Development submission for 142-150 Narrow Neck Road, Katoomba
In response to Environmental Impact Statement, I wish to indicate I object to the project.
I have lived in nearby Essendene Rd, Katoomba for over 50 years. I walk past the entrance to this proposed development on my early morning walk and drive along Narrow Neck Road on each journey into Katoomba or beyond. During my time here I have experienced an increasing number of local bushfire emergences and evacuations.
In recent years there has been development of over 50 two-storey houses at this end of the old golf course. This has been undertaken within current guidelines and has enhanced housing stock. My central argument is that the adjacent new development proposal is on a different scale in a location inappropriate to the nature of the Blue Mountains environmental and cultural values. Its size, height and specific location pose environmental risks on the edge of a World Heritage Area details of which are better presented by experts on local ecology. My central argument in this submission concerns serious traffic issues (particularly in a bushfire emergency).
General Traffic Management
Even for everyday use, the large increase in traffic caused by the addition of 266 apartments plus other commercial premises will add substantially to the traffic entering Narrow Neck Road. The scale of this development is inappropriate and unsafe. Narrow Neck Road is a two-lane road with significant bends. It is also a tourist route. It has no pedestrian pavements and on the road side of the entrance to the development has no off-road area for walking (see EIS Photograph 6). The EIS comment under ‘Pedestrian Connectivity’ (p15) rather understates the issue in claiming there are ‘no established footpaths’. As Katoomba residents know well, visibility is significantly reduced in heavy rain, mist and fog.
A recent bus service has been introduced with a stop near the end of Essendene Rd. The bus runs only on the side of the road where there is no verge for pedestrians. This does not constitute ‘nearness to a transport hub’. It seems likely that the vast majority of occupants of the development would choose to use a car for trips into Katoomba with a substantial increase to the current local and tourist traffic.
Moreover, it is the direct route to the Great Western Highway from this area of Katoomba and poses a serious evacuation risk during bush fires.
Bushfire Evacuations
With the location of this development off Narrow Neck Road, the general traffic concerns become greatly magnified in bushfire outbreaks. The EIS dismisses the bushfire risk of the development with the phrase ‘not mapped as bushfire prone land’ (p16). While serious fires may be unlikely to start in the development complex, it is sited close to the extensive bushland in the World Heritage National Park with natural bush in the streets around the complex. The threat of megafires particularly from the valley will continue to increase, generating mass evacuations. Narrow Neck Rd is not only the most direct route out of the area but the direct route in from the RFS base at the top of Narrow Neck Rd.
Bushfire evacuations are an inevitable and increasingly frequent feature of living on the edge of the escarpment and threats from the Jamieson and Megalong valleys can reach settlements in this part of Katoomba with alarming speed. Often the only way out to relative safely is along Narrow Neck Rd. In conditions of poor visibility, the addition of residents from 266 apartments plus commercial premises onto a road already being used by residents of Essendene Rd, Brougham and Clive Streets, The Escarpments and the section of Cliff Drive that loops off Narrow Neck Rd past Cahill’s Lookout presents an unacceptable risk of substantial casualties. In the 2014 fire on Essendene Rd, I left very early but other residents reported great difficulty in navigating their evacuation in the face of the very large number of fire trucks on and around Narrow Neck Road. This was a small, localised fire.
Potentially much more dangerous were the Black Summer mega bushfires of 2019-2020 immediately to the north and south of Katoomba. A Senior RFS spokesman indicated they could not have stopped the fire if it had got into the Megalong Valley thence racing up to Cliff Drive and putting Katoomba in a direct line of fire. I remember vividly the weekend in early February when over 200 millimetres of torrential rain extinguished these fires. Rain does not always come when most needed.
A much larger numbers of car evacuations and increasing large bushfire threats make for a very dangerous scenario, with traffic chaos threatening lives and impeding fire-fighter access. Of itself this makes the proposed major development totally unacceptable.
Environmental and Cultural Impacts
The World Heritage listed Blue Mountains National Park is in close proximity to the proposed development. The excessive development threatens the ecosystem that supports this unique plant and wildlife environment which is also the backbone of Katoomba’s and the broader Mountains’ tourism economy.
Housing affordability
I strongly support initiatives to provide more affordable housing. However, I do not believe that the rezoning and fast-tracking approval process in such an environmentally sensitive area is appropriate and suggest that affordable housing initiatives could be undertaken in appropriate safe locations in the Blue Mountains under the BMCC guidelines. Moreover, I note that 85% of the proposed residences in the current EIS are not categorised as affordable and the affordable housing has a 15-year limit.
Consultation
The EIS makes a false claim of consultation with local residents via a letter-box drop. I live less than one kilometre from the proposed development and have never received information from the developers, relying instead on the Blue Mountains Gazette and public information sessions run by concerned community groups for information.
Having read the EIS I do not believe that the concerns of the local community and the BMCC have been addressed.
Dr Marian Tulloch
27 Essendene Rd, Katoomba

