I lodge a formal objection to the above State Significant Development (SSD) application.

This objection is made on the basis that the proposal fails to satisfy key provisions of the relevant statutory and strategic planning framework, results in unacceptable environmental and amenity impacts.
1. Inconsistency with Statutory Planning Controls
In particular:
The height, bulk and scale materially exceed what is contemplated for the locality
The proposal fails to respond appropriately to topography, setbacks, and landscaped character
The built form is not compatible with the existing and desired future character
2. Unacceptable Bulk, Scale and Built Form
The proposal constitutes an overdevelopment of the site, evidenced by:
Excessive floor space and building envelope
Inadequate setbacks and separation distances
This results in a development that is visually dominant and inconsistent with the established low-density, landscaped character of Mosman.
3. Non-Compliance with Design Quality Principles
The proposal does not adequately meet the NSW Government’s design quality principles, particularly:
Context and neighbourhood character
Built form and scale
Landscape integration
Amenity
The architectural response appears driven by yield rather than site constraints or contextual integration.
4. Adverse Amenity Impacts
The development will result in significant and unreasonable impacts on surrounding properties
5. Traffic, Access and Parking Impacts
The proposal will generate additional traffic movements that are incompatible with the capacity and function of the surrounding local road network. Mosman is already suffering from significant traffic congestion.
Concerns include:
Increased congestion on Redan Street and surrounding roads
Adverse impacts on pedestrian safety and local amenity
Parking limitations

The traffic assessment does not appear to adequately address cumulative or peak-period impacts.

6. Environmental and Landscape Impacts
Loss or degradation of mature vegetation and tree canopy
Insufficient deep soil zones to support meaningful landscaping
Erosion of the green, garden suburb character that defines Mosman

This is contrary to both local planning objectives and broader environmental sustainability principles.

7. Precedent and Cumulative Impact
Approval of this proposal would set a harmful planning precedent, effectively:
Undermining the integrity of local planning controls
Encouraging similar over-scaled developments
Leading to incremental but irreversible change to neighbourhood character.

In addition, I understand that 13 of the lower income apartments will be "bedsits" not very suitable for living in!
I request that the application be refused.

Yours sincerely, Caroline McCarroll

The scale of this development is inappropriate for the area. It is quite clear that the developer is using rules which are not meant in the spirit with which they were enacted. for example, it appears an inappropriate use of the ‘affordable housing’ exception.

Whilst I support increased density in the area, the scale of the buildings should be appropriate to their surroundings. There are larger/taller buildings up at Spit/Military Rd, close to transport, and that may be an area where it would be more appropriate.

The scale of this building is ridiculous for where it is proposed to be placed.

Submission opposing SSD-93020230
Reference: SSD-93020230

I write to formally oppose the above State Significant Development application and ask the Department to refuse it.
I am a new home buyer in this area, recently committed to building a life and raising a young family here. I purchased in this neighbourhood precisely because of its established character, its liveability, and the planning framework that protects both. This proposal threatens all three — and it does so while dressed in the language of affordable housing, a claim that does not survive scrutiny.
Affordable housing framing does not hold
The apartments proposed in this development are understood to be selling for upward of $3 million each. This is not affordable housing by any accepted definition. Invoking the State's infill affordable housing incentives to justify a 30% height uplift — and then still requiring a Clause 4.6 variation on top of that — makes the intent plain. Every available concession has been stacked, and still the proposal does not fit within the planning envelope. That is not a demonstration of good planning. It is the clearest possible signal that this building does not belong on this site.
For a new family entering the housing market, this is not an abstract concern. The suggestion that a building of this scale, sold at these price points, represents a solution to housing affordability is, frankly, insulting — and it should not be accepted as a planning justification.
An unlawful accumulation of concessions
The proposal layers infill affordable housing incentives, a Clause 4.6 variation, and the SSD pathway simultaneously. The Land and Environment Court has confirmed that Clause 4.6 variations demand strong, site-specific environmental planning grounds — not generalised public benefit arguments: Initial Action Pty Ltd v Woollahra Council [2018] NSWLEC 118; Four2Five Pty Ltd v Ashfield Council [2015] NSWLEC 90. Those tests are not met here. Stacking five planning concessions to construct what is, by any measure, a 12-storey building in an area where the Department's own materials characterise mid-rise as 2–6 storeys goes well beyond policy intent. A 12-storey tower is not mid-rise development. It is not low-rise development. Calling it either does not make it so.
Visual and heritage impacts
The EIS itself acknowledges "severe to devastating" visual impacts. That language does not appear in documents that support approval — it appears in documents that justify refusal. The elevated mid-slope position of this site compounds these impacts significantly, with cumulative privacy consequences for surrounding properties that the EIS has not adequately assessed. The proposal is also incompatible with the heritage streetscape, and the developer's own characterisation of the site as a ridge line has been misapplied to inflate permissible height calculations.
Traffic and parking will permanently damage the street
106 car spaces for 53 apartments — 42 of which are luxury three- and four-bedroom dwellings — is not adequate for the demographics this development will attract. The overflow onto Redan Street and surrounding roads will be permanent and structural.
This is not speculation. A recent development on Redan Street — just six units — consumed all available on-street parking from 7am to 5pm, six days a week, for eighteen months of construction. This proposal is nearly nine times larger. The construction phase alone will effectively close the street to residents for years. The permanent traffic impact will be irreversible. Construction access via the single driveway will repeatedly block a narrow local road that has no alternative route for affected residents.
A flawed consultation process
The developer's own Appendix E shows that residents on Redan Street were explicitly named as having been consulted — yet they were not reached. Mosman Council's detailed and considered objections have been dismissed with boilerplate language noting they were "considered and responded to." This is not genuine engagement. It is the appearance of process without the substance.


