As a resident of the area living in Surry Hills, I strongly
Object to this proposal. It sets a very problematic precedent of tearing down functional and low cost studio apartment housing in our area to build luxury apartments with a very small proportion “affordable” and only for a limited time, alongside 5 private rooftop pools and minimal public amenity. As local residents, we understand the need to increase density and build new housing but doing this by destroying existing affordable housing and displacing residents to build luxury housing is frankly insulting and unacceptable. This is also sets a dangerous precedent for future similar projects across Sydney and mirrors the awful situation with the chimes block in Potts point.

I have lived in Paddington for more than 35 years and have seen many changes. This project is perhaps the worst I have seen. It ticks all the boxes for the wrong reasons:- it is a massive over-development of a modest site,it will overwhelm and ruin the small-scale surroundings, it is incompatible with its"village" low scale dwellings,it is ugly and incompatible with the heritage Victoria Barracks opposite, it will mean the loss of future permanent genuine affordable housing, it will lead to traffic chaos in surrounding streets as the egress and ingress of the development is via the adjacent corner small street and it will be a massive ugly blight on the streetscape of an aesthetically pleasing and historic Sydney thoroughfare.

I don't believe that any plans for the future of Victoria barracks have been laid out as yet. This is now important for the future of a large section of Oxford St. and I would hope that these plans set the standard and style of future development along Oxford St.

The development at 160 Oxford St. should be considered in conjunction with the likely future of that whole part of Oxford St and Victoria barracks as I expect that the current high rise plans placed directly on Oxford St. will glare very rudely at any future Victoria Barracks reuse.

I object on three main grounds: 1) the basis that a breach of the height limit set by the Woollahra Local Environment Plan and Development Control Plan will set an irreparable precedent for this heritage area and Oxford St precinct in general. 2) how this breach of the height limit undermines the Strategic Planning Statements of council and the community consultation and informed them to identify areas for redevelopment, increased height limits and heritage protection. 3) that the building is NOT infill nor additionality and removes a building with multiple residence and affordable housing and replaces it with less housing, including the significant risk that the building is razed, the housing lost and the developer does not proceed in a timely fashion due to financial implosion.


1. Dangerous height precedent that will reset the allowable Height of Buildings on Oxford Street.
The current height of building limit for this R3 land zoning is 10.5m with a FSR of .75:1. This has been set by Woollahra council with intent. The development ACROSS the road at the Hyde barracks is where the heights can be higher and infill and significant additionality possible.

If this development is allowed, it will create a precedent for other height breaches on this village strip of Oxford and heritage area. This breach of height controls on this side of Oxford Street will set a precedent for further breaches and the cumulative impact on the heritage areas and aesthetic of an area that is designated a heritage conservation area.

2. Undermining of Councils and Local Planning Statements
Five years ago, Councils engaged communities and spent significant time developing Local Strategic Planning Statements for the purpose of identifying how the amenity and future housing, economic and active transport zones of the area would improve liveablity and certainty. Plonking overdevelopment as a one-off in a heritage zone undermines the council and its constituents.


3. Negligible benefit to housing supply in the area. This project is not infill or additionality/
The development removes a contemporary building containing 27 affordable apartments to replace it with only an additional 13 apartments. This development is not infill. It is a high risk vanity project where there is a high possibility the building will be razed, 27 apartments lost and years are spent with a void of the site and no funds to build.
REPLACEMENT of like for like is not the Housing Delivery Authority’s remit. The development of brownfield sites and infill is.

The proposed development ACROSS the road at the Hyde barracks is where the height controls can be higher as there is no ADJACENT heritage buildings. This is where there can be significant increase and additionality of housing for the area, in a planned out development that does not directly impact on the Gipps Street heritage area. 21 Gipps Street alone is an 1800s heritage-protected dwelling that is at significant risk from the excavation and access required.

This is a project that should not meet the criteria for SSD and should be assessed by Woollahra Council.

