Submission on SSD 83431958

As an owner/occupier for the last 24 years of a property on Middle Harbour Road, approximately 270 metres from the proposed development site, I recognise the need for more housing in the Lindfield area. That being said, I object to the proposed development in its current form for the following reasons:

Lack of Engagement:
The Proponents have neither consulted with Council nor carried out engagement with the local community other than “informal discussions as required” with neighbouring landowners, mostly about potential site amalgamation. Rather, they rely on the promise of “continued engagement” post-lodgement, with a proposed mail-out covering only the block bordered by Middle Harbour Road, Trafalgar Avenue, Russell Avenue and Lindfield Avenue, and the South side yof Middle Harbour Road between Trafalgar Avenue and Lindfield Avenue. Given that these properties are within the TOD zone, and that most of them are the subject of current or proposed future development applications, this lack of community engagement has limited the number of existing residents likely to continue living in the area who have been made aware of the proposed development in time to submit an objection. This is unacceptable.

Overshadowing:
The proposed development will cause overshadowing of properties including 14 Middle Harbour Road and properties on the Southern side of Middle Harbour Road (which are not the subject of development applications) for significant portions of the day.

Failure to consider cumulative impact on traffic and parking:
The proposed development is one of four current proposals on Middle Harbour Road between Lindfield Avenue and Trafalgar Avenue. This section of Middle Harbour Road is used daily as parking by commuters using Lindfield Station. The Traffic and Parking Assessment Report fails to consider the cumulative impact of all proposed development on traffic and parking, especially during construction, when delivery trucks will be blocking the road, while vehicles belonging to demolition and construction workers will be occupying the parking spaces currently used by commuters.

Removal of trees:
The Proposal includes the removal of 29 trees from the site, including one 18 metre tall, high-retention value, Turpentine tree in the centre of the site, with a large root system and 16 metre crown spread, which is in good health. The proposed removal of this tree in the interests of being able to develop is justified on the basis that it is isolated from other Turpentines or large trees and does not contribute to the streetscape due to its location, it is not an attractive tree, and the proponent cannot keep this tree and get an economical basement car park layout or efficient apartment layout. This tree can be seen from both Middle Harbour Road and Russell Avenue, as well as the Lindfield Tennis Club, and is not unattractive, and there is little evidence that the proponents have made any attempt to achieve a design which would retain this tree. Further, only 20 existing trees are proposed to be retained. The proposed planned Tree Canopy Coverage of 42.6% is unlikely to be achieved, as it includes roof gardens and communal open spaces without deep soil to support large canopy trees. In any event, it will take years for proposed new plantings to grow sufficiently to replace the canopy destroyed by the removal of the Turpentine and other trees.

Insufficient Deep Soil Zone:
The EIS argues that as Council’s Alternate TOD Scenario does not apply, there is no requirement for the Deep Soil Zone to occupy 50% of the site area, and that in fact the 50% requirement would significantly limit development of the site. The size of the Deep Soil Zone is limited by the size of the Basement levels below. While the EIS emphasises that the “landscaped area” is 30.2%, this includes communal open space and rooftop terraces with no deep soil. The EIS does not quantify the Deep Soil Zone. The Architectural Plans and Design Report show a proposed Deep Soil Zone of 24.6% (939sqm). However, the Additional Landscape Report and Crime Prevention Report show Deep Soil at only 884sqm, while the Design Statement says the proposal has provided only 821sqm (21.5%). This inconsistency needs to be resolved. Even at 24.6%, the proposed Deep Soil Zone will be inconsistent with the future character of the area which is highly likely to be 50% under Council’s Alternate TOD.

Inadequate Biodiversity Report:
The BDAR reaches the conclusion that the area of biodiversity on the site is highly degraded Blue Gum High Forest, and that the only significant species present is the Large-eared Pied Bat. This appears to be inconsistent with almost every other BDAR written for proposed development sites in or near Middle Harbour Road which conclude the area is Sydney Turpentine Ironbark Forest. In addition, the report makes no mention of the catchment which flows east from 32 Middle Harbour Road, a mere 200 metres from the proposed development site, into Gordon Creek, or to any of the flora and fauna contained in the Riparian zone associated with this creek which may be affected by the proposed development, as stormwater flows from the proposed development site into the catchment.

Insufficient Assessment of Environmental Heritage:
The Statement of Heritage Impact is based on aerial photographs and views of the proposed development site from the public domain only. It recognises that issues that may be raised by the community during the “ongoing consultation process” are a Key Uncertainty. Given these limitations and uncertainty, the conclusion that the proposed development will have no significant impacts on Heritage Items at 9 Middle Harbour Road and 19 Russell Avenue cannot be relied upon.

Isolation of 22 Middle Harbour Road:
The EIS argues that the isolation of 22 Middle Harbour Road between the proposed development and the site at 24-28 Middle Harbour Road is acceptable, as 22 Middle Harbour Road is capable of being developed on its own. It ignores the fact that if not developed, 22 Middle Harbour Road will be significantly impacted in terms of lack of privacy, overshadowing, view loss and increased stormwater flowing into it.

I object to SSD-83431958 at 16–20 Middle Harbour Road, Lindfield. The proposal has been designed on the assumption that surrounding sites, particularly along Russell Avenue, will remain low scale, which risks unfairly constraining their future redevelopment potential. At nine storeys and nearly 100 units, the building represents overdevelopment, with bulk and density out of character for the area. The widened solar access assessment window masks overshadowing impacts, and the proposal will generate significant traffic and strain on local infrastructure. This application undermines coordinated precinct planning and should not be approved in its current form.

As per correspondence dated 31/10/2025 by NSW EPA (see attached)

Please refer to the attached documents.