Re: Objection to Proposed Development at 11–23 Rangers Avenue, Mosman

To Whom It May Concern,

I am an owner-occupier of a semi-detached dwelling within Holt Avenue, a Heritage Conservation Area in Mosman. I am writing to object to the proposed seven-story residential development at 11–23 Rangers Avenue, which includes approximately 91 car parking spaces and will directly impact adjoining residential streets, including my own.

My concerns are outlined below and are based on day-to-day lived experience, local safety considerations, and the importance of protecting the character and amenity of this established neighbourhood.


Traffic, Safety and Construction Impacts

Local streets in this area already experience high traffic volumes, particularly during peak commuting periods. The construction of a development of this size will introduce extended disruption through heavy vehicle movements, site access, and deliveries, significantly affecting traffic flow and safety for residents.

Once completed, the scale of the development and the associated increase in vehicle movements will place additional pressure on a road network that is constrained by narrow streets, limited visibility, and existing congestion. These impacts will extend beyond Rangers Avenue and affect surrounding residential streets that were not designed to accommodate this level of activity.


Pedestrian Safety and Walking Distance Concerns

I personally need to cross Spofforth Street at the intersection with Holt Avenue as part of my daily movements within the neighbourhood. This intersection is widely recognised by local residents as unsafe. I regularly witness car accidents here, and traffic volumes are particularly heavy during peak hours.

Due to safety concerns, I choose to walk further uphill to Military Road in order to cross Spofforth Street at a safer, signalised location. This lived experience highlights that the route proposed by the applicant cannot reasonably be considered a safe or practical walking connection.

The applicant’s Traffic Impact Assessment does not adequately address traffic flows, driver behaviour, or the well-documented safety issues at the Holt and Spofforth intersection. No clear evidence has been provided to demonstrate that this route meets the intent or definition of a safe “walking distance” under the Housing SEPP. On this basis, the site should not be considered compliant with the LMR Outer Area criteria.


Public Transport Limitations and Military Road Congestion

While Military Road is often cited as a public transport corridor, it already operates under significant congestion, particularly during peak periods. Bus reliability is frequently affected by traffic delays, resulting in inconsistent travel times and reduced practicality for daily commuting.

Beyond Military Road, public transport options servicing Rangers Avenue and the surrounding streets are limited. Access to frequent, reliable services requires walking longer distances along steep gradients and navigating busy intersections, which is not suitable for all residents.

As a result, residents in this area remain heavily reliant on private vehicles for daily travel. This existing car dependency means that additional density in a location with constrained road capacity and limited effective public transport access will inevitably increase traffic congestion and parking demand, rather than reduce it.


Parking Constraints and Safety Implications

Parking availability is already limited in this area. Importantly, as a resident of a Heritage Conservation Area, I am not permitted to add a carport or additional off-street parking due to council heritage controls and minimum frontage requirements. Many of my neighbours face the same constraints.

As a result, many existing households are reliant on on-street parking, not by choice but due to planning constraints designed to preserve the heritage character of the area. Any additional parking demand generated by this development—whether from residents, visitors, service providers, or trades—will place further strain on already limited on-street parking.

This increased pressure will not only reduce amenity but also create safety concerns, including reduced sightlines, narrower effective road widths, and compromised access for emergency and service vehicles.


Impact on Heritage Character

The Holt Estate Heritage Conservation Area and surrounding streets are highly valued for their cohesive Federation-era character and historic significance.

The demolition of existing Federation homes and their replacement with a seven-storey development will permanently alter the setting and visual integrity of this heritage precinct. The height, scale, and bulk of the proposal are inconsistent with the established character of the area and undermine long-standing planning objectives intended to protect Mosman’s heritage identity.

Appropriateness of the Development Pathway
While housing provision is important, it is difficult to reconcile the use of the State Significant Development pathway for a proposal that appears primarily oriented toward high-end residential outcomes.