I am horrified at the totally inappropriate size, scale and complete overdevelopment planned for such a sensitive site in a World Heritage area, this part of Katoomba is highly susceptible to bushfires and access is hugely problematic, traffic in and out of Katoomba is log-jammed at school drop off and pick up on school days, weekends, peak hours ect. Yeamans Bridge is totally unable to manage the traffic that we currently have. It is not a matter of if a fire tragedy occurs it is when, remember the South Coast fires and our traffic bottlenecks in Katoomba are far more fraught.

I write as a long-term resident of Katoomba but have professional qualifications that are relevant to this submission. I am an Accredited Member of the Professional Historians Association NSW/ACT and am a heritage consultant with 30 years of experience providing historical advice to planners, architects, and housing proponents. I also have decades of experience working with Aboriginal communities, including Darug and Gundungurra people who live in Katoomba.

To ensure my objections are clear, I am confining my comments on this proposal to areas I understand through my professional expertise, my weekly use of the former golf course, and 25 years of living in the local area through fire, flood, drought, COVID-19, and the current fuel crisis trigged by global conflict.

I have reviewed the documentation provided by the consultants who have prepared reports for the proponents of this development. I note that while an Aboriginal heritage impact statement has been provided, there have been no direct conversations with Deerubbin Local Aboriginal Land Council, or with representatives of Gundungurra people. I also note the Community and Stakeholder Engagement Report recorded strong opposition from local residents who replied to a letterboxed survey but makes no mention of Blue Mountains City Council's opposition to this project, or the concerns of the Blue Mountains Conservation Society about this assessment. There has not, to the best of my knowledge, been any serious community consultation about this proposal with any groups other than immediate neighbours but this site is adjacent to a former golf course which is widely used by the Blue Mountains community as a place for outdoor recreation and will become the grounds of the Blue Mountains City Council's Planetary Health Institute.

The proposal attempts to shoehorn a large number of buildings into a site in a quiet residential area. These buildings clash with the building stock in Katoomba, being taller than any others, and of a scale and size that is unlike any others. The absence of visual appeal is not the worst thing about this proposal. The worst thing is that such a development is being proposed for this site.

Hydrologically, the Blue Mountains is a wet and highly temperamental landscape, over which water flows rapidly and dangerously. All this water drains into the catchment for Sydney's drinking water, and any work done on this site risks polluting the water we all need to live. Over the last 10 years I have witnessed the runoff and environmental damage caused during the construction of the much smaller complexes at 'The Escarpments' next door. It is impossible to imagine the developers of this proposal could mitigate the flow of high volumes of water during a classic Blue Mountains flooding event, especially given the level of excavation required.

Geologically, the sandstone in this the region is prone to movement that triggers road collapes, as evidenced by the current closure of the Great Western Highway route over Mount Victoria and, right next to this site, the access road to Narrow Neck. In the last six weeks we residents have felt three earthquakes, the most recent of which emanated from Orange, NSW and exceeded 4 on the Richter scale. Sandstone cliff faces close to Narrow Neck and Cliff Drive are calving and collapsing at a dramatic rate that will no doubt be increased by the heavy excavation required for this project.

