See attachment.

I am concerned about the size of this project, the impact on the local streets and the sunlight that will be blocked by the increased size of the building. The project also does not go far enough to provide affordable housing. I would like a review of the application and the impact it will have of those who live adjacent to it.

I support the project

Hi there, I would like to highlight the importance of providing a future home for businesses that make use of the existing space at Marlborough House. Many of these businesses are creative in nature (photography studios, graphic designers and similar). As a nearby resident I do not object to the redevelopment of Marlborough House, including making it bigger and enabling more people to reside in the area. However I see no references in the project materials that pre-existing businesses will have the option to move back into Marlborough House after the redevelopment is complete. These already exist because of Surry Hill's proximity to the city and Central Station. They bring workers into Surry Hills and subsequently provide income for cafes and similar retail businesses. A project that changes Marlborough House to residential and ground-floor retail only will reduce the total supply of space for these businesses, reduce the total economic activity of the suburb and make it less diverse and distinct. Please change the project to provide greater allowance for non-retail businesses.

10 June 2026

Minister for Planning and Public Spaces
c/ Department of Planning, Housing and Infrastructure
Locked Bag 5022
PARRAMATTA NSW 2124

Attention: Ritu Shankar

Submission – Strata Manager Representation
47 – 97 Marlborough Street, Surry Hills
Application Number SSD-78545225

