As the owner and resident of 116 Edinburgh Road, Castlecrag, I live immediately adjacent to the proposed project and share a common driveway subject to a Permanent Right of Carriageway DP609580 as the only access to the rear of my property. I had reached an agreement with the previous owner of the site based on DA 2024-13 and DA 2024-17 approved by Council and The Northern Sydney Planning Committee. I was advised that our shared driveway was due to be demolished as part of the development and access would be unavailable for between six months and a year, as reinstatement of the Right of Carriageway would be given priority.
Since Conquest has taken over I have learned that it is not planned for the Right of Carriageway to be reinstated until the proposed development is completed and an Occupation Certificate issued, a time frame of up to 3 years or possibly more. This is completely unacceptable as there is no long term parking near and I will be competing with a significant number of tradesmen and women for the whole of this time. This forms the major basis of my personal objection and I see no reason why Conquest’s EIS and DA cannot address this. Additionally, I am extremely concerned that the deeper excavation to provide more levels of parking will severely impact the stability of my property given its proximity to my foundations.
On a more general note I object to the scale of the new proposal as it will cause major overshadowing not only to my property but many others in the immediate vicinity.
Also the traffic impact on Edinburgh Road generally and more particularly the impact during rush hours of vehicles trying to exit my shared driveway to turn east towards the junction with Eastern Valley Way cannot be underestimated. Traffic is already backed up to the junction with Rutland Avenue during the morning peak .
While these are just a small number of my reasons to object to the project, I am at a complete loss as to why this application should be even considered as a State Significant Development as it fails its own guidelines in almost every area without even considering Castlecrag’s heritage and its relationship to the architect of our nation’s capital. I urge the Minister and the HDA to approve the previous DA as a reasonable and just compromise for our unique suburb.
Anne Richards

The revised plan of a twin 12-storey residential building is way off the current Castlecrag community landscape and against the area's rich heritage and historical importance - the original Griffin design of a nature-friendly community. The revised plan has not been appropriately consulted with local community, disregards the local traffic and public transport limitations, violates the trust with local community when we supported the original DA. This SSD application is a disgraceful act of profiting, taking advantage of State government's housing crisis.

I am writing to provide a submission regarding the proposed development at 100 Edinburgh Road, Castlecrag.

I want to be clear at the outset: I support appropriate development of this site. Renewal of the former Quadrangle is needed and overdue. However, the scale and intensity of the current proposal are not appropriate for this specific location, and do not align with the physical, transport, and heritage constraints of Castlecrag.

1. Scale is inconsistent with site constraints

The proposed development represents a significant escalation in density relative to the surrounding area. Castlecrag is not a high-density centre, and the site does not function as a transport or commercial hub capable of supporting this level of intensity.

This is not an objection to development — it is an objection to overdevelopment relative to site capacity.

2. Traffic and access constraints

The most critical issue is traffic.

* Castlecrag effectively operates with a single primary entry and exit corridor, creating a natural bottleneck.
* The proposal will materially increase traffic volumes without credible evidence that the surrounding road network can absorb this safely or efficiently.
* Increased congestion directly impacts emergency access, safety, and daily livability.

Given these constraints, the traffic impact is not a marginal issue — it is fundamental to whether the site can support this development at all.

An independent traffic assessment should be required, not solely reliance on developer-commissioned modelling.

3. Lack of alignment with public transport capacity

The site is not located within a high-capacity public transport corridor.

* There is no rail access.
* Bus services are limited in frequency and capacity.
* The proposal assumes a behavioural shift toward public transport that is not supported by existing infrastructure.

As a result, the development will remain car-dependent, compounding the traffic impacts outlined above.

4. Heritage and character impact

Castlecrag, and particularly the surrounding Griffin Conservation Area, has a well-established and sensitive village character.

The proposed scale:

* Risks overpowering the existing built form
* Undermines the architectural and environmental intent of the area
* Creates a precedent that is inconsistent with the locality’s planning framework

This is not simply aesthetic — it is a planning and heritage integrity issue.

5. Community consultation concerns

While consultation has been undertaken, it did not appear to be meaningful.

At a recent session, it was explicitly stated that the SSD process limits the influence of local council and community input. This creates the perception that consultation is procedural rather than genuine.

Effective planning requires not just consultation, but consideration. That has not been demonstrated.

