This overly large development is totally unsuitable to Katoomba, the upper mountains and the geographic location.
The upper mountains relies on eco toursim, this development will negatively impact one of the main tourist drives along the escarpment. It will also be clearly seen from many lookouts and bushwalks thus negatively impacting the natural bush horizon tourists come to see. It is far too high (too many stories) and visually dominant.
It is also putting far too many people in harms way, directly at the top of an escarpment prone to severe bushfires.
It should not go ahead in its present form.

Submission opposing the Development proposal
for 142-150 Narrow Neck Road. Katoomba.


My name is Peter Lammiman, I live at 11 Martin Street, Katoomba, where I have lived since 2009. I have been visiting the Blue Mountains for over 40 years for recreational purposes as well as visiting friends.

Over the decades I have witnessed the growth of visitors to this wonderful natural bush land area. Access has made travel easier by the widening of the Great Western Highway, facilitating a massive increase in visitors to the Mountains.

People travel here to experience the World Heritage Blue Mountains National Park; recognised for its environmental uniqueness, with Katoomba, one of the few cities in the world situated in the national park.

With this in mind when I read about the proposed development for 142-150 Narrow Neck Road, Katoomba I was concerned about the size, scope and purpose of the developers proposal. Such a project is being made in an already environmentally sensitive area under-threat.

The development poses a number of important questions about its impact on our environment and community; who will it serve; the projected scale is larger than anything currently permitted in the Blue Mountains and well outside the existing Blue Mountains Local Government Environmental plan for housing/commercial development.

This proposal fails to take into account the affect it will have on a highly sensitive environment in a UNESCO World Heritage location, where there exists a variety of vulnerable habitats including unique forested areas, water courses and hanging swamps.

The implications of this proposal has serious environmental impacts. Having to clear the site of such size will have irreversible outcomes, including destroying wildlife habitat through loss of vegetation and affecting the current water run off and increasing soil erosion.

The development site is in a bush fire prone area with limited evacuation access and exits. There is no public transport to my knowledge.

One must question the massive impact locally through increased traffic as well as demands on other already stretched local resources that such a large residential complex of 214 apartments, 53 serviced apartments and commercial outlets would have.

There is no doubt about the detrimental effect of this development on my community.

We desperately need affordable/social housing for nurses, hospitality workers in Katoomba, I don’t believe the 15% set aside of the total accommodation will meet Katoomba’s social/affordable housing needs.

I understand this figure is set by the NSW government and applies only for a specific period before changing the low cost housing allocation back to commercial market properties rates.

To conclude, I strongly oppose the proposed development at 142-150 Narrow Neck Road, Katoomba for the reasons outlined above. If you need to contact me to clarify any part of my submission please contact me on 0410153157.

Peter Lammiman.

I received no consultation on this project in th 5 years I have lived at my address within a 1 km of the site. The plans are too large and outside the character and nature of the area. Katoomba is a town inside a nstional park, not a residential suburb of metropolitan Sydney. Finally the site has ecological value which would be threatened by overdevelopment of the area. Nearby there is land and develilopment off Stuarts and Wellington Roads which has not sold or been utilised. Traffic management and infrastructure in the area is unsuitable.

I am opposed to the development of natural land at 142–150 Narrow Neck Road, Katoomba.
I have been a resident of the Blue Mountains for 30 years. I moved here because Western Sydney had become a soulless expanse of new developments and housing. Katoomba offered something unique and beautiful.

The development proposal for 142–150 Narrow Neck Road, Katoomba represents everything I moved away from — the soulless and unattractive overdevelopment of land. This project, proposed under the claim of “affordable housing,” is misleading. The proposal is a farce — a contradiction, or simply a plan built on a false premise. It is being presented as a Housing Delivery Authority (HDA) project; however, it appears more like a resort-style development for the wealthy. What first-home buyer could afford escarpment views? This is not designed for low-income earners or first-home buyers, with only 15% allocated to affordable housing and the remaining 85% clearly intended for affluent purchasers.

