Name Withheld
Object
Name Withheld
Object
MOSMAN
,
New South Wales
Message
My submission relates to the LTS document relating to the distance from the development to the town centre.
Attachments
Name Withheld
Object
Name Withheld
Object
MOSMAN
,
New South Wales
Message
To whom it may concern
Submission on Proposed Development at 11–23 Rangers Avenue, Mosman
Executive Summary
The proposed development at 11–23 Rangers Avenue is fundamentally inconsistent with the Mosman Local Environmental Plan (LEP 2012) and the Mosman Development Control Plan (DCP 2012).
While I empathise with NSW’s housing challenges, this project disregards statutory height limits, breaches heritage conservation objectives, ignores DCP design controls, and introduces unacceptable excavation, traffic, and structural risks. It sacrifices Mosman’s unique heritage character and community amenity for short term housing yield. I urge the consent authority to refuse the proposal in its current form and require a redesign that delivers housing in a way that is heritage respectful, infrastructure aligned, and community centered.
1. Housing Need vs. Planning Obligations
• Clause 1.2(2)(c) of the Mosman LEP 2012 requires housing opportunities to be “appropriate to environmental constraints while maintaining the existing residential amenity.”
• This proposal prioritises raw density over amenity, ignoring the requirement that new housing must be compatible with local character and environmental limits.
2. Heritage and Character
• The site is adjacent to the Rangers Road Heritage Conservation Area, as mapped under the Mosman LEP 2012 Heritage Map.
• Clause 5.10(4) of the LEP requires consideration of the effect of development on heritage significance.
• The proposal’s bulk and height are inconsistent with the heritage conservation objectives in Part 5.10, which require conservation of cultural significance, maintenance of traditional streetscapes, and appreciation of heritage.
3. Height and Scale
• The Mosman LEP Height of Buildings Map generally limits building heights in this precinct to 8.5 metres.
• The proposed development exceeds this control, directly contravening Clause 4.3 (Height of Buildings).
• Height limits exist to protect amenity, preserve heritage character, and prevent overshadowing. Breaching them undermines the integrity of the planning framework.
4. DCP Design Controls Breached
The Mosman Residential Development Control Plan (DCP 2012) provides detailed design guidelines to supplement the LEP. The proposal breaches multiple provisions:
• Setbacks and Scale (Part 4.2): Minimal setbacks dominate the street frontage, contrary to DCP requirements for open, green streetscapes.
• Streetscape and Building Design (Part 5.1): Roof forms, proportions, and materials must reflect Mosman’s traditional character. The proposal’s bulk and façade are unsympathetic.
• Height and Bulk Limits: The DCP enforces a two storey limit in residential zones. The proposed multi storey scale disregards this control.
• Visual Bulk: The DCP requires buildings to be broken into smaller forms or stepped with terrain. The proposed monolithic structure fails this test.
• Privacy and Solar Access (Parts 5.7 & 5.8): Overshadowing and overlooking impacts breach DCP requirements to protect amenity.
• Landscaping (Part 4.4): The DCP requires 25–50% of sites to remain landscaped with deep soil zones. The proposal’s footprint leaves little room for greenery.
5. Excavation and Structural Safety Concerns
• The proposal includes 2.5 basement levels, requiring excavation to a depth of approximately 10 metres across a site of 3,594 sqm. This equates to an estimated 30,000 cubic metres of sandstone, rock and soil to be removed.
• The applicant has not disclosed the excavation volume or demonstrated how this material will be safely removed.
• The Geotechnical Report (Appendix S) has a restricted scope agreed privately with the applicant, omitting assessment of damage to neighbouring homes, the stability of Rangers Avenue and Bloxsome Lane, and the cliff face above Park Avenue.
• The site sits opposite a signposted cliff edge (“Warning cliff edge”), yet the EIS and geotechnical documentation fail to address risks of destabilisation, rockfall, or landslip.
