16 March 2026
The Secretary
NSW Department of Planning, Housing and Infrastructure
Re: Objection submission – Proposed development at 160 Oxford Street, Paddington SSD-97528708
To whom it may concern,
I am writing to lodge an objection to the proposed development at 160 Oxford Street, Paddington, currently being assessed under the State Significant Development (SSD) pathway.
I understand SSD pathways are intended for projects of genuine state significance. However, this proposal delivers only a modest net increase in housing supply (8 additional apartments) and a reduced affordable housing outcome (10 dwellings, down from 27). In practical terms, the SSD process appears to facilitate a building of substantially greater height and scale than would ordinarily be contemplated at this location, while bypassing the usual local assessment framework that applies within the Paddington Heritage Conservation Area.
As such I request that the proposal be referred back to Council for assessment against the Woollahra Local Environmental Plan 2014 (WLEP 2014) planning controls.
Key concerns
• Excessive parking: 83 car parking spaces for 40 dwellings (more than two spaces per dwelling), which is inconsistent with an inner-city location with strong public transport access.
• Housing mix: the proposal includes no studio or one-bedroom apartments, which is a missed opportunity in the context of housing affordability and diverse household needs.
• Height and built-form incompatibility: the proposed height is out of step with the prevailing two-to-four storey character of Oxford Street, Paddington. Examples cited in the EIS of eight-to-twelve storey buildings are generally institutional or landmark buildings, not comparable continuous street-wall development.
• Heritage and streetscape impacts: an eight-storey building (nine storeys at the rear, plus rooftop terraces) across most of the site would materially alter the visual amenity of Oxford Street and disrupt the established relationship with adjoining heritage workers’ cottages.
• Traffic and construction impacts on narrow streets: surrounding nineteenth-century streets are extremely constrained (e.g., Shadforth Street’s effective single-lane width and Gipps Street’s unsuitability for large vehicles). The EIS does not adequately assess the practical limits of the network or cumulative construction/operational traffic impacts on congestion, safety and residential amenity.
Yours sincerely,
Amanda Pullinger

Objection to 160 Oxford Street development proposal

I am a long-term Paddington resident. I have lived in Paddington continuously since 1986 and before that from 1968-70. Like many Paddington residents I value the fact that I live in this unique Heritage Conservation Area which connects us to our past while offering a desirable lifestyle.

Heritage
Paddington is unique; it tells the story of Australia’s early white settlement throughout the 19th century. It is not just the residents that enjoy its heritage status ; it is also a prime tourist destination, attracting visitors from all over the world and the rest of the country. If this development goes ahead Paddington’s unique heritage character will be lost and importantly, it will set an irreversible precedent for further gross overdevelopment of this historic, low-rise streetscape.

Scale and Bulk
I have witnessed many changes to the Paddington environment during the time that I have lived here but most have been respectful of the area’s heritage values and conscious of preserving its unique character.
This is certainly not the case with this proposed development. The proposal is for an 8 storey, 9 level luxury tower with a four-level excavated carpark for 83 cars and 5 swimming pools. At 30m high, 52m long and 25m wide, its enormous scale and bulk would, if approved, be completely incompatible with, and have a disastrous and irreversible impact on, the surrounding heritage precinct. This development would negatively impact the significant heritage site of Victoria Barracks opposite and would overwhelm the modest and beautifully preserved early Paddington workers cottages in Shadforth Street and Gipps St. The proposed development also shows minimal setbacks from the site boundary on Oxford Street and none along Shadforth Street.

Loss of affordable housing
The current apartment building on Oxford Street, that would be replaced by this proposed development, has 27 studio apartments over three levels, housing essential workers. Rent is approximately $500 per week. The proposed development is for 40 luxury apartments with 10 - 12 “affordable” at a minimum of $1000 per week. This represents a significant net loss of 17 genuinely affordable housing, thus decreasing the availability of affordable housing in Paddington. This does not qualify for the “affordable housing bonus” that the developer is claiming.

Impact on residents
The proposed development would involve years of construction work, including extensive demolition and excavation work (for the four level basement car park) resulting in intolerable disruption for residents. When completed the residents would be faced with overshadowing and loss of privacy.

Traffic chaos
The years of construction of this project would involve the movement of heavy trucks through the narrow streets of Paddington that are not designed for the estimated 20 truckloads a day carrying building material to and from the site.

In summary:
The scale and bulk of this development would irreversibly degrade the nationally significant heritage character of Paddington
Set a precedent for more gross overdevelopment in Paddington
Contribute to a loss of affordable housing in Paddington
Create intolerable disruption for Paddington residents
Create traffic chaos
Contribute nothing to the community

We object to the application for 40 dwellings at 160 Oxford Street, Paddington
The proposal is in the exceptionally significant heritage area that is Paddington, and opposite Victoria Barracks, perhaps the most exceptional heritage significant Defence estate in Australia. Oxford Street is predominantly lined by 2-3 storey buildings, occasionally punctuated by larger buildings such as the Paddington Town Hall, with a sandstone wall to the Barracks.

