I wish to lodge a formal objection to the proposed mixed‑use development at 142–150 Narrow Neck Road, Katoomba. After reviewing the Environmental Impact Statement (EIS), I consider the proposal to be inappropriate for the site, inconsistent with the environmental constraints of the Blue Mountains, and likely to result in significant adverse impacts that have not been adequately addressed.
My objections are outlined below.

1. Excessive Height, Bulk and Scale Incompatible with the Local Character

The proposal includes nine buildings up to 15.6 m high, with four storeys above existing ground level (EIS, Table 5; Section 7.2). This is double the current LEP height limit of 8 m and represents a 100% exceedance of the existing planning controls. This scale is not characteristic of Katoomba’s R3 zones, which typically comprise townhouses and low‑rise dwellings, not urban apartment blocks. The built form would dominate the ridgeline and permanently alter the scenic character of Narrow Neck Road. The Visual Impact Assessment itself concedes: “View loss experienced across public viewing locations varies between Nil and Severe” and that “locations within the neighbouring properties that are impacted by the new development” (Appendix AL). A development that produces severe visual impacts in a World Heritage buffer landscape is unacceptable.

2. Significant Tree Removal and Loss of Biodiversity

The proposal seeks to remove 134 of 206 trees on the site (Section 4.3.2). This includes 14 high‑significance trees. The EIS states: “Approximately 0.6 ha of vegetation clearing is required.” (Section 7.13) This is a substantial clearing footprint in an area mapped for biodiversity values under the NSW Biodiversity Values Map. The BDAR acknowledges that the site is within the Biodiversity Offset Scheme. The Blue Mountains is a World Heritage buffer zone, and cumulative clearing across the former golf course precinct is already significant. The removal of 65% of trees on this site alone contributes to incremental ecological degradation. The EIS claims impacts are “unlikely”, but this is speculative and inconsistent with the precautionary principle.

3. Inadequate Stormwater and Water Catchment Protections

The site drains directly into the Sydney Drinking Water Catchment, yet Council has raised concerns that: “Stormwater runoff from the proposal is directed towards Council‑owned land associated with the Blue Mountains Swamp… an environmentally inappropriate outcome.” (Table 12) The EIS proposes discharging stormwater into Basins 1A and 2 on the former golf course (Figure 27), but these basins were designed over 20 years ago for a different land use and a much lower impervious area. The proposal increases impervious surfaces to 72%, which is incompatible with the hydrological sensitivity of the area. The EIS does not demonstrate a neutral or beneficial effect (NorBE) on water quality, which is a statutory requirement for development in the drinking water catchment.

4. Traffic and Access Impacts on Narrow Neck Road and Glencoe Road

The development proposes 316 car spaces and will generate hundreds of daily vehicle movements. Narrow Neck Road is a narrow, winding, shoulder‑less road with no footpaths and limited passing opportunities. The Traffic Impact Assessment claims impacts are “very low”, yet this contradicts:
- The steep topography
- The lack of pedestrian infrastructure
- The constrained geometry of Glencoe Road
- The cumulative traffic from the 24 townhouses at 152–166 Narrow Neck Road and “The Escarpments”
Council has already expressed concern about: “Increase in local traffic volume and parking on surrounding roads.” (Table 12) The TIA relies heavily on assumptions and does not model peak tourist periods, which are significant in Katoomba.

5. Overdevelopment of a Sensitive Ridgeline Adjacent to a World Heritage Area

The site is within the Protected Area – Escarpment under the Blue Mountains LEP. The purpose of this clause is to minimise visual intrusion when viewed from the National Park. The EIS acknowledges: “The highest value components of the views are retained above and behind existing trees…” (Appendix AL) This is misleading. The proposal relies on existing vegetation to screen a permanent built form, yet simultaneously removes 134 trees. Once vegetation is removed, the buildings will be highly visible from:
- The former golf course
- Narrow Neck Road
- Glencoe Road
- The escarpment viewpoints
This is contrary to the intent of the Protected Area provisions.

