FORMAL OBJECTION: Cammeray Seniors Living – 19-23 Rosalind Street (SSD-100234)

I am writing to lodge my strongest objection to the proposed development at 19-23 Rosalind Street. This project is a clear case of over-development that exploits planning loopholes at the expense of both the local community and the dignity of senior citizens.

My objection is based on the following grounds:

Cynical "Seniors Living" Loophole: The proposal claims to be a seniors housing and care facility, yet it provides only two care beds, both of which are located underground in a basement. This is a blatant and disrespectful misuse of the planning system. To suggest that "care" consists of two basement rooms while the rest of the building is dedicated to luxury features like a wine cellar, cinema, pool, and gym is an insult to the intent of seniors' housing. This is clearly a luxury apartment complex masquerading as a care facility to bypass local height and density controls.

Excessive Scale and Height Blow-out: At 18.4 metres, this building is 50% above local height controls. It is completely out of scale with the surrounding homes. With minimal 3-metre setbacks, it will cause severe overshadowing and a total loss of privacy for over 100 adjoining properties.

Safety Risk on a Key School Route: The proposal requires a 10-metre deep sandstone excavation, resulting in up to 8,000 truck movements on a quiet residential street. Rosalind Street is a primary walking route for school children; introducing industrial-scale heavy vehicle traffic, rock-breaking noise, and dust into this environment poses a direct and unacceptable safety risk.

Permanent Environmental Loss: I object to the near-total site clearance, including the destruction of a 2.5-metre wide Port Jackson Fig. This mature canopy defines the character of the street and provides essential cooling and shade. It cannot be "replaced" by new plantings on a concrete slab.

Externalized Waste Impacts: The plan to manage waste (including commercial waste from the cafe and potentially clinical waste from the "care" rooms) via the kerbside is a failure of design. It will obstruct footpaths for pedestrians and prams, creating noise, odors, and hygiene issues on a public street.

Conclusion and Call for Policy Review
I urge the Department of Planning to see this proposal for what it is: a luxury development using a "seniors living" loophole to maximize profit while ignoring local character and public safety. I request that this application be refused in its entirety.

Furthermore, I believe there must be an urgent review of what constitutes "seniors and affordable housing" under current state policies. The current framework allows developers to take advantage of these incentives for their own gain without providing genuine, high-quality care or affordability for the community. The planning system should serve the public interest, not provide a mechanism for bypassing local protections for luxury gain.

There are several reasons I object to this proposal and they are outlined below:
- The project heights and proximity to boundary properties will impact on the neighbours by: reducing their available sunlight; reduce privacy with a direct line of sight into yards; compromise usability of outdoor spaces which in Sydney function as an extension of living areas for families. This will impact me directly as I have family who will be impacted neighbours whom we visit frequently.
- The proposal is for seniors living. However these are 3-4 bedroom properties. This is incongruent with what we need as a society: downsizing older Australians to smaller properties to free up existing family homes for new home buyers. If the proposal included majority 2 or 3 bedroom homes better use of this land would be made, increasing the units and therefore bringing more homes onto the market through downsizing.
- The proposal for two care beds in the basement is abysmal and tokenistic to meet planning requirements to bypass standard council scrutiny. Two care beds would be challenging to adequately and safely staff given nursing ratios for RACF are not 1:1 or 1:2. How will this higher nursing ratio be paid for? Will this ultimately result in these beds being too expensive and thus not used and a further tick box? 24hr care for only 2 people with high care needs might also require more than 1 staff member for key cares, how will this be facilitated? Who is paying for a registered nurse to deliver all medications up to 6 times a day if an enrolled nurse or assistant in nursing is employed to provide essential cares? This model with only 2 standalone care beds is nonsensical and impractical and demonstrates a clear lack of understanding for how the care needs of elderly Australians are to be met outside of a physical room/bed.
If these beds are occupied, these vulnerable elderly Australians will be living in an underground room without access to adequate natural lighting. It is well known access to natural light is essential to support normal circadian rhythms, especially in those with medical conditions such as a stroke or dementia. Some of the likely key target populations for these beds. Additionally, as a healthcare worker I find it horrible to imagine someone moved down to the basement to live out their remaining years. This is tantamount to abuse and should absolutely be scrapped from the proposal.

It is for the above reasons I strongly object to this project.

I look forward to your consideration of my objections and hearing the outcome of your review.

