Dear Mr Kim,

I object to State Significant Development Application SSD-90572458. I live in the immediate area and am directly affected by traffic generated through the Eastlakes/Rosebery precinct. While I support the renewal of the ageing shopping centre and the delivery of new housing in principle, this proposal — four towers of 14 to 18 storeys, 736 apartments, 95,073 sqm of floor space at an FSR of 5.29:1 on a 1.8 ha site — is grossly out of scale with the locality and is not supported by any corresponding upgrade to the road network or public infrastructure. My grounds of objection are set out below.

1. Permissibility and inappropriate use of the SSD/HDA pathway

The site is zoned E1 Local Centre under the Bayside Local Environmental Plan 2021. The applicant's own material acknowledges that the build-to-rent component (215 dwellings) is not permissible in the E1 zone and that the application relies on a rezoning being granted as part of the SSD process. A development of this magnitude should not be able to manufacture its own permissibility through the Housing Delivery Authority pathway, bypassing the strategic planning, community consultation and infrastructure sequencing that a rezoning would ordinarily require. The proposed height of 62.9 metres and FSR of 5.29:1 vastly exceed the scale of development contemplated for this local centre site and represent a spot rezoning by stealth. If the built form cannot be delivered within the permissible planning controls, the proposal should be refused or substantially amended, not the controls rewritten to fit the proposal.

2. Traffic — an already failing road network with no proposed upgrades

Eastlakes is served by a small number of narrow access routes, principally via Gardeners Road and Evans Avenue, and the network is already at or beyond practical capacity in peak periods. Morning traffic on Evans Avenue and at the Racecourse Place roundabout regularly comes to a near standstill, and this congestion is now pushing rat-running and speeding traffic through surrounding residential streets, including my own — a direct and worsening safety risk to residents, children and pedestrians.

This application proposes 736 new dwellings and 1,223 car spaces — well over a thousand additional daily vehicle movements plus retail customer, delivery, service and waste vehicle traffic — with no material upgrade to the surrounding road network. I note the application also requires separate Roads Act approval, confirming the intensity of its interaction with the local road system.

I request that the Department:

Commission an independent peer review of the applicant's Traffic and Transport Impact Assessment, based on observed weekday peak conditions (7:30–9:30 am and 4:30–6:30 pm), not theoretical modelling or pre-COVID counts;
Require assessment of rat-running and speeding impacts on surrounding residential streets in Eastlakes and Rosebery, with funded traffic-calming measures (LATM scheme) as a condition of any approval;
Require the applicant to fund intersection upgrades, signalisation and turning capacity identified as necessary by the independent review, before occupation, not after;
Impose construction traffic conditions prohibiting heavy vehicle movements in peak periods and mandating approved truck routes away from residential streets.
3. Cumulative impact has not been honestly assessed

This proposal cannot be assessed in isolation. The adjoining Grand Eastlakes development (the former Crown Group project) has already added approximately 490 dwellings and a new retail precinct feeding the same section of Evans Avenue. Together with this application's 736 dwellings, well over 1,200 new households — several thousand new residents — will be concentrated on one intersection of a suburb with no rail, metro or light rail connection and a limited bus service. Residents and Bayside Council have already raised serious traffic concerns on the related Early Works application (SSD-105575706) for this same site. The Department must undertake a genuine cumulative impact assessment covering the completed Grand Eastlakes precinct, this proposal, background growth, school and retail traffic, before any determination is made.

4. Height, bulk and scale — out of character with Eastlakes

The surrounding residential context is predominantly two- and three-storey walk-up apartment buildings and low-scale dwellings. Towers of 14 to 18 storeys (62.9 metres) would be several times the height of virtually everything around them and would permanently dominate the skyline of Eastlakes and neighbouring Mascot and Rosebery. An FSR of 5.29:1 is a density appropriate to a CBD or a major transit-oriented centre with heavy rail — not a small local centre with no rail access. The height and density should be substantially reduced to a scale that transitions appropriately to the surrounding low-rise neighbourhood.