6. Insufficient Justification for Rezoning and Height/FSR Increases

The proposal relies on a spot rezoning to justify its scale. However:
- The Blue Mountains are not identified as a growth area under State planning strategies.
- The LSPS emphasises protecting landscape character, not intensifying development on ridgelines.
- The EIS repeatedly cites the Housing Delivery Authority pathway, but this does not override the need for site suitability.
Council has stated: “The State Government has confirmed that the Blue Mountains is not identified as a location for housing growth.” (Table 12) The rezoning appears developer‑driven, not strategically justified.

7. Cumulative Impacts with the Planetary Health Precinct

The site directly adjoins the future Planetary Health Precinct, intended as a low‑impact, educational, ecological landscape. The EIS acknowledges: “Potential overshadowing and light spill impacts on the adjoining Planetary Health Precinct.” (Table 12) A dense, four‑storey apartment complex is fundamentally incompatible with the intended character and function of the Precinct.

8. Construction Impacts on a Constrained Site

The EIS proposes:
- Five separate basement excavations
- Extensive rock sawing and hammering
- Heavy vehicle movements on narrow roads
The Noise and Vibration Report anticipates: “Highly concentrated and loud activities” requiring “one‑hour respite periods.” (Section 7.10). This indicates significant construction impacts over a prolonged period, likely several years.

Conclusion

For the reasons outlined above, the proposed development is excessive, inappropriate, and environmentally unsustainable for this sensitive site. It is inconsistent with the character of Katoomba, the environmental constraints of the Blue Mountains, and the expectations of the local community.

The site is near the escarpment of the world heritage area will be highly visible from any vantage point in Katoomba , is completely out of place and unsightly in the location selected,is the largest and highest development in the Blue Mountains, is located at the start of a fragile catchment area for the Katoomba Creek Falls, is located in an area of limited access via road in a bushfire prone area at a choke point that would prove chalenging in the event of an emergency arising, preventing the timely evacuation of existing residential area it would dominate, is double the height and floor area allowed under the Blue Mountains Local Envioment Plan of 2015 making this development totally unsuited for the area selected and finally is located away from the town CBD and has very limited public transpore and access to town services.

6 May 2026

SUBJECT: State Significant Development Residential flat buildings at 142-150 Narrow Neck Road, Katoomba

To the Department of Planning, Housing and Infrastructure

I write in response to the above State Significant Development Application for Residential flat buildings at 142-150 Narrow Neck Road, Katoomba. As a resident of Katoomba, I have many concerns about this proposed development and am against it proceeding further.

Most importantly, as a resident within 1 to 2 kilometres of the proposed site I should have been notified via letter box drop in late 2025. However, this was not the case, which is in contradiction to what the applicant has told Blue Mountains Council. While this may seem like a small matter, I believe it is a good indication of how this applicant may interact with and respect the local community.

Other major concerns I have are the increased traffic that this development will have on the town's roads, which already require maintenance. Although this is a state significant development, I doubt that the NSW Government will be providing funds to ensure that the local infrastructure can sustain such a development.

While I understand the land the proposed development is on has been rezoned and is no longer 'bushfire prone land', given its proximity to bushfire prone land and the escarpment, I am concerned by the lack of attention given to bushfire protective materials in the building plans, something residents are required to do regardless of whether or not they are building on 'bushfire prone land'.

I note the TRAFFIC AND PARKING IMPACTS REPORT determines existing traffic along Narrow Neck Road is "very low". However, with 218 additional dwellings and 52 serviced apartments I would expect in the vicinity of an additional 250 to 300 people in the area which could mean another 200 to 250 vehicles potentially using the road each week or each day.

This will have a significant impact on that street, especially if the area needs to be evacuated in the event of an oncoming bushfire, something which has happened at least twice in the last decade.

The last major bushfire threat in Katoomba (2019/2020) put homes along Narrow Neck Road at risk as Narrow Neck Plateau burned. In 2015 homes were lost on Cliff Drive (which joins Narrow Neck Road) as a bushfire raced up the escarpment.

Evacuating an additional 250 to 300 people from one site in the event of another bushfire is a significant burden on local Rural Fire Services. Narrow Neck Road also serves as the main access road to the Great Western Highway for a number of other streets in that area, which could be seriously compromised in the event all residents were trying to leave the area at once.

