**FORMAL OBJECTION TO DEVELOPMENT APPLICATION SSD‑89584717**
**Submitted by:** Resident, Unit 18, No. 46 Stewart Street
**Directly Adjacent Affected Property**

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## **1. INTRODUCTION**

I am the owner and resident of **Unit 18, 46 Stewart Street**, immediately adjoining the proposed development under **SSD‑89584717**. I submit this objection on the basis that the proposal will cause **severe, unacceptable, and irreversible impacts** on my home, my health, my amenity, and the wellbeing of the many elderly residents living in the surrounding buildings.

This objection is based on **direct, lived proximity** to the site and the **significant cumulative impacts** that have not been adequately assessed, mitigated, or justified.

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# **2. SUMMARY OF KEY OBJECTIONS**

1. **Loss of privacy, sunlight, and view** to my unit (Unit 15), causing permanent amenity loss.
2. **Excessive noise impacts**, including construction noise, operational noise, and after‑hours disturbance.
3. **Dust, air quality deterioration, and health risks**, especially given my documented medical condition.
4. **Severe impacts on elderly residents** in neighbouring buildings, many of whom are vulnerable.
5. **Traffic congestion, parking pressure, and unsafe access** on an already narrow and constrained street.
6. **Overdevelopment and inconsistency with neighbourhood character**.
7. **Failure to adequately assess cumulative impacts** on adjacent residential buildings.
8. **Construction impacts not properly mitigated**, including vibration, structural risk, and loss of quiet enjoyment.
9. **Insufficient community consultation** and lack of transparency.
10. **Non‑compliance with planning principles**, including SEPP, local controls, and amenity protection.

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# **3. DETAILED OBJECTIONS**

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## **3.1 Loss of View, Privacy, and Residential Amenity**

As a resident of **Unit 15**, my windows and balcony directly face the proposed development site. The proposal will:

- **Block my existing view**, which is a key feature of my property’s value and amenity.
- **Overshadow my unit**, reducing natural light and increasing reliance on artificial lighting.
- **Create direct line‑of‑sight into my living areas**, resulting in a **serious privacy breach**.
- **Reduce cross‑ventilation**, making the unit hotter in summer and less liveable.

The NSW Land & Environment Court’s **Planning Principle on View Loss (Tenacity v Warringah)** clearly states that **view loss must be minimised**, especially where residents currently enjoy established outlooks.

This DA fails that test.

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## **3.2 Noise Impacts – Construction and Ongoing**

The proposal will generate **continuous, high‑intensity noise**, including:

- Demolition noise
- Heavy machinery
- Concrete cutting
- Truck movements
- After‑hours deliveries
- Operational noise from the completed development

My bedroom faces the site. I already suffer from a **medical condition that affects my sleep**, and any increase in noise will have **serious health consequences**.

The Noise Management Plan is **inadequate**, lacks enforceable limits, and does not address:

- Sleep disturbance
- Early‑morning works
- Weekend works
- Noise reflection off surrounding buildings
- Cumulative noise impacts on elderly residents

This is unacceptable.

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## **3.3 Dust, Air Quality, and Health Risks**

The proposal involves significant excavation and construction activity that will generate:

- **Dust plumes**
- **Fine particulate matter**
- **Diesel emissions**
- **Concrete and silica dust**

My medical condition makes me **highly sensitive to airborne pollutants**, and prolonged exposure will worsen my symptoms.

The Dust Management Plan is **generic**, not site‑specific, and does not address:

- Prevailing wind direction
- Proximity to residential balconies
- Elderly residents with respiratory issues
- Continuous monitoring
- Enforcement mechanisms

This poses a **serious health hazard**.

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## **3.4 Impacts on Elderly Residents**

The building next door houses **a large number of elderly residents**, many of whom:

- Have mobility issues
- Have respiratory conditions
- Are sensitive to noise and vibration
- Rely on quiet, stable living environments

The DA does not address:

- Accessibility impacts
- Emergency access during construction
- Noise‑related stress
- Dust‑related health risks
- Disruption to essential services

This is a **major oversight** and demonstrates a lack of consideration for vulnerable community members.

