Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
Submission of Strong Objection
Project: 903-921 Bourke Street, Waterloo (SSD-95997711)
Objector Role: Resident of NO.1 Lachlan (Directly Affected Party)
To the Department of Planning, Housing and Infrastructure,
I am a resident of NO.1 Lachlan, located in close proximity to the proposed development at 903-921 Bourke Street. I am writing to formally lodge my strong objection to the SSDA modification submitted by DASCO. This proposal is not a minor adjustment; it is a radical departure from the approved planning framework that will cause immediate harm to the residential amenity of existing neighbours and the planning integrity of the Green Square precinct.
My objection is based on the following grounds:
1. Severe and Unacceptable Impact on Solar Access and Outlook The proposed height increase from 65m to a maximum of 126m represents an unprecedented 94% increase in scale. Specifically, the modification seeks to raise the Young St North (YSN) tower to 38 storeys and the Young St South (YSS) tower to 31 storeys.
Direct Overshadowing: The applicant’s own shadow diagrams (specifically for 21 June, 12pm–3pm) confirm that the proposed scheme results in significant additional overshadowing to NO.1 Lachlan compared to the approved envelope.
Loss of Winter Solar Access: During the critical midday period, when many apartments in our building currently receive vital direct sunlight, the shadows will now extend across our building. The drawings indicate that many apartments would receive less than 2 hours of solar access under this scenario.
Loss of Sky View: The scale of the proposed massing will result in a tangible loss of sky view and open outlook, which are essential components of our daily liveability and wellbeing.
2. Gross Overdevelopment and Excessive Density The request to more than double the Floor Space Ratio (FSR) from 1.5:1 to 3.2:1 (to accommodate approximately 580 apartments) represents an unjustified intensification. This level of density prioritises developer yield over the residential amenity of the surrounding community and significantly exceeds what the surrounding urban context can reasonably accommodate.
3. Avoidance of Critical Infrastructure Obligations (Clause 6.14) I strongly object to the proposed exclusion of Clause 6.14 (Community Infrastructure floor space at Green Square). The additional population generated by this development will place massive demand on local roads, public transport, and wastewater systems. It is inequitable to allow a developer to double their yield while seeking to bypass the infrastructure contributions required to mitigate these impacts on the existing community.
4. Undermining Design Quality and Planning Controls (Clause 6.21D) The proposal seeks to bypass the Competitive Design Process, which is a key mechanism in the City of Sydney for ensuring architectural excellence. For towers of this height (126m), avoiding this process undermines public confidence in the final built form and weakens the planning governance intended to protect the visual amenity of our neighbourhood.
5. Negative Planning Precedent Approving such a fundamental redesign and departure from established controls would set a dangerous precedent for the Waterloo / Green Square precinct, effectively signalling that strategic planning controls and solar rights can be bypassed for commercial gain.
Conclusion
This proposal represents an excessive intensification that will have clear and lasting negative impacts on the residents of NO.1 Lachlan, specifically through the loss of solar access and increased pressure on local infrastructure.
I respectfully request that the Department refuse this application. At a minimum, the project should be restricted to the originally approved scale and required to fully comply with all infrastructure contributions and design review processes.
Sincerely,
Resident of NO.1 Lachlan - 2 Thread Lane, Waterloo
Project: 903-921 Bourke Street, Waterloo (SSD-95997711)
Objector Role: Resident of NO.1 Lachlan (Directly Affected Party)
To the Department of Planning, Housing and Infrastructure,
I am a resident of NO.1 Lachlan, located in close proximity to the proposed development at 903-921 Bourke Street. I am writing to formally lodge my strong objection to the SSDA modification submitted by DASCO. This proposal is not a minor adjustment; it is a radical departure from the approved planning framework that will cause immediate harm to the residential amenity of existing neighbours and the planning integrity of the Green Square precinct.
My objection is based on the following grounds:
1. Severe and Unacceptable Impact on Solar Access and Outlook The proposed height increase from 65m to a maximum of 126m represents an unprecedented 94% increase in scale. Specifically, the modification seeks to raise the Young St North (YSN) tower to 38 storeys and the Young St South (YSS) tower to 31 storeys.
Direct Overshadowing: The applicant’s own shadow diagrams (specifically for 21 June, 12pm–3pm) confirm that the proposed scheme results in significant additional overshadowing to NO.1 Lachlan compared to the approved envelope.
Loss of Winter Solar Access: During the critical midday period, when many apartments in our building currently receive vital direct sunlight, the shadows will now extend across our building. The drawings indicate that many apartments would receive less than 2 hours of solar access under this scenario.
Loss of Sky View: The scale of the proposed massing will result in a tangible loss of sky view and open outlook, which are essential components of our daily liveability and wellbeing.
2. Gross Overdevelopment and Excessive Density The request to more than double the Floor Space Ratio (FSR) from 1.5:1 to 3.2:1 (to accommodate approximately 580 apartments) represents an unjustified intensification. This level of density prioritises developer yield over the residential amenity of the surrounding community and significantly exceeds what the surrounding urban context can reasonably accommodate.
3. Avoidance of Critical Infrastructure Obligations (Clause 6.14) I strongly object to the proposed exclusion of Clause 6.14 (Community Infrastructure floor space at Green Square). The additional population generated by this development will place massive demand on local roads, public transport, and wastewater systems. It is inequitable to allow a developer to double their yield while seeking to bypass the infrastructure contributions required to mitigate these impacts on the existing community.
4. Undermining Design Quality and Planning Controls (Clause 6.21D) The proposal seeks to bypass the Competitive Design Process, which is a key mechanism in the City of Sydney for ensuring architectural excellence. For towers of this height (126m), avoiding this process undermines public confidence in the final built form and weakens the planning governance intended to protect the visual amenity of our neighbourhood.
5. Negative Planning Precedent Approving such a fundamental redesign and departure from established controls would set a dangerous precedent for the Waterloo / Green Square precinct, effectively signalling that strategic planning controls and solar rights can be bypassed for commercial gain.