I am sure many other submissions have outlined concerns around the environmental impacts on the native vegetation, removal of trees and the greater height and scale of the proposed development in comparison to any other development in the Blue Mountains. I also share these concerns but wish to highlight the very real dangers the development could pose to residents in the event of a bushfire.


Kind regards

Penny Pryor

I am writing to advise that after numerous attempts, I have been unable to make a submission through the public portal due to system issues. As part of this submission, I agree to my information being released. I have consulted many residents who also state they have not been able to make a submission via the portal. This raises concerns about the integrity of the process.

I would also like to highlight that, last year when there was a consultation process about this development, we recently learnt that a letterbox drop occurred so that residents could attend. I would like it noted that I did not receive any such notification neither did many other residents.

For the purpose of my submission, I would like to start by expressing my strong opposition to the proposed development t 142 – 150 Narrow Neck Road, Katoomba.

I live in Katoomba. This is my home. And I hold serious concerns about this proposal and the fact that it has even been allowed to progress this far.

The proposed development site is situated in a World Heritage area. That's not a sticker on a brochure. It means this place is internationally recognised for its natural value. And this proposed development ignores that completely. Nine four-storey buildings on Narrow Neck Road, is monstrous. This development will destroy iconic escarpment views, tear up sensitive bushland, and chase out native animals that live there. For what, a massive concrete block that belongs in Sydney, not here.

The proposed development site is also in the heart of Blue Mountains and presents significant fire safety and evacuation issues. Bushfires are not a possibility—they're a certainty. Narrow Neck Road has two lanes. And this proposal wants to add 266 apartments. That's hundreds more cars trying to evacuate on that same tiny road during an emergency. It's reckless and it's dangerous. Narrow Neck Road (2 lanes) accommodates locals, tourists, tradies, bus routes, school runs and the like. This development would add hundreds more cars. Our local roads cannot cope with this level of traffic, neither can evacuation routes.

Additionally, publicly available data shows Katoomba already has plenty of hotels, motels, and B&Bs which consistently have vacancies all year round. Katoomba does not need 52 serviced apartments This proposal is not solving a housing shortage; it is forcing unwanted commercial tourism into a residential area.

Furthermore, the proposal mentions fifteen percent will be set aside for affordable housing, however most people who need affordable housing work in Penrith, Parramatta, Blacktown, or Sydney’s surrounding areas. People do not want to live hours from their jobs with unreliable and long public transport commutes.

I would also like to note the way this development is being pushed through—bypassing our Council, using the state government's Housing Delivery Authority—it's a disgrace. The Blue Mountains is not Western Sydney. We have unique bushfire risks, fragile ecosystems, and a World Heritage listing. For all these reasons, I oppose this development, It is the wrong project, in the wrong place, at the wrong scale.

I write to formally object to the proposed State Significant Development (SSD) located on Narrow Neck Road, Katoomba. While I acknowledge the need for thoughtful development and housing supply within regional NSW, I strongly object to this proposal on the grounds of bushfire risk, environmental impact, inappropriate scale, and incompatibility with the established character and planning intent of the Blue Mountains region.

This proposal, comprising a multi-building high-rise complex of approximately nine buildings, each up to four storeys, with over 200 residential units, associated wellness facilities, restaurants, and supporting infrastructure, represents a fundamentally inappropriate form of development for this sensitive and unique location.

1. Inappropriate Scale and Bulk – Failure to Respect Local Context

The proposed development is significantly out of scale with the surrounding built environment. Katoomba and the broader Blue Mountains context is characterised by low-density residential dwellings, small-scale tourist accommodation, and a natural landscape dominated by escarpments, bushland, and World Heritage-listed values.

A development of this height, density, and built form will introduce an urbanised massing that is visually dominant and incongruent with the existing character of Narrow Neck Road and surrounding areas.

The cumulative bulk of nine buildings and associated infrastructure will result in:

* Overwhelming visual dominance when viewed from surrounding ridgelines and public lookouts
* Loss of scenic integrity within a nationally and internationally significant landscape
* A precedent for further high-rise intrusion into low-density bushland interface zones

This proposal does not reflect sensitive infill or context-aware design. Instead, it represents an urban-scale insertion into a landscape that is not designed to absorb such intensity of development.