The inclusion of affordable housing, while noted, appears to facilitate a larger luxury apartment development positioned to maximise views and market value. This raises concerns about whether the proposal genuinely aligns with the intent of state planning policies and whether this site is appropriate for such intensity of development.


Conclusion

The concerns outlined above reflect both personal experience and broader community impacts. The proposal raises serious issues relating to pedestrian safety, traffic congestion, parking constraints, and irreversible harm to heritage character.

For these reasons, I respectfully request that the application for 11–23 Rangers Avenue, Mosman be refused.

Thank you for considering this submission.

Yours sincerely,
Lauren Evans
Owner-Occupier
93 Holt Avenue
Mosman NSW
December 17, 2025

I write to formally object to the above State Significant Development Application currently on public exhibition. My objection is based on significant planning, amenity, traffic, safety, and character impacts arising from the proposed development.

The proposed seven-storey apartment development is fundamentally inconsistent with the established low-density residential character of the street and surrounding locality. The street is characterised predominantly by detached dwellings and heritage-style homes, generally of one to two storeys.
The introduction of a building of this scale and intensity would be visually incongruous, dominating the streetscape and eroding the established character that defines the area. This form of development is more appropriately located within designated higher-density zones or activity centres, not within a predominantly residential street.
Approval of this proposal would set an undesirable planning precedent, opening the door to further high-rise apartment development in streets that have historically and strategically been planned for low-rise residential use.

The proposal will significantly worsen an already constrained traffic environment.
• Street congestion is currently severe, particularly during school zone operating hours, where traffic frequently becomes standstill.
• The additional vehicle movements generated by a development of this scale will exacerbate congestion, delays, and safety risks.
Of particular concern is vehicle access from Bloxsome Lane, including:
• The removal of six existing crossovers
• Increased reliance on an extremely narrow laneway that is not designed to accommodate high traffic volumes
The laneway:
• Is too narrow for two-way vehicle movement
• Has no safe pull-over areas, resulting in vehicles needing to reverse long distances to allow passing
• Is already operationally unsafe and will be further compromised by increased use

The development will result in significant amenity impacts, including:
• Overshadowing
• Loss of privacy
• Increased noise and activity
• Visual bulk and dominance
These impacts will negatively affect the livability of surrounding homes, many of which have been occupied long-term by residents who reasonably expected the area to remain low-rise and residential in nature.

The proposal is likely to result in devaluation of surrounding properties due to:
• Loss of character and amenity
• Increased congestion and safety concerns
• Overshadowing and visual intrusion

While the proposal is framed under the banner of “affordable housing”, it does not meaningfully address the housing crisis in a way that justifies its scale and impacts.
• The number of genuinely affordable dwellings is limited
• The proposal does not provide a proportionate public benefit to offset its significant negative impacts
• Affordable housing objectives should not override fundamental planning principles relating to character, safety, and infrastructure capacity

Bloxsome Lane is used regularly by school-aged children walking to and from school. Increasing vehicle volumes and turning movements within this confined space presents a clear and unacceptable safety risk.
The proposal fails to adequately address:
• Pedestrian–vehicle conflict
• Safe sightlines
• Child safety in a high-use pedestrian environment
These risks are particularly concerning given the narrowness of the laneway and the lack of refuge or footpath separation.

The existing road network, laneways, and local infrastructure were not designed to accommodate development of this scale. The proposal places additional strain on:
• Roads and intersections
• Pedestrian routes
• Parking availability
• Local services
There is insufficient evidence that the surrounding infrastructure can safely or effectively absorb this level of intensification.

In summary, the proposed development is:
• Incompatible with the established residential and heritage character of the area
• Excessive in height, scale, and intensity
• Detrimental to traffic flow and pedestrian safety
• Particularly dangerous given the narrowness of Bloxsome Lane
• Likely to reduce amenity, property values, and neighbourhood cohesion
• Not justified by its limited contribution to affordable housing outcomes
• Negatively impacts the local well established environment and landscape with the removal of 21 trees

For these reasons, I respectfully request that the application be refused, or at minimum substantially reduced in height, scale, and intensity to align with the existing character and capacity of the area.

