Name Withheld
Object
Name Withheld
Object
SYDNEY
,
New South Wales
Message
Addendum to Submission – SSD-95997711
Mixed Use Development – 903–921 Bourke Street, Waterloo
I wish to provide the following additional objections, specifically in relation to the proposed increase in building height, bulk and scale. I am a resident of Dunkerley Place Waterloo and believe the additional height may impact not just the views from the pool at my building but others along Bourke Street too.
1. Overshadowing and loss of solar access
The proposed increase in height (to 126m) will result in significant additional overshadowing of surrounding residential buildings and communal open spaces.
This is likely to:
- Reduce solar access to apartments, balconies, and living areas
- Impact the usability and amenity of communal facilities, including rooftop and podium-level open space
Loss of sunlight—particularly during winter—has a direct and material impact on residential amenity and should be carefully assessed and mitigated.
2. Wind impacts and pedestrian amenity
Buildings of this scale in dense urban environments can create adverse wind conditions, including:
- Wind tunnelling along Bourke Street
- Downdraft effects at street level and building entrances
These impacts can significantly reduce pedestrian comfort and safety. A development of this scale must demonstrate that it will not create unacceptable wind conditions in the public domain.
3. Bulk, scale and lack of appropriate transition
The proposed increase in height and floor space ratio represents a substantial departure from the existing built form in the surrounding area.
The development:
- Does not provide an appropriate transition in scale to neighbouring buildings
- Risks creating an overbearing “wall effect” along Bourke Street
- Will visually dominate the surrounding precinct
This is inconsistent with good urban design outcomes and diminishes the character and liveability of the area.
4. Loss of views and outlook
The proposed height increase is likely to materially impact existing view corridors and outlook from surrounding residential developments, including from upper-level apartments and communal open spaces.
While views are not protected, the scale of the proposed uplift introduces a significant and unreasonable impact on visual amenity. Specifically in relation to Dunkerley Place, the pool is located on level 10 building D and this development is likely to obstruct the view of the city from the pool with a corresponding impact on the value of our property.
5. Cumulative impact
This proposal must be considered in the context of the broader Green Square precinct, which is already experiencing rapid and substantial densification. Council have already mismanaged the problem and let developers over densify without requiring sufficient infrastructure or community facilities - the area doesn’t even have a Bank or a free cash machine?! Let alone a new pub or sufficient buses for all these people now living in the area of Green square, Waterloo and Zetland.
The cumulative effect of repeated increases in height and density across developments is resulting in:
- Increased pressure on infrastructure and public space
- Reduced residential amenity
- A growing imbalance between density and liveability
Approving further uplift of this magnitude risks exacerbating these existing issues.
6. Precedent
Approval of this proposal would set a concerning precedent for similar increases in height and density across the precinct.
This would:
- Undermine the integrity of existing planning controls
- Encourage further overdevelopment
- Erode confidence in the planning framework
Conclusion
For the reasons outlined above, the proposed increase in height, bulk and scale is excessive and will result in unacceptable impacts on surrounding properties and the broader precinct.
I request that these matters be carefully considered in the assessment of this application (by rejecting it) and others in the area; the a council and developers should take note of these concerns more generally, and take urgent steps to modify the approach to development in this area.
Mixed Use Development – 903–921 Bourke Street, Waterloo
I wish to provide the following additional objections, specifically in relation to the proposed increase in building height, bulk and scale. I am a resident of Dunkerley Place Waterloo and believe the additional height may impact not just the views from the pool at my building but others along Bourke Street too.
1. Overshadowing and loss of solar access
The proposed increase in height (to 126m) will result in significant additional overshadowing of surrounding residential buildings and communal open spaces.
This is likely to:
- Reduce solar access to apartments, balconies, and living areas
- Impact the usability and amenity of communal facilities, including rooftop and podium-level open space
Loss of sunlight—particularly during winter—has a direct and material impact on residential amenity and should be carefully assessed and mitigated.
2. Wind impacts and pedestrian amenity
Buildings of this scale in dense urban environments can create adverse wind conditions, including:
- Wind tunnelling along Bourke Street
- Downdraft effects at street level and building entrances
These impacts can significantly reduce pedestrian comfort and safety. A development of this scale must demonstrate that it will not create unacceptable wind conditions in the public domain.
3. Bulk, scale and lack of appropriate transition
The proposed increase in height and floor space ratio represents a substantial departure from the existing built form in the surrounding area.
The development:
- Does not provide an appropriate transition in scale to neighbouring buildings
- Risks creating an overbearing “wall effect” along Bourke Street
- Will visually dominate the surrounding precinct
This is inconsistent with good urban design outcomes and diminishes the character and liveability of the area.
4. Loss of views and outlook
The proposed height increase is likely to materially impact existing view corridors and outlook from surrounding residential developments, including from upper-level apartments and communal open spaces.
While views are not protected, the scale of the proposed uplift introduces a significant and unreasonable impact on visual amenity. Specifically in relation to Dunkerley Place, the pool is located on level 10 building D and this development is likely to obstruct the view of the city from the pool with a corresponding impact on the value of our property.
5. Cumulative impact
This proposal must be considered in the context of the broader Green Square precinct, which is already experiencing rapid and substantial densification. Council have already mismanaged the problem and let developers over densify without requiring sufficient infrastructure or community facilities - the area doesn’t even have a Bank or a free cash machine?! Let alone a new pub or sufficient buses for all these people now living in the area of Green square, Waterloo and Zetland.
The cumulative effect of repeated increases in height and density across developments is resulting in:
- Increased pressure on infrastructure and public space
- Reduced residential amenity
- A growing imbalance between density and liveability
Approving further uplift of this magnitude risks exacerbating these existing issues.
6. Precedent
Approval of this proposal would set a concerning precedent for similar increases in height and density across the precinct.
This would:
- Undermine the integrity of existing planning controls
- Encourage further overdevelopment
- Erode confidence in the planning framework
Conclusion
For the reasons outlined above, the proposed increase in height, bulk and scale is excessive and will result in unacceptable impacts on surrounding properties and the broader precinct.
I request that these matters be carefully considered in the assessment of this application (by rejecting it) and others in the area; the a council and developers should take note of these concerns more generally, and take urgent steps to modify the approach to development in this area.
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
I am writing to formally object to the proposed amendments to the development at 903–921 Bourke Street, which seek to significantly increase the approved building heights and density. As a local resident living nearby, I am deeply concerned about the very real and immediate impacts this proposal will have on my day-to-day life and the broader Waterloo/Zetland community.
Daily Impact on Infrastructure and Transport:
From my own experience, local infrastructure is already under significant strain. Buses such as the 304 are frequently full during peak hours and often pass stops without picking up passengers. Similarly, trains from Green Square are regularly overcrowded, making commuting stressful and unreliable. The nearest metro station is only accessible by one bus - which is often delayed and is so overcrowded.
Adding hundreds more apartments- and therefore residents will only exacerbate this issue. On a daily basis, this means longer wait times, more crowded services, and reduced quality of life for existing residents like myself who rely on this infrastructure to get to work and carry out everyday activities.
Lack of Supporting Amenities:
The local area is already struggling to support its current population. Public amenities such as libraries, cafes, and shared spaces are consistently busy. Even simple activities like finding a place to sit and work at the local library can be difficult.
