To whom it may concern:

I am writing to strongly object to the proposed modifications for 903–921 Bourke Street, Waterloo (SSD-95997711). I live within walking distance of the site at 32 Wellington Street Waterloo, with my wife, 3 young children and an au pair. What is being proposed here will directly shape the streets my family walks every day, the school my children will go to, the buses my wife and I rely on for the daily commute, and the neighbourhood we chose to put down roots in. Like many of my neighbours, I am not opposed to housing, and I am not opposed to renewal in this part of Waterloo. I am opposed to the way this proposal has expanded so far beyond what was originally approved, the absence of any matching plan for the schools, transport and community infrastructure that 580 apartments will demand, and the fact that the most meaningful community protections - including the affordable housing offer - appear to be optional rather than binding.

What is being proposed is no longer the same project:

The original consent for this site was for 347 dwellings at around 65 metres in height, with a floor space ratio of 1.5:1. The application now before the Department proposes 580 dwellings (a 67% increase) at 126 metres (almost double the height), with a floor space ratio of 3.2:1. That is not a modification. It is a substantially different project. A change of this magnitude should require a fresh assessment process, a new design competition, and a new Voluntary Planning Agreement scaled to what is actually being asked for.

Instead, the State Significant Development pathway is being used to push the project through while excluding the very clauses - 6.14 and 6.21D - that would normally require independent design review and proper infrastructure contributions to the City of Sydney. The community is being asked to accept a building 55% larger than what was approved, while the public benefits offered in return are essentially unchanged. The same plaza, the same footpath widening, the same heritage square, for 233 additional apartments. That is not a fair exchange. It has the appearance of a community benefit without the substance of one.

My concerns as a local resident:

I have three direct, day-to-day concerns.

1. Schools - Alexandria Park Community School is already at capacity for kindergarten next year. Our eldest child will start primary school in 2028, and will surely be affected by this development. There is no plan in this application for additional school infrastructure to accommodate the families that 580 new apartments will bring. Parents in this neighbourhood are already being told their children may not get a place at their nearest school. Adding this many homes without any matching investment in school capacity is an obvious and avoidable failure of planning.

2. Transport - Buses on the routes that serve this site regularly pass already full at peak hour. My wife and I take the 343 every morning and evening. The McEvoy/Burke Street corner has well-documented blind spots. The Young/Danks Street intersection floods. Yet this proposal adds 233 dwellings while providing only 20 additional car spaces, on the assumption that those residents will rely on a public transport network the application has not assessed in any meaningful cumulative way. When the Coronation development, the Barings development on O'Dea Avenue, and the Waterloo Metro Quarter are layered on top of this proposal, the impact is not negligible. It has simply not been assessed together.

3. Neighbourhood character - The site sits beside streets of one and two-storey terraces. A 40-storey tower next to that built form is not a transition - it is a wall. The proposal makes no serious attempt to explain how a building of this height belongs in this part of Waterloo. Compounding that, the wind assessment relies on a neighbouring development (Coronation) that has not yet been approved or built. Pedestrian safety at street level is, in effect, being modelled against a building that may never exist.

The affordable housing offer is not what it appears to be:

The part of this application that concerns me most is the headline 12% affordable housing contribution presented in the planning statement. On a careful reading of the applicant's own documents, that figure is drawn from a City of Sydney policy the application explicitly states it is not bound by. Both the mandatory baseline and the 12% uplift contribution can be discharged through "an equivalent financial contribution" rather than as actual dwellings. There is no binding Voluntary Planning Agreement securing the affordable component.

In plain terms: it is entirely possible for this development to be approved, built, and sold without a single affordable dwelling existing on the site. That is not an affordable housing offer. It is a marketing line. If the Department is being asked to approve a 67% increase in yield on the strength of community benefits, those benefits must be enforceable - secured through a binding VPA, delivered as actual on-site dwellings, and managed in perpetuity by a registered community housing provider. Anything less is a transfer of value from the public to the developer dressed up as a community return.