Submission of Objection — Proposed Residential Development at 11–23 Ranges Avenue, Mosman
1. Introduction
I lodge this objection to the development application for a 7–8 storey residential building at 11–24 Ranges Avenue, Mosman. My objection is made on planning grounds including incompatibility with statutory controls, impacts to heritage and local character, and adverse traffic and amenity effects.

2. Statutory Planning Grounds of Objection
2.1 Inconsistency with Mosman LEP 2012 — Height, Bulk and Scale
The intent of the Mosman Local Environmental Plan 2012 is to ensure development respects the existing residential amenity and character of Mosman, including its visual qualities and heritage values. Objectives include:
• protecting neighbourhood character and existing residential amenity;
• conserving heritage; and
• ensuring development is compatible with the built form of the area.

Although the LEP sets numeric height and floor space ratio standards (via the Height of Buildings, Wall Height and FSR maps and clauses), the objectives make clear that compliance is not the only test — the proposal must also satisfy the underlying planning intent. The subject proposal’s height and massing are not reflective of the surrounding townscape, which is primarily low-rise (one to two storeys). There is no meaningful transitional design response on the interface with adjacent low-rise development.

2.2 DCP Controls — Site Siting and Scale
The Mosman Residential DCP emphasises that the siting and scale of buildings should maintain a ‘satisfactory relationship with neighbouring properties and the wider street context.’ It also notes that building height and bulk should reflect the existing or future desired townscape scale and contribute positively to neighbourhood character.

Key control objectives that the proposal fails to satisfy include:
• Scale inconsistent with existing townscape character — the building’s sheer verticality, lack of stepping down, and excessive mass is not in keeping with predominant 1–2 storey forms;
• Lack of contextual response — there is no graduation of height or modulation to respect adjoining low-rise residential buildings; and
• Failure to demonstrate how new built form will ‘sit comfortably’ in context as required by DCP guidance.

These siting and scale outcomes are not merely aesthetic preferences — they are embedded in the statutory planning instruments to ensure neighbourhood amenity and character are conserved.

2.3 Heritage Considerations
The LEP and DCP frameworks both require consideration of heritage significance where relevant. Mosman contains numerous heritage items and conservation areas identified in the LEP, and the DCP requires new development to consider heritage context in design — particularly where adjacent to heritage items or precincts.

The proposal’s height, massing and visual prominence will significantly detract from the setting of nearby heritage precincts and buildings, undermining heritage conservation objectives. The proposal also fails to articulate a heritage impact assessment that satisfactorily demonstrates minimal visual or contextual harm.

3. Amenity and Traffic Impacts
3.1 Traffic and Road Safety
The proposed development will introduce a substantial increase in traffic generation and turning movements on an already busy Ranges Avenue. The entry/exit point’s location presents conflict with existing traffic flows, pedestrian movement and sightlines. Increased congestion, waiting times and potentially crash risk are legitimate planning and safety concerns — particularly where existing road design does not provide adequate capacity or separation of movement types.

Traffic and access impacts that cannot be satisfactorily mitigated are a valid basis for objection under general amenity and environmental impact considerations provided in the standard Environmental Planning and Assessment Act assessment framework.

3.2 Privacy, Overshadowing and Amenity
Given the building’s height and massing, overshadowing of neighbouring properties, loss of privacy and increased overlooking towards adjacent residential yards and living rooms will be significant. These effects materially degrade residential amenity and conflict with DCP objectives that seek to protect solar access and privacy.