5. Overshadowing and solar access

Towers of this height on this site will cause significant overshadowing of the adjoining and nearby residential buildings, private open space and the public domain, particularly in mid-winter. I request that the Department rigorously test the applicant's shadow diagrams against the solar access requirements of the Apartment Design Guide (SEPP 65) for existing neighbouring apartments, not just the new dwellings, and refuse or amend the scheme where existing residents would lose compliant solar access. Wind effects at street level from towers of this scale should also be independently assessed.

6. Infrastructure and services

No commensurate upgrades are proposed to public transport, schools, open space, stormwater or utility infrastructure to serve approximately 2,000 additional residents. Eastlakes has no train, metro or light rail; residents are car-dependent, which compounds the traffic impacts above. Any approval should be conditional on satisfactory arrangements — funded by the developer — for public transport service improvements and local infrastructure contributions proportionate to the scale of the development.

7. Parking and servicing pressure

Parking pressure in Eastlakes is already acute, as documented in submissions on the Early Works application. Visitor, retail and overflow parking from this development will spill into surrounding streets. Loading, delivery and waste collection for a two-level commercial podium and 736 apartments will add constant heavy vehicle movements. The parking and servicing strategy should be independently reviewed, and on-street resident parking protections implemented in surrounding streets.

Conclusion

I am not opposed to the redevelopment of the Eastlakes Shopping Centre or to new housing, including affordable housing. But this proposal seeks nearly double the housing of the previously approved concept for this site, at a height and density with no precedent in the suburb, on a road network that is already failing, with no infrastructure upgrades and a build-to-rent component that is not even permissible under the current zoning.

I respectfully request that the application be refused in its current form, or alternatively substantially amended to: reduce the height and FSR to a scale compatible with the E1 Local Centre zone and surrounding neighbourhood; demonstrate through independently verified traffic modelling that the network can accommodate the development; and deliver the road, traffic-calming and public transport upgrades needed before occupation.

Submission Objecting to SSD-90572458 – Eastlakes Mixed Use Development (19A Evans Avenue, Eastlakes)

I object to the proposed development at 19A Evans Avenue, Eastlakes.

While I support additional housing in appropriate locations, this proposal represents a significant increase in scale beyond the previously approved development. The application seeks buildings of up to 18 storeys and 62.9 metres in height, compared to the existing approval of 7–12 storeys and 40.8 metres. It also increases the floor space ratio from 2.11:1 to 5.29:1 and the number of dwellings from 425 to between 736 and 877 dwellings.

My concerns include:

1. Excessive Height and Bulk – The proposal is substantially larger than the approved development and is out of character with the surrounding Eastlakes area.
2. Traffic and Congestion – The developer’s own assessment predicts an increase of approximately 246 vehicle trips in the morning peak and 332 vehicle trips in the afternoon peak. Local roads, particularly Evans Avenue, Gardeners Road and surrounding intersections, already experience congestion.
3. Overshadowing and Loss of Amenity – The proposal acknowledges increased shadow impacts on neighbouring properties and Jack Mundey Reserve. Residents and park users should not bear the cost of excessive overdevelopment.
4. Insufficient Open Space and Landscaping – Despite the scale of the project, deep soil planting is limited to only 595m² (3.3% of the site area), which is inadequate for a development of this size.
5. Pressure on Local Infrastructure – Hundreds of additional apartments will place further strain on local roads, public transport, schools, health services and community facilities without corresponding infrastructure upgrades.

I respectfully request that the Department refuse the application in its current form or require significant reductions in height, density and traffic impacts before any approval is considered.

Yours faithfully,
Christabelle Denis
304 24 rochester st botany nsw 2019

Submission Objecting to SSD-90572458 – Eastlakes Mixed Use Development (19A Evans Avenue, Eastlakes)

I object to the proposed development at 19A Evans Avenue, Eastlakes.

While I support additional housing in appropriate locations, this proposal represents a significant increase in scale beyond the previously approved development. The application seeks buildings of up to 18 storeys and 62.9 metres in height, compared to the existing approval of 7–12 storeys and 40.8 metres. It also increases the floor space ratio from 2.11:1 to 5.29:1 and the number of dwellings from 425 to between 736 and 877 dwellings.