With the proposed increase to the number of apartments, this pressure will intensify. There is no clear evidence that the necessary supporting infrastructure and amenities will be delivered in step with this growth. This will directly affect my ability to comfortably use local services that are already stretched.
Cumulative Overdevelopment:
This proposal cannot be considered in isolation. Alongside the adjacent proposal for a 38-storey development at 881–885 Bourke Street and numerous other large-scale developments in Waterloo and Zetland, the cumulative impact is enormous.
An estimated 4,000 new apartments is comparable to introducing an entire small town into the area within a short period. From a resident’s perspective, this scale of growth feels uncontrolled and unsustainable, with no clear plan for how the area will absorb such a rapid increase.
Parking and Local Congestion:
The proposal to add only 20 additional parking spaces for 233 new apartments is clearly inadequate. This imbalance will inevitably push more cars onto already congested local streets.
For residents like myself, this will mean increased difficulty finding parking, more traffic congestion, and greater frustration for both residents and visitors. The current situation is already challenging, and this proposal will make it significantly worse.
Visual Impact and Neighbourhood Character:
The proposed towers are excessively tall and out of character with the surrounding area. Their scale will dominate the streetscape and significantly alter the visual identity of the neighbourhood.
As someone who values the existing character and livability of this area, I am concerned that this proposal prioritises density over thoughtful urban design. The result will be an overbearing and visually intrusive development that diminishes the sense of community and place.
Overshadowing and Loss of Amenity:
The height and positioning of these towers, particularly when considered alongside nearby proposed developments, will result in significant overshadowing - especially during winter months.
This will impact nearby apartments, streets, and public spaces by reducing natural light and making outdoor areas less usable and enjoyable. Access to sunlight is a fundamental aspect of residential amenity, and this proposal risks significantly diminishing that.
Wind and Pedestrian Comfort:
Developments of this scale often create wind tunnel effects at street level. This reduces pedestrian comfort and makes the public domain less inviting and harder to use.
As someone who walks through the area daily, this is not an abstract concern - it directly affects how safe and pleasant it feels to move around the neighbourhood.
Daily Impact on Infrastructure and Transport:
From my own experience, local infrastructure is already under significant strain. Buses such as the 304 are frequently full during peak hours and often pass stops without picking up passengers. Similarly, trains from Green Square are regularly overcrowded, making commuting stressful and unreliable. The nearest metro station is only accessible by one bus - which is often delayed and is so overcrowded.
Adding hundreds more apartments- and therefore residents will only exacerbate this issue. On a daily basis, this means longer wait times, more crowded services, and reduced quality of life for existing residents like myself who rely on this infrastructure to get to work and carry out everyday activities.
Lack of Supporting Amenities:
The local area is already struggling to support its current population. Public amenities such as libraries, cafes, and shared spaces are consistently busy. Even simple activities like finding a place to sit and work at the local library can be difficult.
With the proposed increase to the number of apartments, this pressure will intensify. There is no clear evidence that the necessary supporting infrastructure and amenities will be delivered in step with this growth. This will directly affect my ability to comfortably use local services that are already stretched.
Cumulative Overdevelopment:
This proposal cannot be considered in isolation. Alongside the adjacent proposal for a 38-storey development at 881–885 Bourke Street and numerous other large-scale developments in Waterloo and Zetland, the cumulative impact is enormous.
An estimated 4,000 new apartments is comparable to introducing an entire small town into the area within a short period. From a resident’s perspective, this scale of growth feels uncontrolled and unsustainable, with no clear plan for how the area will absorb such a rapid increase.
Parking and Local Congestion:
The proposal to add only 20 additional parking spaces for 233 new apartments is clearly inadequate. This imbalance will inevitably push more cars onto already congested local streets.
For residents like myself, this will mean increased difficulty finding parking, more traffic congestion, and greater frustration for both residents and visitors. The current situation is already challenging, and this proposal will make it significantly worse.
Visual Impact and Neighbourhood Character:
The proposed towers are excessively tall and out of character with the surrounding area. Their scale will dominate the streetscape and significantly alter the visual identity of the neighbourhood.
As someone who values the existing character and livability of this area, I am concerned that this proposal prioritises density over thoughtful urban design. The result will be an overbearing and visually intrusive development that diminishes the sense of community and place.
Overshadowing and Loss of Amenity:
The height and positioning of these towers, particularly when considered alongside nearby proposed developments, will result in significant overshadowing - especially during winter months.
This will impact nearby apartments, streets, and public spaces by reducing natural light and making outdoor areas less usable and enjoyable. Access to sunlight is a fundamental aspect of residential amenity, and this proposal risks significantly diminishing that.
Wind and Pedestrian Comfort:
Developments of this scale often create wind tunnel effects at street level. This reduces pedestrian comfort and makes the public domain less inviting and harder to use.
As someone who walks through the area daily, this is not an abstract concern - it directly affects how safe and pleasant it feels to move around the neighbourhood.
Hugo Hornschuch Welke
Object
Hugo Hornschuch Welke
Object
WATERLOO
,
New South Wales
Message
Dear Assessment Team,
I am a resident of a street immediately adjacent to the proposed development site and write to formally object to SSD-80441462 in its current form. While I support well-planned densification in appropriate locations, this proposal is, in my view, materially out of step with its context, unsupported by the surrounding infrastructure, and a significant departure from the planning framework under which this site was originally approved.
My objections are as follows.
### 1. Excessive height, wholly out of character with the neighbourhood
The proposed built form — including a 36-storey tower reaching approximately 125m — is more than double the height of any surrounding building in the precinct. Recent and current developments in the immediate area sit between 4 and 13 storeys. The proposal creates an abrupt and visually jarring transition with no meaningful modulation, dominating the streetscape and the skyline from multiple public vantage points. A tower of this scale belongs at a major transit intersection (e.g. Green Square, Waterloo Metro, Wolli Creek) — not on a mid-block site on Bourke Street.
### 2. Substantial and unjustified departure from the approved planning controls
The site already has a development approval that was granted under significantly lower height and FSR controls. The current proposal seeks an extraordinary uplift — from approximately 29m to 125m in height, and from an FSR of 2.15:1 to 3.05:1 — without commensurate public benefit. Residents and neighbouring owners made purchasing and investment decisions based on the existing planning framework and the previously approved envelope. Allowing this magnitude of uplift, on a site that already had an approved scheme, undermines the predictability and integrity of the NSW planning process. If a shorter building was acceptable to the proponent at application stage, the onus is on them to demonstrate why that scheme is no longer viable — not simply to request substantially more.
### 3. Loss of sunlight and solar access to surrounding residences
The scale and positioning of the proposed towers will materially reduce sunlight to existing residential buildings in adjacent streets, including my own residence. I note that the proponent's own Solar Access report (E3 Architectural Design Report, A2 Solar Access) does not appear to assess impacts on a number of directly affected residential buildings in the precinct — including Cameo (6 Lachlan Street), Aria (4 Lachlan Street), and other west-facing dwellings along adjoining streets. This is a significant gap in the EIS and should, in my view, require the assessment to be re-exhibited once completed.
