To whom it may concern
I wish to express my opposition to the proposed development at 142-150 Narrow Neck Road, Katoomba and also the use of the Housing Delivery Authority (HAD) pathway in the Blue Mountains.
I moved to the Blue Mountains 13 years ago to enjoy a quiet retirement. I live opposite the creek which runs from the Gully to Katoomba Falls and look across the creek to the escarpment at Narrow Neck Road. This view is dominated by trees and is very restful.
I am opposing this proposal for the following reasons.
1. The escarpment at Narrow Neck Road will be spoilt by the erection of high rise buildings which are not in keeping with the vista expected in the Blue Mountains. The view from Echo Point to the west will be dominated by the proposed development.

2. The proposed development appears to be partially a tourist facility with serviced apartments and a Wellness Centre and restaurant. I do not understand how this facility can be regarded as a housing development under the Housing Delivery Authority pathway.

3. The development site is currently zoned R3 Medium Density. The proposed rezoning of the site and the size of the proposed development are in opposition to the Blue Mountains Local Environment Plan (LEP). The LEP represents years of expert planning and community consultation and is tailored to the Blue Mountains unique environmental context.

4. The site is adjacent to the Blue Mountains Swamps. These swamps feed the Katoomba Falls catchment. The increased surfaces would change water flow to the swamps, increase stormwater velocity and damage the swamp ecology.

5. The site is surrounded by bushfire prone land with limited evacuation routes. Adding hundreds of new residents would increase risk to life and hamper emergency response.

6. There is limited public transport to this area therefore the development would add several hundred vehicles to narrow local roads. The proposed development is two kilometres from local shops and rail transport in Katoomba.

7. There are limited health facilities in Katoomba. There are no specialists and all residents must travel to Penrith for specialist care. Increasing the population by several hundred residents will put a huge strain on the existing medical facilities and also increase traffic on the Highway with more people travelling to Penrith for care.

8. The proposed development threatens the unique character of Katoomba and surrounding visitor destinations.
Due to the unique site of Katoomba in a National Park the proposed development would adversely affect the areas character.
Katoomba is not suburb of Sydney and as such I believe should be exempt from the HDA pathway.
I understand the local member has previously written to the minister requesting this exemption and opposition to the proposed development. I trust you will consider this letter in opposition to the proposed development.

As a resident of Katoomba for over 20 years and having been employed in the Tourism industry for most of that time, I strongly oppose the Development proposal for 9 four storey buildings at 142 – 150 Narrowneck road.
The Blue Mountains is a unique wilderness area and the townships within that area have their own charm. The dramatic sandstone cliffs that these townships are perched upon are one of our star attractions. Tourism numbers to the area exceed 4 million visitors each year and the industry and associated businesses employ a vast majority of our population. The Visit NSW website highlights this world famous areas natural beauty.
The NSW governments new Housing Delivery Authority should not be applied to this area as it is distinctly different to any other area in the state. All development needs to be considered carefully and should be limited to constraints such as those set out in our Local Environmental Plan and Development Control Plan. Our local council has worked with the community for many years to protect our environment and foster Tourism in a sustainable manner. To allow building of this scale in an area so close to the escarpment will dramatically affect the natural bushland setting, views from Katoomba township and from Narrowneck plateau.
Additionally, the road access to & from Narrowneck road is in poor condition and not up to the increased traffic movement expected with an additional 800 – 1000 people staying in the area. This zone is also at high risk for bushfire being surrounded by vegetation. It would be irresponsible to significantly increase population in such an area, as it will put lives at risk.
Environmentally, the impact of this project will significantly increase stormwater volumes due to the hard impervious surfaces and roof areas. I doubt our current infrastructure is sufficient to take these volumes. One would imagine the sewerage system would also need to be upgraded. In extreme events any increased overflow would impact nearby swamps which are classified as a threatened ecological community. Further down these riparian corridors flow into the Kedumba river which in turn flows through escarpment into the catchment of Warragamba dam, Sydney’s main water supply. The escarpment ecosystems are also extremely sensitive and part of the reason the area is World Heritage listed.
I fear that if this proposal were to be approved, it would give the green light to other similar development, our Blue Mountains communities would be adversely affected and our surrounding environment would suffer. The fact that lives may be also put at risk should be enough to see merit in stopping this development proposal in its tracks. The Blue Mountains LGA should be excluded from Housing Delivery Authority pathway for development.
Yours sincerely