We write in our capacity as Strata Manager representing the Owners Corporation of Edgeview Apartments )508-528 Riley Street Surry Hills), directly adjoining the subject site.
This submission focuses specifically on strata management, asset protection, and long-term operational impacts arising from the proposed development.
________________________________________
1. Asset Protection and Risk to Existing Strata Buildings
The proposed development presents material risks to Edgeview Apartments, particularly during construction.
Technical documentation confirms:
• Extensive excavation (approximately 26–29 metres),
• Groundwater drawdown and associated settlement risks, and
• The need for further structural assessment of adjoining properties.
However, there is no resolved or coordinated methodology demonstrating how these risks will be managed in practice.
From a strata management perspective, this raises significant concerns regarding:
• Structural movement and damage to existing buildings,
• Impacts on waterproofing systems and building services,
• Future defect attribution and dispute resolution, and
• Insurance and liability exposure for the Owners Corporation.
It is essential that these risks are fully assessed by the design team including appropriate independent peer reviews prior to determination, rather than deferred to post-approval stages.
________________________________________
2. Inconsistency in Building Definition and Its Impact on Strata Outcomes
There is a lack of clarity and consistency across the documentation regarding:
• Number of storeys and levels – ranging from an additional 4 storeys in words to 7 storeys on the drawings,
• Inclusion of ground, rooftop, and plant levels, and
• The overall building envelope.
While some documents refer to “9 levels,” others indicate a built form incorporating additional levels, rooftop structures and plant, resulting in a significantly larger development.
From a strata perspective, this inconsistency has direct implications for:
• Understanding overlooking and privacy impacts,
• Assessing building dominance and proximity, and
• Determining future maintenance and access constraints along shared boundaries.
Clear and consistent definition of the built form is critical to enable proper assessment of impacts on Edgeview Apartments.
________________________________________
3. Construction Interface with Edgeview Apartments
The proposal does not adequately address how construction will be managed at the interface with Edgeview Apartments.
Key issues include:
• Lack of detail regarding boundary treatments during construction,
• Potential need for underpinning of Edgeview Apartments,
• Unclear arrangements for crane operations, access, and protection zones, and
• Limited strategy for managing impacts such as vibration, noise, dust, and access disruption over an extended construction period.
For an occupied strata building, these issues directly affect:
• Resident safety and amenity,
• Access to units and common property, and
• Ongoing building operation during construction.
A detailed, site-specific construction management methodology is required to mitigate these risks prior to determination.
________________________________________
4. Ongoing Operational Impacts on Adjoining Strata
Beyond construction, the proposal introduces long-term operational impacts that will affect neighbouring strata buildings:
• Increased overlooking and reduced privacy due to proximity of building elements,
• Potential security risks associated with separation distances and accessibility between buildings, and
• Reduced access to daylight and outlook, impacting liveability and property value.
These impacts also affect the Owners Corporation’s responsibilities in managing:
• Resident complaints and disputes,
• Security measures and upgrades, and
• Ongoing maintenance and mitigation works.
________________________________________
5. Reliance on External Conditions and Strata Implications
The documentation indicates that the development relies on adjoining properties, including Edgeview Apartments, to achieve outcomes relating to:
• Daylight access,
• Building separation, and
• Environmental performance.
From a strata perspective, this is inappropriate, as:
• The Owners Corporation has no control over how its property is relied upon,
• Future changes to adjoining sites could compromise the development’s performance, and
• This creates ongoing interdependency between unrelated properties, which is not acceptable in a well-resolved design.
A development must function independently within its own site to avoid long-term operational and legal complications.
________________________________________
6. Lack of Design Resolution and Implications for Future Management
The proposal appears to defer key design elements, including:
• Building services and plant locations,
• Final façade treatments and separations, and
• Construction methodology.
For strata management, this presents a high-risk scenario where:
• Impacts are not fully understood at approval stage,
• Future changes may intensify impacts on adjoining properties, and
• There is limited ability for neighbouring Owners Corporations to respond.
A development of this scale should be fully resolved prior to application for approval, particularly where it directly interfaces with existing residential strata buildings.
________________________________________
7. Apparent Reliance on Edgeview Boundary Walls for Separation and Servicing Outcomes
The available plans indicate a further concern regarding apparent reliance on Edgeview Apartments’ boundary walls to achieve separation and servicing outcomes along the western boundary.
The plans indicate:
• A loading dock and new greenway entry located along the western boundary,
• A boundary interface that appears to rely on existing Edgeview wall conditions, and
• Insufficient evidence that the proposal provides its own fully self-contained separation and servicing solution within the subject site.
• Loading dock operations,
• Western access and greenway interface arrangements, and
• Boundary separation and servicing outcomes.
• Whether the illustrated truck turning circle can operate wholly within the site,
• Whether the loading dock can function if proper independent walling is required, and
• Future dispute, operational and liability risks if Edgeview Apartments’ building fabric is treated as part of another development’s design solution.
The applicant should therefore be required to demonstrate, through revised plans and swept path analysis where relevant, that the proposal can operate lawfully and safely within its own boundaries without reliance on Edgeview Apartments’ walls or adjoining property conditions.
________________________________________
8. Security Risk to Edgeview Apartments Arising from the Greenway Interface
The survey material and landscape plans raise a further concern regarding security risk to Edgeview Apartments arising from the proposed Greenway interface.
The plans indicate:
• A new greenway entry and public-facing landscape treatment along the western boundary,
• Existing levels and boundary wall conditions recorded in the survey at that same interface, and
• A more accessible pedestrian edge immediately adjoining Edgeview Apartments.
From a strata management perspective, this raises concern that the Greenway may reduce the effective separation presently afforded to Edgeview Apartments and create additional opportunities for:
• Approach to boundary walls,
• Climbing or overlooking,
• Unauthorised access or intrusion, and
• Ongoing building security and resident safety issues.
For an existing residential strata building, this is not a minor design issue. It may result in additional obligations for the Owners Corporation in managing:
• Additional surveillance or monitoring,
• Lighting, fencing or access control upgrades, and
• Future resident complaints, security incidents and management burden.
The applicant should therefore be required to provide a specific assessment of Greenway-related security impacts on Edgeview Apartments, including the effect of finished levels, boundary wall differentials and opportunities for unauthorised access along the western boundary. In the absence of that analysis, the security risk to Edgeview Apartments remains insufficiently assessed and unresolved.
________________________________________
9. Conclusion
From a strata management perspective, the proposal presents:
• Unresolved structural and construction risks,
• Lack of clarity regarding building height and scale,
• Inadequate consideration of construction interface with adjoining buildings,
• Material loss of significant northern views currently enjoyed from Edgeview Apartments, including views toward the SCG and Allianz Stadium,
• Insufficient recognition of the combined impact of reduced solar amenity, daylight loss and diminished residential liveability for adjoining apartments,
• Apparent design reliance on Edgeview Apartments’ existing boundary walls to achieve separation and servicing outcomes for the loading dock and western greenway entry,
• Insufficient assessment of security risk to Edgeview Apartments arising from the Greenway interface, including the implications of levels and boundary conditions along the western side, and
• Ongoing operational, amenity and legal risks arising from reliance on neighbouring properties.
These issues create significant uncertainty and potential long-term impacts for adjoining Owners Corporations. In particular, the proposal does not adequately recognise or respond to the practical consequences for Edgeview Apartments of losing important northern outlooks and experie

