I understand NSW state is trying to lodge more residents by building high rise, however the system seems disorganised and offensive to local residents.
1, future high rise doesnt care lower houses, by blocking their sun access and privacy, can you imagine how much agony to each householder? physically and financially. Can you believe people are losing freedom even in their own home by living in Australia?
2, pacific high way is jammed badly already, all vehicles will flow into traffic soon after squeeze/struggle out from nearby small streets.
3, I have visited many countries in Europe, their towns are full of local culture and tradition, should we borrow some ideas and preserve our traditional culture?.
God bless Australia and Lindfield

I am writing to express my strong objection to the Concept SSD proposed by Castle Hill No.7 Pty Ltd, (SSD-82900461)
• Overshadowing cannot be assessed. Shadow Diagram DA402,403 did not have a true depiction of the surrounds. With such distorted representation of the neighbouring properties and no window placements, it is not possible to assess the true extend of overshadowing. It is also possible to assess if it has satisfied SEARs requirement on solar access let along whether it achieved Good Design Principles or satisfied ADG 2F requirements.
• Heritage Impact on Heritage Item 142 was not addressed. “Concept Plans” were used as an excuse by the applicant to avoid addressing any controls around development next to a heritage item. How can the visual impact be assessed when there is no definite proposal on design, material and colour scheme?
• Traffic Impact Underestimated
o Traffic analysis was done on a Thursday over two hours. However, highest traffic volume happens on Tuesdays and Wednesdays. The “peak hour” time chosen by the consultant was in fact “off peak” especially in the afternoon. 4:15pm is when school pick up subsides and real peak hour hasn’t started. To base an entire traffic analysis on such a small sample of data does not seen to be sufficiently scientific.
o The report states that Middle Harbour Rd records approximately 1600 vehicles on a typical weekday. However, it did not specify if this data was recorded based on one-day observations or over a period of time. It’s an overly simplistic statement to make with no substantiation.
o Cumulative traffic impacts in the report only included one development on Middle Harbour Rd, namely, 24-28 Middle Harbour Rd. However, there are two other development applications that are being proposed. These are,
 16 & 18-20 Middle Harbour Road Lindfield
 5 & 7 Middle Harbour Road Lindfield
There are other developments in close proximity to this site which were omitted. The cumulative impact should be assessed in aggregate as given the current traffic condition, vehicles, especially buses, have trouble turning right from Middle Harbour onto Lindfield Ave in peak hour time. Given the number of proposed developments along Middle Harbour Rd, one could envisage vehicles having trouble getting onto Middle Harbour Rd from their own apartment building!
• Riparian zone being overlooked completely. Council letter to DPHI dated 5 May stated clearly that “Part of the subject site is identified as “Category 3a Riparian Land” under Clause 6.4”. However, it was stated boldly in the Geotechnical Report (Appendix 13) that “The site is not in an area of riparian lands and further assessment is not required.” This casts doubt over the credibility of the entire report if such a glaring mistake can be made.
• “Landmark Group confirm that Landmark Group Property Management Pty Ltd, registered as a community housing provider under the National Regulatory System for Community Housing, will be managing the affordable housing at the site for a minimum of 15 years from the date of issue of the Occupation Certificate” (Appendix 7) However,
o Landmark, being the developer of this project, is registering Landmark Group Property Management Pty Ltd , part of Landmark Group, to be the CHP?
o In NSW, CHP should be a non-profit organisation. Is it the case with Landmark Group Property Management Pty Ltd?
Architectural design is the essence of any development. The lack of detail in the architectural plans of this proposal meant that the SEARs requirements cannot be satisfied. No assessments (eg. overshadow/solar/noise/visual impact) can be made because there is simply no information to substantiate such conclusion. The integrity of the planning process would be severely compromised if such process sets a precedent. It is for this reason that I believe this proposal should be rejected.

Dear Prity Cleary,

As a resident of Lindfield for the past 8 years, I believe that I am well-placed to provide informed feedback on this SSDA proposal.

I am not opposed to development and fully recognise the importance of increasing affordable housing in Sydney. However, any proposed development should be carefully assessed based on factors such as its sensitivity to the surrounding environment, the impact on local amenity, and the overall benefit or detriment to the community.