I ask the Department to refuse this application. It fails on planning grounds — the stacking of concessions, the inadequate justification for the Clause 4.6 variation, the acknowledged visual impact, the unassessed cumulative privacy harm, the heritage incompatibility, the traffic and parking shortfalls, and the deficient consultation. It also fails the basic public interest test: a development of this price point and scale does nothing for housing affordability, and its approval would cause lasting harm to an established residential community — including families like mine who have only just arrived here.

YES , I definitely object to this development, Its a great damage and environmental destruction ,architectural and cultural ,it violate any regards for the height and bulk inappropiate with rhe surrounding building ,taking the beauty of the place with no result other than give developers freedom to do what they wanted . You dont't build apartments on balmoral slopes to help the housing crisis like they like to tell you , appartaments in Balmoral costing millions of dollars are not going to be accessible accomodations . you are destroying a beautiful place for greediness ,nothing else . I sincerely hope reasons will prevail

This is an overdevelopment that is completely out of place in a low-rise, residential suburb. A building of this height would dominate the streetscape and undermine the character that makes Mosman what it is.

While basement parking is proposed, it does not eliminate the impact on local traffic. A development of this scale will still significantly increase vehicle movement in and out of the area, on streets that are not designed for that level of use.

It would also bring major disruption during construction and reduce privacy and sunlight for surrounding homes.

This proposal prioritises density over livability and does not sit well within the character of the area.

As a resident in the near neighbourhood of this development, I strongly object for the following reasons:
1. This proposal is for a 10 storey building which clearly constitutes a high rise development, not 'mid -rise. It is not a 'compliant' development as described in the application, and seems to me to be an opportunistic use of the 'LMR' legislation, which itself has serious shortcomings, and, I would argue, does not achieve its stated purpose of providing affordable housing.
2. It is of such height and bulk, that it will totally dominate the site on which it is proposed to sit, the whole streetscape of Redan St and the ridgeline as viewed from Military Rd, Balmoral Beach and the harbour. It is a massive, massive increase in height, bulk and density from the surrounding built landscape.
3. The development is not in keeping with the surrounding low rise buildings in Redan St, which sit beautifully in their environment, set back from the street, with large verges and planting, thus changing the whole character of Redan St.
4. The proposed building detracts from the heritage listed properties in the street and the neighbourhood, looming over them like a monster, overshadowing houses, gardens and invading privacy
5. In view of the above, it is important to note that the development is proposed in a Scenic Protection Area, created to preserve the character of the landscape on Balmoral Slopes. This development is the antithesis of the aims of the Scenic Protection Area.
6. The proposal is an overdevelopment of the site, requiring deep excavation into the sandstone bedrock (down 10m, as I understand it) and to all boundaries. The risk of movement, water issues and consequent damage to existing properties is huge.
7. This area of Mosman does not have the transport infrastructure to support a development which adds more people and at least 106 additional cars, which will add significantly to the existing traffic issues in Mosman.