2. Bushfire Risk and Emergency Access Concerns

The site is located within a known bushfire-prone region of the Blue Mountains. Given increasing fire severity due to climate change, any large-scale residential development in this location must demonstrate exceptional resilience, evacuation capacity, and defensible space design.

I have serious concerns regarding:

* Evacuation capacity for over 200 residential units in a single bushfire emergency event
* Reliance on Narrow Neck Road as a primary access/egress route, which is limited in capacity and already constrained in emergency scenarios
* The potential for catastrophic entrapment risk during fast-moving fire conditions
* Increased ignition risk due to higher population density and associated infrastructure loads

The scale of this development appears to significantly increase life safety risks rather than reduce them. In my view, it is not appropriate to concentrate such a high resident population in a high-risk bushfire interface zone.

3. Environmental Impact and Ecological Sensitivity

The Blue Mountains region is of exceptional environmental significance, with unique biodiversity and sensitive ecosystems. The proposed level of development raises concerns regarding:

* Vegetation clearing and habitat fragmentation
* Increased stormwater runoff impacting surrounding ecosystems
* Light pollution and noise intrusion affecting nocturnal wildlife
* Long-term pressure on surrounding bushland from increased human activity

Even with mitigation measures, the sheer scale of built form and population density will inevitably place sustained pressure on the surrounding natural environment.

The cumulative ecological impact is not consistent with the conservation values of the region.

4. Incompatibility with Planning Controls and Regional Character

While I understand that State Significant Development pathways can override local planning controls such as those administered by the Blue Mountains City Council, this does not remove the requirement to consider the intent of those controls.

Local planning frameworks exist to preserve:

* Low-density settlement patterns
* Scenic and landscape character
* Environmental protection of bushland interfaces
* The cultural and visual identity of the Blue Mountains

This proposal is inconsistent with these principles. It introduces a level of urban density more aligned with metropolitan centres rather than a World Heritage landscape and regional township setting.

By bypassing local council assessment, there is a risk that critical local knowledge and contextual planning intent is not adequately reflected in decision-making.

5. Visual Impact on a World Heritage Landscape

The Blue Mountains is recognised globally for its natural beauty, escarpments, and forested landscapes. Development of this scale will inevitably:

* Be visible from surrounding vantage points and ridgelines
* Alter the visual integrity of the landscape
* Create a permanent built intrusion within a predominantly natural horizon line

Once constructed, the visual impact will be irreversible. This raises serious concerns regarding intergenerational planning responsibility and stewardship of a globally significant landscape.

6. Infrastructure Strain and Cumulative Impact

A development of over 200 apartments, plus commercial hospitality and wellness facilities, will place significant pressure on existing infrastructure, including:

* Road networks and traffic capacity on Narrow Neck Road and surrounding access routes
* Water supply and sewerage systems
* Waste management services
* Emergency services response times and capacity

There is insufficient evidence that surrounding infrastructure is capable of supporting this level of intensified use without significant adverse impacts on existing residents and visitors.

7. Precedent Risk

Approval of this development would establish a concerning precedent for further high-density developments within sensitive bushland and scenic protection zones in the Blue Mountains.

This risks incremental erosion of planning protections that have historically preserved the unique character of the region.

Conclusion

While I support appropriate, sensitively designed development that aligns with local character and environmental constraints, I strongly object to this proposal in its current form.

The scale, intensity, and urban nature of this development is incompatible with:

* Bushfire safety requirements for the area
* Environmental protection obligations
* The scenic and cultural values of the Blue Mountains
* The established low-density character of Katoomba and its surrounds

I respectfully request that this State Significant Development application be refused, or at minimum subject to substantial redesign and scale reduction to ensure genuine alignment with environmental, safety, and planning principles.

I strongly object to the proposed development at 142–150 Narrow Neck Road, Katoomba.

This proposal is fundamentally inconsistent with the environmental, landscape, hazard and planning constraints of the site and fails to satisfy the principles of ecologically sustainable development required under the Environmental Planning and Assessment Act 1979 (NSW).