I wish to formally object to this SSDA proposal for the following reasons:

1. Bulk and scale

a. The proposed development significantly exceeds the maximum building height permitted under the TOD guidelines, even accounting for the 30% uplift allowed for infill affordable housing. Any proposal of this nature should comply with established planning controls to maintain consistency and fairness in the development assessment process

b. Lack of appropriate height transitions to neighbouring properties, resulting in a visually jarring and disproportionate streetscape

c. Proximity to a heritage-listed dwelling, which is particularly troubling. Shadow diagrams indicate that this neighbouring heritage property will not receive the minimum required sunlight during the winter solstice, contravening solar access standards

d. The proposal includes insufficient setbacks from adjacent properties, contributing to a sense of overdevelopment and reduced residential amenity. Notably, a driveway servicing 286 car parking spaces is positioned immediately beside a neighbouring home. The noise and disruption caused by such a high volume of vehicle movements in close proximity to a residence is unacceptable and should not be permitted

e. Rooftop communal open spaces, which poses a serious privacy risk to neighbouring residents and should not be permitted in this context

f. Misrepresentation in architectural drawings, where neighbouring properties are depicted as large apartment buildings. In reality, these are not multi-storey dwellings, and such inaccuracies undermine the credibility of the proposal


2. Traffic and Congestion

a. The proposed development raises serious concerns regarding traffic flow and local infrastructure capacity. The area has limited access to main arterial roads, and the additional vehicle load from this SSDA will exacerbate existing congestion

b. Limited road access to major routes, which will intensify bottlenecks during peak hours

c. Cumulative traffic impact from multiple SSDAs in the immediate vicinity must be considered holistically by the assessment panel, rather than in isolation

d. Local buses travelling past this site along Middle Harbour Rd will be directly affected by increased traffic volumes, potentially disrupting public transport reliability

e. Peak-hour congestion is already severe at both ends of Middle Harbour Rd particularly at the eastern junction with Archbold Rd and the western junction with Lindfield Ave/Strickland Ave, which connects to the Pacific Highway

f. Spillover traffic will likely affect surrounding streets such as Trafalgar Ave, Russell Ln, Nelson Rd and Tryon Rd. These are narrow residential streets not designed to support the traffic volumes associated with large-scale apartment developments


3. Solar access

a. The proposed development fails to provide sufficient solar access to neighbouring dwellings, particularly during the winter solstice. Shadow diagrams included in the application indicate that adjacent properties will not receive the minimum required sunlight during this period, which contravenes established solar access guidelines


4. Endangered Native Trees

a. According to the Biodiversity Development Assessment Report (BDAR), the site contains Sydney Turpentine and Blue Gum Forest Trees, both of which are listed as a critically endangered ecological community under the NSW Biodiversity Conservation Act 2016 and the Commonwealth Environment Protection and Biodiversity Conservation Act 1999. The proposed clearing of this vegetation poses a direct threat to the survival of these native trees and the broader ecological community they support. Given their conservation status, any development on this site must be ecologically sensitive and designed to avoid adverse impacts. This includes retaining existing trees, protecting root zones, and implementing long-term management strategies to ensure their preservation. Allowing the removal of these trees would not only contravene environmental legislation but also undermine regional biodiversity and community efforts to protect Sydney’s remaining native bushland


5. Geotechnical Report was a desktop study

a. The submitted Geotechnical Report appears to be based on a desktop study, lacking sufficient on-site investigation through borehole sampling or subsurface testing. For a development of this scale and complexity, a comprehensive geotechnical assessment is essential to evaluate soil stability, groundwater conditions and potential risks such as erosion or subsidence. Without detailed borehole data and site-specific analysis, the report cannot reliably inform foundation design, earthworks, or stormwater management. Proceeding with approval based on such limited information poses significant safety and engineering risks. A full geotechnical investigation, including multiple boreholes across the site and laboratory testing, should be conducted and reviewed prior to any development consent being granted.