My concerns include:

1. Excessive Height and Bulk – The proposal is substantially larger than the approved development and is out of character with the surrounding Eastlakes area.
2. Traffic and Congestion – The developer’s own assessment predicts an increase of approximately 246 vehicle trips in the morning peak and 332 vehicle trips in the afternoon peak. Local roads, particularly Evans Avenue, Gardeners Road and surrounding intersections, already experience congestion.
3. Overshadowing and Loss of Amenity – The proposal acknowledges increased shadow impacts on neighbouring properties and Jack Mundey Reserve. Residents and park users should not bear the cost of excessive overdevelopment.
4. Insufficient Open Space and Landscaping – Despite the scale of the project, deep soil planting is limited to only 595m² (3.3% of the site area), which is inadequate for a development of this size.
5. Pressure on Local Infrastructure – Hundreds of additional apartments will place further strain on local roads, public transport, schools, health services and community facilities without corresponding infrastructure upgrades.

In regards to roads especially, as a resident the traffic getting out of Eastlakes is very bad at peak hour with several roads backed up during the morning commute.

There needs to be additional public transport . Whilst there are numerous bus lines a metro that extends from Waterloo to eastlakes to Randwick will help to reduce the congestion on buses

I respectfully request that the Department refuse the application in its current form or require significant reductions in height, density and traffic impacts before any approval is considered.

Yours faithfully,

Joanne Del Rosario
1 Randolph st Rosebery

I object to the proposed development at 19A Evans Avenue, Eastlakes.

While I support additional housing in appropriate locations, this proposal represents a significant increase in scale beyond the previously approved development. The application seeks buildings of up to 18 storeys and 62.9 metres in height, compared to the existing approval of 7–12 storeys and 40.8 metres. It also increases the floor space ratio from 2.11:1 to 5.29:1 and the number of dwellings from 425 to between 736 and 877 dwellings.

My concerns include:

1. Excessive Height and Bulk – The proposal is substantially larger than the approved development and is out of character with the surrounding Eastlakes area.
2. Traffic and Congestion – The developer’s own assessment predicts an increase of approximately 246 vehicle trips in the morning peak and 332 vehicle trips in the afternoon peak. Local roads, particularly Evans Avenue, Gardeners Road and surrounding intersections, already experience congestion.
3. Overshadowing and Loss of Amenity – The proposal acknowledges increased shadow impacts on neighbouring properties and Jack Mundey Reserve. Residents and park users should not bear the cost of excessive overdevelopment.
4. Insufficient Open Space and Landscaping – Despite the scale of the project, deep soil planting is limited to only 595m² (3.3% of the site area), which is inadequate for a development of this size.
5. Pressure on Local Infrastructure – Hundreds of additional apartments will place further strain on local roads, public transport, schools, health services and community facilities without corresponding infrastructure upgrades.

I respectfully request that the Department refuse the application in its current form or require significant reductions in height, density and traffic impacts before any approval is considered.

Yours faithfully,

Submission Objecting to SSD-90572458 – Eastlakes Mixed Use Development (19A Evans Avenue, Eastlakes)

I object to the proposed development at 19A Evans Avenue, Eastlakes.

While I support additional housing in appropriate locations, this proposal represents a significant increase in scale beyond the previously approved development. The application seeks buildings of up to 18 storeys and 62.9 metres in height, compared to the existing approval of 7–12 storeys and 40.8 metres. It also increases the floor space ratio from 2.11:1 to 5.29:1 and the number of dwellings from 425 to between 736 and 877 dwellings.

My concerns include:

1. Excessive Height and Bulk – The proposal is substantially larger than the approved development and is out of character with the surrounding Eastlakes area.
2. Traffic and Congestion – The developer’s own assessment predicts an increase of approximately 246 vehicle trips in the morning peak and 332 vehicle trips in the afternoon peak. Local roads, particularly Evans Avenue, Gardeners Road and surrounding intersections, already experience congestion.
3. Overshadowing and Loss of Amenity – The proposal acknowledges increased shadow impacts on neighbouring properties and Jack Mundey Reserve. Residents and park users should not bear the cost of excessive overdevelopment.
4. Insufficient Open Space and Landscaping – Despite the scale of the project, deep soil planting is limited to only 595m² (3.3% of the site area), which is inadequate for a development of this size.
5. Pressure on Local Infrastructure – Hundreds of additional apartments will place further strain on local roads, public transport, schools, health services and community facilities without corresponding infrastructure upgrades.