4. Precedent and Strategic Implications
Approving a development of this scale here would establish a precedent for other large, out-of-context developments along ridgelines and near heritage precincts, incrementally eroding Mosman’s townscape character and heritage values. This would be inconsistent with strategic planning priorities set by Council and reflected in both the LEP and DCP frameworks.

5. Summary of Grounds of Objection
Primary grounds include:
1. Incompatible bulk and scale inconsistent with Mosman LEP/DCP character objectives.
2. Lack of meaningful height transition to adjacent low-rise buildings.
3. Adverse visual prominence given the site’s ridgeline position.
4. Inadequate response to heritage context and impact on nearby heritage precinct.
5. Traffic safety and congestion impacts.
6. Loss of residential amenity (overshadowing, privacy).

6. Conclusion and Requested Outcome
For the reasons above, I respectfully request that the application be refused or substantially redesigned to properly address statutory controls, context, heritage impacts, traffic and amenity concerns.

I object strongly to the proposed State Significant Development at 11-23 Rangers Avenue, based on significant non-compliance, inaccurate assessment documents, unacceptable bulk and scale, and irreversible impacts on local character, heritage, and public safety.
My objection is based on the following areas:

Misleading representations by the Applicant
Page 33 of the Engagement outcomes report of the EIS of the application states that the developer distributed a near neighbour letter which provided an overview of the SSDA and outlined how residents could make enquiries and provide feedback via the 1800 number and project email address. Page 51 appendix B within Appendix P is a map demonstrating which houses this included. Our house is within this are and yet we did not receive such letter representing a false statement by the applicant. Our requests for an in person briefing was denied and then we were offered a zoom meeting by Urbis after the lodgement of a SSDA by the developer. In essence we denied an opportunity to provide feedback during the early stages of the planning process as described by the developer in their documents.

Inappropriate Location and Non-Compliance with LMR Policy
The application relies on accessing Local Medium Density Residential (LMR) planning controls that permit greater density. However, the properties at 11-23 Rangers Avenue are not within the LMR Outer Area (i.e., not within 800m walking distance of the Cremorne Town Centre),.
• The walking route proposed by the applicant ( Appendix GG), which crosses Spofforth Street at the intersection with Holt Avenue, is not safe due to heavy traffic volumes, especially during peak hours, and known pedestrian safety concerns. Everyone who lives in the area knows this and I personally experience this on a daily basis.
• There have been at least 30 reported traffic accidents at the junction of Holt & Spofforth since 2018 indicating this is not a safe pedestrian pathway.
• If safe walking routes utilizing existing traffic lights (Spofforth-Military Road) or pedestrian crossings (Spofforth-Rangers Avenue intersection) are measured, the properties fall outside the LMR Outer Area.
• The Department should deny the application on the basis that no evidence has been provided to support that the applicant's proposed route meets the definition of ‘walking distance’ in the State Environmental Planning Policy (Housing) 2021 (Housing SEPP).

Excessive Bulk, Scale, and Failure of Design Transition
The proposed development constitutes overdevelopment that is highly inappropriate for this specific location.
• The development fails to provide a necessary built form transition to the adjacent C4 Environmental zones on Holt Avenue, Spencer & Cowles Roads which are excluded from LMR policy due to their intrinsic environmental and scenic values,. The design seeks to maximize and even exceed permitted building height and scale under the LMR policy, disrespecting the adjoining C4 zone to the north (Holt Avenue/Spencer Road).
• The applicant’s Environmental Impact Statement (EIS) claims the transition is managed "in a contextually responsive way". This is contradicted by the proposal's clear intent to maximize vertical massing, including substantial built elements like lift shafts and rooftop plant that contribute materially to perceived bulk despite being excluded from the Gross Floor Area (GFA) calculation,.
• The Land and Environment Court (LEC) recognizes that numerical compliance with Floor Space Ratio (FSR) does not guarantee acceptable planning merit if the bulk, scale, and dominance are inappropriate in context,. The proposal, especially situated on an already high ledge, will be an enormous, hulking eyesore visible from surrounding streets.