6. Visual Impact Assessment

a. The submitted Visual Impact Assessment lacks transparency and accuracy. Photographs were strategically taken from distant vantage points, often obstructed by buildings, vegetation, or other structures, thereby minimising the perceived impact of the proposed development. This approach fails to represent the true visual intrusion and scale of the development as experienced from neighbouring properties. A meaningful assessment must include photo documentation from directly affected residences and public viewpoints in close proximity to the site. To ensure an informed and balanced evaluation, it is strongly recommended that the Assessment Panel conduct site visits to neighbouring properties. This will provide a clearer understanding of the local context and allow for a more accurate appraisal of the development’s visual impact on the surrounding community


7. Concerns Regarding Proponent's Credibility

a. An SSDA represents a significant undertaking, and it is reasonable to expect that such a large-scale proposal would be led by a well-established company with a proven track record. In this case, the application has been submitted by “Castle Hill No. 7 Pty Ltd,” a company that, according to the ASIC Company Register, was only recently established. A basic search via Google and the White Pages reveals no website, no listed phone number, and no physical address indicating a complete lack of public presence. These omissions raise serious concerns about transparency, accountability, and the company’s capacity to deliver a project of this scale. The absence of even the most fundamental due diligence markers should be considered a significant red flag.

Thank you for taking the time to read my objection.

In closing, the Concept SSDA clearly fails to provide the wider community with reasonable amenity, is insensitive to the surrounding area, has failed basic due diligence checks and should therefore be rejected by the assessment panel.

Sincerely,
Concerned resident

I am writing to register my strong opposition to the Concept Proposal SSD-82900461 for a multi-storey residential flat building at 11–19 Middle Harbour Road, Lindfield. As a resident of the same street, I am deeply concerned about the proposal’s lack of detail, as inherent in it being a "concept proposal only", its legal validity, heritage impacts, environmental harm, and its incompatibility with Ku-ring-gai Council’s Alternative Preferred Scenario for development in the Gordon–Roseville rail corridor. My objections include:-
1) Failure to Meet SSD Eligibility. The claimed capital investment of $68 million is well below the statutory $75 million threshold under the Environmental Planning & Assessment Regulation for State Significant Development. Proceeding under SSD classification despite this shortfall is procedurally unsound and risks an error of law. This application should be assessed at the local development level, where more stringent and context-sensitive controls apply.
2) Misstated TOD Eligibility – Actual Distance Exceeds Limit. The proponent’s assertion that the site lies within 450 metres of Lindfield Station appears inaccurate and misleading. Independent measurement confirms the distance is closer to 500 metres, exceeding the eligibility limit for Transport Oriented Development incentives and the eligibility of this proposal under TOD should be refused.
3) Proposed Height is Well Beyond SEPP Limits. At a proposed 33.6 metres, the building height surpasses the 28.6-metre control by 5 metres. This that will exacerbate overshadowing, visual intrusion into neighbouring properties, dominate the streetscape, and fails to offer acceptable height-based transitions to the overall neighbourhood and surrounding streets. The justification advanced under Housing SEPP “bonus” provisions is neither compelling nor consistent with local planning controls or the Council’s Alternative Preferred Scenario, which specifically resists over-height buildings in proximity to low-scale areas.
4) Encroachment, Unjustified Disruption to Streetscape and Failure to Propose any Meaningful or Detailed Design that fits within the Heritage Context of the neighbourhood and road. The proposed front setback protrudes forward of the neighbouring heritage-listed property at No. 9 Middle Harbour Rd, severely disrupting established view corridors and the collective streetscape. This departure from the prevailing building line will be visually jarring and diminish the prominence of significant heritage assets. These R2 Low Density Residential built landscapes and the heritage landscapes that are in very close proximity (Clanville, Trafalgar, Middle Harbour) are integral to Lindfield’s identity. The proposal provides no robust heritage impact analysis at this stage, deferring it to later—a wholly inadequate approach given the sensitivity of the setting and irreplaceable character and value of the neighbourhood.
5) Loss of Urban Tree Canopy and Biodiversity