The proposal represents an extreme overdevelopment of a highly sensitive escarpment location adjoining the Greater Blue Mountains World Heritage Area and raises serious concerns regarding bushfire safety, biodiversity impacts, visual intrusion, infrastructure capacity, water catchment protection and inconsistency with local planning controls.

Excessive Scale and Non-Compliance with Planning Controls

The proposed height, bulk and floor space ratio substantially exceed the development standards established under the Blue Mountains Local Environmental Plan 2015 (LEP 2015).

The proposal seeks approximately double the permissible density and significantly exceeds the applicable height controls. This scale is entirely incompatible with the established character of Katoomba and the low-scale built form envisaged by the LEP.

While variations to development standards may be considered in limited circumstances, the magnitude of the departures in this case cannot reasonably be characterised as minor or justified. The proposal appears inconsistent with the intended operation of the Housing Delivery Authority pathway and undermines the integrity of local strategic planning controls.

The development would set a dangerous precedent for inappropriate high-density development within environmentally constrained areas of the Blue Mountains.

Incompatibility with the Blue Mountains World Heritage Landscape

The site forms part of the visually sensitive escarpment landscape adjoining the Greater Blue Mountains World Heritage Area.

The proposed five-storey building forms would introduce substantial visual bulk and urban intensity into a landscape specifically protected for its scenic, ecological and cultural significance.

The Blue Mountains is internationally recognised for its natural landscape values. The visual impacts of this proposal on the escarpment, ridgelines and surrounding national park vistas have not been adequately addressed.

The proposal is inconsistent with the objectives of escarpment protection provisions and fails to demonstrate that the development will preserve the visual and environmental qualities of the locality.

Unacceptable Bushfire Risk

The proposal raises severe concerns regarding bushfire evacuation and occupant safety.

The site is bushfire-prone land surrounded by heavily vegetated areas and relies on evacuation routes that themselves traverse bushfire-prone corridors. The concentration of hundreds of additional residents and visitors on this site creates an unacceptable life safety risk during bushfire events.

The application does not appear to include an adequate strategic bushfire assessment addressing large-scale evacuation, cumulative risk, or emergency access capacity during concurrent hazard scenarios.

Given the increasing frequency and severity of bushfire events in the Blue Mountains, the precautionary principle should apply. Approval of a development of this scale in such a constrained location would be irresponsible and contrary to the objectives of community safety and hazard resilience under NSW planning policy.

Environmental and Biodiversity Impacts

The proposal would result in substantial clearing of native vegetation and fragmentation of environmentally sensitive habitat within the Katoomba Creek catchment.

The site and surrounding area contain important ecological values associated with the Blue Mountains ecosystem, including threatened species habitat. The application fails to demonstrate that impacts on biodiversity can be adequately avoided, minimised or offset.

Concerns include:

clearing of native bushland,
impacts on threatened flora and fauna,
edge effects and habitat fragmentation,
increased stormwater runoff and pollution,
long-term impacts on adjacent protected lands.

The absence of a comprehensive Biodiversity Development Assessment Report raises serious concerns regarding the adequacy of environmental assessment undertaken to date.

Impacts on Water Catchment and Hydrology

The development is located within the Sydney drinking water catchment and upstream of sensitive swamp and creek systems connected to the broader catchment network.

The proposal introduces extensive hard surfaces, excavation and urban runoff risks on steep terrain without demonstrating adequate long-term stormwater management outcomes.

There is insufficient evidence that the proposal can achieve neutral or beneficial effect outcomes for water quality or protect downstream waterways from sedimentation, contamination and hydrological change.

The cumulative impacts on the Katoomba Creek catchment and connected ecosystems have not been adequately assessed.

Poor Urban Design and Failure to Respond to Site Constraints

The proposal demonstrates a generic high-density urban design response that is inappropriate for the topography, climate and environmental conditions of the Blue Mountains.

The development appears inconsistent with key principles of the Apartment Design Guide, including:

solar access,
natural ventilation,
landscape integration,
deep soil provision,
response to steep terrain,
minimisation of visual bulk.

The scale and configuration of the buildings prioritise yield over environmental responsiveness and local character.

The proposal fails to exhibit the design excellence expected for a prominent gateway escarpment site adjoining a World Heritage landscape.

