OBJECTION — SSD-97528708 — 160 Oxford Street, Paddington

I object to this application. A detailed submission is attached addressing each ground with specific references to the applicant's documents. Key grounds are summarised below.

1. NET LOSS OF AFFORDABLE HOUSING

The site contains 27 genuinely affordable studio apartments housing real tenants. The proposal replaces these with only 10 formal affordable units — a net loss of 17 affordable dwellings. The affordable housing obligation is limited to 15 years. The "Affordable Housing Management Plan" is a 1.5-page letter of intent from EchoRealty (Document GG) containing no detail on income targeting, rental methodology, tenant protections, or post-15-year arrangements. The EIS's Social Impact Scoping Study (Section 6.8, page 109) does not identify tenant displacement as a social impact and concludes a full SIA is "not required." This is a critical omission. The proposal defeats the purpose of the Infill Affordable Housing provisions.

2. EXPLOITATION OF THE AFFORDABLE HOUSING BONUS

The Woollahra LEP base height for this R3-zoned site is 10.5 metres (confirmed in the Scoping Meeting Request, page 5). The LMR SEPP raises this to 22m. The 30% affordable housing bonus raises it to 28.6m. The applicant then seeks a Clause 4.6 variation above even the bonus, proposing 30.6–32.6 metres — a further 7–14% exceedance (Document X, Table 2). The building will be approximately three times the base LEP height. The DPHI Practice Note states bonuses "should not be treated as an entitlement." The Clause 4.6 request does not meaningfully engage with site-specific heritage constraints.

3. HERITAGE IMPACT — DEFICIENCIES IN THE HIS

The Statement of Heritage Impact (Document K, GBA Heritage) contains significant analytical deficiencies: (a) It classifies all existing buildings as "intrusive" but fails to recognise their contribution lies in their scale — replacing 2–3 storey structures with a 32m tower will have far greater adverse impact on the HCA than the existing buildings. (b) It adopts a view hierarchy framework that systematically minimises every viewpoint to below the "material threshold." (c) It uses the existing UNSW Block F as justification for inserting another tall building near Victoria Barracks — a "two wrongs" argument. (d) It relies on mature trees to "obscure views of the lower 5 stories" — tree canopies are seasonal and the upper storeys will be permanently visible. (e) Its cumulative impact assessment is a single paragraph that does not address precedent for other HCA sites. (f) It concludes the Department should have "no hesitation" in approving — an advocacy statement requiring independent peer review.

4. WIND IMPACT ASSESSMENT — ABSENT

No wind impact assessment exists in the 41 documents lodged. The EIS's only reference is a single assertion (Section 6.1) that the design avoids "wind effects" — without any supporting analysis. For a building of 30.6–32.6m in a low-rise environment, this is a material deficiency preventing determination.

5. TRAFFIC — METHODOLOGICAL ERROR

The Traffic Assessment (Document R, Varga Traffic Planning) applies the TfNSW "Low Density Residential" rate (0.68 trips/dwelling) to the 27 existing studios in a 3-storey RFB. By TfNSW's own definition, these are "High Density Residential" (building with 20+ dwellings, 3+ storeys). The correct rate is 0.19 trips/dwelling. This inflates the existing baseline by approximately 80%, making the net increase appear "statistically insignificant" at 1.6 vph. The report also provides 83 car parking spaces but projects only 10 vehicle trips per hour — a disconnect requiring explanation.

6. GEOTECHNICAL RISKS

Four levels of basement excavation adjacent to heritage buildings on unreinforced sandstone foundations presents risks of vibration damage, settlement, and groundwater drawdown. Pre-construction dilapidation surveys within 50m and developer liability should be mandatory.

7. PRECEDENT

This is one of the first infill affordable housing SSDs in a Heritage Conservation Area in NSW. Numerous comparable Oxford Street sites are eligible for the same bonus. Approval establishes an irreversible precedent.

8. PROCEDURAL CONCERNS

The IPC referral mechanism has been removed for this SSD category. DCPs do not apply. The 14-day exhibition period for 41 documents is inadequate. The community has no independent avenue for scrutiny.