Already, Military Rd is a carpark and access to it, and the other side of Mosman, from Balmoral, is almost impossible at certain times of the day. Ask the drivers of the 114 bus, the main public transport out of Balmoral. The right hand turn from Raglan St onto Military Rd is slow and difficult. It is a very wide intersection, which is constantly blocked by cars coming through on the amber, and getting held up by cars parking in the next block. At almost every light change, there are cars stuck in the middle of the intersection, causing pedestrians to walk around them and preventing the cars at the lights in Raglan St from turning into Military Rd. This problem is amplified at school pick up time by the additional traffic from Queenwood. I have almost been hit by a car coming so late through the lights that I was half way across the crossing by the time it came through.

From my house, one way to avoid this bottleneck, it to use Balmoral Avenue, Redan St, then Almora St to access Military Rd, though a right hand turn is nigh impossible due to the banked up traffic, and pedestrians crossing Almora St at the crossing. The pedestrian crossing here is not a safe one due to the number of cars turning onto and off Military Rd and I have seen a few near misses over the years. More traffic, more people in cars, and more people trying to access the limited public transport in this area ie buses along Military Rd, is not acceptable without significant upgrades to infrastructure.

And, to that we can add the problem of parking for the cars for which no spot is provided in the building.

8. This developer is trying to take maximum advantage from the ill-conceived LMR legislation by providing so-called affordable housing in what is intended to be, and like most of the others proposed in Mosman, advertised as a luxury development with expansive harbour views. The affordable units, which are required for only 15 years (does anyone care what happens after that?) are accessed via a separate Redan Lane access - a so-called "poor door', which is totally unacceptable in our society and which was banned in New York city. That it has been proposed at all is absolutely appalling. That this accommodation is primarily bedsits is appalling.
9. The LMR legislation does not achieve what it is intended to achieve, in many instances in Mosman, but most particularly with this development. This proposal is not within 400m walking distance of a town centre or a valid transport hub. This proposal does not provide meaningful affordable housing. It is not LMR. It represents destruction of our existing environment forever without achieving the stated aims of the legislation. As a community being asked to sacrifice significant amenity, we should be able to feel assured that the aim of affordable housing is being achieved. That is far from the case. Again, particularly with this development, which so blatantly using and over-reaching the LMR legislation to build something that would otherwise be totally unacceptable, and should be deemed unacceptable now.

Thank you for the opportunity to comment on the State Significant Development Application SSD-93020230 which seeks consent to the 'demolition of existing building ; construction of a 10-storey residential flat building compromising : 53 apartments ( including 11 in-fill affordable housing apartments ) , two basement levels with parking for 106 cars , communal open space ; and associated works including site preparation , excavation , earthworks , landscaping and installation of services ' at 40-48 Redan Street Mosman
I have lived in the area for 42 years and have owned and resided at 32 Redan Street for some 14 years . My property lies 3 properties south of the southern extent of the proposed development on Redan Street.
It is my opinion that the application should be rejected for a number of reasons . Firstly it is difficult to see this development as a 'State Significant Development' , one cannot imagine this oversized building bulk of 10 storeys rising up immediately next to 2 heritage listed cottages would ever be considered by the residents of NSW to be significant to our state . It would certainly not appear on any promotional material highlighting the wonderful features of our Harbourside city
The proposed development is out of proportion to all surrounding exiting buildings and the attempt by the proposers of the development to include in their submitted diagrams and models other oversized buildings that have NOT been approved is misleading and inappropriate
The proposed development is at total variance to the ambience of this area of Mosman and the streetscape of lower scale residential housing with landscaped setbacks greatly enhancing the appeal of the area including heritage buildings and historic Mosman residences
This development is not a minor change to the local environment but rather a massive overbuild overlooking and overshadowing adjacent properties to the north east ,south and west and in many cases obliterating middle harbour views
My property backs onto Redan Lane (as does the proposed development) . Redan Lane is narrow and although two way traffic is permitted , one of the vehicles needs to pull to the side if there are 2 cars in the same part of the lane at the same time . Trucks including the weekly garbage collection vehicles have significant problems negotiating the lane most particularly at the S bend adjacent to 34 Redan Lane Vehicular traffic will be significantly impacted should this development proceed with the lane access for the "in fill component" with service , delivery and transportation vehicles. Furthermore there is no formed pedestrian footpath on this section of Redan Lane and as recognised by Mosman Council it is not a safe thoroughfare for pedestrians . This is a significant problem given it would appear from the submitted plans that pedestrian access to the in fill accommodation is via the lane
The in fill component is a bizarre proposal sitting at the back of the huge overbuild . In a number of these properties the lower level of the unit sits below the level of Redan Lane from which access is obtained as previously mentioned . It appeared from the plans submitted for public exhibition that residents in some of these units would need to leave their unit via Redan Lane and reenter at another site on Redan Lane if they wished to access either the basement garaging or the bicycle storage area . As mentioned previously Redan Lane is not currently considered safe for pedestrian traffic
Another grave concern for me is the extensive excavation detailed in this proposal , not only in terms of the short term amenity issues ( noise ,traffic ,cranes , vehicular disruptions, visitor parking ), during development but the long term effects on run off of groundwater flows off the slopes as we already observe in Redan Lane ,and the potential negative effects on adjacent land holdings from the sandstone excavation
In summary the development fails the test for improving the neighbourhood in which it is to be constructed with the loss of landscaping dominated by an unattractive 10 storey oversized build at variance to the Mosman Scenic Protection Area principles for the Sydney Harbour landscape
The application should be rejected

