I attach a full submission to allow photos. In summary my key concerns are:
1. Visual and heritage impacts on the Holt Estate Heritage Conservation Area (HCA), including loss of established city views and inadequate visual impact assessment.
2. Excessive bulk, height, and scale, with no meaningful transition to the surrounding single and two storey dwellings. Monolithic structure will present as a "wall" behind existing single dwellings.
3. Overshadowing of existing properties across Rangers Avenue due to the extended height.
4. Traffic congestion and inadequate transport planning, particularly along Avenue Road, Holt Avenue, Rangers Avenue, and Spofforth Street.
5. Unsafe pedestrian conditions, including reliance on an unsuitable “pram crossing” and lack of safe walking routes for an additional 100+ residents.

This submission is made on behalf of the landowner of 9A Rangers Avenue, Georgina Lepouris, in objection to the proposed development on the basis that it fails to adequately address the relevant considerations applicable to the site and its surrounding locality. While the principle of redevelopment is not opposed, the sheer form, scale and intensity of the proposed development are not appropriate for this site and have not been demonstrated to be consistent with the established character, infrastructure capacity or amenity expectations for Rangers Avenue and the proposed development’s surrounding locality. For the reasons set out below, the proposal gives rise to unacceptable adverse impacts in relation to bulk, scale and density; streetscape and neighbourhood character; traffic congestion and road safety; waste servicing; residential amenity; and the orderly and equitable future development of adjoining land. These impacts have not been satisfactorily mitigated and weigh heavily against approval.

- The proposed development is excessive in bulk, scale and density and is inconsistent with the established low-density residential character of Rangers Avenue and its surrounding locality. The development fails to demonstrate compatibility with the existing streetscape and built form.

- The proposal represents, in practicality, an overdevelopment of the site, and will result in a dominant and visually intrusive built form that undermines the prevailing character of a street primarily comprised of longstanding freestanding dwellings.
The cumulative impact of the building’s height, massing and footprint will adversely affect the spatial quality and visual coherence of the area, contrary to good urban design principles and relevant LEP/DCP objectives relating to neighbourhood character and scale transition.

- The proposal fails to appropriately consider the ongoing amenity and reasonable future development potential of the adjoining properties at 9 and 9A Rangers Avenue, rendering them landlocked as a considerably inferior and substandard isolated site (Karavellas principle).

- As the applicant’s EIS noted, 9 and 9A Rangers Avenue would create a potential site irregular in shape and affected by topography, resulting a significantly inferior planning outcome were the proposed development to proceed on its current site area (and in its current bulk and scale).

- Further, the example development at 36 and 36A Park Avenue Mosman, with a residential flat building of 13 units on a 365 sqm lot, is not reflective of a development which would contribute sufficient/desirable amenity to the area (or to its residents with a view to modern standards of expected amenity), or would be approved in today’s planning environment under current planning provisions/controls.

- Rangers Avenue is a constrained local road, accommodating single lanes in each direction and intersecting with Park Avenue via a small roundabout with restricted turning movements. The existing road infrastructure is already operating under pressure and is not suitably designed to accommodate the additional traffic generated by a development of this intensity.
The proposal includes provision for approximately 80 resident car spaces and 11 visitor spaces servicing 44 proposed apartments, which will generate a significant increase in vehicular movements. This increase will exacerbate congestion, reduce traffic efficiency, and pose safety risks for pedestrians, cyclists and motorists. The development fails to adequately address traffic safety and capacity impacts.

- The required increase in waste collection at one specific point to service waste for 44 apartments will undoubtedly result in negative outcomes, contribute to traffic congestion, noise, and safety concerns, particularly on waste collection days. The proposal does not adequately demonstrate that waste servicing can occur efficiently and without adverse impacts on the surrounding road network and residential amenity, contrary to adequate waste management principles.
Rangers Avenue already functions as a busy thoroughfare relied upon by a significant portion of the suburb. The additional traffic generated by the proposed development will result in cumulative impacts including increased congestion, noise, air pollution, and reduced residential amenity. These impacts have not been adequately mitigated or justified and are inconsistent with the objectives of sustainable development and residential amenity protection.

- The proposed development will result in unacceptable impacts through potential loss of privacy given its height and the extent of front balconies, reduced access to sunlight, overshadowing and increased visual bulk. The scale and mass of the building, when viewed from surrounding dwellings, will create an oppressive built form inconsistent with the present low-rise residential context.

For the reasons outlined above, the proposed development is not an appropriate or suitable form of development for the site. The excessive bulk, scale and density of the proposal are incompatible with the established low-density residential character of Rangers Avenue and will result in unacceptable impacts on the amenity of surrounding properties. The proposal fails to demonstrate that the existing road network and servicing infrastructure can safely and efficiently accommodate the significant increase in traffic and waste collection activity generated by 44 dwellings. It also gives rise to cumulative impacts that have not been adequately addressed or justified, including congestion, safety risks and loss of residential amenity. Further, the development would unreasonably compromise the ongoing amenity and future development potential of adjoining properties at 9 and 9A Rangers Avenue, resulting in an inferior and substandard isolated site outcome, contrary to established planning principles and orderly planning objectives.

The applicant should be required to provide further information, as outlined in my submission, to enable DPHI to perform a full and proper assessment.

This proposed development at 11-23 Rangers Avenue is immediately adjacent Holt Estate Heritage Conservation Area. The scale and bulk of this excessively large modern 7 storey block of units is completely out of context and character of this historical local area. Immediately to the north of the proposed development are a unified group of one and two level Federation cottages, circa early 1900's.

The narrow lane (previously a 'night soil lane') is all that separates the rear of our houses with the proposed development at 11-23 Rangers Avenue. This Bloxsome Lane is in constant use by residents walking and driving in and out of their garages, as well as cars taking short cuts and the provision of Council Services.
Additionally, this lane is used in times of emergency and gives vital Fire access to the rear of properties on the southern side of Holt Avenue and north side of Rangers Avenue.

Over the years there has been an increasing trend in using this lane when doing building renovations, particularly for properties fronting Rangers Avenue. Rangers Avenue is a major and busy road and twists around the natural landform and has a 3 tonne weight limit. In addition , at 11-23 Rangers Avenue the natural ground level is considerably above the height of the road, some 2 metres in parts and so construction will cause significant disruption to traffic.

The expected approx 10 m excavation of this development raises issues with the structural integrity of the sandstone cliff face and the impact on properties in Park Avenue.

Rangers Avenue is a major local route as well as for through-traffic. In addition traffic is likely to bank up around the nearby roundabout at the junction of Rangers Avenue and Avenue Road. Currently, Holt Avenue, Spofforth Street, Spencer Road are taking the traffic overflow from Rangers Avenue.

I cannot believe that the proposed development at 11-23 Rangers Avenue will meet the State Planning Authority's obligation to increase 'affordable housing'. With harbour and city views these units will each sell potentially in the range of 3-5 Million dollars plus. These units will not increase affordable housing and will ruin the historic harbourside suburb of Mosman. The only gain will be to maximise profits for developers - not a good outcome for Sydney. Please reconsider this proposed development.

Donna Leslie, Heritage Architect (retired)
and Andre Leslie
70 Holt Avenue
Mosman 2088
0407 231152

Please see the attachment for my objections to the proposed development.