I object to the proposal on the following grounds:

1. Excessive scale and height
The building’s elevation will dominate the district skyline and permanently alter the visual landscape.
Measured AHD, it would be the tallest structure in the district, presenting unacceptable bulk and scale inconsistent with the area’s established character.
The proposal lacks an appropriate transition in height to surrounding low-rise development.

2. Overdevelopment and density
The addition of 150 apartments is out of character with Castlecrag’s local context and residential scale, more suited to designated major centres such as Crows Nest, St Leonards, or Chatswood.
The intensity of use substantially exceeds what the local area can reasonably accommodate without adverse impacts.

3. Traffic and access impacts
Vehicle entry/exit to Edinburgh Road for both commercial and residential components will generate excessive traffic movements.
The relevant intersection(s) are already operating over capacity; additional volumes will exacerbate congestion, queuing, and safety risks.
Insufficient information has been provided on cumulative impacts, peak-hour performance, and mitigation measures.

4. Public transport and SSD suitability
The site is not on a major transport corridor and lacks the high‑capacity public transport required to support a development of this scale.
Given its location and context, the proposal should not be assessed as State Significant Development.

Requested determination
Refuse the application, or require a substantial reduction in height, yield, and traffic generation, with design amendments that respect local character and capacity.
Require an independent peer‑review of traffic modelling, visual impact, and strategic merit against relevant metropolitan and local planning frameworks.

I oppose the proposed development, particularly with reference to (but not limited to) the topics listed below.
SEARS Table / 5. Design Quality requirements:
The development should achieve Design Excellence in accordance with seven objectives for good design as stated in the NSW Government’s Better Placed design policy.
i.e.
better for people (safe/liveable):
better working (functional/efficient)
better value (lasting community value)
better look and feel (engaging/attractive)
better landscape (environmental quality)
better community (inclusive/connected)
better process (collaboration)

On the southern and south-eastern side of the proposed development the houses, Community Centre, Kindergarten, and Library (where I am a volunteer) will lose much of their winter sun. The land drops away very steeply on the southern side of the development, solar access will be lost, greater use of heating and dehumidifying would be needed. Solar panels will be useless. The playground and kindergarten forecourt will be damp, and the children will be denied much needed winter sun.
This is a Griffin Conservation Area. The development shows total disregard for Griffin’s design for sharing access. The proposed development will not be better for the people living, working, or visiting these areas.
The height of the proposed development is completely out of character and will greatly disaffect those properties/people to the south and south-east. The built environment would in no way be subservient to the natural environment.
Every one of those 7 objectives of Design Quality are missing.

SEARS Table / 7. Environmental Amenity requirements:
“Assess amenity impacts on the surrounding locality, including solar access, visual privacy, view loss and view sharing, as well as wind, lighting and reflectivity impacts. A high level of environmental amenity for any surrounding residential or other sensitive land uses must be demonstrated”.
The proposed development is in total opposition to these qualities.

Increased traffic will seriously jeopardise access and egress, especially of emergency vehicles. There is a hospital in Castlecrag. Longer queues in peak hours would warrant an extra lane being carved off the site to allow additional traffic exiting Castlecrag.
Disregard for Castlecrag: Promotional hoardings at the vacant site are deliberately misleading – a beautiful photo of the golf course in the next suburb - the other side of the next ridgeline and down into a bay. No way, even from the proposed top level would anyone be able to see down onto that golf course. The developers show a complete disregard for Castlecrag residents.
High Rise Hell
I reject the SSD proposal and support the existing Development Consent (3-5 storeys 38 apartments) already granted.

Subject: OBJECTION to Proposed Mixed-Use Development at 100 Edinburgh Road, Castlecrag (SSD-90134958)

I am writing to formally lodge my strong objection to the State Significant Development proposal for 100 Edinburgh Road, Castlecrag (the "Quadrangle" site). While I recognize the need for a functional redevelopment of this site, the current proposal is a gross overdevelopment that threatens the fundamental character and heritage of Castlecrag.

My objections are based on the following key grounds:

1. Excessive Scale and Height Inconsistent with Local Character
The proposed height of up to 13–14 storeys (comprising two residential towers) is entirely unprecedented and inappropriate for Castlecrag. This suburb is world-renowned for its low-scale, "organic" architecture designed by Walter Burley Griffin and Marion Mahony Griffin. A high-rise tower of this magnitude would dominate the skyline, destroy the village atmosphere, and set a dangerous planning precedent for "density-at-all-costs" in sensitive heritage conservation areas.