I respectfully request that the Department refuse the application in its current form or require significant reductions in height, density and traffic impacts before any approval is considered.

Yours faithfully,

Kim Nguyen
49 Gordon St Rosebery NSW 2018

I write as a nearby resident to object to the Redevelopment of Eastlakes Shopping Centre, SSD-90572458, in its current form.

I am not opposed to the renewal of the shopping centre in principle. Eastlakes needs investment, a better retail environment and additional housing in appropriate locations. However, I object to this proposal as exhibited because the scale, height, density and traffic consequences have not been adequately justified for this site and its immediate low-rise residential context.

My principal concerns are the following:

The proposal is excessive in scale and height relative to the immediate neighbourhood.
The exhibited material describes a development comprising a two-storey podium with four towers of approximately 14 to 18 storeys above it. By contrast, the immediate residential context to the south and east is identified in the applicant’s own material as being predominantly three-storey brick walk-up apartments. The Visual Impact Assessment expressly states that there are three-storey brick walk-up apartment buildings immediately south and east of the site. The Design Report’s Appendix B also reproduces the State Design Review Panel comments that the “substantial uplift” sought for the site is a significant departure from the existing context and that the height strategy should be revised to better transition to the lower-scaled context to the south.

In my submission, this is the central flaw in the proposal. The bulk and height are not being introduced into a context already defined by comparable tower forms on the surrounding boundaries. The applicant’s own response material states there are currently minimal development applications proposed within the immediate locality. Accordingly, the argument that the proposal is simply responding to an already-established future high-rise character is not persuasive.

Under section 4.15(1) of the Environmental Planning and Assessment Act 1979, the Department must consider the likely impacts of the development, the suitability of the site, submissions and the public interest. The Department must also consider the relevant planning instruments. Under Chapter 4 of the State Environmental Planning Policy (Housing) 2021, the consent authority must consider the quality of the design evaluated against Schedule 9 and the Apartment Design Guide. Schedule 9 requires good design to respond to context, achieve a scale, bulk and height appropriate to the existing or desired future character of the street and surrounding buildings, ensure density is appropriate to the site and its context, and positively influence amenity for residents and neighbours.

In my view, the current scheme does not satisfy those considerations.

The proposal will have unacceptable overshadowing impacts on existing low-rise neighbours.
The exhibited solar access analysis is one of the clearest examples of why the design is not acceptable as shown. The Appendix E solar analysis indicates very poor winter solar outcomes for several of the existing Barber Avenue apartment buildings. Across the nine existing Barber Avenue buildings tabulated in the solar appendix, only 54 of 112 units achieve more than two hours of direct sunlight in mid-winter.

That is not a minor or incidental impact. It is a strong indicator that the southern edge of the built form remains too tall and too bulky for its relationship to existing neighbours.

The Apartment Design Guide states that, in the Sydney Metropolitan Area, living rooms and private open spaces of at least 70% of apartments in a building should receive a minimum of 2 hours direct sunlight between 9 am and 3 pm at mid-winter, and that a maximum of 15% of apartments should receive no direct sunlight in that period. I acknowledge that those criteria apply to the design of the proposal itself, rather than directly regulating neighbouring buildings. However, they remain a highly relevant benchmark for understanding the seriousness of the shadowing now being imposed on adjoining low-rise apartments.

At minimum, the Department should require a revised built form that materially improves solar access to the neighbouring Barber Avenue apartments before any approval is considered.

The applicant has not demonstrated that the surrounding road network can accommodate the proposal at this scale.
The surrounding local road structure is constrained. Access is concentrated on Evans Avenue and Barber Avenue, with broader network connection dependent on Racecourse Place, Gardeners Road and nearby intersections including Maloney Street / Gardeners Road / Dalmeny Avenue. This is not a location with abundant alternative road access.

The exhibited Traffic Impact Assessment calculates a net increase of approximately 246 vehicle trips in the AM peak, 332 vehicle trips in the PM peak, and 291 Saturday peak trips associated with the retail component. Even after using multiple demand-reducing assumptions, the modelling still reports a 194.5 m AM queue at Gardeners Road / Racecourse Place and a DoS of 1.063 at Maloney Street / Gardeners Road / Dalmeny Avenue in the AM development scenario.

