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.

Submission Opposing Proposed Development at 40–48 Redan Street, Mosman NSW

To the Department of Planning,

I wish to register my formal objection to the proposed redevelopment of 40–48 Redan Street, Mosman. As a long-standing resident and homeowner in the area, I am extremely concerned about the lasting consequences this project would have on the local environment, heritage streetscape, and overall quality of life within our community.

1. Overextension of Planning Controls
The scale of the proposal is made possible only through the combined use of multiple planning concessions. These include provisions under the Low and Mid-Rise Housing Policy, a 30% height increase linked to the NSW Infill Affordable Housing scheme, and an additional Clause 4.6 variation—all within the State Significant Development framework.

Even after applying these incentives, the development still requires further variation to exceed prescribed height limits. This indicates that the proposal pushes beyond what the planning system reasonably anticipates, representing an excessive and inappropriate use of discretionary planning mechanisms.

2. Limited and Questionable Affordable Housing Outcomes
Although the project is presented as delivering affordable housing, the reality appears quite different. Of the 53 proposed apartments, the majority are large, high-end residences ranging from 129 to 321 square metres, including premium penthouse offerings with expansive views toward Balmoral.

Only 11 units are earmarked as “affordable,” and these come with notable limitations:

Availability is capped at 15 years
Placement is on lower floors
Some are accessed via a rear laneway

There is also a lack of transparency around rental pricing and eligibility criteria. Given the already high levels of rental stress among very low-income residents in Mosman, it is difficult to see how these units would meaningfully address housing need. The classification of this project as “affordable housing” is therefore highly questionable. The developer is taking advantage of the SSD to completely bypass usual development regulation to build a large luxury apartment building. This is not consistent with the Government's intentions.

3. Irreversible Heritage Impacts
The development would require the removal of five Federation-era dwellings dating back to the early 1900s. These homes contribute significantly to the established character of Redan Street and the broader heritage context of the area.

Replacing them with a 12-storey structure adjacent to heritage-listed properties would fundamentally alter the streetscape and diminish the historic setting. Such changes are permanent and cannot be undone once implemented.

4. Traffic and Parking Pressures
The proposed provision of 106 parking spaces for 53 large apartments appears inadequate, particularly given the expected profile of residents in high-end, multi-bedroom dwellings. Likely consequences include increased on-street parking demand, greater congestion, and intensified vehicle movement concentrated through a single access point on a quiet residential street.

These impacts would significantly affect safety and day-to-day amenity for existing residents.

5. Absence of Local Decision-Making
As a State Significant Development, the proposal bypasses Mosman Council and excludes local decision-making processes. There is no council determination, no local planning panel involvement, and limited opportunity for meaningful community representation.

Developments of this scale should not proceed without proper input from locally elected bodies who understand and represent the interests of the community.

6. Inadequate Community Engagement
The consultation process described by the developer has been insufficient. Many nearby residents, myself included, did not receive notification materials that were claimed to have been widely distributed.

Reported participation levels—just 43 survey responses and 6 attendees across two focus groups—do not reflect genuine or broad-based community engagement. Feedback from long-term residents indicates strong opposition that has not been properly captured.

7. Disproportionate Community Impact
The planning rationale relies on a trade-off: a 30% increase in building height in exchange for 15% of units being designated as affordable housing for a limited 15-year period. In this instance, that equates to just 11 units providing temporary benefit, while the impacts of a 12-storey development would be permanent.

This imbalance raises serious concerns about whether the proposal delivers a fair or appropriate outcome for the community.

Conclusion
In its current form, the proposal represents an overdevelopment of the site that depends on stretching planning controls beyond their intended application. It delivers minimal long-term public benefit while imposing significant and lasting impacts on the character, heritage, and livability of the area.

For these reasons, I strongly oppose the development and respectfully request that the Department of Planning decline the application.

This development is deceptively and greedily using the provision of the affordable housing law to profit from luxury water-view apartments, at the impact of the local community. For such a massive building, it's only providing 11 "affordable" homes, shoved down the back. There are clearly better places around Mosman for affordable housing, mainly being up near Bridgepoint and along Military Rd towards Cremorne, where apartments would be level with nearby shopping centres.

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

As someone who previously lived at 71 Muston St, Mosman and still has family there, I write to lodge a formal objection to the proposed residential development at 40-48 Redan Street, Mosman. This application would introduce a fundamentally incompatible development into a well-established, low-rise neighbourhood. The ten-storey building proposed here will irreversibly alter the streetscape that defines this part of Mosman, and the concerns outlined below demonstrate that the application fails to respond appropriately to its context or the constraints of the site.