There are many more appropriate locations for high-density housing developments. For example, along the Great Western Highway from Penrith to Kingswood. These areas offer access to public transport, established road networks, local employment opportunities, hospitals, schools, proximity to the new airport, and sufficient land to accommodate multiple four-storey unit blocks, along with restaurants and businesses. Much of this land is currently vacant and overgrown. Another suitable location for high-density housing would be along High Street, Penrith, particularly above existing shops. This could revitalise what is currently a lifeless and underutilised strip, transforming it into a vibrant and active area. An influx of residents could stimulate local businesses, create employment opportunities, and contribute to a more dynamic community in a location already supported by infrastructure. Narrow Neck Rd, Katoomba is the wrong location for any development. It has minimal facilities which makes this proposed development untenable. The location of the proposed development has one road and can become congested with increased traffic and population and would be problematic during an emergency such as a bushfire with people needing to evacuate which happens all too often in the Blue Mountains. The natural environment is what the tourists want in Katoomba and not large resort style accommodation.

Why is this development being proposed in a World Heritage-listed region with a unique and sensitive landscape — one that attracts tourism from around the world? This development would be visually intrusive, out of character, and fundamentally inappropriate, driven more by profit than by planning merit. It would have a devastating impact on the local environment, including sensitive flora and fauna. This includes the hanging swamps, unique plant species, and migratory birdlife such as the Regent Honeyeater, which relies on spotted gum trees in this area. The Narrow Neck plateau should remain a place for all people to visit and enjoy.

The Minns State Labor Government should reverse the previous Liberal Government’s policy of bypassing local council planning processes, which has enabled too many inappropriate developments across the Sydney region. Many suburbs have already lost their character — for example, Parramatta, with its significant loss of heritage. Now, the Blue Mountains risks losing its own natural beauty. The Blue Mountains should also be exempt from the Housing Delivery Authority (HDA) policy.

There must be greater respect for the natural environment, as well as for the character and heritage of local communities, rather than allowing inappropriate developments driven by corporations whose primary interest is profit over environmental protection.

A concerned resident of Katoomba. Glenda Van Dyk
40 Lett Street
Katoomba, 2780, NSW
MOBILE: 0498351357

I strongly object to this proposal. It is completely out of keeping with the Blue Mountains, with the World Heritage Area, and with the wishes of the local inhabitants. The scale might not look out of place in Parramatta or central Sydney but in the midst of an area millions of tourists visit annually in order to enjoy the beauties of nature, it is an eyesore that will detract significantly from the value that the Blue Mountains embody for people from all around the world.

The idea that the buildings are going to provide accommodation for permanent residents is a bad joke. Only 15% of the complex is made over to what they call 'affordable housing'. The rest is serviced apartments for tourists. We already have masses of BNBs here - more than are needed for the accommodation of visitors. It is an important source of income for many local residents who can ill afford to have their small businesses undermined by large and wealthy companies like this one.

The land on which this development is to be built already offers accommodation to local residents, the echidnas and snakes and lizards and marsupials and plants that live in the bush these people are proposing to destroy. They have no voice, no say in the matter but it is their home. They have no other.

To propose a development on this scale so close to the western escarpment from which direction the prevaling winds bring the fires at a terrifying speed is simply insane. Are our firefighters, local volunteers, expected to risk their lives to protect such a monumentally foolish and greedy excrescence? Have you already forgotten the fires of 2019-2020? Evacuation orders were put in place on Narrowneck Road and Cliff Drive for weeks. Where do you propose that these people go? With climate change fires will become fiercer and more frequent. The Blue Mountains is the most fireprone area in the world. This development makes no sense at all.

Local residents live here because they love it. If they wanted to live in a city or in an area full of apartments there are plenty of places to choose from. Why should the wishes of non-resident business people with cash to throw around always be put before the wishes and amenity of the local community? This is not a rich town but we love it and we live in a close and supportive community. We feel for the people and animals who will be most affected by this. We feel for the loss of our unique and fragile environment. We feel it deeply.

There are already empty buildings in the town centre, blocks of flats boarded up, the Renaissance Centre left to rot away, places that are eminently suitable to provide affordable housing, are not in bushfire zones, and would not destroy bushland. These are the places that the developers should be reviving, beautiful old buildings that would be a joy to live in. This would be of benefit to the community. Why is it not being done?

In conclusion, I believe that you should be following our council's painstakingly prepared local environment plan and the representation of our local members who speak for our community, and immediately rejecting this wholly unsuitable and unnecessary development.

Yours faithfully etc.