Misleading Visual Impact and View Loss Assessments
The applicant has failed to provide adequate assessments, which directly impacts my rights to reasonable view sharing and the preservation of the local scenic character.
• The Visual Impact Assessment (VIA) is misleading as it incorrectly claims only part of the site is within the Scenic Protection Area (SPA) when the entire lots of 11-23 Rangers Avenue are within the SPA - Scenic Protection Map Sheet SCP_002 within Mosman Local Environmental Plan 2012
• The VIA fails to consider the adjacent Holt Estate Heritage Conservation Area immediately to the north. The applicant has failed to provide any visual analysis from the north (e.g., from Holt Avenue, Spencer Road or Cowles Road), where the visual impact will be high.
• The proposed height and bulk, located on a sloping ridgeline where the Holt Estate HCA is at a higher elevation, will significantly and adversely change the existing natural landscape and landform, violating the Mosman Local Environmental Plan 2012
• The applicant has not demonstrated any measures to minimize the visual impact on views to Sydney Harbour or the CBD, which is required under Mosman Local Enviroment Plan 2012 . I request the Department require the applicant provide the detailed view loss and sharing assessment having regard to the LEC principles for view loss.

Significant Impact on Heritage Character and Items
The development will inflict permanent damage on one of Mosman’s most aesthetic and iconic areas.
• The proposal will become a permanent backdrop to the historic Holt Estate Heritage Conservation Area. This area includes homes identified as "contributory" to heritage character, yet the applicant’s Heritage Impact Statement (HIS) downplays its significance.
• The HIS failed to list Heritage Item I380, the Holt Avenue street trees, which are categorized as “rare” and noted as one of Mosman’s finest avenues of street trees.
• The claim in the HIS that architectural design follows the existing topography and mitigates impacts is misleading, if not completely false.

Construction Risks and Traffic Impacts
The required construction methodology poses an unacceptable risk to surrounding properties and local infrastructure.
• The two-level basement carpark requires extensive excavation to cut the structure into the sandstone across most of the land, extending under Bloxsome Lane and Rangers Avenue.
• Excavation near the cliff face opposite Rangers Avenue poses a significant threat of rockfall, progressive landslip, and destabilization of Rangers Avenue and neighboring properties. The Geotechnical survey supplied by the applicant clearly demonstrates Rangers Avenue sits on a cliff face at this site and the applicant can make no guarantees that major structural damage will not occur to the road or neighbouring & downslope properties.
• The location is historically a natural path for water (suggested by a former waterfall nearby), and excavation into the porous sandstone increases the risk of flooding, landslides, and structural instability. There does not appear to be a comprehensive assessment of the flooding impact on the properties north of the development site.
• The noise and vibration from weeks or months of massive rock breaking will inevitably damage the structural integrity of nearby heritage houses.
• The garage exit onto Rangers Avenue will magnify the already chaotic traffic issues that occur frequently on that street, placing increased strain on offstreet parking and making access to public transport difficult for existing residents.
• Rangers avenue has a 3 ton weight limit for vehicles. The applicant has not adequately explained how a development of this size can be undertaken given this constraint. The rear Bloxsome Lane is not suitable for access by heavy vehicles.

In summary, I request the Department denies this application on the basis that the proposed design represents overdevelopment that breaches core planning principles relating to safety, heritage preservation, scenic protection, and contextual bulk/scale.

I am writing to object to SSD-96272465 (11-23 Rangers Avenue, Mosman) specifically as it concerns my property but also more generally because the EIS (and many of its supporting documents) contain substantial errors, omissions and misleading statements.