I write to object to the State Significant Development Application SSD-96505456 for the proposed Cammeray Seniors Living development at 19–23 Rosalind Street, Cammeray. The proposal involves the demolition of three existing residential flat buildings and the construction of two new buildings of five and six storeys, containing 48 independent living units, a two-bed residential care “care hub,” a neighbourhood shop, two levels of basement car parking accommodating 104 vehicles, and associated landscaping.

While I recognise the genuine need for quality aged care and seniors housing in our community, this particular proposal raises significant concerns relating to height and bulk, the use of planning mechanisms to bypass local development standards, the absence of a confirmed aged care provider, and the broader precedent this development would set for the Cammeray area. I outline each of these concerns below.

1. Excessive Height, Bulk, and Scale

The site at 19–23 Rosalind Street is currently occupied by three-storey residential flat buildings that are consistent with the low-to-medium density character of the surrounding streetscape. The proposal seeks to replace these with buildings of five and six storeys — effectively doubling the height of built form on the site. This represents a dramatic intensification that is out of step with the established character of Rosalind Street and the broader Cammeray neighbourhood.

The six-storey building in particular will dominate the streetscape, creating adverse impacts on the visual amenity of the locality. The increased bulk and scale will also generate overshadowing of neighbouring properties, reduce privacy through overlooking, and create a built form that is visually incongruent with the predominantly low-rise residential context. The North Sydney Local Environmental Plan 2013 sets building height standards specifically to manage these impacts, and this proposal substantially exceeds those standards.

2. Clause 4.6 Variation Request — Building Height

The application includes a Clause 4.6 variation request seeking to exceed the building height development standard under the North Sydney LEP 2013. I submit that this variation is not justified and should not be supported.

The objectives of the height of buildings standard in Clause 4.3 of the North Sydney LEP include ensuring that new development is compatible with the desired future character of the locality, maintaining appropriate building heights relative to surrounding development, and protecting the amenity of neighbouring properties. A development of five and six storeys on a site currently occupied by three-storey buildings is fundamentally inconsistent with these objectives. The variation cannot be said to achieve the objectives of the standard notwithstanding non-compliance — rather, it directly undermines them.

Furthermore, the Clause 4.6 variation documentation, referenced in the Environmental Impact Statement, does not adequately demonstrate that strict compliance is unreasonable or unnecessary in the circumstances. The site is not uniquely constrained in a way that justifies the proposed height exceedance. The variation appears driven by commercial yield rather than genuine planning merit.

3. Absence of a Confirmed Aged Care Provider

A critical deficiency in this application is the absence of an identified and committed aged care provider for the proposed care hub. The development is being advanced by Perifa Rosalind Development, a property development entity, yet no operator has been named to deliver the residential care component that is central to the project’s justification as seniors housing.

This raises legitimate questions about whether the care hub will be delivered to an appropriate standard, or indeed delivered at all. The care component should not be treated as an afterthought or a planning vehicle to access the favourable assessment pathways available to seniors housing under NSW planning legislation. An aged care provider should be identified and involved in the design process from the outset, not appointed after approval has been secured. Without this commitment, the development risks being, in substance, a high-end residential apartment project dressed in the language of aged care.

4. Use of the SSDA Pathway to Bypass Local Planning Controls

This application has been lodged as a State Significant Development, which means it will be assessed by the NSW Department of Planning, Housing and Infrastructure rather than by North Sydney Council. While the SSDA pathway exists for developments of genuine state significance, its use in this instance effectively removes meaningful local planning oversight from a development that will have a direct and lasting impact on the Cammeray community.

North Sydney Council and its Local Planning Panel have detailed knowledge of the area’s character, development history, and community expectations. The SSDA pathway should not be used as a mechanism to circumvent local height and density controls that the community and council have established through proper strategic planning processes. I urge the Department to give full and genuine weight to the local planning framework and to the concerns of residents who will live with the consequences of this decision.

5. Undesirable Precedent for Higher Density Development

Approval of this development at the proposed height and scale will establish a clear precedent for future applications in Cammeray and surrounding suburbs. If a six-storey building is permitted on a site zoned and developed for three-storey residential flats, it sends an unambiguous signal that the height and density controls in the North Sydney LEP are negotiable. This will encourage further applications seeking similar or greater exceedances, progressively eroding the low-rise residential character that defines Cammeray and that existing residents chose when they moved to the area.