6. Inconsistency between planning controls and proposed outcome

There appears to be a disconnect between:

* The planning proposal controls (including height expressed in AHD/metres), and
* The scale of development now being proposed (in terms of storeys and density)

This raises concern that the proposal is testing or exceeding the intent of the approved controls, rather than working within them.

7. Precedent risk

Approving a development of this scale in this location would set a significant precedent for similar uplifts in areas not designed to accommodate them.

This has broader implications beyond this single site and should be considered carefully.

Conclusion

This site should absolutely be redeveloped. However:

The current proposal exceeds what the site, infrastructure, and surrounding environment can reasonably support.

I urge the consent authority to:

* Require independent traffic and infrastructure assessments
* Reassess the appropriate scale and density for the site
* Ensure that heritage and village character are preserved
* Demonstrate that community input has been genuinely considered

A more balanced, context-appropriate development would likely receive broad community support. The current proposal does not.

SSD 90134958, 100 Edinburgh Road, Castlecrag

I support more housing and more diverse housing, including affordable housing. This proposal is not “more housing at a sensible scale.” It is a tower outcome in a low scale local centre, and the EIS reads as contrived in the way it tries to justify it.

What is proposed is a tower scheme, not a mid rise local centre outcome
The EIS seeks “a 4 storey podium” with “two 11 storey residential envelopes” above, plus five basement levels, delivering 150 dwellings.
It also seeks a maximum building height of 48.96 metres, an FSR of 4.2:1, and 376 car spaces.

The EIS’s own comparison table shows the scale jump is extreme: 38 dwellings to 150, and 15.75 metres to 48.96 metres.
That is not “incremental uplift.” It is a step change.

Right place, right scale, and this is the wrong scale
The EIS itself describes low scale built form immediately around the site. For example, west of the site it notes “low scale residential dwellings of primarily one and two storeys.”
It also describes two storey mixed use buildings nearby, and low density residential zoning to the north and south in the broader context.

The EIS tries to normalise 11 storeys by claiming nearby provisions could allow “built forms between 4–8 storeys” and that the proposal is compatible with that “likely future context.”
Even on their own framing, that points to mid rise, not 11 storeys.

The same EIS also says “LMR” and “Infill Housing 30%” provisions allow “envelopes up to 24m in height.”
This proposal is 48.96m.
That is not a reasonable extension of “emerging” controls. It is doubling them.

Requested outcome
Approve more housing only with a mid rise envelope: 4 to 5 storeys to Edinburgh Road, and maximum 7 storeys to the rear, with enforceable step backs, setbacks, and separation.

Overshadowing and amenity are being minimised, and the document contradicts itself
The EIS admits the development will “result in overshadowing to the south,” but then claims the impacts are “similar” to the approved scheme and “acceptable.”
That assertion is not a substitute for a rigorous impact test at 11 storeys.

More importantly, the EIS also admits a clear internal amenity failure that is a direct symptom of pushing too much bulk and height: “more than 15% of apartments do not receive direct sunlight at the winter solstice,” which it says is “not consistent with the ADG’s recommendations.”
A scheme that cannot meet baseline solar expectations for its own residents should not be waved through on the basis that shadows are “acceptable.”

Requested outcome
Independent peer review of solar access and overshadowing for surrounding properties and for the proposed apartments. If impacts are material, mandate the reduced envelope above.

Traffic and access is the clearest example of a contrived narrative
The EIS repeatedly leans on buses and accessibility, including claiming a “well established bus network” with direct access to major centres.
Yet it also proposes five basement levels and 376 car spaces.
That is not a public transport led design. That is car infrastructure on a huge scale.

The EIS states “Access to the site is provided via Edinburgh Road, by way of a combined entryway,” and that waste vehicles enter from Edinburgh Road.
It also states the intersection of Eastern Valley Way and Edinburgh Road is “operating below desired standards in the morning peak hour” because right turn traffic exceeds capacity and overflows into through lanes.
Despite that, the proposal still concentrates all movements onto Edinburgh Road.

This is exactly backwards. The site has major frontage to Eastern Valley Way, and the access strategy should use it to reduce pressure on the Edinburgh Road movements and the intersection.