Conclusion
This proposal represents an excessive intensification that will have clear and lasting negative impacts on the residents of NO.1 Lachlan, specifically through the loss of solar access and increased pressure on local infrastructure.
I respectfully request that the Department refuse this application. At a minimum, the project should be restricted to the originally approved scale and required to fully comply with all infrastructure contributions and design review processes.
Sincerely,
Resident of NO.1 Lachlan - 2 Thread Lane, Waterloo
Attachments
Daniel Brooks
Object
Daniel Brooks
Object
WATERLOO
,
New South Wales
Message
I am an owner-occupier living on the 6th floor at 4 Lachlan Street, which is south-east of the development site. I’ve lived in the Waterloo area with my spouse for the last 8 years. This area has seen a lot of change over this time and I was pleased to see the initially approved DA for the development at 903-921 Bourke Street. However, after seeing the proposed updates, I strongly object to this proposal for the following reasons:
Building Heights
The increase in buildings heights is substantial (57-150% increase compared with the approved DA) and not in keeping with the local neighbourhood character. For context, the tallest apartment building in this neighbourhood is 17 storeys high. The 31 and 38 storey towers would look significantly out of place within the area and set a poor precedent for future developments.
The Community Engagement Report notes that the 'proposal is a departure from the existing heights in the area, however is in line with the emerging character of taller buildings'. This doesn't offer a reasonable justification for the significant height uplift from the approved DA. The proposed towers are taller than the approved development directly above the Waterloo Metro station, whereas the development site sits within a predominantly residential area which is 1km away from any nearby stations.
Visual Impact
The addition of 4 storeys (or 57% additional height) to the Bourke Street South building will result in a significant loss of sky views from our balcony towards the west, and would be taller than all apartment buildings directly next to the southeast corner of the site.
The Visual Impact Assessment doesn’t provide clarity on the loss of views for the majority of the residents living in the Crown Square precinct. Many of the viewpoints are taken far away from the development site. Diagrams VP01, VP02 and VP05 are the closest viewpoints and these don't show the full impact of the development. This implies that the view loss will be significant for residents living near the development site.
Overshadowing & Solar Access
The Shadow Plans in Appendix 9A of the Design Report only show additional overshadowing impacts during the winter solstice. Our apartment is south-facing and located on the 6th floor. We currently receive around 2 hours of direct sunlight to our balcony and living area during the late afternoon in the summer months. It is unclear whether we would lose access to direct sunlight with the proposed building height increases as there are no shadow diagrams available for the summer solstice period. If we did, our apartment wouldn’t comply with the ADG requirements for solar access.
Public Transport
The statements in the Transport Impact Assessment about the area having 'excellent access to nearby public transport network' and that the 'additional [87 trips by bus during the AM and PM peak hours] can be accommodated through the high frequency bus routes along Bourke Street' and that 'the opening of the Waterloo Metro station in 2024 has...relieved capacity on existing bus services in the Waterloo area' are misleading.
Waterloo is one of the most densely populated suburbs in Sydney. My spouse and I currently rely on the existing bus networks to transport us to nearby stations, as these aren’t within a convenient walking distance. These bus networks are already overcrowded and unreliable and the frequency of buses and number of available destinations have decreased over the years. The proposed 67% increase in apartment numbers will further add to an overstretched bus network without any provision for additional public transport links.
The current construction works at the Bourke Street site have already resulted in the loss of a bus stop for 2 major bus routes that connect local residents to the nearby stations of Central, Redfern and Waterloo Metro. This has led to more queuing at neighbouring bus stops. A larger development will mean longer construction times and more disruptions to existing bus routes.
Traffic Generation
There is already a high volume of traffic in the area due to the proximity to the Eastern Distributor and Lachlan Street being a major connector between the eastern and western suburbs. The proposed development increases apartment numbers by 67% but only allows for 10% additional parking spaces and 10% total cars. This suggests that most new residents will use public transport, which is unrealistic based on the limits of the current public transport networks in the area.
If the local public bus services become strained, this will lead to increased car usage, adding to the congestion of local road networks. This would make pedestrian and cyclist activity more dangerous, increase noise and air pollution in the area and increase demand for the few local on-street parking spaces.
The proposed construction vehicle route shown in the Traffic Impact Assessment will create significant additional traffic on Potter Street and Gadigal Street, which have residential carpark access for our building and other neighbouring buildings, as well as being part of the 304 bus route.
Public Amenities
The development proposal increases apartment numbers by 67% whilst reducing retail space by 4% and creating no additional areas of public domain. The proposal solely benefits private residences at the expense of the local community. The increased density will create further strains to local amenities such as the Green Square Library and Gunyama Park public pool, which we use regularly and already find to be busy the majority of the time.
Building Heights
The increase in buildings heights is substantial (57-150% increase compared with the approved DA) and not in keeping with the local neighbourhood character. For context, the tallest apartment building in this neighbourhood is 17 storeys high. The 31 and 38 storey towers would look significantly out of place within the area and set a poor precedent for future developments.
The Community Engagement Report notes that the 'proposal is a departure from the existing heights in the area, however is in line with the emerging character of taller buildings'. This doesn't offer a reasonable justification for the significant height uplift from the approved DA. The proposed towers are taller than the approved development directly above the Waterloo Metro station, whereas the development site sits within a predominantly residential area which is 1km away from any nearby stations.
Visual Impact
The addition of 4 storeys (or 57% additional height) to the Bourke Street South building will result in a significant loss of sky views from our balcony towards the west, and would be taller than all apartment buildings directly next to the southeast corner of the site.
The Visual Impact Assessment doesn’t provide clarity on the loss of views for the majority of the residents living in the Crown Square precinct. Many of the viewpoints are taken far away from the development site. Diagrams VP01, VP02 and VP05 are the closest viewpoints and these don't show the full impact of the development. This implies that the view loss will be significant for residents living near the development site.