What I am asking the Department to do:

I ask the Department to refuse the application as proposed. If the Department is minded to consider it further, I ask that it:

1. Refuse the exclusion of clauses 6.14 and 6.21D, or alternatively require an independent design review and a renegotiated Voluntary Planning Agreement scaled to the 55% increase in apartment yield.
2. Require the affordable housing component to be delivered as actual on-site dwellings, secured through a binding VPA that cannot be substituted with a financial contribution, and managed by a registered community housing provider.
3. Require a cumulative transport assessment covering all concurrent developments in the precinct before consent is granted.
4. Require a revised wind assessment that does not rely on the unapproved Coronation development.
5. Require a binding plan for additional school capacity to match the increase in dwellings.

Given the scale of the changes proposed and the precedent this would set for development across Waterloo and the wider inner south, I also ask that a public hearing be held so that residents have a proper opportunity to be heard.

This is not a submission against change in Waterloo. It is a submission against this particular change - one that is too tall, too dense, too thin on infrastructure, and too easy on the developer. Waterloo can absorb more housing. It cannot absorb this version of it.

Yours sincerely,

Ed Sholl
32 Wellington Street Waterloo

I am writing to formally object to the proposed Waterloo Mixed Use Development at 903-921 Bourke Street, SSD-95997711. I acknowledge the need for thoughtful urban growth, but this proposal, in its current form, raises significant concerns regarding height, density, and the cumulative strain it will impose on an already congested local infrastructure. Details of my concerns are as follows:
1. The proposal creates a Vertical Obstruction Angle that results in extreme visual bulk and overwhelming looming presence. The development would be a dominant wall-like mass with negative visual impacts, detriment of solar access on public areas and adjacent lower level dwellings, and general damage to liveability and environmental performance, contrary to the intent of the NSW Government Apartment Design Guide (ADG, July 2015) and SEPP 65 principles.
2. The increased height and additional dwellings would intensify the development impacts, amplifying issues relating to traffic, congestion, and infrastructure strain. It should be noted that the population density in the area is already one of the highest in Australia. Local infrastructure is already under considerable pressure, such as the road network on Bourke Street, McEvoy Street and surrounding intersections, which gets heavily congested, particularly during peak hours.
3. Public transport is a sensitive issue, with bus services and the nearby Green Square train station already at or near capacity, especially during commuting periods. The proposal does not address how increased demand will be accommodated. With the Waterloo metro station about 18 minutes walk from the site, this is hardly an argument for a transport solution catering for the additional dwellings proposed.
4. Recent studies show that educational facilities in the Waterloo-Zetland area are currently overstretched, with a significant increase in student enrolment, which has not been matched by adequate school infrastructure planning. The proposal does not describe how this issue would be addressed.
5. The proposal seeks to significantly increase the number of dwellings without demonstrating that supporting infrastructure, including essential services, stormwater and sewer capacity, electrical capacity, and waste collection, can accommodate this growth. Community centres, recreational facilities, and open spaces are already struggling to meet current demand. The development does not provide adequate additional community infrastructure to offset its impact.
6. This proposal places a cumulative impact on residents already dealing with pressure from a similar proposal immediately north of this development (SSD-80441462 by Coronation Property - refer to attachment*), who is also seeking approval for increased building heights and additional bulk, with no serious regard for the rules (their proposed changes, for example, are well above and beyond the FSR bonuses offered for design and affordable housing) and no demonstrated benefit to the current and future residents. Approval of either of these two proposals will likely set a precedent for approval of the other, doubling the impact of the issues noted above (with new apartment numbers increasing to around 500) and causing long term damage to existing residents - reflected in loss of amenity, congestion, cumulative deterioration of the mixed-use character that makes Danks Street functional and attractive. This would also adversely affect the market value of established properties.

