This proposal is not appropriate for a number of reasons.
1 - the area has very little employment that is not service related, so very very few jobs that pay decent money, are secure or utilise higher education
2 - The road itself is very narrow with no opportunity to widen, it is also heavily used by tourists that add and complicate residential traffic
3 - Services in the area are not available for this number of new residents,the existing medical infrastrucure already has problems coping with current population
4 - The distance from Sydney and even Penrith, Blacktown and Parrmatta is quite significant. Roads and Maritime services may say that Katoomba is 1hr 45mins from Sydney but those of us who live here (yes I live in the lower Mountains but work and travel to the upper mountains and beyond very regularly) know that this estimation is a joke. Travel time may be applicable when the weather is fine and it is the middle of a week day but it only takes one traffic accident to block the whole highway and even at present weekend travel can be a nightmare
5 - The alternative of Public Transport is also another nightmare. It is a long cold dark trip in winter, the trains are more than full on the weekends and it is only since the disaster of Mount Victoria that there are even enough trains
6 - Overall this is not a good proposal. The area is in a major fire zone on top of everything else.
There are many reasons why this proposal is not a good idea, from environmental to cultural to transport to services. If the Governement is so set on too many new people into the country medium density housing needs to be in areas that can cope with the influx of population and the strain on the environment

The proposed development at 142–150 Narrow Neck Road is exactly the kind of sensible, well-located project Katoomba actually needs. This is even if any form of development in general, tends to be treated locally as if it were an outrageous suggestion to be avoided at all costs. As outlined in the EIS (p.23), the proposal supports the Blue Mountains City Council’s strategic objectives outlined in ‘2040 Living Sustainably – Local Strategic Planning Statement’ by delivering much-needed housing diversity and strengthening Katoomba’s role as a key centre. This is hard to argue against unless the preferred alternative is simply to do nothing or replicate the single dwelling, 2 storey grey boxes, on 300m2 lots that combine to form the dystopian hellscape that outer Sydney is fast becoming.
The reality is that Katoomba needs more residents—not fewer—to stay alive and relevant. A growing population brings customers, which brings businesses, which brings jobs and revenue, which hopefully leads to a town centre that doesn’t feel like it peaked sometime in that latter stages Queen Victoria’s reign. Right now, too many tourists arrive, take a quick photo of the Three Sisters, and leave without spending much time or money, largely because there’s limited vibrancy to keep them around. More locals means more life, more choice, and a stronger economy.
From a planning perspective, the proposal stacks up. It’s on land that isn’t bushfire or flood-prone, isn’t heritage listed, and only takes up a small portion of the disused Katoomba Golf Course. There’s already a clear precedent nearby with the development at 152–166 Narrow Neck Road, so this isn’t exactly a radical experiment. The design incorporates ESD principles and substantial landscaping, and the stepped form ensures it sits comfortably within the landscape rather than looming over it. Importantly, it also delivers a mix of housing, including affordable options, which is critical given the very real housing crisis facing Sydney and its surrounds.
For those opposing the project on principle, it’s worth remembering that Council approved a very large development on this very site back in 2001, including a hotel and over 100 residential units. So the idea that this land should remain frozen in time doesn’t quite hold up. Ultimately, the question is whether Katoomba wants to evolve into a more vibrant, functional centre, or slowly fade into a picturesque but struggling relic. This proposal leans firmly toward the former, and for that reason, deserves support.

Re: Residential flat buildings at 142-150 Narrow Neck Road, Katoomba, this proposed development at Narrow Neck is unsuitable because:

1) The Blue Mountains is a World Heritage National Park, not a blank canvas for developers to be given free rein to destroy and redesign as they choose.

2) To insert such a concentrated amount of residential development into such a high bushfire prone area, will only pose a major increase in the risk to firefighters as well as to the residents who live there.

3) The network of roads in this area is not suitable to cope with the additional traffic payload that would be introduced as a result of this proposal. The Blue Mountains national park already has significant traffic chaos due to the sheer number of tourists and visitors, as it is one of THE most visited national parks in NSW.

4) The construction of a project of this size would have a huge impact on the natural environment immediately adjacent to it, due to the run off and pollution, both during the construction phase and afterwards.