The most immediate concern is how this development will reshape our street. A ten-storey building in a suburb characterised by two to three storey homes and low-rise apartment blocks represents a dramatic and unwelcome departure from the established character. This is not a marginal exceedance; it is a wholesale change in scale. The proposal breaches the height controls set out in Mosman Local Environmental Plan 2012 Clause 4.3 and requires a Clause 4.6 variation, yet the application materials describe the development as compliant. This framing is misleading. A development that fundamentally breaches the height standards that shape our neighbourhood should be honestly presented as such. The floor space ratio controls in Clause 4.4 are similarly exceeded. These controls exist for good reason — to maintain the character and livability of residential areas. When a development breaches them, that breach should be transparent and justified, not obscured.

The site itself presents significant engineering challenges that the proposal does not adequately address. The development requires excavation of up to 10 metres into sandstone, extending to site boundaries. This is not a minor engineering matter. Deep excavation of this scale, particularly where it reaches neighbouring properties, creates real risks of ground movement, vibration, and structural damage. The approach here appears to be one where the building is being engineered to fit the site, rather than the building responding respectfully to the site's constraints. This reversal of normal design priorities raises serious concerns about whether adequate protection has been afforded to neighbouring properties during the construction phase and beyond.

Access and traffic safety must also weigh heavily in this assessment. Redan Lane, which is to serve as the primary access for this development, is only a little over 4 metres wide, has no footpaths, and was clearly not designed to accommodate the increased service and waste vehicle activity that a ten-storey residential building would generate. The introduction of larger vehicles into such a constrained space creates genuine safety hazards. This is not a theoretical concern — it is a practical reality that will affect daily life on our street. The Department's guidelines on traffic and access, and the public interest considerations under section 4.15(1)(e) of the Environmental Planning and Assessment Act 1979, require careful scrutiny of these arrangements.

The affordable housing component, while welcome in principle, raises design concerns that cannot be overlooked. The proposal includes 11 affordable housing units with separate access from the laneway, creating what amounts to a "poor door" arrangement. This design approach undermines inclusive housing principles and effectively creates a second-class entry for residents in affordable units. The State Environmental Policy (Housing) 2021 supports affordable housing, but not at the cost of inclusive and equitable design. Affordable housing should be integrated into the development in a way that treats all residents with equal dignity and access.

For these reasons, I urge the Department to refuse this application or require substantial amendment. The proposal is incompatible with the neighbourhood's character, presents unresolved engineering and safety risks, and fails to deliver genuinely inclusive affordable housing. Mosman's appeal as a residential suburb depends on maintaining appropriate scale and character. This development threatens both.

Yours sincerely,
Ben Olesnicky

My wife Judy and I live at 2 Moruben Road, Mosman - a heritage-listed stone residence known locally as the Tower House or Castle — and have done so for many years. We are part of the same Federation-era precinct that this development would permanently and irreversibly overwhelm. We are not opposed to development. We are opposed to the exploitation of planning provisions designed for a different purpose to justify a luxury tower in a heritage streetscape.
What is proposed at 40–48 Redan Street is, in my assessment, one of the most structurally opportunistic development applications I have encountered. The applicant has pulled every available lever in the State planning system simultaneously — the Low and Mid-Rise Housing SEPP, a 30% affordable housing height bonus, a Clause 4.6 variation, and the SSD pathway — to extract a building height five times what the Mosman LEP permits. The most telling detail is that a Clause 4.6 variation is still required even after all of those concessions have been applied. This application has exhausted everything the planning system offers and then asked for more.
The affordable housing justification does not bear scrutiny. Eleven units out of 53 - 8 of them bedsits tucked along Redan Lane, accessed through a segregated 'poor door' entrance separate from the market building, reverting to full market housing after 15 years. The community is being asked to accept the permanent destruction of a significant heritage precinct in exchange for that. It is not a reasonable trade-off.
The impacts documented in my attached objection are severe and permanent: irreversible damage to one of Mosman's most intact Federation precincts; conflict with the Scenic Protection Area; elimination of views to Manly, North Head, South Head and Middle Harbour; near full-day overshadowing for Redan Lane on 21 June; permanent loss of privacy through close-range elevated overlooking; a canyon-effect acoustic environment along Redan Lane; and structural traffic overflow onto roads not built for a 53-apartment building. None of these impacts can be conditioned away. They are inherent in the scale of the building.
The Panel is not required to approve everything the planning framework technically permits. It is required to assess the public interest. This proposal does not serve it, and I urge the Panel to refuse it.