The traffic conclusion should not be accepted at face value because the modelling depends on several optimistic assumptions:
the former shopping centre was only 70% active at the time of survey,
20% of proposed retail trips will be internally captured,
no Saturday residential trip estimate is included,
only Existing Base and Existing Base + Development scenarios are modelled, and
post-development signal optimisation is assumed.

The applicant has therefore not demonstrated, in a sufficiently conservative way, that the local road network can absorb the full demand of the development. That is especially so when the Design Report also states that dual-key units could increase the total number of dwellings from 736 to as many as 877.

In my view, the Department should require a revised Traffic Impact Assessment that includes:
a cumulative future background traffic scenario,
sensitivity testing at the possible higher dwelling count,
Saturday residential trip assessment,
sensitivity testing with reduced or no internal capture,
a more robust justification for the existing retail deduction, and
independent agency confirmation that any assumed signal optimisation is feasible.

Servicing and loading are not adequately resolved.
The exhibited servicing analysis indicates a substantial servicing task, with 503 daily vehicle arrivals through the Freight Forecaster. The initial loading scenario tested on the current arrangement has only 74.94% average efficacy, with 74 rejected vehicles per day and 12 rejected vehicles in the peak hour. It improves only if small vehicle spaces are increased to 14.

This suggests that the current servicing arrangement is not properly resolved. For nearby residents, the consequence is obvious: more risk of kerbside friction, waiting vehicles, informal loading behaviour and additional traffic pressure on the surrounding streets.

Construction impacts are significant and not properly pinned down in the exhibited material.
The exhibited construction traffic material is only preliminary. It says construction traffic volumes are unknown, staging is to be confirmed, and the final routes and access arrangements via Evans Avenue and/or Barber Avenue will be settled later by the contractor. That is not sufficient for a project of this scale in close proximity to existing apartments.
The Noise and Vibration Assessment also concludes that construction noise management levels are expected to be exceeded during all construction stages. This means the construction impact is not hypothetical. It is expected.

The visual bulk and streetscape impact are unacceptable in the current form.
The Visual Impact Assessment itself identifies moderate-to-severe visual impacts from close public viewpoints, including Evans Avenue and Jack Mundey Reserve. At the Evans Avenue viewpoint, the report says the proposal would significantly change the apparent height, scale and enclosure of the immediate streetscape and transform the existing low- to mid-rise character into a much denser urban edge condition. It is a fundamentally different order of scale.

Submission Objecting to SSD-90572458 – Eastlakes Mixed Use Development (19A Evans Avenue, Eastlakes)
I object to the proposed development at 19A Evans Avenue, Eastlakes.
While I support additional housing in appropriate locations, this proposal represents a significant increase in scale beyond the previously approved development. The application seeks buildings of up to 18 storeys and 62.9 metres in height, compared to the existing approval of 7–12 storeys and 40.8 metres. It also increases the floor space ratio from 2.11:1 to 5.29:1 and the number of dwellings from 425 to between 736 and 877 dwellings.
My concerns include:
1. Excessive Height and Bulk – The proposal is substantially larger than the approved development and is out of character with the surrounding Eastlakes area.
2. Traffic and Congestion – The developer’s own assessment predicts an increase of approximately 246 vehicle trips in the morning peak and 332 vehicle trips in the afternoon peak. Local roads, particularly Evans Avenue, Gardeners Road and surrounding intersections, already experience congestion.
3. Overshadowing and Loss of Amenity – The proposal acknowledges increased shadow impacts on neighbouring properties and Jack Mundey Reserve. Residents and park users should not bear the cost of excessive overdevelopment.
4. Insufficient Open Space and Landscaping – Despite the scale of the project, deep soil planting is limited to only 595m² (3.3% of the site area), which is inadequate for a development of this size.
5. Pressure on Local Infrastructure – Hundreds of additional apartments will place further strain on local roads, public transport, schools, health services and community facilities without corresponding infrastructure upgrades.
I respectfully request that the Department refuse the application in its current form or require significant reductions in height, density and traffic impacts before any approval is considered.
Yours faithfully
GUIOIVANNY MANTILLA QUINTERO.
26/66 MASCOT DRIVE
Eastlakes Resident

