I write to formally submit concerns and comments regarding the proposed development at 16 - 20 Middle Harbour Road, Lindfield, in the context of broader planning considerations affecting the surrounding precinct.

1. Need for Strategic Coordination with 15–27 Russell Avenue & 54-50 Trafalgar Avenue, Lindfield
The proposed development at Middle Harbour Road must be considered in parallel with the potential future development of 15–27 Russell Avenue & 54-50 Trafalgar Avenue. This site encompasses a large, contiguous landholding which is currently under review for significant redevelopment potential, including the proactive heritage delisting of 19 Russell Avenue. This step is being undertaken specifically to enable the parcel’s integration into a cohesive TOD (Transport Oriented Development) project in alignment with the State’s strategic housing objectives.

2.Built Form Interface
The proposed development at Middle Harbour Road must be assessed in the context of the anticipated higher-density development of 15–27 Russell Avenue & 54-50 Trafalgar Avenue. The Russell Avenue site is expected to support a greater building height and residential yield, consistent with the principles of the TOD SEPP and its proximity to key transport infrastructure.
It is critical that approval of the Middle Harbour Road development does not pre-emptively constrain the future development potential of 15–27 Russell Avenue & 54-50 Trafalgar Avenue —particularly through built form transitions that may later be used to justify a reduction in permitted height or floor count on the Russell Avenue site.

To meet the State Government’s strategic housing and urban consolidation goals, 15–27 Russell Avenue & 54-50 Trafalgar Avenue must be allowed to achieve its maximum feasible height and density and should not be penalised by the timing or design of adjacent developments approved without reference to its future potential.
 

Submission with comments attached as Word document

• Its a 10storey building with excessive bulk and size.
• With another SSD for 24-28 Middle Harbour Road, it will completely isolate the single storey dwelling at number 22 MHR.
• It does not meet the required setbacks
• It has 4 areas of communal space on the roof that will generate excessive noise
• There are numerous inaccuracies and inconsistent data in the Environment Impact Statement.
• The 10 storey development will have an unacceptable impact on neighbouring properties.
• It does not fulfill the objective of the TOD controls in Chapter 5 of the Housing SEPP which is to ensure development is of an appropriate bulk and scale.
• The building design includes a long 41m façade of 10 storeys to Middle Harbour Road without any open central space to visually reduce its bulk in the context of the existing streetscape.
• The habitat of the endangered species Large-eared Pied Bat (Chalinolobus dwyeri) is cited as using this site.
• The development site is over 550 metres walking distance from Lindfield Station. At 31m this is higher than Council’s Preferred scenario limits for this site.
• The site is part of the overflow from the Highway ridgeline into Gordon Creek and then Middle Harbour. The 15 m excavation will disturb and alter the flow of water increasing the flooding in an existing flood prone area.
• More than half the existing trees will be removed.
• The proposal does not provide sufficient details of the affordable housing it includes and guarantees that it will always stay affordable housing in an affluent area.

refer to attachment.

Please see the attached submission objecting to the project

I believe the council's alternative plan for the TOD program should be accepted by the state governemnt. The proposal for this large development in Middle Harbour Road has not been considered in the context of the area and other properties surrounding it. Those properties adjacent to the property will be completely over whelmed by the sheer size of this property. The council's alternate plan has been well thought out and delivers more dwellings in a way that is sympathic to the unique environment of Ku-Ring-Gai. Large blocks of units have been put on the west of the highway where the natural slope of the land can be used for better views, light and ventilation (ie more energy efficient). This has been done well in Gordon. Areas of historical significance on the east side can be maintained.