To Whom It May Concern,
I am writing to formally object to the proposed State Significant Development at 11-23 Rangers Avenue. For the reasons outlined below, I believe the scale, intensity and impacts of this proposal are wholly inappropriate for its location and would cause lasting harm to the surrounding neighbourhood.
Traffic and access impacts
The local road network, including Rangers Avenue, Holt Avenue and nearby connecting streets, is already operating beyond comfortable capacity, particularly during peak commuting times and school drop-off and pick-up periods. The addition of a 91-space basement car park will generate a substantial increase in vehicle movements in streets that are not designed to accommodate this level of traffic. This will worsen congestion, diminish residential amenity and place further pressure on on-street parking, which is already fully utilised.
Pedestrian and cyclist safety concerns
The streets surrounding the site are narrow, steep and winding, with limited visibility and no capacity to safely absorb increased traffic volumes. These conditions already pose challenges for pedestrians and cyclists. Introducing a large-scale development with intensified vehicle movements significantly heightens safety risks, particularly for children and other vulnerable road users.
Loss of views and residential amenity
The proposed height and mass of the development would permanently obstruct long-established views of the city skyline and Sydney Harbour Bridge from multiple residences along Holt Avenue. These highly valued views would be replaced by the bulk and façade of a seven-storey apartment building, resulting in a severe and irreversible loss of amenity.
When assessed against the Tenacity v Warringah (2004) view-sharing principles, the proposal clearly fails to demonstrate that reasonable design alternatives, such as reduced height or altered massing, were considered to minimise view loss. The extent of the impact is excessive, unnecessary and avoidable, and on established planning grounds, the proposal cannot be supported in its current form.
Overdevelopment and character impacts
The scale of the development is incompatible with the existing low-rise residential character of the area. Its bulk and height will cause overshadowing, loss of privacy and an overwhelming sense of enclosure for neighbouring properties.
In addition, the proposal will have a detrimental effect on the harbour foreshore, introducing large multi-storey buildings that disrupt established rooflines and detract from the Sydney Harbour skyline, an iconic and highly sensitive visual landscape valued by residents and visitors alike.
Local infrastructure limitations
The impacts of the proposal extend beyond traffic concerns. The area is serviced by limited public transport, has constrained pedestrian infrastructure and lacks sufficient parking capacity. There is no evidence that local infrastructure can accommodate a development of this intensity without further eroding safety, functionality and residential amenity.
Deficiencies in visual, view and heritage assessment
The Visual Impact Assessment submitted with the application fails to include any analysis from Holt Avenue or the Holt Estate Heritage Conservation Area, despite their immediate proximity to the site. This omission is particularly concerning given that the Department requested a detailed view-loss and view-sharing assessment, which remains outstanding. As a result, the impacts on Sydney Harbour views, the natural landform and the heritage character of the surrounding streetscape have not been adequately or transparently assessed.
Absence of transition to environmentally sensitive land
The proposal applies maximum height and bulk directly adjacent to land zoned C4 Environmental Living and areas within the Scenic Protection Area. These zones were intentionally excluded from higher-density development due to their environmental and scenic importance. The absence of any meaningful transition in scale or built form demonstrates a disregard for the sensitivity of the adjoining landscape.
Misuse of the State Significant Development pathway
Although the project is presented as an affordable housing State Significant Development, the majority of dwellings are clearly positioned at the high-end of the market. The limited affordable housing component appears to serve primarily as a mechanism to access the SSD approval pathway and to add additional height to the building, rather than to respond meaningfully to genuine local housing needs.
For these reasons, I respectfully request that this proposal be refused, or at minimum substantially redesigned to reflect the capacity, character and environmental sensitivity of the surrounding area.

