To Whom It May Concern,
Attached please find my objection letter opposing SSD 96272465 and labeled:
BHolt SSD-96272465 objection.pdf
In addition to my submission, you will also find the following attachments:
APPENDIX A: McLaren Traffic Engineering Letter of Advice 16 Dec2025 (F).pdf
APPENDIX B: Spofforth St Accident Report.pdf
APPENDIX C: 11-23 Rangers Avenue-Mosman Survey Report Dec42025.pdf
APPENDIX D: Objection Submission to SSD 96272465.pdf

Please confirm receipt of all documents listed above.

Kind regards

I object to this project and raise the following concerns:
• Increased Traffic congestion
The surrounding streets (Holt Avenue, Rangers Avenue and connecting roads) are already heavily congested, especially during school and peak periods. A 91-car basement will substantially increase vehicle movements in an area with limited road capacity.
• Pedestrian and cyclist safety risks
Rangers Avenue is narrow, steep and used frequently by pedestrians, schoolchildren and cyclists. The proposed vehicle volumes intensify collision risks and worsen existing safety issues.
• Significant view loss for Holt Avenue residents and possibly Spencer Road residents
The proposed height and bulk would remove long-established city skyline and Harbour Bridge views from numerous homes, replacing them with the facade and mass of a seven-storey apartment block.
• Overdevelopment and neighbourhood impact
The scale is inconsistent with the surrounding low-rise residential character, resulting in overshadowing, loss of privacy, and a sense of enclosure for nearby properties.
• Local infrastructure constraints
The cumulative strain goes beyond traffic, with limited public transport, insufficient street parking, constrained pedestrian pathways and no capacity in the immediate area to absorb a development of this scale.
• Inadequate visual, view-loss and heritage assessments
The Visual Impact Assessment omits any analysis from Holt Avenue and the Holt Estate Heritage Conservation Area, even though these sit directly north of the site. The Department requested a detailed view-loss and view-sharing assessment, which has not been provided. As a result, impacts on Sydney Harbour views, natural landform and the heritage character of the streetscape have not been properly evaluated.
• No built-form transition to protected C4 and scenic areas
The development proposes maximum height and bulk directly beside C4 Environmental Living land and areas within the Scenic Protection Area. These zones were intentionally excluded from LMR due to their scenic and environmental value, yet the design provides no meaningful transition in scale.
• Misalignment with SSD policy intent
Although labelled as an “affordable housing” SSD, the project primarily delivers luxury apartments, with the affordable component serving to unlock the SSD pathway rather than meeting genuine affordable-housing need.

I wish to lodge an objection to the proposed development at 11–23 Rangers Avenue.

I recognise the broader policy objectives around housing supply and density. However, those objectives do not remove the obligation under section 4.15 of the Environmental Planning and Assessment Act to ensure that development is suitable for its specific site and does not cause unreasonable impacts on surrounding residents or infrastructure.

In my view, this proposal is overly intensive for its location and raises serious concerns in relation to traffic impacts, the scale and depth of excavation and the loss of residential amenity, particularly views and privacy.

2. Traffic impacts and local road network capacity

2.1 Impact on already congested intersections and roundabouts
While Rangers Avenue is capable of accommodating some additional traffic, the more pressing issue is not the immediate site frontage but the downstream effects on nearby intersections and roundabouts, particularly:
Rangers Avenue / Park Avenue, and Rangers Avenue / Avenue Road.

These roundabouts already experience congestion during peak periods and operate under constrained conditions. The proposal will introduce a substantial increase in vehicle movements, including residents, visitors, servicing vehicles and deliveries.

The Traffic Impact Assessment appears to focus on the site in isolation and does not adequately address how additional traffic will be absorbed by these already pressured junctions, particularly during peak times, nor does it convincingly assess the cumulative impact of this development together with other current and foreshadowed developments along Rangers Avenue.

In my view, the analysis underestimates the likelihood of congestion, queuing and indirect traffic redistribution through surrounding residential streets.

2.2 Construction traffic has not been realistically assessed

The scale of excavation proposed for this development will require a prolonged period of heavy vehicle movements, including excavation trucks, concrete agitators, crane components and large delivery vehicles.

The Traffic Impact Assessment relies heavily on average traffic assumptions and does not sufficiently demonstrate how sustained construction traffic of this nature can be safely and efficiently accommodated on Rangers Avenue and the surrounding road network, particularly during peak periods.

This is not a short-term or minor inconvenience. It will be months of intensive construction activity with real impacts on safety, congestion and daily life for surrounding residents.

3. Depth of excavation and geotechnical risk

3.1 Excavation scale is excessive for this site
The proposal involves excavation to a depth of approximately 10 metres to accommodate multiple basement levels. While deep basements may be achievable on some sites, the suitability of such excavation must be assessed in the context of local conditions.
This site is constrained by:
- sloping topography
- sandstone and rock formations typical of Mosman
- the close proximity of neighbouring residential properties.
The excavation will occur very close to adjoining land, leaving little margin for error.

3.2 Risk to surrounding structures and long-term stability
I am concerned that the documentation does not provide sufficient confidence that risks associated with:
- ground movement,
- vibration,
- changes to groundwater conditions, and
-long-term stability of rock faces and retaining structures
can be adequately managed.

Experience across Sydney shows that deep excavation on constrained sites can lead to cracking of neighbouring buildings, destabilisation of rock faces and long-term structural issues. Once such damage occurs, it is often irreversible and extremely difficult to remedy.
Given the cumulative development pressure along Rangers Avenue, these risks should be treated with particular caution.

4. Loss of residential amenity: views and privacy

4.1 Loss of valued views
The proposed building will result in the loss or significant reduction of established views from surrounding homes, including views towards Mosman Bay, the harbour and the broader scenic landscape.

