Pamela Davis
2904/184 Forbes Street
Darlinghurst, NSW 2010
[email protected]

11 November 2025

The Assessment Officer
Department of Planning and Environment / City of Sydney Council
456 Kent Street
Sydney, NSW 2000


Re: Objection to Proposed Development – 164–172 & 174–194 William Street, Woolloomooloo (SSD-80211463)

Dear Assessment Officer,

I am writing to formally object to the proposed State Significant Development at 164–172 & 174–194 William Street, Woolloomooloo. As a local resident directly impacted by this and other nearby developments, I urge the Department to defer or refuse consent until a full precinct-wide cumulative impact assessment is completed and key deficiencies in the current Environmental Impact Statement (EIS) are rectified.

1. Cumulative and Precinct Impacts

The EIS for 164 William Street ignores the combined effects of two other concurrent nearby developments—134 William Street, Woolloomooloo, and 203–225Victoria Street, Potts Point. Collectively, these projects will add approximately 543 dwellings, 1,000 new residents, and more than 540 vehicles within a small, already congested precinct. The failure to assess their cumulative impacts on traffic, parking, amenity, and infrastructure renders the current analysis incomplete and misleading.

2. Overcrowding and Infrastructure Strain

The Woolloomooloo–Kings Cross–Darlinghurst corridor is already overburdened with some of Sydney’s highest densities and legacy infrastructure. Previous large-scale developments have been refused or scaled back due to capacity and safety issues. Proceeding without robust infrastructure and service upgrades ignores both precedent and community wellbeing.

3. Traffic, Parking and Access

The Traffic Report overlooks the combined vehicle movements from all three projects. With limited arterial access and “no right turn” restrictions from Bourke Street, spill-over congestion into back streets is inevitable. Existing conditions are already strained, and the lack of parking and loading provisions for both retail and residential will worsen amenity and safety.

4. Visual, Wind and Public Space Impacts

The Visual Impact Assessment demonstrates excessive building height beyond LEP and SEPP allowances, undermining local character. The Wind Assessment underplays the impact of increased wind tunnelling along William Street, making proposed open spaces impractical. Furthermore, the so-called “public park” is privately owned and included in the gross floor area, raising doubts about future accessibility, safety, and genuine public benefit.

5. Community Safety and CPTED Concerns

The development area already experiences high levels of crime and antisocial behaviour. The CPTED report defers key safety measures to future management plans rather than embedding them in the design. Increased density without cohesive, enforceable safety standards will heighten risks for residents and visitors.

6. Questionable “Affordable Housing” Claims

To label high-value harbour-side developments as “affordable housing” is disingenuous. The current offer of 60 units (≈26%) for only 15 years fails to deliver genuine, long-term affordability. This has just been a scheme for developers to be allowed extra height without providing substantial benefits to the community or those in need of affordable housing.

7. Environmental and Construction Impacts

Three simultaneous major projects will cause severe cumulative noise, dust, vibration, and truck movements through narrow heritage streets. Site investigations already show hydrocarbon and lead contamination risks. The EIS defers these issues to future management plans without enforceable mitigation.

8. Consultation and Transparency

The community consultation process has been tokenistic. A single, heavily curated online session failed to engage residents meaningfully or address critical concerns raised in submissions. Genuine engagement must be transparent, accessible, and responsive to community feedback before further approvals proceed.

9. Design Excellence and Regulatory Compliance

The proposal conflates previous concept designs and misrepresents compliance with the Design Excellence process. Additionally, the assertion that no Roads Act s138 approval is required contradicts statutory requirements, given the proposed changes to public roads and kerbs.

In Summary

The cumulative scale, inadequate assessment, and disingenuous framing of public benefit in this proposal threaten the amenity, safety, and character of the Woolloomooloo–Kings Cross–Darlinghurst precinct. I therefore request that the Department of Planning and Environment:
1. Defer determination of SSD-80211463 pending a full precinct-wide cumulative impact assessment.
2. Require binding precinct-level plans for traffic, construction, and safety management.
3. Clarify and strengthen affordable housing standards.
4. Mandate environmental auditing and public transparency throughout excavation and construction.