The proposed development at 11-23 Rangers Avenue Mosman is on the edge of the Holt Estate Heritage Conservation Area which has been relatively free of development thanks to the diligent work of Mosman Council. The current proposal is to dump a block of "modern" apartments one hundred metres long and over twenty metres high into this preciously preserved historical environment. Despite all the good intentions of the designers it is, and always will be, an alien structure in what is a one and two storey historically domestic environment. Would other cities in the world like San Francisco, New Orleans, Paris or Rome turn their historical areas into rubble and construct "modern" high -rise apartments. Please don't let it happen to Mosman. I would remind you of a proposal in the 60's by the pre-eminent architect of the time to demolish "The Rocks" area and build many high rise apartments to accommodate up to 10,000 residents. Thankfully common sense and public opinion prevailed and we all get to enjoy the charm and history of the "The Rocks" today....... and the public would not have it any other way. Developers keep nibbling away at our heritage ..... let's not nibble away another part of Mosman's history.

The northern face of the proposed development faces directly on to one and two storey homes in Holt Avenue that have been classified as being in a "Heritage Street" and as such enjoy the ambience of low key historical homes and surroundings. Despite all the good intentions of designers and developers these would be overlooked by six storey apartments directly behind them whereas up to now they enjoyed long views to the South.
The Governments LMR policy allows for bonuses to developers if they provide "Low Cost Housing" (LCH) In this proposal it is noted that the LCH is for rental only and will not be available for purchase. In this way the developer maintains control of the apartments and when their obligatory 15 years of providing LCH is up they can rent or sell the apartments at Mosman commercial rates. Making a mockery of the original intent of the legislation.
The proposal indicates Bloxome Lane as a means of pedestrian access/egress to and from the site. I would point out to you that Bloxome Lane is exactly what it says 'a lane'. It is one vehicle wide with NO footpath and provides access to residents garages in Holt Avenue and Rangers Avenue. Any pedestrian walking along the lane when a vehicle approaches has to quickly find safety in any nearby recess. The report also refers to pedestrians crossing Spofforth Street via a recently constructed pedestrian crossing. NO such crossing exists and pedestrians have to "run the gauntlet" to get across Spofforth Street .... a particularly dangerous maneuver ....particularly during peak periods that seem to get longer and longer.
Rangers Avenue has a Gross Vehicle Mass (GVM) limit of 3 tonnes and construction of such a large project is not conducive to limits imposed by Mosman Council.
In summary one could say that this development is nothing more than a developers attempt to maximize profit margin on the back of good intended, but badly legislated, reform intended to assist low and middle income earners to purchase a home. The end result will be a destruction of a part of Sydney's historical area to enable high income earners to purchase multi-million dollar properties. Meanwhile existing residents in Holt Avenue who have made the financial decision to invest in their properties due to their historical significance, their views and their privacy have the values of their properties greatly reduced because of overlooking, lose of views, a downgrading of the surrounding ambience and increased traffic.

Brian Britt B.Arch (NSWIT) Ret.
Architect
and
Ashlear Britt
52 Holt Avenue
Mosman 2088
Ph. 0433 798 230

I am concerned that the proposed development on Rangers Ave will cause significant impacts on the local residents both during construction and once established. The address is only accessible by Rangers Ave or Bloxome Ln. The former is one of the main streets out of south Mosman towards the city and is already often congested. The latter is a very small lane that provides access to drive ways on Rangers Ave and Holt Ave. It can only fit one car at a time, does not have a turning area, and often has residents walking along it; this includes children and elderly residents. A large development such as that proposed would greatly and directly affect every resident on Holt Ave, Rangers Ave and all those commuting away from South Mosman.

Not only is there not enough traffic infrastructure in the area to facilitate the development, there is also not enough public transport infrastructure to support the rapidly increasing number of residents. The proposed re-zoning requirements are that this area is 800m from a transport hub. The proposed development site is over 800m from the Cremorne Plaza and bus stop. Additionally, this "hub" does not have that many buses stop at it. Therefore this development does not satisfy the new rules anyway put in place to protect at least some of the current residents.

