Castlecrag has been in decline for years, with a very conservative 'anti-progress' association of long-time NIMBYs. We need more housing and I support the development of this project and any project up to the first round about on Edinburgh Road heading East. There is no doubt more buses to and from Eastern Valley Way will be required to service the number of potential occupants, and some further consideration should be given for possibly a left turn only exit from the basement directly onto Eastern Valley Way, but I can not for the life of me see how this impacts the Walter Burly Griffen heritage work which is miles away from this intersection. I would love to see some actual life in the village for a change, and I have lived in the 'Avenues' down Edinburgh Road for over 40 years!

I am writing to formally object to the aforementioned submission based on its failure to comply with established zoning and statutory controls. My concerns are detailed below:

Incompatibility with Zone Objectives: The proposal significantly exceeds the expectations for the E1 Local Centre zone. This designation is intended to support small-scale, village-style mixed-use developments, rather than the intensive urban scale currently being proposed.

Excessive Height and Scale: The existing planning framework anticipates low-to-mid-rise structures. By proposing a 12 to 14-storey high-rise, the development directly conflicts with current height limits, which are capped at approximately 3 storeys.

Privacy Impacts: The disproportionate height of the building will lead to a significant loss of privacy for our property, specifically resulting in the direct overlooking of our backyard.

Visual and Skyline Breach: The proposed scale represents an unacceptable intensification that breaches both the natural ridgeline and the established skyline, permanently altering the character of the area.

We strongly object to the project's current proportions, which would permanently degrade our local character. There is an undeniable need to scale back the height and bulk of the design. This proposal represents an extreme shift in development standards that the community simply cannot sustain.


Warners Avenue Willoughby

I am objecting to the proposal in its current form because:
1 It is a gross over-development of the site and is entirely out of keeping with the character of the neighborhood, Castlecrag, which has so much heritage value
2. As the only structure on top or the ridge of that height, it will be an eyesore as it is not integrated with other low-height buildings nearby, and exceeds what is reasonable given the heritage of the area. It even exceeds by far the height of new buildings going up in nearby Northbridge which is a designated growth area and does not have the same heritage sensitivity as Castlecrag
3. The location is not near a train or metro station and the bus service is limited outside peak times
4. It will bring too much traffic into the area, and access into and out of that location is already constrained by the difficulty of getting in and out from Eastern Valley Way and/or Edinburgh Road west of Castlecrag
5. Excessive tree removal and no tree management plan
6. Lack of communal space and failure to support the village character of the area
7. Based on the residents' consultants report, the application and EIS is defective and misleading in many respects

The height of the proposed development at 11 storeys is significantly higher than the existing housing with low density R2 zoning accross the road. To go from 2 storeys residential housing to 11 story mixed use in less than 100m does not provide any graduated height increase. The site has a development approval for a 5 storeys mixed use which was 3 greater than the existing facility that has been demolished, This was a much more reasonable increase in height and scale for the local area.

Edinburgh has substantial morning peak traffic trying to exit the suburb as there are only 2 exit roads for the entire suburb. By adding 150 dwellings or over 300 addtional residents with the vehicle access occuring via Edinburgh road, this will add to the traffic congestion trying to exit the suburb especially for residents in Raeburn ave turning right onto Edinburgh rd. The proposed development is not provided the minimum number of required parking spots for the new residents which will lead to those with more that 1 vehicle parking on the neighbouring streets which are already filled with vehicles every day.


This development is to high for the area and should be reduced to the approved 5 storeys, 11 storeys is over development in a predominately R2 area

As a resident of Castlecrag for 15 years I vehemently object to the proposed development of 100 Edinburgh Road, Castlecrag.
The proposal is a major departure from the approved development of 3 stories by Willoughby Council and from Castlecrag`s planning framework. There is only one road in and out of Castlecrag and this road will be clogged with vehicles from this proposed development, already in peak hour there is a traffic buildup with vehicles leaving Castlecrag. The proposed building introduces excessive height and. density , there will also be significant tree loss with such a huge development. Also, overshadowing is an issue. This huge development will have a significant negative impact on our garden suburb created by Walter Burley Griffin in 1920 impacting this heritage conservation area and the village character of Castlecrag which we the residents currently enjoy and love. This site is not serviced by rail or metro infrastructure and bus services are limited and infrequent especially during the middle of the day. This is a failure of fundamental principles of locating density near transport hubs.
The only people this proposed development will benefit is the greedy developer.

I am a resident of Castlecrag and deeply value the character of this place as it is. I believe we have a responsibility to preserve what remains of its natural environment and distinctive atmosphere.

The Castlecrag Quadrangle once exemplified this balance, but it has been lost—largely, it seems, to short-term commercial interests rather than a genuine regard for residents or the surrounding landscape.

I note that Mosman Council has taken deliberate steps to protect its low-profile retail areas from large-scale commercial encroachment. With similar foresight and commitment, I am confident that Willoughby Council can do the same.