I object to this proposal for a multitude of reasons, outlined in the attached PDF and summarised below:

1. Inappropriate Built Form: Excessive Height, Bulk and Scale that is fundamentally incompatible with the character of Paddington Heritage Conservation Area
2. Unacceptable Visual Impact and the critical omission of Gipps Street from the Visual Impact Assessment
3. Environmental Amenity and Acoustic Infringement: The inclusion of five rooftop/outdoor pools and a 15m deep excavated carpark creates unmitigated noise, light spill, and pollution impact to the residential amenity of the surrounding dwellings.
4. Exacerbation of Unmitigated Groundwater Concerns due to the oversized excavated carpark.
5. Critical Risk to Trees and Landscaping, and the reliance of the developer for the Oxford Street plane trees to minimise building bulk, particularly with the Arboricultural Report admitting to "moderate incursions" into the Root Protection Zones during deep excavation.
6. Unacceptable Local Traffic and Parking Impacts: The provision of 83 car spaces will funnel heavy traffic into 19th-century lanes that are physically incapable of supporting this increase in traffic, lack of planning for essential service vehicle access.
7. Unmitigated Health Risks during Construction: Air Quality and Respiratory Impact; requirement to produce an Air Quality Management Plan
8. Negative Social Impact: The demolition of 27 existing low-cost studios to create only 10 temporary "affordable" units (15-year sunset) results in a net loss of 17 dwellings, does not justify the extent of this intervention and fails the core objective of the Housing SEPP.
9. Zero Public Benefit; just extensive negative impacts to the community through reduced environmental amenity and on-street parking; increased congestion on the narrow local streets.
10. Lack of Community Engagement: There has been notable lack of effort to engage with the residents most directly impacted by the proposal, particularly those on Gipps and Shadforth Streets.
11. Other matters of statutory non-compliance, ranging from artificial inflation of the EDC, the GFA, manipulated boundaries and inclusions for the site to reach minimum thresholds.

In assessing this application, the Department must determine whether a permanent 130% height increase in exchange for a temporary, 15-year "affordable" housing benefit is truly in the Public Interest (s 4.15(1)(e)). To approve this development would be to prioritise private developer profit over the survival of one of Australia’s most significant heritage precincts.

Submitted by: Resident of Elfred Street, Paddington NSW 2021
Application Reference: SSD-97528708

To whom it may concern,
I write to formally object to the proposed mixed-use development with infill affordable housing at 160 Oxford Street, Paddington.

I am a resident of Elfred Street, located within the immediate neighbourhood of the proposed development at the corner of Oxford Street, Shadforth Street and Gipps Street. While I support appropriate housing development in well-located areas, I object to this proposal in its current form due to heritage impacts and significant traffic, safety and amenity concerns that have not been adequately addressed in the Transport and Accessibility Impact Assessment.

The key grounds of my objection are:
- Heritage impact
- Traffic and road safety
- Inadequate traffic modelling
- Parking pressure on surrounding streets
- Driveway location on Shadforth Street
- Driveway sightlines and compliance with Australian Standards

Connection to the Neighbourhood
I have lived in Paddington since 2007. My son attended Glenmore Road Public School and is now in Year 12. Over nearly two decades I have walked these historic streets daily and deeply value the character of this neighbourhood.

Paddington is one of the few areas in Sydney that has preserved its original architecture and village-scale streetscape. Streets such as Elfred Street, Gipps Street, Shadforth Street and Prospect Street contain small Victorian and Edwardian cottages built for workers associated with Victoria Barracks. The “Elfred Estate” mentioned on the heritage sign on Oxford Street reflects the historical significance of this area.

It is with concern for both the character and liveability of this neighbourhood that I submit this objection.

1. Heritage and Neighbourhood Character
The proposed development sits at the gateway to one of the most intact Heritage Conservation Areas in Sydney. The scale and massing of a multi-storey mixed-use building at this location is inconsistent with the fine-grain, low-rise character of surrounding streets such as Elfred, Gipps and Shadforth Streets, which consist largely of small historic terraces and cottages. A development of this scale risks undermining the qualities that make Paddington distinctive and historically significant.

2. Traffic and Road Safety
The streets surrounding the development are narrow residential streets with existing traffic constraints. Elfred Street is one-way and connects from Gipps Street. Access to Gipps Street is primarily via Liverpool Street or via Shadforth Street from Oxford Street.

The development proposes 83 basement parking spaces for only 40 apartments, accessed via Shadforth Street, a quiet residential street. This represents a substantial increase in traffic for streets that were never designed to carry high vehicle volumes.

Existing constraints in the area include:
- Shadforth Street and Gipps Street designated “Unsuitable for Large Vehicles”
- High pedestrian activity zone
- 3-tonne load limit on nearby Glenmore Road
- One-way sections of Gipps Street
- No right turn from Oxford Street into Shadforth Street during morning peak

These restrictions mean vehicles entering or exiting the development will circulate through nearby residential streets including Gipps Street, Shadforth Street and Elfred Street, increasing congestion, rat-running and safety risks.

