheme
While variation to controls may be considered, such variation must be supported by a clear planning benefit and design excellence. This has not been demonstrated.
________________________________________
8. Failure to assess cumulative impacts
The proposal is assessed largely in isolation, despite being located within a rapidly densifying precinct.
There is no meaningful analysis of cumulative impacts arising from:
• Other approved and proposed developments in Waterloo and Green Square
• Combined population growth
• Aggregated demand on transport, open space, and community infrastructure
This is a critical omission. Even if individual developments appear acceptable in isolation, their cumulative impact can result in unacceptable outcomes.
________________________________________
9. Lack of demonstrated design excellence
Given the extent of planning uplift sought, a high standard of design excellence should be clearly demonstrated.
However, the proposal:
• Prioritises yield and building envelope over urban integration
• Relies on compliance-based arguments rather than qualitative design outcomes
• Does not convincingly demonstrate a superior architectural or public domain outcome
In the absence of clear design excellence, the justification for significant departures from planning controls is not established.
________________________________________
Conclusion
The proposal represents a substantial intensification that is not supported by:
• Robust transport analysis
• Credible visual impact assessment
• Demonstrated infrastructure capacity
It relies on strategic housing arguments without adequately addressing site-specific and cumulative impacts.
Accordingly, I request that the consent authority:
Reject the proposal in its current form, or
Require significant reductions in height, density, and FSR.
Yours sincerely,
Resident, 810 Elizabeth Street, Waterloo
903–921 Bourke Street, Waterloo
To whom it may concern,
I am a resident of 810 Elizabeth Street, Waterloo and object to the proposed amendments to the approved development at 903–921 Bourke Street, including the increase in residential yield, height, and floor space ratio.
________________________________________
1. Excessive and unjustified intensification
The proposal seeks to:
• Increase apartments from 347 to 580
• Increase FSR from 1.5:1 to 3.2:1
• Increase height up to 126m
(EI&RS Summary; Section 4.1)
This represents a fundamental intensification requiring rezoning, not a minor amendment.
The justification relies on housing supply objectives (Section 8.1), however this does not demonstrate:
• Site-specific suitability
• Infrastructure capacity
• Acceptable local impacts
The proposal effectively overrides established planning controls on a site-specific basis without sufficient justification.
________________________________________
2. Transport Impact Assessment is inadequate
The TIA acknowledges the uplift:
“increase from 376 to 580 apartments” (Section 1.1)
However, it relies on previous modelling:
impacts were “previously reviewed and deemed acceptable” (Section 2.2)
Key issues:
1) Failure to reassess impacts
• Approved scheme: 34 AM / 41 PM peak trips
• No recalculation provided for 580 units
2) Overreliance on precinct modelling
• Based on earlier Danks Street South modelling
• Does not test site-specific or cumulative impacts
3) No public transport capacity analysis
• Proximity to rail/metro cited (Section 3.1)
• No evidence of available capacity
4) Optimistic mode share assumptions
• High reliance on public transport/walking
• No supporting behavioural data
Overall, the TIA does not demonstrate that the increased density can be accommodated.
________________________________________
3. Visual Impact Assessment understates impacts
The VIA states the development will be:
“a prominent new built form element… due to its vertical scale”
Yet concludes:
“overall visual impacts are generally negligible”
(VIA Executive Summary)
This is internally inconsistent.
Key issues:
• Methodology reduces impacts where views are partially obstructed
• Limited viewpoint selection within a 2km radius (Section 1.4)
• Insufficient consideration of local street-level experience
• Reliance on landscaping to mitigate bulk and height
Tree planting cannot mitigate the visual impact of 100m+ towers.
________________________________________
4. Amenity impacts framed through compliance rather than outcomes
The EI&RS acknowledges impacts including:
• Shadowing (Section 7.4.6)
• Visual privacy (Section 7.4.3)
• Wind (Section 7.4.7)
These are considered acceptable based on compliance.
However:
• Compliance represents minimum standards
• The proposal significantly exceeds baseline controls
• Cumulative impacts across Waterloo are not addressed
This approach understates the real impact on amenity.
________________________________________
5. Infrastructure capacity not demonstrated
The EI&RS states infrastructure is adequate (Section 4.3.4), however:
• No detailed capacity modelling is provided
• No binding infrastructure commitments are identified
• Reliance is placed on existing or future capacity
This creates a risk that infrastructure will not keep pace with development.
________________________________________
6. Precedent and planning integrity
The proposal requires:
• Significant height increases
• Major FSR uplift
• Site-specific LEP amendments
(Section 4.1)
Approval would:
• Set a precedent for similar uplifts
• Undermine LEP and DCP controls
• Shift planning toward ad hoc outcomes
________________________________________
7. Inconsistency with planning framework
The proposal is inconsistent with the intent of key planning controls, including the Sydney Local Environmental Plan 2012 and relevant Development Control Plan provisions.
In particular:
• The proposed FSR and height significantly exceed established controls without sufficient site-specific justification
• The scale of development is inconsistent with the intended character and staging of the Waterloo/Green Square precinct
• The proposal does not demonstrate that it achieves a better planning outcome than a compliant scheme
While variation to controls may be considered, such variation must be supported by a clear planning benefit and design excellence. This has not been demonstrated.
________________________________________
8. Failure to assess cumulative impacts
The proposal is assessed largely in isolation, despite being located within a rapidly densifying precinct.