Overshadowing & Solar Access
The Shadow Plans in Appendix 9A of the Design Report only show additional overshadowing impacts during the winter solstice. Our apartment is south-facing and located on the 6th floor. We currently receive around 2 hours of direct sunlight to our balcony and living area during the late afternoon in the summer months. It is unclear whether we would lose access to direct sunlight with the proposed building height increases as there are no shadow diagrams available for the summer solstice period. If we did, our apartment wouldn’t comply with the ADG requirements for solar access.
Public Transport
The statements in the Transport Impact Assessment about the area having 'excellent access to nearby public transport network' and that the 'additional [87 trips by bus during the AM and PM peak hours] can be accommodated through the high frequency bus routes along Bourke Street' and that 'the opening of the Waterloo Metro station in 2024 has...relieved capacity on existing bus services in the Waterloo area' are misleading.
Waterloo is one of the most densely populated suburbs in Sydney. My spouse and I currently rely on the existing bus networks to transport us to nearby stations, as these aren’t within a convenient walking distance. These bus networks are already overcrowded and unreliable and the frequency of buses and number of available destinations have decreased over the years. The proposed 67% increase in apartment numbers will further add to an overstretched bus network without any provision for additional public transport links.
The current construction works at the Bourke Street site have already resulted in the loss of a bus stop for 2 major bus routes that connect local residents to the nearby stations of Central, Redfern and Waterloo Metro. This has led to more queuing at neighbouring bus stops. A larger development will mean longer construction times and more disruptions to existing bus routes.
Traffic Generation
There is already a high volume of traffic in the area due to the proximity to the Eastern Distributor and Lachlan Street being a major connector between the eastern and western suburbs. The proposed development increases apartment numbers by 67% but only allows for 10% additional parking spaces and 10% total cars. This suggests that most new residents will use public transport, which is unrealistic based on the limits of the current public transport networks in the area.
If the local public bus services become strained, this will lead to increased car usage, adding to the congestion of local road networks. This would make pedestrian and cyclist activity more dangerous, increase noise and air pollution in the area and increase demand for the few local on-street parking spaces.
The proposed construction vehicle route shown in the Traffic Impact Assessment will create significant additional traffic on Potter Street and Gadigal Street, which have residential carpark access for our building and other neighbouring buildings, as well as being part of the 304 bus route.
Public Amenities
The development proposal increases apartment numbers by 67% whilst reducing retail space by 4% and creating no additional areas of public domain. The proposal solely benefits private residences at the expense of the local community. The increased density will create further strains to local amenities such as the Green Square Library and Gunyama Park public pool, which we use regularly and already find to be busy the majority of the time.
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
Subject: Formal Objection to SSD-95997711 – 903–921 Bourke Street, Waterloo
As a resident of Waterloo 2017 for 13+ years I write to formally object in the strongest possible terms to the proposed amendments to the development at 903–921 Bourke Street, Waterloo (SSD-95997711).
This proposal represents a substantial and unjustified intensification of the originally approved scheme. The increase in building heights—from 12 to 31 storeys and from 21 to 38 storeys—alongside a significant uplift in dwelling numbers, is excessive and constitutes a clear overdevelopment of the site. It is a fundamental departure from the scale, intent, and planning rationale of the original approval.
My objection is based on the following key planning concerns:
1. Unacceptable strain on existing infrastructure
The surrounding area is already experiencing significant pressure on transport and road networks. Public transport services, including buses and trains servicing Green Square, are frequently operating at or beyond capacity. Road congestion and limited parking availability are ongoing issues. The addition of hundreds of new dwellings with minimal corresponding infrastructure upgrades is neither responsible nor sustainable.
2. Inadequate provision of social and community infrastructure
Local amenities—including libraries, open spaces, and community facilities—are already stretched. This proposal fails to demonstrate how these essential services will be expanded or enhanced to meet the needs of a significantly increased population. Planning decisions must ensure that infrastructure keeps pace with growth, which is clearly not the case here.
3. Excessive height, bulk, and visual impact
The proposed towers are grossly out of scale with the existing and approved built form in the area. Such an increase in height will dominate the local streetscape, erode the established character of Waterloo, and set a concerning precedent for future overdevelopment.
4. Significant overshadowing and loss of amenity
The increased height and density will result in substantial overshadowing of nearby residences and public spaces, particularly during the winter months. This will negatively impact sunlight access, comfort, and overall liveability for existing residents.
5. Cumulative impact and planning integrity
This proposal cannot be assessed in isolation. When considered alongside other major developments in Waterloo and Zetland, the cumulative effect is the introduction of thousands of additional dwellings and residents within a short timeframe. This level of densification, without coordinated infrastructure delivery, undermines confidence in the strategic planning framework and raises serious concerns about planning integrity.
In its current form, this proposal prioritises development yield over community wellbeing, infrastructure capacity, and good urban planning principles. It fails to achieve an appropriate balance between growth and liveability.
I respectfully urge the NSW Government to reject SSD-95997711 in its current form. At a minimum, the proposal should be required to revert to a scale and density consistent with the originally approved scheme, or be significantly redesigned to address the serious concerns outlined above. This ultimately all will result in a material reduction in the quality of life for the thousands of existing residents of Waterloo, 2017, already one of Sydney's most populous postcodes - an area that has been under urban intensification strain for years. Ghettoisation and a real erosion of the sense of community and belonging for Waterloo, 2017 is the inevitable next step, if this proposal proceeds in its current form.
Thank you for the opportunity to provide this submission.
Yours faithfully,
Paul Dobson.
As a resident of Waterloo 2017 for 13+ years I write to formally object in the strongest possible terms to the proposed amendments to the development at 903–921 Bourke Street, Waterloo (SSD-95997711).
