I object to this concept and stage one proposal on the following grounds:

1. it will result in the demolition of several significant heritage
items within the listed SCEGGS site. This demolition is inconsistent
with the heritage conservation objectives under the applicable
provision of the Sydney Local Environmental Plan, and it is not
justified having regard to the well- rehearsed planning principles
applied by the Land & Environment Court. The proposal does not
conserve heritage but will rather destroy it. It will also negatively
impact the nearby listed items as well as the heritage conservation
zone, to the value of which the SCEGGS buildings slated for demolition
make a positive contribution. The buildings to be demolished are all
in good order and could readily be repurposed for other school uses,
and the EIS assessment of this issue does not put forward a robust or
reasoned case for demolition which would survive scrutiny in the Land
& Environment Court. The Department should also reject it.

2. the impacts of the large increase in gross floor area which the
Concept and stage 1 DA propose will inevitably create a larger
capacity which will likely result in an increase in student numbers,
but the proposal simply side-steps this increase by asserting the
school has a "present intention" not to increase student numbers. This
proposition beggars belief, and it cannot be used as the underlying
assumption which informs the assessment of impact.

3. it follows from 2 that the serious likely amenity impacts (traffic,
noise, parking) are not adequately or transparently assessed. The
cumulative impact of this proposal must be considered against the
exiting environment of the school and its surrounding where there are
already significant traffic and noise impacts resulting from the
existing school. The likely impacts of this proposal will add
significantly to these amenity issues, but they have not been assessed
in a transparent or orthodox manner.

4. The proposal exceeds the hight of building limits in the LEP, but
this issue has not been properly assessed or justified in terms of the
objectives of the LEP or the mandatory requirement of the principles
set out in schedule 4 of the State Environmental Planning Policy
(Education). This proposal does not withstand scrutiny against those
matters, and it is insufficient for SCEGGS to argue that height limits
can be ignored by reason of SEPP Education, and because this proposal
is "state significant development".
5. The capital investment value of this project must be subjected to
scrutiny by the Department, given that it falls just short of a $50
million threshold. In any case, it does not satisfactorily address the
design excellence requirement of the LEP.

6. The proposal will have a serious impact on the Forbes Street
frontage, by introducing a new building to replace the exiting
heritage listed building and take up open space along Forbes st. This
is out of character with the local area and will impact on locally
listed items outside the site and in the nearby heritage conservation
area. It will change the character of the street, which retains its
19th and early 20 th Century character.

7. The proposal will result in loss of iconic views from various
residents in Forbes St, but these impacts have not been tested agains
the planning principles for view sharing which have been set out by
the Land & Environment Court.

To Whom It May Concern.

I would like you to consider an OBJECTION to the proposal above, in
particular the demolition of Wilkinson House, and the increase in
traffic to the local area.

WILKINSON HOUSE. My apartment FT9 is situated on Forbes St almost
directly opposite Wilkinson House. In my opinion this heritage
building is integral to the eclectic nature of Darlinghurst, part of
the history of the area, and as an important heritage building should
be retained.

INCREASED TRAFFIC FLOW FROM ADDITIONAL BUILDINGS.
As noted above, my apartment in the low rise section of The Horizon on
Forbes St and my bedroom window overlooks Wilkinson House. School
busses frequently park on Forbes St opposite my bedroom window both
early in the morning and at weekends. For long periods the busses wait
for school girls to board, their motors are kept running, presumably
to keep the air conditioning running on the bus, causing both air and
noise pollution.
At school drop-off and pick-up time the traffic in Forbes St is
horrendously congested. There is always a long queue of cars down
Forbes St with parents dropping girls off. Many parents have no regard
for road rules and simply double park while waiting for a parking spot
in the drop off zone outside SKEGGS so there is no possibility of
by-passing the queue of cars to enter Horizon car park (note - mainly
teenage girls are being dropped off, not small children who need
parental care). Also many parents continue to use the Horizon driveway
into the car park as an area to do a three point turn and go back up
Forbes St, causing more congestion.