Lastly, the aims of the development are very questionable. I fail to see how the complex located in Mosman will provide affordable housing. The proposed value of the apartments and rents have not been stipulated and I believe that no people that require affordable housing will actually reside here.

Development is oversized for the streetscape .it adds 91 carspaces to an already traffic burdened back street in mosman especoally in the summer months as a back thoroughfare to balmoral beach and the surrounds . it will affect the ability of owners in park ave to access rangers ave in a significant manner .
it is outside the development LMR outer area .there are significant conerns re the sound footings of the planned project as one of the houses contributing to the development has already has had significant foundation issues because of subsidence .concerned about the actual construction process -where will the trucks go and how do they access the site on the side of a hill significantly effecting the traffic flow in an already over loaded small back road .What is affordable housing in mosman in $ terms and how is this monitored
or is IT ?? where is the publc transport facilities ?? the 230 bus from Mosman wharf already has its significant difficulties with ongoing cancellations !! that means the residents will. use their cars and again a load on a tiny back street in mosman that cannot cope with the current load !! there are soo many sites on military road and other major routes that could be used for "affordable housing "and are on major transport links why are we overloading tiny back streets of at iny suburb .Why cant we do things with sympathy to the local areas wherever they are with more thought and planning -why do we leave it up to greedy developers to decide NSW housing outcome who have no interest in protecting any environments .this is just a money grab !! we were only given 13 days(especaill y at this time of year ) to submit an objection which is not acceptable and not reasonable especially for development of this bulk on the lanadscape !!!
i am totally against this development and i have lived in Mosman for 36 years and came because of its history and beauty -this is being ruined like many other areas in NSW

To the NSW Department of Planning, Housing and Infrastructure,

I write to formally object to the SSD application for residential development with in-fill affordable housing at 11–23 Rangers Avenue, Mosman. While affordable housing is a critical policy priority, this proposal is inappropriate for the site and inconsistent with the objectives of the Environmental Planning and Assessment Act 1979.

1. Strategic Planning Inconsistencies

• The SSD proposal conflicts with the Greater Sydney Region Plan and the North District Plan, which emphasise locating higher-density affordable housing near transport hubs and centres. Rangers Avenue is a constrained residential street, lacking adequate infrastructure.
• The proposal undermines the Mosman Local Character Statement, which is recognised in strategic planning frameworks and should inform SSD assessments.


2. Public Interest and Amenity

• Traffic and Safety: Rangers Avenue is narrow and already congested. Increased density will compromise pedestrian and vehicular safety.
• Residential Amenity: The bulk, scale, and overlooking impacts are inconsistent with the surrounding low-density character, reducing privacy and sunlight access.
• Environmental Impact: Removal of mature trees and increased impermeable surfaces will reduce canopy cover and exacerbate stormwater issues, contrary to NSW sustainability objectives.


3. Statutory and Policy Considerations

• The proposal fails to demonstrate consistency with the Environmental Planning and Assessment Act 1979, particularly Section 4.15 matters relating to suitability of the site and public interest.
• Affordable housing objectives under SEPP (Housing) 2021 must be balanced with heritage and environmental protections. This site selection does not achieve that balance.
• The SSD process should not be used to bypass legitimate local planning concerns where the proposal is fundamentally incompatible with the site.


4. Precedent and Cumulative Impact

• Approval would set a precedent for overdevelopment in sensitive residential areas, undermining confidence in the SSD framework.
• It risks eroding community trust in planning processes by disregarding local character protections and infrastructure limitations.