I, Leighton Waterworth of Edgeview, 504/508 Riley Street, object to this development (SSD-78545225, Marlborough House).

My main concerns are:
Traffic:  I'm seriously concerned about the impact additional vehicles for the Marlborough House development will have on the surrounding area. Over 150 cars in and out through a narrow one way driveway on Lansdowne Street will clog our streets and make them less safe. 
The high density built-up neighbourhood is already at maximum capacity within tight, narrow one way streets. This is already problematic and dangerous to access, especially for emergency services such as ambulances & fire brigade who regularly attend incidents in our area. In one instance, I observed an ambulance that was trapped due to vehicles blocking it from all sides within the narrow one way street. Adding further pressure with the addition of 150 vehicles from the Marlborough House development will create dangerous congestion to an already over populated area. 
Excavation: I'm worried about the deep excavation so close to neighbouring buildings, and how it could damage or undermine nearby homes and structures. 
I'm deeply concerned that major excavations required to create a six level underground car park plus demolition works to remove hard rock, rubble, and concrete will structurally damage our heritage Edgeview building. 
Massive deep vibrations resulting from the excavation works penetrating & undermining the structural foundations of our heritage building could create the potential for another Mascot Tower situation, which left those owners legally bound to a building that was deemed unsafe and uninsurable. There is no assurance that any impact on our building caused by the Marlborough House development will be satisfactorily addressed.
Privacy: The height and closeness of the building means it overlooks existing homes and apartments.
Noise: As well as the loss of privacy, the proposed Marlborough House balconies overlooking west facing Edgeview apartments and the communal rooftop, will contribute to ongoing noise pollution by amplifying and ricocheting sounds in an already high density area. In addition to the years of deep excavation and construction, plus the extra cars and mechanical car lifts once completed, which will mean a lot more noise for neighbours.
I have communicated with Jonathan Hannen-Williams and Mel Chandler. I encourage the Department to respond to their submissions, which cover a lot of the detail.