An increase in size of SKEGGS buildings would surely mean in increase
in scholars in the future, and the traffic problems noted above would
also increase.

* Already traffic is a nightmare on Forbes Street and the proposed
development will simply exacerbate the problem
* I don't agree with the demolition of Wilkinson House which is a
significant local heritage icon. Its demolition would impact on the
Heritage Conservation Area and impact on the streetscape;
*The Master Plan fails to address current significant traffic
management issues;
*The Traffic Report included in the submission is deficient;
*Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
*Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
*Impact of staging and construction.

Demolition of Wilkinson House - loss of a significant local heritage
item, impact on the Heritage Conservation Area and impact on the
streetscape;
Failure of Master Plan and address current significant traffic
management issues - these are of particular concern with school
traffic already very bad in Forbes Street;
Inadequacy of the Traffic Report included in the submission - see
above;
Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
Impact of staging and construction on residents of Forbes Street.

I am horrified that this proposal by SCEGGS school proposes to demolish
the heritage listed Wilkinson House, and to overshadow and overcrowd
the historic 1830's Barham building with a 7-storey general-purpose
building.

It is hard to see what justification there is for such a large
building that would be non compliant with rules applying to the
surrounding heritage conservation area.

The neighbouring terrace houses in Thomson Street and Forbes Street
are one of the most attractive remaining examples of their type, and
would not be allowed to reach the heights proposed for this 7-storey
building, but would be subject to over shadowing, and loss of iconic
views from its construction.

SCEGGS has an enormous school site, why should they be permitted to
cause historic terrace houses to lose their northern sun and views?

How can SCEGGS be permitted to argue that the only increase in school
enrollments will be 90 children in the early learning child centre? If
this was so, what need is there for such a monstrously large general
purpose building?

The increase in school population that is implied by the proposed size
of this general purpose building may have major effects on the already
problematic traffic issues around arrival and departure times in
Forbes and Bourke Streets.

Last but certainly not least, is the over bearing effect this building
would have on the very historic Barham building. Residents in the
surrounding areas would like to see more of this building, not less.

I am making an objection to the SCEGGS Darlinghurst DA on the basis of
concerns over the impact of the newly constructed site on increasing
traffic around the school area which will impact residents of The
Horizon.

I do not object to reasonable, sympathetic redevelopment or re-purposing
of buildings on the SCEGGS site, but the current proposal represents a
direct challenge to the heritage conservation area of which it is a
part.

I have seven specific objections.

1. The proposal does not include any rationale for the extraordinarily
large increase in floor space. Given the growth in student numbers
(currently 942) over the past decade, and the proposal to enrol 90
children in the short term in the early learning/child care centre,
the only reasonable conclusion is that enrollments are intended to
grow considerably.

2. Any increase in enrollments would exacerbate traffic problems that
exist currently in the morning and afternoon drop-off and pick-up
times.

3. The planned partial external restoration of the 1830s Barham
building seems commendable, but is negated by the inappropriate modern
structure between it and Forbes Street.

4. I see no great problem with changing the interior of Wilkinson
House, but the local-heritage listed 1920s building's demolition would
be sheer vandalism. Not only is it a key part of the area's heritage
at the William Street end of Forbes Street, damaged already by the
forty-three storey Horizon building, but it is an example of the work
of Emil Sodersten, co-architect of the Australian War Memorial in
Canberra, and the architect of Birtley Towers in Elizabeth Bay and the
Reid Building at St Andrew's College at the University of Sydney.

5. The bulk of the proposed general-purposes building of up to seven
storeys is significantly non-compliant with rules applying to the
surrounding heritage conservation area, particularly in relation to
the neighbouring terrace houses.

6. It appears from the plans that some residents of Forbes Street and
Liverpool Street would lose their iconic Harbour Bridge views.

7. Although I am not an expert on overshadowing, I understand that
several houses in Thompson Street would lose all northern light and
some western light.