### 4. Dangerous precedent for the precinct
Approving a 36-storey tower on this site — which is not adjacent to a major transport interchange and sits among 4–13 storey built form — will establish a precedent for further disproportionate upzoning across Waterloo. Other landowners will reasonably point to this approval as justification for equivalent uplifts on their own sites, progressively eroding the character and amenity of the precinct. This is inconsistent with the orderly development objectives of the *Environmental Planning and Assessment Act 1979*.
### 5. Inadequate transport infrastructure
Waterloo has no train station. The Waterloo Metro is approximately a 15-minute walk and is closer to Redfern than to this site. Bus services — particularly the 304 along Bourke Street — are already consistently at or near capacity during peak periods. The 392 and 348 are similarly overcrowded. Adding approximately 850 dwellings to this corridor, without any committed upgrade to public transport frequency or capacity, will push existing services beyond their functional limit.
### 6. Traffic congestion and road network impacts
Local streets are already heavily congested, particularly at the Bourke/Lachlan, Bourke/Danks, and Bourke/McEvoy intersections. Residential streets in the precinct are increasingly used as rat-runs to avoid arterial bottlenecks, degrading safety and amenity. The Traffic Impact Assessment accompanying the proposal does not, in my view, adequately model cumulative impacts from this development combined with the adjacent Dasco project, the Waterloo Metro precinct, and the broader Waterloo Estate renewal.
### 7. Local services are at capacity
Existing community services — schools (Green Square Public School is already operating at capacity and there is no nearby public high school), local medical clinics, and healthcare facilities — are stretched. The proposal provides no meaningful commitment to additional social infrastructure to support an influx of residents of this scale.
### 8. Inadequate public open space
The central park proposed as a public benefit is small, heavily enclosed by buildings of 13–36 storeys, receives limited winter sunlight, and lacks meaningful recreational function (no play equipment, limited open lawn, no dog-friendly areas). It cannot reasonably serve the open-space needs of 850 new households in addition to existing residents. Moore Park and existing local open spaces are already operating at capacity.
### 9. Cumulative construction impacts
The precinct is already experiencing sustained construction activity from multiple concurrent developments. Residents are living with ongoing noise, dust, vibration, heavy-vehicle movements, and street disruption. Adding a development of this scale — which will involve multi-year construction at significant height — will compound these impacts substantially. I request that any approval, in any form, include an enforceable and publicly available Construction Management Plan addressing noise limits, operating hours, haulage routes, and cumulative coordination with other active sites in the precinct.
### Requested outcome
For the reasons above, I respectfully request that the Department:
- refuse the application in its current form, or alternatively
- require substantial amendments, including a significant reduction in maximum building height (aligned with surrounding built form), a redistribution of massing away from adjoining residential interfaces, a complete and transparent solar access assessment covering all affected residential buildings, and an enforceable Construction Management Plan.
I do not oppose development on this site. I oppose a development of this scale, at this height, on this site, under the current planning framework.
Thank you for considering my submission.
Yours sincerely,
Hugo Welke
Unit Owner on Danks Street
I am a resident of a street immediately adjacent to the proposed development site and write to formally object to SSD-80441462 in its current form. While I support well-planned densification in appropriate locations, this proposal is, in my view, materially out of step with its context, unsupported by the surrounding infrastructure, and a significant departure from the planning framework under which this site was originally approved.
My objections are as follows.
### 1. Excessive height, wholly out of character with the neighbourhood
The proposed built form — including a 36-storey tower reaching approximately 125m — is more than double the height of any surrounding building in the precinct. Recent and current developments in the immediate area sit between 4 and 13 storeys. The proposal creates an abrupt and visually jarring transition with no meaningful modulation, dominating the streetscape and the skyline from multiple public vantage points. A tower of this scale belongs at a major transit intersection (e.g. Green Square, Waterloo Metro, Wolli Creek) — not on a mid-block site on Bourke Street.
### 2. Substantial and unjustified departure from the approved planning controls
The site already has a development approval that was granted under significantly lower height and FSR controls. The current proposal seeks an extraordinary uplift — from approximately 29m to 125m in height, and from an FSR of 2.15:1 to 3.05:1 — without commensurate public benefit. Residents and neighbouring owners made purchasing and investment decisions based on the existing planning framework and the previously approved envelope. Allowing this magnitude of uplift, on a site that already had an approved scheme, undermines the predictability and integrity of the NSW planning process. If a shorter building was acceptable to the proponent at application stage, the onus is on them to demonstrate why that scheme is no longer viable — not simply to request substantially more.
### 3. Loss of sunlight and solar access to surrounding residences
The scale and positioning of the proposed towers will materially reduce sunlight to existing residential buildings in adjacent streets, including my own residence. I note that the proponent's own Solar Access report (E3 Architectural Design Report, A2 Solar Access) does not appear to assess impacts on a number of directly affected residential buildings in the precinct — including Cameo (6 Lachlan Street), Aria (4 Lachlan Street), and other west-facing dwellings along adjoining streets. This is a significant gap in the EIS and should, in my view, require the assessment to be re-exhibited once completed.
### 4. Dangerous precedent for the precinct
Approving a 36-storey tower on this site — which is not adjacent to a major transport interchange and sits among 4–13 storey built form — will establish a precedent for further disproportionate upzoning across Waterloo. Other landowners will reasonably point to this approval as justification for equivalent uplifts on their own sites, progressively eroding the character and amenity of the precinct. This is inconsistent with the orderly development objectives of the *Environmental Planning and Assessment Act 1979*.
### 5. Inadequate transport infrastructure
Waterloo has no train station. The Waterloo Metro is approximately a 15-minute walk and is closer to Redfern than to this site. Bus services — particularly the 304 along Bourke Street — are already consistently at or near capacity during peak periods. The 392 and 348 are similarly overcrowded. Adding approximately 850 dwellings to this corridor, without any committed upgrade to public transport frequency or capacity, will push existing services beyond their functional limit.
### 6. Traffic congestion and road network impacts
Local streets are already heavily congested, particularly at the Bourke/Lachlan, Bourke/Danks, and Bourke/McEvoy intersections. Residential streets in the precinct are increasingly used as rat-runs to avoid arterial bottlenecks, degrading safety and amenity. The Traffic Impact Assessment accompanying the proposal does not, in my view, adequately model cumulative impacts from this development combined with the adjacent Dasco project, the Waterloo Metro precinct, and the broader Waterloo Estate renewal.
### 7. Local services are at capacity
Existing community services — schools (Green Square Public School is already operating at capacity and there is no nearby public high school), local medical clinics, and healthcare facilities — are stretched. The proposal provides no meaningful commitment to additional social infrastructure to support an influx of residents of this scale.
### 8. Inadequate public open space
The central park proposed as a public benefit is small, heavily enclosed by buildings of 13–36 storeys, receives limited winter sunlight, and lacks meaningful recreational function (no play equipment, limited open lawn, no dog-friendly areas). It cannot reasonably serve the open-space needs of 850 new households in addition to existing residents. Moore Park and existing local open spaces are already operating at capacity.
### 9. Cumulative construction impacts
The precinct is already experiencing sustained construction activity from multiple concurrent developments. Residents are living with ongoing noise, dust, vibration, heavy-vehicle movements, and street disruption. Adding a development of this scale — which will involve multi-year construction at significant height — will compound these impacts substantially. I request that any approval, in any form, include an enforceable and publicly available Construction Management Plan addressing noise limits, operating hours, haulage routes, and cumulative coordination with other active sites in the precinct.