Requested outcome
Require the proponent, in consultation with TfNSW, to assess and implement if feasible:

Ingress from Eastern Valley Way for southbound vehicles via a safe left in, and
Egress to Eastern Valley Way for southbound dispersal via a safe left out,
so that a significant portion of trips do not need to use Edinburgh Road to move south.

If TfNSW will not permit Eastern Valley Way access, require a funded, deliverable intersection upgrade package that directly addresses the EIS acknowledged morning peak failure mode.

Affordable housing is being used as a narrative, while being deliberately minimised
The EIS sets out its alternatives and explicitly rejects an “Infill Affordable Housing” option because 15% affordable is “not feasible,” and because “the 15% requirement is too great.”
It then prefers the HDA scheme because it provides “greater density” and “a lower affordable housing component.”

At the same time, the proposal delivers 10 affordable dwellings, and only for “a minimum of 15 years.”
That is not a credible trade off for a 48.96 metre, 150 dwelling tower scheme.

Requested outcome
Either reduce the scale to mid rise, or materially increase the affordable housing offer and tighten delivery and duration commitments.

Wind and public domain comfort show the ground plane is being compromised
The wind mitigation measures include relocating an entrance away from “accelerated winds,” and avoiding outdoor dining around a corner.
A local centre should improve street comfort and activation. If the scheme needs to move entrances and avoid uses to be comfortable, the bulk is part of the problem.

Requested outcome
Require redesign that achieves acceptable ground plane comfort without avoiding uses and relocating entrances.

Cumulative impacts are acknowledged, then brushed aside
The cumulative impact section identifies construction noise and traffic as having potential cumulative impacts.
Given the scale of excavation, parking, and traffic concentration, this cannot be dealt with by generic management plans. It requires enforceable design changes, and enforceable traffic mitigation.

Conclusion
I support more housing. I do not support two 11 storey envelopes at 48.96 metres in this context, justified by arguments that simultaneously rely on “mid rise emergence,” while doubling the height they cite, and minimising amenity and traffic issues they themselves acknowledge.

Consent should not be granted unless the proposal is redesigned to a mid rise outcome: 4 to 5 storeys to Edinburgh Road, maximum 7 storeys to the rear, with materially reduced overshadowing, and a credible access strategy that uses Eastern Valley Way for both ingress and egress, or delivers equivalent intersection performance outcomes through funded upgrades.

NSW PLANNING PORTAL SUBMISSION
Objection to State Significant Development
100 Edinburgh Road, Castlecrag NSW 2068
Submission Type: Objection
Summary of Position:
I strongly object to the proposed development. The proposal is inappropriate in scale, inconsistent with heritage protections and represents a misuse of the State Significant Development pathway.
Key Reasons for Objection:
1. Heritage Impact
Castlecrag is a nationally and internationally significant planned suburb designed by Walter Burley Griffin and Marion Mahony Griffin. The proposed 11-storey towers are fundamentally incompatible with the low-rise, landscape-integrated character of the Griffin Heritage Conservation Area and would cause irreversible damage to its integrity.
2. Excessive Height and Scale
The proposal for two 11-storey towers and approximately 150 units is grossly excessive. It represents a significant departure from the previously approved 3–5 storey, 38-unit scheme and is entirely out of character with the surrounding built environment.
3. Strategic Planning Inconsistency
The site is not located within a designated housing growth area and lacks proximity to major transport infrastructure. The proposal is inconsistent with NSW planning policy, which directs higher density development to appropriate, well-serviced locations.
4. Misuse of State Significant Development Pathway
The application appears to rely on the SSD pathway to bypass local planning controls and heritage protections. There is no justification for treating this development as state significant in a manner that overrides established local planning frameworks.
5. Traffic and Infrastructure Impacts
The scale of the development will place significant strain on local roads and infrastructure. Insufficient detail has been provided to demonstrate that these impacts can be appropriately managed.
6. Community and Expert Opposition
The proposal is strongly opposed by the Castlecrag Progress Association, the Walter Burley Griffin Society, local residents, and Willoughby Council (8–1 resolution). This reflects well-founded concerns supported by heritage and planning expertise.
7. Precedent
Approval would set an unacceptable precedent for high-rise development within a protected heritage suburb, undermining the integrity of planning controls and heritage conservation efforts.
Conclusion:
The proposed development is inappropriate, excessive, and inconsistent with both local and state planning principles. It would cause permanent harm to the heritage significance and character of Castlecrag.
Declaration:
I request that the NSW Planning Department refuse this application in its entirety.
Name:
Richard Morris
Address:
PO Box 4232 Castlecrag NSW 2068
Date:
22 April 2026