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## **3.5 Traffic, Parking, and Safety Concerns**

Stewart Street is already:

- Narrow
- Congested
- Frequently blocked by delivery vehicles
- Used by pedestrians, including elderly residents

The proposal will add:

- Construction trucks
- Trade vehicles
- Increased parking demand
- Reduced visibility
- Higher risk of accidents

The Traffic Impact Assessment is **incomplete**, **outdated**, and **fails to reflect real‑world conditions**.

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## **3.6 Overdevelopment and Inconsistency with Local Character**

The scale, bulk, and height of the proposal are **excessive** and **incompatible** with the surrounding low‑rise residential environment.

The development will:

- Dominate the streetscape
- Create a canyon effect
- Reduce sky exposure
- Overwhelm neighbouring buildings

This is **not in keeping with the established character** of Stewart Street.

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## **3.7 Construction Impacts – Vibration, Structural Risk, and Safety**

The DA does not adequately address:

- Vibration impacts on neighbouring buildings
- Potential cracking of walls and foundations
- Structural monitoring
- Safe pedestrian access
- Emergency vehicle access
- Noise barriers
- Dust suppression

Given the proximity to my unit, these risks are **unacceptable**.

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## **3.8 Inadequate Community Consultation**

Residents were:

- Not properly notified
- Not given sufficient time to respond
- Not provided with clear, accessible information
- Not consulted on alternatives

This undermines the integrity of the planning process.

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## **3.9 Non‑Compliance with Planning Principles**

The proposal appears inconsistent with:

- SEPP (Housing)
- Local Environmental Plan (LEP)
- Development Control Plan (DCP)
- NSW Planning Principles on amenity, overshadowing, and view loss
- Environmental Planning & Assessment Act requirements for impact minimisation

The DA fails to demonstrate that impacts have been **avoided**, **minimised**, or **mitigated**.

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# **4. REQUEST FOR REFUSAL**

Given the **significant**, **unmitigated**, and **unacceptable** impacts on:

- My health
- My amenity
- My property
- My sleep
- My privacy
- My view
- My quality of life
- The wellbeing of elderly neighbours

I strongly request that **SSD‑89584717 be refused** in its current form.

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# **5. IF APPROVED, STRICT CONDITIONS MUST BE IMPOSED**

If the consent authority is minded to approve the development, I request the following mandatory conditions:

- No works before 8am or after 5pm
- No weekend or public holiday works
- Continuous dust monitoring
- Acoustic barriers installed before construction
- Independent structural monitoring of neighbouring buildings
- No truck idling
- No after‑hours deliveries
- Privacy screens facing my unit
- Height reduction
- Setback increases
- Real‑time noise monitoring
- A 24/7 complaints hotline with mandatory response times

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# **6. CONCLUSION**

This development will **fundamentally and permanently damage my home, my health, and my quality of life**, and will severely impact the elderly residents who rely on a quiet, stable environment.

The proposal is **overly intrusive**, **poorly justified**, and **incompatible** with the surrounding residential community.

For these reasons, I strongly oppose SSD‑89584717 and request that it be **refused**.

To Whom It May Concern,

I am writing to formally lodge my strong objection to the proposed Seniors Housing development at the Lottie Stewart Hospital site. As a local resident, I believe this proposal, in its current form, represents an overdevelopment that prioritizes profit over community welfare, local character, and the genuine well-being of our aged and vulnerable citizens.

The grounds for my objection are detailed below:

1. Loss of Accessible Green Space, Amenity, and Well-being
The local gardens at Lottie Stewart Hospital currently serve as a vital, safe, wide-open space for reflection, privacy, and escape from everyday chaos. This green infrastructure is essential for the mental and physical health of both local residents and the vulnerable community members the site serves. The destruction of this peaceful environment is an unacceptable loss of local amenity that cannot be easily replaced.

2. Incompatible Scale and Impact on Local Character
Our community is defined by its low-rise, low-density, and peaceful residential character. Introducing a high-density development into this quiet pocket will completely alter the local environment. A massive shift in scale threatens the very fabric of our neighborhood, replacing a serene community with overbuilt infrastructure.

3. Traffic, Noise, Pollution, and Safety Concerns
The introduction of a large-scale housing project will fundamentally disrupt the local ecosystem through:

Traffic Congestion: Local roads are not built to handle the significant influx of construction vehicles, service vehicles, and residential traffic this development will bring.

