Please see attached for my objection to the SSDA at 23-31 Dover Road Rose Bay

We strongly object to SSD-86017721 (23-31 Dover Road, Rose Bay).

Main reasons:

1. We have learnt that this area is within a "high-risk settlement area", which would mean that deep excavations into saturated loose marine sands here would be hazardous,
resulting in e.g. inundation risks & pedestrian hazards.
2. We have also learnt that cumulative risk assessments for this massive constructions have not been carried out, which we find to be a serious omission.
3. We have also learnt that deep excavation can potentially result in acidic sulphates and toxic acidic contaminants flowing into the foreshore and Sydney Harbour.
4. We have also learnt that 27 (!) trees will be removed to give way for the huge construction. In this day and age, it is appalling that this would be approved, as this would result in loss of shade, causing increased heat in the spring, summer and autumn months.
5. The Dover Road/Ian Street roundabout is already very busy, especially in peak hour times. The large resulting increase in traffic (as a result of many more people/cars in the area after people have moved into the multi-story building, with the additional number of cars) will cause in further congestion, with grave pedestrian safety concerns.

And, very importantly, I also would like to express that I feel that new rules and regulations implemented by the NSW government in regards to the LMR reforms not only would greatly destroy the current amenity of Rose Bay, they will also not provide any affordable housing.

Thank you in advance for your consideration.

Yours sincerely,


Bengt Peder Martin Kastengren
3/9 Wilberforce Avenue, Rose Bay
0415 556 260
[email protected]

• The site is in the HIGH-RISK, low lying Rose Bay Settlement Area
A known high-risk zone with shallow groundwater, soft soils and known structural damage from
previous excavations.
• Deep two-storey basement is unsafe
It will cut into groundwater, increase uplift pressure, divert water flows and risk subsidence to
surrounding properties.
• No cumulative risk assessment
Several major excavations are proposed nearby – approx. 16000 sqm worth on that one strip of Dover
Rd/Wilberforce Ave alone. The combined groundwater and stability impacts have not been assessed,
but we know that serious damage has already been caused from single, far smaller excavations here.
• Acid Sulphate Soil ASS (Class 4) risk
Excavation deeper than 2m can disturb ASS and release acid/contaminants into the groundwater and
the harbour. The fragile Rose Bay foreshore risks being overwhelmed.
• Flood and overland-flow vulnerability
This is a low-lying basin. Deep excavation here can worsen local flooding and basement inundation.
• Not in the public interest
The area has already suffered structural cracking and water damage. More deep excavation
poses foreseeable, irreversible harm. The vulnerable, low-lying parts of Rose Bay are simply NOT
suitable for this level of development. Any adverse environmental effects are likely to be
irreversible.

The inner area of Sydney desperately need upzoning and increase density for sustainable growth. This prime location should be unlocked for more housing, increasing the supply of the overall housing market in Sydney.

Old South head Road and New South Head Road are already beyond saturation level at peak times. Developments such as this will create more traffic and delays for the whole Rose Bay and Vaucluse peninsula. The traffic situation can never be fixed in the future as road widening for both major access roads is now impossible.
Secondly, the DA proposes a 2 level underground car park. Noting the water table and disturbance of surrounds and also the history of flooding of car parks during major weather events this will create problems going forward.

Please consider my objection to the SSD-86017721 on the following grounds :
A). This site is in the HIGH RISK, low-lying Rose Bay Settlement Area. It is a high-risk zone with shallow groundwater, soft soils and known structural damage has already been documented associated with smaller developments in the area. Excavation to allow for 2 levels of underground parking for 66 cars will intersect the water table in loose to very loose sands.
B). Deep 2 storey basement excavations are unsafe. The excavation will cut into groundwater, increase uplift pressure, divert water flows and risk subsidence in neighbouring properties.
C). No cumulative risk assessment has been carried out. Several major excavations are proposed nearby - approx 16000 sq metres of side-by-side sites on 1 strip of Dover Road and Wilberforce Ave alone. The combined groundwater and stability impacts have NOT been assessed. We know that serious damage has already been caused from single, far smaller excavations in the area.
D). There is an Acid Sulphate Soil risk. Excavations deeper than 2 metres can disturb ASS and release acid/contaminants into the groundwater and then flowing into the harbour. The fragile Rose Bay foreshore risks are overwhelming on a long-term basis.
E). This is a low-lying basin. Deep excavations can lead to worse flooding in the area after heavy rain and cause basement flooding.
F). These vulnerable, low-lying parts of Rose Bay are NOT suitable for this level of development. Any adverse environmental effects are likely to be irreversible.
G). The housing SEPP uplift (LMR) does not apply on high-risk land.
H). As a neighbouring property, we require indemnity from the NSW Government if damage and losses occur as a result of this development.
Please consider these objections of high importance.
Yours faithfully.
Susan Park

Rose Bay is at a tipping point. It has undergone accelerated development in the last few years without accompanying improvements in infrastructure. Further development could tip the balance and change this iconic harbourside suburb of Sydney - which features in so many campaigns showcasing Sydney's beauty - into another highrise cluster.
This development is part of a greater plan that will deliver tiny amounts of affordable housing, increase density considerably and choke off this small peninsular where traffic, and some times of the day, is actually stationary.

I object on environmental grounds, public safety & the long-term impact & cost this development will bring to the broader local community.

Whilst I advocate affordable housing initiatives, this particular development proposes for excavation directly into the groundwater table where the risks of doing so are clear & known, such as destabilisation of existing building structures & long-term building settlement issues due to groundwater interference.

The proposed site is a mapped high-risk floodway. The risks of setting building foundations into such floodways is known. It is extremely dangerous to public safety & the surrounding environment with irreversible & destructive processes such as releasing toxic contaminants into the foreshore & harbour with an excavation of this magnitude is inevitable. It is a matter of long-term public health & safety that demands the attention of this issue from the NSW State Government.

Unfortunately, a development of this magnitude would set the precedent for further excavation across an already fragile water-table system & regardless of any impact on housing affordability in the short-term it would be far out-shadowed by the greater cost to the broader community including to the inhabitants of those new dwellings in the long-term in the form but not limited to building safety, possible reparation works required on buildings unfit for inhabitants, bio-hazards to the local area including harbour & foreshore areas & financial burden.

These matters pose serious concern to the long-term settlement, stabilisation & well being of the local community & it is believed the NSW Government should revise the cost-benefit analysis of supporting such projects under the guidance of affordable housing should that cost of housing be irreversible & actually unaffordable to the community in the long run as a whole.

So many things are wrong with this development proposal. I refer you to the submission of the Rose Bay Residents Association that I fully support.

Specifically, the excavation goes directly into the ground water; no cumulative risk assessment to look at the big picture of development in concentrated area); this specific site is mapped a high risk flood at; environmental impact of inevitable acidic contamination.

I’m writing as the Treasurer of 40-42 Wilberforce Ave and our concern at the potential structural damage to our apartment building, possibly the only remaining housing . I’ve followed and supported the successful efforts to have Rose Bay included in parking restriction to a single basement level. On these grounds alone the proposal is out of scope. I do support medium density housing and despite the disruption, would not object to redevelopment of the sites that did not threaten me directly . But that is unlikely to meet the governments medium and low income housing objectives .

We intend to insure ourselves comprehensively and meet all requirements necessary to sue the developer for damages that we will prove are caused by the development. The fact that they only registered with ASIC in 2025 worries me but I will trust in your due diligence to ensure they have sufficient liquidity and insurance cover to proceed with the development proposed here and provide compensation for damages.