Castlecrag is internationally recognised for its planning and architectural significance, based on the principles of Walter Burley Griffin and Marion Mahony Griffin. The Conservation Area is defined by:

* Low-scale, landscape-integrated dwellings
* Minimal visual impact from the public domain
* Retention of native vegetation and natural topography
* A cohesive architectural language that responds to the bushland setting

The proposed apartment development, by its scale, bulk, and intensity, is fundamentally at odds with these principles. It introduces a built form that is visually dominant and inconsistent with the fine-grain residential character that defines Castlecrag.

The proposal represents a clear overdevelopment, characterised by:

* Excessive building bulk and scale relative to surrounding development
* A density outcome inconsistent with the established low-density character
* Reduced landscape setting and inadequate deep soil zones
* Likely impacts on privacy, solar access, and outlook for adjoining properties

This level of intensification is not appropriate within a sensitive heritage conservation area and sets an undesirable precedent for further erosion of planning controls.

Castlecrag is not equipped to support large-scale apartment development. Key concerns include:

* Traffic and Access: Narrow, winding roads with limited capacity to accommodate increased traffic volumes
* Parking Pressures: Likely overflow parking impacting already constrained streets
* Public Transport: Limited public transport options relative to the proposed density
* Services and Utilities: Existing infrastructure was not designed for high-density development

Approving developments of this scale without corresponding infrastructure upgrades places undue strain on the locality and diminishes amenity for existing residents.

The proposal is likely to result in:

* Removal of significant native vegetation
* Disruption of the natural bushland character
* Increased stormwater runoff and associated impacts
* Loss of the visual “bush setting” that is integral to the identity of Castlecrag

The Griffin vision was one of harmony between built form and landscape. This proposal moves in the opposite direction.

It is also important to note that the Willoughby City Council local government area is already accommodating significant housing growth and is contributing to the NSW Government’s housing targets, including those associated with the Transport Oriented Development (TOD) Program.

Recent planning reforms have identified appropriate locations for increased density, typically centred around transport hubs and areas with existing infrastructure capacity. Castlecrag is not one of these locations.

There is no demonstrated strategic need to introduce additional high-density development in a sensitive heritage conservation area when:

* Housing targets are already being met or exceeded within the LGA
* More suitable, better-serviced locations have been identified for increased density
* The subject site lacks the transport and infrastructure characteristics that underpin TOD principles

Allowing this proposal would undermine the strategic intent of the TOD framework by directing density to inappropriate locations.

The proposal appears inconsistent with the intent of the Willoughby City Council Local Environmental Plan and Development Control Plan, particularly in relation to:

* Heritage conservation
* Built form and scale
* Landscape character
* Streetscape integration

It also fails to reflect the long-standing community expectation that Castlecrag’s unique character will be protected, not diluted through inappropriate development.

Approval of this development would create a damaging precedent, encouraging similar over-scaled proposals within the Conservation Area. This would lead to incremental erosion of the very qualities that make Castlecrag unique and significant.

For the reasons outlined above, the proposed Conquest apartment development should be refused. It is:

* Inconsistent with the heritage significance of the Burley Griffin Conservation Area
* An overdevelopment of the site
* Unsupported by local infrastructure
* Contrary to the strategic intent of the TOD framework
* Detrimental to the environmental and landscape character of Castlecrag

We respectfully request that the NSW Government give due consideration to these concerns and reject the proposal in its current form.

My comments concern traffic safety, scale and suitability of the proposal.

Concerning traffic, I believe that what the developer reported to me as constituting the basis for their plan is not correct: that is, the classification of the intersection of Edinburgh Road and Eastern Valley Way as being in the highest rank of available transport service. Several of the bus lines 'serving' the location only pass through without stopping on the way to/from the city. The service along Edinburgh Rd is very infrequent. The route to Chatswood winding and lengthy. There is no direct access to either Metro or the train line at Chatswood, only at North Sydney. As a consequence, it is likely the selected site will depend mostly on private car traffic, both for residents and shoppers as well as deliveries for the planned supermarket and shops. I note that the proposed single ingress/egress point for the whole development lies within 100 paces of busy traffic lights at the 4-way intersection of two major roads: congestion and accidents are surely predictable, as is access for emergency vehicles etc. Both restriction of scale of the building and/or remedial traffic planning for Castlecrag as a whole are needed, as I have commented to the developer in two different submissions. This landlocked suburb has only two roads leading into and out of it, the lesser of which is a narrow and winding street debouching onto Eastern Valley Way at the bottom of a steep dip with no traffic lights. In addition, existing new residential developments are increasing density already around the main intersection.