While high-rise developments are rapidly reshaping much of Sydney, there are still opportunities to safeguard pockets that reflect the city’s authentic identity—places where scale, nature, and community remain in harmony. Castlecrag deserves to be one of them.

I write to formally object to the proposed development at 100 Edinburgh Road, Castlecrag, comprising two residential towers of up to 11 storeys, approximately 150 apartments, ground floor retail, basement parking, and rooftop communal open space.

I am not opposed to development in principle. Thoughtful, well-planned urban growth is essential for Sydney's future. However, this proposal goes well beyond what Castlecrag can reasonably accommodate, and represents a dramatic and unjustified departure from both the established character of the area and the previously approved development application for 3–4 storeys on the same site.

Transport and Infrastructure Inadequacy

Castlecrag is poorly serviced by public transport. The suburb is accessible by a single road and has no rail connection. It is not located on any high-frequency bus corridor, nor does it benefit from the transport infrastructure that would ordinarily justify density of this scale. Neighbouring suburbs such as St Leonards, Crows Nest, and Chatswood are far better connected to rail, metro, and arterial road networks, and are consequently far better suited to high-density residential development. Approving an 11 storey development in a location so disconnected from critical infrastructure is poor planning and will generate significant traffic and amenity impacts that cannot be mitigated.

Failure to Meaningfully Address Housing Affordability

The proposal includes only 10 affordable housing units out of 150 apartments — a trivial proportion that does not constitute a genuine contribution to housing affordability. The development has already been marketed as luxury apartments. There is no credible basis to conclude that the so-called affordable units will be genuinely affordable at the point of delivery, nor that any affordability requirements will be maintained with longevity. This proposal does not in any way contribute to any solution to the housing crisis when it is, in substance, a luxury residential development with a negligible affordability component attached as a concession.

Destruction of Heritage and Suburban Character

Castlecrag is a tree-lined heritage suburb with a distinct low-rise character established over many decades. It is recognised for its Walter Burley Griffin-designed landscape and architecture. A dual-tower development of this size would be catastrophically out of scale with the surrounding built environment and would irreparably destroy the character and amenity of the suburb. The previously approved 3–4 storey development on this site represented a reasonable and proportionate density uplift. The current proposal bears no rational relationship to that approval and cannot be reconciled with the heritage significance of the area.

Opportunistic Private Interest Should Not Drive State Planning

This proposal appears to be driven by the commercial interests of an opportunistic private equity fund, not by sound planning principles. The State Government should not lend its approval to a development that so plainly prioritises short-term developer profit over genuine community benefit. Any competent planning assessment would recognise that this is not sensible planning — it is a short-term headline fix designed to give the appearance of action on housing supply without delivering meaningful outcomes for the local or wider community. The planning system exists to serve the public interest, not to be leveraged by private capital seeking to extract maximum value from an inappropriate site.

I respectfully urge the Department to refuse this application and to ensure that any future development on this site is consistent with the scale, character, and infrastructure capacity of Castlecrag.