6. Traffic, Parking, and Local Amenity

The proposal includes 104 basement car parking spaces across two levels. This represents a significant increase in vehicle movements on Rosalind Street and surrounding roads, including Trafalgar Street, which are not designed to accommodate this intensity of traffic. The construction phase will also generate substantial disruption over an extended period. I note that the impact on Trafalgar Street in particular warrants careful scrutiny, as referenced in the Clause 4.6 variation documentation.

Conclusion

I support the provision of quality seniors housing and aged care in our community. However, this support does not extend to developments that exploit planning pathways to achieve outcomes that are inconsistent with the established character and planning controls of the local area. This proposal is excessive in height and bulk, relies on an unjustified variation to the building height standard, lacks a committed aged care provider, and bypasses the local planning framework that exists to protect community interests.

I respectfully request that the Department of Planning, Housing and Infrastructure refuse this application, or at a minimum, require substantial amendments to reduce the height and bulk of the development to a scale that is consistent with the North Sydney LEP 2013 and the character of the Cammeray locality.

Objection to SSD 96505456 – Cammeray Seniors Living

I am a local resident and homeowner living directly opposite to the development site. I also have young toddler (under two years old) at home and will be significantly and adversely impacted by this proposal from substantial planning, environmental, cultural grounds and lifestyle wellbeing.

I Strongly OBJECT to this development application for the following reasons:

1. Inappropriate Location Selection

The proposed site is poorly located, with limited access to public transport. Residents would need to walk 15-30 mins to the nearest train station or rely on local bus, neither of which is considered senior-friendly.

The nearby bus stop offers limited routes, primarily catering to city commuters. Nearby essential amenities like shops and medical services are already overstretched, with medical services facing long wait times for patients at the moment. Compared to better-serviced suburbs like Crows Nest or St. Leonard, this site offers no clear advantages for senior living.

The $68 million development cost for 49 units equates to ~$1.4 million per unit, likely pushing unit sale prices to $2.5–3.0 million. This excludes potential cost variations and inflation over the project’s lifespan. Such pricing contradicts the State Significant Development’s goal of providing affordable housing.

2. Design Inconsistency and Negative Aesthetic Impact

Rosalind Street is a quiet street, low-medium density area defined by single and double-story dwellings with Edwin/Victorian/Federation heritage character. The proposed 5-6 storage modern design starkly contrasts with this heritage aesthetic, creating significant visual discord.

This oversized, out-of-scale development will fundamentally alter the neighbourhood’s character, undermining its historical charm and streetscape integrity.

3. Excessive Height, Scale & Privacy Violations

The proposed 18.36m height including roof top equipment height breaches planning limits, creating an overwhelming, non-compliant structure that clashes with our low-to-medium density area. The street has no 5-6 storage buildings. The inadequate setbacks further exacerbate this issue, resulting in a visually dominant and imposing bulk with no sensitive transition to neighbouring homes.

From my property, this design will:
• Directly overlook my backyard and living spaces due to north-facing balconies and habitable rooms.
• Severely compromise my family’s privacy—either seniors are confined to fixed screens (limiting their views and wellbeing), or their ability to enjoy outdoor spaces invades our daily privacy.
• Fail to balance the needs of residents with those of existing homeowners, making it an unworkable design.

This poorly considered layout disregards both planning compliance and basic liveability for all parties.

4. Insufficient Parking and Severe Traffic Impact

The scale of the development will exacerbate existing parking pressures on our local street, which already at the capacity. It will introduce the parking crisis for the local residents:
• The proposed on-site café will attract non-resident visitors, compounding existing parking shortages.
• Essential services for senior living (medical deliveries, food supplies, maintenance, café suppliers) will generate additional traffic.
• Street parking is already at capacity – I frequently must park blocks away due to lack of spaces.

It will also introduce traffic dangers:
• The 49-unit development plus its essential services will create constant additional vehicle movements throughout the day, posing hazards to residents, especially families with young children.
• Emergency vehicle access may be compromised during peak periods.
• The traffic study relies on unvalidated assumptions, making its predictions unreliable.

The local street network already fails to handle current traffic volumes. Adding this development without substantial infrastructure upgrades is both irresponsible and dangerous.