These views are not incidental. They form an important part of the amenity and character of the area and are a key reason why many residents have invested in and maintained their homes over long periods.

Under established NSW planning principles, including those outlined in Tenacity v Warringah Council, view loss must be assessed having regard to the value of the view, the extent of the impact and whether the outcome is reasonable in the circumstances.
In my view, the bulk and height of the proposed development exceed what can reasonably be accommodated on this site without causing undue harm to surrounding properties.

4.2 Loss of privacy and visual dominance
The height, scale and proximity of the proposed building will also lead to increased overlooking of neighbouring dwellings and private open spaces.

Despite proposed setbacks and screening, the elevated nature of the site and the number of apartments proposed will fundamentally change the outlook and sense of privacy currently enjoyed by surrounding residents. The resulting built form will be visually dominant and out of keeping with the established residential character of the area.

5. Cumulative and precedent impacts

This proposal should not be assessed in isolation. Rangers Avenue is already experiencing significant development pressure, with multiple sites under consideration or investigation.

Approving a development of this scale and intensity on a constrained site would set a precedent for similar proposals along the street, compounding traffic, excavation and amenity impacts in a way that was not contemplated when the existing residential neighbourhood was established.

6. Conclusion
For the reasons outlined above, I submit that the proposed development at 11–23 Rangers Avenue:
- does not adequately address traffic impacts on the surrounding road network,
- involves excavation of a scale and depth that presents unacceptable risk given the site constraints, and
- will result in unreasonable loss of views, privacy and residential amenity for surrounding properties.

I respectfully request that the consent authority refuse the application, or at the very least require a substantial redesign to reduce height, bulk, excavation depth and traffic impacts to a level that is genuinely compatible with the site and its surroundings.

SSD-96272465 11-23 Rangers Ave Mosman 2088
I have considered the plans and documents for the above proposal. I am a Mosman resident and have been so for many years including 10 years living at 13 Holt Avenue, so I do know the area of the proposed development very well.
The visual and traffic aspects of the development will adversely affect me. The development is out of character for the part of Mosman in which it is to be located. While more housing is needed in Sydney, several developments are already proposed for the Mosman Council area and the required increase in housing numbers will be easily achieved by other developments. Many of the other developments are better located and will have less traffic and visual amenity impacts. In addition there are other parts of Mosman that are nearer to transport, shops and where the scale of proposed development would be more in keeping with the surrounding development. These areas are where multi apartment developments should be located.
Visual Impact
The proposed development will be among the very largest buildings in Mosman being more than 70 metres wide and more than 27 metres high (above Rangers Avenue at the eastern end of the site). The façade presents as an area of approximately 1900m2 – one and half Olympic Swimming Pools tipped on their side! The building will appear overbearing when approaching from either direction along Rangers Avenue and will dwarf its neighbours which are single or double storey and mostly detached dwellings. This is illustrated in the photomontages included with the EIS. There is no other building of comparable scale within 500m of the site.
Sydney Harbour is our city’s jewel in the crown and views from the harbour are particularly important in keeping it that way. Wherever possible the views should be of vegetation, sandstone outcrops and sky. The photomontage view from Mosman Bay illustrates how the proposed development will unacceptably impose itself on this view. Also, the white sandstone and blond brick materials chosen will accentuate the building’s visual intrusion.
Traffic Impact
With 90 car bays and 11 visitor spaces if each car is used every second day with 2 movements per car (i.e. in and out) 100 car movements can be expected per day. The traffic count taken for the TIA indicates negligible traffic between 12am and 4am, so average movements per hour is 5, but peak hour usage is likely to be twice that and off peak less. So reasonable to assume 10 movements/ hour in peak hour, considerably more than the 3 or 4 per hour estimated in the TIA. The Transport for NSW Guide to Transport Impact Assessment (GTIA) document recommended vehicular trip rates for high density residential developments are not appropriate for a development that is aimed at a high socio-economic demographic. The major impact on traffic flows is due to west-bound vehicles turning right into the building entry. During high traffic times they will wait a considerable time to find a gap between east bound vehicles thus causing delays to all following west-bound vehicles. Traffic will back up and block the Park Street roundabout and likely the Avenue Road roundabout as well.
Weekend traffic along Rangers is often worse than weekday peak hour traffic. This is particularly the case on Saturday mornings driven by children’s sport plus trips to Mosman’s attractions. Sunday afternoons can also be bad as people leave beaches and zoo etc. It is not uncommon to see traffic at a crawl and backed up a long way eiter side of the 2 Avenue Road roundabouts. No further increase to this traffic should be tolerated.
Traffic during construction will cause considerable chaos. We have a current example of a smaller multi-unit development under construction in Redan Street north of Raglan Street. Redan Street is the same width as Rangers Avenue (approx. 8.5m). Traffic is often stopped to allow safe loading and unloading of materials. Sometimes this is in both directions, sometimes single lane traffic is possible with appropriate traffic control. Redan Street is not heavily trafficked and there are easy alternatives. This will not be the case with the Rangers development. If approved a condition of consent should require an unloading area for delivery vehicles to be developed totally within the site.
In Mosman there is a significant drop off in traffic during public and private school holidays. The traffic counts used in the TIA were taken in September. To be of any use they need to have been taken before the holidays at the end of Term 3 commenced.

It's absurd that the Government allows luxury multi-million dollar harbourview apartments in our backyards while claiming to help people. All it's doing is lining the pockets of developers while destroying our neighbourhood, our heritage, our privacy, our peace and quiet, our light, our views and our ability to move on un-congested roads.

Please find attached my objection email that was submitted earlier.