Environmental Impact: The community will face a severe increase in noise and air pollution, completely stripping the area of its quiet, peaceful nature.

Safety and Crime: The rapid, high-density alteration of a low-density neighborhood introduces increased security risks and alters the safety dynamics of our streets.

4. Deficient Community Consultation and Lack of Social Responsibility
There has been an egregious lack of meaningful, thoughtful consultation with local residents and homeowners. The current proposal demonstrates a disregard for the voices of those who live here. Furthermore, by packing a high-density footprint onto this site under the guise of "seniors housing," the developers appear to be driven by financial gain rather than a genuine, compassionate interest in the well-being of the elderly or vulnerable community members.

Conclusion & Demands
This project is an inconsiderate and inappropriate development for this site. I urge the planning authority to reject the proposal in its current form.

If the project is to proceed in any capacity, it must be completely redesigned to actually think about and integrate with the community. I demand that the developers:

Conduct a rigorous, transparent community consultation process.

Significantly scale back the density and height of the project to match the surrounding low-rise neighborhood.

Guarantee the preservation of the existing local gardens and open green spaces to maintain the community's calm privacy and environmental integrity.

Thank you for your time and consideration of this submission.

Objection based on the following
I am a Property owner and full time resident at the nearest perimeter fence line of the proposed redevelopment.

I have significant concerns and strong grounds for opposing or rejecting this Redevelopment proposal in its current form and will attempt to list just some of those reasons and concerns here. I will also be seeking further professional, legal and or parliamentary support in this same matter.

I have never been contacted, questioned or known to be given any consideration in regard to this application, its content and ultimately, its impact on me, my young at risk family or even my nearest neighbours for that matter. 

The SSD proposal is absent of any genuine social impact studies and completely lacks and overlooks the significant impacts on my personal property, health, privacy and well being, and even that of the other 36 dwellings within the private estate where I live which also happens to be sandwiched between this (SSD Application) and Timor barracks (another likely future redevelopment currently for sale) on the other side of my private estate property.

This redevelopment proposal is not only fundamentally flawed, it is a mostly regurgitated document lacking any evidence of or plans to mitigate (or at least address) the many number of concerns, issues and shortfalls in its presentation. It also exaggerates or misrepresents many facts such as the site being in a major transport hub and yet there are no trains, no trams and no light rail within miles, and just a bus that services the area.

In its entirety, I cannot even see one, realistic practical plan to address even the most basic of issues that will arise for myself or many of my neighbours. There is not even a clear description, construction plan or timeline provided let alone any studies on the effects and therefore, appropriate plans on how they will address the changes, damage to both the environment (safe, peaceful neighbourhood) and the personal health and well being of its adjoining (neighbouring) occupants, which is a mixture of young families, vulnerable and at risk (young and old) people and even the local wildlife for that matter.

I have two young boys with asthma, one of which has previously been hospitalised due to respiratory problems caused by (inter alia) poor quality air, and wondering how they plan to protect against and reduce the risk of this or something similar happening. Death is a very serious consequence of neglect and or allowing a development of this type to proceed without taking every conceivable measure to mitigate all (especially human life) risks associated with its activity.

I am right smack bang in the middle of the downhill flight path and in the closest most immediate vicinity of these proposed works but had no consultation, no communication and no attempt from the applicant whatsoever to contact, ask or consider my views and opinions or to learn more about the likely impact and consequences to me, my family or even my adjoining neighbours who also have young children. 

In addition to the following list of direct and alarming consequences and or concerns to me, my neighbours and I have also collated a list of not only concerns but real likely consequences and effects from this SSD if it goes ahead in its current form, and this will be supplied and submitted independently by a representative body.  My Personal and very real concerns and questions are among but not limited to the following items;
(Where are the plans to address these and who, when and where will a social impact study be carried out?)
1/   Demolition/ Construction Noise
2/   Air / water Pollution and flooding
3/   Traffic and parking congestion, noise and control
4/   Security, Privacy and safety - increased volume of people
5/   Storm and wastewater runoff - Sewage (travels through our complex)
6/   Vibration and land movement affecting building structure/ integrity incl. my retaining walls
7/   Dilapidation report/s and related remediation works and responsibility
8/   Significant visual change to my current green outlook - who would be looking directly into my bedroom and living area during and post any demolition and construction?
9/   Land degradation due to over development
 10/   Building heights are too high, inconsistent and not in keeping with the local area.
11/   Land zoning/- conditions of use per bequest of Sir Frederick Harold Stewart
12/   Impact (likely reduction) to property values during the years of construction

Some additional questions include, where are the resulting plans deriving from a Social impact study?

