To Whom It May Concern,
I am writing as a long-standing resident of Spencer Street to lodge a formal objection to the proposed development at 2–16 Spencer Street, Rose Bay.
Having reviewed the application and the associated assessment reports, I am deeply concerned that the bulk, height and overall scale of the proposed building are inconsistent with the established character of our street. Spencer Street is predominantly comprised of low-rise dwellings of one to two storeys, and the proposed development would constitute a significant visual and physical intrusion within this context. Even the applicant’s own documents acknowledge that certain visual and overshadowing impacts are classified as “Severe”, which highlights the extent to which the proposal is incompatible with its surroundings. It is difficult to understand how impacts of this magnitude could be considered acceptable or capable of being mitigated.
In addition, parking and traffic impacts have not been adequately addressed. As residents, we already experience chronic on-street parking shortages, with many households unable to find parking near their homes during evenings and weekends. The Traffic and Parking Assessment accompanying the application appears to underestimate both existing parking stress and the additional demand. The cumulative impact is likely to exacerbate what is already an untenable situation.
Further, Spencer Street is a relatively narrow local road that currently experiences congestion and safety issues, particularly for pedestrians, cyclists, children, and older residents. The development will inevitably introduce a substantial increase in vehicle movements.
While I acknowledge the need for additional housing, this proposal represents overdevelopment relative to the capacity and character of Spencer Street. The scale and intensity of the development do not adequately respond to local conditions or the constraints identified in the reports themselves.
For these reasons, I respectfully request that Council give serious consideration to the concerns of local residents and require significant redesign or refuse the application in its current form.
Yours sincerely,
A Resident of Spencer Street

Rose Bay is NOT a hub. It has insufficient facilities and services for the existing population. There are essentially just 2 main roads in and out of the area, Old South Head and New South Head Roads. At several times of day these roads become gridlocked for hours at a time with school and peak hour traffic. This is a particular danger in case of any emergencies.
Public transport is grossly inadequate with major access blocked by the Public and Royal Sydney Golf Courses. There is no access to trains as there is in Edgecliff, Bondi Junction and even near in Double Bay.
There is only one bank in the Eastern Suburbs Peninsula.
The public schools are already at or close to capacity.
This in no way can this area be considered a suitable hub for multiple development.

Moreover, the building description indicates 13 affordable housing apartments. These apparently do not have any off-street parking, which is already limited. The suggestions that motorbike or bicycle parking would materially address this problem is laughable for apartments in this area and at their likely prices.
Importantly the proposed building to 9 storeys along the north side of Spencer Street would block sunlight to street level on both sides of the street and to all housing on the south side of the street.
Furthermore, it is understood that the water supply and sewerage systems in this area are already on the verge of failure. The proposed increases in residences would likely cause the system to fail.
We consider this an unsuitably sized development for an already overloaded system with no capacity to address these deficiencies.

I support the project

This project will damage surrounding properties - there are well-documented hydrogeological and flooding hazards and strong evidence to date of damages from excavation to surrounding buildings and infrastructure.

The LMR Housing Policy has prompted an influx of SSDAs and other DAs that are proposing excavations for much larger and deeper basements (up to 3 levels underground) to accommodate parking for apartment complexes up to 9 storeys in height. If approved, the excavation of this development will further increase the risk of damages to surrounding buildings and infrastructure.

I am writing to you as a concerned owner at 5 Spencer Street Rose Bay, located directly opposite the proposed State Significant Development at 2–16 Spencer Street Rose Bay. I am writing to register my strong objection to SSD-86122958.

My wife and I chose this building last year because Spencer Street has always been a quiet residential area characterised by modest medium-density housing. Nothing in the planning controls, community consultation, or local character ever suggested that a development of this height, scale or excavation depth would be imposed here.

The proposal now before the Department departs dramatically from the intended R3 medium density outcome and presents unacceptable impacts on the liveability, safety, and amenity of every home across the road, including mine.


Reasons for Objection
1. The height and bulk are excessive for this street
The size and visual dominance of the proposed building are entirely unreasonable for Spencer Street. From my balcony and living areas, the outlook would be replaced by an oversized structure that is inconsistent with the character of this neighbourhood.
This is not the scale of development the R3 zone anticipates. The proposal reads more like an R4 high density scheme, and I do not believe a structure of this size is compatible with the surrounding residential context.


2. Overshadowing of homes opposite, including mine
Morning light is a critical part of how my unit functions. The overshadowing diagrams do not give proper regard to the Draft DCP controls for public and private open space. The scale of the building would cast substantial shadow across several homes opposite, including our building.
The loss of light will have real consequences for comfort, energy use, and quality of life.