Until these conditions are met, approval of this proposal would be premature, inequitable, and inconsistent with sound urban planning principles.

This development raises profound concerns from multiple angles of community impact—from the visual and environmental to the social and economic. I strongly urge the council to reconsider this proposal, ensure comprehensive evaluations of all impacts, and foster genuine engagement with community members who will be most affected by this development.

Thank you for considering my concerns. I look forward to seeing a thoughtful and conscientious approach to this matter.


Yours sincerely,
Pamela Davis

Attention : Ms Michelle Niles, Department of Planning, Housing and Infrastructure
Re : SSD-80211463 for 164-172 . 174-194 William Street Woolloomooloo NSW 2011
Mixed Use Development with i-fill affordable housing , 164-194 William Street , Woolloomooloo

Dear Ms Niles ,
We are affected property owner near the subject site at Strata Plan 20087 ( 5-15 Farrell Avenue /26 Kirketon Road , Darlinghurst ).

Views from 5-15 Farrell Avebueand 26 Kirketon Road include panoramic, sweeping views of the iconic Sydney skyline , clear water elements , the Sydney Harbour Bridge , Opera House and Royal Botanic Gardens . These iconic views provide key and hightly valued residential amnityto our apartments , which are located higher up the topografy.

We Angelika Thill and Michael Bowe owners and have lived in our home for 33 years at Palisades , unit 42 5-15 Farrell Avenue , Darlinghurst NSW 2010.
We are sending our submission to strogly opose the above mentioned mixed use development .
The subject of views should not be talked down or underestimated .
Views are part of our daily live all year round , morning , noon and night , rain hail or shine .
We enjoy watching the activities on the harbour , festivities involving the Harbour Bridge and the Opera House like New Year Fire Works , Australia Day , Vivid festival, ships arriving at the Navy Base , Cruise Liners and sailing competitions.
Fire works for many different occasions , Luna Park sparling in glorious colours.
We look down into the beautiful tree lined valley of Woolloomooloo , watch the seasons changing , autumn leaves changing colours .We wake up and enjoy theiconic and scenic views, we go to bed and look at the stars over the iconic Harbour Bridge and Opera House .
We feel blessed .
The scale and stacked extreme height proposed will be visible from our buildings and detrimental.
This monstrocity is a developer's dream of exorbitant profits for themselves and their investors will become a nightmare .
Our daily joy of life all year round will be destroyed forever , our homes as we know them will not be the same anymore
This will cause serious harm to so many in the neighbourhood .
Please understand and support our community and scale down the height of the buildings substantially and request that the buildings are of highest architectural standard , pleasant to look at from all angles .
Yours sincerely
Angelika Thill and Michael Bowe
42 5-15 Farrell Avenue , Darlinghurst 2010

Dear Sir/Madam,

I write to lodge a formal objection to the development application SSD-80211463 based on its severe and detrimental impacts on public safety, local infrastructure, and pedestrian amenity.

I am a long-term resident of the Horizon building at 184 Forbes Street and have first-hand, daily experience of the issues this development will severely worsen. My objection is based on the following key grounds:

Unacceptable Traffic Generation and Impact on Emergency Services

William Street already operates at or beyond its capacity. It is a major arterial road known for significant daily congestion, gridlock, constant noise pollution from horning, and dangerous merging conditions.

Crucially, William Street is a primary corridor for emergency services, including ambulances accessing St. Vincent's Hospital and fire services from the Darlinghurst station. Existing traffic frequently impedes their response times, and requires tricky manoeuvres from the emergency services and from the cars on the road. This is already a significant and unresolved public safety issue.

The proposal will add a significant number of new residents to this already strained location. Due to the area's lack of local amenities for children, such as schools and sporting facilities—a fact I can attest to personally having raised a child here—new residents with families will be highly car-dependent. This will generate a direct and substantial increase in vehicle movements, exacerbating congestion, increasing noise, and further impacting the efficiency of critical emergency services.