Severe Traffic Congestion and Bottlenecks: Local roads—including Evans Avenue, Barber Avenue, Gardeners Road, and Florence Avenue—are already heavily congested during peak morning and afternoon periods. Adding thousands of daily vehicle trips generated by high-density residential towers and expanded commercial space will severely degrade local road service levels. The proposal creates dangerous traffic bottlenecks, queues back into narrow residential side streets, increases safety risks for pedestrians, and delays emergency vehicle response times along critical corridors.
Inadequate On-Site Parking and On-Street Spillover: The proposed parking allocation fails to account for realistic vehicle ownership rates for multi-bedroom apartments, alongside visitor and retail parking demand. This shortfall will inevitably force excess parking onto surrounding residential streets where space is already severely constrained. Furthermore, constant heavy delivery, service, and waste management vehicles will cause ongoing traffic blockages and safety hazards on narrow local lanes.
Incompatibility with Established Neighborhood Character: Eastlakes is defined by a distinct low-to-medium density suburban scale, an established tree canopy, and a low-rise village layout. The excessive height, overall bulk, and floor space ratio (FSR) of the multi-story towers stand in stark contrast to surrounding single-dwelling houses and modest apartment blocks. The proposal represents an aggressive urban overdevelopment that completely ignores the established architectural context and scale of the area.
Severe Overshadowing, Microclimate, and Loss of Solar Access: Due to the excessive height and massing of the towers, adjoining residential properties and public spaces will suffer severe overshadowing. Solar access to living areas and private open spaces of neighboring homes will drop well below acceptable planning guidelines. Additionally, towering structures of this scale risk creating unpleasant microclimates, including wind-tunnel effects and heat islanding that degrade the ground-level pedestrian experience.
Loss of Privacy and Overlooking: The height and placement of upper-level residential units create direct, unmitigated sightlines into the private open spaces and windows of surrounding low-density residences. This permanent loss of visual privacy severely diminishes the amenity and quiet enjoyment of nearby homes.
Removal of Mature Tree Canopy and Loss of Green Amenity: The footprint of the proposed development requires the destruction of mature trees and existing urban greenery that provide essential shading, local biodiversity habitat, and natural heat mitigation. The replacement planting proposed in deep soil zones is insufficient to offset the loss of established canopy cover, worsening the urban heat island effect across the precinct.
Strain on Overburdened Social and Public Infrastructure: Injecting a massive new resident population into a concentrated precinct will place unsustainable strain on local public assets. Surrounding primary schools, early childhood learning facilities, healthcare providers, and local council sporting fields are already operating at or near capacity. The proposal offers no commensurate expansion of public open space or community facilities to support this dense population influx.
Inadequate Public Transport Capacity: While the proposal relies heavily on public transport assertions to justify reduced parking ratios, local bus networks along Gardeners Road and surrounding routes are already overcrowded during peak hours. Without guaranteed, funded capacity increases to state transit services, the influx of commuters will lead to overcrowded buses, missed connections, and increased reliance on private vehicles.
Inadequate Deep Soil and Environmental Design: High-density site coverage severely limits genuine deep soil zones required for large canopy trees and natural stormwater infiltration. The extensive hardscape increases surface runoff, placing additional pressure on local stormwater drainage systems during heavy rainfall events and increasing localized flooding risks.
Loss of Community-Focused, Essential Retail: Replacing an accessible, human-scale local village center with a high-density commercial complex risks pricing out essential, affordable day-to-day services. Long-term residents, low-income households, and elderly community members rely on convenient, walkable access to affordable retail, which will be displaced in favor of high-turnover commercial tenants tailored to high-density living.
Failure to Meet Design Excellence Standards: The sheer bulk, repetitive massing, and minimal building setbacks demonstrate a design driven by yield maximization rather than architectural excellence or contextual integration. The design fails to provide appropriate transitions to lower-density boundaries, creating an overbearing visual impact from all street frontages.

I object to this proposal as exhibited because the scale, height, density and traffic consequences have not been adequately justified for this site and its immediate low-rise residential context.

