A 45 storey building is almost double the current height of permitted building at 90m and will mean that there will be no sunlight for the properties across from this address (especially as Archer St is not that wide) and a building of 154m will almost overshadow all properties facing it. Traffic and human traffic will also become even more problematic than is it today as Archer Street is already a main street close to Chatswood Chase; and I strongly believe that keeping to the existing maximum height of 90m will ensure the current 'homey/residential' vibe of this side of Chatswood (buildings of this type of requested height can continue to be built closer to the station side for those individuals who would like to opt for high rise living.
I have no ojections to growing and further developing Chatswood, however I strongly feel that maintaining the current height of buildings (e.g. to 10-15 storey mixed use sites) will give Chatswood a refreshed vibe whilst maintaining a good mix of residential/commercial vibe.
Also, more taller high rises puts pressure on the current overcrowdedness on weekdays especially weekends with people from all over Sydney; as well as consideration to be put on the ratio of parks, child care, schools and other infrastructure/amenities. Whilst Chatswood may be a hub, I would really like it to continue to keep its name as a good local neighbourhood for families to raise future generations; and with more and more higher rises coming in, the locals vibe is being diminished.

I support the project, I believe it will significantly improve housing affordability and availability in the area.

I would however like to see the number of units and storeys significantly increased as well as units set aside for essential workers.

Chatswood is already highly developed. In the past, the high risers are on the other side of station and residents around here can enjoy a relatively quiet suburb. The driving time it takes From Mandarin Centre to Pacific Highway is 15 mins every morning already. How will adding another high rise building help with the congestion?

I strongly object to the proposed residential development at 51, 53, 53A and 55 Archer Street, Chatswood (SSD-94409457).

I am a resident of a neighbouring property and I am seriously concerned about the scale and height of the proposed development and the significant impact it may have on surrounding residents.

My main concern is the loss of sunlight and solar access. A development of this scale and height may cause substantial overshadowing of neighbouring residential properties, including my home. This could significantly reduce natural sunlight to our living areas, windows and private open spaces, particularly during winter when sunlight is already limited.

I am also concerned about the visual impact and loss of privacy caused by such a large residential building being located close to existing homes. The height and bulk of the proposed development may result in overlooking into neighbouring apartments and create an unreasonable sense of enclosure.

In addition, a development of this size may substantially increase traffic, parking demand, noise and construction impacts in the surrounding residential area.

As a directly affected neighbouring resident, I request that the Department carefully assess the overshadowing and solar-access impacts on my property, including the cumulative impact of the proposed building height and bulk. I also request that the applicant provide detailed shadow diagrams demonstrating the impact on neighbouring properties during different times of the day, particularly around the winter solstice.

I therefore object to the development in its current form and request that the proposed height, scale and building envelope be reconsidered and substantially reduced to minimise the impacts on neighbouring residents.

Thank you for considering my submission.

I have received notification about the development of 55 Archer Street, Chatswood. I live in the residential block south of this proposal. It is so bizarre that the council has allowed this block to be rezoned for development of this scale. The east side of Archer Street from Albert to Mowbray has been always low rise and residential. The fact that development of this scale has been approved will change the whole character of the east side of Chatswood. These monoliths will take away any privacy of our homes from Archer to probably Penshurst Street. Shadowing will affect properties east, south and west at different times through the day. Our property values will decrease significantly. The amount of development from Pacific Highway to the railway line has created a wind tunnel and shade and now this will be our future too. The traffic in Chatswood is already unmanageable, and the local schools are overflowing and have no green spaces anymore. There are already so many towers planned in Chatswood that development of this scale in the rezoned block between Albert and Johnson Street is showing the residents how greedy the council and state governments are. To say they are providing affordable housing is a joke and just a way to increase the capacity of these eyesores. The price of these units is in no way affordable. We all know who will be buying the apartments in these buildings, and we know they will sit empty like so many properties in Chatswood. Why is it that in other areas they aren't building 45 storey towers in residential streets which are hideous, and you are in our street. Just because you can, doesn't mean you should!