Inconsistency with Strategic Planning for the Blue Mountains

The Blue Mountains has historically been excluded from broad high-density housing reforms due to well-recognised environmental and hazard constraints, including bushfire risk, topography, biodiversity sensitivity and infrastructure limitations.

Concentrating a substantial proportion of the region’s housing target onto a single constrained escarpment site is strategically unsound and inconsistent with orderly and sustainable planning principles.

Housing supply objectives must not override fundamental environmental protections, hazard considerations and place-based planning outcomes.

Inadequate Community Consultation

The community consultation undertaken prior to lodgement appears inadequate for a proposal of this scale and significance.

Many nearby residents report receiving no notification despite being directly affected by the development. Concerns have also been raised regarding the limited scope and effectiveness of engagement undertaken with the local community.

Given the scale of the proposal and its potential regional impacts, a far more comprehensive and transparent consultation process should have occurred prior to lodgement.

Failure to Properly Address Existing Legal and Site Constraints

The application appears to insufficiently address existing development consent conditions, easements, title restrictions and historical planning constraints affecting the site.

These matters require detailed clarification prior to any determination and raise questions regarding the suitability of the site for the intensity of development proposed.

Conclusion

This proposal is inappropriate for its location and represents an unacceptable overdevelopment of an environmentally constrained and internationally significant landscape.

The development fails to appropriately address:

bushfire safety,
environmental protection,
biodiversity impacts,
visual impacts,
infrastructure constraints,
water catchment protection,
local character,
strategic planning consistency.

The Department should refuse the application in its current form.

At minimum, the proposal requires substantial redesign, significantly reduced scale and density, comprehensive independent environmental assessment and a more rigorous community consultation process before any further consideration.

I request that this submission be formally considered in the assessment of the application.

Yours faithfully,
CG
Leura

The recent move by the NSW state government to address the lack of housing is admirable. I imagine that planners want to build in areas of safety and where the local community wants and needs increased development.
Mindful of this then, it seems tome that the new Housing Development Authority, in choosing 142-150 Narrow Neck Road, Katoomba in the Upper Blue Mountains as it's first project has chosen the worst possible project to develop.
Katoomba is a TOWN. It is not a suburb of Sydney,it's not a suburb of anywhere.It's a premier tourist town, one of the most visited in New South Wales by people from all over the world for it's natural beauty, it's unique flora and fauna, relatively unpolluted fresh air at 1,000m altitude. It's wondrous native flora and rugged contours provide inspiration and health for humans and native fauna alike - essentials for life. The Upper Blue Mountains is a special and precious place - a site of the critically endangered dward mountain pine is found just a short distance from this proposed development.
Before becoming a resident/ratepayer in an Upper Mountains town as a baby I was taken by my parents many years ago to camp on some land they had bought there. We walked into the beautiful bush, sometimes it snowed gently and the serenity of the bushland seeped into my soul and dwells there still. These days, the quiet, sometimes broken by the plaintiff calls of the yellow-tailed cockatoos, the aromas, flora and tiny ground-dwelling fauna of the bush as one walks through it, bring peace.
The encroachment of even a modest development in this area would be threatening but to have 9 x 4 storey buildings is absolutely a mega over-development, a monstrosity in so many ways - surely you can't be serious!.
This quiet area is prone to bushfire, has quality environmental amenity which would be seriously impacted by massively increased traffic, tar and cement, and pollution of air and water and must be excluded from such an onslaught.
The proposed development is just plain wrong; it's the wrong idea, the wrong buildings in the wrong place.
I object to it in the strongest terms.
Not only would it ruin the local area but also would set a most dangerous precedent.
Surely we must all protect natural values, retain the character of our towns and surrounds which are World Heritage listed, not over-rule our elected councils and strive to rise to the real threat of climate change and housing crises by appropriate measures without ruining our country.
I strongly urge you to reject this development proposal at 142-150 Narrow Neck Road, Katoomba.

I am a permanent resident of the Blue Mountains and believe that our world heritage status is of major importance to this area. The approval of this project may well put this mentioned status in jeopardy. The survival of businesses in Katoomba is contingent on the visitors and tourists who come to this area as it has world heritage status and I believe that they would be significantly impacted by approval of this project. I also have concerns that the infrastructure at the proposed site would not cope with the increased population that will ensue.