2. Departure from Previously Approved DA
In November 2024, the Sydney North Planning Panel approved a development for this site that was the result of extensive community consultation. That approved plan (3–5 storeys) was deemed suitable for the site’s topography and context. This new SSD proposal, which seeks to jump from 38 residences to 150, is a massive escalation that ignores the carefully balanced outcomes of the previous planning process. The use of the SSD pathway to bypass local planning controls is an affront to the community.

3. Heritage and Environmental Impact
Castlecrag is defined by its "harmony with nature." This proposal involves significant bulk and scale that will:

Overshadow adjoining residential properties and public spaces.

Impact the Heritage Conservation Area: The height and modern tower design do not respect the Griffin legacy or the specific site-specific Development Control Plans (DCP) that were intended to limit height to AHD 97.49 (approx. 11m above Edinburgh Rd).

Tree Loss: I am concerned about the long-term viability of the mature trees on the southern boundary given the increased excavation required for four levels of basement parking.

4. Traffic and Infrastructure Strain
The intersection of Edinburgh Road and Eastern Valley Way is already a significant bottleneck. Increasing the residential density by nearly 400% (compared to the approved DA) will create an unmanageable increase in traffic volume. The proposed basement parking and increased delivery requirements for the retail component will lead to further congestion and safety risks for pedestrians in the village heart.

5. Loss of Commercial Vitality
The previous Quadrangle was a community hub. By prioritizing high-density residential towers, the proposal risks diminishing the "village" feel of the retail space. The community needs a functional, accessible local centre, not a high-density residential enclave that prioritizes developer profit over local amenity.

Conclusion
The 100 Edinburgh Road site deserves a design that celebrates Castlecrag’s unique history and environment. This SSD proposal does the opposite—it imposes an urban high-rise model onto a sensitive suburban bushland setting.

I urge the Department to reject this proposal in its current form and require the developer to return to a scale consistent with the 2024 approval and the Willoughby Local Environmental Plan.

Sincerely,

I write to object to the proposed mixed-use development comprising two residential towers, approximately 150 apartments including 10 designated as affordable housing, retail space, basement parking, rooftop communal areas, and strata subdivision.

1. Incompatible scale and bulk
This site sits within one of Australia’s most important enclaves of early modernist architecture. The scale, bulk, and visual dominance of two towers up to 13 storeys are fundamentally incompatible with this context.

2. Loss of architectural character
This area was designed with a clear idea in mind. Buildings should sit within the landscape, not dominate it. The natural shape of the land, the trees, and the bush setting are part of the design. The buildings are kept to a human scale and feel connected to their surroundings. This approach, associated with planners such as Walter Burley Griffin, is what gives the area its distinctive character and underpins its importance as a rare and nationally significant part of Australia’s architectural and cultural history.

3. Detracts from beauty and cultural significance
The proposed development departs from these principles. Its height and bulk will overwhelm the area. It will detract from the beauty of this place and from its cultural significance. This is not just a local issue. This area represents something unique in Australian architectural history, and once it is changed in this way, it cannot be restored.

4. Overdevelopment of the site
The proposal represents overdevelopment of the site. The height and density exceed what is appropriate for this setting. It will be highly visible and will disrupt the existing scale of the area.

5. Lack of public transport
I am also concerned about the location of such a dense development in an area with limited public transport. Developments of this scale require strong, accessible transport links to function sustainably. In this case, public transport access is limited, traffic demand will increase, and residents will rely heavily on private vehicles. This outcome conflicts with sound urban planning and environmental goals.

6. Minimal affordable housing benefit
The inclusion of 10 affordable housing units within a 150-apartment development is minimal and does not reflect the intent of planning frameworks designed to increase access to housing for those in need. The proportion is too low to deliver meaningful impact, and the location lacks the transport connectivity required for equitable access to employment and services. The proposal appears to rely on planning mechanisms without delivering genuine public benefit.

7. Harmful precedent
Approval of this development will set a precedent for similar proposals and accelerate the erosion of a unique architectural and environmental asset. Short-term financial gain should not outweigh the protection of places that are part of Australia’s shared history and identity, or our responsibility to preserve them for future generations.

