Objection to SSD Proposal for 11–23 Rangers Avenue, Mosman

I strongly object to the proposed development at 11–23 Rangers Avenue, Mosman. This proposal represents a grossly over-scaled and high-impact development that is entirely out of character with the surrounding low-rise, quiet residential streetscape. The seven-storey structure will dominate views for residents of Holt Avenue, causing loss of skyline outlook, excessive overshadowing, and a profound reduction in the amenity and character of existing homes.

The scale and intensity of this development also pose serious risks to the wider community. Increased traffic volumes, road safety concerns, and cumulative pressure on local infrastructure, which is already near capacity, have not been adequately addressed. The applicant’s walking-distance assessment is misleading: independent analysis clearly shows that safe pedestrian routes to Cremorne Town Centre exceed the 800m limit under the Housing SEPP, undermining the claim that the site is suitable for high-density development.

Critically, the design fails to provide any meaningful transition between the proposed seven-storey massing and the adjoining C4 Environmental Living zone. This zone was deliberately excluded from the LMR for its scenic and environmental value, yet the proposal disregards its protection, causing unacceptable environmental and visual impacts.

This development is excessive, non-compliant, and incompatible with the existing character and planning intent of Mosman. I strongly urge the consent authority to reject this proposal or require a substantial redesign that respects local amenity, environmental protection, and planning controls.

Please see our submission attached

1. The new development puts at risk an increased number of pedestrians who would be required to walk down Spofforth street and cross busy intersections at Cabramatta Rd, Spencer Rd and Holt Ave.
Holt avenue in particular is a "rat run" alternative during peak hours and vehicles seeking to cross Spofforth run a heightened risk of collision. There are accidents at that crossing. I have personally attended such an accident, called 000 and waited for the ambulance to arrive to treat vehicle occupants. Pedestrians are of course even more vulnerable as they are both less visible and less protected.
2. The development will add even more vehicles and will heighten risk to other travellers and residents.
3. The development represents a threat to the character of the Holt Avenue Estate Heritage Conservation area. The impact on the landscape and sight lines are significant for the residents and those who visit the area. The area is famous for federation style houses framed by large trees. The presence of a looming multi storey residential development taller than those trees undermines heritage of Holt Avenue which has been preserved for more than a hundred years.
Please do not approve this development.

The project also involves extensive excavation, tree removal, landscaping and infrastructure works, fundamentally reshaping what is currently a quiet, low-rise streetscape and replacing it with one of the largest and most visually dominant buildings ever proposed for this part of Mosman.

This is a substantial, high-impact development on a narrow and heavily constrained section of the suburb. For residents of Holt Avenue, the seven-storey structure proposed across their rear boundary would result in a significant change to their outlook, including loss of existing skyline views, increased overshadowing and a marked shift in the character and amenity of their homes.

Beyond the visual and residential impacts, the scale and intensity of the proposal raise broader concerns for the wider community, particularly regarding road safety, increased traffic volumes and cumulative pressure on local infrastructure that is already operating near capacity.

Additionally, several core planning issues raised by residents and experts remain unresolved. The applicant’s walking-distance assessment places the site within the LMR Outer Area, yet independent analysis indicates that safe pedestrian routes to Cremorne Town Centre fall outside the required 800m distance under the Housing SEPP. The design also fails to provide any meaningful transition between the proposed seven-storey massing and the adjoining C4 Environmental Living zone, which was intentionally excluded from LMR due to its scenic and environmental value.

I am a local resident living behind the proposed development and use Rangers Avenue daily. While I support more housing, this proposal is unsuitable for this location due to its scale, context impacts, safety risks and untested assumptions.

1. Excessive height and bulk – proposal is fundamentally overdeveloped

The seven-storey form represents a drastic departure from the established one- to two-storey character of this prominent ridgeline. Even with the bonus height under the Housing SEPP, the Clause 4.6 variations seek an envelope that clearly exceeds what the site can reasonably accommodate.

The proposal would visually dominate Rangers Avenue and adjoining properties, contrary to the objectives of the height controls and Scenic Protection Area.