In conclusion, the proposal to change the maximum building height from 65m to a maximum of 126m and increase the Floor Space Ratio from 1.5:1 to 3.2:1 (more than double!) is completely out of balance, opportunistic and excessive, only translating in revenue potential for the developer. There is little verifiable evidence of active initiatives to address the issues inherent to the proposal and create overall benefits contributing to the Vision conceived by the City of Sydney Council for the Danks Street South Precinct**. The proposal to create a clause to exclude applicability of Clauses 6.14 and 6.21D of the Sydney Local Environmental Plan 2012 (as noted in the exhibition letter) clearly suggests the Proponent's desire to be exempt from the rules that were precisely put in place to create a careful and consistent approach to developments in the area.

For all the reasons above I respectfully request that the terms of this proposal be rejected and the development under this application (SSD-95997711) only be allowed to proceed under the currently approved terms.
_______
Notes:
*The attachment is an edited version of a schematic shown by the proponent during a webinar presentation on 25/02/2026.
**Link: https://www.cityofsydney.nsw.gov.au/research-reports/danks-street-south-precinct-concept-design-summary.

Formal Objection to Proposed Rezoning
903–921 Bourke Street, Waterloo
SSD‑95997711 | Proposed Amendment to Sydney Local Environmental Plan 2012
To whom it may concern,
I write to formally object to the proposed rezoning of land at 903–921 Bourke Street, Waterloo, as outlined in State Significant Development application SSD‑95997711.
The proposal seeks to amend the Sydney Local Environmental Plan 2012 to:
Increase the maximum building height from 65 metres to 126 metres
Increase the floor space ratio (FSR) from 1.5:1 to 3.2:1
Introduce a site‑specific clause to exclude the application of:
Clause 6.14 – Community Infrastructure Floor Space at Green Square
Clause 6.21D – Competitive Design Process
These amendments would result in an extraordinary uplift in height, density and population, while simultaneously removing key planning controls specifically designed to manage growth, infrastructure demand, and design quality in the Green Square and Waterloo precincts.
1. Inappropriate and Excessive Uplift in Height and Density
The proposed rezoning seeks to more than double the allowable building height and floor space previously approved for this site.
Under the proposal:
Bourke Street North increases from 12 storeys to 31 storeys
Young Street Tower increases from 21 storeys to 38 storeys
Apartment yield increases from 347 to approximately 580 dwellings
This represents a fundamental departure from the planning framework, built form controls, and strategic intent that underpinned the original approval by the City of Sydney.
Such an increase cannot reasonably be characterised as a minor planning adjustment. It is a radical intensification that undermines certainty in the planning system and disregards the reasonable expectations of existing residents and landowners who relied on approved controls.
2. Removal of Critical Community Infrastructure Contributions (Clause 6.14)
The proposal explicitly seeks to exclude the application of Clause 6.14, which exists to ensure that significant uplift in residential density is accompanied by appropriate contributions to community infrastructure.
This is particularly concerning given:
The addition of 233 apartments on this site alone
The cumulative impact of multiple nearby State Significant Developments
Existing pressure on libraries, community facilities, open space and local services
Allowing a substantial population increase without commensurate infrastructure provision directly contradicts both the intent of the LEP and principles of orderly and sustainable development under the Environmental Planning and Assessment Act 1979.
3. Infrastructure, Transport and Parking Impacts
The proposal would generate a significant increase in daily trips, service vehicles, deliveries and ride‑share activity, yet provides only 20 additional car parking spaces.
Local infrastructure is already operating at or near capacity:
Bus services (including the 304 route) are regularly overcrowded, with services bypassing stops
Green Square Station experiences severe peak‑hour congestion
Local roads and on‑street parking are heavily constrained
The proposal relies on existing infrastructure that is already inadequate and provides no credible or enforceable mechanism to address the increased demand created by this rezoning.
4. Failure to Address Cumulative Impacts
The proposed rezoning must be assessed in conjunction with:
The approved and proposed development at 881–885 Bourke Street, Waterloo (SSD‑80441462), including a 38‑storey residential tower
Multiple other high‑density developments across Waterloo and Zetland
The cumulative outcome is an estimated 4,000 additional dwellings and up to 8,000 new residents within a highly concentrated area over a short period of time.
This scale of growth is equivalent to inserting a small regional town into an inner‑city precinct without the infrastructure, transport or open space capacity to support it.
5. Overshadowing, Amenity and Built Form Impacts
The proposed towers, when combined with adjacent developments, would result in substantial cumulative overshadowing, particularly at the winter solstice, affecting:
Nearby residential properties
Public open spaces
Street‑level amenity
The proposed height and bulk are visually dominating and out of scale with the surrounding context and undermine planned height transitions within the precinct.
6. Wind Impacts and Public Safety
Buildings of the proposed height and bulk present a high risk of adverse wind conditions at street level, including wind tunnelling and downdrafts.
These conditions can:
Reduce pedestrian comfort
Pose safety risks
Diminish the livability and usability of streets and public areas
It is therefore wholly inappropriate that the proposal seeks to remove the requirement for a Competitive Design Process under Clause 6.21D, which is a critical mechanism for ensuring design excellence and mitigating high‑rise impacts.
7. Strategic and Precedent Concerns
Approval of this rezoning would establish a dangerous precedent, signalling that approved height and density controls can be significantly exceeded through post‑approval rezoning, rather than through strategic, precinct‑wide planning.
This undermines:
Confidence in the planning system
Strategic planning for Green Square and Waterloo
The principle that growth should be aligned with infrastructure delivery
Conclusion
This proposal represents overdevelopment of the site, removal of essential planning safeguards, and a clear failure to balance private development yield with public interest outcomes.
For these reasons, I strongly object to the proposed rezoning of 903–921 Bourke Street, Waterloo, and urge the NSW Government to refuse the LEP amendments in their current form.