3. Excessive car parking and traffic generation
The proposal includes 120 car spaces for 54 apartments. This is far beyond reasonable need and is inconsistent with the objectives of Draft DCP 37, which seeks to limit parking in accessible locations.
As a resident who enters and exits the building multiple times each day, I am very concerned about:
• Higher traffic volumes
• More noise along the street
• Cars queueing on Spencer Street during peak hours
• Increased congestion and obstruction near my driveway
This level of car parking is not required, is not supported by local policy, and would create ongoing amenity issues.

4. Deep, high-risk excavation directly opposite my home
The basement involves three levels of excavation, extending well below the groundwater table in a geotechnically sensitive part of Rose Bay. Our building is directly opposite and sits on the same settlement basin that Woollahra Council has identified as highly vulnerable.
I am particularly concerned about:
• Settlement and ground movement
• Cracking affecting our building
• Long-term disturbance to groundwater
• Construction vibration
• Long duration excavation noise
• Safety risks if the basement design fails
Recent incidents in Rose Bay and Double Bay highlight the very real consequences of deep excavation in this area. The EIS does not provide the technical modelling needed to demonstrate that my home and others nearby will remain safe.

5. Failure to comply with key Woollahra DCP requirements
The application fails to meet several mandatory considerations, including:
• The 1.5 metre excavation setback
• The requirement for fully tanked basements
• The 0.3 metre groundwater drawdown limit for the Rose Bay settlement area
• Excavation volume controls
• Draft DCP Amendment 30 (geotechnical and groundwater safeguards)
• Draft DCP Amendment 37 (parking, dwelling mix, bulk and form)
The EIS makes almost no attempt to address these controls, despite their clear relevance under s 4.15 of the EP&A Act.

6. Insufficient geotechnical, groundwater and settlement analysis
The proposal has not provided:
• Numerical groundwater modelling
• Settlement modelling
• Basin-wide cumulative impact assessments
• Confirmation that the 0.3 metre drawdown limit can be met
• A fully tanked basement design
Without this information, the Department cannot reasonably form the view that our building, or other homes nearby, will not experience damaging settlement or cracking.
This level of uncertainty triggers the precautionary principle and should result in either refusal or a major redesign.

7. Significant construction impacts on residents opposite
Given the scale of excavation and the intensity of basement work, residents opposite would face:
• Prolonged noise disturbance
• Dust and heavy vehicle movements
• Vibration impacting foundations
• Early morning and late evening disruptions
• Safety concerns for pedestrians, children and cyclists
Our street is narrow, with limited manoeuvring space, and simply cannot support the volume of construction activity this project would require without severe disruption.

8. The proposal is not in the public interest
A development of this size, depth and intensity in a sensitive part of Rose Bay is contrary to community expectations, inconsistent with planning controls, and presents risks that extend well beyond the subject site.
It is not in the public interest to place existing buildings and residents at risk from poorly assessed geotechnical conditions or to burden Spencer Street with an oversized building and traffic load.

9. Referral to the Independent Planning Commission
Given the technical complexity, high level of uncertainty and strong community opposition, I request that the proposal be referred to the Independent Planning Commission.
This is too significant and too risky to be determined without independent, specialist scrutiny.

Conclusion and Requested Determination
For the reasons set out above, I respectfully request that SSD-86122958 be refused in its current form.
The site cannot accommodate a three-level basement, the proposal is excessively bulky for Spencer Street, the EIS fails to demonstrate geotechnical safety, and the impacts on residents opposite are unacceptable.
If the proponent intends to pursue a future proposal, it must be dramatically reduced in height and excavation depth, comply with the DCP controls, and include full groundwater and settlement modelling to confirm the safety of surrounding homes.

Thank you for reviewing my submission.

Objection to SSD Application: 2–16 Spencer Street, Rose Bay

I am a local resident writing to object to the proposed State Significant Development at 2–16 Spencer Street. After reviewing the material on exhibition, I have serious concerns about the height, scale, environmental impacts, and the pressure this project will place on already strained local infrastructure. I respectfully request that the Department defer determination until these issues are properly addressed.

1. Exhibition Period Too Short for a Complex Proposal
Given the number of technical documents included in the EIS - particularly around geotechnical conditions, traffic, contamination and hydrology - the shortened exhibition period has not given residents a reasonable chance to obtain advice or properly understand the risks.
Request: I ask that the standard 28-day exhibition period as a minimum, be applied so the community can meaningfully participate.

2. Groundwater, Excavation and Potential Settlement
The EIS acknowledges that the site sits in a sensitive groundwater environment and that the excavation will require significant dewatering. As many neighbouring homes are older and built on shallow footings, any groundwater drawdown could have real impacts on structural stability for both existing homes and future surrounding developments.
I am concerned that the modelling provided so far does not give residents confidence that settlement risks have been fully explored.
Request: Further detailed groundwater and settlement assessment should be required before determination, along with independent dilapidation reports for all surrounding properties.

