As a long standing Blue Mountains local, I wish to lodge a formal objection to the proposed mixed‑use development at 142–150 Narrow Neck Road, Katoomba. I consider the proposal to be inappropriate for a World Heritage site and incompatible with the environmental constraints of the Blue Mountains. I also believe that there are likely to be adverse impacts that have not been adequately addressed, such as increased traffic and inadequate evacuation paths in the event of a catastrophic bushfire.

My objections to the proposal are outlined below:

1. Excessive Height, Bulk and Scale Incompatible with the Local Character

The proposal of nine buildings up to 15.6 m high is double the current LEP height limit of 8 m. This scale is not characteristic of Katoomba’s R3 zones, which typically comprise townhouses and low‑rise dwellings, not urban apartment blocks. The ridgeline would also be permanently altered, creating significant, detrimental visual impact.

2. Significant Tree Removal and Loss of Biodiversity

Under the proposal, 134 of 206 trees would be cleared from the site, including 14 trees of high‑significance. This is significant clearing in an area mapped for biodiversity values under the NSW Biodiversity Values Map and would contribute to ecological degradation. The Blue Mountains is a World Heritage buffer zone, and cumulative clearing across the former golf course precinct is already significant.

3. Traffic and Access Impacts on Narrow Neck Road and Glencoe Road

The development proposes 316 car spaces and will generate hundreds of daily vehicle movements. Narrow Neck Road is a narrow, winding, shoulder‑less road with no footpaths and limited passing opportunities. To claim that impacts are "very low" (Traffic Impact Assessment) overlooks the reality of the situation, whereby pedestrian infrastructure is inadequate, topography is steep and the road narrow. It also fails to take into consideration the increased risks in the event of a catastrophic bushfire. Increased traffic and inadequate infrastructure combine to create potential loss of life in a bushfire zone due to inadequate evacuation routes.

4. Overdevelopment of a Sensitive Ridgeline Adjacent to a World Heritage Area

The site is within the Protected Area – Escarpment under the Blue Mountains LEP. The purpose of this clause is to minimise visual intrusion when viewed from the National Park. The EIS acknowledges: “The highest value components of the views are retained above and behind existing trees…” (Appendix AL) This is misleading. The proposal relies on existing vegetation to screen a permanent built form, yet simultaneously removes 134 trees.

5. Insufficient Justification for Rezoning and Height/FSR Increases

Potential rezoning for the purpose of this proposal appears developer-driven rather than being strategically justified. The Blue Mountains are not identified as a growth area under State planning strategies and the Housing Delivery Authority pathway should
not override the need for site suitability. The current housing crisis cannot be used to justify this proposal. This proposal is not offering affordable housing, thus does not address the fact that housing remains out of reach for so many Australian families.

6. Construction Impacts on a Constrained Site

The EIS proposes:
- Five separate basement excavations
- Extensive rock sawing and hammering
- Heavy vehicle movements on narrow roads
The Noise and Vibration Report anticipates: “Highly concentrated and loud activities” requiring “one‑hour respite periods.” (Section 7.10). This indicates significant construction impacts over a prolonged period, likely several years.

Conclusion

I strongly believe the proposed development is excessive, inappropriate, and environmentally unsustainable for this sensitive site. It is inconsistent with the environmental constraints of the Blue Mountains, the character of Katoomba, and the expectations of the local community. It also presents ecological and safety challenges that have been inadequately addressed. This proposal only seeks to benefit developers and does not consider the residents of the Blue Mountains or the fragile UNESCO world heritage site.

I am a resident of Katoomba in the Blue Mountains, and I write to formally object to the above-referenced State Significant Development application. The proposal seeks approval for nine buildings of up to five storeys comprising 218 dwellings, 52 serviced apartments, a restaurant and an art gallery on a 1.68 hectare site adjacent to Narrow Neck Road and Cliff Drive.
I object to this proposal on the following grounds:

1. Scale and Bulk of Development – Gross Overdevelopment of the Site
The proposed development is entirely out of scale with the established character of Katoomba and the surrounding Blue Mountains environment. Nine buildings of up to five storeys, accommodating in excess of 260 dwellings and serviced apartments on a single 1.68 hectare site, represents a density that is unprecedented for this area and wholly inconsistent with the Blue Mountains Local Environmental Plan (LEP).