Dear Prity


SCEGGS DARLINGHURST CONCEPT AND STAGE 1 DA - OBJECTION

We object to the proposed SCEGGS Concept and Stage 1 development
application and make the following submission for the consent
authority's consideration under the Environmental Planning &
Assessment Act.

RATIONALE FOR RE-DEVELOPMENT AND INCREASED CAPACITY OF THE SCHOOL

The proposed concept plan does not make the case that the significant
development is necessary, with all the inherent constructions risks,
demolition of heritage buildings and loss of amenity to the
neighbourhood. The assessment has also not properly considered the
likely impacts which will almost certainly result from the increased
size and capacity of the school facilities which will be authorised by
this concept proposal.

The EIS and the expert reports which inform the EIS conclusions rely
upon a "statement of present intent" that the proposed redevelopment
is not intended to increase the existing student population of the
School or the site area of the campus.

There are some fundamental problems with this approach. First, this
proposal does include a dramatic increase in Gross Floor Area of
3,123.3m2 over the site. This represents a 24.44% increase in GFA. In
other words, the area of the site occupied by school facilities will
be increased by almost 25%, but the precise future uses of that
additional space are not specified, nor the need for the increase
justified.

Whilst SCEGG's currently stated intent is not to increase the existing
student population of the School, once the additional `educational
establishment' and `early education and care facility' have been built
and once the overall GFA of the school site has increased in line with
the Concept proposal, the school will almost certainly seek to fund or
part fund the large cost of the development by increasing the number
of students. The deliberate decision to outline a "statement of
present intent" rather than an enforceable cap on student numbers
almost certainly means that the intent will inevitably change in the
future, by which time the opportunity to oppose a large increase in
the size of the school population will be lost to the people of
Darlinghurst and Sydney.

This concern is supported by publicly available data about the recent
trend in the SCEGGS population. The www.myschool.edu.au website
records the following enrolments:

2019 - not published (942 according to EIS)
2018 - not published (no annual or other report available at this
date)
‪2017 - 920‬
‪2016 - 917‬
‪2015 - 918‬
‪2014 - 921‬
‪2013 - 911‬
‪2012 - 911‬
‪2012 - 903‬
‪2010 - 898‬

Accepting the EIS and the myschool data, the trend between 2010 and
2019 shows an increasing number of enrolled students. If the
"statement of present intent" is to be given any weight in this
assessment, it can only be on the basis that the existing student cap
of 942 is preserved as an enforceable limit, and that this cap must
form the basis of all other assessment assumptions going forward.

In any case, when assessing the environmental impacts of this
proposal, the Department must consider the capacity of the proposed
new works, and their ability to accommodate more students. The
approach the School has adopted is not a proper basis for a valid
assessment of impact, and it should be rejected by the Department.

HEIGHT OF BUILDINGS

The proposal involves a significant exceedance of the height of
building development standard (refer to clause 8.1.1 of the EIS -
Figure 6 and Figure 7. The clause 4.6 submission).

The EIS argues that the exceedance of the height of buildings is
addressed by clause 42 of the State Environmental Planning Policy
State Environmental Planning Policy (Educational Establishments and
Child Care Facilities) 2017 (Education SEPP), which provides that for
a school classified as State Significant Development (such as this)
consent may be granted even though the proposal would contravene a
development standard imposed by an environmental planning instrument.
That may be true, but it does not allow the Department simply to
dismiss the height of buildings objectives under the LEP, which are
still relevant and must be considered by reason of section 4.40 of the
Planning Act.

Clause 4.3 of the Sydney Local Environmental Plan is in the following
terms:

4.3 Height of buildings

(1) The objectives of this clause are as follows:
(a) to
ensure the height of development is appropriate to the condition of
the site and its context,
(b) to ensure appropriate height
transitions between new development and heritage items and buildings
in heritage conservation areas or special character areas,
(c)
to promote the sharing of views,

In our opinion, the objective (a) is not met as it does take into
account the unique nature of the neighbourhood and the condition of
the site when considered in conjunction to the heritage buildings
nearby, the residential nature of the neighbourhood and the existing
height of neighbouring buildings. It is also our opinion that
objective (c) is unmet due to it clearly limiting or impacting the
view of adjacent buildings towards the harbour area. We are therefore
of the opinion that the proposed buildings that exceed the statutory
height limits be rejected under their present application.