This proposal represents a substantial and unjustified intensification of the originally approved scheme. The increase in building heights—from 12 to 31 storeys and from 21 to 38 storeys—alongside a significant uplift in dwelling numbers, is excessive and constitutes a clear overdevelopment of the site. It is a fundamental departure from the scale, intent, and planning rationale of the original approval.
My objection is based on the following key planning concerns:
1. Unacceptable strain on existing infrastructure
The surrounding area is already experiencing significant pressure on transport and road networks. Public transport services, including buses and trains servicing Green Square, are frequently operating at or beyond capacity. Road congestion and limited parking availability are ongoing issues. The addition of hundreds of new dwellings with minimal corresponding infrastructure upgrades is neither responsible nor sustainable.
2. Inadequate provision of social and community infrastructure
Local amenities—including libraries, open spaces, and community facilities—are already stretched. This proposal fails to demonstrate how these essential services will be expanded or enhanced to meet the needs of a significantly increased population. Planning decisions must ensure that infrastructure keeps pace with growth, which is clearly not the case here.
3. Excessive height, bulk, and visual impact
The proposed towers are grossly out of scale with the existing and approved built form in the area. Such an increase in height will dominate the local streetscape, erode the established character of Waterloo, and set a concerning precedent for future overdevelopment.
4. Significant overshadowing and loss of amenity
The increased height and density will result in substantial overshadowing of nearby residences and public spaces, particularly during the winter months. This will negatively impact sunlight access, comfort, and overall liveability for existing residents.
5. Cumulative impact and planning integrity
This proposal cannot be assessed in isolation. When considered alongside other major developments in Waterloo and Zetland, the cumulative effect is the introduction of thousands of additional dwellings and residents within a short timeframe. This level of densification, without coordinated infrastructure delivery, undermines confidence in the strategic planning framework and raises serious concerns about planning integrity.
In its current form, this proposal prioritises development yield over community wellbeing, infrastructure capacity, and good urban planning principles. It fails to achieve an appropriate balance between growth and liveability.
I respectfully urge the NSW Government to reject SSD-95997711 in its current form. At a minimum, the proposal should be required to revert to a scale and density consistent with the originally approved scheme, or be significantly redesigned to address the serious concerns outlined above. This ultimately all will result in a material reduction in the quality of life for the thousands of existing residents of Waterloo, 2017, already one of Sydney's most populous postcodes - an area that has been under urban intensification strain for years. Ghettoisation and a real erosion of the sense of community and belonging for Waterloo, 2017 is the inevitable next step, if this proposal proceeds in its current form.
Thank you for the opportunity to provide this submission.
Yours faithfully,
Paul Dobson.
Ed Sholl
Object
Ed Sholl
Object
WATERLOO
,
New South Wales
Message
To whom it may concern:
I am writing to strongly object to the proposed modifications for 903–921 Bourke Street, Waterloo (SSD-95997711). I live within walking distance of the site at 32 Wellington Street Waterloo, with my wife, 3 young children and an au pair. What is being proposed here will directly shape the streets my family walks every day, the school my children will go to, the buses my wife and I rely on for the daily commute, and the neighbourhood we chose to put down roots in. Like many of my neighbours, I am not opposed to housing, and I am not opposed to renewal in this part of Waterloo. I am opposed to the way this proposal has expanded so far beyond what was originally approved, the absence of any matching plan for the schools, transport and community infrastructure that 580 apartments will demand, and the fact that the most meaningful community protections - including the affordable housing offer - appear to be optional rather than binding.
What is being proposed is no longer the same project:
The original consent for this site was for 347 dwellings at around 65 metres in height, with a floor space ratio of 1.5:1. The application now before the Department proposes 580 dwellings (a 67% increase) at 126 metres (almost double the height), with a floor space ratio of 3.2:1. That is not a modification. It is a substantially different project. A change of this magnitude should require a fresh assessment process, a new design competition, and a new Voluntary Planning Agreement scaled to what is actually being asked for.
Instead, the State Significant Development pathway is being used to push the project through while excluding the very clauses - 6.14 and 6.21D - that would normally require independent design review and proper infrastructure contributions to the City of Sydney. The community is being asked to accept a building 55% larger than what was approved, while the public benefits offered in return are essentially unchanged. The same plaza, the same footpath widening, the same heritage square, for 233 additional apartments. That is not a fair exchange. It has the appearance of a community benefit without the substance of one.
My concerns as a local resident:
I have three direct, day-to-day concerns.
1. Schools - Alexandria Park Community School is already at capacity for kindergarten next year. Our eldest child will start primary school in 2028, and will surely be affected by this development. There is no plan in this application for additional school infrastructure to accommodate the families that 580 new apartments will bring. Parents in this neighbourhood are already being told their children may not get a place at their nearest school. Adding this many homes without any matching investment in school capacity is an obvious and avoidable failure of planning.
2. Transport - Buses on the routes that serve this site regularly pass already full at peak hour. My wife and I take the 343 every morning and evening. The McEvoy/Burke Street corner has well-documented blind spots. The Young/Danks Street intersection floods. Yet this proposal adds 233 dwellings while providing only 20 additional car spaces, on the assumption that those residents will rely on a public transport network the application has not assessed in any meaningful cumulative way. When the Coronation development, the Barings development on O'Dea Avenue, and the Waterloo Metro Quarter are layered on top of this proposal, the impact is not negligible. It has simply not been assessed together.
3. Neighbourhood character - The site sits beside streets of one and two-storey terraces. A 40-storey tower next to that built form is not a transition - it is a wall. The proposal makes no serious attempt to explain how a building of this height belongs in this part of Waterloo. Compounding that, the wind assessment relies on a neighbouring development (Coronation) that has not yet been approved or built. Pedestrian safety at street level is, in effect, being modelled against a building that may never exist.