Who is going to manage and oversee the findings of an impact study and make recommendations to address the identified issues.

Who or what independent auditor will oversee the implementation of all recommendations and be a conduit between existing local residents and the developer.

What independent body will be responsible and or accountable to ensure and or enforce compliance of any potential satisfactory solutions that may be put in place.

Who will take responsibility and fund the cost for dealing with anything and everything from handling and addressing complaints to providing temporary accommodation or support to residents displaced or in any way impacted (health, mentally, physically or even structurally) by the proposed long term works and therefore, social and environmental changes proposed.

Last but certainly not least, why is this project even being considered in its current form?
While I am actually in support of a genuine residential aged care facility or similar, this is a far cry from anything providing meaningful care, respite or otherwise for the aged and frail. It is nothing more than a large residential profit grabbing development disguised as a seniors living estate. Furthermore, it is also being disguised as something it is not, in order to qualify and be given expedited treatment in the evaluation and approval process.

I and no doubt many others would appreciate a full accountable re-evaluation of this SSD application and await a meaningful response to our concerns and issues raised herein. 

 Thank you,

TO: NSW Department of Planning, Housing and Infrastructure
Assessment Team - Major Projects
RE: Lottie Stewart Hospital Seniors Housing Redevelopment - Submission from Directly Adjoining Resident
DATE: 21 June 2026

Dear Assessment Team,

I am writing to formally lodge my submission regarding the proposed redevelopment of the Lottie Stewart Hospital site. As a property owner and full-time resident whose backyard shares a direct boundary with the project site, I will be profoundly and uniquely impacted by this development.

I do not object to the proposal in its entirety and support the responsible development of seniors housing in our community. However, I am deeply concerned that the current environmental and social impact statements do not adequately address or protect the health, safety, privacy, and livelihoods of immediately adjoining neighbours.

Because I work from home full-time remotely, the site’s construction and ongoing operations will directly impact my ability to earn a living through client calls, meetings, and focused work. I request that the following issues be stringently addressed and incorporated into mandatory Conditions of Approval for the project to proceed.

1. Asbestos and Hazardous Materials Management
Given the age and former hospital use of the site, there is a high risk of legacy hazardous materials, particularly asbestos. Dust drift into my directly adjoining backyard presents an immediate health hazard.
Requested Condition: The developer must provide a transparent, publicly accessible Asbestos Management Plan (prepared by a licensed specialist) prior to any demolition. This must include real-time air monitoring equipment installed along our shared boundary, with data publicly available to residents and an immediate “stop-work” trigger if air quality thresholds are breached. All removal must be undertaken by fully licensed asbestos removalists with strict containment protocols.

2. Noise, Vibration, and Work-from-Home Impacts
Standard construction hours (7:00 am to 6:00 pm) completely overlap with my professional working hours. Continuous noise, vibration from heavy machinery, and dust will severely impair my productivity and livelihood.
Requested Condition: A strict Noise and Vibration Management Plan must be enforced, including mandatory respite periods for high-impact works (such as rock-breaking or piling) during core business hours (e.g., 9:00 am - 5:00 pm). Works should be restricted to 8:00 am - 5:00 pm weekdays only, with no high-noise activity on weekends or public holidays. An independent pre-construction dilapidation report must be conducted on my property and boundary structures (including retaining walls) at the developer’s expense.

3. Dust Suppression, Amenity, Privacy and Visual Impact
My backyard and living areas are highly vulnerable to dust deposition, runoff, loss of privacy, and overshadowing from the proposed seven-storey buildings.
Requested Condition: Physical hoarding and dust screens of adequate height must be erected along the boundary before demolition begins. Active dust suppression measures (including wetting of debris) must be maintained, especially on high-wind days. The development design should incorporate increased setbacks, screening, and lower building heights or stepped forms adjacent to residential boundaries to minimise overlooking, overshadowing, and visual bulk.