My objections are based on the following concerns:

Excessive Building Height and Visual Impact:
The proposed building is significantly taller than the surrounding structures, which are predominantly no more than 8 storeys in height. A 45-storey development would be entirely out of scale with the existing neighbourhood character and would disrupt the visual harmony of the area. I would be more supportive of the project if the height were reduced to a more appropriate scale—ideally in the range of 8 to 10 storeys—to better align with the surrounding built environment.

Traffic and Parking Impacts:
The development includes 114 residential units and large number of car parking spaces, which will substantially increase traffic volume in an already congested area. This is particularly concerning during weekends and public holidays, when traffic is at its peak. The additional pressure on local roads and infrastructure could negatively impact the quality of life for existing residents and exacerbate current traffic issues.

The scale and density of this development is really the bare minimum required around Sydney’s major transport nodes like Chatswood. We have run out of land to expand the city and must go up. Chatswood has great amenities and this building will have great views for future residents.

I object to the proposal and do not support rezoning of the site to allow for height for 45 levels on the basis that:
1. NOT PERMISSIBLE UNDER CURRENT CONTROLS. The proposal does not use a clause 4.6 variation; it seeks a concurrent rezoning to rewrite the controls so it becomes permissible. Under existing WLEP 2012 a residential flat building is not a permitted use here; the height limit is 90m (this is a 45-storey tower); FSR is 5:1 (proposal 8.45:1, ~69% uplift). [EIS Table 12; §5.2; Notice of Exhibition.] The scale of this departure is itself a reason to refuse, and it means many EIS "compliance" claims are compliance with the proposed, not existing, controls.

2. OVERSHADOWING / SOLAR. The EIS assesses only clause 6.15(3) (3 hours winter sun to South Chatswood Conservation Area dwellings) and then asserts "no unreasonable" impact because shadows are "fast moving." [EIS §8.4.1.] There is NO receiver-specific shadow analysis of the dwellings opposite, including mine — no figure for the winter sunlight I have now or would retain. The solar percentages (79% of units) measure the proposal's OWN apartments (ADG Part 4A), not neighbours. [EIS §8.3.2.] Impact: loss of winter sunlight to my living areas and open space, loss of daylight, and reduced rooftop solar generation (a direct financial loss). I ask for refusal. I do not assert the hours lost; the missing figure is the ground. Therefore this EIS impact assessment is incomplete and proposal should be rejected on those grounds.

3. NOISE. The Noise & Vibration Assessment is, on the EIS's own words, "preliminary." It protects the new apartments from outside noise (façade glazing) rather than assessing noise from the development onto neighbours; operational plant noise is deferred because "specific mechanical equipment has not been selected"; and the baseline survey (5–15 Dec 2025) was taken while the adjacent 57–61 Archer St site was under construction. [EIS §8.8.1–8.8.3.] Approving before operational noise is assessed is contrary to s4.15(1)(b).

4. PRIVACY / SETBACKS. ADG building separation is NOT met on the north and south interfaces — 3–6m provided against a 9m/4.5m requirement — "fixed" with louvres and screening, with no window-to-window privacy analysis. [EIS Table 18; §8.3.1.] The onus to justify the departure is the applicant's and is not discharged.

TREES. Removal of all 16 site trees and 4 public street trees, offset only by container planting. [EIS §4.8; §8.12.2.] Established canopy and public street trees are not immediately replaced.

8. ADG DESIGN QUALITY. Communal open space sunlight meets the 50% criterion exactly (no margin); deep soil sits at the 7% minimum; cross-ventilation is stated as "42 of 57 units" for a 114-unit building — unverifiable. [EIS §8.3.6; §8.3.7; §8.3.5.] On inconsistent or bare-minimum figures the authority cannot be satisfied the design-quality principles are met.

9. VIEW LOSS. The view analysis assessed only 57–61 Archer St and 34 Albert Ave; dwellings opposite were not assessed at all. [EIS §8.5.] The assessment is incomplete as to affected receivers. I do not assert my view loss quantum, as it was not analysed.