8. Inconsistent with planning intent
This proposal is inconsistent with the character, planning principles, and infrastructure capacity of the area. It fails to respect the architectural significance of the precinct, does not align with sustainable transport planning, and provides only a token contribution to affordable housing.

For these reasons, I strongly object to the proposal and urge that it be refused in its current form.

Objection Summary – Proposed Development (Willoughby LGA, Castlecrag)
I strongly object to the proposed development at 100 Edinburgh Road on the basis that it represents a gross overdevelopment of the site and is fundamentally inconsistent with the planning objectives and character of both the Willoughby Local Government Area and the unique suburb of Castlecrag.
The scale of this proposal is excessive and entirely out of context. A site that was previously approved for a modest three-storey development has now escalated into a proposal for two towers reaching up to 12 storeys, and up to 14 storeys at the rear. This dramatic increase in height and bulk is unreasonable and represents a clear overreach that will dominate and overwhelm the surrounding neighbourhood.
Castlecrag is renowned for its natural beauty, low-rise built form, and its integration with the surrounding bushland. This proposal fails completely to respect these defining qualities. Instead, it introduces a large, bulky, and visually intrusive development that will appear out of place and significantly detract from the character of the area. The design is overbearing and unattractive, and will permanently alter the visual identity of the suburb.
The proposal also raises serious concerns in relation to traffic and access. The existing road network, particularly with effectively limited access in and out of the area, is not capable of supporting a development of this scale. Increased traffic, congestion, and safety risks for residents and pedestrians are inevitable.
There appears to be a lack of genuine consideration for heritage and environmental impacts. The proposal risks loss of vegetation, increased urban heat, and further erosion of the natural landscape that defines Castlecrag. These impacts are inconsistent with responsible and sustainable planning.
The scale of the development—comprising approximately 150 apartments with only a minimal number classified as “affordable”—raises further concerns about the true community benefit of this proposal. It appears to prioritise high-density, high-end development outcomes over the needs and character of the existing community.
There will also be significant impacts on residential amenity, including overshadowing, loss of privacy, and increased noise during both construction and ongoing use. These impacts are unacceptable for surrounding residents.
In addition, the proposal threatens the viability of existing local businesses and undermines the established community fabric. Developments of this scale risk replacing the unique, local character of the area with something far more generic and disconnected from the community.
The capacity of existing infrastructure has not been adequately addressed. Parking, drainage, and local services will all be placed under increased strain, with no clear or sufficient mitigation.
In summary, this proposal is excessive in scale, inappropriate in design, and inconsistent with the character and planning expectations of Castlecrag. It represents a significant departure from what was previously approved and introduces unacceptable impacts on residents, infrastructure, and the environment.
This development is not in the public interest and should be refused.

There are many things about the proposal that I object to.
Firstly, I do not see how it can be considered as meeting the SSID requirements given its location - the site is NOT within a kilometre of a transport hub and hence many of the new residents will have no way of getting to work/school other than private transport thereby adding to the significant congestion that currently occurs especially during morning and afternoon peak periods. This has all the hallmarks of being a public safety issue were there a need to evacuate the suburb due to some form of emergency. For example a bush fire - not unimaginable in a bush suburb. It’s hard enough currently getting in or out of the peninsula when there is an accident or breakdown on eastern valley way or alpha road. In fact, school sporting events at the nearby Shore Oval and Leisure centre already cause significant traffic congestion and driver frustration with increasing frequency.
A second concern I have is the scale of the proposed development. It will be a giant carbuncle on the ridge top. Every home in Castlecrag is going to feel overlooked and will loose its privacy. The properties closer to the site will loose their light and this will impact existing gardens and trees - not in a good way. It’s just too big and so out of keeping with the heritage standing of the Griffin conservation area which the site is adjacent to. It conflicts with the Griffins vision of the built landscape being subservient to nature and the natural contours of the land. And it goes against the WCC planning rules (a 2story maximum) so fiercely applied throughout the suburb. I have lived in Castlecrag for 27 years and my parents and grandparents (all now deceased) lived here since 1952 and there has been a lot of change in that time. Closing the local primary school was the last significant mistake the state government made. Please don’t let it make an even bigger one by allowing this oversized building to be built.
Regards
Vicki Craig

100 Edinburgh Road, Castlecrag
Mixed-use Development SSD-90134958

Objection to EIS/Development Application

I am a young woman (20) living in Castlecrag and have been living here my whole life. The culture of Castlecrag is very special to me and my family, and an apartment building of this scale, and for the purposes it is being built for will have a severe negative impact on our community.