Detrimental Impact on Pedestrian Amenity and Poor Urban Design

Despite its wide footpaths, William Street suffers from a poor and unpleasant pedestrian environment. The existing array of high-rise buildings already creates an uncomfortable 'wind-tunnel' effect, making it a cold and unwelcoming street to walk along.

It functions as a major traffic thoroughfare, not a community space. As a resident, I can attest that people do not go for a casual stroll, stop to shop, or have a pleasant coffee catch-up on William Street precisely because of this cold, windy, and traffic-dominated atmosphere. I personally try to avoid walking along it and use the quieter, more pleasant streets of Darlinghurst instead.

While the proposal may suggest new retail spaces or a public park to create amenity, its core design—adding another oversized 18-storey tower—will only aggravate the very conditions that make the street so unwelcoming. It will increase wind-tunnelling and overshadowing, further contributing to the sense of a cold, traffic-dominated canyon. This will likely undermine the success and viability of any public-facing amenity being proposed and represents a poor urban design outcome that fails to contribute positively to the local streetscape.

In conclusion, this proposal will place an unacceptable burden on already-failing local infrastructure, particularly the William Street traffic network. It will create a demonstrable public safety risk by negatively impacting emergency service access. Furthermore, it represents poor urban design by contributing to an unpleasant and unwelcoming pedestrian environment.

Based on these negative impacts on the existing community, I cannot support this application. I urge the Department to give full weight to these community concerns and respectfully request that this matter be referred to the Independent Planning Commission for a public hearing.

Yours faithfully,
XXX XXX

Submission on State Significant Development Application:
164–172 & 174–194 William Street, Woolloomooloo NSW 2011
(SSD-80211463)
Nadia Lalak BSocStud; MA; App Science (Landscape); PhD (Architecture)
3703/184 Forbes St., Darlinghurst, NSW, 2010
[email protected]; 0408445025
_________________________________________________________________________________
As can be seen by my address I am a resident of the area directly impacted by the proposed Submission on State Significant Development Application 164–172 & 174–194 William Street, Woolloomooloo NSW 2011 (SSD-80211463).
However, I wish to point out that I am also very concerned about two other proposed developments nearby, namely 134 William Street, Woolloomooloo and 203–225 Victoria Street, Potts Point.
From both a personal and professional perspective I am deeply concerned about the potential cumulative impact of these proposed developments in their present form on:
a) the physical, psychosocial and emotional wellbeing of residents/retailers/visitors in the Woolloomooloo–Kings Cross–Darlinghurst precinct and
b) significant overcrowding and infrastructure strain on an already stressed precinct with high residential density, transient accommodation, car parking shortage, crime and antisocial behaviour, wind tunnels, heritage listed buildings etc.
The area in question already has unpleasant and disturbing wind tunnels. Few pedestrians venture down William Street even though it is an obvious direct route to the city of Sydney. Erecting more exceedingly high developments (with potential retail as well as residential accommodation) would exacerbate the existing problems. There would be reduced sunlight, increased shadowing and increased wind tunnelling. Many residents in existing buildings would lose their views to Sydney Harbour and cherished landmarks – often a compelling reason for their choice of residence.
Businesses already struggle to survive, many premises are empty and neglected - why would new retail succeed where the old has failed? How would the addition of hundreds, if not thousands, of new residents and more cars ameliorate the already dire situation of the stressed precinct?
Parking, traffic and access are already over stretched eg there are minimal parking bays on William Street offering only a handful of parking spots, many streets are only one-way (creating complicated detours), and access to the major freeway from William Street is often at a standstill with cars caught up across the traffic lights. Adding potentially hundreds more vehicles in an already congested area would create more chaos and gridlocks, particularly in peak hours. Nor has attention been given to the inevitable overflow of traffic into the adjacent streets, or that many existing residents would not be able to park near their homes.
In summary, the Development Applications have glossed over or ignored many of the detrimental and problematic aspects of their proposals

227 apartments over 18 storeys would be a significant impact to the already strained infrastructure and traffic congestion within this location. At present throughout the day (7days a week) traffic can extend from Riley street right back through the Kings cross tunnel to Rushcutters bay with commuters trying to access both the Eastern Distributer and the Harbour bridge approaches. 18 Storeys will create a overwhelming shadowing gloomy vision for William street on what should be a tree lined Boulevard style link between the CBD and Kings Cross/Eastern Suburbs.