5) Every council in Sydney is responsible for their local area from the planning, development and approval stages to ensure that what is done is appropriate and in keeping with their particular area. This proposal has been taken out of the hands of our local council, who would follow the appropriate investigation. It has totally bypassed the Blue Mountains City Council with a complete disregard for the many issues involved.

6) The Blue Mountains City Council follows the principle of responsible development which is controlled by the LEP, the Local Environment Plan. The LEP allows the Blue Mountains City Council to approve balanced responsible developments to take place, which is not what this proposal has done.

7) The proposal suggests there could be some 218 new residences. Given the lack of any regulation or meaningful control on the number of Airbnb properties in the Blue Mountains, then how many of these residences may also ONLY be used for Airbnb and not for the purpose of meaningfully helping to solve the local housing problem for residents in the Blue Mountains.

8) There was a time when it was acknowledged by the NSW government that the Blue Mountains is a special environment that needs to be protected and exempted from many of the policy decisions that affect the Sydney basin, such as the NSW Low and Mid-rise Housing Policy. We now have the Housing Delivery Authority with the right to dictate what happens in this area of national significance, with absolute impunity.

9) As another example of the speed that this proposal is being pushed through with, is the total disregard for the normal democratic processes. The Environmental Impact Statement (EIS) was on exhibition for a short 14 day period, which does not give much time for people who would reasonably object to it to make their submission. I do wish however to thank Major Projects for extending the time allowed to make a submission, by an extra week.

In conclusion, this State Significant Development is a complete over reaching of power by the Department of Planning, Housing and Infrastructure. The only justification for this proposal to be granted an elevated status is purely a reflection of how much money is involved, which is not what I would have expected from a responsible Labor Government but from the Liberal Party working in tandem with developers.

I sincerely hope that the decision on this proposal will not be made by people who live “out of the area” in which the decision will impact, such as has already happened with the Sydney Western City Planning Panel to approve a Springwood Woolworths project despite the number of objections received against it.

I grew up in the Blue Mountains and recently moved back with my young family. I chose this area because it offers a relaxed lifestyle surrounded by nature. Living here again has made me acutely aware of how precious our environment, safety and community character are, particularly after experiencing constant and poorly planned development during my years in Sydney.

Why I oppose the proposal

1. Overriding local council
The Blue Mountains City Council has spent years consulting residents, experts and stakeholders to protect our unique landscape. The Housing Delivery Authority (HDA) bypasses that process, bringing outsiders who prioritise developer interests over local communities. This undermines the credibility of decisions that affect our lives.

2. Bushfire risk
The site is in a bushfire‑prone area with very limited evacuation routes. The proposal adds hundreds of residents to an already narrow road network, creating a dangerous bottleneck during emergencies. There is only one major evacuation route to the Great Western Highway, which may become impassable during emergencies. This density will put lives at serious risk.

3. Zoning
The land is zoned R3 Medium Density, with a maximum height of 8 metres under the Blue Mountains LEP. The developer’s request to build nine four‑storey buildings far exceeds what the zoning allows and would set an unwanted precedent for future high‑density projects in the Blue Mountains. Moreover, this development lies within a World Heritage Area; placing such dense construction there is wholly inappropriate and contrary to the principles that protect these globally significant landscapes - Particularly developments that are visible on the escarpment and impact local watercourses.

4. Infrastructure overload
The existing road, sewer, electricity and transport systems are already near capacity. Adding several hundred new vehicles and residents would overwhelm them and degrade the quality of life for all residents.

Specific requests
- I request that the Department refuse approval for the proposed nine four‑storey buildings as they stand.
- I ask that the Blue Mountains Local Government Area be exempted from the HDA/SSD pathways so that decisions remain in local hands. Particularly as it is an environmentally sensitive world heritage area with significant bushfire considerations.
- I recommend a site visit by the Consent Authority, including an assessment of surrounding visitor destinations and environmentally sensitive areas.

The Blue Mountains are a fragile ecosystem that must be protected for future generations. Approving this proposal would set a dangerous precedent, compromise the environment, safety and character of the mountains, and place unnecessary risk on new and existing residents in an emergency. I urge you to consider these points carefully and reject the development as it is currently proposed.

To Whom It May Concern,

I wish to formally object to the proposed Residential Flat Buildings development at 142–150 Narrow Neck Road, Katoomba (SSD-86456706).