As a young person, affordable and accessible housing is extremely important to me. These apartments have been advertised as both luxury and affordable. Apart from the clear hypocrisy in these statements, the affordability aspect is simply not true. It has been estimated that the ‘affordable’ apartments (10 out of the 150 requested apartments, equating to 6.7% of all the apartments) will be rented for at least $1400/week, which equates to $72,800 per year. With the average income in Sydney after tax and Medicare levy being $81,700 (likely less for young adults entering the workforce), living in these ‘affordable’ apartments would leave $8,900. That has to then cover food, bills, fuel, car payments, healthcare etc. It is absolutely ludicrous that Conquest is deeming these as affordable. Personally, I live with epilepsy and have for 10 years. I still have to go to at least one neurologist’s appointment per year, complete scans at least once per year, and have to purchase medication monthly. This would leave near nothing, even with private health insurance to cover all the forementioned costs of living.

Conquest have also claimed that there is adequate public transport around Castlecrag. As a young person, I can attest that this is completely untrue. One of my main goals growing up was to get my licence, because without one, there is no way to efficiently get around. One of the 6 bus stops they claim are within 150 meters of these apartments only runs down to the end of Castlecrag, which in reality will not provide the residents of this apartment to travel to work/school. If you do not have a car, you will have to catch a bus, which come very infrequently, if they come at all. The closest train/metro station is at least an hours walk away if you miss this bus. That is the extent of the public transport in Castlecrag, which is a far cry from what these developers are claiming. With this being said, even with a car, the traffic out of Castlecrag is extreme, and this development would make it significantly worse.

The nature is another important and thriving part of Castlecrag, which all the community are proud of and work to maintain. This development has not started past digging a hole in the ground and is already killing trees. If you look at the parameters, it is clear that the flora is suffering. Conquest has claimed that they will address this by planting 6 small trees, in pots, outside the front of their ridiculously large building. This demonstrates a complete lack of care about the environment, and their lack of understanding of the culture and community of Castlecrag.

To expand on the sheer size of what they are proposing to build, when standing across the road from this building, at eye level, you cannot even see the top of it, which is made clear by their ai generated images of their building plan.

Overall, allowing Conquest to build these apartments would permanently alter the culture, community, and beauty of Castlecrag in an extremely aggressive and negative manner. Their claims are not only false, but they contradict themselves, showing a complete lack of understanding of not only the community of Castlecrag, but of their own project. They are building apartments which are completely unattainable to the majority of the population. They are building apartments and justifying them with completely false claims. And they are building apartments that will change the future of Castlecrag, which will destroy everything our community has worked so hard to preserve.

I am writing this submission as a previous resident of the Castlecrag area prior to moving to Moss Vale.My children attended Glenaeon school and we have had many years of involvement with the Castlecrag community.
I object to this proposal for 3 reasons.
1) Castlecrag is a unique area and although Council has not included the proposed site in its Conservation area, it is the gateway to the whole peninsular. Walter Burley Griffin and his wife Marion, bought this tract of land on which to develop a unique community which pays homage to the natural world. His philosophy resulted in buildings which did not supercede the natural world and blended aesthetically with that world. Whilst housing is an issue the State Government must address, to desecrate the site by building a monolith of two structures towering over the suburb would be to dishonour the contribution and intention of that great architect. Griffin intended for that whole peninsular to be a model of how to work complementary with nature, not dominating it.
This proposal completely negates that principle and would undermine the unique heritage that Castlecrag offers to walkers. swimmers, boaters , all lovers of nature. Being so close to the city and the harbour is unique not just for the current generations but for all subsequent generations. It is our responsibility to preserve that heritage and honour the legacy Griffin and his wife left us.
2) Being at the gateway to the peninsular, the practical and logistical aspects of the development proposal must be called into question. Currently, there being only one road in and one road out presents difficulties which become obvious at peak times. To add another 100 vehicles to the mix of cars leaving the area around 6.00 a.m. - 9.00 a.m. and returning in the afternoons between 3.00 and 6.00 p.m.would create an unsustainable situation. Also, according to the NSW Planning portal on affordable housing, new developments would need to be within 800 metres from a railway station, which this site is not. The legislation was intended for low income working households who could avail themselves of public transport. The bus service from Castlecrag is neither regular nor reliable therefore creating extra issues..
3) This proposal is advertised as offering affordable housing and given the likely value of these apartments being beyond the realms of most people, this is not serving the people for whom this new law was intended.
Affordable housing as per the planning portal states,
"The NSW Government is tackling the housing crisis by facilitating the increased supply of social and affordable housing for low-income households and essential workers." Low and middle income households are defined as between $70,000- $100,000 per annum. Given the likelihood of these apartments being in the multi millions , Conquest has not demonstrated how they would be able to provide such accommodation at " 20%-30% below the market rate " ( a recently advertised 3 bedroom house in Castlecrag at 99 Edinburgh Road was advertised at $2,300 per week so 20% of that would be still $1,840 per week, an amount no low or even middle income household could afford ) Thus their affordable housing would be UNAFFORDABLE to low income buyers or renters. . These apartments will be for the wealthy only and will not address the housing crisis for those in need. The State government would be better placed approving sites which remain within the budget of low-middle income households.
Finally, to disregard the requests of the community who had already worked with Council to develop an acceptable proposal, is to disrespect the hard work and commitment of those individuals.
Castlecrag is an area of natural beauty for all and the community should not be penalised by destroying the quality of its environment. Willoughby council when asked whether it had filled its quota of new housing without this development said yes in the affirmative. This is not a necessary or desirable venture but a commercial proposal clothed in altruistic intentions.
In dealing with this proposal, the State Government should consider the ethics of approval, and support the local community who already have a development approved which is consistent with its heritage value.