### Requested outcome
For the reasons above, I respectfully request that the Department:
- refuse the application in its current form, or alternatively
- require substantial amendments, including a significant reduction in maximum building height (aligned with surrounding built form), a redistribution of massing away from adjoining residential interfaces, a complete and transparent solar access assessment covering all affected residential buildings, and an enforceable Construction Management Plan.
I do not oppose development on this site. I oppose a development of this scale, at this height, on this site, under the current planning framework.
Thank you for considering my submission.
Yours sincerely,
Hugo Welke
Unit Owner on Danks Street
Attachments
Name Withheld
Object
Name Withheld
Object
Waterloo
,
New South Wales
Message
Regarding the proposed development SSD-95997711 Address: 903-921 Bourke Street And 3 McEvoy Street, Waterloo.
We have no objection to the original DA and have considered purchasing in it. However, we would not purchase in the complex if the new proposed DA is approved.
It is very evident and clear that the additions in the new proposal will cause significant drains on all existing infrastructures and local amenities. The proposed new height is definitely not in keeping with the area and existing properties. One would also expect there to be significant resident overcrowding and building overshadowing.
As a local resident for the past 6 years we have enjoyed all that Waterloo and Zetland has to offer. We use the local transport system regularly.
With the significant increase in new residents via the new proposal, it would cause numerous issues for existing residents, for example:
Busses
Overcrowding of busses. Busses are already at capacity throughout the day. With the current mix of residents and their work schedules, peak hours really do not exist. It is almost impossible to get a seat in the area assigned for elderly persons or prams. Also, please note that often due to current crowded busses they do not stop along Bourke Street and/or Potter Street. We have often had to miss 2 busses.
Sewerage System
The sewerage system is bound to be put under increased pressure. Noting the existing site may have had up to 100 toilets, with the new development the significant increase in toilets and their usage is bound to increase the risk of overflows.
Electricity
There will also be a high chance that the electrical grid will be put under constant pressure. Especially with the likelihood of more developments requiring EV infrastructure.
Mobile Phone Towers
These will be put under pressure. Already, we think they are having issues coping.
Libraries
The local libraries are almost at capacity. At times it is had to find a space.
Footpaths
There will be an increase in the use of e-bikes, e-scooters and Uber type deliveries. Currently one takes their life in their hands when walking the local streets. Any increase in these items will increase the danger, especially for young children and the elderly.
Parking
Street parking is already at capacity.
We would like to know as to why this new proposal was not part of the original DA. If it was, we are sure that all approving authorities concerned would have rejected the DA. It is unlikely to be an after thought!
We have no objection to the original DA and have considered purchasing in it. However, we would not purchase in the complex if the new proposed DA is approved.
It is very evident and clear that the additions in the new proposal will cause significant drains on all existing infrastructures and local amenities. The proposed new height is definitely not in keeping with the area and existing properties. One would also expect there to be significant resident overcrowding and building overshadowing.
As a local resident for the past 6 years we have enjoyed all that Waterloo and Zetland has to offer. We use the local transport system regularly.
With the significant increase in new residents via the new proposal, it would cause numerous issues for existing residents, for example:
Busses
Overcrowding of busses. Busses are already at capacity throughout the day. With the current mix of residents and their work schedules, peak hours really do not exist. It is almost impossible to get a seat in the area assigned for elderly persons or prams. Also, please note that often due to current crowded busses they do not stop along Bourke Street and/or Potter Street. We have often had to miss 2 busses.
Sewerage System
The sewerage system is bound to be put under increased pressure. Noting the existing site may have had up to 100 toilets, with the new development the significant increase in toilets and their usage is bound to increase the risk of overflows.
Electricity
There will also be a high chance that the electrical grid will be put under constant pressure. Especially with the likelihood of more developments requiring EV infrastructure.
Mobile Phone Towers
These will be put under pressure. Already, we think they are having issues coping.
Libraries
The local libraries are almost at capacity. At times it is had to find a space.
Footpaths
There will be an increase in the use of e-bikes, e-scooters and Uber type deliveries. Currently one takes their life in their hands when walking the local streets. Any increase in these items will increase the danger, especially for young children and the elderly.
Parking
Street parking is already at capacity.
We would like to know as to why this new proposal was not part of the original DA. If it was, we are sure that all approving authorities concerned would have rejected the DA. It is unlikely to be an after thought!
Name Withheld
Object
Name Withheld
Object
SYDNEY
,
New South Wales
Message
Submission: Objection to SSD-95997711
Mixed Use Development – 903–921 Bourke Street, Waterloo
To: Department of Planning, Housing and Infrastructure
Application Number: SSD-95997711
Location: 903–921 Bourke Street, Waterloo
Position: Objection
I write as a local resident and property owner in the Green Square / Waterloo area to formally object to the above State Significant Development application and associated rezoning proposal.
While I support the continued renewal and growth of Green Square as a major urban centre, this proposal represents a further intensification of density without adequate consideration of supporting infrastructure, community amenity, and—critically—the quality and diversity of the non-residential offering at ground level.
1. Overdevelopment without commensurate infrastructure
The proposal seeks to:
• Increase building height from 65m to 126m
• Increase FSR from 1.5:1 to 3.2:1
• Increase dwellings from 376 to 580 apartments
This represents a substantial uplift in density. However, infrastructure and services in the Green Square precinct have already failed to keep pace with existing development, let alone future growth.
Local residents are already experiencing:
• Overcrowding in public spaces and transport nodes
• Limited access to community facilities and social infrastructure
• A lack of meaningful retail, hospitality, and cultural destinations
Increasing density at this scale, particularly while seeking to exclude provisions such as community infrastructure, contributes to risks further exacerbating these issues and undermining the long-term liveability of the precinct.
2. Failure to deliver a diverse and high-quality retail environment
A critical concern is the continued proliferation of low-value, homogenous retail offerings across new developments in Green Square, Zetland, and Waterloo.
Recent developments in the area demonstrate a clear pattern:
• Repetition of similar fast-food and retail outlets (e.g. fried chicken, bubble tea, dumplings, vape shops)
• Limited diversity in cuisine, format, and experience
• A lack of independent, destination-quality or community-oriented venues
This has resulted in a retail landscape that is increasingly generic, transactional, and disconnected from the needs of a growing, diverse residential population.
The subject proposal does not provide sufficient confidence that it will deliver anything materially different. More units, even higher density, without any real mitigation for the issues above.
3. Missed opportunity to create a genuine mixed-use destination
Given the scale of this development, it should function as a genuine local centre and ‘community hub’ not simply a high-density residential complex with incidental retail.
Best-practice developments in comparable inner-city areas demonstrate what is possible when retail is curated with intent:
• A balanced mix of dining (casual, mid-range, and premium)
• Independent cafés and specialty operators
• Community-oriented venues (e.g. pubs, small bars, cultural spaces)
• Flexible and experiential formats (e.g. food halls, co-working, pop-ups)
Without clear planning controls or commitments, there is a strong risk that this development will replicate the same pattern seen elsewhere in Green Square, namely, convenience-focused takeaway outlets with limited contribution to place-making.