10. PROCEDURE. Pre-exhibition engagement was mostly "inform/consult" (a ~100-person phone survey, an email address, a flyer). [EIS §7.2; §7.4.] I ask DPHI to confirm on the record that the exhibition met the statutory minimum period and that directly-opposite owners like me were adequately notified — not only the adjoining sites. I do NOT allege the EIS is deliberately false; I have no evidence of intent. But its core figures (height stated as RL 242.6m / RL 241.3m / 154.15m / 152.85m; units 114 vs 57) are internally inconsistent, so the authority does not have reliable information and should require correction and re-exhibition, and must genuinely consider all valid submissions (s4.15(1)(d)).

11. An inconsistency in the exhibited maximum height (raised as a reliability issue, not as proof of a height).
The maximum height of the building is stated in at least four different ways across the exhibited documents: RL 242.6m AHD (EIS Executive Summary and Table 12); RL 241.3m AHD (EIS §5.2.2); 154.15m (Notice of Exhibition); and a “proposed height of 152.85m” used within the setback calculation (EIS §8.3.1). [Cross-ref: EIS Exec Summary; EIS §5.2.2; EIS §8.3.1; Notice of Exhibition.] I do not assert which figure is correct — I cannot, from the exhibited material. My point is procedural: a member of the public reading the exhibited documents cannot reliably ascertain how tall the building they are being asked to comment on will actually be. That undermines the integrity of the exhibition and should be resolved on the public record before determination.

I object to SSD-94409457 and request refusal of the application and concurrent rezoning.

The proposal seeks a 45-storey residential tower at a sensitive interface with the South Chatswood Heritage Conservation Area. The exhibited material does not demonstrate that the impacts on neighbouring residents, local amenity, heritage character or the public interest are acceptable.

1. Excessive scale and inadequate transition

The issue is not whether higher-density development is appropriate generally in Chatswood, but whether a 45-storey building with an FSR of 8.45:1 is appropriate at this specific location, about 35 metres from the South Chatswood Heritage Conservation Area.

The EIS identifies nearby towers of 32, 28 and 26 storeys. This proposal would nevertheless exceed them in both height and density. The existence of other towers does not establish that a further, substantially taller building provides an acceptable transition to adjoining low-rise and heritage development. It instead makes cumulative effects and a coherent transition more important.

The exhibited material does not demonstrate an acceptable transition in height, bulk, setbacks or built-form character. [EIS sections 2.9 and 8.15; Table 12.]

2. Major departure from current controls

The proposal cannot proceed under the planning controls currently applying to the site. It depends on a concurrent amendment to Willoughby LEP 2012 to permit residential flat buildings, increase the height limit from 90 metres, and increase the FSR from 5:1 to 8.45:1. [EIS Table 12; section 5.2; Notice of Exhibition.]

This is not a minor variation. It is a substantial rewriting of the current planning framework, involving an FSR increase of approximately 69 percent. Statements in the EIS that the proposal “complies” with relevant standards often depend upon the controls the applicant seeks to introduce, rather than the controls currently applicable to the site.

The applicant has not demonstrated why this exceptional height and density are justified at a low-rise heritage interface, or why the resulting impacts should be accepted.

3. Inconsistent core information

The exhibited documents give conflicting information about the building height: RL 242.6m AHD, RL 241.3m AHD, 154.15m and 152.85m. [EIS Executive Summary; Table 12; sections 5.2.2 and 8.3.1; Notice of Exhibition.]

They also describe both 114 dwellings and “42 out of 57 units”. [EIS sections 8.3.2, 8.3.5 and 8.7; Notice of Exhibition.]

These are material discrepancies. Final height and dwelling yield affect assessment of built form, traffic, parking, ventilation, solar access, waste, servicing and residential amenity. The authority should not approve a development where core parameters remain unclear and the public cannot determine precisely what is being assessed.