HERITAGE IMPACTS

The demolition of Barham additions (1907-1922), Chapel Building
additions (1909-1926), Old Gymnasium (1925), Wilkinson House (1926)
and the Science building does not respond to and enhance the positive
qualities of their setting, landscape and heritage listing and will
not meet the objectives of clause 5.10(1) of Sydney Local
Environmental Plan:

The objectives of this clause are as follows:
(a) to conserve the environmental heritage of the City of Sydney,
(b) to conserve the heritage significance of heritage items and
heritage conservation areas, including associated fabric, settings and
views,
(c) to conserve archaeological sites,
(d) to conserve Aboriginal objects and Aboriginal places of heritage
significance.


The SCEGGS Darlinghurst site is identified as a local heritage item
(no. I301) within the C13: East Sydney Conservation Area. It is also
located within the vicinity of a number of local and state significant
heritage items.

The EIS's Heritage Impact statement purports to address the LEP
objectives as follows:

The proposed Stage 1 redevelopment design for Wilkinson House achieves
the objectives of this clause through the:
- retention of views through Forbes Street and St Peters Street

- establishment of a building of a similar height and mass to
the preceding Wilkinson House 
- establishment of a building
which reinforces the street alignment of Forbes Street and St Peters
Street

These documents do not demonstrate how the proposal conserves the
environmental heritage of the City of Sydney, or achieves any of the
LEP objectives. Far from conserving heritage, this proposal will
result in its destruction.

Some of the buildings to be demolished are over 100 years old. The
buildings in question are all in good order, and not only have
heritage significance within the listed site, but also contribute to
the heritage character of the surrounding items and the heritage
conservation area. Given the comments above about the need for the
project, and that the precise specific future school uses of the
proposed new building envelopes remains unclear, there has been no
robust assessment of whether the proposed demolition of heritage
buildings, and the significant loss of our heritage, is justified.

Wilkinson House is to be demolished. The 1920s Wilkinson Building
which is located at the corner of Forbes street and St Peters Street
was designed by the renowned architect Emil Sodersten and makes a
highly significant visual contribution to defining the heritage
streetscape of this section of Forbes Street. Insufficient attempts
have been made to adapt the building for re-use, to explained why the
buildings are unsafe or unsound and why they cannot be adaptively
reused. The starting point of this application is that the heritage
buildings should be demolished, but that proposition is not properly
justified.

The existing 1830's John Verge designed 'Barham' which is located
within the school site only has limited public views available from
the Forbes Street. The proposed Masterplan desires to further reduce
these public views by constructing an inappropriate modern building on
the Forbes Street side of the Barham building, which will then
effectively block all meaningful public views of the historic building
from the Forbes Street and overwhelm the historically important house.

To allow this demolition to proceed on the information provided in the
EIS would be inconsistent with the clear principles established by the
Land and Environment Court (see
https://www.caselaw.nsw.gov.au/decision/549f84273004262463abec2e).


LOSS OF VIEWS


The height of the proposed new Multipurpose Building is approximately
2.8 metres higher than the existing heritage listed Old Gym Building
(which will be demolished) with the inherent loss of views and light.
Some residents in Forbes Street and Liverpool Street will lose
entirely their iconic Harbour Bridge views. Others will lose their
city views, including of the Centrepoint tower. None of these impacts
have been properly assessed and justified in accordance with the `view
sharing' principles outlined by Land and Environment Court planning
principles. The statutory non-compliance with height limits
immediately indicates that the significant view loss impacts are
unacceptable, if the relevant Court precedents are correctly applied
(see: https://www.caselaw.nsw.gov.au/decision/549f893b3004262463ad0cc6).