For these reasons, I respectfully request that the Department refuse the SSD application for 11–23 Rangers Avenue. Affordable housing must be delivered in locations that are strategically suitable, environmentally sustainable, and consistent with community values — not at the expense of Mosman’s heritage and amenity.

please refer to the attached notice of objection

I believe the surveyor LTS that has submitted the Applicants walking distance assessment needs to be investigated for possible loss of license in NSW. After using waze and my own analysis it seems very clear the LMR outer Area is not within 800m of the created Cremorne Town Centre. I admit i am no expert but just based on looking at the rules and the development application it intentionally misleads to say its within 800 using safe walking path. The relevant State Environmental Planning Policy (Housing) 2021 (Housing SEPP) as “the shortest distance between 2 points measured along a route that may be safely walked by a pedestrian using, as far as reasonably practicable, public footpaths and pedestrian crossings.” the Department should deny the application on this basis alone .. go no further - these types of developments should be by town hall on military road etc..no evidence has been provided to support that the applicant’s proposed route meets the definition of ‘walking distance’ in the Housing SEPP. Ok the developer say people cross Spofforth Street at the intersection with Holt Avenue - anyone that cares about public knows that is not safe. Spofforth is so busy there cars cant even cross it easily and back up..now we have individuals crossing there ... this can not be used for safe walking distance. Imagine for a moment children crossing there rather that the light. We all know what would happen.

from here on ill refer This Development 11-23 Rangers av as the the star wars death star that has landed on Mosman Bay hill and has intentionally not provided an adequate visual impact assessment and anyone that has seen what this will look at from Mosman bay knows why. Additionally if you look it from The Mosman bay side the developer provides no meaningful transition between the C4 Environmental living zone and where this Star wars Death Star development has its footprint.

Once again lets be honest this project is a luxury Star wars death star type development and seems to anyone looking at it fairly knows its not alined with SSD policy intent making it massive by labelling it including affordable housing. Any honest assessment makes it clear the affordable component serves only to to unlock the SSD pathway rather than meeting genuine affordable-housing need. They do it for one reason to propose the maximum height and bulk possible. There is no way residents can trust government when they are encouraging such behaviour by developers and not holding them accountable.

The Developers excavation pan with shake in a earthquake like way and damage the historical homes on Holt Av. Without this massive excavation the development doesn't work and therefore should not be accpted.

I wish to object to the proposed development at 11-23 Rangers Avenue, Mosman. NSW 2088

The development is not within the LMR guidelines and in fact is non-compliant with the NSW Government low-and Mid-Rise (LMR) Housing Guidelines. I wish to make a formal submission objecting to the proposed Development at 11-23 Rangers Avenue, Mosman NSW 2088. The LMR is intended to provide walking distances to amenities - the closest hub bring Cremorne Town Centre (if you are walking on formal safe footpaths). This development is not within the LMR Outer Area (800m of Cremorne Town Centre). This development is clearly non-compliant and will cause considerable safely issues which I am deeply concerned about. The proposed development would change the community feel and heritage environment that exists now. If our heritage buildings are destroyed, they can never be rebuilt or regained which is a total mismanagement of our heritage buildings as they exist today. This would be a total disaster for Mosman, Sydney and Australia.

The development would change the landscape, overshadow existing building and residents. The proposals sheer bulk is not in keeping with the existing environment and will be visually obtrusive. I have serious traffic concerns for the residential areas and safety issues for children in particular. If you would like to speak to me on these and my other concerns, please reach out and I am happy to meet and elaborate further. Regards

I write to formally object to the proposed development currently under consideration, which has been submitted as a State Significant Development (SSD) on the basis of its classification as “affordable housing”. For the reasons outlined below, the proposal is inappropriate for the site, inconsistent with planning policy intent, and would result in unacceptable impacts on the local environment, heritage, amenity, and infrastructure.

1. Misalignment with SSD Policy Intent

Although the proposal is characterised as an “affordable housing” development, the predominant outcome is the delivery of high-end, luxury apartments. The affordable housing component appears to function primarily as a mechanism to access the SSD approval pathway, rather than as a genuine response to demonstrated local affordable housing need.

This approach undermines the intent of State planning policy, which is to facilitate meaningful and equitable housing outcomes, not to enable developments that would otherwise be inconsistent with local planning controls. The disproportionate scale and market positioning of the development is incompatible with the policy rationale underpinning the affordable housing provisions.