5. Serious Safety Concerns for Young Families

As a parent of toddler under 2yrs old living opposite this site, I strongly oppose this development due to unacceptable risks as below:

Construction Dangers:
• Prolonged exposure to heavy machinery, toxic dust and noise pollution poses direct health risks to developing children
• Daily air quality impacts from construction will affect our children's respiratory health

Traffic Hazards
• Massive increase in vehicles will endanger children walking, cycling or playing
• Inadequate parking will lead to dangerous roadside manoeuvres near our homes
• Residential streets will become unsafe play areas due to constant traffic

Unreasonable Burden on Families
• Forcing parents to use daycare full-time or relocate to avoid hazards creates:
- Significant financial strain
- Developmental harm from excessive institutional care
- Complete disruption of family routines

This development places an impossible choice on young families: compromise our children's health and safety or bear unsustainable costs. Neither is acceptable.

6. Construction Impact

The proposal involves:
- Demolition of multiple existing buildings
- Excavation of dual-levels of basement (substantial earthworks)
- Construction of a 6-storey building
- Construction period likely to extend 18-24+ months

This will result in:
- Extended noise, dust, and vibration impacts on neighbouring residents
- Heavy vehicle movements through residential streets
- Disruption to daily life for surrounding families
- Potential structural impacts on neighbouring properties from excavation
- Reduced air quality during construction

7. Solar Access and Overshadowing

The building’s excessive height and bulk will:
• Cast prolonged shadows over my southern front yard and rear garden, severely reducing sunlight during key daylight hours.
• Deprive my south-facing living area of natural daylight and south-east facing future solar amenity provisioning, fundamentally altering its usability and comfort.

This represents a material loss of my future solar access provisioning, negatively impacting my electricity bill, and the property’s liveability and enjoyment.

8. Environmental Impacts (Tree Loss and Excavation)

The removal of 24 mature trees, including specimens over 50 years old, will cause irreversible environmental harm. These trees currently provide vital green canopy, habitat, and contribute to the microclimate and visual character of our neighbourhood. Their loss from my immediate vicinity will degrade local air quality and biodiversity.

Furthermore, the proposed deep excavation poses risks of subsidence and disruption to the root systems of remaining vegetation on my property.

9. Cultural and Spiritual Amenity Impacts on the Adjacent Cemetery

The development site is in immediate proximity to the Thomas Rest Park, a place of profound cultural, historical, and spiritual significance for our community. The proposed years of intensive construction—involving persistent heavy machinery noise, ground vibration, dust, and increased traffic—will severely disrupt the peace, dignity, and solemnity essential to this sacred space. This demonstrates a complete disregard for the needs of mourners, visitors, and the broader community.

As a Chinese immigrant, I find this proposal deeply disrespectful. Senior living apartments constructed in such an inappropriate location:
• Show disregard for the elderly and their cultural values.
• Risk alienating Chinese buyers, creating perceptions of discrimination.
• Fail to consider the cultural sensitivities of diverse communities.

10. Misuse of Care Room Provisions

The provision of only two care beds, located underground adjacent to service areas, appears to be a mechanism to claim a 25% FSR bonus rather than a genuine commitment to supporting “ageing in place.” This misuse of planning provisions undermines the policy intent and represents a poor planning outcome that offers no real community benefit.

11. Inadequate Community Consultation

The developer’s consultation process was fundamentally flawed:
• No Direct Notification: I was not personally informed of the proposal in a timely manner.
• Reliance on Neighbours: I only learned about the development through informal channels.
• Limited Engagement: Only two information sessions were held, which were insufficient to address technical concerns or demonstrate how community feedback would shape the design.

This lack of meaningful consultation disregards community input and fails to meet basic standards of transparency and engagement.

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Formal Opposition and Relief Sought:

Based on the fundamental planning breaches, adverse community and cultural impacts, and environmental harms outlined above, I strongly oppose this proposal in its current form. I formally request the Department to:

1. Reject the current application based on:
• Exceeds appropriate scale and density for the site and surrounding area
• Fails to provide adequate parking or address existing traffic problems
• Will destroy established trees and wildlife habitat
• Creates unacceptable amenity impacts through overshadowing
• Poses safety risks to local families and children
• Is inconsistent with the natural heritage look of Rosalind Steet at Cammeray

2. Mandate a compliant and transparent community consultation process for any future proposal, ensuring affected residents, children health authorities, cemetery authorities, and cultural stakeholder groups are properly notified and that their feedback is meaningfully incorporated into the design.

In conclusion, the current proposal prioritizes developer profit over community wellbeing, environmental protection, and appropriate planning principles.

I request that this submission be given full consideration in the assessment process and to be kept informed of all future proceedings related to this application.