To whom it may concern,
I’m writing to object strongly to the proposed development at 40-48 Redan Street. I am utterly incredulous that it could even be considered.

I live on Muston St and my house backs onto Redan Lane which we use to access our garage. Redan Lane is already a nightmare. Yesterday it took me 10 minutes to drive from one end to the other. The lane is so narrow that I often can’t get past if someone has parked in the lane so you need to (hopefully) find the owner of the car to ask they move it. (Incidentally last year my husband requested the council erect no parking signs near our driveway, but all we have received is acknowledgement of our email). It is obviously worse on bin collection days. Also, as the lane is two- way, if a car is coming in the other direction, one has to reverse to the end or try to back into a very tight driveway. This usually requires a six point turn at least. Hence the 10 minute trip. Yet making the lane one way would not work. It would force traffic to go down Muston St which would become an even busier rat run then it is presently. It is already busy enough trying to turn in or out of the lane from Raglan St in summer with cars coming up from Balmoral. And this development would add another 106 cars using the lane! Madness. It will not work. There is also a safety issue. I have toddler grandchildren that I need to leave in my car while I request people move their car. The lack of footpath in a lane with so much traffic is dangerous to adults, but especially children.

Also, the scale and height are completely out of step with what anyone would reasonably expect in a heritage-listed street. There’s no real attempt to design something that fits with the existing homes or the character of the area, which has developed over many years. If this goes ahead, it will permanently alter the look and feel of the whole area.

The claims around “affordable housing” are a joke. Since when are multimillion dollar apartments affordable? The only winners will be the developers. High rise buildings are necessary, but they belong on arterial roads, such as Military Road, not suburban streets.
Finally, the fact that developments of this size and scale are now being fast-tracked is a real red flag. Something so important should not be rushed.

Please use common sense and reject this outrageous proposal.

This project is totally out of context with surrounding houses. Redan Street is very narrow, always full of cars so the impact will be severe. There is almost no green space within the development so the atmosphere will be harsh within and without the building.
Residents will be reliant on existing open space for their recreation. To my mind, the greatest impact is the size and clash with the existing low level housing. The design has no sympathy with the area at all.

28 March 2026

Edwina Ross
Senior Planning Officer
Department of Planning, Housing and Infrastructure
[email protected]

Dear Ms. Ross,

Objection to Development Application SSD-93020230 at 40-48 Redan Street, Mosman

I write to lodge a formal objection to the proposed residential development at 40-48 Redan Street, Mosman NSW 2088 (SSD-93020230).

The proposal includes 11 affordable housing units, which are located with separate access from Redan Lane. This arrangement raises significant concerns about inclusive housing design. The State Environmental Planning Policy (Housing) 2021 and contemporary planning principles for affordable housing require that such accommodation be genuinely integrated within developments, not segregated or accessed through secondary routes. A "poor door" arrangement — where affordable housing residents access their homes via a laneway rather than the primary entrance — undermines the objective of inclusive housing and creates a two-tier living environment. Affordable housing should be indistinguishable in quality, amenity and accessibility from market-rate housing within the same development. The proposed design fails this fundamental test and should be rejected unless substantially redesigned to provide equal access, identical amenities, and genuine integration of all residents within the building.

The proposal seeks approval for a 10-storey building on this site. This height is manifestly excessive and incompatible with the surrounding context. Mosman LEP 2012, Clause 4.3, establishes height controls that reflect the low-rise character of the locality. The site adjoins heritage listed properties at 36 and 38 Redan Street, which are protected under Mosman LEP 2012, Clause 5.10. A 10-storey structure would overwhelm these heritage items, disrupt their visual setting, and erase the existing character of Redan Street. The applicant seeks to vary the height control under Clause 4.6, yet the development is described as "compliant". A proposal that breaches fundamental height controls and requires variation should not be presented as meeting the planning framework. The visual dominance of a 10-storey building in this heritage precinct is incompatible with the objectives of the Heritage provisions and the character protection objectives of Mosman LEP 2012.

The site is also affected by a Scenic Protection Area, governed by Mosman LEP 2012, Clause 6.5. The planning objectives for this area include limiting visual intrusion and protecting landscape character. A 10-storey building is difficult to reconcile with these objectives. The height and bulk of the proposal would create a visual intrusion inconsistent with the scenic protection framework and would fundamentally alter the character of this part of Redan Street.