• Excavation of this scale requires significant retaining structures to mitigate lateral earth pressures and surcharge loads. The applicant has not demonstrated that neighbouring properties along Holt Avenue and Rangers Avenue will be protected.
• In light of these risks, the Department should commission an independent expert geotechnical review before considering approval.
6. Traffic and Safety Implications
• The EIS estimates 10–20 vehicles per day during construction, but this excludes excavation traffic volumes.
• Rangers Avenue has a Gross Vehicle Mass (GVM) limit of 3 tonnes, with blind corners and a 25 km/h speed limit. Heavy rigid vehicles proposed in the Construction Traffic Management Plan (Appendix W) are incompatible with this restriction.
• Sustained use of heavy vehicles on Rangers Avenue is unsafe, unfeasible, and contrary to community amenity.
• Traffic impacts during excavation and construction phases have been grossly underestimated.
7. Community Impact and Precedent
• Clause 1.2(2)(g) of the LEP requires development to “minimise adverse environmental impacts on the amenity of residents and the quality of the environment.”
• Approving this proposal would set a dangerous precedent for overdevelopment in Mosman’s heritage precincts.
• The cumulative effect of similar developments would irreversibly alter the fine grained, low scale character of the suburb.
8. A Call for Redesign
• I urge the Department and Council to require a substantial redesign that reduces bulk and height, integrates with the heritage streetscape, and delivers housing in a way that enhances—not undermines—the community fabric.
• Housing solutions must be human centered, heritage respectful, and infrastructure aligned. Anything less is poor planning and a disservice to both current and future generations.
Conclusion
This proposal is incompatible with the Mosman LEP 2012, the Mosman Residential DCP 2012, the mapped Heritage Conservation Area, statutory height controls, and basic public safety standards. It sacrifices heritage, amenity, and structural integrity for short term housing yield. I respectfully request refusal in its current form and a redesign that genuinely balances housing need with heritage protection, community impact, and public safety.
Yours sincerely,
Submission on Proposed Development at 11–23 Rangers Avenue, Mosman
Executive Summary
The proposed development at 11–23 Rangers Avenue is fundamentally inconsistent with the Mosman Local Environmental Plan (LEP 2012) and the Mosman Development Control Plan (DCP 2012).
While I empathise with NSW’s housing challenges, this project disregards statutory height limits, breaches heritage conservation objectives, ignores DCP design controls, and introduces unacceptable excavation, traffic, and structural risks. It sacrifices Mosman’s unique heritage character and community amenity for short term housing yield. I urge the consent authority to refuse the proposal in its current form and require a redesign that delivers housing in a way that is heritage respectful, infrastructure aligned, and community centered.
1. Housing Need vs. Planning Obligations
• Clause 1.2(2)(c) of the Mosman LEP 2012 requires housing opportunities to be “appropriate to environmental constraints while maintaining the existing residential amenity.”
• This proposal prioritises raw density over amenity, ignoring the requirement that new housing must be compatible with local character and environmental limits.
2. Heritage and Character
• The site is adjacent to the Rangers Road Heritage Conservation Area, as mapped under the Mosman LEP 2012 Heritage Map.
• Clause 5.10(4) of the LEP requires consideration of the effect of development on heritage significance.
• The proposal’s bulk and height are inconsistent with the heritage conservation objectives in Part 5.10, which require conservation of cultural significance, maintenance of traditional streetscapes, and appreciation of heritage.
3. Height and Scale
• The Mosman LEP Height of Buildings Map generally limits building heights in this precinct to 8.5 metres.
• The proposed development exceeds this control, directly contravening Clause 4.3 (Height of Buildings).
• Height limits exist to protect amenity, preserve heritage character, and prevent overshadowing. Breaching them undermines the integrity of the planning framework.
4. DCP Design Controls Breached
The Mosman Residential Development Control Plan (DCP 2012) provides detailed design guidelines to supplement the LEP. The proposal breaches multiple provisions:
• Setbacks and Scale (Part 4.2): Minimal setbacks dominate the street frontage, contrary to DCP requirements for open, green streetscapes.