• The proposal dramatically exceeds the height and density limits set out in the Blue Mountains LEP and Development Control Plan (DCP). It is only able to proceed at this scale because it has been declared State Significant Development under the Housing Delivery Authority (HDA), which effectively bypasses local planning controls.
• The bulk of nine multi-storey buildings would be visually dominant and wholly inconsistent with the low-scale residential and natural character of the Narrow Neck precinct, including its proximity to Cliff Drive and the adjoining escarpment landscape.
• Blue Mountains City Council – the elected body responsible for local planning – has itself described the proposal as 'grossly inappropriate' and an 'overdevelopment'. The Council has formally resolved to oppose the development. This strong position from the local authority must be given significant weight in the assessment.
• The development includes only 15% affordable housing. For a proposal of this scale and one that overrides local planning protections, this proportion is inadequate to justify the exceptional approval pathway being used.

2. Environmental Impact – Bushfire Risk and World Heritage Setting
The site is located in one of the most environmentally sensitive areas in Australia, within and immediately adjacent to the Greater Blue Mountains World Heritage Area. The environmental impacts of this proposal are severe and, in my view, have not been adequately addressed.
• Bushfire risk: The site is surrounded by bushfire-prone land at the top of the escarpment. Fires in 2014 destroyed a home less than one kilometre from this site. During the catastrophic 2019–20 fire season, Cliff Drive – which is adjacent to the development – was repeatedly closed due to fire threats. Adding hundreds of residents to this location significantly increases the risk to human life.
• Evacuation constraints: There is only a single two-lane road providing access to the site. In a bushfire emergency, orderly evacuation of 270+ dwellings plus any commercial visitors would be severely constrained and potentially impossible. This is an unacceptable risk.
• World Heritage values: The Blue Mountains World Heritage Area is of global significance. Any development that degrades its visual integrity, natural buffers or ecological connectivity is contrary to Australia's obligations under the World Heritage Convention. The proposed scale and built form would be visible from heritage-significant viewpoints and the escarpment.
• Vegetation clearing and habitat: The construction of nine large buildings on this site will necessitate significant removal of native vegetation, impacting local fauna habitat including threatened species known to inhabit the Blue Mountains.
• Solar access: As has been publicly reported, the design of the buildings means some future residents would receive no direct sunlight at all – a failure of basic amenity standards and indicative of the overdense nature of the proposal.

3. Inadequate Infrastructure to Support Proposed Density
The existing infrastructure serving the Narrow Neck Road precinct is not designed to support a development of this density. No evidence has been provided that essential services and infrastructure have the capacity to accommodate hundreds of additional residents.
• Road network: Narrow Neck Road is a local street that was never designed to carry the volume of traffic generated by 270+ dwellings plus commercial uses. Traffic modelling must account for peak demand, construction traffic, emergency access and the interaction with the already constrained Cliff Drive.
• Water, sewerage and stormwater: The capacity of reticulated water and sewerage infrastructure to service this development at its proposed scale must be independently verified. Stormwater runoff from nine large buildings and associated car parking and impervious surfaces will significantly increase peak flows, with potential impacts on the escarpment below.
• Public transport: Katoomba's public transport network, while adequate for existing residential densities, would require substantial augmentation to serve a development of this size. No commitments to public transport improvements appear to have been made.
• Community services and facilities: Schools, medical facilities, emergency services and community infrastructure in Katoomba are scaled to the existing population. A development adding hundreds of residents in a concentrated location requires assessment of cumulative demands on these services.
• Precedent: Approval of this development under the HDA pathway would signal that local planning controls in the Blue Mountains can be overridden at will. This risks a wave of further inappropriate high-density proposals across the Mountains, further straining infrastructure that was never designed for such densities.