RELIEF SOUGHT: Refusal. Alternatively: height reduction to 4–5 storeys; affordable housing increased to 30% with 30-year covenant; binding tenant relocation plan; Heritage NSW endorsement; wind assessment; full SIA; independent heritage peer review; dilapidation surveys within 50m.

A detailed submission addressing each ground is attached.

Completely out of character with the beautiful village of Paddington

Andrew Starr and Associates Heritage Consultants


Andrew Starr Telephone 9360 6540
Mobile 0414400224
[email protected]
11 Prospect Street
Paddington
NSW 2021


3 March 2026

Re : (SSD-97528708) Development Proposal for an eight storey mixed commercial and residential tower at 6 Shadforth St, 13 Gipps St, 142 - 148 and 160 Oxford Street, Paddington.

I am writing this letter to object to the proposal SSD-97528708 on the grounds of heritage impact and impact on the amenity of local residents. I am a resident of the Paddington Village, or ‘Little Paddington’ and I live nearby the site of the proposed project, in a small workers cottage constructed in the 1840s that is typical of the area. I am a heritage consultant, and I have also prepared a history and heritage report for the residents impacted by the proposal which will be attached as part of my objection.

As discussed, and described in my attached report ‘Little Paddington’ is a unique remnant of 1840s domestic architecture in Sydney. It is the first section in Paddington subdivided as a residential area. This small remnant area contains remnants of the development hat housed the workers both building and provisioning the Victoria Barracks. The area has historic significance well beyond the current status as a part of the Paddington heritage conservation area as it relates to the historic significance of the Victoria Barracks which is on the National Estate.

The unique Victorian Georgian character of this precinct contains small workers cottages of one and two storeys and some Victorian filigree terrace houses built a few years after the original village. The area contains houses of sandstone and sandstock brick. The prevalence of sandstone is a rare contributing factor to the heritage character of the precinct. These sandstone buildings include the original Paddington Police Station in Gipps Street and groups of sandstone terraces in Shadforth Street and Gipps Street.

The proposal will have a major impact on the character of the area. The proposal is over scale. It is higher than any residential development in Oxford Street Paddington. The proposal dwarfs ‘Little Paddington in total disregard for the character of the area. The character of this conservation area must be taken into account for any development proposed even if the State Government is interceding in the approval process for this development proposal. The proposal does not meet the controls and objectives of Woollahra Council for the conservation area. In the DCP demolition is restricted to intrusive elements. Nos 142-148 Oxford Street is an early 1980s development but one that took in regard of prevailing Victorian terrace styles. They are not intrusive and are in good condition.

One at No. 142 contains a cellar from a previous shop that has archaeological significance and should not be demolished.

The proposed site backs on to ‘Little Paddington’ an area that has historic links to the Victoria Barracks. ‘Little Paddington’ contained workers’ cottage for those who built and maintained the barracks. Many of these cottages survive and the 1840s character is apparent. Building such a large and intrusive building has a negative aesthetic impact on ‘Little Paddington’s’ character. It is a site of high historic significance. Residents are worried particularly about the impact of vibration caused by the four-level excavation damaging the fabric and destabilizing their houses.

The ‘Little Paddington’ area is defined by very narrow streets. The building cannot be constructed without major disruption to the area in terms of carparking. The narrow roads are not wide enough for the heavy vehicles necessary for the job. Disruption will go on for years.

The proposed development has a negative impact on the aesthetic significance of the Victoria Barracks. The Victoria Barracks is listed on the National Estate. Any impact on the National Estate should be reviewed by the Commonwealth and relevant minister. Damage to the aesthetics of this item impact the historic significance of the site. The height of the new building also has impacts of wind shear. As the barracks is used as a helipad for the army and air ambulance this has impacts on air safety.