Attn: Chris Eldred, Key Sites Assessments
Department of Planning, Housing and Infrastructure
GPO Box 39, Sydney NSW 2001
Application Number: SSD-95997711
Project Name: 903-921 Bourke Street, Waterloo
Submission Type: Objection
Subject: Technical Objection Regarding Non-Compliance with ADG Solar Access Requirements
To the Planning Secretary,
I am writing to lodge a formal objection to the amended proposal for 903-921 Bourke Street. As the owner-occupier of Apartment 432 at 4 Lachlan Street, I am submitting this objection based on a technical analysis of the Appendix 9E Shadow Report, which indicates an unacceptable and non-compliant impact on the solar access of my residence.
My objection is centered on three technical points:
1. Failure to Meet Apartment Design Guide (ADG) Objective 4A-1
The ADG requires that living rooms and private open spaces of at least 70% of apartments in a building receive a minimum of 2 hours of direct sunlight between 9:00 am and 3:00 pm at the winter solstice.
As a north-facing apartment directly south of the site, my unit currently relies on the midday sun clearing the established 65m height limit. The Shadow Analysis in Appendix 9E shows that the proposed 126m height creates a substantial "additional shadow" plume between 11:30 am and 1:30 pm. By doubling the height, the developer is effectively eliminating my only window of direct solar access. This proposal moves my apartment from a compliant state to a non-compliant state, which is a significant adverse impact.
2. Disproportionate Impact Due to Topography
The Department must account for the specific topography of the Lachlan-Potter Street precinct. Although my apartment is designated as Level 4, it sits at a lower elevation relative to the development site due to the northward upward slope.
From my perspective, the development starts from a higher base, meaning the 126m tower creates a steeper angle of incidence. The shadow diagrams provided in the EIS appear to underestimate the "ground-level" impact on 4 Lachlan Street, where the shadow duration will be longest. I request that the Department require a unit-by-unit solar access study for the northern face of 4 Lachlan Street to verify the exact loss of hours.
3. Inappropriate Scale and Visual Bulk
The jump from 65m to 126m represents a 94% increase in height. This scale is inconsistent with the "stepped" transition typical of sound urban planning for this precinct. The resulting "canyon effect" will not only block direct sun but will significantly reduce ambient sky-light (daylight) for my unit, leading to an increased reliance on artificial lighting and heating, which contradicts the state's sustainability and BASIX objectives.
Closing Request
I urge the Department to reject the proposed 126m height and maintain the previously approved 65m envelope. At a minimum, I request that the tower heights be redistributed or "stepped" away from the southern boundary to ensure that existing residents at 4 Lachlan Street retain their mandatory 2 hours of winter solar access.