In terms of suitability of design, I believe that Castlecrag is uniquely based upon a whole-of-suburb design by the world-famous architects, Marion and Walter Griffin, encompassing a large section of the present roads, houses, community facilities (including a hospital, school and pre-school and public library as well as an outdoor theatre and multiple walking paths and reserves. The site proposed is literally a Gateway Site to a carefully planned and largely preserved human-scale living communal precinct. This means that the development's own design should enhance and complement the suburb as a whole, not dominate it in the way a building like Blues Point Tower-- however admirable as the work of another eminent architect -- imposes itself upon a whole peninsula.

I urge the panel to take into account both scale of building, traffic impacts and complementarity of design with the exisiting nature of the suburb when evaluating this proposal. I note that the proposal as approved at the DA stage by Willoughby Council constitutes a reasonable approach to all these concerns, and I question whether the proposal before the panel is equally able to meet those three criteria in its current form.

The proposed development in outrageous in its scale.The developer has complete disregard for Castlecrag and what the Crag means to residents including with the original plans by Walter Burley Griffin to make this a fabulous place to live.
There are no residential developments in the immediate area above 3 levels the site is not within a TOD area..
This development should not be approved the fact that it’s being considered in its current form is a disgrace.
Ray Gent

1.The original DA which was approved by Council and the supported by the community at large. It was a measured response to a need to redevelop this site.
2.There has been continued development of medium density housing along Eastern Valley Way and the western side of Edinburg Road. None of this development exceeds 3 to 4 storeys. The new proposal will dwarf anything that surrounds it and is totally out of character for the area.
3.The current Government undertook to develop multi-storey housing along major transport routes, most specifically rail. The Castlecrag development can in no way be categorised as being anywhere near a major transport hub. In fact its height far exceeds that of the new developments along the Pacific Highway and rail corridor from Roseville to Wahroonga.
4. The duplicity of suggesting this development contains affordable housing is quite hard to believe. Around 10 apartments at a reduced rent for 15 years, which I believe is to equivalent to around 20% of the median rental for the area. This will still be unaffordable for even some lower middle income residents, let alone a pensioner!
5.Access into and out of Castlecrag is by one major artery i.e. Edinburgh Road. The developer's representatives at the last information session admitted that the development would further impact on the current problem of access especially during peak hour. They also acknowledged that there was an assumption that more residents would use public transport. They had know way of justifying this assumption and admitted that any increase in public transport was not part of the proposal and beyond their control. Much of Castlecrag has steep and narrow winding streets unsuited to large vehicles such as buses. So to expect elderly residents to walk significant distances to public transport is grossly unreasonable.
6.Castlecrag is recognised as a significant example of a suburb planned by the world renowed Burley-Griffin architects. What is being suggested is a development at the immediate gateway to the suburb. A number of local and overseas architects have strongly condemned the proposal.
7.The developer has given no indication of awareness of the aged sewerage system in the Castlecrag, and many other, areas. When questioned they basically said it was not their problem but had to be dealt with by Sydney Water. I have spoken to Sydney Water empolyees when they have been regularly on-site for repairs. These Tradespeople confirmed that the system will be overwhelmed by the increasing load placed on it.
8.It seems self evident that the more than 3 fold increase in the size of the development is driven by profit motive alone. The height increase beyond any surrounding medium density dwellings is to obtain views from the mutimillion dollar apartments on the upper floors. The claims of nimbyism by the Premier and his minister are quite fatuous. I believe neither of them has visited the community to justify the listing of this building as a State Significant Development. In short I believe the development is driven by profit motive and political expediency. It cannot be justified considering the many negatives.
9. The developer paid for an already approved DA, they have been duplicitous and should be held to the original DA that was included in their purchase.