Yours sincerely,
Leighton Waterworth

Marlborough House Development Proposal, Surry Hills SSD-785455225
Notes prepared by Anna Fraser, Owner-Occupier of 38 Marlborough Street Surry Hills for NSW Government Development proposal of Marlborough House.
There are a number of issues associated with the proposed development that will impact our dwelling and our ambient environs. The most important factor is our property has not been included in the assessment from Pulse White when there will clearly be significant impacts from numerous components, that has been addressed in the Pulse White report connected to the Major Works Proposal SSD-785455225. A revision of the report would need to reflect that 38 Marlborough St is directly impacted and a property that should be included in further impact studies and conditions associated with the drafting of an acceptable construction certificate for works to proceed with considerations for residents and their environs.
Factors of significance to us as Owner-Occupiers include:
• Off-site/environmental impact from noise and vibrations
• Erosion of infrastructure – damage to roads by construction, development and heavy vehicle services
• Vehicle accessibility and parking availability
• On-site building works noise and vibrations (refer to highlighted impact queries in Pulse White report extracts below)
Please find below comments voicing our concerns as residents regarding noise and vibration impact to our property and place of residence for the first three factors:
- The site proposed for development is within 50m of our dwelling, diagonally across the road from our house which is situated opposite Ward Park. It is the second house up from the corner of Landsdowne and Marlborough Streets, with one other property between us and the corner. We have lived at this property for 17 years and are fully aware of the round-the-clock ambient noise that occurs on any given day of the week.
- Additionally, we are astute to the detrimental impact of infrastructure development, such as road and footpath upgrades and other utility investigations and maintenance, that has occurred to our dwelling in recent years. This is in part due to the nature of the construction of historic houses in the area (ours dating from 1892 and many in the adjacent streets constructed in the 1890’s). The houses are built on clay bases and have no structural foundations therefore the buildings are very susceptible to environmental changes, i.e. seasonal and changing ground water conditions, causing shifts in structural footing and internal and external cracks in our dwelling (and other structures on the same axis along Marlborough Street) have presented and are of ongoing concern.
- It is evident that many of the roads and footpaths around our house and at the top of Lansdowne Street on this same axis are sitting on top of empty cavities, where much of the ground soil has eroded away over time. Many sink hole type pockets in the road and footpaths have been repatched in recent years but the underlying issue beneath the tarmac still remains the significant issue particularly in the absorption of intense vibrations from construction and increased/heavy vehicle use.
- More recent resurfacing of our section of Marlborough Street (from Lansdowne to the tram line on Devonshire Street), due to the use of heavy machinery and drilling equipment creating extensive subterranean vibrations, has caused significant cracks in our adjoining walls which have continued to widen. With empty cavities under the road and paths and no ground soil of absorb some of the impact of the construction works’ vibrations, the walls of our house and many other in the immediate are severely compromised. We have a report from our structural engineer, issued within the last 5 years, which can be provided to support the implications of intensive and extended vibrations and its impact on our dwelling.
- Additionally, the access roads have not been deemed an area of impact and have not been included in the report provide by Pulse White Noise and should be included in the above development proposal. With very limited access to our property (due to the tram infrastructure) and the establishment of a dead end we have concerns about the increased level of traffic, heavy vehicles, reduced access to already limited parking and general access to our property when construction commences. Access roads to the site and our property is via small one-way streets and planned road closures would greatly impact our ability to access our property and park within a reasonable accessible distance to our dwelling. NB: The City of Sydney and their recent developments in our street and around the park continue to reduce accessible parking and many terraces don’t have offsite parking to utilise as an alternative.

Please see attached document which includes highlighted queries and concerns regarding the boundaries of impact and other points relating to the factors stipulated above.

I am the owner of Apartment 905 at 508 Riley Street, located directly adjacent to the proposed Marlborough House redevelopment site. I strongly object to this proposal in its current form due to significant impacts on my apartment. Key impacts include loss of outlook, reduced privacy, potential overshadowing, degradation of shared amenities, increased traffic and security risk, construction impacts, and direct financial loss as I purchased this apartment based on existing conditions. The proposal introduces a material adverse change, effectively transferring value from existing owners to the developer. I request substantial redesign or refusal of the application.
1. Context and Reliance on Existing Conditions
I purchased Apartment 905 as an investment property based on the existing built form, which provided outlook, privacy, and a balanced urban scale. The proposal introduces increased height and density, creating a material departure from existing conditions relied upon at purchase.
2. Overshadowing and Solar Impact
The solar analysis does not clearly assess impacts to Edgeview or my Level 9 apartment. I am concerned about reduced afternoon sunlight and diminished amenity to living areas and shared facilities.
3. Privacy and Overlooking
The proposal introduces numerous balconies and windows facing Edgeview. This will result in direct overlooking, reducing privacy and comfort for my apartment.
4. Visual Bulk and Outlook
The increased building height and proximity will reduce openness and alter the outlook from my Level 9 apartment, impacting both amenity and perceived value.
5. Financial Impact
As an investment property, the value depends on light, outlook and privacy. The proposal risks reduced rental returns, higher vacancy, and downward pressure on capital value.
6. Traffic and Access
The increase in vehicle movements will impact access and congestion in the surrounding one-way street network.
7. Security
Design elements along the boundary introduce potential security risks and reduced separation between buildings.
8. Construction and Structural Risk
Deep excavation poses risks to nearby structures. Greater clarity on mitigation measures is required.
9. Noise Impacts
Construction noise and ongoing activity post-completion will impact amenity and tenant appeal.
10. Consultation
Documentation is complex and lacks clear articulation of impacts to Edgeview. Consultation has not been meaningful for directly affected residents.
11. Fairness and Planning Certainty
The proposal introduces adverse changes not anticipated at purchase, disproportionately impacting existing owners.
12. Request
I request reduction in scale, improved setbacks, better privacy and solar protections, and resolution of traffic, security and structural risks. If impacts cannot be mitigated, the application should be refused.
Conclusion
While redevelopment is supported in principle, this proposal imposes significant and unfair impacts on neighbouring properties and requires substantial revision.