The affordable housing offer is not what it appears to be:
The part of this application that concerns me most is the headline 12% affordable housing contribution presented in the planning statement. On a careful reading of the applicant's own documents, that figure is drawn from a City of Sydney policy the application explicitly states it is not bound by. Both the mandatory baseline and the 12% uplift contribution can be discharged through "an equivalent financial contribution" rather than as actual dwellings. There is no binding Voluntary Planning Agreement securing the affordable component.
In plain terms: it is entirely possible for this development to be approved, built, and sold without a single affordable dwelling existing on the site. That is not an affordable housing offer. It is a marketing line. If the Department is being asked to approve a 67% increase in yield on the strength of community benefits, those benefits must be enforceable - secured through a binding VPA, delivered as actual on-site dwellings, and managed in perpetuity by a registered community housing provider. Anything less is a transfer of value from the public to the developer dressed up as a community return.
What I am asking the Department to do:
I ask the Department to refuse the application as proposed. If the Department is minded to consider it further, I ask that it:
1. Refuse the exclusion of clauses 6.14 and 6.21D, or alternatively require an independent design review and a renegotiated Voluntary Planning Agreement scaled to the 55% increase in apartment yield.
2. Require the affordable housing component to be delivered as actual on-site dwellings, secured through a binding VPA that cannot be substituted with a financial contribution, and managed by a registered community housing provider.
3. Require a cumulative transport assessment covering all concurrent developments in the precinct before consent is granted.
4. Require a revised wind assessment that does not rely on the unapproved Coronation development.
5. Require a binding plan for additional school capacity to match the increase in dwellings.
Given the scale of the changes proposed and the precedent this would set for development across Waterloo and the wider inner south, I also ask that a public hearing be held so that residents have a proper opportunity to be heard.
This is not a submission against change in Waterloo. It is a submission against this particular change - one that is too tall, too dense, too thin on infrastructure, and too easy on the developer. Waterloo can absorb more housing. It cannot absorb this version of it.
Yours sincerely,
Ed Sholl
32 Wellington Street Waterloo
I am writing to strongly object to the proposed modifications for 903–921 Bourke Street, Waterloo (SSD-95997711). I live within walking distance of the site at 32 Wellington Street Waterloo, with my wife, 3 young children and an au pair. What is being proposed here will directly shape the streets my family walks every day, the school my children will go to, the buses my wife and I rely on for the daily commute, and the neighbourhood we chose to put down roots in. Like many of my neighbours, I am not opposed to housing, and I am not opposed to renewal in this part of Waterloo. I am opposed to the way this proposal has expanded so far beyond what was originally approved, the absence of any matching plan for the schools, transport and community infrastructure that 580 apartments will demand, and the fact that the most meaningful community protections - including the affordable housing offer - appear to be optional rather than binding.
What is being proposed is no longer the same project:
The original consent for this site was for 347 dwellings at around 65 metres in height, with a floor space ratio of 1.5:1. The application now before the Department proposes 580 dwellings (a 67% increase) at 126 metres (almost double the height), with a floor space ratio of 3.2:1. That is not a modification. It is a substantially different project. A change of this magnitude should require a fresh assessment process, a new design competition, and a new Voluntary Planning Agreement scaled to what is actually being asked for.
Instead, the State Significant Development pathway is being used to push the project through while excluding the very clauses - 6.14 and 6.21D - that would normally require independent design review and proper infrastructure contributions to the City of Sydney. The community is being asked to accept a building 55% larger than what was approved, while the public benefits offered in return are essentially unchanged. The same plaza, the same footpath widening, the same heritage square, for 233 additional apartments. That is not a fair exchange. It has the appearance of a community benefit without the substance of one.
My concerns as a local resident:
I have three direct, day-to-day concerns.
1. Schools - Alexandria Park Community School is already at capacity for kindergarten next year. Our eldest child will start primary school in 2028, and will surely be affected by this development. There is no plan in this application for additional school infrastructure to accommodate the families that 580 new apartments will bring. Parents in this neighbourhood are already being told their children may not get a place at their nearest school. Adding this many homes without any matching investment in school capacity is an obvious and avoidable failure of planning.
2. Transport - Buses on the routes that serve this site regularly pass already full at peak hour. My wife and I take the 343 every morning and evening. The McEvoy/Burke Street corner has well-documented blind spots. The Young/Danks Street intersection floods. Yet this proposal adds 233 dwellings while providing only 20 additional car spaces, on the assumption that those residents will rely on a public transport network the application has not assessed in any meaningful cumulative way. When the Coronation development, the Barings development on O'Dea Avenue, and the Waterloo Metro Quarter are layered on top of this proposal, the impact is not negligible. It has simply not been assessed together.
3. Neighbourhood character - The site sits beside streets of one and two-storey terraces. A 40-storey tower next to that built form is not a transition - it is a wall. The proposal makes no serious attempt to explain how a building of this height belongs in this part of Waterloo. Compounding that, the wind assessment relies on a neighbouring development (Coronation) that has not yet been approved or built. Pedestrian safety at street level is, in effect, being modelled against a building that may never exist.
The affordable housing offer is not what it appears to be:
The part of this application that concerns me most is the headline 12% affordable housing contribution presented in the planning statement. On a careful reading of the applicant's own documents, that figure is drawn from a City of Sydney policy the application explicitly states it is not bound by. Both the mandatory baseline and the 12% uplift contribution can be discharged through "an equivalent financial contribution" rather than as actual dwellings. There is no binding Voluntary Planning Agreement securing the affordable component.
In plain terms: it is entirely possible for this development to be approved, built, and sold without a single affordable dwelling existing on the site. That is not an affordable housing offer. It is a marketing line. If the Department is being asked to approve a 67% increase in yield on the strength of community benefits, those benefits must be enforceable - secured through a binding VPA, delivered as actual on-site dwellings, and managed in perpetuity by a registered community housing provider. Anything less is a transfer of value from the public to the developer dressed up as a community return.