Guy McIlrath

Sustainable, compliant development is essential to maintaining the environmental integrity, safety, and character of the Blue Mountains. This obligation is heightened where development is proposed under the State Significant Development (SSD) pathway and accompanied by a site-specific rezoning, which together elevate development outcomes beyond standard local planning controls.
This submission objects to the proposed mixed-use development at 142–150 Narrow Neck Road, Katoomba on the basis that:
The application cannot be properly determined under Section 4.15 of the Environmental Planning and Assessment Act 1979 (EP&A Act) due to unresolved and insufficiently demonstrated impacts
There remain material uncertainties and inadequacies relating to:
Land Use and Zoning
Traffic, road network capacity, and public safety
Parking provision and internal/external access
Visual and landscape impacts in a sensitive Blue Mountains setting
Infrastructure capacity and servicing delivery
Geotechnical constraints and landform suitability
Stormwater management
Bushfire evacuation and emergency access
The proposal relies on a site-specific rezoning and SSD pathway that collectively enable development outcomes well beyond current controls without sufficient strategic justification.
The proposal, in its current form, contains unresolved and insufficiently demonstrated impacts and cannot be properly determined. It should be deferred, independently reviewed, and resubmitted following further detailed assessment
Accordingly, the application should be:
Deferred and referred to the Independent Planning Commission (IPC) for independent review, with a requirement to rescope and re-exhibit the proposal following clarification and demonstration of key impacts.
Land Use, Zoning and Strategic Planning Concerns
The site is currently zoned R3 Medium Density Residential. The proposal, however, comprises:
218 residential apartments
52 serviced apartments
Restaurant and public-facing uses
Information and education facilities
While elements of the proposal may be permissible with consent, the combined scale and mix of uses introduce:
A level of intensity beyond typical medium-density residential outcomes
A development profile more consistent with mixed-use or destination-style accommodation rather than local residential infill
The proposal relies on a concurrent rezoning to:
Increase height to 15.6m
Increase FSR to 1.17:1
This represents a substantial uplift from current controls and effectively enables a development outcome that would not otherwise be achievable.
Key Issue
The rezoning appears to be:
Site-specific and development-driven, rather than arising from a broader strategic planning framework
Not clearly supported by demonstrated infrastructure capacity or precinct-wide planning
This raise concerns regarding:
Consistency with the intent of the Blue Mountains LEP 2015
The precedent such uplift may create for similar sites
Traffic, Road Network and Public Safety
Road Network Constraints
The site is accessed via:
Narrow Neck Road (regional road)
Connections to the Great Western Highway
The surrounding road network is characterised by:
Constrained road widths
Limited pedestrian infrastructure
Minimal active transport options
While a Traffic Impact Assessment has been prepared, the EIS does not clearly demonstrate that:
The road network can safely accommodate the combined residential, serviced apartment, and visitor traffic
Intersection performance and peak movements remain within acceptable limits under all operating conditions
Construction Traffic and Safety
The development involves:
Significant excavation
Multi-stage construction
Basement works across multiple buildings
However, there is limited detail at the SSD stage regarding:
Construction traffic volumes
Heavy vehicle routes
Staging impacts on surrounding roads
Given the topographical constraints and residential context, further detailed assessment is required to demonstrate that:
Construction impacts can be safely managed
Public safety risks are minimised
Cumulative Traffic Impacts
The EIS does not clearly articulate:
Cumulative impacts from:
Existing developments within the precinct
Future development enabled by rezoning uplift
This is particularly relevant given:
The scale of the proposal
Limited alternative transport modes
Parking Provision and Access
The proposal includes a combination of:
Residential parking
Serviced apartment parking
Visitor and commercial parking demand
However, the EIS does not clearly demonstrate:
Adequacy of visitor parking provision
How peak demand across different uses will be managed
That parking supply will prevent overflow into surrounding streets
Key Risk
Inadequate parking provision may result in:
On-street parking pressure
Reduced road capacity
Increased safety risks and impacts on emergency access
Visual Impact and Landscape Character
The Blue Mountains landscape is highly sensitive, requiring development to:
Respond to topography
Avoid visual dominance
Maintain consistency with the natural and built character
The proposal introduces:
Multiple four-storey buildings
Significant bulk across a large site area
Assessment Concerns
While a Visual Impact Assessment has been undertaken, it is not clearly demonstrated that:
All relevant viewpoints, including broader landscape perspectives, have been fully considered
The cumulative visual impact of the development mass has been adequately assessed
Key Issue
The proposed height and FSR uplift:
Substantially exceed existing controls
May result in a built form that is visually prominent within the landscape, particularly given the site’s elevated and sloping nature
Geotechnical Constraints and Landform Suitability
The Preliminary Geotechnical Assessment confirms that:
The development will require excavation of up to approximately 9 metres across the site
The investigation is based on limited borehole sampling across a large site area
The report explicitly recommends further geotechnical investigation and monitoring
As stated in the report, additional investigation is required to inform final design parameters and construction methodologies.
Key Issue
This confirms that:
The geotechnical assessment is preliminary in nature
Site suitability for the proposed scale and intensity of development is not fully resolved at the SSD stage
Conclusion
Given the extent of excavation and the complexity of the site, the consent authority cannot be satisfied that:
Ground stability
Excavation impacts
Groundwater interaction
have been sufficiently demonstrated to support determination of the application.
Stormwater Management and Off-Site Impacts
The Services and Infrastructure Report confirm that:
Stormwater from the site will be discharged to existing basins located off-site
New stormwater infrastructure is required, including:
New drainage lines leaving the site
Potential works across adjoining land
The design relies on historical assumptions regarding basin capacity and impervious area
The report indicates that downstream basins were designed to accommodate an assumed 80% impervious area, compared to an estimated ~72% impervious area for the proposed development.
Key Issue
This approach:
Relies on historical design assumptions, rather than clearly demonstrated contemporary modelling
Does not clearly demonstrate that:
Downstream systems can accommodate flows under current conditions
Off-site infrastructure impacts are fully resolved
Conclusion
The stormwater strategy introduces uncertainty regarding:
Downstream flooding and drainage behaviour
Off-site infrastructure requirements
Long-term system performance
Further detailed assessment is required to demonstrate that stormwater impacts are acceptable.
Infrastructure and Servicing
The Services and Infrastructure Report identifies that:
Existing utility services and easements are to be relocated, modified or extinguished
The extent of service realignment and infrastructure works will be further defined at subsequent development stages
Final servicing arrangements are subject to further approvals and detailed design
Specifically:
The report states that service relocations and requirements will be “further identified during subsequent development applications”
Existing drainage easements are proposed to be extinguished and reconfigured
Key Issue
This indicates that:
Critical infrastructure design is not resolved at the time of assessment
The proposal relies on future design development and approvals to confirm feasibility
Conclusion
Without confirmed servicing arrangements, the consent authority cannot be satisfied that:
The development can be adequately serviced
Off-site impacts and works are fully understood
Infrastructure delivery is feasible and coordinated
Vegetation and Site Constraints
The site includes:
Remaining vegetation at the perimeter and internal areas
A 12m vegetation protection covenant along the road boundary
The proposal includes:
Tree removal
Encroachment into parts of the covenant area
Assessment Concerns
While the EIS indicates that development may occur within the covenant area subject to consent, this raises:
Questions regarding the intent and ongoing effectiveness of the vegetation protection measures
The extent to which environmental constraints have influenced site design
Bushfire and Emergency Access
The site is not mapped as bushfire prone land; however:
It is located within a broader landscape where bushfire risk is a relevant consideration
Access is reliant on a limited road network
Assessment Concerns
The EIS does not clearly demonstrate:
Evacuation capacity under emergency conditions
How increased population and traffic demand will affect egress during a bushfire event
Key Issue
Given:
The scale of the development
The constrained access network
further clarity is required to demonstrate that emergency evacuation can be safely managed.
Use of SSD and Rezoning Pathway