The development entails removal of nearly all mature trees on the site, including ecologically significant Turpentines. This represents a permanent loss of canopy cover and wildlife habitat connectivity, directly contravening KLEP 2015, the Ku-ring-gai DCP, and the Biodiversity Conservation Act 2016. Replacement plantings will not replicate the ecological and microclimatic benefits of the mature tree canopy and instead will deliver effects on wildlife habitat and biodiversity in direct contradiction of NSW's and Council's environmental targets.
7) Compliant sunlight and shadow diagrams—required under the Ku-ring-gai DCP and relevant SEPPs—are absent. Without accurate modelling, the true extent of shadow impacts on neighbouring homes cannot be evaluated, compromising the transparency and rigour of the assessment process.
8) Unassessed Cumulative Impact on Local Infrastructure. This proposal cannot be assessed in isolation. There are multiple SSD and other major apartment proposals currently lodged or anticipated in Lindfield under the State’s TOD push, including nearby sites in Nelson Road, Trafalgar & Valley Roads, Beaconsfield Parade, and the Pacific Highway corridor and many more in the Roseville - Gordon rail corridor. When considered collectively, these developments will generate substantial cumulative and long-term pressure on: Stormwater and drainage systems (already flooding over roads and at maximum capacity throughout the downstream Gordon Creek riparian zone in heavy rainfall); Road networks and traffic congestion (already very busy along Middle Harbour Rd and congested at all traffic routes to enter Pacific Highway or Archbold Rd) particularly in peak hour ; On-street parking availability; Local schools (enrolment pressures on Lindfield Public, Lindfield Learning Village, and Killara High); Childcare centres (limited vacancies in the area); Health services (local GP clinics and allied health already at capacity); Public transport (Lindfield Station peak-hour crowding). No integrated infrastructure assessment has been undertaken by the applicant or the NSW State Government to evaluate these combined impacts. Proceeding without such a study is contrary to good planning practice and risks creating systemic infrastructure shortfalls in the long-term.
9) Incompatibility with Council’s Alternative Preferred Scenario. On 5 June 2025, Ku-ring-gai Council adopted and submitted to the NSW Government its Alternative Preferred Scenario, which delivers housing targets while preserving 80% of Heritage Conservation Areas, protecting the tree canopy, moderating heights in sensitive areas, and ensuring quality transitions in built form. As of 13 June 2025, TOD controls for new applications have been suspended pending consideration of this scenario and SSD-82900461 should therefore be assessed under Council’s framework—not outdated TOD provisions.
Given that this proposal fails to deliver any meaningful or responsible strategic planning or detail on its proposals in keeping with the existing character of the neighbourhood, misrepresents key eligibility criteria, sidesteps heritage and environmental responsibilities, fails to reasonably protect Lindfield's liveability, particularly with regard to solar access/potential overshadowing, visual intrusion into and major privacy loss for neighbouring properties) and wilfully ignores the real-world and long-term infrastructure consequences of stacking multiple over-scaled developments into the same locality, this concept proposal must therefore be refused.

For close to 24 years, I have lived on Middle Harbour Road approximately 280 metres from the proposed development site at 11-19 Middle Harbour Road. I OBJECT to the Concept Proposal for the following reasons:

Statutory Context

The proponent has made a Clause 4.6 Variation Request in support of a concept envelope of 9 storeys with a building height of up to 33.6 metres, or 5 metres (17.48%) above the maximum permissible height of 28.6 metres. This is a very significant variation, for which there is no good reason. The proponent’s argument that the maximum variation in the South East corner will not affect adjoining properties to the South as these properties will already be affected by the compliant elements of the development, ignores the likelihood that the variation of 4.7 metres on the Eastern side will affect the adjoining property to the East.

Engagement

The proponent has not sufficiently addressed the concerns noted in the Engagement Report.

Community concern was expressed that the proposal was inconsistent, particularly with regards to building height, with Council’s Alternate TOD zoning. These concerns were dismissed on the basis that the proposal complied with the current controls and Council’s alternate scheme was unknown. It is now anticipated that Council’s alternate TOD scheme is likely to be approved before the end of September 2025. The Alternate scheme provides for the State’s requirements regarding the number of new dwellings and affordable housing to be met without the need for a 9 storey building on this site which would be close to Heritage Conservation areas and inconsistent with the existing and future character of the street.

There was both community and Council concern regarding the Heritage Item at 9 Middle Harbour Road (MHR) adjoining the proposed development site, in particular its isolation and the impact on its heritage value. The proponent dismisses the isolation concern on the basis that isolation is not the reason that the Heritage Item cannot be developed. However, there is more than development potential to consider. In the event that the proposed developments at both 5-7 MHR and 11-19 MHR are approved, the single-storey Heritage Item will be “closed in” with 7-9 storey residential flat buildings on each side, significantly affecting solar access, visual privacy and views of open sky, and thus the amenity and quality of life of its residents. Council also expressed concern that the development should provide an appropriate landscape setting at the interface with the Heritage Item. This concern is not addressed in the Engagement Report.

There was further concern that parts of the proposed development site were identified as Biodiversity and Riparian land. These concerns were to be addressed in the BDAR.

Design Quality

As no “Detailed Design” has yet been prepared, Design Quality cannot be assessed.