4. Inconsistency with strategic planning objectives
The City of Sydney’s planning framework for Green Square emphasises:
• A vibrant, diverse, and sustainable community
• A mix of employment, retail, and cultural uses
• High-quality urban design and activation
Allowing significant increases in height and density while weakening planning controls and failing to ensure diversity in non-residential uses is inconsistent with these objectives.
5. Requested actions
I respectfully request that the Department and the Minister:
1. Refuse or significantly amend the proposal to ensure density increases are aligned with infrastructure capacity and community outcomes.
2. Retain and strengthen planning controls, including:
o Community infrastructure contributions
o Competitive design processes
o Requirements for high-quality public domain and activation
3. Introduce stronger requirements for retail diversity, including:
o A mandated mix of retail types and uses
o Measures to prevent over-concentration of similar takeaway outlets
o Incentives or provisions for independent and community-oriented businesses
4. Ensure the development delivers genuine place-making outcomes, including:
o Spaces for social interaction (e.g. pubs, small bars, cultural venues; arts, comedy, independent coffee places etc)
o Flexible and experiential retail formats
o Consideration of the needs of a work-from-home population (e.g. co-working or hybrid spaces)
6. Conclusion
Green Square represents one of the most significant urban renewal projects in Australia. Developments of this scale must do more than maximise yield: they must contribute meaningfully to the creation of a liveable, diverse, and engaging community.
In its current form, this proposal prioritises density over quality and risks further entrenching the shortcomings already evident across the precinct.
Finally, the period for submissions on this proposal are wholly inadequate (15 Apr-28 Apr) and poorly advertised.
For these reasons, I object to the application.
Mixed Use Development – 903–921 Bourke Street, Waterloo
To: Department of Planning, Housing and Infrastructure
Application Number: SSD-95997711
Location: 903–921 Bourke Street, Waterloo
Position: Objection
I write as a local resident and property owner in the Green Square / Waterloo area to formally object to the above State Significant Development application and associated rezoning proposal.
While I support the continued renewal and growth of Green Square as a major urban centre, this proposal represents a further intensification of density without adequate consideration of supporting infrastructure, community amenity, and—critically—the quality and diversity of the non-residential offering at ground level.
1. Overdevelopment without commensurate infrastructure
The proposal seeks to:
• Increase building height from 65m to 126m
• Increase FSR from 1.5:1 to 3.2:1
• Increase dwellings from 376 to 580 apartments
This represents a substantial uplift in density. However, infrastructure and services in the Green Square precinct have already failed to keep pace with existing development, let alone future growth.
Local residents are already experiencing:
• Overcrowding in public spaces and transport nodes
• Limited access to community facilities and social infrastructure
• A lack of meaningful retail, hospitality, and cultural destinations
Increasing density at this scale, particularly while seeking to exclude provisions such as community infrastructure, contributes to risks further exacerbating these issues and undermining the long-term liveability of the precinct.
2. Failure to deliver a diverse and high-quality retail environment
A critical concern is the continued proliferation of low-value, homogenous retail offerings across new developments in Green Square, Zetland, and Waterloo.
Recent developments in the area demonstrate a clear pattern:
• Repetition of similar fast-food and retail outlets (e.g. fried chicken, bubble tea, dumplings, vape shops)
• Limited diversity in cuisine, format, and experience
• A lack of independent, destination-quality or community-oriented venues
This has resulted in a retail landscape that is increasingly generic, transactional, and disconnected from the needs of a growing, diverse residential population.
The subject proposal does not provide sufficient confidence that it will deliver anything materially different. More units, even higher density, without any real mitigation for the issues above.
3. Missed opportunity to create a genuine mixed-use destination
Given the scale of this development, it should function as a genuine local centre and ‘community hub’ not simply a high-density residential complex with incidental retail.
Best-practice developments in comparable inner-city areas demonstrate what is possible when retail is curated with intent:
• A balanced mix of dining (casual, mid-range, and premium)
• Independent cafés and specialty operators
• Community-oriented venues (e.g. pubs, small bars, cultural spaces)
• Flexible and experiential formats (e.g. food halls, co-working, pop-ups)
Without clear planning controls or commitments, there is a strong risk that this development will replicate the same pattern seen elsewhere in Green Square, namely, convenience-focused takeaway outlets with limited contribution to place-making.
4. Inconsistency with strategic planning objectives
The City of Sydney’s planning framework for Green Square emphasises:
• A vibrant, diverse, and sustainable community
• A mix of employment, retail, and cultural uses
• High-quality urban design and activation
Allowing significant increases in height and density while weakening planning controls and failing to ensure diversity in non-residential uses is inconsistent with these objectives.
5. Requested actions
I respectfully request that the Department and the Minister:
1. Refuse or significantly amend the proposal to ensure density increases are aligned with infrastructure capacity and community outcomes.
2. Retain and strengthen planning controls, including:
o Community infrastructure contributions
o Competitive design processes
o Requirements for high-quality public domain and activation
3. Introduce stronger requirements for retail diversity, including:
o A mandated mix of retail types and uses
o Measures to prevent over-concentration of similar takeaway outlets
o Incentives or provisions for independent and community-oriented businesses
4. Ensure the development delivers genuine place-making outcomes, including:
o Spaces for social interaction (e.g. pubs, small bars, cultural venues; arts, comedy, independent coffee places etc)
o Flexible and experiential retail formats
o Consideration of the needs of a work-from-home population (e.g. co-working or hybrid spaces)
6. Conclusion
Green Square represents one of the most significant urban renewal projects in Australia. Developments of this scale must do more than maximise yield: they must contribute meaningfully to the creation of a liveable, diverse, and engaging community.
In its current form, this proposal prioritises density over quality and risks further entrenching the shortcomings already evident across the precinct.
Finally, the period for submissions on this proposal are wholly inadequate (15 Apr-28 Apr) and poorly advertised.
For these reasons, I object to the application.
Mark Frazer
Object
Mark Frazer
Object
JERRABOMBERRA
,
New South Wales
Message
I strongly object to the amendments made in regard to this project for the following reasons.
The additional 233 apartments will place an enormous strain on the already aging infrastructure. Power, water and sewer services may need to be upgraded to cater for the additional load.
Limited existing amenities will also struggle to cater for the estimated additional 500 residents.
The extra height of the development will have a significant impact of shadowing in the afternoon meaning that existing developments will be forced to increase their heating/cooling costs.
The amended plan does not compliment the existing building height of surrounding developments.
The additional 233 apartments will place an enormous strain on the already aging infrastructure. Power, water and sewer services may need to be upgraded to cater for the additional load.
Limited existing amenities will also struggle to cater for the estimated additional 500 residents.
The extra height of the development will have a significant impact of shadowing in the afternoon meaning that existing developments will be forced to increase their heating/cooling costs.
The amended plan does not compliment the existing building height of surrounding developments.
Lee Bradley
Object
Lee Bradley
Object
WATERLOO
,
New South Wales
Message
write to formally object to Development Application D/2021/1415 in respect of the proposed development at 903–921 Bourke Street, Waterloo. This objection is made pursuant to the Environmental Planning and Assessment Act 1979 (NSW) and is grounded in substantive planning, environmental, and procedural deficiencies that render the application unsuitable for approval. When assessed against the statutory framework administered by the City of Sydney and overseen within the broader policy context of the NSW Department of Planning, Housing and Infrastructure, the proposal fails to meet fundamental requirements and should be refused.