The other defining feature of this site is its extremely poor location. It cannot meet the requirements of Transport Oriented Developments or the definition of walkable suburbs, or meet the needs of the aged or disabled. It is a full 3 kilometres or 50-minute walk from Katoomba Station, over undulating country. It is the same distance from the nearest state high school, primary school, and TAFE, so students will need transport to access their education. Public transport is limited to one bus (686G) that runs every 30 minutes but only between 6am and 8pm. As a result, residents will be entirely car-dependent and, in the current fuel crisis, that has a significant impact on the cost of living.

When you consider that Narrow Neck Road is narrow and winding, unsafe for high volumes of traffic, and is 'one way in, one way out', the risks of the movements of 215 households and their visitors to and from the site are obvious.

The poor transport access to this site will matter most during bushfire events. Fires along Narrow Neck Road are a regular occurrence, with the most recent in 2019 impacting properties and access along Narrow Neck Road and Cliff Drive. If you add the pressure of 215 households who must evacuate by car, the ability of fire services to act to protect properties and life will be greatly restricted.

The proponents have stated they will meet government-mandated levels for 'affordable' housing in this development, but do not explain what that may mean for affordability in our community. The current definition of affordable housing is rents set at 75–80% of market rates or capped at 30% of gross household income for 10–15 years. There is no equivalent property in Katoomba to determine market rents, as apartments are rare. The median weekly income for households in Katoomba–Leura at the 2021 Census (https://www.abs.gov.au/census/find-census-data/quickstats/2021/124011452#:~:text=household%20income%20(a)%2C%201%2C246%2C%2072.6%2C%20677%2C486%2C%2071.9%2C,repayments%20greater%20than%2030%25%20of%20household%20income) was $1238 per week, but 34% of residents (median age 50) live on less than $800 per week. More than half of Katoomba-Leura residents already spend more than 30% on housing and the median rent locally is just $380.

Importantly, affordable housing improves social outcomes when it is located close to jobs. The only major employer close to this site is Scenic World (1.5km distance), which employs around 100 people, often in casual and part-time roles. The hospitality and retail venues on Katoomba Street are located 3km from this site and Blue Mountains City Council, which is another major employer, is more than 3km distance.

Essential workers need work that is within walking distance from their homes, but schools and childcare facilities are at least 3km distant, and Blue Mountains District Anzac Memorial Hospital is more than 5kms away. The proposed shop, restaurant and gallery are unlikely to employ residents from this site, and any workers from Katoomba who come to the site will need to travel 3km to get to it (on the same narrow, winding road, using the same buses that do not run during the hours of most shift and late night workers).

This proposal is wholly wrong for this location and will not deliver benefits for the residents of Katoomba. I urge the panel to reject it, in its entirety.

Narrowneck Road Development Proposal



As a long term Blue Mountains resident of 30 years, I was surprised and shocked to hear of the scope of the development proposal at Narrowneck Road on the old Katoomba Gold Course site. The proposal seems way out of size and character compared to anything that has been built in Katoomba before. And indeed anywhere else in the Mountains.

There are many concerns to note:

The project design and proportions appear to completely ignore the environmental protections which our local government has developed and put in place over time with knowledge and consideration relevant to the particular needs of this area. The Blue Mountains as a World Heritage site is surely in a unique position, needing to balance thoughtful development whilst adequately protecting and conserving the attractive local villages and the wild natural surrounds. This is not the same as a suburban area in Sydney or other Australian city and should not be treated as such. I believe the recent HDA pathway is not appropriate for the Blue Mountains. It feels rash to fast-track and override these protections which were developed over time to support and protect these natural surrounds without properly understanding these local considerations.

Environmental: The Blue Mountains is truly a unique place because we have a string of residential villages on a cliff line surrounded by an extensive National Park. The fact that the area is a World Heritage site and acknowledged as a place of special significance in a global sense makes it especially important. There is always a fine balance to be maintained here between the reality of the need to provide shelter for residents and visitors and the necessary amenities, alongside the importance of protecting what is most valuable in this area we are privileged to live in. The beautiful natural bushland, the scenic landscapes, and local wildlife.