My principal concerns are the following:

The proposal is excessive in scale and height relative to the immediate neighbourhood.
The exhibited material describes a development comprising a two-storey podium with four towers of approximately 14 to 18 storeys above it. By contrast, the immediate residential context to the south and east is identified in the applicant’s own material as being predominantly three-storey brick walk-up apartments. The Visual Impact Assessment expressly states that there are three-storey brick walk-up apartment buildings immediately south and east of the site. The Design Report’s Appendix B also reproduces the State Design Review Panel comments that the “substantial uplift” sought for the site is a significant departure from the existing context and that the height strategy should be revised to better transition to the lower-scaled context to the south.

In my submission, this is the central flaw in the proposal. The bulk and height are not being introduced into a context already defined by comparable tower forms on the surrounding boundaries. The applicant’s own response material states there are currently minimal development applications proposed within the immediate locality. Accordingly, the argument that the proposal is simply responding to an already-established future high-rise character is not persuasive.

Under section 4.15(1) of the Environmental Planning and Assessment Act 1979, the Department must consider the likely impacts of the development, the suitability of the site, submissions and the public interest. The Department must also consider the relevant planning instruments. Under Chapter 4 of the State Environmental Planning Policy (Housing) 2021, the consent authority must consider the quality of the design evaluated against Schedule 9 and the Apartment Design Guide. Schedule 9 requires good design to respond to context, achieve a scale, bulk and height appropriate to the existing or desired future character of the street and surrounding buildings, ensure density is appropriate to the site and its context, and positively influence amenity for residents and neighbours.

In my view, the current scheme does not satisfy those considerations.

The proposal will have unacceptable overshadowing impacts on existing low-rise neighbours.
The exhibited solar access analysis is one of the clearest examples of why the design is not acceptable as shown. The Appendix E solar analysis indicates very poor winter solar outcomes for several of the existing Barber Avenue apartment buildings. Across the nine existing Barber Avenue buildings tabulated in the solar appendix, only 54 of 112 units achieve more than two hours of direct sunlight in mid-winter.

That is not a minor or incidental impact. It is a strong indicator that the southern edge of the built form remains too tall and too bulky for its relationship to existing neighbours.

The Apartment Design Guide states that, in the Sydney Metropolitan Area, living rooms and private open spaces of at least 70% of apartments in a building should receive a minimum of 2 hours direct sunlight between 9 am and 3 pm at mid-winter, and that a maximum of 15% of apartments should receive no direct sunlight in that period. I acknowledge that those criteria apply to the design of the proposal itself, rather than directly regulating neighbouring buildings. However, they remain a highly relevant benchmark for understanding the seriousness of the shadowing now being imposed on adjoining low-rise apartments.

At minimum, the Department should require a revised built form that materially improves solar access to the neighbouring Barber Avenue apartments before any approval is considered.

The applicant has not demonstrated that the surrounding road network can accommodate the proposal at this scale.
The surrounding local road structure is constrained. Access is concentrated on Evans Avenue and Barber Avenue, with broader network connection dependent on Racecourse Place, Gardeners Road and nearby intersections including Maloney Street / Gardeners Road / Dalmeny Avenue. This is not a location with abundant alternative road access.

The exhibited Traffic Impact Assessment calculates a net increase of approximately 246 vehicle trips in the AM peak, 332 vehicle trips in the PM peak, and 291 Saturday peak trips associated with the retail component. Even after using multiple demand-reducing assumptions, the modelling still reports a 194.5 m AM queue at Gardeners Road / Racecourse Place and a DoS of 1.063 at Maloney Street / Gardeners Road / Dalmeny Avenue in the AM development scenario.

The traffic conclusion should not be accepted at face value because the modelling depends on several optimistic assumptions:
the former shopping centre was only 70% active at the time of survey,
20% of proposed retail trips will be internally captured,
no Saturday residential trip estimate is included,
only Existing Base and Existing Base + Development scenarios are modelled, and
post-development signal optimisation is assumed.

The applicant has therefore not demonstrated, in a sufficiently conservative way, that the local road network can absorb the full demand of the development. That is especially so when the Design Report also states that dual-key units could increase the total number of dwellings from 736 to as many as 877.

In my view, the Department should require a revised Traffic Impact Assessment that includes:
a cumulative future background traffic scenario,
sensitivity testing at the possible higher dwelling count,
Saturday residential trip assessment,
sensitivity testing with reduced or no internal capture,
a more robust justification for the existing retail deduction, and
independent agency confirmation that any assumed signal optimisation is feasible.

