When comparing the original approved design (D/2022/139 from April 2024) to the current exhibited design, there are significant variations that change both the size, structure, character and the aesthetics of the buildings. The changes include:
A RL height increase from 57.9 to 85.47 - an increase of 48%
A GFA increase from 20,545 to 33,036 - an increase of 61%
an increase from a height floor height of 14 floors (basement to roof) to 26 floors (basement to roof), including two new basements, a mezzanine, a plaza and additional laneway
a reduction in communal space from 1600m2 to 1159m2 (a decrease of 28% and less than the required 25% of total space)
a completely redesigned roof structure that is obtrusive and unmatched by the original design
and yet the design excellence uplift of 10% has been retained, and this structure is considered to be of equal design excellence. There are major areas of the design still waiting clarification (solar, noise, venting) and many areas left to the developer to determine (demolition waste, traffic). The allowed uplift is excessive and unsupported by the changes in the design and the variance still required to permit the excessive height of the buildings. The design should be rejected until it meets the required standards, adheres to the height, gfa and other required limitations imposed by the site and the surrounding area.

Position

I object to the application in its current form and request refusal, or approval only with enforceable conditions that keep all built elements within the approved concept RL envelope, address street‑level wind safety so pedestrians are not exposed to hazardous conditions, coordinate construction traffic across overlapping precinct projects, and secure a genuine, durable affordable housing outcome tied to the uplift claimed.​

Height and envelope compliance

The concept consent established specific reduced levels (RLs) as the operative height envelope to balance uplift with neighbourhood amenity, and detailed design should not exceed those RLs unless independent verification proves no additional external impacts, which is not demonstrated in the current material.​

Conditions are requested to cap all crowns and plant within the concept RLs shown on the approved drawings, prohibit roof overruns/ancillary accretions, and require independent certification of as‑built RLs before Construction and Occupation Certificates, with refusal if exceedances are necessary to achieve the proposed yield.​

Street‑level wind safety and comfort

The Pedestrian Wind Assessment records exposed corners and edges with Lawson comfort classifications at “Pedestrian Walking/Business Walking” and identifies exceedance locations including an “Able‑Bodied” safety exceedance, yet it concludes no mitigation is required and relies on landscaping that the report itself cautions is an unreliable primary control in high winds.​

Conditions are requested for a wind‑tunnel addendum focused on street‑edge hotspots (William/Forbes and William/Dowling corners, plaza entries, and through‑site links), a pre‑CC mitigation plan specifying hard controls (canopies, screens, baffles) rather than trees, 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 substantial heavy‑vehicle movements across demolition, excavation and superstructure phases with off‑site worker parking, creating risks of queuing/idling, diesel emissions and vibration on narrow local streets immediately adjoining The Horizon.​

The EIS acknowledges other major projects in the catchment but defers coordinated staging, haulage windows and traffic control to later plans, which is inadequate for overlapping programs on William/Victoria Street corridors.​

Conditions are requested for a precinct‑wide cumulative Construction Traffic and Pedestrian Management Plan with Council/TfNSW, capped heavy‑vehicle rates by stage, haulage windows avoiding commuter and school peaks, a prohibition on layover/queuing on Forbes, Judge and Dowling, mandatory baseline counts and peak (including Saturday) intersection analysis, a contractor travel/parking plan, and Horizon‑specific dilapidation and vibration monitoring with stop‑work thresholds and make‑good obligations.​

Affordable housing uplift: feasibility, durability and public benefit

The EIS relies on the in‑fill affordable housing pathway to justify a materially larger envelope and density but provides limited transparency on deliverability under current cost and funding conditions, distribution and mix of affordable dwellings, and mechanisms to ensure genuine affordability and management quality through the nominated period.​

Conditions are requested for a binding Affordable Housing Delivery and Management Plan fixing the minimum yield, mix, dispersion and rent setting against moderate‑income bands with 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; require a post‑uplift public benefit statement quantifying net additional affordable dwellings relative to a compliant non‑uplift scheme.​

Public domain safety and management

Given recognised safety risks and the introduction of 24/7 links, lifts and a new park, CPTED and operational measures should be embedded now rather than deferred to future plans.​

Conditions are requested for a Social Impact Management Plan and detailed Plan of Management prior to CC fixing lighting to Australian Standards, CCTV coverage, transparent lift walls to public areas, security staffing levels and incident reporting in consultation with NSW Police for at least three years post‑occupation.​

Determination request

Refuse the application, or approve only with the condition suite above 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 credible, durable public benefit that justifies the intensity sought.

I support affordable housing and appropriate development.
This needs to be well thought out and planned to ensure that poor decisions are not made.

Variation to Building Height and Floor Space Ratio
The proposed building height increase compared to the Development Application of 2022 is very significant and unreasonable. The applicant is taking advantage of the current political climate, which looks favourably on an affordable housing component. The applicant proposes a height greater than the bonuses in the Housing SEPP permit and the DA relies on a clause 4.6 variation request in respect of both height and FSR limits referred in Sydney LEP 2012 plus the 30 per cent bonuses allowed by the Housing SEPP.

Traffic Impact
The Transport Impact Assessment is simplistic and unconvincing. Simulation is required to give a realistic indication of the impact. The situation in Kings Cross, Woolloomooloo, Darlinghurst, Potts Point and Surry Hills with regard to e-bikes and delivery bikes is already unmanageable. The addition of these multi-story buildings will increase the number of delivery e-bikes significantly, resulting in a major impact on traffic flow.

Community Engagement
The consultation with the local community has been very poor. Additionally, the time period to respond to the notification letter of 27 October 2025 is very short. The letter was received several days later and the period to respond is less than the normal 30 days notification.

This project should be approved, due to its extensive merit. In the midst of an ongoing and worsening housing crisis, the only reasonable response is to approve a high quality development like this.

Furthermore, with more than 25% affordable dwellings as a part of the project, it can provide immediate relief to people who need it. Additionally, we know from research that supplying market rate housing also reduces pressure on housing costs for all, so this strikes an excellent balance.

Additionally, the retail and public domain improvements that will come from this project make it a very attractive project. The land on William St this development will occur on is currently low value, this will bring much needed improvements.

Whilst I question the necessity of providing so much parking in an area that is served by excellent public and active transport links, this is not a reason to reject the plans as submitted.

And while variations are necessary to both FSR and building height, these should be accepted, as City of Sydney’s development controls for this site are already too restrictive. As we’ve seen in the recent Grattan Institute report “More homes, better cities”, any delays to a project, especially one of this magnitude will have significant costs. As the Premier has made clear, we need to deliver more housing, as NSW has simply not built enough over the last few decades.

While not within the scope of this project, the state government needs to start to give serious thought to restricting traffic volumes on William St. For years we’ve been promised a more pedestrian and bike friendly street, yet these promises continue to come to nought.

It is essential to approve this project, thinking not only about current residents, but those who will have more access to housing as a result. Even if I never live in this development, I look forward to being able to spend time in the public domain that it creates, and that it makes Woolloomooloo and Sydney more broadly an even greater city.

I made a submission objecting to the updated project details, but also wanted to include a request for a visual impact statement, which I have also submitted to Michelle Niles from NSW planning. Please see attached. Thanks

Please see attached letter of objection to this development. Thanks