I object to approval of the proposed development for the following reasons.
1. Height and scale of the proposed construction is completely incompatible with the surrounding urban landscape and is inappropriate to a location that has not been designated as a local town centre under the Willoughby City Local Centres Strategy. The maximum height of any residential development within the surrounding 2-3 square kilometres is 4 stories, with the majority being no greater than 3. The visual impact of twin 12-14 storey towers located on the crest of a hill will be significant, dominating the skyline as it will. Castlecrag is a village and the bulk of what is proposed is in no way appropriate for the site, where a 3-5 storey DA was granted approval in 2024 after extensive community consultation and input. Such considerations have been completely absent from the current process. The proposed development virtually quadruples the scale of the approved plan.
2. The proposed development will result in no meaningful contribution to the current housing shortage being experienced in NSW. Units within the complex are being presented as luxury dwellings, the likely sale prices for which will be outside the capacity of low-middle income earners to afford. While affordable housing dwellings are included in the plan, only 10 such units are proposed, amounting to less than 6% of Gross Floor Area, representing minimal/limited public benefit. The planned affordable housing, even if offered for rental at the applicable discount on the current market rate for the area, would also be beyond the capacity of low-middle income earners to afford. The affordable housing units are apparently not to be offered in perpetuity, limiting any possible positive impact on the housing shortage. For this reason, the development fails to meet a key justification for the implementation of the SSD process, and thus there is no valid reason for it to be approved under that regime.
3. Significant adverse heritage impacts - the site is a gateway to the world famous Griffin Heritage Conservation Area and there Heritage expert, GML Heritage Pty Ltd has assessed that the proposed scale, height and prominence of two 12-14 storey towers will introduce a visually prominent built form element into this area and to alter the relationship, conceived by Walter Burley Griffin and Marion Mahoney Griffin, in which built development is designed to be subordinate to the bushland landscape. In GML’s opinion, this would be likely to result in a substantial adverse impact on those aspects of heritage significance that are expressed through setting and views. The bulk of the proposed structures provides for no mitigation of these factors. Based on the EIS documents, in GML’s professional opinion, SSD-90134958 does not demonstrate compliance with Clause 1.2 and Clause 5.10 of Willoughby LEP 2012 or relevant conservation principles. This would irreversibly diminish the identified heritage significance of the subject site.
4. Significant overshadowing impacts - the development produces major overshadowing impacts on residential properties to the south (solar access not achieved for 2 hours between 9:00am-3:00pm to at least 50% of private open space) for 6 months of the year to residences at 9 and 11 The Postern and 99 Eastern Valley Way (comprising 4 townhouses). This will adversely impact the living conditions enjoy by residents of these dwellings. Additionally, the proposed development is does not comply with building separation/setback requirements under the NSW Apartment Design Guide (ADG). The existing dwellings south of the site range from single to two storeys and can only develop under planning controls to two storeys under the LEP or three storeys with the in-fill affordable housing bonus. The dwellings to the south also sit at a lower level than the site, however a review of the site survey reveals that there are no contours or spot heights shown on land to the south or east of the site.
5. Castlecrag is located approximately 4 kilometres from the nearest train stations (heavy rail and Metro) and is serviced by bus transport solely. Edinburgh Road provides the sole entry and exit point to the suburb, effectively single lane in both directions (east and west) when kerbside parking is taken into consideration. The addition of in excess of 350 parking spaces within the proposed development and the additional traffic these will generate, will likely have highly adverse impacts upon traffic flow at morning and afternoon peak times, to the extent that gridlock may result and vehicles may be prevented from entering and exiting the development (one entry/exist point only). While amended interval phasing of the traffic lights at the intersection with Eastern Valley Way (EVW) may address these problems, the resulting negative impact on traffic flow on EVW, a major arterial route, may be devestating, particularly in morning peak times.
6. Lack of community consultation - the proponent's unwillingness to engage with the community and, by its own admission, to take into consideration any community feedback in relation to drafting of the EIS and DA, represents a failure to comply with one of the fundamental requirements applicable to the SSD process. The supposed consultation sessions were strictly limited in attendee numbers, presented little meaningful information and were characterised by misinformation and incomplete disclosure. The developer has displayed contempt for the community which it is claiming to serve. The purported benefits that the proposed development will deliver to the community are overwhelmingly exceeded by the negative impacts.

Excessive hight does not fit in with surrounding area causing overshadowing.

Traffic
Table 8 of the EIS states that Transport for NSW has not commented on the Traffic Management Plan. This is a significant concern as the Traffic Impact Assessment identified that the “Intersection of Eastern Valley Way and Edinburgh Road is operating below desired standards in the morning peak hour as the right turning traffic exceeds the right turn lane capacity and is overflowing into through traffic lanes on north approach of Eastern Valley Way.”
As a local resident, this is a significant concern as this intersection is already over capacity and sometimes takes a few sequences to get through the intersection. The addition of potentially up to 376 additional vehicles at the development during operation will mean that this intersection will be impossible to use.
Also during construction the trucks needed for deliveries will also impact the neighbouring road network. What measures are in place to ensure work vehicles do not impact neighbouring residents by using local roads as rat runs and parking?
No adequate measures have been provided to mitigate these issues.
TfNSW need to review these reports and provided their advice as I am sure they will reject the development.

Heritage
Section 7 of the EIS (Assessment & Mitigation of Impacts), summaries where the requirements of the SEARs have been considered. Page 85 states that only a standard assessment (not detailed assessment) was required for heritage.
The site adjoins the Griffin Heritage Conservation Area and due to the significance of this association a detailed assessment should have been undertaken.
Also Section 7.2.16. of the EIS (Heritage), states “The WBGS provided guidelines for the Quadrangle Architectural Design Brief that informed the initial Planning Proposal.” It appears that they have not been consulted for the revised proposal.
In addition the mitigation measures are not sympathetic to the heritage of the area.

Inadequate Consultation
Within the EIS, Section 6.3 Engagement Activities refers to the letter box drops included as part of the consultation area and refers to Sections 5.1 and 61 of the Community Engagement Outcomes Report (Appendix K). Figures within these sections show where “notices were distributed to properties within proximity to the site”. Looking at these figures the catchment does not extent very far. The reports justification these properties are the ones “that were most likely to hear, see or otherwise be impacted by the proposed development.” This is inadequate as was a very limited distribution and therefore the community may not have known about the events.
According to NSW Government guidance, SSD projects typically have a distribution of several 100 metres in all directions. It is evident that this has not been done and appears that the letter box drops were selective. In particular it was noticed that most of the residences on Raeburn and Rutland Avenues were excluded. These roads are likely to be significantly impacted by additional construction traffic (including their use as “rat runs”) as well as parking by workers.
The project has not adequately engaged with the community.