There is no meaningful analysis of cumulative impacts arising from:
• Other approved and proposed developments in Waterloo and Green Square
• Combined population growth
• Aggregated demand on transport, open space, and community infrastructure
This is a critical omission. Even if individual developments appear acceptable in isolation, their cumulative impact can result in unacceptable outcomes.
________________________________________
9. Lack of demonstrated design excellence
Given the extent of planning uplift sought, a high standard of design excellence should be clearly demonstrated.
However, the proposal:
• Prioritises yield and building envelope over urban integration
• Relies on compliance-based arguments rather than qualitative design outcomes
• Does not convincingly demonstrate a superior architectural or public domain outcome
In the absence of clear design excellence, the justification for significant departures from planning controls is not established.
________________________________________
Conclusion
The proposal represents a substantial intensification that is not supported by:
• Robust transport analysis
• Credible visual impact assessment
• Demonstrated infrastructure capacity
It relies on strategic housing arguments without adequately addressing site-specific and cumulative impacts.
Accordingly, I request that the consent authority:
Reject the proposal in its current form, or
Require significant reductions in height, density, and FSR.
Yours sincerely,
Resident, 810 Elizabeth Street, Waterloo
John Bowden
Object
John Bowden
Object
Waterloo
,
New South Wales
Message
I oppose any modifications to the development application for 903-921 Bourke Street Waterloo (SSD-95997711). My objections are: to the proposed increased size of the development, to its increased height and to the effect that the greater numbers of residents will have on the limited infrastructure of the suburb. I have been a resident of the suburb since 2005 and I am very concerned at the deterioration of the livability of Waterloo these changes would entail.
The major roads in the district, McEvoy, Bourke and Elizabeth Streets are already seriously crowded for increasing hours each day. McEvoy Street has become an extension to the WestConnex system and is often overcrowded. It is a suburban street being compelled to act as a highway. Side roads off McEvoy have become 'rat runs' for motorists trying to avoid traffic and are often made more dangerous by trucks and vehicles double parking to unload goods. The footpaths are another danger because of the number of cyclists and e-bike riders using them, because they have been forced off the streets. This situation will only become worse if the changes to the development application are allowed and if the number of residents and vehicles are allowed to increase.
Regarding the proposed increases in the heights of the building, I would think that the problems that this will create with overshadowing are obvious, but there is also the effect that this will have on wind levels. One need only visit the Green Square development on a mildly windy day to experience the gusting winds around those buildings even though they do not reach the heights of the proposed buildings on Bourke Street. I might also point out that there are very large developments already planned for the area between Elizabeth Street and Botany Road that are currently occupied by public housing.
As for the lack of proper infrastructure to support the increased resident numbers that the development proposal will bring about, may I point out that while there is the Green Square Station and the new Waterloo Metro, both of these, Green Square in particular, are already very heavily used at the beginning and end of the day and the most commonly used form of public transport in the district is the bus and all lines through Waterloo are frequently packed to capacity. Beside transport, other services, shops, schools, libraries, parks and medical services are near their limits.
I have not touched on the aesthetics of the development, nor on the morality of allowing an increase in its size for which I can see no justification other than to increase the profits for the developers. The progress in the development so far has seen the removal of businesses and retailers who provided employment and services. The destruction around the formerly fenced area of the old Water Board site on the corner of Bourke and McEvoy Streets has seen the removal of nesting sites for plovers, ibis, kestrels, magpies, egrets and butcher birds. I feel that for current and long term residents of Waterloo, their homes and the things they value about where they live will be similarly lost if development on the scale proposed is permitted. The original proposal was harsh enough. The modifications sought go too far.
The major roads in the district, McEvoy, Bourke and Elizabeth Streets are already seriously crowded for increasing hours each day. McEvoy Street has become an extension to the WestConnex system and is often overcrowded. It is a suburban street being compelled to act as a highway. Side roads off McEvoy have become 'rat runs' for motorists trying to avoid traffic and are often made more dangerous by trucks and vehicles double parking to unload goods. The footpaths are another danger because of the number of cyclists and e-bike riders using them, because they have been forced off the streets. This situation will only become worse if the changes to the development application are allowed and if the number of residents and vehicles are allowed to increase.
Regarding the proposed increases in the heights of the building, I would think that the problems that this will create with overshadowing are obvious, but there is also the effect that this will have on wind levels. One need only visit the Green Square development on a mildly windy day to experience the gusting winds around those buildings even though they do not reach the heights of the proposed buildings on Bourke Street. I might also point out that there are very large developments already planned for the area between Elizabeth Street and Botany Road that are currently occupied by public housing.
As for the lack of proper infrastructure to support the increased resident numbers that the development proposal will bring about, may I point out that while there is the Green Square Station and the new Waterloo Metro, both of these, Green Square in particular, are already very heavily used at the beginning and end of the day and the most commonly used form of public transport in the district is the bus and all lines through Waterloo are frequently packed to capacity. Beside transport, other services, shops, schools, libraries, parks and medical services are near their limits.
I have not touched on the aesthetics of the development, nor on the morality of allowing an increase in its size for which I can see no justification other than to increase the profits for the developers. The progress in the development so far has seen the removal of businesses and retailers who provided employment and services. The destruction around the formerly fenced area of the old Water Board site on the corner of Bourke and McEvoy Streets has seen the removal of nesting sites for plovers, ibis, kestrels, magpies, egrets and butcher birds. I feel that for current and long term residents of Waterloo, their homes and the things they value about where they live will be similarly lost if development on the scale proposed is permitted. The original proposal was harsh enough. The modifications sought go too far.