I object to this proposal as it is not a good fit for the area. The height of the development is not in keeping with the local skyline and is an eyesore for the area. They increased traffic and environmental footprint has not been fully accounted for. There are sites that are more suited closer to the train line that require redevelopment. This is purely a money grab by a property developer with no thought whatsoever for the local community. This is a bush fire prone area.

I have lived opposite near the proposed high-density development for 46 YEARS ! When I saw the the proposal I vomited from stress. This monstrosity is something that breaches every environmental code of World Heritage Area and Blue Mountains Local Environment Plan 2015. The person who proposed this must immediately seek psychiatric help from any of our local psychologists. Few suggestions: Heather Andonicos, Maria Taylor, Jade Sullivan from Wentworth Falls.

**Submission in Opposition to Proposed Multi-Storey Development – Narrow Neck, Katoomba**

This submission raises significant concerns regarding the proposed construction of nine multi-storey buildings at Narrow Neck, Katoomba. The proposal presents substantial risks and unresolved issues across cultural heritage, environmental sustainability, public safety, and essential service capacity. The following matters require formal investigation, evidence-based assessment, and community consultation prior to any approval.

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### 1. Aboriginal Cultural Heritage and Legal Obligations

The proposed development site is located along recognised Aboriginal songlines of cultural and spiritual significance, including associations with men’s initiation practices. These areas hold ongoing importance to Aboriginal and Torres Strait Islander communities.

There is insufficient evidence that appropriate consultation has occurred with relevant Traditional Owners, Elders, and knowledge holders. This includes, but is not limited to, representatives connected to The Gully and surrounding communities.

The proponent must demonstrate compliance with applicable cultural heritage legislation and duty of care obligations, including:

* Formal cultural heritage impact assessments
* Documented consultation with recognised Elders and custodians
* Measures to avoid or mitigate harm to sacred sites and intangible heritage

Failure to adequately address these matters may constitute a breach of legal protections for Aboriginal cultural heritage.

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### 2. Bushfire Risk and Emergency Management

Narrow Neck is a known bushfire-prone area with a single primary access route. The proposed increase in population density introduces heightened risk to life and property.

Critical concerns include:

* Absence of a clearly defined and tested bushfire evacuation plan
* Increased strain on local Rural Fire Service (RFS) and emergency response capacity
* Suitability of building design in a high-risk fire zone, including materials, fire suppression systems, and compliance with bushfire construction standards
* Consideration of resident preparedness, particularly for individuals without prior experience in bushfire-prone environments

Further, clarification is required regarding:

* Current and future insurability of properties in this location
* Potential implications of increased development on insurance coverage availability and cost

A comprehensive bushfire risk assessment and emergency management strategy must be provided and independently reviewed.

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### 3. Impact on Local Health and Community Services

The Blue Mountains region, including Katoomba, already experiences significant limitations in healthcare and support services.

Existing constraints include:

* Limited capacity at Katoomba Hospital
* Shortage of general practitioners, with many clinics not accepting new patients or not offering bulk billing
* Lack of urgent care facilities and 24-hour pharmacy services
* Strain on aged care, disability, and mental health services

The addition of approximately 200 new residents will exacerbate these pressures.

The proponent must provide:

* A service impact assessment addressing health, aged care, disability, and community support systems
* Evidence of planned investment or integration with existing services to accommodate increased demand

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### 4. Environmental Impact and Ecosystem Integrity

The development site is located within a sensitive natural environment that contributes to the ecological and cultural significance of the Blue Mountains.

Key concerns include:

* Potential damage to native ecosystems, flora, and fauna
* Risks associated with unstable rock formations and landslide susceptibility
* Long-term environmental degradation due to increased human activity

The community requests:

* A full environmental impact assessment (EIA)
* Independent ecological studies and recommendations
* Transparency regarding whether such assessments are legally required and, if not, justification for proceeding without them

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### 5. Impact on Local Economy and Outdoor Recreation

The Blue Mountains economy is closely tied to outdoor recreation, including hiking, mountain biking, and climbing. These activities support local businesses and contribute to the region’s identity.

The proposed development may:

* Disrupt access to recreational areas
* Alter the natural landscape that attracts tourism
* Negatively impact businesses reliant on the area’s environmental character

An economic and social impact assessment is required to evaluate these risks.

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### 6. Built Form, Visual Impact, and Heritage Character

The scale, height, and design of the proposed multi-storey buildings are inconsistent with the established character of Katoomba and the surrounding landscape.