• Streetscape and Building Design (Part 5.1): Roof forms, proportions, and materials must reflect Mosman’s traditional character. The proposal’s bulk and façade are unsympathetic.
• Height and Bulk Limits: The DCP enforces a two storey limit in residential zones. The proposed multi storey scale disregards this control.
• Visual Bulk: The DCP requires buildings to be broken into smaller forms or stepped with terrain. The proposed monolithic structure fails this test.
• Privacy and Solar Access (Parts 5.7 & 5.8): Overshadowing and overlooking impacts breach DCP requirements to protect amenity.
• Landscaping (Part 4.4): The DCP requires 25–50% of sites to remain landscaped with deep soil zones. The proposal’s footprint leaves little room for greenery.
5. Excavation and Structural Safety Concerns
• The proposal includes 2.5 basement levels, requiring excavation to a depth of approximately 10 metres across a site of 3,594 sqm. This equates to an estimated 30,000 cubic metres of sandstone, rock and soil to be removed.
• The applicant has not disclosed the excavation volume or demonstrated how this material will be safely removed.
• The Geotechnical Report (Appendix S) has a restricted scope agreed privately with the applicant, omitting assessment of damage to neighbouring homes, the stability of Rangers Avenue and Bloxsome Lane, and the cliff face above Park Avenue.
• The site sits opposite a signposted cliff edge (“Warning cliff edge”), yet the EIS and geotechnical documentation fail to address risks of destabilisation, rockfall, or landslip.
• Excavation of this scale requires significant retaining structures to mitigate lateral earth pressures and surcharge loads. The applicant has not demonstrated that neighbouring properties along Holt Avenue and Rangers Avenue will be protected.
• In light of these risks, the Department should commission an independent expert geotechnical review before considering approval.
6. Traffic and Safety Implications
• The EIS estimates 10–20 vehicles per day during construction, but this excludes excavation traffic volumes.
• Rangers Avenue has a Gross Vehicle Mass (GVM) limit of 3 tonnes, with blind corners and a 25 km/h speed limit. Heavy rigid vehicles proposed in the Construction Traffic Management Plan (Appendix W) are incompatible with this restriction.
• Sustained use of heavy vehicles on Rangers Avenue is unsafe, unfeasible, and contrary to community amenity.
• Traffic impacts during excavation and construction phases have been grossly underestimated.
7. Community Impact and Precedent
• Clause 1.2(2)(g) of the LEP requires development to “minimise adverse environmental impacts on the amenity of residents and the quality of the environment.”
• Approving this proposal would set a dangerous precedent for overdevelopment in Mosman’s heritage precincts.
• The cumulative effect of similar developments would irreversibly alter the fine grained, low scale character of the suburb.
8. A Call for Redesign
• I urge the Department and Council to require a substantial redesign that reduces bulk and height, integrates with the heritage streetscape, and delivers housing in a way that enhances—not undermines—the community fabric.
• Housing solutions must be human centered, heritage respectful, and infrastructure aligned. Anything less is poor planning and a disservice to both current and future generations.
Conclusion
This proposal is incompatible with the Mosman LEP 2012, the Mosman Residential DCP 2012, the mapped Heritage Conservation Area, statutory height controls, and basic public safety standards. It sacrifices heritage, amenity, and structural integrity for short term housing yield. I respectfully request refusal in its current form and a redesign that genuinely balances housing need with heritage protection, community impact, and public safety.
Yours sincerely,
Attachments
Rose Saltman
Object
Rose Saltman
Object
MOSMAN
,
New South Wales
Message
I would like to object to this proposal on behalf of myself, Rose Saltman, and Michael Wiles, who resides at the same address as I. Further detail of our objection is in the attached submission.
Attachments
Name Withheld
Object
Name Withheld
Object
MOSMAN
,
New South Wales
Message
Please see attached objection and relevant reports