The height/scale of the proposed development (6 storeys) remains out of keeping with the surrounding houses which are only 2 storeys and are part of the crown blocks heritage conservation area.

Intensive extended (24 hour) operational lighting required for a high-density aged care facility will result in significant light pollution and nocturnal disruption that will blind and permanently displace nocturnal wildlife along the national park boundary. This is a holding submission; I reserve the right to submit detailed flora and fauna impacts.

Acoustic Pollution in a Quiet Valley:
The jackhammering, demolition, continuous flow of trucks and construction over an extended three stage period, plus the introduction of massive commercial HVAC systems, cooling towers and daily delivery bays will destroy the natural acoustic sanctuary of the Garigal bushland boundary. These outcomes should not be allowed in any shape or form.
This is a holding submission; I reserve the right to submit independent acoustic impact reviews.

TO WHOM IT MAY CONCERN:

31 July 2026

Being a resident of this area for a few years, I thought I would provide you with some feedback and some insight as to the area in which you propose to develop.
1. I see a significant problem having aged residents, some with severe issues both mentally and physically trying to exit the area if there are any emergency situations as the road, Stanhope Road does not constitute or support heavy traffic flow and heavy vehicles - I feel it is just so unrealistic and quite dangerous.
2. I also find it quite bemusing, that each of these SSD's have hundreds of pages of information of which, the general population is having to read and I believe it is on purpose that they try to inundate people with high volumes of information to confuse and frustrate residents. I also find it quite extraordinary that only a few boundering properties were notified my mail as this affects a significant area of land and landowners within the area.
3. What about the impact on the environment and biodiversity impacts with loss of tree canopy, native trees and wildlife?
4. I would think developers could have chosen a better suited area within Kuringgai for this proposed development. If it was smaller in scale, height, volume and more considerate of the existing environment, residences would not be as vocal in condemning these projects.
5. The traffic reports that have been conducted are highly inaccurate. Each working day is different and differs with parking capacity on streets, coupled with large vehicles parked blocking line of sight and buses using narrow streets makes for precarious driving lines.

Thanking you for taking the time to read my assessment.

Yours faithfully

OBJECTION - SSD-88004956, Lourdes Retirement Village, Killara
Scott Savage, Northcote Road, Lindfield NSW 2070

I object to the Clause 4.6 height variation and to the staging. Attached: covering letter; Annexure A (grounds, 25pp; sources and caveats); Annexure B (Figures 1-7).

Every room of my house looks to the ridge where the taller buildings would go; Building H is 261m from my lounge window. I SUPPORT the bushfire retreat, the 56m APZ, the cut from 172 to 145 dwellings and the consolidated footprint - spreading it out would only cost more trees. I am asking for fewer storeys on the same footprints. This village should be rebuilt; its residents deserve better than forty-year-old buildings in a flame zone.

Every figure below is the applicant's own.

1. THE VARIATION IS BIGGER THAN STATED. The sections annotate a lift overrun 1.30m above roof level on every building (Building A roof RL +120.15, overrun +121.45). The Standard Instrument Dictionary measures building height to the highest point "including plant and lift overruns". Measured properly, Building A is ~19.70m against a 9.5m standard - 107%, not the 60% reported. SO WHAT: the Department is asked to approve a variation whose size has been understated by half.

2. NOBODY CAN SAY HOW TALL IT IS. DA205 shows Building A with six levels, five above ground on the south. The EIS says "2-5 storey" in one line and "2 to 4 storeys" eleven lines later; s4.7.4 gives Buildings E and F "two additional lower part storeys to the south". SO WHAT: there is no consistent statement of what is being approved, and every inconsistency runs one way.

3. THE CANOPY PROMISE IS BROKEN. The Scoping Report told the Department the taller buildings "will sit below the canopy of the trees and not be visible from external locations". The arborist has since measured every tree: of 254 retained, 230 have a recorded height and the median is 12.0m. Building A at 18.4m stands taller than 206 of them. SO WHAT: the assurance on which this variation was foreshadowed is contradicted by its own arborist. A building above nine tenths of the trees meant to conceal it is not below the canopy.

4. THE AFFECTED SIDE WAS NEVER ASSESSED. Every exceedance is on a southern elevation. Every viewpoint within 200m is on the northern side, where the buildings comply. No viewpoint on the southern side is closer than 337m. All 19 are public domain views; the report names Tenacity as the test for private views and never applies it. The VIA's own Northcote Rd cameras sit at RL +100.90 and +103.77; Building H's roof is RL +115.80 and Building A's overrun RL +121.45, so these buildings stand 12 to 21m above my street across a valley, on a slope carrying unbroken canopy. SO WHAT: the "negligible" finding rests on an assessment that excluded the direction and the receivers actually affected. It is not evidence the Department can rely on.

5. BUSHFIRE IS NOT WHY THE TREES GO. Of 366 trees to be removed, the arborist attributes 16 to bushfire - 116 to buildings, 58 to roads, 33 to grading, 127 to landscaping. SO WHAT: the trees are not going to make the village safe. They are making room for the buildings whose height is excused by safety.

6. A STATED GROUND FOR THE VARIATION IS UNTRUE. The Clause 4.6 says the proposal "remains well below the maximum FSR permissible on the site" and offers that as proof it prioritised "safety and good design over maximising yield". The EIS s7.1.3 and the FSR Clause 4.6 both record the ILU component at 0.5:1 - the ceiling under s108. SO WHAT: cl 4.6(3) requires the applicant to demonstrate sufficient environmental planning grounds. One of the grounds relied on is contradicted by its own documents, all three dated 22 June 2026.