The old golf course site where the multi tower development is proposed is situated near the escarpment with a slope down to a swamp below. With the many hard surfaces which would be needed around 9 multi story buildings, how will rainfall and drainage on the site be managed? In the natural scheme of things, rainfall would gradually be absorbed through the low vegetation and seep down into the soil and gradually down the slope to the lower swamp areas. There have already been more landslides along the escarpment and in steep sloping areas below residential areas in recent times. Cliff Drive near the Leura Cascades was closed for over two years due to a major landslide. Recently there was a landslide just across Cliff Drive from my own home in Katoomba which was serious enough to cause the walk to Echo Point to be closed indefinitely. This was after some heavy rain which has recently become more common. The cliff edge stability can be precarious as there is often only a thin layer of soil over the prevalent sandstone.

Tourism: Another huge reason for managing and protecting the Blue Mountains area is its uniqueness as a draw card for both Australian and international tourists. I believe that if we allow large scale developments such as this proposed project, it will be the start of a downhill progression. Not only will it challenge the local environment in ways that may not become fully apparent until it is too late, the sheer scale and size of the development will be a blot on the landscape. The site is very close to the escarpment and will be obvious from many different vantage points in the National Park and not in character with the local area. Tourism is surely one of the areas most valuable income resources and of benefit to the State revenue as a whole. Why will tourists want to come if the villages start to look like a generic suburban area of any city?

Bushfire Danger: Another serious issue to consider is the prevalence of bushfires in our area. The proposed development would be on a site which is very close to the escarpment which makes it extremely vulnerable in the event of a serious bushfire. Climate change and hotter weather conditions increasing each year means this is a very serious and likely possibility. The site really only has one main viable access and egress point on Narrowneck Road in the event of a calamity like this. Therefore all the extra residents in this area would be needing to use it in the case of evacuation and competing with the many emergency vehicles heading in and out. Very similar to the access to the serious bushfire that occurred In Yellowrock, Winmalee in 2013. Residential builds up here are subject to stringent building regulations when close to escarpment areas. BAL29 is the bushfire rating in my own street and this is back from the cliff edge with houses and a road in between.

I am not against development in general if it is considered and appropriate for the purpose and location it is situated in. I understand we need more housing and particularly subsidised social housing. However, it is still important to take time to assess the proposal responsibly in relation to the environment and also consider the needs of the community in general. I don't believe these proposed apartments are the kind of housing we need and they would be way out of scale and proportion to anything else ever built up here. This and all the considerations outlined above mean that I strongly object to this development.

We have owned this property on Pinnacle Ridge in the Megalong Valley for 40 years and lived here for 12 years. I first walked along Narrow Neck Peninsular in 1962. The Narrow Neck Peninsular is an Iconic part of the Megalong Valley.
The height of the proposed development is immensely excessive and will create a significant adverse visual impact on the Valley and our view, with adverse consequences for the value of our land and our historical enjoyment of it.

To whom it may concern,
It is always quite a frustrating thing to have to sit and write these submissions on projects that in so many ways seem outlandish. This development proposal is one of those, to a degree I have not witnessed before. As a Katoomba local, I was shocked to learn of this proposal. I am especially concerned by a number of issues, although there are many more, I will focus on my top 3 concerns that lead to my strong opposition to this horrific proposal.

Firstly, the HDA pathway overrides and undermines local environment plans -- this is an incredible overreach of state government and antidemocratic. This is one of the most beautiful places in Australia; a World Heritage Site and our local environment plans are the result of years of expert and community input, crafted uniquely for our local environment. How a state organisation can override local plans in this way is beyond me.

Secondly, this site is located in severely bushfire prone lands. How we would think to put hundreds of new residents into a high risk site is shocking and doesn't make sense. It is dangerous both for the future residents who would live at a site but also for those of us who live in other parts of town as this would put pressure on evacuation sites & emergency responses in the almost certain event of a bushfire in coming years.