At the outset, the application does not demonstrate compliance with the applicable Local Environmental Plan, Development Control Plan, and relevant State Environmental Planning Policies. While the applicant may assert technical compliance with certain numerical controls, it is well established that compliance in form does not equate to compliance in substance. The proposal undermines the objectives of those controls, particularly in relation to built form, scale, amenity, and environmental performance. Any reliance on variations or departures is not supported by a rigorous or lawful justification and would fail to satisfy the established planning principles governing such departures. In this respect, the application is not merely marginally non-compliant; it reflects a fundamental misalignment with the strategic intent of the planning framework.
The proposed development constitutes a clear instance of overdevelopment. The bulk, scale, and massing of the buildings are excessive and produce an outcome that is visually dominant, overbearing, and incompatible with both the existing and desired future character of the Waterloo locality. The design fails to provide appropriate modulation or articulation to mitigate its apparent scale, and the transition to surrounding development is abrupt and unresolved. Rather than integrating with the urban fabric, the proposal imposes itself upon it. This is contrary to well-established urban design principles and to the objectives of the Development Control Plan, which seek to ensure that development contributes positively to the streetscape and the broader public domain.
The amenity impacts arising from the proposal are significant and unacceptable. The development will result in material loss of solar access to neighboring residential properties and to areas of the public domain, contrary to the objectives of preserving reasonable sunlight access. The extent of overshadowing has not been adequately mitigated and appears to be understated in the supporting documentation. In addition, the proposal will give rise to overlooking and privacy impacts that are inconsistent with acceptable residential standards. The cumulative effect of visual intrusion, loss of outlook, and increased density will materially diminish the amenity of adjoining properties. These impacts are not speculative; they are a direct and foreseeable consequence of the scale and configuration of the proposed development.
The traffic and transport assessment accompanying the application is deficient and cannot be relied upon. It is based on assumptions regarding modal shift and public transport usage that are not adequately substantiated and which appear overly optimistic. The analysis fails to properly account for cumulative impacts arising from other developments in the locality, thereby understating the true burden on the road network. The likely outcome is increased congestion, reduced safety, and a deterioration in the efficiency of local transport infrastructure. In the absence of a robust and credible assessment, the Consent Authority cannot be satisfied that the development will not have adverse impacts on the transport network, as required under section 4.15 of the Act.
Closely related to this is the failure of the application to demonstrate that existing infrastructure and services have the capacity to accommodate the proposed development. There is insufficient evidence to support a conclusion that transport systems, utilities, open space, and community facilities can absorb the additional demand generated by the project. Approval of development in the absence of such evidence is premature and inconsistent with the principles of orderly and sustainable planning. It effectively transfers risk from the applicant to the community, which is neither equitable nor acceptable.
The environmental aspects of the application are similarly inadequate. The documentation does not provide sufficient assurance that issues such as contamination, stormwater management, and environmental sustainability have been comprehensively addressed. In particular, the absence of a clearly defined and enforceable remediation strategy raises serious concerns regarding site suitability. The proposal also fails to demonstrate alignment with contemporary sustainability standards or to adequately address the urban heat island effect, which is of increasing relevance in high-density urban environments. These omissions are material and go directly to the question of whether the site is suitable for the proposed use.
The proposal further fails to adequately consider the character of the Waterloo precinct. Even in circumstances where formal heritage listings may not apply, the planning framework requires development to respond sensitively to its context. The application does not achieve this. Instead, it prioritizes yield and intensity at the expense of character and cohesion, resulting in a development that is discordant with its surroundings. This failure is compounded by the cumulative impact of similar developments in the area, which underscores the need for careful and contextually responsive planning rather than further escalation of scale.
There are also significant procedural deficiencies in the application that undermine its credibility. The supporting technical reports are, in several instances, incomplete, inconsistent, or reliant on assumptions that are not independently verified. Key methodologies are not transparently disclosed, limiting the ability of stakeholders to meaningfully assess the proposal. The planning justification lacks coherence and does not adequately reconcile the various impacts identified. These deficiencies are not merely technical; they go to the heart of the assessment process and render the application incapable of proper evaluation.
When considered in its entirety, the application is contrary to the public interest. It delivers substantial private benefit to the applicant while imposing disproportionate adverse impacts on the surrounding community. It does not provide a commensurate contribution to public amenity, infrastructure, or environmental outcomes. The imbalance between benefit and burden is stark and cannot be justified within the planning framework.
For these reasons, the Consent Authority cannot be satisfied that the application meets the requirements of the Environmental Planning and Assessment Act 1979. The proposal fails to achieve the objectives of the applicable planning controls, results in unacceptable impacts, and is supported by inadequate and deficient documentation. Approval in its current form would not only be contrary to sound planning principles but would also expose the decision to significant legal and merit-based challenge.
Accordingly, I respectfully submit that Development Application D/2021/1415 must be refused.
At the outset, the application does not demonstrate compliance with the applicable Local Environmental Plan, Development Control Plan, and relevant State Environmental Planning Policies. While the applicant may assert technical compliance with certain numerical controls, it is well established that compliance in form does not equate to compliance in substance. The proposal undermines the objectives of those controls, particularly in relation to built form, scale, amenity, and environmental performance. Any reliance on variations or departures is not supported by a rigorous or lawful justification and would fail to satisfy the established planning principles governing such departures. In this respect, the application is not merely marginally non-compliant; it reflects a fundamental misalignment with the strategic intent of the planning framework.
The proposed development constitutes a clear instance of overdevelopment. The bulk, scale, and massing of the buildings are excessive and produce an outcome that is visually dominant, overbearing, and incompatible with both the existing and desired future character of the Waterloo locality. The design fails to provide appropriate modulation or articulation to mitigate its apparent scale, and the transition to surrounding development is abrupt and unresolved. Rather than integrating with the urban fabric, the proposal imposes itself upon it. This is contrary to well-established urban design principles and to the objectives of the Development Control Plan, which seek to ensure that development contributes positively to the streetscape and the broader public domain.
The amenity impacts arising from the proposal are significant and unacceptable. The development will result in material loss of solar access to neighboring residential properties and to areas of the public domain, contrary to the objectives of preserving reasonable sunlight access. The extent of overshadowing has not been adequately mitigated and appears to be understated in the supporting documentation. In addition, the proposal will give rise to overlooking and privacy impacts that are inconsistent with acceptable residential standards. The cumulative effect of visual intrusion, loss of outlook, and increased density will materially diminish the amenity of adjoining properties. These impacts are not speculative; they are a direct and foreseeable consequence of the scale and configuration of the proposed development.
The traffic and transport assessment accompanying the application is deficient and cannot be relied upon. It is based on assumptions regarding modal shift and public transport usage that are not adequately substantiated and which appear overly optimistic. The analysis fails to properly account for cumulative impacts arising from other developments in the locality, thereby understating the true burden on the road network. The likely outcome is increased congestion, reduced safety, and a deterioration in the efficiency of local transport infrastructure. In the absence of a robust and credible assessment, the Consent Authority cannot be satisfied that the development will not have adverse impacts on the transport network, as required under section 4.15 of the Act.