Servicing and loading are not adequately resolved.
The exhibited servicing analysis indicates a substantial servicing task, with 503 daily vehicle arrivals through the Freight Forecaster. The initial loading scenario tested on the current arrangement has only 74.94% average efficacy, with 74 rejected vehicles per day and 12 rejected vehicles in the peak hour. It improves only if small vehicle spaces are increased to 14.

This suggests that the current servicing arrangement is not properly resolved. For nearby residents, the consequence is obvious: more risk of kerbside friction, waiting vehicles, informal loading behaviour and additional traffic pressure on the surrounding streets.

Construction impacts are significant and not properly pinned down in the exhibited material.
The exhibited construction traffic material is only preliminary. It says construction traffic volumes are unknown, staging is to be confirmed, and the final routes and access arrangements via Evans Avenue and/or Barber Avenue will be settled later by the contractor. That is not sufficient for a project of this scale in close proximity to existing apartments.
The Noise and Vibration Assessment also concludes that construction noise management levels are expected to be exceeded during all construction stages. This means the construction impact is not hypothetical. It is expected.

The visual bulk and streetscape impact are unacceptable in the current form.
The Visual Impact Assessment itself identifies moderate-to-severe visual impacts from close public viewpoints, including Evans Avenue and Jack Mundey Reserve. At the Evans Avenue viewpoint, the report says the proposal would significantly change the apparent height, scale and enclosure of the immediate streetscape and transform the existing low- to mid-rise character into a much denser urban edge condition. It is a fundamentally different order of scale.

Requested outcome
For the reasons above, I request that the Department:
Refuse the proposal in its current form, or alternatively require a substantially revised scheme and re-exhibition before any approval is considered.
Require reduced height and bulk, especially along the southern and eastern boundaries adjoining the existing low-rise apartment context.
Require increased setbacks, deeper landscape buffers and a more meaningful transition to neighbouring three-storey apartments.
Require a revised Traffic Impact Assessment with cumulative growth, sensitivity testing and a conservative approach to trip generation.
Require a redesigned loading and servicing strategy that demonstrably avoids spillover and rejected vehicles.
Require a final detailed Construction Traffic Management Plan and Construction Management Plan before any consent is granted or relied upon, including quantified truck movements, routes, staging and resident protection measures.
Require revised overshadowing analysis and built form changes that materially improve solar access to affected neighbouring apartments.
Require exhibition and review of any stand-alone wind assessment and any other technical material not presently available in a full and accessible form to the public.

I therefore object to the proposal in its current form and request that the Department refuse it, or require a materially reduced and redesigned proposal before any approval is considered.

I object to the proposed development at 19A Evans Avenue, Eastlakes.

While I support additional housing in appropriate locations, this proposal represents a significant increase in scale beyond the previously approved development. The application seeks buildings of up to 18 storeys and 62.9 metres in height, compared to the existing approval of 7–12 storeys and 40.8 metres. It also increases the floor space ratio from 2.11:1 to 5.29:1 and the number of dwellings from 425 to between 736 and 877 dwellings.

My concerns include:

1. Excessive Height and Bulk – The proposal is substantially larger than the approved development and is out of character with the surrounding Eastlakes area.
2. Traffic and Congestion – The developer’s own assessment predicts an increase of approximately 246 vehicle trips in the morning peak and 332 vehicle trips in the afternoon peak. Local roads, particularly Evans Avenue, Gardeners Road and surrounding intersections, already experience congestion.
3. Overshadowing and Loss of Amenity – The proposal acknowledges increased shadow impacts on neighbouring properties and Jack Mundey Reserve. Residents and park users should not bear the cost of excessive overdevelopment.
4. Insufficient Open Space and Landscaping – Despite the scale of the project, deep soil planting is limited to only 595m² (3.3% of the site area), which is inadequate for a development of this size.
5. Pressure on Local Infrastructure – Hundreds of additional apartments will place further strain on local roads, public transport, schools, health services and community facilities without corresponding infrastructure upgrades.

I respectfully request that the Department refuse the application in its current form or require significant reductions in height, density and traffic impacts before any approval is considered.

Yours faithfully,
Irene Petropoulos