Creating such a large and intrusive building on this site will create precedent for other buildings exploiting The State Significant Building Act. On this specific site the applicant states that development is over the minimum amount of cost to qualify. However, it should be noted that the proposal at the moment can be changed. A reduction in scale is sought, but a dilemma is created for developers that the reduction in scale would drop costs below the threshold for a State Significant Project. It is possible that development could be approved by the State Government and then fall below costs after a modification.

The applicants are making this proposal on the proposition that 10 infill affordable are a component of the new apartment tower. However, 27 affordable low rent studio apartments are lost. This means there is a net loss of 17 affordable apartments. I understand that the State Government needs to provide affordable housing because of ever increasing demand. But it is absurd to claim that this is happening if there is a reduction in affordable housing overall (as there is in this case). The other problem in the claim that affordable housing is being provided lies in the fact that provision is short term 10-15 years and then the 10 affordable apartments become unaffordable apartments. So overall 27 affordable apartments ants are lost eventually. The concessions granted to the developers to provide the 10 apartments are of little value to the taxpayers of NSW. If indeed affordable housing is a priority of the State Government significantly more than 27 affordable apartments would be created.

The scale of the proposed excavation is severe and will cause damage to neighbouring houses due to vibration caused by excavation equipment. Excavation would also necessitate demolition of sections of a cellar that is also in areas not under the proposed site.

Yours sincerely





Andrew Starr

The current proposal is too high for the location. The height should be reduced. The other concern I have is the the traffic management. There is not enough parking for the number of building contractors during construction and the surrounding roads cannot handle the large trucks required to demolish and excavate the site.

We are writing to you about the stopping of the development of 160 Oxford street, Paddington. We are currently located in Shop1/168 Oxford street as OSKA Shop.
We are writing on behalf of 2 current employees who agree to the stopping of this development. As it will overshadow our shop and change the character of the shop and shop faces of Paddington. We have been here for twelve years at least and enjoyed a good steady business in this premises.
With creation of a ten storey apartment block directly to our shop this will disrupt the flow of business particularly of a good three years. As the duration of building underground parking and a high rise of ten storeys we believe the building is really too high in particular for the rest of the surrounding buildings. Being out of character with the village feel and intimate society. No longer will there be the availability of affordable housing for people , only for the supper rich.
Traffic will be a nightmare for our customers to park and the noise of consent heavy construction will definitely impact our business in negative way.
We hope this project will not go ahead for the interest of protecting our community and all businesses around.
Best
Jes and Laura
OSKA Paddington

I support the project, I believe it will really increase housing availability and affordability in the area. I would like to see the number of storeys increased.

Oxford Street Paddington is the perfect location for additional residential height and density, walkable to the city, on multiple bus routes. In a housing crisis this is the level of height and density that’s required. All the shops on oxford street in Paddington should have more height if they keep the facades and contribute additional residential capacity. It’s also great for local businesses

Dear NSW Government

I am writing as an owner-occupier in Paddington regarding the Paddington Tower (160 Oxford St) proposal.
There is widespread objection and concern among residents about the proposal’s impacts and we need your support. I am concerned that this proposal risks undermining the very heritage protections that define and safeguard Paddington’s character.

The height of the tower, being a 14 level ultra luxury tower, is also going to overshadow neighbouring buildings and create a loss of privacy for neighbours.

It also sets an important precedent for future developments within conservation areas, particularly under the Low and Mid Rise (LMR) Housing within Woollahra Muncipal Council.

Key concerns with the proposal include:

* The net loss of affordable housing.
* The impact on the Paddington HCA, particularly the original workers’ cottages associated with Victoria Barracks.
* The height and bulk of an 14 level luxury tower building within a low-rise Victorian terrace precinct.
* Years of extensive excavation and traffic impacts in narrow residential streets.
* Overshadowing of Oxford Street’s public open space and loss of privacy and amenity for neighbouring residents.
* Potential impacts on Oxford Street’s iconic Plane and Jacaranda trees.
* A lack of meaningful community consultation.

I strongly object to the development of this "ultra luxury tower" under the guise of affordable housing and also the height of the building that will create privacy issues for those that live around it.

Kind regards,
Paddington resident