Closely related to this is the failure of the application to demonstrate that existing infrastructure and services have the capacity to accommodate the proposed development. There is insufficient evidence to support a conclusion that transport systems, utilities, open space, and community facilities can absorb the additional demand generated by the project. Approval of development in the absence of such evidence is premature and inconsistent with the principles of orderly and sustainable planning. It effectively transfers risk from the applicant to the community, which is neither equitable nor acceptable.
The environmental aspects of the application are similarly inadequate. The documentation does not provide sufficient assurance that issues such as contamination, stormwater management, and environmental sustainability have been comprehensively addressed. In particular, the absence of a clearly defined and enforceable remediation strategy raises serious concerns regarding site suitability. The proposal also fails to demonstrate alignment with contemporary sustainability standards or to adequately address the urban heat island effect, which is of increasing relevance in high-density urban environments. These omissions are material and go directly to the question of whether the site is suitable for the proposed use.
The proposal further fails to adequately consider the character of the Waterloo precinct. Even in circumstances where formal heritage listings may not apply, the planning framework requires development to respond sensitively to its context. The application does not achieve this. Instead, it prioritizes yield and intensity at the expense of character and cohesion, resulting in a development that is discordant with its surroundings. This failure is compounded by the cumulative impact of similar developments in the area, which underscores the need for careful and contextually responsive planning rather than further escalation of scale.
There are also significant procedural deficiencies in the application that undermine its credibility. The supporting technical reports are, in several instances, incomplete, inconsistent, or reliant on assumptions that are not independently verified. Key methodologies are not transparently disclosed, limiting the ability of stakeholders to meaningfully assess the proposal. The planning justification lacks coherence and does not adequately reconcile the various impacts identified. These deficiencies are not merely technical; they go to the heart of the assessment process and render the application incapable of proper evaluation.
When considered in its entirety, the application is contrary to the public interest. It delivers substantial private benefit to the applicant while imposing disproportionate adverse impacts on the surrounding community. It does not provide a commensurate contribution to public amenity, infrastructure, or environmental outcomes. The imbalance between benefit and burden is stark and cannot be justified within the planning framework.
For these reasons, the Consent Authority cannot be satisfied that the application meets the requirements of the Environmental Planning and Assessment Act 1979. The proposal fails to achieve the objectives of the applicable planning controls, results in unacceptable impacts, and is supported by inadequate and deficient documentation. Approval in its current form would not only be contrary to sound planning principles but would also expose the decision to significant legal and merit-based challenge.
Accordingly, I respectfully submit that Development Application D/2021/1415 must be refused.
Name Withheld
Object
Name Withheld
Object
ERSKINEVILLE
,
New South Wales
Message
Hello
Please consider my strong objection to this proposal. It is excessive and totally egregious compared to the original plan, and will turn an already over populated area into a less safe and enjoyable place to live. The number of apartments and scale of the plan is too large for the area, and the number of parking spots planned is completely inadequate. Our family lives in Waterloo and this would materially impact us. I look forward to a common sense approach returning to this planning process.
Please consider my strong objection to this proposal. It is excessive and totally egregious compared to the original plan, and will turn an already over populated area into a less safe and enjoyable place to live. The number of apartments and scale of the plan is too large for the area, and the number of parking spots planned is completely inadequate. Our family lives in Waterloo and this would materially impact us. I look forward to a common sense approach returning to this planning process.
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
I write to formally object to Development Application D/2021/1415 in respect of the proposed development at 903–921 Bourke Street, Waterloo. This objection is made pursuant to the Environmental Planning and Assessment Act 1979 (NSW) and is grounded in substantive planning, environmental, and procedural deficiencies that render the application unsuitable for approval. When assessed against the statutory framework administered by the City of Sydney and within the broader policy context of the NSW Department of Planning, Housing and Infrastructure, the proposal fails to meet fundamental requirements and should be refused.
At the outset, the application does not demonstrate compliance with the applicable Local Environmental Plan, Development Control Plan, and relevant State Environmental Planning Policies. While the applicant may assert technical compliance with certain numerical controls, it is well established that compliance in form does not equate to compliance in substance. The proposal undermines the objectives of those controls, particularly in relation to built form, scale, amenity, environmental performance, and the orderly development of land. Any reliance on variations or departures is not supported by a rigorous or lawful justification and would fail to satisfy the established planning principles governing such departures, including the requirement to demonstrate that strict compliance is unreasonable or unnecessary and that there are sufficient environmental planning grounds to justify the contravention. In this respect, the application reflects not a marginal inconsistency but a fundamental misalignment with the strategic intent of the planning framework.
The proposed development constitutes a clear instance of overdevelopment. The bulk, scale, and massing of the buildings are excessive and produce an outcome that is visually dominant, overbearing, and incompatible with both the existing and desired future character of the Waterloo locality. The design fails to provide appropriate modulation or articulation to mitigate its apparent scale, and the transition to surrounding development is abrupt, unresolved, and discordant. Rather than integrating with the established urban fabric, the proposal imposes itself upon it in a manner that is inconsistent with good urban design and contrary to the objectives of the Development Control Plan. The cumulative effect is a built form that erodes streetscape quality and diminishes the public domain, rather than enhancing it.
The amenity impacts arising from the proposal are significant, material, and unacceptable. The development will result in substantial loss of solar access to neighboring residential properties and to areas of the public domain, contrary to the objectives of preserving reasonable sunlight access and ensuring livable urban environments. The extent of overshadowing appears to be understated in the supporting documentation and has not been satisfactorily mitigated. In addition, the proposal will give rise to overlooking and privacy impacts that are inconsistent with acceptable residential standards, particularly in a high-density context where such impacts must be carefully managed. The cumulative effect of visual intrusion, loss of outlook, increased density, and potential noise impacts will materially diminish the amenity of adjoining properties. These impacts are foreseeable, direct, and consequential, and they weigh heavily against approval.
The traffic and transport assessment accompanying the application is deficient, incomplete, and unreliable. It is predicated on assumptions regarding modal shift and public transport usage that are not adequately substantiated and which appear overly optimistic given prevailing travel patterns. The analysis fails to properly account for cumulative impacts arising from other developments in the locality and does not adequately assess peak period conditions or network resilience. The likely outcome is increased congestion, reduced safety, and a measurable deterioration in the performance of the local transport network. In these circumstances, the Consent Authority cannot be satisfied that the proposal will not have adverse transport impacts, and approval would be inconsistent with the statutory obligation to consider such matters.
Closely related to this is the failure of the application to demonstrate that existing infrastructure and services have the capacity to accommodate the proposed development. There is insufficient evidence to support a conclusion that transport infrastructure, utilities, open space, health services, educational facilities, and broader community infrastructure can absorb the additional demand generated by the project. The absence of a coordinated infrastructure response suggests that the development is being advanced ahead of the capacity required to support it. Approval in such circumstances would be premature and contrary to the principles of orderly and sustainable planning, effectively externalizing infrastructure costs onto the community.
The environmental aspects of the application are similarly inadequate and give rise to serious concern. The documentation does not provide sufficient assurance that issues such as contamination, stormwater management, water quality, and environmental sustainability have been comprehensively addressed. In particular, the absence of a clearly defined, enforceable, and independently verified remediation strategy raises questions as to whether the site is suitable for the proposed use. The proposal also fails to demonstrate alignment with best-practice sustainability benchmarks, including energy efficiency, water reuse, and climate resilience. The lack of meaningful measures to address urban heat island effects further underscores the inadequacy of the environmental response.
