My issues in objecting to the proposal , as advised
Bulk and Scale
o Although the proposed development complies with the Floor Space Ratio (FSR) standard under Clause 16 of the Housing SEPP, compliance with FSR does not determine whether the bulk and scale of the development are acceptable. FSR only regulates the quantity of floor area; it does not regulate the form, distribution, or amenity impacts of that floor area.
o The consent authority must assess the likely environmental impacts of the development, including visual bulk, scale, dominance, interface relationships, view loss, and sense of enclosure. These considerations operate independently of FSR compliance.
o The Land and Environment Court recognises that buildings with compliant FSR can still be unacceptable on planning merit where their bulk and scale are inappropriate in context. Numerical compliance does not resole unreasonable visual impacts or interface failures.
o The extent of vertical massing, combined with the exceedance of even the bonus 22.75 metre height standard, indicates that the proposed built form cannot reasonably be accommodated within an envelope appropriate for this location. Achieving compliance would require removal or substantial redesign of upper levels rather than minor refinements, demonstrating that the proposal represents overdevelopment rather than a marginal variation.
o The upper levels also contain substantial built elements excluded from the GFA calculation but which contribute materially to perceived bulk, including lift shafts and the lift over-run, rooftop plant, hot water systems, communal corridors and stair structures.
View Loss
* its appears there will be significant view loss toward the harbour to a number of properties, ultimate impact on surrounding property values and adding significant shading.
Construction impacts
* the noise and traffic disruption to the neighbourhood will be significant.
• Extensive excavation to create the basement carpark, and the weight it will need to support. The carpark will extend across most of the land, including right up to Bloxsome Lane, hollowing out a substantial area of sandstone.
o The two-level basement carpark will be below both Bloxsome Lane and Rangers Avenue. The other side of Rangers Avenue is a cliff face.
o Excavation near a cliff can destablise the slope, causing rockfall or progressive landslip, and threaten the public road and neighbouring properties.
o Sandstone is a highly porous rock, and water ingress will increase the risk of flooding, landslides and structural instability.
o Based on historical records, there was a waterfall very close to the proposed development on Rangers Avenue, suggesting the area is a natural path for water, again increasing the risk of instability
• Site excavation raises significant concerns regarding damage to neighbouring properties and public safety
• The proposed development will include 2.5 basement levels which will contain parking spaces, waste storage, plant and services.
• According to the Environmental Impact Assessment (EIS), excavation for the proposed basement carpark for the site would be to an approximate depth of 10m. Based on the site plan, the basement carpark would cover the majority of the proposed site, which is 3,594 sqm.
• Based on our review, none of the applicant’s documents include an estimate of the volume of sandstone, rock and soil that would need to be excavated. However, a back-of-the-envelope estimate based on 3,000sqm by 10m would result in 30,000 cubic metres of sandstone, rock and soil.
• The scope of Appendix S - Geotechnical report is noted to be as agreed between the provider of the report and the client, Mike Armstrong. Keeping the scope hidden means that anyone reviewing the report cannot determine its limitations. Further, the scope of the report appears not to include damage to near neighbour's homes, the potential impact on stability of Rangers Avenue and Bloxsome Lane and the structural integrity of the cliff face which sits above residential properties on Park Avenue.
Traffic implications
• The traffic implications of this bulk excavation are substantial. The applicant’s documents appear to only contain information about estimated traffic volumes during the construction phase (estimated as 10-20 vehicles on a typical day - see p. 74 of the EIS). We believe this does not include vehicles required for the excavation or site preparation stage, as the EIS has identified them as separate phases at p.38 of the EIS.
• Rangers Avenue has a Gross Vehicle Mass (GVM) limit of 3 tonnes, which is visibly signposted at the entry points to Rangers Avenue at the intersections with Spofforth Street, as well as Avenue Road. In addition, Rangers Avenue is windy, and contains blind spots, resulting in a 25 km speed limit at its midpoint, reinforcing potential dangers along this road.
• According to the applicant’s Construction Traffic Management Plan (Appendix W), the following vehicles are intended to be used: 12.5m Heavy Rigid Vehicles; 8.8m Medium Rigid Vehicles; 6.5m Small Rigid Vehicles; utes and vans. It is difficult to see how most of these types of vehicles would be permitted along Rangers Avenue noting the 3T GMV limit, and at sustained, high volumes over a long period of time.
Structural implications
• We have serious concerns about the potential structural implications of excavating to depths of 10m at the scale intended in the proposed development.
• The application documentation fails to include any reference to the cliff edge on the other side of Rangers Avenue, despite a highly visible yellow sign with the words “Warning cliff edge” opposite the proposed development site (there is no reference to this in the EIS, site survey plan, design documentation or geotechnical report). The applicant has not demonstrated that any assessment has been made as to whether the proposed excavation works could destabilise the slope, causing rockfall or progressive landslip, and threaten the integrity of Rangers Avenue and the properties on Park Avenue, immediately below the cliff edge.
• The applicant has not demonstrated that removing such a significant amount of rock matter will not create instability, as a massive amount of supporting material will be removed. The basement will need significant retaining structures to mitigate lateral earth pressures, as well as surcharge or load from the land to the north of the proposed development (the land slopes down towards Rangers Ave, creating gravitational pressure). This could damage the foundations of properties along Holt Avenue as well as other neighbouring properties along Rangers Avenue.
• The applicant has not provided information on the volume of sandstone that will need to be excavated for the 2.5 level basement carpark. This is material, as this calculation will determine the volume of vehicles required to remove the sandstone and other rock matter.
• The 3T GMV limit along Rangers Avenue will severely impede the applicant’s ability to remove sandstone and other matter during the excavation phase of the project, let alone during the construction phase. It is unreasonable and unfeasible to allow excessive numbers of vehicles along a residential road that is also a significant transport artery in the area.
• The applicant has not adequately demonstrated the excavation works will not impact the structural integrity of Rangers Avenue. The applicant appears to have omitted the existence of a cliff edge immediately opposite the proposed development site, as this does not appear to be reflected in the SSD documentation. There could be public safety concerns for the properties at the base of the cliff edge on Park Avenue, as well as to Rangers Avenue.
• In light of these safety concerns, the Department should commission an independent expert geotechnical review, as well as assess the feasibility of the bulk excavation anticipated and the impact on traffic and other amenities for residents along Holt Avenue, Rangers Avenue, Park Avenue and commuters who utilise Range Avenue.
Refering directly to:
Environmental Impact Statement, (link) |
Appendix S - Geotechnical (link) |
Appendix W - Construction Traffic Management Plan (link)