4. Inadequate assessment of overshadowing

The EIS appears to assess overshadowing primarily against clause 6.15(3), concerning three hours of winter sunlight to dwellings within the conservation area, before concluding that impacts are acceptable because shadows are “fast moving”. [EIS section 8.4.1.]

That does not demonstrate effects on individual nearby dwellings, gardens and private open spaces. The exhibited material does not provide receiver-specific, hour-by-hour winter analysis of sunlight retained by affected neighbours. Solar-access figures for apartments within the proposal do not address sunlight lost by existing residents.

A general statement that shadows are “fast moving” is insufficient for a 45-storey tower. The EIS does not establish that solar access, daylight and residential amenity impacts on neighbouring dwellings would be acceptable.

5. Privacy and building separation

The EIS identifies that Apartment Design Guide separation criteria are not met on several interfaces. Setbacks of 3–6 metres are proposed where 9 metres for habitable rooms and 4.5 metres for non-habitable rooms are identified. [EIS section 8.3.1; Table 18.]

The response relies on louvres and screening. This does not demonstrate that overlooking and privacy effects on neighbouring dwellings and private open spaces will be acceptable, particularly given the proposed building’s height and proximity. The exhibited material does not provide adequate assessment of relevant sightlines or the effectiveness of screening.

6. Noise, excavation and construction impacts

The Noise and Vibration Assessment is described as preliminary. Specific mechanical equipment has not been selected, so impacts from plant, ventilation, loading, waste collection, vehicle movements and servicing have not been assessed on a final, site-specific basis. [EIS sections 8.8.1–8.8.3.] The baseline survey was also undertaken while construction was occurring at the adjoining 57–61 Archer Street site.

The proposal includes six basement levels and excavation of approximately 17–19.3 metres, including rock excavation near Sydney Water infrastructure. [EIS sections 8.8.2 and 8.10.1.] Vibration, structural protection and construction controls are deferred to future management plans. The EIS does not establish that excavation, rock breaking, vibration, settlement, heavy vehicles and prolonged construction impacts on nearby residents would be acceptable.

7. Traffic, servicing and cumulative impacts

The parking assessment relies on an unresolved dwelling count. The EIS identifies approximately 19 additional AM-peak vehicle trips per hour and construction use of kerbside works-zone spaces on Archer Street. [EIS sections 8.7.2–8.7.3; Appendix Z.] The permanent loading dock accommodates a truck of approximately 6.4 metres. [EIS section 8.7.4.]

These impacts must be assessed cumulatively with nearby 26-, 28- and 32-storey development, rather than in isolation. The EIS does not adequately address combined effects on traffic, kerbside parking, servicing, construction disruption, privacy, solar access, wind, local character and the heritage interface.

8. Loss of tree canopy

The proposal removes all 16 trees on the site and four public street trees. [EIS sections 4.8 and 8.12.2.] Replacement planting cannot replicate the immediate canopy, shade, habitat, streetscape value and amenity provided by established trees. The EIS does not demonstrate that this loss is justified.

Refusal sought

For these reasons, I request that the consent authority refuse SSD-94409457 and the associated concurrent rezoning proposal.

The applicant has not demonstrated that this exceptional uplift in height and density, or its resulting impacts on built-form transition, sunlight, privacy, noise, excavation, traffic, servicing, trees and cumulative amenity, would be acceptable.

The inconsistent height and dwelling-yield information further prevents a reliable assessment. The consent authority cannot be satisfied that the proposal is appropriate having regard to section 4.15 of the Environmental Planning and Assessment Act 1979, and it should be refused.

As a resident who will be significantly and directly impacted by the proposed development (which is within meters of the proposed development), I strongly object to the proposed development and/or SSD-94409457 and request that the consent authority refuse the application and do not rezone the proposed site to the proposed building height level for following reasons.
This objection is made under the Environmental Planning and Assessment Act 1979 (EP&A Act) and the Environmental Planning and Assessment Regulation 2021 (EP&A Regulation). Under section 4.15(1) of the EP&A Act (applied to State significant development through section 4.40 and the assessment process under Division 4.7), the consent authority must consider the likely impacts of the development on the built and natural environment and on the locality, the suitability of the site, any submissions made, and the public interest. The grounds below go directly to those mandatory considerations.