4. Process Concerns – Community Consultation and HDA Pathway
• The applicant has indicated that community consultation was undertaken with nearby residents in late 2025. I was not notified of this consultation, nor were many other local residents I am aware of. The absence of meaningful early consultation undermines community confidence in the process.
• The use of the Housing Delivery Authority's streamlined pathway to declare this proposal State Significant Development is highly inappropriate for an environmentally sensitive area such as the Blue Mountains. The HDA process is designed for housing delivery in contexts where local planning controls represent genuine obstacles to appropriate development – not as a mechanism to override carefully considered protections for a World Heritage landscape.
• Blue Mountains City Council has been given no formal decision-making role despite being the elected body responsible for the area. This disenfranchisement of local government and the local community in decisions of such significance is contrary to principles of good planning governance.

Having recently built a new house in South Katoomba and having tolerated an incredibly arduous process to get a DA approved including severe restrictions on height, colour, house footprint and vegetation I am extremely surprised at how easily these (mostly understandable) considerations can be overridden. I now worry about the precedent this will set and what this means for this area.

I strongly oppose this development in its current form. I urge the Department of Planning, Housing and Infrastructure to refuse this application on the basis that it represents a gross overdevelopment of this site, poses unacceptable risks to life due to bushfire and inadequate evacuation capacity, is incompatible with the World Heritage values of the Blue Mountains, and cannot be supported by existing local infrastructure.

Should the Department consider approving any development on this site, I request that approval only be granted for a significantly reduced proposal that:
• Complies with the height and density limits of the Blue Mountains LEP and DCP;
• Demonstrates adequate bushfire evacuation capacity with independent expert certification;
• Is supported by a comprehensive infrastructure capacity assessment covering roads, water, sewerage, stormwater, public transport and community services;
• Delivers a substantially higher proportion of genuinely affordable housing; and
• Is developed in genuine consultation with the local community and Blue Mountains City Council.

I strongly object to the proposed development at Narrow Neck. As a past member of the now closed Katoomba Golf Club the proposed development is ugly, does not suit the local environment, will create environmental issues and is part of Warragamba Catchment area. It does not address the affordable housing issue. It is also outside the governments criteria of being within close proximity to a major transport hub.

Besides the high fire risk of the proposed location during fire season, the area also contains unique flora and fauna which relies on the current water table. This proposal looks like an attempt to not only bring the over development that is choking the Penrith region into a world heritage national park that contains significant , which cannot realistically support such radical development but also an attempt from state government to amend Blue Mountains City Council policies which have been created to protect the blue mountains region from this kind of over development as the uniqueness of the mountains was identified and deemed worthy of preservation. The local infrastructure can barely handle the thousands of tourists that fill Katoomba on a daily basis, and Narrow Neck Road and surrounding roads could not smoothly handle the traffic flow and wear this built would create during construction and long after occupation. There are better uses for the site than a concrete jungle which would be visible from most of Katoomba. State government shouldn't have any say relating to developments in local council regions, I am completely against this monstrous proposal in such a delicate region which I was fortunate to call home through my early life.

Please find attached my objections to the project but also my comments on failure to consider whether there is any sewerage system capacity.

I am against this development proposal. It is a totally inappropriate overdevelopment of this site. It has not given appropriate consideration to:
1. BMCC required LEP and DCP planning controls;
2. environmental protections;
3. safety of residents; and
4. community impacts.

Problems with it are:
- The vulgarly large scale and height inappropriate for this area and not in accordance with BMCC planning regulations;
- The bushfire risk. It was a bushfire zone area until just after the development application was lodged;
- It’s significant and very detrimental visual impact on the escarpment and this glorious World Heritage landscape;
- Stress on local infrastructure;
- Excessive traffic on local roads from the volume of vehicles it will bring, and no, trashing the surroundings with bigger roads is not acceptable to improve the application; and
- Detrimental environmental impacts on the Katoomba Creek catchment area.

Please see attachment.