While I acknowledge the need for additional housing supply in regional NSW and support well-considered development that responds appropriately to local context, this proposal represents a profound overdevelopment of one of the most environmentally and visually sensitive areas in the Blue Mountains.

The scale, density, and urban form proposed are fundamentally incompatible with the existing character, infrastructure limitations, ecological sensitivity, and tourism identity of Katoomba and the Narrow Neck precinct.

At its core, this proposal appears to import a metropolitan density model into a landscape that is internationally recognised precisely because it is not metropolitan.

Katoomba is not lacking identity awaiting intensification to become economically viable. Its identity, ecological significance, tourism economy, and liveability already derive from the balance between built environment and surrounding landscape. Developments of this scale risk eroding the very qualities that make the area desirable in the first place.

The proposal includes:

* 218 dwellings
* 52 serviced apartments
* nine separate buildings
* associated hospitality and commercial uses

This is an extraordinarily large development footprint for a highly constrained mountain environment already experiencing infrastructure pressure, road congestion during peak tourism periods, and increasing strain on local services.

Of particular concern are the following issues:

1. Incompatibility with Local Character

The proposed bulk, density, and built form are inconsistent with the established low-rise, dispersed character of Katoomba and the broader Blue Mountains region.

While change and growth are inevitable, planning policy should still exercise proportionality and contextual judgment. There is a substantial difference between incremental densification and effectively inserting a quasi-urban apartment complex into an environmentally constrained mountain township.

The cumulative visual impact of nine buildings in this location risks permanently altering the landscape character of the Narrow Neck corridor and setting a precedent for further inappropriate intensification.

2. Environmental and Ecological Concerns

The Blue Mountains is not an ordinary development corridor. It is part of a globally recognised World Heritage landscape with highly sensitive ecosystems, biodiversity corridors, and bushfire exposure.

Even where mitigation measures are proposed on paper, there are legitimate concerns regarding:

* habitat fragmentation
* stormwater runoff and downstream impacts
* vegetation loss
* increased human pressure on surrounding bushland
* long-term ecological degradation through cumulative development pressure

Planning systems should not operate solely on the assumption that every impact can be “managed” through technical conditions. Some locations are simply less appropriate for developments of this intensity.

3. Bushfire and Emergency Access Risks

The Narrow Neck area is already known for bushfire exposure and evacuation complexity.

Increasing permanent and transient population density in this location through both residential dwellings and serviced apartments raises serious questions regarding:

* evacuation capacity
* emergency vehicle access
* road network resilience
* visitor management during high-risk periods

Given recent fire history in the Blue Mountains, it is difficult to understand the strategic rationale for concentrating such a large population footprint in this location.

4. Traffic and Infrastructure Pressure

Katoomba already experiences substantial congestion during weekends, holiday periods, and tourism peaks.

A development of this scale will place additional pressure on:

* local roads
* parking availability
* water and sewer infrastructure
* waste systems
* emergency and health services

The inclusion of serviced apartments further intensifies this issue by introducing a semi-tourism accommodation layer on top of permanent residential demand.

There is also concern that infrastructure modelling often reflects ideal operational assumptions rather than lived reality in regional tourist towns with fluctuating peak demand.

5. Housing Outcomes and Community Benefit

While the inclusion of 15% affordable housing is noted, it is difficult to ignore that the majority of this proposal appears oriented toward higher-density investment and tourism outcomes rather than genuinely addressing the structural housing needs of the local community.

There is growing frustration across regional NSW at developments that invoke the language of “housing supply” while functionally operating as tourism-adjacent or investor-oriented urban expansion.

The Blue Mountains absolutely needs thoughtful housing solutions. However, scale and appropriateness still matter.

Poorly contextualised development is not automatically justified simply because it contains housing.

6. Strategic Planning Concerns

Approving a project of this magnitude risks establishing a precedent that significantly shifts the planning expectations for Katoomba and similar Blue Mountains townships.

Residents are entitled to ask whether this reflects a genuine long-term strategic vision for the region, or whether planning controls are increasingly being stretched through State Significant Development pathways that override local character considerations.

There is a growing perception that “state significance” can sometimes function less as a marker of public benefit and more as a mechanism to bypass the normal scale expectations communities reasonably rely upon.

In closing, I strongly urge the Department to reject this proposal in its current form.