The proposal also fails to adequately consider the character and evolving identity of the Waterloo precinct. Even where formal heritage listings do not directly apply, the planning framework requires development to respond sensitively to its context and contribute positively to the urban environment. The application does not achieve this outcome. Instead, it prioritizes density and yield at the expense of coherence and character, resulting in a development that is discordant, visually intrusive, and inconsistent with the broader planning vision for the area. The incremental erosion of local character through developments of this nature is a matter of legitimate planning concern and must be given due weight.
There are also significant procedural deficiencies that further undermine the integrity of the application. The supporting technical reports are, in several instances, incomplete, internally inconsistent, or reliant on assumptions that are not independently verified. Key methodologies are insufficiently disclosed, limiting transparency and preventing meaningful scrutiny. The planning justification is fragmented and fails to reconcile the various impacts identified across disciplines. These deficiencies materially prejudice the assessment process and prevent the Consent Authority from being properly satisfied as to the merits of the proposal.
When considered holistically, the application is contrary to the public interest. It confers substantial private benefit while imposing disproportionate and inadequately mitigated impacts on the surrounding community. It does not deliver a commensurate public benefit in terms of infrastructure, amenity, or environmental performance. The imbalance between private gain and public burden is pronounced and unacceptable within the context of the planning framework.
For these reasons, the Consent Authority cannot be satisfied that the application meets the requirements of the Environmental Planning and Assessment Act 1979. The proposal fails to achieve the objectives of the applicable planning controls, results in unacceptable impacts, and is supported by inadequate and unreliable documentation. Approval in its current form would be inconsistent with sound planning practice and would expose the decision to a high risk of successful challenge on both merit and legal grounds.
Accordingly, I respectfully submit that Development Application D/2021/1415 must be refused.
At the outset, the application does not demonstrate compliance with the applicable Local Environmental Plan, Development Control Plan, and relevant State Environmental Planning Policies. While the applicant may assert technical compliance with certain numerical controls, it is well established that compliance in form does not equate to compliance in substance. The proposal undermines the objectives of those controls, particularly in relation to built form, scale, amenity, environmental performance, and the orderly development of land. Any reliance on variations or departures is not supported by a rigorous or lawful justification and would fail to satisfy the established planning principles governing such departures, including the requirement to demonstrate that strict compliance is unreasonable or unnecessary and that there are sufficient environmental planning grounds to justify the contravention. In this respect, the application reflects not a marginal inconsistency but a fundamental misalignment with the strategic intent of the planning framework.
The proposed development constitutes a clear instance of overdevelopment. The bulk, scale, and massing of the buildings are excessive and produce an outcome that is visually dominant, overbearing, and incompatible with both the existing and desired future character of the Waterloo locality. The design fails to provide appropriate modulation or articulation to mitigate its apparent scale, and the transition to surrounding development is abrupt, unresolved, and discordant. Rather than integrating with the established urban fabric, the proposal imposes itself upon it in a manner that is inconsistent with good urban design and contrary to the objectives of the Development Control Plan. The cumulative effect is a built form that erodes streetscape quality and diminishes the public domain, rather than enhancing it.
The amenity impacts arising from the proposal are significant, material, and unacceptable. The development will result in substantial loss of solar access to neighboring residential properties and to areas of the public domain, contrary to the objectives of preserving reasonable sunlight access and ensuring livable urban environments. The extent of overshadowing appears to be understated in the supporting documentation and has not been satisfactorily mitigated. In addition, the proposal will give rise to overlooking and privacy impacts that are inconsistent with acceptable residential standards, particularly in a high-density context where such impacts must be carefully managed. The cumulative effect of visual intrusion, loss of outlook, increased density, and potential noise impacts will materially diminish the amenity of adjoining properties. These impacts are foreseeable, direct, and consequential, and they weigh heavily against approval.
The traffic and transport assessment accompanying the application is deficient, incomplete, and unreliable. It is predicated on assumptions regarding modal shift and public transport usage that are not adequately substantiated and which appear overly optimistic given prevailing travel patterns. The analysis fails to properly account for cumulative impacts arising from other developments in the locality and does not adequately assess peak period conditions or network resilience. The likely outcome is increased congestion, reduced safety, and a measurable deterioration in the performance of the local transport network. In these circumstances, the Consent Authority cannot be satisfied that the proposal will not have adverse transport impacts, and approval would be inconsistent with the statutory obligation to consider such matters.
Closely related to this is the failure of the application to demonstrate that existing infrastructure and services have the capacity to accommodate the proposed development. There is insufficient evidence to support a conclusion that transport infrastructure, utilities, open space, health services, educational facilities, and broader community infrastructure can absorb the additional demand generated by the project. The absence of a coordinated infrastructure response suggests that the development is being advanced ahead of the capacity required to support it. Approval in such circumstances would be premature and contrary to the principles of orderly and sustainable planning, effectively externalizing infrastructure costs onto the community.
The environmental aspects of the application are similarly inadequate and give rise to serious concern. The documentation does not provide sufficient assurance that issues such as contamination, stormwater management, water quality, and environmental sustainability have been comprehensively addressed. In particular, the absence of a clearly defined, enforceable, and independently verified remediation strategy raises questions as to whether the site is suitable for the proposed use. The proposal also fails to demonstrate alignment with best-practice sustainability benchmarks, including energy efficiency, water reuse, and climate resilience. The lack of meaningful measures to address urban heat island effects further underscores the inadequacy of the environmental response.
The proposal also fails to adequately consider the character and evolving identity of the Waterloo precinct. Even where formal heritage listings do not directly apply, the planning framework requires development to respond sensitively to its context and contribute positively to the urban environment. The application does not achieve this outcome. Instead, it prioritizes density and yield at the expense of coherence and character, resulting in a development that is discordant, visually intrusive, and inconsistent with the broader planning vision for the area. The incremental erosion of local character through developments of this nature is a matter of legitimate planning concern and must be given due weight.
There are also significant procedural deficiencies that further undermine the integrity of the application. The supporting technical reports are, in several instances, incomplete, internally inconsistent, or reliant on assumptions that are not independently verified. Key methodologies are insufficiently disclosed, limiting transparency and preventing meaningful scrutiny. The planning justification is fragmented and fails to reconcile the various impacts identified across disciplines. These deficiencies materially prejudice the assessment process and prevent the Consent Authority from being properly satisfied as to the merits of the proposal.
When considered holistically, the application is contrary to the public interest. It confers substantial private benefit while imposing disproportionate and inadequately mitigated impacts on the surrounding community. It does not deliver a commensurate public benefit in terms of infrastructure, amenity, or environmental performance. The imbalance between private gain and public burden is pronounced and unacceptable within the context of the planning framework.
For these reasons, the Consent Authority cannot be satisfied that the application meets the requirements of the Environmental Planning and Assessment Act 1979. The proposal fails to achieve the objectives of the applicable planning controls, results in unacceptable impacts, and is supported by inadequate and unreliable documentation. Approval in its current form would be inconsistent with sound planning practice and would expose the decision to a high risk of successful challenge on both merit and legal grounds.
Accordingly, I respectfully submit that Development Application D/2021/1415 must be refused.