I, Suzanne Riley of 76 Marlborough St Surry Hills, request modifications to this development (SSD-78545225, Marlborough House).

My house (76 Marlborough Street, Surry Hills) is located in very close proximity to the proposed development and clearly within the Affected Properties Zone. I will be significantly impacted by changes to residential amenity, parking, noise and traffic conditions that are likely to occur if the proposed development is approved in its current format.

I purchased my property and have greatly enjoyed living in Marlborough Street Surry Hills for 10 years. Of particular appeal to me about my Marlborough Street location was the one way street with the perfect mix of residential and appropriate commercial properties. It is a street that has always felt safe with respectful neighbours, minimal traffic and noise disturbances and has a great sense of community fostered by the local residents. I have significant concerns that the development proposal in its current form will cause significant negative impacts on residential amenity

I envisage that there will be regular and significant disruption to myself and fellow residents during the construction phase as we who need to function and work (many of us work from home). Construction and particularly deep excavation noise for years is not something anyone would choose to live near and we are especially concerned as we have a newborn baby.

I had hoped that appropriate Community Consultation would occur and that resident’s concerns would be legitimately discussed. I had hoped that the development would add to the current amenity the surrounding residents enjoy and that during the construction period impacts on surrounding residents would be minimised.

I'm not against new housing, especially affordable housing. But this proposal has many flaws and I do not believe that genuine community consultation has occurred.

I attended the first community consultation session run by Brilliant Logic and attended by Time & Place. I found the promised follow-up information and documentation provided after the meeting to be inadequate and/or non existent. When I tried to RSVP to the second community consultation session I was told via email by Tess: “Thank you for getting in touch and for your interest in joining the focus group. Unfortunately, we are at capacity at this time. We keep focus groups intentionally at a set number, so we can capture feedback from all attendees and allow enough time for everyone to have their say”. You would assume for a project of this magnitude, an extra few spots could be made available for directly impacted residents (I own and occupy a terrace directly across the street - 76 Marlborough St, Surry Hills).

Additionally, the Developers gave affected residents only two weeks to get on top of 3,500 pages of information, this seems quite unfair.

My main concerns are centred around the following topics:

Overshadowing: It will block sunlight to nearby homes and gardens. I do not believe the analysis done covers everyone affected. I personally know neighbours who have back gardens that currently get plenty of afternoon sun that this building would take away. Other neighbours back gardens will lose sunlight as well as their main living areas and bedrooms. Some of this could be avoided if a design that respected solar guidelines was chosen rather than the current design which puts commercial yield above retaining current residential amenity for existing residents.

Traffic:

The streets providing vehicular access to the proposed development are narrow and residential. In fact, it has been communicated to us previously by City of Sydney Council that Marlborough Street is/was a designated ‘bicycle street’. There is a high volume of pedestrian activity, including children walking to and from school, parents pushing their small children in prams to the nearby daycare centre and residents walking their dogs to Ward Park. There are also a large number of vulnerable people who use Marlborough Street to walk to Coles, some on walkers or with disabilities. The streets are already under stress from traffic (evidence of this is that the white lines at the junction of Lansdowne and Marlborough need repainting every 6 months).