The proposal is completely out of scale with its context, 8 storeys, 48m long opposite the Barracks gates.
The SEARS requires the proposal to address and respond to the context, with respect to height, bulk, scale, setbacks and interfaces. The proposal is too high, too bulky, and out of scale with the low rise Paddington.
Attempts to justify the height , bulk, and scale cannot be supported. There are no other buildings of this scale within visible distance of 160 Oxford Street. Any buildings of 8 floors in Paddington stopped being permissible in the 1970's (to stop any proliferation with a LEP and the new Heritage DCP.) There is nothing of relevant height and bulk relationship between South Dowling Street and Centennial Park.

The proposal would never have any adjoining development of this scale. It is not permissible.

The proposal will have significant negative impacts on surrounding residents with impacts on privacy, noise amenity, and general outlook. None of the residents would ever have anticipated an 8 storey building of huge bulk in their neighbourhood. Challenges the whole concept of a Paddington neighbourhood.

Attempts to justify 8 floors at 160 Oxford Street by referencing Parramatta CBD, and George Street in the Sydney CBD cannot be supported. The CBD contexts bare absolutely no relationship to Paddington.

Selective view points for the visual assessment fail to describe the bulk of this development, 30m high, 47m long, and 25m deep in a special world of terrace house forms.


There is something Orwellian about the justification for 8 floors and 7 additional dwellings replacing 27 affordable dwellings in an existing 3 floor development. We do not agree that the existing buildings on the site are 'intrusive' compared to what is proposed. We submit that the existing buildings are remarkably respectful for their Oxford Street Paddington environment and Paddington would benefit from their retention. The definition of affordable housing makes no sense. How can bonuses be provided for providing less affordable housing because the only definition of affordable housing is based on CPH management delivering fewer affordable dwellings. Where are the existing residents going to go?

We object to the findings of the so-called Heritage Impact Statement and the 'self-assessment' for Victoria Barracks. The impact on the heritage of Paddington and on Victoria Barracks will be significant Too argue that a huge building the scale of the Edgecliff Centre on Paddington, on Oxford Street, and on the Barracks is a minor impact is obviously wrong.

This failure in the assessment by the consultants is exacerbated by a failure to appreciate that Plane Trees are deciduous and spend much time without leaves.
The controls in the Heritage DCP for Paddington are a vey useful guide to the assessment of any development in Paddington. The DCP is the result of careful study, negotiation, and community input over a long period of time. Claims by the heritage consultant that the proposal is consistent with the objectives of the heritage guidelines are clearly incorrect.

We object to any claim that the proposal is sympathetic to Paddington. Nothing proposed is sympathetic to Paddington. In fact it would have a significant negative impact on this wonderful place.

The proposal for 160 Oxford Street should be rejected. It is too big, to intrusive, too visible, and delivers less truly affordable housing. An Orwellian disaster.

I am writing to register my strong objection to the proposed development SSD 97528708, Mixed use development with infill affordable housing at 160 Oxford st Paddington. I have been a resident of Liverpool st Paddington (section between Glenmore Road & Shadforth st) for over 20 years, so am very familiar with the unique neighbourhood that is impacted by this proposal, which I think is a clear “lose lose” proposition (from both a local and a state-wide perspective) for the reasons outlined below.

First, I would like to highlight that this area in its existing form is already of state-wide significance due to the unique history of the original worker’s cottages that are concentrated in that pocket & preserved largely in their original form since the late 1800s. These were built to service Victoria Barracks originally & the suburb of Paddington subsequently grew from this area. Of note, the streets in this pocket are very narrow due to these origins & are a delight to walk through as pedestrians, but already quite difficult to drive through even with a normal sized car, let alone large construction trucks or any further increase in car traffic resulting from this development.

I often host visitors from interstate or overseas who really appreciate visiting & spending time in this character-filled area & to learn about Sydney’s early history. These visitors (many of whom are seasoned world travellers) marvel at the unique streetscape & are amazed that these tiny homes continue to support modern-day living by happy residents, including families with young children…high density inner-city living at its best!

So, the first & very big “lose” will be this uniquely significant neighbourhood & its valuable heritage character, both through the impacts of years long massive construction (which itself seems unfeasible in view of the physical constraints of the local streets) as well as at completion of such an oversized & completely incongruous development at that location. This includes negative impacts on historic Victoria barracks & Oxford street reserve directly opposite.