Thirdly, we simply don't want this kind of urban style of development in our precious village. The sense of place that is present here is one of the many things that make living in Katoomba and the mountains more generally one of the most beautiful places I've ever lived. This kind of building would change the character of this place forever. We don't want this here!

There are many other reasons I could mention here in large amounts of detail but, in terms of a quick summary, other factors that make me object strongly to this project are: (1) the impacts on traffic and infrastructure; we're already struggling with this here, this would make it worse and (2) and most importantly of all, the environmental impacts. This is a world heritage national park with delicate and important ecosystems. This massive development will damage the surrounding ecosystems, altering the swamp, degrading local wildlife, affecting drinking water, and so many other impacts it's not really possible to list here.

Please listen to your conscious and oppose this crazy development.

Many thanks,
Yelena

The current development proposal at 142 - 150 Narrow Neck Road, KATOOMBA SSD-86456706 represents the very worst of it's type. What is clearly missing from this proposal is any knowledge of, or sympathy for the unique environs of the area. It sits within a World Heritage Area which is highly bush fire prone, adjacent to a small township with inadequate services. The road access is limited; a disaster waiting to happen in a bushfire emergency, with no reliable taxi service, non existent public transport and due to the steep terrain, a long, difficult and in parts dangerous walk or even bicycle ride to amenities. Katoomba has a decrepit, sub standard hospital and a congested under resourced health care network. The current wait for a standard GP consultation is approximately 2 weeks. Most residents must seek hospital and specialist medical care out of area; travelling considerable distance to do so.
Additionally and importantly, the proposal will annihilate the fragile escarpment ecosystem upon which it proposes to sit, create yet more waste water run off into the adjacent bushland, displace wild life, encourage the spread of environmental weeds, block the scenic vista and forever destroy exactly what it is that makes Katoomba unique - a place where nature and people can respectfully co-exist to mutual benefit. This proposal fails dismally in this regard.
This development with further accelerate the need for Blue Mountains City Council to seek more land to deal with the building and general waste generated during construction and it's considerable waste and garbage output into the future. Katoomba Waste Disposal Unit is already at tipping point so this is a real concern and it's storm water infrastructure is aged and in many parts non functional.
The development is deeply unattractive and contravenes planning laws currently in place and hard won by Blue Mountains City Council which are overwhelmingly supported by tax and rate paying local residents and business owners alike. Katoomba may be classed as "Greater Sydney" by bureaucrats, but it is not and never will be just another suburb of Sydney.
I say NO to this proposal.

Katoomba population of less than 1400. As a community we are privileged and value living in the Greater Blue Mountains World Heritage site. Katoomba features extensive heritage listings, including the Jamison Valley, Lurline Street Precinct, and Central Katoomba Urban Conservation Area, protecting its unique 19th and early 20th-century character. As a long term resident I have a vested interest in maintaining both the character and environment of this unique area. I oppose this development as it will compromise our town, creating broad adverse environmental impacts and degrade the area's character.

The proposal for a high density residential apartment complex at 142-150 Narrow Neck Road is inappropriate for both the Blue Mountains and the area of Katoomba specifically.
I am a nearby resident and was not notified of this development proposal by the applicant. I received no notice in my letterbox.
The proposal is in an area poorly serviced by public transport (no public transport after 9pm at night, and only running half hourly schedules in peak hour), with narrow main roads which have no footpaths. Access to and from this development could only reasonably be by car. The local train station or town center is a 40 minute walk (3km) according to Google maps, with approximately 2km of that along Narrow Neck road /Cliff Drive, which has no paved footpath, and in places no place to walk off the road at all. The road is used by tourists travelling to and from the scenic railway, lookouts and just driving along the tourist route, along with coaches, minibuses and other heavy delivery vehicles. To add even more traffic to this area would be detrimental to the roads, the neighbours and the environment.
The site is in a bushfire prone area, and again the road would be an issue for evacuation in the event of a fire making it unsafe. It is also near the escarpment and would be visible from vantage points in Katoomba - affecting our local tourism, and the livelihood of many. I don't think people would like to see that large complex from lookouts!
This is a huge development, bigger than anything we currently have in the Blue Mountains. It is out of keeping with the local area, and with the small town feel that the Blue Mountains is known for. It will also affect catchment areas causing downstream impacts.
I appreciate and support the need for more housing in NSW but would strongly disagree that this development is suitable for the area in which it is proposed. It would greatly and disproportionately increase the number of people living in an environmentally sensitive area that already has limited services, and would put unnecessary strain on our local environment and those limited services along with those of us who currently live here. To be allowed to build something so big is also a little unfair to those of us who have previously built in the area and had to follow strict restrictions on size and building type.
Yours sincerely