Built Form and Urban Design

The Architectural Drawings show a setback from the street of only 6 metres. This is described as “minimally forward” of the setback of the adjacent Heritage Item at 9 Middle Harbour Road from the street, but will have a significant impact on the streetscape, particularly the view of the Heritage Item, and on the amenity of the Heritage Item, particularly if it is isolated between two residential flat buildings.

Without a “detailed design”, it is not possible to assess whether the form and scale and visual design of the proposed development are appropriate.

Environmental Amenity

Based on the shadow diagrams in the Architectural Drawings, the Heritage Item dwelling at 9 MHR will be overshadowed by the proposed development until at least 1pm on 21 June.

Visual Impact

The EIS contains no photo montages, architectural drawings or artist’s impressions to show the visual impact of the proposed development from either Chelmsford Avenue or Trafalgar Avenue.

Trees and Landscaping

Due to the size of the proposed building, the Arboricultural Impact Assessment Report recommends that of the 65 trees within the boundary of the proposed development site, 51 be removed. In fact, almost all of the 23 trees shown on the Ground Floor Landscape Plan as being retained are located outside of the site boundary. This destruction of the mature tree canopy cannot be replaced by new plantings.

The proposed new plantings as shown on the Ground Floor Landscape Plan consist of only 15 new trees in the deep soil area around the site boundary, and 3 round planters in the communal open space. There are no deep soil plantings in the communal open spaces. The proposed new tree plantings are neither “extensive” nor “throughout the site” as claimed in the EIS.

Biodiversity

The BDAR (Figure 3) confirms that there are two areas of Biodiversity Value at the rear of the proposed development site, including at least one protected Turpentine tree. It is not clear whether this tree is to be removed or retained.

The BDAR, however, does not address the concerns relating to parts of the proposed development site identified as Riparian land. Rather, the BDAR accepts the incorrect information that the closest mapped stream, Gordon Creek has its head 280 metres away at 38 MHR, when in fact the stream starts closer to the proposed development site, at 32 MHR. On the basis that the development site is located outside of the Riparian zone, the BDAR considers it “not to impose impacts to the hydrological function of this stream”, and therefore does not address Council’s concerns.

Environmental Heritage

As noted in both the Heritage Impact Assessment Report and the EIS, the design requires further refinement and heritage impact assessment to confirm the heritage impacts.

Lack of “Detailed Design”

Without a “detailed design”,the Proposal has not met, or in some cases even addressed, the requirements of the SEARS.

For these reasons, the Concept Proposal should not be approved.

This proposed development at 11-19 Middle Harbour Road compounds my deep concerns surrounding two other Landmark developments in our neighbourhood, namely 59-63 Trafalgar Avenue, Lindfield (SSD-79276958) and 1-5 Nelson Street (SSD-82899468).
The scale developments in close proximity, individually and in combination:
1. Will destroy the character of our neighbourhood, characterised by heritage homes and a tree canopy.
2. Endanger the environment, given their proximity to the endangered turpentine forest with abundant fauna, including the endangered powerful owl in and around Middle Harbour Road
3. Will exacerbate existing traffic congestion at the key entry / exit points:
a. Lindfield Road / Havilah Road turning onto the Pacific Highway
b. Strickland Ave and Clanville Road, turning onto the Pacific Highway
c. Tryon Road turning onto Archbold Road (creating road safety hazards, where motorists seek to access Archbold Road at intersections without lights)
4. The construction phase for these and other projects in the neighbourhood – which could go for years – will be a nightmare.
5. The mass and scale of Landmark’s developments is inappropriate, given their distance from the train station - at best at the fringe of the TOD zone or potentially beyond it.
In respect of 11-19 Middle Harbour Road:
1. I am deeply concerned about the removal of most of the mature trees, including endangered turpentine trees. This will further degrade the environment and tree canopy.
2. While heritage-listed 9 Middle Harbour Road will be retained, its proximity to this oversized development makes a mockery of heritage laws
3. The development will add to the hard surfaces and is likely to exacerbate flooding and suburban run-off (e.g., plastic pollution) into Gordon Creek
4. I am concerned with the impact of traffic on Middle Harbour Road
5. The site appears to be outside the 400m radius from the train station
6. A concept proposal and difficult to assess without proper planning and design. We have no idea what the product will look like and cannot assess its full impact on the neighbourhood. This process is unacceptable.
I support Ku-ring-gai Council’s superior alternative TOD proposal adopted on 5 June. This proposal, developed with community consultation, delivers the required increase in housing while better protecting heritage areas and the environment and creating a more appropriate transition from high density close to transport infrastructure to low density further away from the station.
Since the Landmark and other developments were announced, I have engaged broadly within our local community. As a community, we strongly oppose these developments.