Source: Appendix M - Design Report Part 2

Hello

Please find attached my objection to the proposal for 11-23 Rangers Avenue Mosman

Regards

John

My home situated in Park Avenue is in close proximity to the proposed development site. The seven-storey building will significantly alter the outlook from my property, replacing the current low-rise, leafy streetscape with a large, imposing structure.
Increased traffic and parking demand from 44 new apartments and 91 basement car spaces will directly affect Rangers Avenue and surrounding roads, which are already congested during peak hours. This will make it more difficult for residents, like myself, to safely enter and exit our street, and may reduce available on-street parking for visitors and service vehicles.

The height and bulk of the proposed building will result in overshadowing and loss of sunlight to my apartment, particularly in the afternoon. This will diminish my enjoyment of my home and could impact my property’s value. In addition to this, the communal open spaces and increased density will likely generate more noise and activity, disrupting the quiet residential character that is a key reason I chose to live in this area.

The removal of mature trees and green space will reduce local biodiversity and the natural buffer that currently shields Park Avenue from noise and pollution. This may also increase stormwater runoff and the risk of flooding, which is a concern given the positioning of my apartment block.

Construction works, including demolition, excavation, and increased vehicle movements, will create dust, noise, and disruption for an extended period, directly affecting my daily life and wellbeing.

The influx of vehicles and construction traffic will increase safety risks for pedestrians, including children and elderly residents who regularly use Rangers Avenue, Park Avenue and nearby streets. Emergency vehicle access may be compromised during both construction and after completion, given the increased density and parking pressures.

Finally, but importantly, only 10 out of 44 apartments are designated as affordable, which is a minimal contribution given the scale of the project and the disruption to existing residents.

For all these reasons, I strongly object to the proposed development and urge the consent authority to reject this application in order to protect the amenity, safety, and character of our community.

Please see the attached objection to this development application