FSR compliance does not justify the bulk

Although the scheme complies with FSR, this does not determine whether bulk, scale and visual impacts are acceptable. FSR only controls the quantum of floor area, not its arrangement, dominance, overshadowing or design merit.

The Land and Environment Court has repeatedly found that compliant FSR developments can still be unacceptable where the perceived bulk is inappropriate. Here, achieving an appropriate scale would require meaningful removal or redesign of upper levels — a sign of overdevelopment, not marginal variation.

Non-GFA mass contributes significantly to perceived bulk

Lift overruns, rooftop plant, hot water systems and communal circulation spaces are excluded from GFA but materially add to the building’s bulk and dominance on a visually sensitive ridgeline.

2. No transition to C4 Environmental Living or Scenic Protection Areas

The proposal places maximum height directly beside C4 Environmental Living land and Scenic Protection Areas — zones intentionally excluded from Low- and Medium-Rise Housing reforms because of their scenic and environmental values.

Despite this, the design provides no meaningful transition. The upper levels read as a single dominant mass from protected viewpoints, undermining the intent of the surrounding zoning and scenic protections.

3. Streetscape and heritage impacts

Replacing seven fine-grain dwellings with a single continuous building creates an abrupt and inappropriate shift in scale. The development does not provide a respectful transition to the Holt Estate Heritage Conservation Area and disrupts the established rhythm of the street.

This directly conflicts with the scenic and heritage context, which should constrain rather than absorb intensive redevelopment.

4. Pedestrian access issues and inappropriate reliance on laneways

While Appendix GG demonstrates that the site may meet the 800-metre requirement via Rangers Avenue, the EIS and Traffic Impact Assessment rely heavily on an alternative route via Bloxsome/Bardwell Lane to justify walkability and connectivity.

This laneway:

* has no footpath,

* is used primarily for garage access,

* is not a practical or safe pedestrian route.

Using this laneway to support broader accessibility claims overstates walkability and does not reflect real conditions. Although the distance may comply, the quality and safety of pedestrian access is misrepresented.

5. Structural parking constraints on Holt Avenue

Many Holt Avenue homes lack off-street parking because they do not have rear-lane access on the north side, and Mosman Council generally does not approve new garages or carports in this locality. On-street capacity is already saturated and cannot be expanded.

Any overflow parking from the development — residents, visitors or servicing — will exacerbate a situation with no feasible mitigation.

This structural, permanent constraint is not addressed in the EIS.

6. Traffic and pedestrian safety on Rangers Avenue

Rangers Avenue experiences heavy congestion during school and commuter peaks and is frequently used by pedestrians, particularly students.

Consolidating all vehicle access, service bays and waste collection into a single frontage increases risks of:

* vehicle-pedestrian conflict,

* queuing,

* reduced visibility,

* congestion during peak periods.

The Transport Impact Assessment does not adequately address these issues.

7. Significant excavation and geotechnical risks

The proposal involves two basement levels excavated into porous sandstone, extending across nearly the full site and up to Bloxsome Lane. This creates a deep void beneath both Rangers Avenue and Bloxsome Lane, adjacent to a cliff face.

Key risks include:

* destabilising the public road,

* rockfall or progressive slips,

* undermining neighbouring properties,

* altering groundwater movement,

* increased seepage and long-term structural impacts.

Historical mapping indicates a former waterfall near the site, suggesting natural water movement that excavation could disrupt. The EIS does not include a detailed geotechnical assessment demonstrating these risks can be safely managed.

Given recent stability failures across Sydney ridge sites, this is a serious unresolved issue.

8. Urban design shortcomings

The building presents as a monolithic and visually dominant form with limited modulation and little human-scale interface. The public-domain outcome is weak, and the reliance on the laneway to support urban design and access narratives highlights inconsistencies in the design logic.

9. Methodological weaknesses in the visual impact assessment

The visual assessment relies on selective, desktop-generated views rather than field-verified photomontages. There are no surveyed viewpoints, no heritage-focused sightline analysis, and minimal assessment of perceived bulk from surrounding homes and public viewpoints.