As a resident of Castlecrag, I strongly object to the proposed development. We have lived in Castlecrag for 9 years, having chosen the suburb for its heritage, its unique bushland setting and its strong community. The proposed development will irreparably compromise the very things that make Castlecrag special and liveable.

In completing significant restoration work to our own home, we complied with heritage, design and landscape provisions of the suburb. We went to great personal expense to ensure that our development supports the Griffin ethos, building subservient to nature, addressing the landscape, no fences, low rise, etc. How is it that some blow-in deep-pocket developer can ignore all of these important requirements that the rest of us have all had to comply with? For over 100 years, the development in this suburb has aligned with the Griffins’ ethos. It is unacceptable to throw that away without appropriate consultation, and without a proper plan for the growth and development of our suburb.

This past weekend, we opened our home in celebration of Walter Burley Griffin’s 150th birthday. Hundreds of people toured our home. We met people who had come from Tasmania, Victoria, South Australia and Canberra especially for this event. We have had visitors from the US, Europe and Asia visit to see our home, preserved carefully as an authentic example of good design. We have had groups of students visit. Countless architects, landscape designers, urban planners… They come because Castlecrag is special, it is world-renowned for its integrity as a suburb that embodies the Griffins’ ethos. This proposed development throws that away. It’s a slap in the face for those of us who value heritage and who do the right thing to protect it.

I am not anti-development – I am strongly in favour of the approved 38 apartment plan. However the current proposal for a 150 apartment, two 15-storey development is entirely inappropriate for the site. Its scale is completely out of context, and being sited on a ridgeline exacerbates this further. It encroaches on the heritage setting, dominates the conservation area and disrupts the heritage integrity of Castlecrag. Its vertical dominance is inherently misaligned with the setting, dominating the tree canopy and failing to appropriately address or interface with the adjacent low-rise development.

The excessive height, bulk and misaligned form of this proposed development incorrectly relies on low to medium rise uplifts that are not designated for this area. It bears no resemblance to any of the planning controls ever contemplated for this area, and is even greater than what is permitted in suburbs with larger town centres.

A far more effective and appropriate approach to growth would be to uplift zoning along the full Eastern Valley Way corridor to encourage 4-6 storey development. This would deliver substantially more overall housing at an appropriate scale addressing a road that can handle additional traffic. Building the twin towers on a two-lane street servicing an entire suburb is an insane proposition.

Castlecrag should grow and develop. We want more families to be able to enjoy this incredible place, but we need a proper plan for growth that doesn’t throw away what’s special and valuable about Castlecrag. The government should reject this proposal, invest in a proper growth plan for Castlecrag, consult with the community in developing that plan, and then approve all future development in line with that plan. Spot zoning doesn’t deliver good outcomes for communities, it only benefits rich developers. Please don’t subject Castlecrag to that fate.