I oppose the proposed development at 142-150 Narrow Neck Road, Katoomba. It is a completely inappropriate development for the Blue Mountains, which is a city within a UNESCO-declared World Heritage Area. The size of the proposed development far exceeds anything else in the Blue Mountains, and is completely contrary to our local planning controls.

I have lived in the Blue Mountains for 16 years, and was drawn to this special place due to its incredible beauty and environmental values. The Blue Mountains also has a very strong sense of community, and the towns and villages retain significant charm, character and heritage. The combination of these factors provides a strong sense of place, wholly different from most other parts of Greater Sydney.

I am very concerned that the proposed development will erode this sense of place, by building something that is completely unsympathetic to the character and landscape of the Blue Mountains. The sheer size of this development will make it visible from many other parts of Katoomba and indeed from places within the World Heritage National Park. This style of high-density, multi-story development is incompatible with the character and cultural identity of the Blue Mountains.

I am concerned about the environmental impacts of this proposal. The proposed site is adjacent to a Threatened Ecological Community - the Blue Mountains Swamp - and is likely to have detrimental impacts on downstream communities, which are part of the Sydney Drinking Water Catchment.

I am aware that the site of the proposed development is not currently rated as bushfire prone land, however it is in very close proximity to bushfire prone land, and the threat of bushfire in that part of Katoomba is a hugely significant risk. There are very limited evacuation routes from that area, and adding hundreds of new residents will increase risk to life and likely hamper the emergency response when the next major bushfire occurs. The Blue Mountains is one of the most bushfire prone parts of Australia, so this is not a matter of 'if' but 'when' there is another major bushfire.

I am also very concerned about the HDA pathway process. The fact that a development proposal of this size and significance is on public exhibition for only 14 days is outrageous. This is barely enough time for the community to hear about the proposal, let along study the dozens of documents on exhibition and prepare an informed submission. The fact that the HDA pathway has the potential to override the Blue Mountains LEP, which has been developed and refined in consultation with the community over decades, is deeply concerning. The Blue Mountains is a very unique LGA, particularly due to its extreme bushfire risk and World Heritage environment, and should be exempted from the HDA process.

For the above reasons, I object to the proposed development at 142-150 Narrow Neck Road, Katoomba. Please don't allow such a monstrosity to go ahead.

I am writing to lodge my concerns and opposition to the above Narrow Neck Road Katoomba proposed development.
I have been a resident of the upper Blue Mountains for forty three years now and currently live within sight of the Narrow Neck Road ridge.
Apart from being an eyesore the modelling shows a building completely oversized for this area and also beyond out of character for this part of the Blue Mountains.
We are adjacent to the World Heritage listed area for no small reason. This is not just another suburb of Sydney but visited by millions of people who enjoy its unique natural beauty not insensitive urban sprawl.
Further to the projects size, I understand that it dramatically overreaches the existing height and floor space allowed by the Blue Mountain's Local Environment Plan 2015. Why such a gross exception for this scheme?
It does not really address he more basic housing needs of the upper mountains. The '15%' 'Affordable Housing' component is insulting, at best tokenism.
The excavation that would be undertaken would have a severely detrimental effect on the Katoomba Creek Catchment - a delicate eco system home to many specific species of both flora and fauna. All of course running toward the Sydney Water Catchment. Such a large number of apartments could only further strain the existing and ageing sewer system. The increased and massive hard surface area run off will increase amount and speed of flow also affecting erosion and the creek system.
Many local and especially small business' serve people who come to partake of different surrounds and to be refreshed, not to endure more urban blight.
The proposed structure dwarfs all in its surrounds and is aesthetically appalling.
The area already has seen an influx of greater tourist traffic negotiating the narrow and limited streets of residents. This is especially the case with accessing the popular lookouts and viewpoints such as 'Boars Head Rock' Narrow Neck proper and the valleys below. Hundreds of new and changing tenants dependent on cars (virtually non existent public transport, a single poorly timed bus) to access the towns shopping and services will only add to the problem which now needs already needs attention and solutions. Especially with the influx of ever increasing coach traffic.
The block may not be strictly designated as bush fire prone but having experienced many terrible and destructive fires over the years I've seen enough with intensity and a fickle wind that will put paid to a'line' drawn on paper. I have seen particularly fierce blazes just a few blocks away. Is this worth the risk of lives?
The narrow points of entry and exit are completely inadequate for the safe evacuation of numbers of people in an emergency, and that is when it really counts.
Finally, I don't consider a random minimal leaflet letter box drop as 'Community Consultation'. Evidence of the disregard that the proposers hold for our community.
Graham Hallett