My objections are as follows -
1. This is a massive development spread over 5 properties (approx. 150 m) going back to Redan Lane being one whole block. It will be a blight on the surrounding area and an eyesore. The sheer bulk is staggering.
2. The development falls within the Scenic Protection Zone blocking views from hundreds of residents which are meant to be enjoyed by everyone. Otherwise why have this Zoning in place at all if it is going to be violated.
3. The current residential count for the 5 properties at say an average of 3 per household is 15 which will become an estimated 150 people, 10 times the current occupancy.
4. The number of motor vehicles will increase 10 fold also – say 2 per household now say10 total to say 106 if the development is approved as lodged. This will have a significant impact on the surrounding streets as well as the already congested traffic on Military Road along the shopping strip. How many of those people will walk to the shops to do their weekly shopping? They will drive.
5. There are-
a. 8 bedsits proposed to be set aside for affordable housing for 15 years. What restrictions are placed on these units. Can they be held by the developer for 15 years or sold to an associate/s of the developer. Is there a limit on the current and/or future sale price of these units to ensure that they actually remain affordable? AND
b. 3 larger “executive affordable” units.
Endorsement of class discrimination!!!
This setting aside of 11 affordable housing units is merely a means of getting around the SSD process to approval.

6. If this development is approved as is or with minimal alteration, then this will just open the doorway to other developers wanting to over develop other areas of Mosman. Even the new developments along the shopping strip as well as the Aberdeen development are not 10 storeys.
7. Sunlight – there’s another point. The bulk of this building will block the sun to some extent affecting surrounding properties
8. Mosman is a destination suburb that is, it ends at the coastline and the Zoo. It has an old road infrastructure which cannot be expanded or improved. The State government makes this impact worse by not endorsing and constructing the long awaited Northern Beaches tunnel, which would divert a great deal of traffic away from Mosman. More traffic will have a major impact on the suburb. I understand that there are currently 13 other multi-story development applications which have been lodged either under the SSD policy or with Mosman Council.

I would like to strongly object the Residential Development with IN-Fill Affordable Housing 40-48 Redan Street Mosman
SSD-93020230
1. This is not what the Low and Mid-Rise Housing Policy was intended for. It is not mid-rise ie. 2-6 storeys it is a 12 storey building. Clearly 5 planning concessions stacked on to each other.
2. This is NOT about affordable housing with the purchase price for similar penthouses as this project offers selling for $20 Million and above with the other apartments comparable to $10 Million and above apartments. The 11 "affordable appartments" last for 15years and offers a back lane entry making it clear that its seperate to the exclusive luxury appartments at the front with the views under the cloak of this being Affordable housing its a disgrace. Who does this project serve.....I'd say the
Developer who has used legislation for his own financial gain not those seeking home security.
3. Five beautiful federation homes with we removed. Why do we want the beautiful city of Sydney to end up like Dallas or Tokyo. What people love about our city is the character whether it be Newtown, Northern Beaches, The Hills District or the Shire. Why allow this destruction. Even the view from the beautiful harbour will be changed. This can't be put back once it's gone and it's not what the legislation was intended for.
4. The number of car spaces is not realistic for the number of units. Adult children move in with their parents, people have more than one car per family and many have at least 3. Our streets are clogged already. We are a penisular with Balmoral, The Zoo, Cliffton Gardens and Georges Heights. Add to that hundreds of cars and we have a bigger mess than we have already
5. Why is the Scenic Protection Zone being totally ignored. We have as a City protected our harbour foreshore for all these years for a very good reason. Why would you turn your back on it now. We can't get it back.
6. I don't believe this development meets the 400 safe walking distance required by the LMR zoning.
7. The bulk and scale is just overpowering to all the properties close by.
Wendy Procter
I am not opposed to development, I want to see true secure affordable housing, however this is not achieving any of the objectives it is someone taking advantage of legislation.