What I am asking the Department to do:
I ask the Department to refuse the application as proposed. If the Department is minded to consider it further, I ask that it:
1. Refuse the exclusion of clauses 6.14 and 6.21D, or alternatively require an independent design review and a renegotiated Voluntary Planning Agreement scaled to the 55% increase in apartment yield.
2. Require the affordable housing component to be delivered as actual on-site dwellings, secured through a binding VPA that cannot be substituted with a financial contribution, and managed by a registered community housing provider.
3. Require a cumulative transport assessment covering all concurrent developments in the precinct before consent is granted.
4. Require a revised wind assessment that does not rely on the unapproved Coronation development.
5. Require a binding plan for additional school capacity to match the increase in dwellings.
Given the scale of the changes proposed and the precedent this would set for development across Waterloo and the wider inner south, I also ask that a public hearing be held so that residents have a proper opportunity to be heard.
This is not a submission against change in Waterloo. It is a submission against this particular change - one that is too tall, too dense, too thin on infrastructure, and too easy on the developer. Waterloo can absorb more housing. It cannot absorb this version of it.
Yours sincerely,
Ed Sholl
32 Wellington Street Waterloo
Name Withheld
Object
Name Withheld
Object
WATERLOO
,
New South Wales
Message
I am writing to formally object to the proposed Waterloo Mixed Use Development at 903-921 Bourke Street, SSD-95997711. I acknowledge the need for thoughtful urban growth, but this proposal, in its current form, raises significant concerns regarding height, density, and the cumulative strain it will impose on an already congested local infrastructure. Details of my concerns are as follows:
1. The proposal creates a Vertical Obstruction Angle that results in extreme visual bulk and overwhelming looming presence. The development would be a dominant wall-like mass with negative visual impacts, detriment of solar access on public areas and adjacent lower level dwellings, and general damage to liveability and environmental performance, contrary to the intent of the NSW Government Apartment Design Guide (ADG, July 2015) and SEPP 65 principles.
2. The increased height and additional dwellings would intensify the development impacts, amplifying issues relating to traffic, congestion, and infrastructure strain. It should be noted that the population density in the area is already one of the highest in Australia. Local infrastructure is already under considerable pressure, such as the road network on Bourke Street, McEvoy Street and surrounding intersections, which gets heavily congested, particularly during peak hours.
3. Public transport is a sensitive issue, with bus services and the nearby Green Square train station already at or near capacity, especially during commuting periods. The proposal does not address how increased demand will be accommodated. With the Waterloo metro station about 18 minutes walk from the site, this is hardly an argument for a transport solution catering for the additional dwellings proposed.
4. Recent studies show that educational facilities in the Waterloo-Zetland area are currently overstretched, with a significant increase in student enrolment, which has not been matched by adequate school infrastructure planning. The proposal does not describe how this issue would be addressed.
5. The proposal seeks to significantly increase the number of dwellings without demonstrating that supporting infrastructure, including essential services, stormwater and sewer capacity, electrical capacity, and waste collection, can accommodate this growth. Community centres, recreational facilities, and open spaces are already struggling to meet current demand. The development does not provide adequate additional community infrastructure to offset its impact.
6. This proposal places a cumulative impact on residents already dealing with pressure from a similar proposal immediately north of this development (SSD-80441462 by Coronation Property - refer to attachment*), who is also seeking approval for increased building heights and additional bulk, with no serious regard for the rules (their proposed changes, for example, are well above and beyond the FSR bonuses offered for design and affordable housing) and no demonstrated benefit to the current and future residents. Approval of either of these two proposals will likely set a precedent for approval of the other, doubling the impact of the issues noted above (with new apartment numbers increasing to around 500) and causing long term damage to existing residents - reflected in loss of amenity, congestion, cumulative deterioration of the mixed-use character that makes Danks Street functional and attractive. This would also adversely affect the market value of established properties.
In conclusion, the proposal to change the maximum building height from 65m to a maximum of 126m and increase the Floor Space Ratio from 1.5:1 to 3.2:1 (more than double!) is completely out of balance, opportunistic and excessive, only translating in revenue potential for the developer. There is little verifiable evidence of active initiatives to address the issues inherent to the proposal and create overall benefits contributing to the Vision conceived by the City of Sydney Council for the Danks Street South Precinct**. The proposal to create a clause to exclude applicability of Clauses 6.14 and 6.21D of the Sydney Local Environmental Plan 2012 (as noted in the exhibition letter) clearly suggests the Proponent's desire to be exempt from the rules that were precisely put in place to create a careful and consistent approach to developments in the area.
For all the reasons above I respectfully request that the terms of this proposal be rejected and the development under this application (SSD-95997711) only be allowed to proceed under the currently approved terms.
_______
Notes:
*The attachment is an edited version of a schematic shown by the proponent during a webinar presentation on 25/02/2026.
**Link: https://www.cityofsydney.nsw.gov.au/research-reports/danks-street-south-precinct-concept-design-summary.
1. The proposal creates a Vertical Obstruction Angle that results in extreme visual bulk and overwhelming looming presence. The development would be a dominant wall-like mass with negative visual impacts, detriment of solar access on public areas and adjacent lower level dwellings, and general damage to liveability and environmental performance, contrary to the intent of the NSW Government Apartment Design Guide (ADG, July 2015) and SEPP 65 principles.
2. The increased height and additional dwellings would intensify the development impacts, amplifying issues relating to traffic, congestion, and infrastructure strain. It should be noted that the population density in the area is already one of the highest in Australia. Local infrastructure is already under considerable pressure, such as the road network on Bourke Street, McEvoy Street and surrounding intersections, which gets heavily congested, particularly during peak hours.
3. Public transport is a sensitive issue, with bus services and the nearby Green Square train station already at or near capacity, especially during commuting periods. The proposal does not address how increased demand will be accommodated. With the Waterloo metro station about 18 minutes walk from the site, this is hardly an argument for a transport solution catering for the additional dwellings proposed.