3. Wind Impacts from a 9-Storey Building
A building of this height is completely out of scale with the existing character of Spencer Street. The proposal is likely to create wind and downdraft issues for pedestrians and neighbours, especially given the site’s exposure to coastal conditions.
The desktop wind analysis provided feels inadequate for a development of this size.
Request: More robust wind assessment should be undertaken before any approval is considered.

4. Acid Sulfate Soils & Flood Risk
The EIS identifies the presence of acid sulfate soils on the site. Excavation in a known flood-prone area creates a genuine risk of these materials being mobilised into the environment if not properly managed.
Request: A more detailed, site-specific management plan should be required up front, not deferred to conditions after approval.

5. Traffic, Construction Access & Servicing
Spencer Street is a narrow residential street already struggling with congestion and limited manoeuvring space. The traffic study seems to assume ideal conditions that do not reflect daily reality, especially when considering construction vehicles, delivery trucks and the number of apartments proposed. In addition, there is currently major sewerage works being undertaken on Carlisle street, and I do not think any development works can even be considered until that is entirely complete in the first instance.
Request: A full construction traffic plan should be provided now, demonstrating how the development can be built and serviced without blocking residents, public transport, or emergency vehicles.

6. Height, Bulk, Overshadowing & Privacy
My strongest concern is the sheer height and bulk of the proposal. A nine-storey tower is completely uncharacteristic for Rose Bay and the local area. It would have major impacts on neighbouring homes, and the character of the local area.
• Overshadowing: The winter shadow diagrams show a significant loss of sunlight to surrounding residences, potentially falling below Apartment Design Guide requirements.
• Privacy: The upper levels appear to directly overlook private outdoor areas and living spaces of nearby properties, with minimal effective screening.
This level of impact is inconsistent with the existing lower-scale residential character of Spencer Street and the broader neighbourhood.

7. Infrastructure Capacity & Cumulative Impact
The EIS seems to consider this development in isolation, yet there are numerous other potential projects now being explored within the Rose Bay area. Without assessing these collectively, the true impact on infrastructure is impossible to understand.
• Sewer and stormwater systems in the area already experience pressure during heavy rain
• Electricity and schooling capacity have not been confirmed by the relevant authorities.
• Traffic and parking pressures will grow substantially if multiple large developments proceed simultaneously
Request: A cumulative infrastructure capacity assessment is essential before any decision is made.

Rose bay is enjoyed by both local residents and as a destination for tourists and visitors both locally and internationally. It is essential that any development in the area is considered in a broader future focussed, placemaking perspective from both a design and functionality perspective.

For these reasons - particularly the height and scale, overshadowing and character impacts, excavation risks, and the lack of clear infrastructure capacity, I believe the development should not be approved in its current form. At minimum, significant additional information and design changes are required before the application can be responsibly assessed.

Thank you for considering this submission on behalf of the residents, citizens and visitors who will be directly affected.

We’re writing to object to the proposed development at 2–16 Spencer Street. We know housing is needed and we’re not against change, but this feels too large and too intense for the spot it’s being placed. After reading what we can, we’re mainly worried about how much extra movement, construction activity and long-term pressure this will bring to a suburb that already feels like it’s reaching its limit.

Spencer Street is mostly low-rise homes — two or three storeys at most — and this part of Rose Bay has a much gentler scale. A nine-storey building would stand out dramatically and change the balance of the street, not just visually but in how it functions day-to-day. There’s a big difference between new housing that blends in naturally and a development that becomes the dominant feature of an area. This proposal feels like the latter.

Traffic is where the long-term impact hits hardest. Rose Bay isn’t a suburb with endless access roads and spare network capacity — it’s small, contained, and already busy at certain times of day. Adding 50-plus apartments and over a hundred parking spaces means more people coming and going, more cars on roads that don’t have much room to absorb extra movement, and more overall strain. When new developments all start arriving around the same period, the effects don’t just add up — they build on each other. One building might be manageable, but several in close proximity can shift the whole rhythm of the suburb.

We don’t need exact traffic counts to feel the reality of this. Residents notice queues getting longer, small delays becoming everyday ones, and formerly quiet streets turning into thoroughfares. Once a pattern like that begins, it rarely reverses. That’s why it seems important to properly understand the combined impact of multiple developments rather than looking at each one on its own.

Excavation and construction are also worrying. Going deep into groundwater means noise, vibration, dust and trucks for a long period of time, and once digging starts there’s no easy way back if things don’t go to plan. A project this size needs solid answers about how disruption will be handled before approval is given, not after.

The removal of trees adds to the concern. Mature canopy isn’t just decoration — it cools the street, absorbs rain, softens the outlook and gives Rose Bay the calm character many of us treasure. Young planting can’t replace that immediately, and once lost, we won’t get it back for decades.