Position
• Object to consent in its current form; alternatively, support approval only if strict conditions are imposed to keep all built elements within the approved concept RL envelope, remove hazardous pedestrian wind hotspots at corners, entries and through site links, implement precinct wide construction traffic controls, and secure a feasible and durable affordable housing outcome tied to the uplift claimed.
Height and envelope control
• The concept determination fixes operative height limits as reduced levels (RLs) to balance uplift with neighbourhood amenity, and detailed design should not exceed those RLs unless independent verification proves no additional external impacts on sensitive receivers, which the SSDA does not demonstrate.
• Conditions sought: cap all building crowns and roof plant strictly within the RLs on the approved concept drawings, prohibit rooftop overruns and ancillary accretions, and require independent pre CC and pre OC certification that as built RLs match the concept envelope, with refusal if exceedances are necessary to achieve the proposed yield.
Street level wind: pedestrian safety and comfort
• The Pedestrian Wind Assessment records exposed edges and corners with Lawson comfort classifications of Pedestrian Walking/Business Walking and at least one location with an Able Bodied exceedance, while recommending no mitigation and cautioning that trees are not a reliable primary control in high winds.
• With taller massing introduced on William/Forbes/Dowling and new through site links and plaza entries, the risk of acceleration, cornering gusts and downwash increases for people waiting, crossing and lingering, which warrants hard controls and verification rather than reliance on landscaping.
• Conditions sought: wind tunnel addendum targeting the William/Forbes and William/Dowling corners, plaza thresholds and through site links; a pre CC mitigation plan specifying canopies, wind screens and baffles sized to tested performance; a 12 month post occupation audit against Lawson safety/comfort criteria; and rectification triggers backed by a performance bond.
Cumulative construction traffic and neighbourhood amenity
• The Transport Impact Assessment anticipates sustained heavy vehicle activity across demolition, excavation and superstructure with off site worker parking, creating likely queuing/idling, diesel emission and vibration impacts on narrow local streets immediately adjoining The Horizon.
• The EIS flags multiple major developments in the catchment but defers coordinated staging, haulage windows and traffic control arrangements to later plans, which is inadequate for overlapping construction programs on the William/Victoria Street corridors.
• Conditions sought: a precinct wide cumulative Construction Traffic and Pedestrian Management Plan prepared with Council and TfNSW; capped heavy vehicle rates by stage; haulage windows avoiding commuter and school peaks; prohibition on layover/queuing on Forbes, Judge and Dowling; updated baseline counts and intersection analysis including Saturdays; a contractor travel/parking plan; and Horizon specific dilapidation plus vibration monitoring with stop work thresholds and make good obligations.
Affordable housing uplift: feasibility, durability and public benefit
• The SSDA relies on the in fill affordable housing pathway to justify a materially larger envelope and density but provides limited transparency on delivery risk under current cost/funding conditions, the distribution and mix of affordable dwellings across buildings and floors, and mechanisms to ensure genuine affordability and robust management for the nominated period.
• The SIA acknowledges community concern about multiple large developments and public domain challenges, reinforcing the need for clear, enforceable commitments rather than high level intentions.
• Conditions sought: a binding Affordable Housing Delivery and Management Plan fixing minimum yield, mix, dispersion and rent setting against moderate income bands under a registered community housing provider; independent feasibility certification prior to CC; and a registered restriction/VPA ensuring delivery and affordability for at least the nominated term with clear default remedies, plus a public benefit statement quantifying net additional affordable dwellings versus a compliant non uplift scheme.
Public domain safety and operations
• Given recognised safety risks in the locality and the introduction of 24/7 links, lifts and a new park, CPTED and operational measures should be embedded now rather than deferred to later plans to assure day to day safety.
• Conditions sought: a Social Impact Management Plan and detailed Plan of Management before CC that fixes lighting to Australian Standards, CCTV coverage, transparent lift walls to public areas, security staffing and incident reporting, prepared with input from NSW Police and monitored for at least three years post occupation.
Determination request
• Refuse the application, or approve only with the above condition suite to ensure heights remain within the approved concept envelope, pedestrians are protected from hazardous street level winds, construction traffic is coordinated across the precinct, and the affordable housing uplift delivers a feasible, durable public benefit commensurate with the intensity sought.