Concerns include:

* Visual intrusion on scenic views and tourist attractions
* Incompatibility with the historic and low-density nature of the area
* Diminished amenity for existing residents and businesses

The proposal must demonstrate alignment with local planning controls, heritage considerations, and community expectations.

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### 7. Traffic, Infrastructure, and Road Safety

Local road infrastructure is not designed to accommodate significant increases in traffic volume.

Issues include:

* Increased congestion in a small town setting
* Safety risks associated with limited access routes
* Additional pressure following the indefinite closure of Mt Victoria Pass

The proponent must provide:

* A traffic and transport impact assessment
* Costed infrastructure solutions and funding commitments
* Analysis of long-term road safety implications

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### 8. Required Investigations and Community Consultation

Prior to any determination, the following must be completed and made publicly available:

* Environmental impact assessment and ecosystem analysis
* Cultural heritage assessment with documented Aboriginal consultation
* Health and community services capacity review
* Bushfire risk assessment and emergency response evaluation
* RFS and emergency services capacity analysis for increased population
* Traffic and infrastructure impact study, including funding strategies
* Confirmation of compliance with building and bushfire safety standards

Meaningful community consultation must be undertaken, ensuring transparency and inclusion of local stakeholders.

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### Conclusion

The current proposal presents unresolved risks across multiple critical domains. In its present form, it lacks sufficient evidence, planning, and consultation to demonstrate that it can proceed without significant harm to the community, environment, and cultural heritage.

Approval should not be granted until all identified concerns are comprehensively addressed through independent assessment, legal compliance, and genuine consultation with community.

Statutory Non-Compliance and Legal Concerns
Under s4.15 of the Environmental Planning and Assessment Act 1979 (EP&A Act), a consent authority must consider environmental, social, economic impacts, site suitability, and public interest. The proposal fails to adequately address these mandatory considerations and is therefore not lawfully supportable in its current form.
Aboriginal Cultural Heritage
The site is within an area of cultural significance, including songlines and ceremonial associations. Under the National Parks and Wildlife Act 1974, harm to Aboriginal objects or places without an AHIP is a criminal offence, with strict liability applying. The Aboriginal and Torres Strait Islander Heritage Protection Act 1984 may also apply. No Cultural Heritage Assessment Report, AHIP pathway, or evidence of consultation under the Aboriginal Cultural Heritage Consultation Requirements 2010 is provided. This represents a failure of due diligence and exposes the proposal to legal invalidity.
Bushfire Risk and Site Suitability
The land is bushfire-prone under the Rural Fires Act 1997. A Bush Fire Safety Authority is mandatory. Compliance with Planning for Bush Fire Protection 2019 and AS 3959 Construction of Buildings in Bushfire-Prone Areas is not demonstrated. The single access route presents a critical evacuation constraint, raising unacceptable risk to life and questions of suitability under s4.15 EP&A Act. Asset Protection Zones, defendable space, emergency access, and water supply remain unaddressed.
Environmental and Biodiversity Impact
Assessment is required under the Biodiversity Conservation Act 2016 and EP&A Act. A BDAR is required where thresholds are exceeded. The Environment Protection and Biodiversity Conservation Act 1999 may be triggered due to proximity to World Heritage values. Impacts on threatened species, ecological communities, and geotechnical stability (including landslip and rock failure) are not properly assessed, creating legal vulnerability.
Infrastructure, Services and ESD
s4.15 requires consideration of infrastructure capacity and social impacts. The proposal fails to demonstrate adequate provision for health, emergency, aged care, disability, and community services, and provides no Social Impact Assessment. This is inconsistent with Ecologically Sustainable Development principles embedded in the EP&A Act and strategic alignment with regional and local planning frameworks.
Planning Controls and Built Form
The proposal has not demonstrated compliance with the Blue Mountains Local Environmental Plan 2015, including height, density, scenic protection, and character provisions. Visual impact and incompatibility with the established built and natural environment remain unresolved.
Traffic, Access and Safety
The EP&A Act requires assessment of transport impacts. No adequate Traffic Impact Assessment is provided. Increased traffic, constrained roads, and limited evacuation routes present unacceptable safety risks. Infrastructure contributions under ss7.11/7.12 EP&A Act are not addressed.