My objection to this project is primarily based on the issue of traffic management in Rose Bay and the surrounding suburbs. Rose Bay is only accessible to the rest of the state by two roads, New south head road via Double Bay and Old south head road via Bondi.

The suburb already suffers from significant traffic problems particular during school drop off hours 7:30-9:30am and school pickup hours 2:30pm-4:30pm. One can observe the severity of this issue on any school day between these critical peak hours on either of these roads or the roads that connect them (e.g. Dover Road). During peak hours, it can take an hour to get from Rose Bay to the heavy rail stations Bondi Junction or Edgecliff. These stations are just 3km away!

Given that this infield development and the numerous other similar proposed developments in the area are not supported by infrastructure investment to improve traffic congestion and that there is not a single major road project targeted at solving this issue nor is there a government policy aimed a reducing the number of cars on the road. How are existing residents as well as all of the new residents going to get from their homes to their places of work? How are people who don’t live in the area but work in the area supposed to get from their homes to Rose Bay?

The panel must consider the aggregate detrimental affect of the multiple proposed developments in Rose Bay and surrounding suburbs on traffic congestion in the area particularly where the government is not providing supporting infrastructure. Rose Bay is not a transport oriented development precinct and can not sustain such significant levels of growth.

Developers are targeting Suburbs like Rose Bay because the average off the plan apartment price in this area is significantly above the comparable price in other suburbs in NSW, adding small number of ‘affordable’ apartments to the development as a box ticking exercise to satisfy government policy requirements, these ‘affordable’ homes are unlikely to be affordable to most people in NSW. These developments are simply lining the pockets of big business and developers. How do these developments solve the issue of affordable housing to the people of NSW who need it?

Please refer to the attached submission objecting to residential development with in-fill affordable housing - 23-31 Dover Road, Rose Bay

This notification is SUPPLEMENTARY to the Submission previously lodged. The EP&A Act 1979 Instrument of Delegation from the Minister to various Delegatees (within NSW Planning) dated 15 December 2024 has just come to my attention. It covers the delegation of the function of determining development applications for State Significant Development under section 4.38 of the Act. The existence of this delegation has not been publicised and it seems to contradict the information contained on the NSW Planning and IPC websites.
The Submission previously lodged requested that determination of this SSDA be referred to the Independent Planning Commission for independent determination. This Supplementary Submission reaffirms that request even moreso, given the existence of the 15 December 2024 delegation that seems to diminish the importance placed upon community well-informed participation in this process. Again this delegation has raised the number of required objections to over 100 (before the Planning Secretary needs to be involved) and seems to obliterate any objection that might be lodged by Woollahra Council (by subjecting it to an "opinion" formed). This again erodes natural justice and procedural fairmess in this planning process and that is not in the public interest. Again, I tried to attach a copy of the Delegation but the Portal declined my attempt to attach it on the basis that it had too many words. This is very frustrating and reinforces the point in the Submission that the portal is not user friendly. This is very unsatisfactory. Despite this, the previously lodged submission is affirmed.

Please refer to my objections regarding the development .

I object to SSD-86017721 as key impacts do not yet appear demonstrated as manageable or in the public interest. The proposal introduces an eight-storey building, removes 27 mature trees and increases density, traffic, excavation and stormwater load, yet no cumulative modelling has been provided to show Rose Bay can absorb this alongside the substantial redevelopment pipeline created by recent LMR reforms, which is already material and expected to continue. Although the proposal meets LMR requirements by providing 11 affordable dwellings for 15 years, this is a temporary benefit against permanent environmental and infrastructure impact. There also appears to be no transparent hazard classification, and groundwater/ASS risk remains unresolved. Based on my understanding, s4.15 still requires cumulative impact and public interest assessment even under LMR reform. Given the high private value of redevelopment in this location, evidence-based oversight appears essential. I request refusal unless cumulative impact, risk controls and public benefit can be clearly demonstrated.

Submission – Objection to SSD Application for 23–31 Dover Road, Rose Bay

To whom it may concern,

I am a long-term resident of the Rose Bay and Vaucluse area and am writing as a concerned local community member who uses Dover Road on a daily basis. I am familiar with this part of Rose Bay and, while I appreciate the need for more housing in Sydney, I am very concerned that this particular proposal is far beyond what this site and surrounding streets can safely accommodate.
My comments focus on the issues that are most obvious to me as a local resident: traffic and access, cumulative development pressures, flood and groundwater risks, and the scale of excavation proposed for a site that already has known geotechnical constraints.

1. Traffic, Access and Cumulative Impacts
Anyone who lives in the eastern suburbs knows that our local road network is extremely limited. Dover Road in particular carries school traffic, buses, pedestrians, construction vehicles and local cars throughout the day. Even small developments can have a noticeable effect here; a development of this size will have a major one.