Elfred Street already functions as a rat-run between Oxford Street and Five Ways Paddington, connecting through to Boundary Street and the Cross City Tunnel. Additional traffic generated by this development will likely exacerbate this existing problem.

3. Inadequacy of the Traffic Impact Assessment
The Transport and Accessibility Impact Assessment appears to underestimate the likely traffic impact. The report projects that the development will generate only approximately 10 vehicle trips per hour in the morning peak, based on statistical averages for residential and retail uses.
This modelling does not appear to adequately consider:
- Visitor parking
- Rideshare pick-ups and drop-offs
- Courier and food delivery vehicles
- Retail servicing and supplier deliveries
- Waste collection vehicles

Given the development includes 83 parking spaces, real-world vehicle movements are likely to be considerably higher, particularly during evenings and weekends.

The traffic assessment also models only two intersections (Oxford Street/Shadforth Street and Shadforth Street/Gipps Street) and does not consider impacts on the broader local street network including Elfred Street. This is a significant omission, as these streets will experience the direct impact of additional traffic.

The proposal also includes basement waste collection by private garbage trucks, which will access the site via Shadforth Street. This introduces heavy vehicle movements and additional noise in a narrow residential street, impacts that have not been adequately assessed.

4. Parking Pressure and Local Amenity
Most homes in Paddington do not have off-street parking - our neighourhood is no exception. Residents rely on street parking, which is already limited. Although the development provides basement parking for residents, visitors and service vehicles will inevitably rely on surrounding streets. Paddington is also a destination suburb, with weekend markets, events at Moore Park and significant hospitality venues. Street parking is challenging and it is common to spend considerable time searching for a space.

Additional visitor parking generated by this development will increase pressure on nearby streets including Elfred Street, Gipps Street, Brown Street, Glenmore Road, Liverpool Street and beyond.

5. Driveway Proximity to Oxford Street Intersection
The proposed basement car park driveway is located on Shadforth Street very close to the Oxford Street intersection, which is a busy State Road. While the Traffic Impact Assessment evaluates intersection capacity, it does not assess the safety implications of locating a driveway close to a major intersection.

Transport for NSW driveway guidance generally recommends minimum separation distances between intersections and driveways to avoid vehicle conflict points. The submitted documentation does not demonstrate that these requirements have been satisfied.
Given the scale of the proposed 83-space car park, this raises safety concerns for vehicles, pedestrians and cyclists.

6. Driveway Sightlines and Australian Standard AS/NZS 2890.1:2004
The proposed driveway on Shadforth Street includes a basement ramp serving the 83-space car park. Although the architectural drawings reference a “pedestrian safety sight triangle,” the plans do not provide dimensioned diagrams demonstrating compliance with AS/NZS 2890.1:2004, which requires a 2-metre visibility splay along the footpath with no obstructions above approximately 600mm–1m.

The drawings show potential obstructions near the driveway including landscaping, planters, services and a relocated power pole. Without detailed sightline analysis it cannot be verified that adequate pedestrian visibility will be achieved. Given the narrow footpaths and residential nature of Shadforth Street, this represents a potential safety risk to pedestrians and cyclists.

Summary of Objections on the following grounds:
- Heritage impact: The scale and design are incompatible with the Paddington Heritage Conservation Area and the fine-grain character of surrounding streets.
- Traffic and safety: An 83-space basement car park accessed via Shadforth Street will introduce significant additional traffic to narrow residential streets.
- Inadequate traffic modelling: The Transport Impact Assessment relies on averages, models only two intersections, and does not consider the wider local street network.
- Parking pressure: increase pressure on already limited street parking in the surrounding neighbourhood.
- Driveway location: The driveway is located close to the Oxford Street intersection without demonstrating appropriate intersection separation.
- Driveway sightlines: The application does not demonstrate compliance with AS/NZS 2890.1:2004 sightline requirements for pedestrian safety.

I respectfully urge the NSW Planning Authority to require a revised and more comprehensive Traffic and Accessibility Impact Assessment for this application, one that honestly accounts for real-world vehicle behaviour and the cumulative impact on the full local street network. The current proposal does not adequately demonstrate that traffic safety, pedestrian visibility and driveway design issues have been properly resolved, and the application should not be approved until these matters are fully addressed with broader community consultation and independently verified.
Sincerely,
Resident of Elfred Street