7. NO COMPLIANT ALTERNATIVE WAS EVER TESTED. The alternatives section considers doing nothing, other uses and the earlier taller schemes - never the same retreat at a lower yield. The applicant also concedes it locates parking in semi-subterranean levels, "instead pushing them above the height limit". SO WHAT: the claim that bushfire compels this height is untested, and part of it is admitted to be a car parking decision.

8. NOBODY HAS MEASURED THE HAZARD. The district Bush Fire Risk Management Plan 2016-21 named this site - asset 76, "Likely / Catastrophic / Extreme / 1B" - and prescribed a mosaic burn, programmed once for 2016/17. The 2023 plan replacing it names no aged care asset at all. The NSW fire history dataset records no fire in the bushland south and east of the site. DPHI's own report calls that bushland vegetation Category 1, the highest risk category, and Levande markets Lourdes as "nestled on the edge of Garigal National Park". The APZ is nonetheless sized "to achieve the BAL-29 provisions" - 29 kW/m2 - when PBP 2019 s3.2 says "for most SFPP developments, 10kW/m2... is the maximum exposure at any point of the building wall". SO WHAT: under PBP the APZ is calculated from fuel load, which depends on time since fire. No record of it burning, no statement of its fuel load, apparently the residential radiant heat threshold rather than the aged care one - and 145 households of elderly people proposed on the other side of it. If that threshold is wrong, the entire retreat rests on the wrong number.

9. THE EVACUATION STUDY MEASURES THE WRONG THING. The only numerical analysis is that a bushfire evacuation generates "170 vehicles" at a volume-to-capacity ratio of 0.23 on Stanhope Road. SO WHAT: that tests whether the road is wide enough once people are already in cars. Seniors housing is a Special Fire Protection Purpose precisely because occupants "may be unable to self-evacuate". Whether a frail resident can get down four storeys and into a vehicle is nowhere addressed.

10. THE SAFETY ARRIVES LAST, AND THE RESIDENTS GO FIRST. Demolition of the Flame Zone dwellings - the act creating the APZ - is Stage 3, after 126 of 145 units are built and sold. No stage has a completion date, there is no sunset condition, the staging is only "indicative". Meanwhile Stages 1A and 1B both begin by relocating existing residents INTO those Flame Zone buildings, where they remain through three stages for "a number of years" while Stage 1A demolishes and rebuilds the road they would escape along. The Social Impact Assessment rates this "Low-Medium negative" and calls it "short-term disruption to residents' established routines". It does not mention bushfire at all.

SO WHAT: frail people are to be moved into buildings this application itself calls unsafe, held there for years with their escape route dug up, and the risk recorded as an inconvenience to their routines. The Special Fire Protection Purpose provisions exist for exactly these residents. This scheme puts them nearest the fire and last in the queue for the protection meant to justify it. If the hazard is real enough to justify a 60% height variation, it is real enough to be removed before anyone is moved towards it.

11. AND NOTHING CHECKS THIS AFTERWARDS. On 10 Oct 2023 the Member for Davidson told Parliament: "The Minister for Planning and Public Spaces advised on 5 July 2023: Any future Development Application submitted for the site must be formally referred to the RFS for its detailed consideration and will require a Bush Fire Safety Authority to be issued by the RFS under s100B." That was the assurance given to this community. But s4.14(1B) of the EP&A Act provides: "This section does not apply to State significant development", and no s100B authority is required for SSD. I make no criticism of the Minister - on the pathway contemplated in 2023 the advice was right. SO WHAT: the RFS role here is advisory. No later authority can refuse this or condition it. This determination is the only occasion bushfire safety will ever be tested - which is exactly why nothing can be left to the occupation certificate or to Stage 3. The same speech quoted Ku-ring-gai Council: it "does not want to be held in any way responsible in the event of a bushfire-related incident and any resulting coronial inquest". Council is no longer the consent authority. The Department is.

WHAT I ASK
1. Refuse the Clause 4.6 height variation as it stands.
2. Withhold consent unless no part of any building, including parapets, plant and lift overruns, projects above the canopy of the retained trees, with the datum taken from the arborist's own measured heights and a maximum RL conditioned per building.
3. Before determination require: heights re-stated to the top of each lift overrun; one consistent storey schedule; existing and retained canopy coverage; time since fire and assumed fuel load; the radiant heat threshold used; and survey-verified photomontages from private homes on this side of the valley, including my two viewpoints in Annexure B. I will make my property available.
4. Require a height-compliant retreat modelled at a lower yield, and the reasons for rejecting it. Reconcile "well below the maximum FSR" with the 0.5:1 figure.
5. Restructure the staging: Flame Zone demolition and the APZ first; no occupation certificate for Stages 2 or 3 until the APZ is certified to PBP 2019; a stage-specific evacuation plan approved before Stage 1A; a sunset condition.
6. State what role the RFS has had, whether a s100B authority will be required, and if not how the Department has satisfied itself on what the RFS would otherwise have examined - and publish its advice.

Read these documents against each other and they do not agree - on the height, the storeys, the floor space, whether the buildings sit above or below the canopy. Every disagreement runs one way. Please test the figures, not the summaries.

These residents should get their new village. They should not live in the flame zone to earn it.

I request the opportunity to speak to this submission at any public meeting. I declare I have made no reportable political donation or gift in the period relevant to this application.

Scott Savage, Northcote Road, Lindfield NSW 2070

There is a lack of alternative emergency access for the entire site. The developer has completely failed to secure a secondary, viable emergency-only access and escape route through the surrounding properties and area to alleviate the Stanhope Road choke points, as well as many other associated problems relating to extreme bushfire hazards, including risks to residents and the local community. This is a holding submission. I reserve the right to submit independent safety reviews. Sincerely, Wai Chan