It is now a regular occurrence that at peak times cars are backed up all the way up Marlborough Street, Goodlet Street and Landsdowne Street as they queue at the light trying to turn onto Cleveland Street. The noise from the constant beeping of horns from disgruntled drivers is already extremely intrusive to residents. The current proposal will increase the number of staff and patron vehicles further adding to the already considerable traffic issues. On top of that, it will increase the number of heavy vehicles such as garbage and delivery trucks, and consequently increase wear and tear on roads and reduce pedestrian amenity.

Over 150 cars in and out through one narrow driveway on Lansdowne Street will clog our streets and make them less safe. I have deep concerns about the safety of my small child and others who use Marlborough Street and the surrounding streets to get to daycare and school.

The underground car parking proposed is by a mechanical stacker, not by a driver going down a ramp. There are 174 parking spaces, and so if this is to operate during peak periods there is very likely to be traffic jams at Lansdowne and Marlborough Streets caused by drivers queuing to access the stacker. It is currently very unclear if there will be more than one entry for stacker.

Parking: It is my regular experience that despite having an Area 18 Parking permit, it is extremely difficult to find parking spots in the blocks north of the development site, up to Devonshire Street and across to High Holborn Street. There are regularly no spaces available for residents with Area 18 permits. Cars without Area 18 permits consistently park for longer than the 1hr time limit. I often have to do multiple laps of the surrounding streets to secure a car spot (and I have a very small car that can fit into even the tiniest of car spot gaps) and it is not uncommon for me and other residents spending over 30 minutes driving around the streets trying to secure a spot during peak times. Adding additional parking pressure from those visiting the new residents of the proposed development will only exacerbate the existing problems with insufficient parking that residents are already regularly experiencing.

In addition I am concerned about construction vehicles blocking Marlborough Street or Goodlet Lane, which are already narrow and heavily used, garbage collection trucks arriving in early hours, creating loud disturbances and the overflow parking new resident visitors who stay beyond time limits and without permits

Affordable Housing Issues: The proposed affordable housing units in the project will not meet the standards for light and ventilation. But these units justify a 30% increase in the floor space and thus allow for two new towers at the north end of the site, one of 11 floors and one of 12 floors. Therefore this makes the project an over development for the site.

Privacy: The height and closeness of the building means it overlooks existing homes and apartments. For me and my neighbours on Marlborough Street, there will be people sitting on balconies across the street, looking into our front bedrooms.

Noise: Years of deep excavation and construction, plus the extra cars and mechanical car lifts afterwards, will mean a lot more noise for neighbours. I would like more details about how the noise concerns will be managed and what steps will be taken to ensure no structural damage happens to neighbouring properties.

Excavation: I'm worried about the deep excavation so close to neighbouring buildings, and how it could damage or undermine nearby homes and structures. We are concerned on the lack of professional structural engineers information on impact on the heritage buildings. There is no engineering study about the impact of this excavation on the structure of our homes, or on the structure of the existing Marlborough House. I urge you to ensure that these engendering assessments are conducted and shared with impacted residents as well as plans for how our homes will be remediated should damage be caused during the construction period.

I have communicated with Jonathan Hannen-Williams and Mel Chandler. I encourage the Department to respond to their submissions, which cover a lot of the detail

I object to the project in its current format and ask that the Department scale back the development to reduce the impact across all of the areas I mentioned in my submission.

I strongly urge the Department to carefully consider the cumulative impact this development will have on the day-to-day lives of nearby residents. While I support local improvements and thoughtful development, it must not come at the cost of residential amenity and safety.

Thank you for taking note of these concerns. Surry Hills is a wonderful place to live because of the well-balanced mix of residential and business amenity. To maintain this positive community, and fair use, I request that the Department carefully evaluates the impact of this development as it stands to ensure that the day-to-day lives of nearby residents are not adversely affected. I appreciate the opportunity to provide input.

Please provide me with confirmation of receipt and inclusion of this objection in the assessment process and kindly advise of the dates and next steps in the process.

Kind regards,

Suzanne Riley
76 Marlborough Street, Surry Hills
0414 462 323
[email protected]