This would be a very significant & sadly permanent loss, with state-wide implications. Ironically, such a significant & permanent loss would also not be accompanied by any real gain for the people of NSW, in terms of meaningful increase in the affordable housing stock in that location. So, the second big “lose” is that the proposal in its current form would actually result in a net loss in the number of truly affordable homes that are currently located at that site, which is unacceptable in & of itself!

I offer these brief comments as a personal view & refer you to the submissions from the Paddington Society providing more comprehensive reasons for objection, all of which I also fully support.

Thank you for your careful consideration & hopefully rejection of this proposal in its current form.

A very concerned resident!

I have been trying to upload the submission/objection on behalf of the Paddington Society of which I am president. After progressing through the process which acknowledged my name, address, I proceeded to try to upload the Society submission using both alternative methods via the paper clip and selecting and uploading the PDF document. At each attempt the site did not let me proceed.
I finally sent the submission in an email to Victor Casasanta, apologising for sending it direct to him. I also managed after lengthy waiting on the phone to receive an email form which again I completed and emailed back to the department together with the Society's submission/objection. I will now try one more time to lodge via the Planning Portal.

Please reject this project. It is already an established fact that “Affordable” is a misnomer allowing Developers to game the system. Low income earners including teachers, doctors and front line workers cannot pay $1000+ per week on rent. At a time of increasingly unaffordable homes the needs of good citizens and community stability should be demonstrated by rejecting this development.” Major projects” is another work around for profit seeking developers.
Paddington has a heritage value and cultural ethos that is inclusive of diverse income brackets. I request the Planning Minister dignify low income earners generally and the current residents particularly by rejecting this exclusive luxury development.

I wish to object to the proposed development at 160 Oxford Street – State Significant Development SSD-97528708 (Proposal) – for the following reasons:
The scale and design of the Proposal are considered fundamentally out of character with the surrounding Paddington neighbourhood and its Heritage Conservation Area. The area is defined by small lots, narrow streets, and predominantly two-storey nineteenth-century terraces and cottages. In contrast, the Proposal introduces an eight-storey, nearly 50-metre-wide building with minimal façade modulation and limited setbacks, creating a bulk and scale more typical of commercial or institutional structures. Positioned on a prominent ridgeline along Oxford Street, the building would visually dominate adjacent two-storey homes and disrupt the historic streetscape. Such a large structure would permanently “stick out” within the conservation area, eroding the cohesive low-rise character that has defined Paddington’s urban form for more than a century.
The Proposal would also lead to a net loss of affordable housing in the area. The existing site currently contains 27 studio and one-bedroom units that provide relatively affordable accommodation, yet these would be replaced with only 10 units classified as “affordable” under the proposal. Because these units need only be rented at a 20% discount to market rates, they would remain out of reach for many lower-income renters. In addition, the Proposal eliminates all smaller dwellings and replaces them primarily with larger two- and three-bedroom apartments, including luxury units with rooftop terraces and harbour views. As a result, the Proposal would reduce the diversity of housing types in the neighbourhood and displace existing tenants, undermining rather than strengthening the supply of affordable housing.
Finally, the Proposal raises significant concerns regarding its impact on the nationally significant Victoria Barracks, which sits directly opposite the site. The Proposal’s height of around eight storeys would visually dominate the Barracks’ historic sandstone entrance and low boundary walls, which are only about three metres high. Because the building would sit on the same visual line as the main Barracks structure, it would intrude prominently into key heritage views and appear above the existing tree canopy when seen from within the Barracks grounds.