What concerns me most is that the traffic assessment appears to treat this building in isolation, rather than as one of many developments happening at the same time in this small pocket of Rose Bay. There are multiple LMR sites under construction or proposed in the area, as well as at least three large-scale State Significant Developments, including this one. All of these will ultimately funnel into the same constrained intersections.

The Transport Impact Assessment for this project seems optimistic about the capacity of the road network and does not reflect the level of congestion locals already face — particularly during school pick-up and drop-off times, on weekends, and whenever there is construction activity. Simple trips regularly bank up along Dover Road and Old South Head Road even without major works occurring.

Construction traffic is another major concern. Excavating two full basement levels will involve removing a very large amount of earth, which means months of continuous truck movements along a narrow road that already struggles with visibility and parking. The Preliminary Construction Traffic Management Plan is extremely light on detail for a development of this magnitude.
Without a traffic study that looks realistically at the combined effect of all current and proposed developments in this part of Rose Bay, I do not see how the impacts of this building can be properly assessed.

2. Flood Risk and Emergency Access
After reading the Flood Impact and Risk Assessment (FIRA), I was genuinely shocked at how serious the flood conditions are on this site. The study shows that this part of Dover Road acts as a floodway in storms, with water flowing directly across the road and over the site in major events. The predicted depths and the speed of water movement are significant enough that evacuation is considered unsafe.

The recommendation for residents to “shelter in place” during a flood event is deeply concerning. For a building of this size, with basements, underground car parking and lifts, this seems like an unacceptable risk. Water can move through this area quickly in heavy rain, and we have had unpredictable storm events and flash flooding in Rose Bay in the past. Adding a large basement structure into a mapped floodway feels fundamentally at odds with public safety.

I also note that adding a deep basement can change how water flows across a site. This is not properly considered in the EIS. There is also no meaningful assessment of how a structure of this scale might redirect or worsen overland flow for nearby homes, particularly those on the lower-lying parts of Wilberforce Avenue.

This is an issue that cannot be dismissed, and from my reading, it has not been addressed adequately.

3. Groundwater, Dewatering and Excavation Risks

The documents acknowledge that groundwater is present across the site and that the proposed basement will extend into these saturated soils. The Dewatering Management Plan appears to assume that long-term pumping and impermeable walls will resolve the issue. However, there is little explanation of how surrounding homes will be protected from settlement, groundwater drawdown or changes in soil moisture.

The local area has a mix of older homes, duplexes and small apartment buildings — many of which were not designed with deep excavation next door in mind. The Geotechnical Report identifies layers of fill and loose alluvial material above rock, which is exactly the type of soil profile that can be destabilised by large changes in groundwater conditions.

What stands out to me is that there is no cumulative analysis. With so many other basement projects within a few blocks, the combined effect on groundwater has been completely overlooked. Water does not respect property boundaries, and treating each development as an isolated event is unrealistic and potentially unsafe.

For a site already identified as flood-affected and groundwater-constrained, the scale of excavation proposed feels excessive.

4. Noise, Vibration and Construction Impacts

The Noise and Vibration Assessment acknowledges that excavation will involve rock breaking, piling and other high-impact activities. Many homes surrounding the site are older or lightweight construction, and even minor vibration can cause cracking. The mitigation measures seem generic rather than site-specific and rely heavily on monitoring rather than prevention.
Given the density of existing housing around this site, construction impacts will be felt intensely by neighbours for an extended period. This is something that residents should not be expected to simply absorb without stronger and more reliable safeguards.

5. Scale, Height and Tree Loss

This part of Rose Bay has always been a low- to mid-rise area with a more modest built form. The jump to an eight-storey building is enormous and will fundamentally change the feel and amenity of Dover Road and Wilberforce Avenue. The visual impact diagrams show how dominating the building would be relative to nearby houses and are jarring in appearance even on paper.

The loss of mature trees is also concerning. Larger established trees take decades to regrow and play an important role in shade, cooling and stormwater absorption — particularly in a street with known flooding issues. Replacing them with smaller podium-level planting is not equivalent in function or environmental benefit.

Conclusion

I understand the need for well-designed housing and I am not opposed to redevelopment on this site. However, in its current form, this proposal is too large, too intensive and too risky for a location with known flooding, groundwater and traffic constraints. For these reasons, I respectfully object to the development in its current form.

I would be open to supporting a smaller and more appropriate-scale building, provided that any future proposal is accompanied by thorough and transparent assessments of traffic, groundwater, dewatering, flood behaviour, stormwater capacity and cumulative impacts. Importantly, these assessments need to consider all other current, approved and proposed developments in Rose Bay, so that the combined load on local infrastructure, the road network and the surrounding environment is properly understood.