The development proposes excavation of up to 10 metres into sandstone, extending to site boundaries. This deep excavation creates real and significant risks of ground movement, vibration and structural damage to neighbouring properties. The approach taken in this proposal is to engineer the site to accommodate the building, rather than having the building respond to the site's geological constraints. This reversal of ordinary design priorities raises serious concerns about the suitability of the site for development of this scale, as required by section 4.15(1)(c) of the Environmental Planning and Assessment Act 1979. The risks to neighbouring properties and the structural integrity of the surrounding area have not been adequately addressed.

Access to the site is proposed via Redan Lane, which is only slightly over 4 metres wide, has no footpaths, and is not designed for the volume and type of vehicle traffic that would be generated by a 10-storey residential building. Service vehicles, waste collection trucks, and emergency vehicles would be required to navigate this constrained space on a daily basis. This raises clear safety and access concerns, particularly for emergency response and evacuation. The use of Redan Lane for this purpose is inconsistent with Roads and Maritime Services guidelines and fails to address the public interest in safe and efficient access, as required by section 4.15(1)(e) of the EP&A Act.

This proposal will destroy the heritage character of this area of Mosman. The traffic situation in this locality is already seriously congested, and this development would create traffic chaos throughout the Mosman junction area during and after construction. The introduction of construction activity and permanent traffic generation in an already constrained area raises dangerous situations that cannot be mitigated.

There are growing concerns that infrastructure is not keeping pace with the scale of development being proposed in Mosman. The suburb currently operates with a single fire station and limited emergency services capacity. A significant increase in population combined with the introduction of 10-storey buildings raises practical questions about emergency response times, access for large fire vehicles, and overall service capacity in narrow residential streets. The suitability of the site for a development of this scale must be considered in the context of existing infrastructure constraints, as required by sections 4.15(1)(c) and 4.15(1)(e) of the EP&A Act.

For all these reasons, the application should be refused. The proposal fails to comply with applicable height and floor space ratio controls, is incompatible with the heritage character of the area, raises unresolved risks to neighbouring properties, creates unsafe access conditions, and is not supported by adequate infrastructure capacity. The affordable housing component, while potentially beneficial in principle, is undermined by poor design integration and cannot justify approval of a fundamentally unsuitable development.

I respectfully request that the application be refused, or at minimum, that substantial amendments be required before any approval is considered.

Yours faithfully,

[Your Name]
[Your Address]

Submission

I object to the Proposal.

This proposal takes unreasonable advantage of Government's measures to increase affordable housing for new South Wales residents. It seeks to create a windfall gain of up to $205m for a syndicate led by one of Australia's richest men, providing them with close to a possible 85% simple annual return on their investment during the life of the project.

In addition, the syndicate will also enjoy tax concessions in relation to capital works concessions, Build-to-Rent incentives, GST benefits and credits, and other tax concessions.

This windfall profit is made even after the project is fully compensated for building 11 affordable housing units, with a total of 22 bedrooms. They will all sell at a profit to the developer.

This windfall gain comes at considerable cost to the surrounding community and to the broader public. (This cost has been outlined at length in other submissions.) This cost clearly outweighs the windfall gains sought.

It also comes at considerable economic cost to surrounding homeowners, whose homes will be reduced in value. This reduction in value will lead to reduced Council rates revenues and reduced Stamp Duties for the State Government.

The Massive gain sought in this proposal is against the Government's policy intent and will bring the program into disrepute

The Government's policy intention was to compensate developers for including affordable housing in new developments and to encourage them to do so. This means meeting the usual returns on a development project and providing a reasonable "bonus" on top of them. For large residential projects a "good" Simple Project Margin is usually considered to be 15 - 20%. A good bonus on top of this might be an additional 5%, a total of 20-25%. This proposal would deliver a Simple Project Margin of up to 77%. This is way beyond what the community would accept as a reasonable incentive to a developer. It would be completely inconsistent with the Government's intent. It would be bad policy to allow the proposal to proceed.

The gain for the community for this excessive compensation is 11 affordable two-bedroom apartments for 15 years. The construction cost of these apartments is probably a few million dollars of the $265m likely to be spent on the project and they are all likely to be sold at a good profit by the developer (probably selling for more than $12m in total).

Against this gain, the cost to the community and to the broader public is large. This has been outlined in many other submissions. The damage will be highly visible and lasting.

If it is allowed to proceed, this proposal will likely bring the Government's program into disrepute. The building, which will be clearly visible from Balmoral and beyond, will be a symbol of a program which enriched developers in Sydney's wealthiest suburbs while doing very little for those who need affordable housing.