4. Recent studies show that educational facilities in the Waterloo-Zetland area are currently overstretched, with a significant increase in student enrolment, which has not been matched by adequate school infrastructure planning. The proposal does not describe how this issue would be addressed.
5. The proposal seeks to significantly increase the number of dwellings without demonstrating that supporting infrastructure, including essential services, stormwater and sewer capacity, electrical capacity, and waste collection, can accommodate this growth. Community centres, recreational facilities, and open spaces are already struggling to meet current demand. The development does not provide adequate additional community infrastructure to offset its impact.
6. This proposal places a cumulative impact on residents already dealing with pressure from a similar proposal immediately north of this development (SSD-80441462 by Coronation Property - refer to attachment*), who is also seeking approval for increased building heights and additional bulk, with no serious regard for the rules (their proposed changes, for example, are well above and beyond the FSR bonuses offered for design and affordable housing) and no demonstrated benefit to the current and future residents. Approval of either of these two proposals will likely set a precedent for approval of the other, doubling the impact of the issues noted above (with new apartment numbers increasing to around 500) and causing long term damage to existing residents - reflected in loss of amenity, congestion, cumulative deterioration of the mixed-use character that makes Danks Street functional and attractive. This would also adversely affect the market value of established properties.
In conclusion, the proposal to change the maximum building height from 65m to a maximum of 126m and increase the Floor Space Ratio from 1.5:1 to 3.2:1 (more than double!) is completely out of balance, opportunistic and excessive, only translating in revenue potential for the developer. There is little verifiable evidence of active initiatives to address the issues inherent to the proposal and create overall benefits contributing to the Vision conceived by the City of Sydney Council for the Danks Street South Precinct**. The proposal to create a clause to exclude applicability of Clauses 6.14 and 6.21D of the Sydney Local Environmental Plan 2012 (as noted in the exhibition letter) clearly suggests the Proponent's desire to be exempt from the rules that were precisely put in place to create a careful and consistent approach to developments in the area.
For all the reasons above I respectfully request that the terms of this proposal be rejected and the development under this application (SSD-95997711) only be allowed to proceed under the currently approved terms.
_______
Notes:
*The attachment is an edited version of a schematic shown by the proponent during a webinar presentation on 25/02/2026.
**Link: https://www.cityofsydney.nsw.gov.au/research-reports/danks-street-south-precinct-concept-design-summary.
Attachments
Name Withheld
Object
Name Withheld
Object
Waterloo
,
New South Wales
Message
Formal Objection to Proposed Rezoning
903–921 Bourke Street, Waterloo
SSD‑95997711 | Proposed Amendment to Sydney Local Environmental Plan 2012
To whom it may concern,
I write to formally object to the proposed rezoning of land at 903–921 Bourke Street, Waterloo, as outlined in State Significant Development application SSD‑95997711.
The proposal seeks to amend the Sydney Local Environmental Plan 2012 to:
Increase the maximum building height from 65 metres to 126 metres
Increase the floor space ratio (FSR) from 1.5:1 to 3.2:1
Introduce a site‑specific clause to exclude the application of:
Clause 6.14 – Community Infrastructure Floor Space at Green Square
Clause 6.21D – Competitive Design Process
These amendments would result in an extraordinary uplift in height, density and population, while simultaneously removing key planning controls specifically designed to manage growth, infrastructure demand, and design quality in the Green Square and Waterloo precincts.
1. Inappropriate and Excessive Uplift in Height and Density
The proposed rezoning seeks to more than double the allowable building height and floor space previously approved for this site.
Under the proposal:
Bourke Street North increases from 12 storeys to 31 storeys
Young Street Tower increases from 21 storeys to 38 storeys
Apartment yield increases from 347 to approximately 580 dwellings
This represents a fundamental departure from the planning framework, built form controls, and strategic intent that underpinned the original approval by the City of Sydney.
Such an increase cannot reasonably be characterised as a minor planning adjustment. It is a radical intensification that undermines certainty in the planning system and disregards the reasonable expectations of existing residents and landowners who relied on approved controls.
2. Removal of Critical Community Infrastructure Contributions (Clause 6.14)
The proposal explicitly seeks to exclude the application of Clause 6.14, which exists to ensure that significant uplift in residential density is accompanied by appropriate contributions to community infrastructure.
This is particularly concerning given:
The addition of 233 apartments on this site alone
The cumulative impact of multiple nearby State Significant Developments
Existing pressure on libraries, community facilities, open space and local services
Allowing a substantial population increase without commensurate infrastructure provision directly contradicts both the intent of the LEP and principles of orderly and sustainable development under the Environmental Planning and Assessment Act 1979.
3. Infrastructure, Transport and Parking Impacts
The proposal would generate a significant increase in daily trips, service vehicles, deliveries and ride‑share activity, yet provides only 20 additional car parking spaces.
Local infrastructure is already operating at or near capacity:
Bus services (including the 304 route) are regularly overcrowded, with services bypassing stops
Green Square Station experiences severe peak‑hour congestion
Local roads and on‑street parking are heavily constrained
The proposal relies on existing infrastructure that is already inadequate and provides no credible or enforceable mechanism to address the increased demand created by this rezoning.
4. Failure to Address Cumulative Impacts
The proposed rezoning must be assessed in conjunction with:
The approved and proposed development at 881–885 Bourke Street, Waterloo (SSD‑80441462), including a 38‑storey residential tower
Multiple other high‑density developments across Waterloo and Zetland
The cumulative outcome is an estimated 4,000 additional dwellings and up to 8,000 new residents within a highly concentrated area over a short period of time.
This scale of growth is equivalent to inserting a small regional town into an inner‑city precinct without the infrastructure, transport or open space capacity to support it.
5. Overshadowing, Amenity and Built Form Impacts
The proposed towers, when combined with adjacent developments, would result in substantial cumulative overshadowing, particularly at the winter solstice, affecting:
Nearby residential properties
Public open spaces
Street‑level amenity
The proposed height and bulk are visually dominating and out of scale with the surrounding context and undermine planned height transitions within the precinct.