We are the owners of 1 Valley Road, Lindfield. This is an objection to the proposed development at 11 to 19 Middle Harbour Road.

We are supportive of the NSW State Government’s objective of increasing housing in Sydney, which we believe will be best achieved by Ku-ring-Gai Council’s alternative TOD proposal. The proposed development sits ~500m walking distance from Lindfield Station and is not in keeping with many requirements of the council’s alternative plan which if acceptable to the State, will determine the future character of Lindfield. It is also makes no provision for transition to lower density one and two storey housing which is immediately adjacent, including two heritage conversation areas.

The materials prepared to support the proposal are substantially lacking in detail, show obvious errors (for example Figure 4 on page 17 of the EIS does not even show the correct figure), or is determined to give a false impression of the impact (e.g. the views chosen for the Visual Impact Assessment are often located many hundreds of metres away and seem to be deliberately chosen to mask the development behind existing large trees). This would appear to be a cynical attempt by the applicant to make a proposal within a certain time frame (given that new TODs are not being accepted) without providing the necessary detail for the State to assess the development.

We object to the proposed development of the following six grounds:

1. Height, density and scale – The proposed development is a nine-storey building in an area currently characterised by low-density one and two storey houses. This large scale building is significantly above the heights proposed in the Ku-ring-Gai Alternative proposal (up to 18.5m) and the floor to space ratio. The application seeks a variation to the maximum building height under Clause 4.6 of the KLEP of 33.6m. Clause 4.6 variations must demonstrate that compliance with the standard is unreasonable or unnecessary and that there are sufficient environmental planning grounds to justify the contravention. In this case, the adverse impacts on amenity, local character and heritage outweigh the purported benefits, and the variation should not be supported

2. Loss of Visual Amenity from neighbouring properties - the development will substantially increase overshadowing and result in loss of view from for adjacent properties. The EIS states in section 6.8 that the development “will not result in any unreasonable impacts on any significant views enjoyed from surrounding properties or the public domain but the visual impact pictures have been selectively chosen to minimise the impact on the surrounding properties (either by taking the photo so far away to take advantage of the natural topography of the site from a distant or by angling the photograph to strategically view the property through mature trees).

3. Impact on heritage area and inadequate mitigation of heritage impacts

The proposed development site adjoins several significant heritage assets. It is impossible to assess the impact on the heritage assets with the detail that has been provided by the applicant but as a minimum, the height and minimal setbacks will result in a significant negative impact on the adjoining heritage areas.

4. Tree Removal and Landscaping - the Arborist Report identifies the removal of 51 trees of the 65 trees which are located within the boundary of the site, including the removal of 12 of the trees with a A1 retention value assigned in the Aboricultural Impact Assessment (the majority of the trees of significant height on the site). This will further reduce the tree canopy in Lindfield, which has a number of negative impacts on key aspects of the natural environment, including general heat in the suburb and loss of local bird life. The loss of mature vegetation will further erode the landscape character of the conservation area and the setting of heritage items. The removal of significant trees adjacent to a heritage conservation area is contrary to the objectives of both the KLEP and the Biodiversity and Conservation SEPP.

5. Procedural and Strategic Issue

• Inconsistency with Strategic Planning Objectives - the developers argue that their proposal is justified on the basis of State housing supply targets and the TOD program. However, the Ku-ring-gai Local Strategic Planning Statement and Housing Strategy emphasise the need to balance growth with protection of local character, heritage, and environmental values. The council has proposed an alternative plan to deliver more housing but in a way that is sensitive to these values. The proposal development would be of a significantly reduced height and scale under the council’s alternative plan, reflecting a more appropriate transition to adjacent density and heritage conversation areas. The application of the Housing SEPP in this context is not mandatory and should be balanced against the adverse impacts identified. The developers have also sought to make this a State Significant Project by including affordable housing but it should be noted that many of those apartments will have reduced amenity compared with others, e.g. 27% of units have less than 2 hours solar access (46 units) and 2% have no solar access (2 units).

