Please find attached our submission with regard to this development application.

1) the location of the SSD proposed development is more than the 800-metre walking distance of Cremorne Town Centre and it therefore falls outside the scope of the LMR.
2) the 7-storey proposed building is very bulky and too high and this will result in long shadows being cast over the surrounding 1 -2 storey houses, a loss of privacy and a potential glare factor. The surrounding residential area, public transport, street parking, infrastructure generally cannot support such a large development.
3) Traffic flow in the Rangers Road, Brierley Street, Rangers Avenue and Holt Avenue area is already heavily congested at peak times, especially at 8:30 a.m. and 3:13 p.m. when parents are dropping off and picking up children from school and midday on Saturday. Basement parking for 91 cars will only worsen traffic congestion. Especially as it is unlikely Rangers Avenue can be widened due to the vertical drop on the opposite side of Rangers Avenue.
4) Traffic congestion will also increase on Military Road, and this will be a real problem because Military Road already has heavy traffic conditions all day long.
5) Increased traffic flow and congestion will make it more dangerous for pedestrians, especially children walking to school, and for cyclists who can often be seen using Rangers Avenue to access Mosman Bay.
6) It is alarming that for this and other SSD proposed sites, developers are proposing to build mostly luxury units with only a few token affordable housing units, as if by including these it will bring them under the SSD umbrella and give them the approval they are seeking. Surely this is not what the State Government intended.
7) Quite a number of Holt Avenue residents will lose their views of the city skyline and Harbour bridge and this is not acceptable. Mosman Council is urged to urgently submit an alternative plan to the LMR policy whereby development can take place along Military Road away from 1-2 storey residential areas so Mosman residents are not being stripped of their rights without consultation.

I object to this development. The increase in traffic in this already congested area will be horrific. Also, it will cripple the already burdened infrastructure.
This area has always been a community-orientated area. It is now turning into a high-rise.
I urge you to not approve this development.

Submission Regarding Proposed Development at 11–23 Rangers Avenue, Mosman
Residential Development with In-Fill Affordable Housing – State Significant Development under LMHR Policy

Date: 17 December 2025
 
1. Walking Distance and Application of the 800m Rule
The application of the 800m walking distance rule, which is critical to the project’s eligibility under the LMHR policy, is highly questionable. The proposed route crosses at the intersection of Holt Avenue and Spofforth Street, which is unsafe due to heavy traffic volumes. As a local resident, I never cross at this point; the only safe crossing is at the signalised intersection of Spofforth Street and Military Road. This significantly increases the walking distance beyond 800m.
Request:
• The Department should refuse the application on the grounds that no evidence has been provided to demonstrate that the proposed route meets the definition of ‘walking distance’ under the Housing SEPP.
2. Use of the State Significant Development Pathway
It is unclear how this project qualifies as a State Significant Development under the LMHR policy. The proportion of dwellings designated as ‘affordable housing’ appears nominal and does not ensure affordability for key workers. I myself am a teacher and even in a double income family, there is no way I could afford even the discounted rental in a premium property such as this. This undermines the intent of the policy.
3. Mosman Scenic Protection Area & Heritage Conservation Area – Visual Impact
Our property backs onto Bloxome Lane and adjoins the Holt Estate Heritage Conservation Area (HCA). We chose this location for its heritage significance, established tree canopies, bushland, and views of Sydney Harbour. These elements are integral to the area’s character and are protected under local planning controls.
The proposed development will permanently alter this backdrop, introducing bulk and scale that conflict with the heritage character. The current Visual Impact Assessment inadequately addresses these concerns and contains misleading statements regarding scale differences, relying on hypothetical future LMHR developments that are not permissible under current zoning (C4 Environmental Living to the north and land extending to Mosman Bay to the south and east).
Requests:
• Require a revised Visual Impact Assessment that includes visual analysis from the northern perspective, particularly Holt Avenue.
• Correct inaccuracies regarding building scale and ensure compliance with planning controls designed to preserve heritage character.
Refer to Figures 1–3 (attached) for current views illustrating the visual significance of the area.
4. View Loss and View Sharing
Our home and local community enjoys views of the tree canopy and Sydney Harbour, which will be compromised by the proposed development. These views contribute to residential amenity and community enjoyment along routes to Balmoral and Mosman. Routes that we walk daily on our way to and from walk and for leisure. The application fails to adequately address view loss and sharing principles.
Refer to Figures 1–3 (attached) for current views illustrating the visual significance of the area.
Request:
• The Department should require a detailed view loss and sharing assessment in accordance with NSWLEC 140 and Clause 6.4 (Scenic Protection) of MLEP 2012.
5. Safety Concerns – Bloxome Lane
Our garage, like others on Rangers Avenue and Holt Avenue, is accessed via the narrow Bloxome Lane. Increased pedestrian traffic will exacerbate existing safety risks due to limited visibility and constrained maneuvering space, heightening the likelihood of accidents.
6. Traffic and Parking Impacts
The proposed development will significantly increase traffic volumes on Rangers Road and surrounding streets, including Holt Avenue. Current congestion during peak periods already extends through Avenue Road to local shops, causing gridlock and safety hazards for pedestrians. On my commute to work I have a long wait time to cross these roads on foot and also when driving. Construction traffic will further compound these issues.
Conclusion
The proposed development raises serious concerns regarding compliance with Housing SEPP requirements, heritage preservation, visual impact, view sharing, traffic safety, and community amenity. For these reasons, I respectfully request that the Department:
1. Refuse the application due to non-compliance with the 800m walking distance rule.
2. Require a revised Visual Impact Assessment addressing northern perspectives and correcting scale inaccuracies.
3. Mandate a comprehensive view loss and sharing analysis in accordance with NSWLEC principles.
4. Consider the significant safety and traffic impacts on Bloxome Lane and surrounding streets.
 
Attachments
Figure 1 – View of tree canopy and harbour (southward) 17/12/2025


Figure 2 – View from balcony (south-east) 17/12/2025

Figure 3 – View from balcony (south-west) 17/12/2025