OVERSHADOWING

The EIS states:
"the proposed buildings have been designed to limit overshadowing of
adjacent properties and view impacts are reasonable in the
circumstances of this particular site (Refer Section 8.1.2 of this
EIS). Where impacts to properties to the south are unavoidable from a
reasonable built form due to site orientation and existing setbacks we
note these impacts are largely resulting from a compliant building
height in that location." 

To a certain extent this is
true, but the shadows cast by the additional height of buildings above
15m do further reduce solar access to additional properties further
south of the site. The 19th century terraces at the end of Thomson
Street will lose a large amount of northern light and some western
light.

BULK

The proposed 7 storey multifunction building is too high and not set
back from the existing two storey 19th century terraces that are
adjacent to the building on both Thomson and Bourke Streets. The bulk
and scale of the building is inappropriate for context of the
surrounding heritage conservation zone. The non-compliance with the
LEP is not justified in the circumstances.

AMENTIY IMPACTS

The real impacts of the development have not been properly assessed by
this application. Before the consent authority (and the community) can
assess and comment on this development, these impacts must be
transparently assessed and reported having regard to:
the additional capacity of 3,123.3m2 in GFA. There has been no
assessment whatsoever of the impacts which will result from a 24.44%
increase in the capacity of SCEGGS to accommodate students;
the breach of the Height of Building provisions of the Sydney Local
Environmental Plan;
the breach of the Heritage Conservation Objectives of clause 5.10 of
Sydney Local Environmental Plan; and
principle 1 of the Schedule 4 of the Education SEPP: " Schools should
be designed to respond to and enhance the positive qualities of their
setting, landscape and heritage"

TRAFFIC AND PARKING

Appendix K Traffic Impact Assessment to the EIS dismisses any traffic
or parking impacts as follows:

In summary of the Concept
Masterplan, there will be a net increase of 3,123.3m2 GFA but
importantly, no increase in either staff or student numbers, with the
new facilities focussed on the delivery of improved functionality,
efficiency and amenity.(p.29)

"In summary for Stage 1,
there will be a net increase of 163.1m2 GFA but importantly, as with
the Concept Masterplan, there will also be no increase in either staff
or student numbers for Stage 1.(p.30)

"The Development
Application will not seek to change the number of students or staff
and as such an assessment on the trip generating potential of the
school is not considered warranted.(p.53)

The additional
GFA of 3,123.3m2 proposed in this development is able to accommodate a
significant increase in capacity for the student population and
teacher population. This will inevitably result in a dramatic increase
in traffic which has not been properly or transparently assessed.

INAPPROPRIATE CONSULTATION

The school has never held one meeting where all stakeholders have been
present to hear the concerns of others. The school has carefully
designed the process to avoid opposition to its plans. Where they have
documented consultations, they have actively misrepresented the
discussions, for example, East Sydney Neighbourhood Association (ESNA)
were NEVER "indifferent' to the proposed demolition of the historic
Wilkinson House. The consultation process is illegitimate and does not
comply with reasonable expectations of public participation.

NOISE

The acoustic report in the EIS make no reference to the number of
students which are assumed for the purposes of the assessment. The
assessment of noise impacts should have been made on the basis that
the net increase of 3,123.3m2 GFA must necessarily increase the
capacity of the school to accommodate students, and that this must
inevitably have an effect upon noise impacts on neighbours.

Your sincerely

Tariq Scherer & Erin Fairs-Scherer

Unit 28/200 Forbes Street,
Darlinghurst
NSW 2010

we are objecting to the proposed Demolition of Wilkinson House and
related development and construction. This will be a loss of a
building of significant historical value. In addition the associated
disruption to traffic flow and potential issues this raises are not
adequately catered for.

* Demolition of Wilkinson House - loss of a significant local heritage
item, impact on the Heritage Conservation Area and impact on the
streetscape;
* Failure of Master Plan to address current significant traffic
management issues;
* Inadequacy of the Traffic Report included in the submission;
* Query in relation to the stated Capital Investment Value, which is
just under the level at which a Design Competition is required;
* Ambiguity in the application regarding the Early Education and Care
Facility for 90 children and the impacts arising;
* Impact of staging and construction.