I object to this development proposal as it is completely out of character for the area and adds unnecessary stress onto the surrounding infrastructure including roads, public transport, water, sewage and electricity. This is all expanded upon in my attachment. We strongly recommend that the Blue Mountains LGA be exempted from the HDA pathway and that the proposal be declined.

Dear Hon. Paul Scully,

My name is Tessa Barratt and I am a resident of the Blue Mountains. I am writing to you today to express my concern over the proposed development at 142–150 Narrow Neck Road in Katoomba. I live two streets down from this location, and am greatly worried about the impact such a development will have on the area.

We moved to this spot in Katoomba in June of 2025 to escape the noise of the highway. We could no longer bear to live in our first home in Springwood due to the ever-increasing trucks and resultant noise on the nearby Great Western Highway. We picked this area because it was quiet. Now we are living with the anxiety of this enormous development which threatens the peace we came for.

We have many concerns.

Firstly, the roads are not fit to carry hundreds of extra cars. The increased traffic coming in and out of Narrow Neck road will negatively impact all the current residents. Secondly, while for some bizarre reason the block of land in question has not been zoned as fire prone, the surrounding area very much is. Embers from the fire at Cahill's Lookout reached as far as the proposed development location. In the case of a bush fire, the few, small roads will not cope with the out flowing, panicked traffic as people attempt to evacuate. It is a terrifying thought.

Additionally, the bush that would be demolished makes up an important, ecologically sensitive water catchment area. Water running through that bushland feeds the swamps below, which are already critically endangered in the Blue Mountains. Laying down tonnes of concrete will create severe run off, change the pH of the soil and degrade the surrounding areas. It will also spell the destruction of many organisms along with habitat for plants and animals.

The artist's impression of these buildings are horrifying. Not only are they exceptionally ugly and out of character for the region, the five story height of the buildings will also stand out on the escarpment, and will most certainly be visible from the National Park. This is not supposed to be the case in our beautiful Blue Mountains. This is an exquisite world heritage site, not another suburb of Sydney, and should be treated accordingly. Sweeping, unbroken vistas are what the tourists and visitors come to see. It would, in fact, be in direct violation of the Blue Mountains Local Environmental Plan 2015. We appreciate that ministers such as yourself listened to previous concerns that were raised by our community and developed this Environmental Plan as a protective exemption for our area. I implore you to continue to uphold this promise to the community.

We are also very worried what precedent the approval of a such a development will set for the Blue Mountains. This community cares about nature, and about living in harmony with the land and all its inhabitants. We do not wish to see done to this marvellous place what was done the the Cumberland Plain in Western Sydney.

Finally, contrary to what the applicant states, we were not notified by letterbox drop of this development and found out about it through volunteer awareness raising.

In summary, this development will destroy native flora, affect the water ecology, add congestion to our small roads, increase the population density in a bushfire prone area, thus endangering lives, and will deeply anger and upset the community. We do not want it, and I strongly urge you not to approve it.