1. This proposal has a building height and density that will override Council’s local
planning controls and become a precedent for further developments at the detrimental risk to overall existing concept of our low density city in the centre of a World Heritage Declared Area.

2. The impact on traffic will adversely affect both the existing residents as well as those who are the intended occupants. The existing road infrastructure was not designed for such increases of traffic, both during the construction and in the long term.

3. The cost of maintaining the roads will be another impost on scarce councils resources, ie the ratepayers.

4. The local hospital will not be able to cope with additional people as it cannot service the region now. No operations are undertaken at Katoomba, nor Lithgow hospitals, with patients being transferred by ambulance to Penrith Hospital, which is suffering from overload with a shortage of surgeons. Extensive delays occur at Katoomba while waiting to get an allocation of a surgeon at Penrith.

5. The site was mapped as bush fire prone land and the bush fire risk is too high with evacuation routes from the site being over bush fire prone land. Fires can come up the escarpment from Megalong Valley at a rate that will exceed capabilities of fire crews.

6. There will be significant adverse impacts of the site during the building phase on the quiet amenities of the existing residents.

7. The provision component of “Affordable Housing” can be ameliorated by the developer as the concept of this proposal appears to be an attempt to gain extra density and height bonuses in exchange for providing a small percentage of units as affordable for a limited time, rather than in perpetuity.

8. Affordable housing agreements only require the units to remain affordable for a limited period, often 15 years. After this period, the units convert to market rate, which will allow the developers to reap long-term profits while providing only temporary, short-term relief in the local area.

9. There is a potential that instead of building affordable units the developer will pay a "contribution in lieu” or may negotiate to provide the required units at a different location.
10.The definition of "affordable" is not pertinent to this development as it is based on a percentage of the median household income of the large area like Sydney, instead of the local, low-income community of the Blue Mountains. This can allow these expensive units to be classified as "affordable," and it is doubtful that they are will not be affordable to the local people in our area.

I live less than 1km from the proposed development. I have not been contacted or letterboxed by the proponent as would normally be required, so I have only recently become aware of the proposal.

I object to the proposal because it is approximately double the density permissible under the local environmental plan. This creates unacceptable risks to current and proposed residents in a major fire and runs completely counter to the direction the state government is pursuing to minimise risk to the community in the worsening fire climate.

My objection is grounded in my extensive fire management and emergency control experience. During twenty years as Regional Manager in NSW National Parks and Wildlife Service, I was accountable for all aspects of fire management across the Blue Mountains jurisdiction. I was appointed emergency controller or deputy controller (Rural Fires Act) during the major fire seasons of 1994,1998, 2002, 2003, 2008 and 2013 and numerous other bushfire events in Blue Mountains and broader NSW. I currently serve as President of the Independent Bushfire Group (https://independentbushfiregroup.org/) which advocates for improved fire suppression following the 2019/20 Black Summer fires.

I understand development on the eastern side of the ridgeline marked by Narrow Neck Road is deemed less risk than west facing development from the effects of any major fire running uphill into Katoomba from the Megalong Valley. However, this analysis does not take into account what would actually happen during such an event.

The 2002 Blackheath Glen fire, which started below the western escarpment near Blackheath, is the historic precedent relevant to the proposed development’s location. That fire originated in the valley and burned rapidly up the escarpment to Great Western Highway on the ridgetop spreading about 18km in three hours.

A fire in the valley west of the proposed development in similar conditions would produce embers, ignite spot fires and prompt residents to retreat to designated safe areas in Katoomba town centre. This creates the potential for multiple fatalities. Evacuating residents following their normal route would drive on Narrow Neck Road, a two-lane pavement with discontinuous centre marking and no side markings. In this scenario, drivers would at best be faced with propelled embers and thick smoke and at worst a head fire burning uphill across the road and the vehicles on it. It would only take one accident to block the road and engulf people in their cars.

My objection is grounded in recent history and the reality of fire. Please refuse the current application. It poses unacceptable risks to existing and future residents.