4. Traffic, Boundary Access, and Safety
As highlighted by my neighbours, the influx of heavy construction vehicles, service vehicles, and future residential traffic will create congestion and safety risks. Vehicles will operate directly adjacent to my boundary and driveway.
Requested Condition: A comprehensive Construction Traffic Management Plan (CTMP) must be approved prior to works commencing. This should restrict heavy vehicle staging, idling, and movements near adjoining residential driveways, include speed controls, and minimise activity during peak hours. Construction lighting must be baffled downward to prevent light spill into neighbouring properties.

5. Flooding, Stormwater, Infrastructure, and Ground Stability
The site is in an area already prone to stormwater issues. Increased hard surfaces will exacerbate runoff, flooding risk, and pressure on sewage lines that run through our complex, as well as water, electricity, and other services.
Requested Condition: Detailed independent modelling and upgrades to stormwater, sewage, and related infrastructure must be mandated. Ground stability and vibration impacts on nearby properties must be assessed and mitigated.

6. Accountability, Communication, and Oversight
The application currently lacks clear localised frameworks for ongoing resident input and enforcement.
Requested Condition: Appointment of an independent environmental auditor and a dedicated Community Liaison Officer. Residents must have a 24/7 direct contact line for reporting breaches (noise, dust, safety, etc.), with a mandated 2-hour response and rectification timeframe. A Community Reference Group including directly affected neighbours should be established. Pre- and post-construction dilapidation reports and a clear complaints resolution process must be in place.

Conclusion
I support well-planned seniors housing on this site, but responsible development requires that the significant burdens on existing residents (especially those directly adjoining the boundary) be actively avoided or minimised.

I respectfully request that the Department impose the above conditions rigorously, require a revised Social Impact Assessment focused on adjoining properties, and engage directly with immediately affected residents before determination.

Thank you for your time and consideration of this submission. I am available for further discussion and request acknowledgment of my submission.

Sincerely,
Kim N

Soil organic carbon is critical for soil structure moisture retention nutrient cycling and long term fertility Disturbance from excavation compaction removal of vegetation and altered drainage will harm soil carbon stocks Biodiversity of soil fauna pollinators native grasses riparian vegetation may be severely reduced These affect agricultural health over. Can the proponent show an independent soil carbon baseline survey and model of loss and recovery over the project lifetime including post decommissioning ensuring net soil carbon remains equal or above baseline

Policy for Biophysical Strategic Agricultural Land NSW agriculture policies and local council zoning likely protect Class 1‑3 land The project may conflict with state policies that aim to minimise conversion of prime farmland There may be legal inconsistencies or conflicts the project. What specific state or local policy prohibits conversion of Class 3 land for a BESS facility and how will this project comply or be exempted explicitly

Stormwater infiltration reduced by hard surfaces roads foundations will reduce groundwater recharge Chemical spills leaks runoff from battery infrastructure may pollute shallow groundwater Supplies for bores stock and irrigation may be affected What groundwater monitoring plan independent of the proponent is in place to ensure no contamination or reduction in aquifer recharge over the life of the project including decommissioning

Climate models show heavier rainfall extremes and more frequent droughts Soil erosion increased under both More intense rainfall causes greater runoff and erosion. The assessment appears to assume historical weather patterns not future climate vulnerability
What climate projection scenarios were used in the environmental assessment what worst case scenarios for rainfall drought and temperature extremes were modelled and how resilient is the project design under each

Landowner may be paid rental but neighbour farms affected by noise water loss fire or contamination receive nothing Ecosystem services loss pollinators soil carbon clean water are not compensated Community burdens are uneven
What compensation scheme is proposed that includes all impacted neighbours ecosystem services lost and ongoing monitoring and how is it guaranteed and funded

Rural landscapes are valued for their scenic vistas iconic views sense of place Industrial battery infrastructure hard stands fencing lighting disrupt these views Light spill at night will be visible reducing dark sky character
What visual impact assessment with viewpoint modelling day and night was completed what mitigation (screening landscaping setbacks) is guaranteed and enforceable