Mosman should have a good supply of affordable housing. There will be many good projects that come forward to this end that offer much better value to the community and the Government. This is not one of them. The 400 square metre penthouse at the top of this tower will probably be put on the market for $40-50 million. On the ground floor, facing the back lane, will be eight small apartments intended for rent by people on modest wages. While this may appeal to those with a bleak sense of humour, it is not a sensible way to organise a building community.


Why is the windfall profit so large?

The windfall profit is large because of the location of the proposal and the demand for high end apartments for a wealthy retiring population across the lower and upper North Shore. Based on nearby precedents, the two penthouse apartments will probably be brought to market at between $30 - 50m each. The apartments below them are likely to command $8 -15m each. The apartments on the ground floor will probably each command $5m or more. The shortage of high value apartments has meant that most new developments have found buyers competing strongly for available apartments.

Because of the high value of new up-scale apartments, the total value of apartments in the proposed development is probably between $395-470m. Against that, the cost of the project is probably around $265 m (land $100m, construction $106m) and the quality of the location means that investors will be able to fund the project with 70% debt or more, meaning their own contribution would be around $80m.

This delivers an extraordinary return. For an $80m outlay, the simple profit is likely to be as much as $205m. This represents a simple annual return on equity of 85%, a simple project margin of 77% (against 15-20% for a typical "good" deal), and a simple IRR of around 37% (against a "good" IRR in Private Equity-backed projects of 20%).

The the two attached work sheets out line the calculations behind these returns. They are drawn from what is publicly available, together with the miracle of Google's AI.


What should the Government do?

The Government should use its discretion to reject the proposal.

The size of the windfall profit proposed by the applicants is way out of line with the intent of the Government's policy. It offers a technical compliance with affordable housing rules while placing such apartments at the back of the base of one of the most expensive and luxurious housing blocks in Sydney.

It will bring the Government's policy and program into disrepute. The program is meant to substantially increase affordable housing, not subsidise top-end property investment. The program should bring gains to the community that justify the costs and losses inevitably involved. The costs here are large, well in excess of the gains offered.

Please reject the proposal.




Attachment 1: Economics and Investment of proposed 40 -48 Redan St Development.

Attachment 2: Total value of proposed apartment development

I am Judy Hodgson, owner and continuous resident of 2 Moruben Road, Mosman - the heritage-listed stone residence known locally as the Tower House or Castle, where I have lived since 1970. Over more than fifty-five years I have been the custodian of this property and a witness to the careful stewardship that has preserved the character of the Redan Street precinct across many decades of development pressure. It is from that position, as a resident of over half a century within the same heritage landscape that this proposal would permanently alter, that I submit this objection.

What is proposed at 40–48 Redan Street is not development. It is the systematic exploitation of every available State planning mechanism - the Low and Mid-Rise Housing SEPP, a 30% affordable housing height bonus, a Clause 4.6 variation and the SSD pathway, stacked simultaneously to extract a building height five times what the Mosman LEP permits. That a Clause 4.6 variation is still required after all of those concessions have been exhausted tells the Panel everything it needs to know about this application.

The affordable housing offered in return does not justify what is being destroyed. Eleven units - eight of them bedsits at the rear of the site, entered through a back-lane 'poor door' segregated from the market building, available for only 15 years before reverting to market housing - are being traded against the permanent and irreversible transformation of one of Mosman's most intact Federation precincts. I have watched this precinct endure for over fifty years. The Panel should not allow it to be lost in a single consent decision.

The impacts documented in my attached objection are severe and permanent. On 21 June, properties in Redan Lane will experience total solar loss from early morning — not morning shadow, but near-complete loss of direct sunlight for the entire day. Views to Manly, North Head, South Head and Middle Harbour will be eliminated. Privacy will be permanently destroyed by close-range elevated overlooking that no screen or setback can remedy. And Redan Street will be effectively closed to its residents for years during a construction program nine times the scale of the last development on this street.

My own property - the Tower House - is part of the same heritage landscape this proposal would overwhelm. What is done to the setting of one heritage place affects the integrity of the whole. The Panel's obligation under s.4.15 of the Environmental Planning and Assessment Act 1979 is to assess the public interest - not merely technical compliance. This proposal does not serve it, and I urge the Panel to refuse it. My full written objection is attached.

Dear Assessor, Please can you personally attend the proposed site for this development. I hope it will be self evident to you that building a 10 storey building in this quiet residential street is inappropriate. There is nothing of this scale in the area and it will have a grave negative impact on the existing residents. You will note that the Development is intended to maximise the views of the property and hence the profit of the developer to the detriment of everyone who currently lives there. Thank you for your consideration.