These methodological gaps undermine confidence in the EIS conclusions.

10. Overshadowing impacts not properly evaluated

The overshadowing diagrams do not assess impacts on individual dwellings to the south and west, where steep topography will extend winter shadows and reduce solar access to existing homes.

11. Privacy and overlooking impacts

Upper-level balconies and windows introduce new opportunities for overlooking into nearby dwellings and private open space. No meaningful mitigations are proposed.

12. Construction impacts underestimated

The Construction Traffic Management Plan does not adequately address spoil removal, truck movements or conflicts during school-peak pedestrian periods.

13. Limited and time-bound affordable housing benefit

The proposal provides 10 affordable units (15% GFA) for only 15 years — a modest, temporary benefit compared with the significant and permanent uplift in development potential being sought.

Requested outcome

For the reasons outlined above, the proposal:

* is excessively tall and bulky for a sensitive scenic and heritage-adjacent environment,

* fails to transition appropriately to C4 and Scenic Protection Areas,

* misrepresents pedestrian connectivity by relying on a service laneway,

* exacerbates structural parking and traffic constraints with no mitigation,

* presents significant excavation and geotechnical risks, and

* is supported by incomplete or weak assessment methodologies.

I request that the Department:

1. Refuse SSD-96272465; or

2. Require a substantial redesign that:

* reduces height and bulk,

* introduces a genuine transition to C4 and Scenic Protection Areas,

* removes reliance on Bloxsome/Bardwell Lane as a pedestrian route,

* addresses traffic and parking constraints, and

* provides a detailed and independent geotechnical assessment.

Thank you for considering this submission.

I strongly object to the development of 11 - 23 Rangers Avenue for the following reasons:
* the excessively tall and large structure will be a blot on the landscape, for many kilometres around, not at all in keeping with surrounding homes.
* the unnecessarily enormous building, will create problems of over- shadowing for multiple homes.
* the added number of vehicles will significantly add to already heavy traffic flow in access and nearby streets.
* this development is at a greater distance from a transport hub, than stipulated in the new State Planning Legislation.
* the eradication of all these Federations style homes, means another large chunk of Mosman’s heritage is lost forever.
*residents of extensively renovated homes in Holt Avenue, will lose their city views
* the planned units/apartments will cost way over what is considered’affordable. housing’.
* the developers, not the current Mosman residents, are the only ones being considered with this totally unsuitable structure.
As our elected Council, I urge you to put your electorate and rate paying residents first, in doing all in your power to stop this appalling development.
Jane Edwards