Economic Impact of Proposed TOWER Development at 142 to 160 Oxford Street,
Paddington.
‘Thriving High Streets give communities pride and identity’ – Gabriel Metcalf, Chief Executive of
the Committee for Sydney.
‘The growth of shopping centres has led to High Streets being undervalued’ – Phillip Thallis,
Leading Architect and Urbanist.
Oxford Street Paddington, between Boundary Street and Centennial Park, is Australia’s first and
original suburban shop top retail street.
Its historic significance as the first retail shop top street in Australia is obvious.
Oxford Street, thanks to a protective Council, is in a relatively unblemished original heritage
state.
Whatever development that has occurred in the last century has been consistent with a 2-3
storey height limit on the whole street.
The street is a perfect illustration of historic shop top and consists of many other relevant
heritage significant buildings including,
1. The Victoria Barracks
2. Paddington Town Hall
3. The collection of single built terraces at 2-16 Glenmore Road.
4. The Village Inn Hotel
5. 126 Oxford Street, Paddington - presently the Scanlan Theodore building.
6. Juniper Hall.
7. The Waterworks.
8. Nearly every shop top terrace in the street is original
As consequence of the street’s unblemished historic significance, it is an ECONOMIC
SUCCESS storey despite the threats of ONLINE RETAIL AND WORLD CLASS SHOPPING
MALLS BOOKENDING THE STREET.
Despite the threats upon its commercial viability over the last 50 years, including from,
1. Westfield Bondi Junction,
2. Westfield CBD,
3. Online retail,
Oxford Street has survived and is in fact thriving!
OXFORD STREET IS HOWEVER FRAGILE.
Imposing A NINE STOREY TOWER ON THE STREET IS A MAJOR THREAT.
This is because Oxford Street, Paddington represents a unique opportunity to WALK
The proposal to place a 9-storey ‘mountain’ on an otherwise unblemished consistent height high
street, represents a major threat to the historic setting and economic tourism that the presently
street offers, the lifestyle the street offers and the heritage the street offers.
The existing lifestyle tourism and heritage significance of the street is reflected in:
1. Oxford Street is stop No. 18 on Sydney’s Big Red Bus Tours.
2. The Street around Glenmore Road is listed in Destination NSW top 10 tourist attractions
for Sydney.
3. The Street is the home of the Paddington markets - the birthplace of so many success
Australia fashion brands.
4. The Street is the home of so many Victorian, Edwardian and art deco pubs including,
a. The Albury Hotel.
b. The Village Inn Hotel.
c. The Unicorn Hotel.
5. The street is the Home of the Australian Fashion Walk of Style.
Trade Off
The provision by the developer of a number of low-cost units for rent for only 15 years, is simply
in this case, a means to justify the excessive height is simply an inappropriate trade off.
I am sure that the public would prefer that the low-cost accommodation limited to 15 years, not
be provided at all, rather than using that as a way to increase the height of the building in
perpetuity and reap greedy financial rewards by providing views to the upper floors whilst
simultaneously harming the streetscape.
The buildings to be demolished provide much more low-cost accommodation than it is
proposed.
Conclusion
THE SUCCESS OF OXFORD STREET IS NOT AN ACCIDENT. IT IS A PERFECT BLEND OF
CONSISTENT HISTORIC ARCHITECTURE WITH THRIVING SHOP TOP RETAIL.
Bruce McWilliam
Owner
122 – 124 Oxford Street, Paddington
Legal Argument - Policy Argument
The whole objective of the Minns Government statutory changes was to in fact provide an
increase in residential accommodation, and more particularly to increase low cost housing
supply.

It was clearly the objective of Government statutory changes to effectively increase, not
decrease, the amount of low cost of residential accommodation.

This development directly breaches and is contrary to this statutory objective and therefore the
developer cannot use the legislation to increase density and height on his development.

This case is particularly unusual, and therefore not entitled to any increased density and height,
for the following reasons:

1. 160 Oxford Street, Paddington is a block of 27 existing low cost rental apartments close
to hospitals and the CBD - which is not strata titled. That means it is owned by one
person and every person in that building is a low cost rental tenant of a studio
apartment.
2. This development in fact wipes out those 27 low cost rental apartments and offers to
replace it with 10 low cost apartments for a maximum of 15 years only. A net loss of 17
apartments, short term and 27 apartments long term.
3. This development is directly contrary to the objective of the legislation and consequently
illegal. If 160 Oxford Street was strata titled with 27 different owners then the argument
could be made by the developer that those 27 owners can sell to the developer and
buy replacement homes elsewhere.

In this case none of the 27 tenants evicted by this developer are going to be able to find
alternate cheap rental accommodation in this location both during demolition and construction
and afterwards.

In other words , if this building were owned by 27 owners for example, and the building was
acquired from each of those owners, then that is a different scenario where in fact no low cost
rental accommodation is lost and all people are doing is selling their home to replace it with an
alternate home.

This is an important difference in this development application. If a building is a rental building
not a strata building with all different owners , then that DA should be considered differently
under the legislation as opposed to a building that is already strata and the building is occupied
by individual owners.

This case differs enormously from development in for example Rose Bay and Double Bay
where for example, three mansions are demolished and replaced with thirty apartments.

The proposal raises concerns about its impact on the existing streetscape, the established character of Oxford Street, and the day-to-day amenity of nearby residents, including increased noise, congestion, and reduced neighbourhood cohesion. The scale and nature of the development appear out of step with the surrounding area and risk undermining the character that defines this part of Paddington. It would also set a precedent for future developments in the area, effectively establishing a new standard for building scale and form that could lead to further erosion of the suburb’s historic character.

I'm not a local but I visit the area regularly. This development seems simultaneously to big and too small. It's clearly too big for the area and should be reduced substantially in scale. But it's also too small for this process to be appropriate - it should be returned to the local council which is perfectly capable of handling an application of this nature. Lastly, the plan that affordable housing provided will only be temporary (for 15 years) is unacceptable. If the project is approved, there should be genuinely affordable housing on a permanent basis.