To the Assessment Team,

I write to formally object to State Significant Development application SSD-93020230, which proposes the demolition of five Federation-era homes at 40-48 Redan Street, Mosman, and their replacement with a residential building of up to 12 storeys (35 metres above street level) containing 53 apartments.

I attach a detailed planning submission setting out the full grounds of my objection. I ask that the Department engage substantively with each ground raised.

In summary, my objection rests on the following:

1. STACKED PLANNING CONCESSIONS - The proposal simultaneously invokes the Low and Mid-Rise Housing Policy, a 30% Infill Affordable Housing height uplift, two separate Clause 4.6 variations, and the SSD pathway. A 12-storey building is not low or mid-rise development in any accepted planning sense. The fact that a Clause 4.6 variation is still required after exhausting every available State incentive demonstrates that this proposal exceeds the planning framework at its most generous.

2. DISPROPORTIONATE AND UNVERIFIABLE AFFORDABLE HOUSING JUSTIFICATION - 11 apartments affordable for 15 years is not proportionate justification for a permanent 12-storey building. No financial modelling has been provided to confirm that rents will be genuinely accessible to households in housing stress. Eight of the 11 affordable apartments are accessed via an unpaved, unlit rear service laneway - a 'poor door' arrangement prohibited by law in other jurisdictions.

3. HERITAGE AND SCENIC PROTECTION - Redan Street is a designated Heritage Road. The site is directly adjacent to heritage-listed properties at 36-38 Redan Street. The site falls within a Scenic Protection Area under the Mosman LEP. The developer's own Visual Impact Assessment acknowledges impacts on neighbouring properties ranging from 'severe to devastating', yet concludes these are acceptable.

4. TOPOGRAPHY MISREPRESENTATION - The EIS characterises the site as being on the 'ridgeline' of the Balmoral slopes. The architectural drawings show a mid-slope condition. This mischaracterisation materially understates both the visual impact and the privacy impact of the development throughout the EIS.

5. STOREY COUNT AND PODIUM AMPLIFICATION - The Department's exhibition notice describes a '10-storey' building. The architectural drawings show 12 storeys including two basement levels. The assessment must be anchored to the actual 35-metre height above street level. The EIS does not address the podium amplification effect of deep basement excavation on the building's visual prominence.

6. CUMULATIVE PRIVACY AND OVERLOOKING - Multiple floors of east-facing balconies and habitable rooms on a mid-slope site create direct downward overlooking into the private open space and living areas of numerous neighbouring properties simultaneously. The EIS relies on generic separation distances and does not assess vertical or cumulative overlooking.

7. PARKING, TRAFFIC AND CONSTRUCTION IMPACT - 106 car spaces for 53 luxury apartments is inadequate. A single driveway will concentrate all vehicle movements on a narrow residential street. Construction of this scale will effectively close Redan Street to residents for years. The most recent development on Redan Street - just 6 units - consumed all on-street parking for 18 months.

8. EXCAVATION AND STRUCTURAL RISK - Two full levels of deep sandstone excavation across 3,233 sqm presents serious structural risk to adjacent heritage homes. Previous construction works on Redan Street have caused documented structural damage to neighbouring properties. The EIS provides no binding commitments on vibration monitoring, dilapidation surveys, or liability for damage caused.

9. DEFICIENT COMMUNITY CONSULTATION - Residents on Redan Street received no postcard, no survey, and no focus group invitation despite being named as having been consulted in Appendix E. The process produced 43 survey responses and 6 focus group attendees. Mosman Council's detailed concerns received a single boilerplate dismissal.

10. PRECEDENT RISK - The developer has separately presented a broader redevelopment vision for Mosman. Multiple streets have already been amalgamated and marketed to developers. This application, if approved, becomes the reference point for every future application across the suburb.

The full submission, including case law references, statutory analysis, and a requested determination, is attached.

I ask that the Department refuse this application. If the Department is minded to approve any development on this site, I ask that it require a fundamentally redesigned scheme that complies with the existing planning framework, respects the heritage streetscape and Scenic Protection Area, and delivers a genuine and permanent affordable housing outcome.

Please confirm receipt of this submission and that it has been recorded on the formal submissions register for SSD-93020230.