Please find attached Mosman Council's submission in relation to the SSD for 40-48 Redan Street, Mosman (SSD-93020230)

Please see my detailed objection attached.

I am writing to object to the proposed Residential Development with In‑fill Affordable Housing at 40–48 Redan Street, Mosman. While I support well‑designed and appropriately located affordable housing, this proposal represents an over‑intensification of the site and fails to satisfy key planning, environmental, heritage, and safety considerations. The development is inconsistent with the SEPP (Housing) 2021, the Mosman LEP, the Mosman DCP, and the objectives of the Scenic Protection Area affecting the site.

1. Excessive Height, Bulk, and Overdevelopment

The proposal for a 10‑storey building is fundamentally incompatible with the surrounding low‑rise residential context. Key issues include:

• A height that dramatically exceeds the established built form and breaches the LEP height control.
• A reliance on a Clause 4.6 variation, yet the application is described as “compliant,” which is misleading and undermines transparency.
• A scale and massing that would visually dominate Redan Street and set an undesirable precedent for future high‑rise encroachment.


The building is being engineered to fit the site rather than designed to respond to its constraints, which is a clear indicator of overdevelopment.

---

2. Deep Excavation and Structural Risk

The proposal requires excavation of up to 10 metres into sandstone, extending to the site boundaries. This raises serious concerns:

• Risks of ground movement and vibration affecting neighbouring properties.
• Potential structural damage to heritage buildings and older dwellings not designed for such disturbance.
• A construction methodology that prioritises maximising yield over respecting geotechnical limitations.


The scale of excavation is disproportionate to the site and introduces unacceptable structural and safety risks.

---

3. Heritage Impacts on 36 and 38 Redan Street

The site directly adjoins heritage‑listed properties at 36 and 38 Redan Street. The proposed 10‑storey structure would:

• Overwhelm the heritage items through excessive height and proximity.
• Disrupt their visual setting and diminish their contribution to the streetscape.
• Erode the fine‑grain character that defines this part of Mosman.


The proposal fails to demonstrate how the heritage significance of these items will be conserved, as required under the LEP.

---

4. Conflict with Scenic Protection Area Objectives

The site is within a Scenic Protection Area, where planning objectives include:

• Limiting visual intrusion.
• Protecting landscape character.
• Maintaining the natural and built form harmony of Mosman’s ridgelines and slopes.


A 10‑storey building is fundamentally inconsistent with these objectives and would introduce a visually intrusive element that cannot be mitigated through design measures.

---

5. Traffic, Access, and Safety Concerns

The proposal relies on access via Redan Lane, which is:

• Only slightly over 4 metres wide.
• Lacking footpaths.
• Not designed for increased service, waste, or emergency vehicle activity.


Introducing larger vehicles into such a constrained laneway raises clear safety risks for pedestrians and residents and compromises emergency access.

---

6. Lack of Supporting Infrastructure

There are growing concerns that local infrastructure is not keeping pace with the scale of development being proposed. Mosman currently operates with:

• A single fire station.
• Limited emergency services capacity.
• Narrow residential streets that restrict access for large fire vehicles.


A significant increase in population, combined with the introduction of 10‑storey buildings, raises practical questions about emergency response, evacuation, and service capacity.

---

7. Non‑Compliance and Misleading Claims

The proposal exceeds height controls and requires a Clause 4.6 variation, yet is described as “compliant.” A development that breaches fundamental controls should not be presented as compliant, and such framing undermines confidence in the assessment process.

---

8. Affordable Housing Design and “Poor Door” Concerns

The proposal includes 11 affordable housing units accessed separately from the laneway. This raises concerns about:

• A “poor door” arrangement that segregates residents.
• Whether the design supports inclusive, equitable housing outcomes.
• The long‑term integrity of the affordable housing component.


The design does not demonstrate best‑practice integration of affordable housing within the development.

---

Conclusion

For the reasons outlined above, the proposal is inconsistent with the planning controls, design principles, and strategic intent governing development in Mosman. I respectfully request that the Department / Council refuse the application or require substantial redesign to ensure:

• Compatibility with local character and heritage.
• Protection of the Scenic Protection Area.
• Safe and functional access arrangements.
• Genuine, integrated affordable housing outcomes.
• A scale of development that responds to the site rather than overwhelms it.

Thank you for considering this submission

As a resident of Mosman I am appalled that this current development proposal of a 10 storey building is being made in complete disregard for the Scenic Protection Area which was there to protect over development . The excessive height and bulk would completely dominate the low rise surrounding area and the 10 metre excavation could also inflict serious damage to neighbouring properties. If approved, it would also set a precedent for more of these large developments which will completely change the character of the foreshore area.