Thank you for your time.

Yours sincerely,
Tessa Barratt

SSD-86456706 Development Proposal for 140-150 Narrow Neck Road, Katoomba.

I object to the development of 142-150 Narrow Neck Road, and
I object to the use of the Housing Delivery Authority (HAD) pathway in the Blue Mountains.

On 16th March I was in the train from Sydney to Katoomba. I happened to sit near two elderly visitors to the Blue Mountains, both unknown to me. Their amazement at the scenery and towns along the line was fantastic to overhear. Two overheard comments caught my interest:

1. “It’s wonderful to see no high-rise buildings, nothing like the Gold Coast”. A feature of Katoomba is that there are no ‘high rise’ buildings, which so pleased this couple. It is not like the Gold Coast or hundreds of other destinations. The proposed development of five storeys would ruin the character of the town, and disregard and undermine the R3 Medium Density, Blue Mountains Local Environment Plan (LEP) zoning of the site. The LEP has taken years of planning and community consultation to ensure development in Katoomba is appropriate to the natural (World Heritage Area) and cultural significance of the town.

2. “So many trees, you can see why they have bush fires”. I have strong and personal experience of bushfires and the speed at which the fire front can kill, especially in confined places.
My cousin was killed on a country road by a bush fire which suddenly turned, he was unable escape even though he had a ute and the road clear. In another fire I was on the back of a farm truck fighting a large fire. Suddenly the fire loomed over a ridge and there was nowhere to escape. Providentially, we survived by driving blindly as fast as possible through the fire front. I coughed up soot for weeks.
Fire can and does kill fast. There is only one effective escape route from 140-150 Narrow Neck Road, that is along Narrow Neck Road towards the Highway. This is a narrow uphill road with blind corners. The advent of persons from the already established residential dwellings plus people from 214 residential flats and 52 service apartments trying to fleeing in dense smoke would create a panic filled bottleneck, and if there was one collision many could be caught in the conflagration.

Other than these two concerns, spoken to by brief visitors on the train, I feel the building of 218 residential flats and 52 serviced apartments, will not solve the problem of insufficient housing in Sydney and surrounds. There is vacant housing in Katoomba. Lots of it. But rather than catering for people who live here the residences are used for Short Term Rental & Vacation. In 2024 Blue Mountains Mayor Mark Greenhill said, "We have roughly 100 long-term rentals available in the Blue Mountains right now, but we have 1,000 Airbnb available." (Ibrahim 2024). On average Airbnb dwellings have a 30% occupancy rate. These dwellings create less long-term rental space, decrease affordability for renters and drive away much needed workers (eg hospitality industry). The only benefit is to those investor owners of the Airbnb. One thousand Airbnb reallocated to rental or local ownership would negate the need to build a high-rise development, and all the attendant services the area would require (140-150 Narrow Neck Road is 3 km from the main shops, services and railway in the centre of Katoomba). The addition of another 270 apartments, with only 40 (15%) allocated to affordable housing will, in my view, only make the situation worse with the high probability (in my estimate) that many of the dwellings bought will be used as Airbnb.

Finally, I think it entirely unreasonable for any member of the public to read, digest and prepare a submission within the 14 days allowed for the Exhibition phase of this State Significant Development project. The EIS along with SEARs and the 54 Appendices amounts to 2120 pages of reading material. For comparison Tolstoy’s War & Peace, considered one of the longest modern novels, has 1358 pages. Few people would claim to carefully read this novel within a month let alone in 14 days.

Yours sincerely,

James Burrow FRACP
32 Farnells Rd
KATOOMBA 2780

Ph 0412 616 549


Ibrahim, Tony. 2024. "Blue Mountains locals protest housing insecurity, as Airbnb listings rival long-term rental numbers." ABC News, 23 March 2024. https://www.abc.net.au/news/2024-03-23/blue-mountains-rental-shortage-airbnb-blamed/103615716.