I oppose to the proposed major changes to the development plans for 903-921 Bourke Street, Waterloo (SSD-9599771)

The Waterloo-Zetland-Rosebery suburbs are deemed to form the most densely populated area in Australia, yet the proposed development will increase density beyond what it was originally planned with no commensurate measures to alleviate the impacts on residents.

• Infrastructure strain: no mass transport services are planned or even being considered (proposal for a Parramatta Rd - Green Square tram line have been repeatedly overlooked by the State Government). The new metro station in Waterloo West is 15 min walk from the proposed development, providing little relief to the already busy 304 bus line which is already operating at capacity. The proposed development will hence increase the road traffic in an area already surrounded by major roads and heaving congested streets. This has a particular impact on my family as we are trying to promote active ways of transport (bicycle, walking) with my daughters.

• Shortage of amenities: It was very disappoint to note the proposed development will not increase public amenities from what it was originally envisaged. Even acknowledging the conversion into public park of a portion of the Moore Park golf, it is disappointing to see the developers will not have increased obligations to expand the public green spaces within the development or contribute with connecting bicycle paths. Also, the amount of commercial spaces seems to have been kept to a minimum, which will not attract enough pedestrian traffic and will contribute to a 'ghost town' appeal where most residents choose to move by private car. This new development is a great opportunity to amend the mistakes done in the past in what relates to retail availability, where the solution (one big mall with no shop/street frontage) was mainly dictated by the developer with collusion of big retail operator.

• Visually overbearing development: there are at least 5 developments above 20 storey height and many more within the 15 to 20 storey range in the Gadigal Avenue/Eastern side of Waterloo, where the proposed development would seat. A diverse landscape is critical for the appearance and visual amenity of the suburb but the proposed development will delve into the same high rise solution previously imposed, probably because residents are more tolerant to this kind of developments. This is not a fair and equitable allocation of new developments / increase of density where neighbouring suburbs will preserve their appearance and lifestyle at the expense of Waterloo.

I am not against brining more residents to Waterloo. The empty lots are a great opportunity to complete the transformation of the neighbour from a industrial estate to a thriving an liveable suburb and contribute to solve the housing crisis but the State Government needs to come with comprehensive plans to accommodate these and listen to the local community on their claims to improve connectivity/public transport, local amenities and street appeal.

I strongly object to the proposed changes to the to the development plans for 903-921 Bourke Street Waterloo.
As a resident of 98 Morehead Street Waterloo for the last 19 years feel that the proposed changes will be a significant impact to my family, myself and all residents and public using the Waterloo precinct.
I feel that the proposed changes are a major departure from the original approved development.
The development is now significantly larger (higher) than the initial proposed development.
There are issues with overshadowing, wind tunnelling, increased strain on Public transport, lack of truly affordable housing.
All of the proposed changes should be rejected whilst a proper assessment is carried out to ensure a development that is the right development for the future of Waterloo.
I do hope there can be a public hearing to address issues.

Sincerely

David McGuinness

Objection to SSD-95997711 – 903–921 Bourke Street, Waterloo

I wish to formally object to the proposed amendments to the approved development at 903–921 Bourke Street, Waterloo. While I acknowledge the importance of housing supply, this proposal represents an overdevelopment of the site that fails to adequately consider the cumulative impacts on existing residents, infrastructure, and local amenity.

1. Excessive Height and Overdevelopment

The proposed increase in building heights—from 12 to 31 storeys (Bourke Street North) and 21 to 38 storeys (Young Street Tower)—is a substantial departure from the originally approved scheme.

This scale is inconsistent with the established and approved planning controls for the precinct.
It sets a concerning precedent for further overdevelopment in the Waterloo / Zetland / Green Square corridor.
The proposal prioritises density uplift over liveability, without proportional investment in supporting infrastructure.