A. Inadequate impact assessments in the EIS
A1. Overshadowing and loss of solar access to properties on Bertram St
The EIS overshadowing assessment (§8.4.1) addresses one control only: clause 6.15(3) of WLEP 2012, which prohibits consent where a dwelling in the South Chatswood Conservation Area would receive less than 3 hours of winter sunlight. The EIS concludes only that the proposal complies with that specific clause and asserts, in general terms, that the tower “will not result in any unreasonable overshadowing impacts to existing development.”
The assessment is deficient and incomplete as:
-No property-specific analysis of surrounding dwellings on Bertram St which will be most significantly impacted. The EIS does not identify properties on Bertram (or other dwellings on the opposite side of Archer Street) as a receiver, does not state how many hours of winter sunlight my property currently receives, and does not state how many hours it would retain after construction. The conclusion of “no unreasonable” impact is therefore an assertion unsupported by any receiver-specific measurement in the exhibited text.
-The solar figures in the EIS measure the wrong thing. The solar access figures at §8.3.2 (79% of apartments receiving 2 hours; 6 apartments receiving none) measure sunlight to the proposal’s own apartments under Part 4A of the ADG. They say nothing about sunlight lost by existing neighbouring dwellings. [Cross-ref: EIS §8.3.2 “Solar and Daylight Access”.]
-A 45-storey tower of this height casts a materially longer shadow than the conservation-area test alone captures. The EIS itself describes the shadow as arising from a tower on a podium and relies on the shadow being “fast moving” to characterise it as acceptable — but “fast moving” is a qualitative descriptor, not a measured retained-sunlight figure for my dwelling.
Impact on residents in Bertram St, including those directly opposite the proposed site: loss of direct winter sunlight to my property’s dwelling (and other Bertram St residents’) living areas and private open space, loss of daylight amenity and roof-mounted solar panels — a reduction in solar generation and therefore a direct financial loss. Because the EIS does not quantify the shadow on my property, the consent authority cannot be satisfied under s4.15(1)(b) that the solar impact is acceptable. I request that refusal follow.