6. Wind Impacts and Public Safety
Buildings of the proposed height and bulk present a high risk of adverse wind conditions at street level, including wind tunnelling and downdrafts.
These conditions can:
Reduce pedestrian comfort
Pose safety risks
Diminish the livability and usability of streets and public areas
It is therefore wholly inappropriate that the proposal seeks to remove the requirement for a Competitive Design Process under Clause 6.21D, which is a critical mechanism for ensuring design excellence and mitigating high‑rise impacts.
7. Strategic and Precedent Concerns
Approval of this rezoning would establish a dangerous precedent, signalling that approved height and density controls can be significantly exceeded through post‑approval rezoning, rather than through strategic, precinct‑wide planning.
This undermines:
Confidence in the planning system
Strategic planning for Green Square and Waterloo
The principle that growth should be aligned with infrastructure delivery
Conclusion
This proposal represents overdevelopment of the site, removal of essential planning safeguards, and a clear failure to balance private development yield with public interest outcomes.
For these reasons, I strongly object to the proposed rezoning of 903–921 Bourke Street, Waterloo, and urge the NSW Government to refuse the LEP amendments in their current form.
903–921 Bourke Street, Waterloo
SSD‑95997711 | Proposed Amendment to Sydney Local Environmental Plan 2012
To whom it may concern,
I write to formally object to the proposed rezoning of land at 903–921 Bourke Street, Waterloo, as outlined in State Significant Development application SSD‑95997711.
The proposal seeks to amend the Sydney Local Environmental Plan 2012 to:
Increase the maximum building height from 65 metres to 126 metres
Increase the floor space ratio (FSR) from 1.5:1 to 3.2:1
Introduce a site‑specific clause to exclude the application of:
Clause 6.14 – Community Infrastructure Floor Space at Green Square
Clause 6.21D – Competitive Design Process
These amendments would result in an extraordinary uplift in height, density and population, while simultaneously removing key planning controls specifically designed to manage growth, infrastructure demand, and design quality in the Green Square and Waterloo precincts.
1. Inappropriate and Excessive Uplift in Height and Density
The proposed rezoning seeks to more than double the allowable building height and floor space previously approved for this site.
Under the proposal:
Bourke Street North increases from 12 storeys to 31 storeys
Young Street Tower increases from 21 storeys to 38 storeys
Apartment yield increases from 347 to approximately 580 dwellings
This represents a fundamental departure from the planning framework, built form controls, and strategic intent that underpinned the original approval by the City of Sydney.
Such an increase cannot reasonably be characterised as a minor planning adjustment. It is a radical intensification that undermines certainty in the planning system and disregards the reasonable expectations of existing residents and landowners who relied on approved controls.
2. Removal of Critical Community Infrastructure Contributions (Clause 6.14)
The proposal explicitly seeks to exclude the application of Clause 6.14, which exists to ensure that significant uplift in residential density is accompanied by appropriate contributions to community infrastructure.
This is particularly concerning given:
The addition of 233 apartments on this site alone
The cumulative impact of multiple nearby State Significant Developments
Existing pressure on libraries, community facilities, open space and local services
Allowing a substantial population increase without commensurate infrastructure provision directly contradicts both the intent of the LEP and principles of orderly and sustainable development under the Environmental Planning and Assessment Act 1979.
3. Infrastructure, Transport and Parking Impacts
The proposal would generate a significant increase in daily trips, service vehicles, deliveries and ride‑share activity, yet provides only 20 additional car parking spaces.
Local infrastructure is already operating at or near capacity:
Bus services (including the 304 route) are regularly overcrowded, with services bypassing stops
Green Square Station experiences severe peak‑hour congestion
Local roads and on‑street parking are heavily constrained
The proposal relies on existing infrastructure that is already inadequate and provides no credible or enforceable mechanism to address the increased demand created by this rezoning.
4. Failure to Address Cumulative Impacts
The proposed rezoning must be assessed in conjunction with:
The approved and proposed development at 881–885 Bourke Street, Waterloo (SSD‑80441462), including a 38‑storey residential tower
Multiple other high‑density developments across Waterloo and Zetland
The cumulative outcome is an estimated 4,000 additional dwellings and up to 8,000 new residents within a highly concentrated area over a short period of time.
This scale of growth is equivalent to inserting a small regional town into an inner‑city precinct without the infrastructure, transport or open space capacity to support it.
5. Overshadowing, Amenity and Built Form Impacts
The proposed towers, when combined with adjacent developments, would result in substantial cumulative overshadowing, particularly at the winter solstice, affecting:
Nearby residential properties
Public open spaces
Street‑level amenity
The proposed height and bulk are visually dominating and out of scale with the surrounding context and undermine planned height transitions within the precinct.
6. Wind Impacts and Public Safety
Buildings of the proposed height and bulk present a high risk of adverse wind conditions at street level, including wind tunnelling and downdrafts.
These conditions can:
Reduce pedestrian comfort
Pose safety risks
Diminish the livability and usability of streets and public areas
It is therefore wholly inappropriate that the proposal seeks to remove the requirement for a Competitive Design Process under Clause 6.21D, which is a critical mechanism for ensuring design excellence and mitigating high‑rise impacts.
7. Strategic and Precedent Concerns
Approval of this rezoning would establish a dangerous precedent, signalling that approved height and density controls can be significantly exceeded through post‑approval rezoning, rather than through strategic, precinct‑wide planning.
This undermines:
Confidence in the planning system
Strategic planning for Green Square and Waterloo
The principle that growth should be aligned with infrastructure delivery
Conclusion
This proposal represents overdevelopment of the site, removal of essential planning safeguards, and a clear failure to balance private development yield with public interest outcomes.
For these reasons, I strongly object to the proposed rezoning of 903–921 Bourke Street, Waterloo, and urge the NSW Government to refuse the LEP amendments in their current form.