Dear Sir/Madam,
I am writing to formally submit my objection for the mixed-use development proposed at 164–172 and 174–194 William Street, Woolloomooloo. (Development Application Reference: SSD-80211463).
I confirm that I have not made any reportable political donations in the past two years, and I accept the department’s disclaimer and declaration as part of this submission.
I am in full support all quality development within responsible limits and the delivery of affordable housing for our Community.
My grounds for Objection to this scheme:
1. EXCEEDING HIGHT CONTROLS.
This proposal, prompted by the recent affordable housing provisions now significantly breaches permissible height controls, doubling the previously tested building envelope and aborting the extensive design work already carried out in the approved DA that provided an equitable and suitable scheme that fitted into its context.
The additional height being sought creates an exceedingly large structure, out of scale with its neighbors and positioned at the high point of William St. This will result in the loss of long-standing views and sun for many residents and adversely impacting the amenity of an entire neighborhood south of this site, by its environmental impacts.
URBIS EIS Oct 2025 – Height Controls
SLEP Control 35.0m
30% Uplift Control 45.5m
Proposed 66.3m
Breech +20.8m
This is an over 20m height variation with the only tangible benefit being capitalizing on the sites location to generate high value floorspace, none of which serves the bonuses given to deliver affordable housing. Affordable units that have been provided are located in undesirable areas, poorly ventilated with limited or no solar access.

2. BEING EXCLUDED FROM COMMUNITY CONSULTATION / VIEW ASSESSMENTS
URBIS EIS Oct 2025 – 5. Community Engagement
I reside at No 1 Tewkesbury Ave which is a 80 unit residential building that has been excluded from the community engagement and as a 'key neighbour', yet our building is one of the most impacted. I am a long-time resident of the building but have received no notices or information, seeking my feedback or engagement toward what is being proposed.

3. INNAPROPRIATE FAÇADE DESIGN
The proposed building façade treatment has been changed from the approved warm earth-toned brick to stark white. It is inconsistent and at odds with the area's heritage buildings predominant terracotta face brick palette and no detail can readily be seen in the reports as to why this colour change has been made.
This site is located on a major arterial road, adjacent to an open railway line, major road distributor and rail tunnel exhaust stacks where large amounts of soot and dust are prevalent. The choice of white as a colour in this context is highly inappropriate, likely to weather poorly and stain due to these local environmental factors. The relentless of this colour from the ground plane, where it will not perform well, to the tops of the buildings offers no relief or opportunity to reduce the bulk and scale. It only magnifies this.
White is also highly reflective making it appear more dominant and further amplify the 30% larger building envelope.
CONCLUSION
This new DA is now a significant departure from the approved and the extensive design work that went into creating an equitable and suitable scheme that would fit comfortably into its context.
I submit that, while affordable housing is essential, developments must respect existing planning controls, equitable view sharing, and the visual and social impact on the community.
Distributing the increased height evenly across the site achieves a fair balance between introducing affordable housing, maintaining a viable development for the developers, and equitably distributing the impact of view loss for residents in the surrounding areas.
Request for Consideration:

I respectfully request that Planning NSW:

• Reject the variation to the height controls to allow stacking of GFA to part of the site
• Limit building heights to what is permissible under the controls.
• GFA is equitably shared over the site to provide buildings that are consistent with the surrounding urban fabric.
• Reinstate the DA approved façade colour and material palette to limit further adverse impacts to the area.

I appreciate the opportunity to provide feedback and trust that the concerns of all residents including those with disabilities will be given due consideration in the planning process.


Yours sincerely,
Resident & lot owner
Darlinghurst NSW 2010