A.2 Acoustic and noise pollution
Impact on me and ground for refusal: traffic noise, construction noise, and future operational plant noise directed at dwellings on Bertram St have not been finally assessed or mitigated on the exhibited material. Deferring operational noise assessment to a later plan means the consent authority is asked to approve the development before the operational noise impact is known, which is inconsistent with the s4.15(1)(b) obligation to consider likely impacts before consent.
A.3 Overlooking and privacy
The EIS setback table (Table 18, §8.3.1) discloses that the ADG separation criteria are not met on several interfaces. Against a 9m habitable / 4.5m non-habitable requirement, the proposal provides only 3–6m on the north and south interfaces, relying on “window louvres” and “screening” to “direct views away from neighbouring development.” [Cross-ref: EIS Table 18 “Required DCP and proposed setbacks”, north and south rows, p.75.]
The concern is that reduced separation with a screening “fix” is a design response to a shortfall, not evidence that privacy is preserved. The EIS does not demonstrate the visual-privacy outcome for specific opposing windows or yards. The onus is on the applicant to justify the departure from the ADG separation criteria; a general statement that louvres redirect views does not discharge it.
A.4 Traffic and parking
The parking assessment (EIS §8.7, Tables 19–20; Appendix F) contains internal figures that do not reconcile and warrant scrutiny before any approval:
• The dwelling yield used across the tables is inconsistent — the parking table breaks down units to a total that must be tested against the 114-unit figure used elsewhere in the same EIS, and against a 57-unit figure appearing in the natural-ventilation section (§8.3.5). The consent authority cannot verify the parking calculation while the underlying unit count is stated inconsistently in the exhibited document.[Cross-ref: EIS §8.7 Tables 19–20 vs §8.3.5 (“42 out of 57 units”) vs Notice of Exhibition (“114 units”).]
• The parking provision relies entirely on the minimum rates in s22A of the Housing SEPP (as amended 24 April 2026) being the applicable standard. If that characterisation is wrong, the provision (136 spaces) may be assessed against a different requirement. The applicant should be put to proof that Chapter 2 Part 2 Division 1 applies. [Cross-ref: EIS §8.7 opening paragraphs; Table 19.]
Parking is under-provided relative to actual demand, overflow parking and additional vehicle movements which will affect the amenity and safety of Archer Street, the general public, pedestrians and residents.
Ground B — Non-compliance with planning controls
B.1 The proposal does not comply with current WLEP 2012 controls; it depends on a concurrent rezoning
The proposal does not seek a clause 4.6 variation to the existing standards. Instead, it depends on a concurrent rezoning to change the WLEP 2012 controls in its favour. the development is not permissible under the controls that currently apply. Under existing WLEP 2012, a residential flat building is not a permitted use on the site, the height limit is 90m (the proposal is a 45-storey tower far exceeding this), and the FSR limit is 5:1 (the proposal seeks 8.45:1 — roughly a 69% uplift). The proposal can only proceed if the consent authority first accepts a rezoning that rewrites every relevant control. I object to that rezoning and submit that the scale of the departure from the current controls is itself a reason to refuse.
Inconsistency in the exhibited height figure (I raise this as a reliability issue, not as proof of a particular height): the maximum height is stated four different ways across the exhibited documents — RL 242.6m AHD (EIS Executive Summary and Table 12), RL 241.3m AHD (EIS §5.2.2), 154.15m (Notice of Exhibition), and a “proposed height of 152.85m” used in the setback calculation (EIS §8.3.1). [Cross-ref: EIS Exec Summary; EIS §5.2.2; EIS §8.3.1; Notice of Exhibition.] I do not assert which figure is correct. My point is that a community member reading the exhibited material cannot ascertain the actual maximum height of the building they are being asked to comment on, which undermines the integrity of the exhibition.
B.2 SEPP 65 / Housing SEPP and the Apartment Design Guide (ADG)
The EIS discloses several ADG design-criteria outcomes that are met only marginally or by variation, and at least one internal inconsistency that prevents verification:• Communal open space — the “50% direct sunlight” criterion (Part 3D) is met at exactly the 50% threshold on the EIS’s own figures (“50% (58sqm) of the principal usable part… receiving 2 hours”), i.e. no margin.• Setbacks/building separation (Part 3F) are varied on multiple interfaces (see A.3 above), which is a departure from ADG criteria that the EIS resolves by asserting the “overarching guidelines” are met rather than the numeric criteria. • Cross-ventilation (Part 4B) is stated as “74% of units (42 out of 57 units)” — but the development is described elsewhere as 114 units. The 57-unit denominator cannot be reconciled with the 114-unit project on the exhibited material, so the stated 74% compliance cannot be verified. Where an EIS relies on ADG criteria being met but the supporting figures are internally inconsistent or sit exactly on the minimum, the consent authority cannot be satisfied that the design-quality principles are achieved. Under the Housing SEPP design-quality framework the onus is on the applicant to justify any departure; unresolved inconsistencies are a proper basis for refusal or, at least, for requiring corrected documentation to be re-exhibited.

The Visual and View Impact Analysis (Appendix Y; EIS §8.5) assessed view impact only for two neighbouring properties — 57–61 Archer Street and 34 Albert Avenue — and concluded a “minor” impact for those & those on bertram aren't assessed.
There's been inadequate consultation with local residents in bertram receiving no communications from developer about development.

I submit the consent authority should REFUSE application for this development, and refuse the concurrent rezoning proposal, on the grounds that the development is not permissible under the current WLEP 2012 controls and the exhibited EIS does not demonstrate acceptable impacts under s4.15(1) of the EP&A Act.