2. Traffic Congestion and Road Network Capacity

The surrounding street network—including Holt Avenue, Rangers Avenue and connecting roads—is already heavily congested, particularly during school drop-off and pick-up periods and weekday peak hours. These streets have limited capacity and function within an established residential setting not designed to accommodate intensified traffic volumes.

The provision of a 91-car basement will inevitably generate a substantial increase in vehicle movements, exacerbating existing congestion, reducing road safety, and adversely affecting residential amenity. The proposal fails to demonstrate that the local road network can safely or efficiently absorb this additional traffic load.

The cumulative infrastructure impacts of the proposal extend well beyond traffic considerations. The area is already constrained by limited public transport services, insufficient street parking, narrow and restricted pedestrian pathways, and a general lack of capacity to accommodate development of this scale.

The proposal fails to demonstrate how existing infrastructure will cope with the increased population and activity levels generated by the development, and no meaningful mitigation measures have been proposed.

3. Overdevelopment and Neighbourhood Impact

The proposed scale, height and bulk are fundamentally inconsistent with the surrounding low-rise residential character. The development will result in significant overshadowing, loss of privacy, and a sense of visual enclosure for nearby properties.

Notably, the developer seeks to build to the maximum permissible height available under the affordable housing provisions, despite the site being located on a ridge that is already more than a storey above surrounding street levels. Heights should be measured from street level to accurately reflect the true visual and physical impact of the building.

The proposal bears no relationship to the scale or height of surrounding development and will present as a dominant and intrusive structure. The only nearby buildings of comparable height are located within the gully along Avenue Road, where their siting ensures they do not visually dominate the streetscape. By contrast, the subject proposal will be highly prominent and constitutes an eyesore within the existing neighbourhood context.

4. Significant View Loss for Holt Avenue Residents

The excessive height and bulk of the proposal will result in the permanent loss of long-established views for numerous Holt Avenue residents, including views to the city skyline and the Sydney Harbour Bridge. These valued outlooks will be replaced by the façade and mass of a seven-storey apartment building.

Such view loss represents a substantial and unreasonable diminution of residential amenity and has not been adequately justified or mitigated in the proposal.

5. Inadequate Visual, View-Loss and Heritage Assessments

The Visual Impact Assessment submitted with the application is materially deficient. It omits any assessment from Holt Avenue and the Holt Estate Heritage Conservation Area, despite these areas being located directly north of the site and being clearly affected by the proposal.

The Department specifically requested a detailed view-loss and view-sharing assessment; however, this has not been provided. As a result, the impacts on Sydney Harbour views, the natural landform, and the heritage character of the streetscape have not been properly identified, assessed, or addressed. This represents a significant shortcoming in the supporting documentation and undermines the integrity of the assessment process.

6. Absence of Built-Form Transition to C4 and Scenic Protection Areas

The development proposes maximum height and bulk immediately adjacent to C4 Environmental Living land and areas within the Scenic Protection Area. These zones were deliberately excluded from higher-density zoning due to their scenic, environmental and landscape values.

Despite this, the proposal provides no meaningful transition in scale, height, or built form between the development site and these protected areas. In a locality such as Mosman, which is characterised by dense vegetation and a strong landscape setting, the introduction of a large, unrelieved wall of concrete will have severe visual impacts.

At a minimum, the development should be required to incorporate extensive tall and mature planting along both the northern and southern boundaries to soften its visual presence. Even with such measures, the scale of the proposal remains fundamentally inappropriate for its context.

Conclusion

For the reasons outlined above, the proposed development represents an overdevelopment of the site, is inconsistent with the intent of planning policy, and would result in unacceptable and irreversible impacts on traffic conditions, neighbourhood character, views, heritage values, and local infrastructure. Accordingly, I respectfully request that the application be refused or substantially redesigned to address these concerns in a manner consistent with the established character and capacity of the area.