Taken together — height, scale, traffic, excavation, tree loss — this development feels like it pushes well beyond what this part of Rose Bay can comfortably absorb. It may meet certain planning rules, but that doesn’t mean it suits the street or the way people actually live here.

We ask that this proposal be reconsidered unless it can genuinely be shown that the suburb can carry this scale of development without losing liveability, character, or the ease of movement that makes Rose Bay pleasant to live in.

Thank you for taking the time to hear our concerns.

Dear Sirs,
I write as a deeply concerned resident of Rose Bay regarding the increasing use of State-level planning powers to approve major developments while bypassing both Woollahra Municipal Council and meaningful community consultation.
Under the Environmental Planning and Assessment Act 1979 (NSW), particularly Sections 1.3, 1.4 and 4.15, the planning system is intended to promote:
• Ecologically sustainable development
• Proper consideration of environmental, social, and economic impacts
• Public participation in planning decisions
• The orderly and economic use of land

The increasing reliance on State Significant Development (SSD) and State Significant Infrastructure (SSI)provisions under Part 4 and Part 5 of the EP&A Act is effectively overriding:
• The Woollahra Local Environmental Plan (LEP)
• The Woollahra Development Control Plan (DCP)
• Established height, floor space ratio, traffic, heritage, and environmental protections
• And most critically—the will of the local community
This approach directly undermines the intent of local strategic planning and the statutory role of councils under NSW law.

Even more troubling is the failure to uphold the consultation principles enshrined in:
• Section 2.23 of the EP&A Act (Community Participation Charter)
• The NSW Community Participation Plan (CPP)
These instruments require that communities be genuinely informed, consulted, and given real opportunities to influence decisions before major developments are approved. Current practice does not meet these obligations in any meaningful sense.



Uncontrolled Population Density and Infrastructure Strain
The cumulative impact of the State Government’s major project pipeline is driving a rapid escalation of population density in Rose Bay, without the corresponding delivery of infrastructure required under both:
• The NSW State Infrastructure Strategy
• And local infrastructure contribution frameworks
Rose Bay already experiences:
• Severe traffic congestion on New South Head Road and surrounding feeder streets
• Parking saturation
• Overstretched public transport
• Pressure on schools, medical services, coastal access, and emergency services
• Increasing threats to coastal and marine environments
There is no transparent cumulative impact assessment being provided to residents, despite such assessments being an established requirement for responsible strategic planning under NSW planning principles.

Bypassing Council Undermines Democratic Planning
Woollahra Council is the legally designated planning authority to reflect local conditions, community expectations, heritage values, and environmental capacity. When the State repeatedly overrides local planning controls through SSD and Ministerial discretion, it:
• Weakens democratic governance
• Dismantles community trust
• Erodes the legal purpose of LEPs and DCPs
• And creates an unbalanced, developer-favourable system
Residents are not opposed to sensible development. What we strongly oppose is:
• Development imposed without consent
• Population targets forced without infrastructure
• And the sidelining of community voices guaranteed under NSW law



Our Requests to the NSW Government
I formally call on the Government to:
1. Reinstate the authority of local councils in accordance with the EP&A Act
2. Halt the misuse of SSD and SSI pathways for projects that clearly belong under normal council assessment
3. Mandate cumulative population, traffic, and infrastructure impact studies for Rose Bay
4. Demonstrate compliance with the NSW Community Participation Charter
5. Protect coastal and heritage environments from irreversible overdevelopment

Final Statement
If the State Government proceeds with its major project development program in Rose Bay without addressing these failures, the damage—to infrastructure, environment, heritage, and community cohesion—will be permanent.
Residents should not be forced to bear the economic, environmental, and social cost of decisions made without proper legal process, local authority involvement, or genuine public consent.
I expect a written response detailing:
• How NSW planning law is being complied with
• Why council controls are being overridden
• And what safeguards will be implemented for Rose Bay’s future



Yours sincerely,
Sherna Segal

1.Excavation is directly into the groundwater table.
2.Multiple DAs are proposed in this unstable area and each will contribute to cumulative effect of destabilization
3.The site is in a high risk floodway
4.Consultant reports are all DEVELOPER FUNDED and offer no protection to surrounding properties
5.Housing SEPP uplift does NOT APPLY on HIGH RISK LAND
6. Mature trees on the PAVEMENTS are being removed......against the Councils PRINCIPLES
7. The site is within close proximity to Pre SCHOOL AND PRIMARY SCHOOL AND A CHURCH. SPENCER LANE IS NARROW with no pavement Spencer St is used for pedestrian pick up of SCHOOLCHILDREN and the increased traffic is a DANGER to them.
8.Once the AQUIFER is disturbed THE IMPACT IS PERMANENT and IRREVERSIBLE