Impact on residents:
The excessive scale will fundamentally alter the character of the area, creating a dense, high-rise environment that is not aligned with the originally envisaged urban design.

2. Cumulative Density and Infrastructure Strain

The addition of 233 apartments (increasing total to 580), combined with adjacent developments (including 881–885 Bourke Street and others), will result in a significant population surge.

The estimated influx of up to 8,000 new residents across the precinct is not matched by infrastructure upgrades.
Public transport is already operating at or near capacity, particularly:
Bus services such as the 304
Peak-hour congestion at Green Square Station
Road networks and local intersections are already heavily congested.

Impact on lifestyle:
Increased commute times, overcrowding on public transport, and reduced accessibility will directly diminish day-to-day quality of life for existing residents.

3. Inadequate Parking Provision

The proposal includes only 20 additional parking spaces for 233 new apartments.

This is clearly insufficient and will result in increased demand for on-street parking.
Existing residents already face parking constraints.

Impact on residents:
Greater competition for parking will increase frustration, reduce convenience, and potentially impact emergency and service vehicle access.

4. Insufficient Community and Public Amenities

The proposal fails to demonstrate how essential services and amenities will scale with population growth.

Existing facilities such as libraries, parks, childcare centres, and healthcare services are already under pressure.
There is no clear commitment to expanding community infrastructure in line with demand.

Impact on lifestyle:
Reduced access to public amenities, overcrowded facilities, and diminished community experience.

5. Overshadowing and Loss of Natural Light

The increased height and bulk of the proposed towers will result in significant overshadowing.

Impacts will be particularly pronounced during winter months.
Nearby residential apartments and public open spaces will experience reduced sunlight access.

Impact on my apartment:

Loss of natural light reduces amenity, comfort, and energy efficiency.
Overshadowing negatively affects wellbeing and livability.
6. Visual Bulk and Streetscape Impact

The proposed towers are visually dominant and out of character with the surrounding built environment.

The development will create a “wall effect” along key streets.
It undermines the intended urban design balance of the precinct.

Impact on neighbourhood character:
A loss of visual openness and increased sense of overcrowding.

7. Wind Tunnel and Pedestrian Safety Risks

Buildings of this scale can significantly alter wind patterns at street level.

Increased downdrafts and wind tunnelling may occur.
This creates safety risks for pedestrians, cyclists, and outdoor dining areas.

Impact on lifestyle:
Reduced comfort and usability of public spaces, discouraging outdoor activity and community interaction.

8. Noise, Construction and Ongoing Disruption

Given the scale of the proposal:

Extended construction timelines will result in prolonged noise, dust, and disruption.
Increased population density will lead to higher ongoing ambient noise levels.

Impact on residents:
Diminished residential amenity both during construction and long term.

9. Impact on Property Value and Future Saleability

The proposal may negatively impact property values and future resale prospects.

Oversupply of high-density apartments in the immediate area could suppress property prices.
Reduced amenity (light, space, congestion) makes existing apartments less attractive to buyers.
Perceived overdevelopment may deter future purchasers.

Personal impact:
This represents a direct financial risk to existing property owners who invested based on the originally approved planning framework.

10. Precedent and Planning Integrity

Approving such a significant uplift:

Undermines confidence in the planning system.
Signals that approved developments can be substantially altered without adequate regard for existing residents.
Conclusion

This proposal represents an overdevelopment of the site that prioritises density over liveability, infrastructure capacity, and community wellbeing.

I respectfully request that the NSW Government:

Reject the proposed amendments; or
Require substantial revisions to reduce height, density, and impacts; and
Ensure infrastructure and community services are upgraded in line with any future development.

Hello,
I DO NOT support additional floor space on the referenced development, however DO support the overall project. I believe your online form leads to confusion and is intentionally cumbersome for community members. My comment is obviously cynical due to the frustration of this process and the seemingly purposefully challenging aspect of setting up an account and submitting an objection.
Please find attached my letter outlining my objection to the referenced project uplift.
I would welcome response to my website comments and the core of this objection.