6. Other Issues

• Traffic and Parking - the Transport Impact Assessment claims minimal impact, but the Tryon Rd intersection is already a busy intersection with the school close by so there is no way adding a 9 story apartment block with connected carpark will have a negligible impact on traffic, parking and safe pedestrian impact.
• Cumulative Impacts - the EIS states that the character of Lindfield is changing, but the cumulative impact of multiple high-density developments in or adjacent to two heritage conservation areas has not been adequately assessed.

I strongly oppose the development proposed for 11 – 19 Middle Harbour Rd (Site) for a number of reasons, including that:
• As with the other SSDs proposed within 200m of our home, the required early consultation process was entirely inadequate.
• The proposed development is inconsistent with a good planning outcome and in conflict with the alternative planning scheme proposed by Kuring-Gai Council (Council), which has widespread community support (TOD Alternate Preferred Scenario).
• Its height, bulk and density will produce yet another eyesore.
• There would be a lack of transition, in terms of height and density, to the neighbouring residential properties.
• There would be significant adverse impact in terms of overshadowing and loss of solar access and privacy on adjacent and other neighbouring properties.
• 9 Middle Harbour Road (MHR), a heritage item, would be stranded between this development and another at 5-7 MHR. If either development is approved, there will be a significant adverse impact from a heritage perspective on the adjacent heritage item.
• The loss of tree canopy and biodiversity will be a loss for everyone, both now and in the future
• The proposed development will conflict with the character and streetscape of the neighbourhood, including the adverse visual impacts of such a large, angular and dense building.
I expand on some of my objections as follows:
• The 'early consultation' process referred to in the documents on exhibition was little more than a cynical charade. The webinar was short and uninformative. The consultancy engaged to conduct the consultation began this session approximately ten minutes late, blaming technical issues. Having allocated only half an hour for the session they opened with a noticeably over long acknowledgement of Country, followed by an extensive but simplistic explanation of TOD structure. Then, with five minutes remaining until the scheduled close, they claimed that insufficient time remained for the planned Q and A but, oh well, anyone with questions could put them in the chat. This proposal should fail on the basis that the applicant failed to provide adequate early consultation. This was more abuse of process than consultation. The Board and the State Government need to know that the inadequacy of this part of the process is common to all the SSD applications I have responded to so far. It is clearly a deliberate and planned strategy by developers to deny affected parties any real opportunity to participate.
• The documents on exhibition demonstrate the grossly disproportionate size of the development relative to the existing surrounding properties. The size, bulk and density are disproportionate even relative to the R4 zoning for adjacent and neighbouring properties that is proposed in Council's TOD Alternate Preferred Scenario.
• The proposed height to 33.6m, which is above the permissible height of 28.6m, would substantially exceed the height provided for the Site and adjacent properties in the TOD Alternate Preferred Scenario, which is 18.5 metres. It is completely inappropriate for the Site.
• There is no sensitive interface with the neighbouring dwellings to the east, west and south of the Site.
• The shadow diagrams that are included in the proposal indicate a degree of shadowing that is unacceptable, particularly for the adjacent heritage item.
• The proposed development would dominate, and have an overbearing effect on, the surrounding streetscapes.
• Neighbouring properties that are overlooked by the buildings will suffer a substantial loss of privacy.
• Rooftop communal spaces will mean loss of privacy for surrounding properties and the potential for noise issues, especially at night, and resulting in community disputes.
• The Site is adjacent to a heritage item at 9 MHR. The documents on exhibition indicate that only an inadequate 6 metre setback is contemplated from the neighbouring heritage item. If the development were to proceed, the heritage value of the adjacent heritage item would be substantially diminished.
• The Site is land with high biodiversity value that is particularly sensitive to impacts from development and clearing (see the Biodiversity Values Map (BV Map) available at NSW Planning Portal Spatial Viewer). High value biodiversity would be lost and/or at risk. There is no justification provided for that loss of biodiversity.
• Boundary planting will not hide the stark facades of the buildings, nor attract the bird and other wildlife that the current tree canopy on the Site attracts.
• The applicant has argued that the proposed development is compatible with what might be built on surrounding properties in the future under the TOD, yet it fails to take account of the cumulative effect of the proposed development and the surrounding future developments. The cumulative impact on traffic in MHR and surrounding streets, and on other facilities, such as water and waste water, will be considerable and must be considered.