Supportive of increased density and affordability of housing close to town centres and transport. The affordable housing component needs to be linked to supporting those in front line positions such as teachers, police, emergency services, health care workers. These affordable homes need to be offered on an ongoing basis and without seperate property access. The proposal also needs to consider any heritage listing of the street . It will set a bad precedent should the street’s heritage status not be considered.

FORMAL OBJECTION: SSD-93020230 – 40-48 Redan Street, Mosman

I am writing to formally lodge my strongest objection to the State Significant Development application at 40-48 Redan Street, Mosman. This proposal represents an unacceptable breach of planning controls and a failure to protect the public interest.

My objection is based on the following critical grounds:

The "Affordability" Loophole and Luxury Subsidization: This proposal is a clear exploitation of a planning loophole. The developer is claiming a massive "height uplift" in exchange for a small number of "affordable" units that will remain out of reach for first-time buyers and key workers. It is a mockery of the housing crisis to allow a development to bypass height limits under the guise of affordability when it includes a penthouse with a guide price of $20 million. A scheme designed to help the vulnerable should not be used to facilitate record-breaking luxury real estate. Furthermore, with a 15-year sunset clause on the affordable units, the community is being asked to accept a permanent 35-metre scar on the landscape for a fleeting, temporary social benefit.

Excessive Scale and Visual Impact: At 12 storeys (35m), this building is six times the current 2-storey limit. The site sits within a Scenic Protection Area covering the harbour foreshore. It is telling that the developer's own assessment describes the visual impact as "severe to devastating." To approve a project where the proponent admits to such a catastrophic impact on the iconic Sydney Harbour skyline would be an unprecedented failure of the planning system.

Irreplaceable Loss of History: The proposal involves the demolition of five Federation-era homes, some over 100 years old. These buildings are a finite historical resource; once demolished, this history is lost forever and cannot be replaced. Destroying century-old craftsmanship for a short-term development is a cultural tragedy that ignores the long-term value of our built heritage.

Undermining the Heritage System: Allowing this development makes a complete mockery of the heritage process. Redan Street is a designated Heritage Road with a heritage-listed verge. Heritage listings are legal protections, not optional suggestions. If these protections can be dismissed so easily for developer profit, it signals that no heritage-listed site in New South Wales is truly safe.

Infrastructure and Traffic Failure: Redan Street is a narrow, low-capacity road already burdened by traffic and a lack of street parking. The area is poorly serviced by public transport. Adding 53 high-density dwellings will cause severe congestion and safety issues on a residential street that was never designed for this volume of traffic.

I urge the Department of Planning to do the right thing and uphold the existing local controls and refuse this application in its entirety. Furthermore, I believe there must be an urgent review of what constitutes "affordable housing" under current state policies. The current framework allows developers to take advantage of these incentives for their own gain without providing long-term, genuine affordability for the community. The planning system should serve the public, not provide a mechanism for bypassing local protections for luxury gain.

To: Mosman Council

Dear Councillors,

I am writing to formally object to the proposed development application for the above site.

Firstly, the proposal represents excessive height, bulk, and overdevelopment that is entirely inconsistent with the unique, low-rise village character of Mosman. A 10-storey building in what is a predominantly low-rise area is, quite simply, grossly out of place. The scale of the development fails to respect or respond to the surrounding heritage-listed properties and disregards the established streetscape that defines the charm and identity of our community.

Secondly, as a resident living approximately 50 metres from the proposed site, I am deeply concerned about the significant increase in traffic and parking congestion that will result if this application is approved. The addition of 53 apartment replacing just five existing family home will inevitably intensify local traffic, placing increased strain on already limited parking and raising serious safety concerns for both pedestrians and motorists.

Thirdly, the current infrastructure is inadequate to support a development of this scale. The proposal does not sufficiently address how essential services will operate in a constrained environment, particularly given the narrow laneway access. This raises critical concerns regarding waste collection, deliveries, and most importantly, access for emergency services. The introduction of a 10-storey building without corresponding infrastructure upgrades presents a clear and unacceptable safety risk.

Furthermore, the proposal appears to disregard the Scenic Protection Zone provisions that are intended to preserve the visual and environmental qualities of the area. The imposition of a large scale building would overshadow and dominate neighbouring homes, many of which are heritage properties, fundamentally altering the character and amenity of the locality.

Finally, this development appears to prioritise financial gain over thoughtful, context-sensitive planning. It does not demonstrate an understanding of, nor respect for, the quaint, traditional, and unique environment that makes Mosman so valued by its residents, and the broader community. Approving a development of this nature would set a concerning precedent for future overdevelopment in the area.

For these reasons, we strongly urge Council to reject this development application.

Thank you for considering our submission.

Yours sincerely,
Lauren and Gordon Clubb
6 Arbutus St Mosman