I strongly object to the proposed SSD at 11-23 Rangers Avenue, Mosman, based on the following:
1. Lack of community engagement prior to the lodgement of the SSDA.
Appendix P of the engagement outcomes report, has a map of the near neighbour distribution area, to which a letter was reported to be distributed to allow enquiries and feedback. I live at 46 Holt Avenue and am in the area of distribution but I did not receive a letter. When I became aware of this development, prior to the SSDA lodgement date, I contacted Urbis to request a meeting to discuss my concerns. I was offered a zoom meeting with other residents that was scheduled for 3/12/25 and then rescheduled by Urbis for the 10/12/25, after the lodgement of the SSDA.
2. Location of properties 11-23 Rangers Avenue are outside the LMR Outer Area
The safe walking route, required by the Housing SEPP, puts the properties at 11-23 Rangers Avenue, outside the LMR outer area. The walking route used in the SSDA has the pedestrian crossing at the intersection of Holt Avenue and Spofforth Street. This route was determined by a surveyor as safe but are surveyors qualified to determine what is adequate pedestrian safety? As a resident of Holt Avenue for more than 7 years, I have never crossed at this intersection as I feel it to be unsafe. It is a rule in our family of 5 that no one is to cross at this intersection when walking to Cremorne Town Centre. The Harrison-Bennett Precinct has documentation, including photos, of 30 accidents (as reported by residents so not comprehensive) that have occurred at the Holt Ave Spofforth Street intersection since 17/03/2018. A safe walking route would involve crossing at the pedestrian crossing at 78 Spofforth Street or at the pedestrian crossing at the lights at the junction of Spofforth Street and Military Road. This route puts the properties 11-23 avenue Road outside the LMR Outer Area and on this basis alone, the SSDA should be denied.
3. No build form transition between C4 and R3 zones
Holt avenue was excluded from the LMR due to its environmental and scenic values. The EIS in this application states that “the design has been carefully modelled so it sits comfortably within its setting and that the transition in height is managed in a contextually responsive way”. I see no such transition when I look at the proposed build. This proposed development is using the LMR housing provisions and the in-fill affordable housing provisions to build a development with excessive bulk and scale without consideration of the historical significance of the site or the adjacent C4 zone.
4. Inadequate visual impact statement & view loss and view sharing assessment
The proposed development site is within the Scenic Protection Area, as is Holt Estate to the north of the proposed development. Holt Avenue is a beautiful tree lined street and this development will forever change the natural landscape and landform of the area. This warrants a revised Visual Impact Statement that would include an analysis from the north of the proposed development. In addition, Figure 36 viewpoint 06 photomontage in the EIS, suggests that the proposed development would result in a significant visual impact from Mosman Bay (Sydney Harbour). With regard to view loss and view sharing, Urbis failed to address the many questions raised by local residents and informed us, at the meeting post lodgement of the application, that the view loss and sharing assessments were done on desk top. Out of courtesy, they should have asked near neighbours how they would be impacted and conducted an on ground assessment. My property is not directly behind the proposed development but our outlook to the East from our living area and kitchen will be occupied by the proposed development. Neighbours directly north of the proposed development will be greatly affected.
5. Negative impact on heritage character
The proposed development will be a permanent backdrop to the historic Holt Estate Heritage Conservation area. The application states that “it’s significance has been diminished by modifications, which have catered to the requirements of individual owners’ amenity at the cost of respecting heritage values”. In fact, many of the homes on Holt Avenue are identified by Mosman Council as being “contributory” to the heritage character of the area. The architectural design of the proposed development does not lessen the impact it will have on this protected area of Mosman.
6. The intent of the SSD policy is not met
The affordable housing policy is facilitating the development of luxury apartments on a site clearly chosen for its uninterrupted views of the Sydney CBD and Harbour. This proposal is not about long term affordable housing, it’s about lining the pockets of developers, who couldn’t care less about providing affordable housing to society, including our incredible essential workers. I was appalled to learn that this proposed development has the affordable housing located in the east wing with a separate foyer and lift access from the rest of the tenants. At our zoom meeting with Urbis, they downplayed the separate foyer by telling us that it was the larger than the foyer for the rest of the building. This form of social segregation is outrageous and needs to be addressed. This is not a precedent we should condone in Australia, where integration is key.
7. Concerns around the excavation not addressed
The site excavation raises a few concerns. The application does not disclose the amount of sandstone, rock and soil that would need to be excavated. The EIS reports a proposed basement carpark that would be approximately 10m deep, suggesting a significant removal of earth from the site. There is no reference to the cliff edge on Rangers Avenue or any impact that the proposed excavation could have on the stability of Rangers Avenue or the properties on Holt Avenue. There is currently a 3T vehicle limit on Rangers Avenue. How will this excavation and build be conducted using Rangers Avenue given the 3T limit? It’s difficult to understand how the use of the proposed vehicles, listed in the Construction Traffic Management Appendix W, would be allowed on Rangers Avenue given the 3T vehicle limit and that they would be travelling on this road at high volumes for a long period of time. The Department of Planning needs to organise a geotechnical review to address these issues.
8. Traffic and parking concerns
Traffic and parking concerns have not been adequately addressed in this application. The traffic report does not address peak times and does not include Spofforth Street. As a resident of Holt Avenue, it is already a challenge to get a park near my home on weekdays. It’s also a challenge trying to get out of Holt Avenue and onto Spofforth Street at peak times. I can only imagine the chaos that will ensue should this application be accepted.
I ask that the Department of Planning takes into account my concerns and denies this application.

I object to the proposal on the grounds raised in the attached document.