This is not an objection to all development, nor to all increased housing density. It is an objection to a development whose scale, intensity, and urban character appear fundamentally mismatched to its setting.

Good planning is not merely about maximising yield on paper. It is about exercising judgment, restraint, and long-term stewardship over places that cannot easily recover once overdeveloped.

The Blue Mountains is one of the most environmentally and culturally distinctive regions in New South Wales. Developments within it should reflect that reality with humility and proportionality.

Yours sincerely,
Samuel Herczeg

To whom it may concern
I wish to express my opposition to the proposed development at 142-150 Narrow Neck Road, Katoomba and also the use of the Housing Delivery Authority (HAD) pathway in the Blue Mountains.
I moved to the Blue Mountains 13 years ago to enjoy a quiet retirement. I live opposite the creek which runs from the Gully to Katoomba Falls and look across the creek to the escarpment at Narrow Neck Road. This view is dominated by trees and is very restful.
I am opposing this proposal for the following reasons.
1. The escarpment at Narrow Neck Road will be spoilt by the erection of high rise buildings which are not in keeping with the vista expected in the Blue Mountains. The view from Echo Point to the west will be dominated by the proposed development.

2. The proposed development appears to be partially a tourist facility with serviced apartments and a Wellness Centre and restaurant. I do not understand how this facility can be regarded as a housing development under the Housing Delivery Authority pathway.

3. The development site is currently zoned R3 Medium Density. The proposed rezoning of the site and the size of the proposed development are in opposition to the Blue Mountains Local Environment Plan (LEP). The LEP represents years of expert planning and community consultation and is tailored to the Blue Mountains unique environmental context.

4. The site is adjacent to the Blue Mountains Swamps. These swamps feed the Katoomba Falls catchment. The increased surfaces would change water flow to the swamps, increase stormwater velocity and damage the swamp ecology.

5. The site is surrounded by bushfire prone land with limited evacuation routes. Adding hundreds of new residents would increase risk to life and hamper emergency response.

6. There is limited public transport to this area therefore the development would add several hundred vehicles to narrow local roads. The proposed development is two kilometres from local shops and rail transport in Katoomba.

7. There are limited health facilities in Katoomba. There are no specialists and all residents must travel to Penrith for specialist care. Increasing the population by several hundred residents will put a huge strain on the existing medical facilities and also increase traffic on the Highway with more people travelling to Penrith for care.

8. The proposed development threatens the unique character of Katoomba and surrounding visitor destinations.
Due to the unique site of Katoomba in a National Park the proposed development would adversely affect the areas character.
Katoomba is not suburb of Sydney and as such I believe should be exempt from the HDA pathway.
I understand the local member has previously written to the minister requesting this exemption and opposition to the proposed development. I trust you will consider this letter in opposition to the proposed development.

As a resident of Katoomba for over 20 years and having been employed in the Tourism industry for most of that time, I strongly oppose the Development proposal for 9 four storey buildings at 142 – 150 Narrowneck road.
The Blue Mountains is a unique wilderness area and the townships within that area have their own charm. The dramatic sandstone cliffs that these townships are perched upon are one of our star attractions. Tourism numbers to the area exceed 4 million visitors each year and the industry and associated businesses employ a vast majority of our population. The Visit NSW website highlights this world famous areas natural beauty.
The NSW governments new Housing Delivery Authority should not be applied to this area as it is distinctly different to any other area in the state. All development needs to be considered carefully and should be limited to constraints such as those set out in our Local Environmental Plan and Development Control Plan. Our local council has worked with the community for many years to protect our environment and foster Tourism in a sustainable manner. To allow building of this scale in an area so close to the escarpment will dramatically affect the natural bushland setting, views from Katoomba township and from Narrowneck plateau.
Additionally, the road access to & from Narrowneck road is in poor condition and not up to the increased traffic movement expected with an additional 800 – 1000 people staying in the area. This zone is also at high risk for bushfire being surrounded by vegetation. It would be irresponsible to significantly increase population in such an area, as it will put lives at risk.
Environmentally, the impact of this project will significantly increase stormwater volumes due to the hard impervious surfaces and roof areas. I doubt our current infrastructure is sufficient to take these volumes. One would imagine the sewerage system would also need to be upgraded. In extreme events any increased overflow would impact nearby swamps which are classified as a threatened ecological community. Further down these riparian corridors flow into the Kedumba river which in turn flows through escarpment into the catchment of Warragamba dam, Sydney’s main water supply. The escarpment ecosystems are also extremely sensitive and part of the reason the area is World Heritage listed.
I fear that if this proposal were to be approved, it would give the green light to other similar development, our Blue Mountains communities would be adversely affected and our surrounding environment would suffer. The fact that lives may be also put at risk should be enough to see merit in stopping this development proposal in its tracks. The Blue Mountains LGA should be excluded from Housing Delivery Authority pathway for development.
Yours sincerely