Submission: Objection to Proposed Expansion in the Blue Mountains

To whom it may concern,

I am writing to object to the proposed development associated with the “Not Another Suburb of Sydney” initiative in the Blue Mountains.

My concern is not simply about preserving character. It is that this proposal represents a poor strategic decision from a planning, financial, and risk management perspective. It shifts complexity and cost into an area where delivery will be difficult, expensive, and potentially unsafe, while more viable alternatives exist.

1. This is a high-cost, low-efficiency growth model
The Blue Mountains is geographically constrained, heavily vegetated, and not designed for large-scale expansion. Every additional dwelling requires disproportionate investment in roads, utilities, and services compared to flatter, better-connected areas.

From a delivery standpoint, this is not an efficient way to meet housing demand. It increases cost per dwelling for infrastructure and reduces overall return on public investment. If the objective is to deliver housing at scale, this location works against that objective.

2. Infrastructure will lag behind demand
In practice, infrastructure delivery rarely leads growth. It follows it. This creates a lag where population increases outpace capacity.

In the Blue Mountains, that lag is more pronounced due to terrain and existing constraints. Road networks are limited, public transport is already stretched, and access to healthcare and emergency services is not easily expanded.

The likely outcome is predictable: congestion, reduced service levels, and declining liveability for both new and existing residents.

3. Bushfire risk is not a theoretical issue
This region has a well-documented history of bushfire events. Expanding residential areas in this context is not just a planning challenge, it is a long-term exposure.

There are limits to how much risk can be mitigated through design. Evacuation routes, response times, and environmental conditions impose hard constraints. Increasing population density within those constraints amplifies the consequences of failure.

Approving development under these conditions effectively accepts a higher level of future risk.

4. Environmental exposure extends beyond local impact
The Blue Mountains sits within a globally recognised natural system, including areas linked to the Greater Blue Mountains Area.

Incremental development may appear manageable in isolation, but the cumulative impact is significant. Once thresholds are crossed, environmental degradation is not easily contained or reversed.

This carries reputational implications at a state and national level, particularly where internationally recognised landscapes are involved.

5. Misalignment with contemporary planning principles
Modern urban planning prioritises density where infrastructure already exists, particularly around transport and employment centres.

This proposal does the opposite. It extends the urban footprint into a peripheral, constrained area, increasing reliance on private vehicles and long-distance commuting. This is neither efficient nor aligned with long-term sustainability objectives.

6. Delivery risk and long-term accountability
From a governance perspective, this proposal introduces delivery risk that extends beyond the construction phase. Once approved, the long-term consequences, including infrastructure maintenance, emergency response, and environmental management, remain with government and the public.

Developers may complete projects and exit. The ongoing cost and risk do not.

This raises a fundamental question of accountability. Who carries the burden when the assumptions behind this development do not hold over time?

Conclusion
This proposal does not represent a balanced or well-justified approach to growth. It introduces unnecessary cost, risk, and long-term obligations in a location that is fundamentally constrained.

There are more appropriate, more efficient, and less risky ways to meet housing demand. Pursuing development in the Blue Mountains at this scale suggests a focus on short-term outputs rather than long-term outcomes.

For these reasons, I strongly object to the proposal and urge that it be reconsidered.

Sincerely,
Chayada Hansakulnusorn