Reasons for this include but are not limited to:
• Site Isolation and reasonable development potential of 9 & 9A Rangers
• The applicant has failed to demonstrate that 9 & 9A Rangers Ave (or 9 alone) can achieve a future development of appropriate urban form and with an acceptable level of amenity.
• The EIS offers up alleged precedents, but closer examination shows they are not actually comparable.
• Arguments to support the proposed development height variation are based on inaccurate information, are incoherent, and unpersuasive.
• The EIS does not clearly demonstrate that at least 15% Gross Floor Area (GFA) is allocated to affordable accommodation.
• There are solutions not requiring height variation that would reduce the isolation of my property
• Errors and omissions call the conclusions of the EIS into question.
• The proposal places all affordable housing in one building on a separate strata plan, but uses affordable housing to justify a height on a completely different strata development
• Waste Management, as proposed, is fundamentally flawed.
• Restricted height access together with waste collection realities are likely to materially impact pedestrians and traffic on Rangers Avenue.
• Vibration Risk Assessment is Inadequate
• The Traffic Study is not fit for purpose
• Defects of Survey submitted as part of the EIS
• Inadequate Visitor & Neighbour Parking Provision
• Affordable Housing deficiencies

Substantial Overshadowing of my property would result from approval of this proposal.

The front setback should align with current setbacks on 9 & 9A in the minimum.

The proposed development has, nearest to my property, a front street setback of three (3) metres. I contend the streetscape should have continuity with existing street setbacks that apply to both 9 and 9A Rangers Avenue, Mosman at the Eastern end of the development. Both 9 and 9A Rangers align such that the front wall (including covered verandahs) are in a straight line. This setback of 9 & 9A Rangers from the front boundary, calculated on the basis above, is approximately four (4) metres. This again impacts reasonable development potential and creates site isolation.

The proposed setback to Bloxsome Lane at the rear is around 6 metres. The eastern boundary is only 28.83 metres long and the rear setback to the lane is double the front setback.

The information presented in the EIS and various supporting documents is contradictory. In some it alleges a front setback of 3 metres in others 3.5 metres is proffered. I suspect the difference arises because in some calculations a solid nib at the south eastern corner is included and in others it is not. This nib would likely be around 500mm square and extends the entire length of the building height. As such, its nearest point of projection to the front boundary should define the front setback.
The alleged side setback is not to the nearest point of projection of the actual building. The building is curved and the 3 metre measurement is taken from the furthest projection of the eastern wall not the closest. Clearly, the closest point of projection of the eastern wall to the boundary should be the relevant calculation. In any event, the side setbacks need to be considered in the context of Karavellas outlined above.

The assertion of Deep Soil in the north eastern corner of the proposed development is nonsense. The sandstone ledge at the is, at best, RL 51. 13. Elsewhere in the EIS document there is a proposal for “planter boxes” that would house a 15 metre tall tree. Such a tree would present a substantial hazard to my garage in the event it became dislodged during an extreme weather event. Hence this is a reasonably foreseeable safety risk and should be assessed accordingly.

The lift well located adjacent to the common boundary with the development further restricts future development potential as outlined above.
The Wall height variation sought should be rejected. The alleged “Ground Level” at the eastern end of the development is actually Level 1 for reasons explained above. Therefore, the building at the eastern projection is actually 8 storeys high. The step back does not occur after the 4th storey, as required, but after the 7th storey.

This EIS, in its current form, should neither have been submitted nor exhibited. The exhibition period of fourteen (14) days that ends eight (8) days before Christmas calls into question the procedural fairness of the process.

To Whom It May Concern,
Attached please find my objection letter opposing SSD 96272465 and labeled:
BHolt SSD-96272465 objection.pdf
In addition to my submission, you will also find the following attachments:
APPENDIX A: McLaren Traffic Engineering Letter of Advice 16 Dec2025 (F).pdf
APPENDIX B: Spofforth St Accident Report.pdf
APPENDIX C: 11-23 Rangers Avenue-Mosman Survey Report Dec42025.pdf
APPENDIX D: Objection Submission to SSD 96272465.pdf

Please confirm receipt of all documents listed above.

Kind regards