Guy McIlrath

Sustainable, compliant development is essential to maintaining the environmental integrity, safety, and character of the Blue Mountains. This obligation is heightened where development is proposed under the State Significant Development (SSD) pathway and accompanied by a site-specific rezoning, which together elevate development outcomes beyond standard local planning controls.
This submission objects to the proposed mixed-use development at 142–150 Narrow Neck Road, Katoomba on the basis that:
The application cannot be properly determined under Section 4.15 of the Environmental Planning and Assessment Act 1979 (EP&A Act) due to unresolved and insufficiently demonstrated impacts
There remain material uncertainties and inadequacies relating to:
Land Use and Zoning
Traffic, road network capacity, and public safety
Parking provision and internal/external access
Visual and landscape impacts in a sensitive Blue Mountains setting
Infrastructure capacity and servicing delivery
Geotechnical constraints and landform suitability
Stormwater management
Bushfire evacuation and emergency access
The proposal relies on a site-specific rezoning and SSD pathway that collectively enable development outcomes well beyond current controls without sufficient strategic justification.
The proposal, in its current form, contains unresolved and insufficiently demonstrated impacts and cannot be properly determined. It should be deferred, independently reviewed, and resubmitted following further detailed assessment
Accordingly, the application should be:
Deferred and referred to the Independent Planning Commission (IPC) for independent review, with a requirement to rescope and re-exhibit the proposal following clarification and demonstration of key impacts.
Land Use, Zoning and Strategic Planning Concerns
The site is currently zoned R3 Medium Density Residential. The proposal, however, comprises:
218 residential apartments
52 serviced apartments
Restaurant and public-facing uses
Information and education facilities
While elements of the proposal may be permissible with consent, the combined scale and mix of uses introduce:
A level of intensity beyond typical medium-density residential outcomes
A development profile more consistent with mixed-use or destination-style accommodation rather than local residential infill
The proposal relies on a concurrent rezoning to:
Increase height to 15.6m
Increase FSR to 1.17:1
This represents a substantial uplift from current controls and effectively enables a development outcome that would not otherwise be achievable.
Key Issue
The rezoning appears to be:
Site-specific and development-driven, rather than arising from a broader strategic planning framework
Not clearly supported by demonstrated infrastructure capacity or precinct-wide planning
This raise concerns regarding:
Consistency with the intent of the Blue Mountains LEP 2015
The precedent such uplift may create for similar sites
Traffic, Road Network and Public Safety
Road Network Constraints
The site is accessed via:
Narrow Neck Road (regional road)
Connections to the Great Western Highway
The surrounding road network is characterised by:
Constrained road widths
Limited pedestrian infrastructure
Minimal active transport options
While a Traffic Impact Assessment has been prepared, the EIS does not clearly demonstrate that:
The road network can safely accommodate the combined residential, serviced apartment, and visitor traffic
Intersection performance and peak movements remain within acceptable limits under all operating conditions
Construction Traffic and Safety
The development involves:
Significant excavation
Multi-stage construction
Basement works across multiple buildings
However, there is limited detail at the SSD stage regarding:
Construction traffic volumes
Heavy vehicle routes
Staging impacts on surrounding roads
Given the topographical constraints and residential context, further detailed assessment is required to demonstrate that:
Construction impacts can be safely managed
Public safety risks are minimised
Cumulative Traffic Impacts
The EIS does not clearly articulate:
Cumulative impacts from:
Existing developments within the precinct
Future development enabled by rezoning uplift
This is particularly relevant given:
The scale of the proposal
Limited alternative transport modes
Parking Provision and Access
The proposal includes a combination of:
Residential parking
Serviced apartment parking
Visitor and commercial parking demand
However, the EIS does not clearly demonstrate:
Adequacy of visitor parking provision
How peak demand across different uses will be managed
That parking supply will prevent overflow into surrounding streets
Key Risk
Inadequate parking provision may result in:
On-street parking pressure
Reduced road capacity
Increased safety risks and impacts on emergency access
Visual Impact and Landscape Character
The Blue Mountains landscape is highly sensitive, requiring development to:
Respond to topography
Avoid visual dominance
Maintain consistency with the natural and built character
The proposal introduces:
Multiple four-storey buildings
Significant bulk across a large site area
Assessment Concerns
While a Visual Impact Assessment has been undertaken, it is not clearly demonstrated that:
All relevant viewpoints, including broader landscape perspectives, have been fully considered
The cumulative visual impact of the development mass has been adequately assessed
Key Issue
The proposed height and FSR uplift:
Substantially exceed existing controls
May result in a built form that is visually prominent within the landscape, particularly given the site’s elevated and sloping nature
Geotechnical Constraints and Landform Suitability
The Preliminary Geotechnical Assessment confirms that:
The development will require excavation of up to approximately 9 metres across the site
The investigation is based on limited borehole sampling across a large site area
The report explicitly recommends further geotechnical investigation and monitoring
As stated in the report, additional investigation is required to inform final design parameters and construction methodologies.
Key Issue
This confirms that:
The geotechnical assessment is preliminary in nature
Site suitability for the proposed scale and intensity of development is not fully resolved at the SSD stage
Conclusion
Given the extent of excavation and the complexity of the site, the consent authority cannot be satisfied that:
Ground stability
Excavation impacts
Groundwater interaction
have been sufficiently demonstrated to support determination of the application.
Stormwater Management and Off-Site Impacts
The Services and Infrastructure Report confirm that:
Stormwater from the site will be discharged to existing basins located off-site
New stormwater infrastructure is required, including:
New drainage lines leaving the site
Potential works across adjoining land
The design relies on historical assumptions regarding basin capacity and impervious area
The report indicates that downstream basins were designed to accommodate an assumed 80% impervious area, compared to an estimated ~72% impervious area for the proposed development.
Key Issue
This approach:
Relies on historical design assumptions, rather than clearly demonstrated contemporary modelling
Does not clearly demonstrate that:
Downstream systems can accommodate flows under current conditions
Off-site infrastructure impacts are fully resolved
Conclusion
The stormwater strategy introduces uncertainty regarding:
Downstream flooding and drainage behaviour
Off-site infrastructure requirements
Long-term system performance
Further detailed assessment is required to demonstrate that stormwater impacts are acceptable.
Infrastructure and Servicing
The Services and Infrastructure Report identifies that:
Existing utility services and easements are to be relocated, modified or extinguished
The extent of service realignment and infrastructure works will be further defined at subsequent development stages
Final servicing arrangements are subject to further approvals and detailed design
Specifically:
The report states that service relocations and requirements will be “further identified during subsequent development applications”
Existing drainage easements are proposed to be extinguished and reconfigured
Key Issue
This indicates that:
Critical infrastructure design is not resolved at the time of assessment
The proposal relies on future design development and approvals to confirm feasibility
Conclusion
Without confirmed servicing arrangements, the consent authority cannot be satisfied that:
The development can be adequately serviced
Off-site impacts and works are fully understood
Infrastructure delivery is feasible and coordinated
Vegetation and Site Constraints
The site includes:
Remaining vegetation at the perimeter and internal areas
A 12m vegetation protection covenant along the road boundary
The proposal includes:
Tree removal
Encroachment into parts of the covenant area
Assessment Concerns
While the EIS indicates that development may occur within the covenant area subject to consent, this raises:
Questions regarding the intent and ongoing effectiveness of the vegetation protection measures
The extent to which environmental constraints have influenced site design
Bushfire and Emergency Access
The site is not mapped as bushfire prone land; however:
It is located within a broader landscape where bushfire risk is a relevant consideration
Access is reliant on a limited road network
Assessment Concerns
The EIS does not clearly demonstrate:
Evacuation capacity under emergency conditions
How increased population and traffic demand will affect egress during a bushfire event
Key Issue
Given:
The scale of the development
The constrained access network
further clarity is required to demonstrate that emergency evacuation can be safely managed.
Use of SSD and Rezoning Pathway