I strongly object to further developments in Rose Bay and surrounding suburbs. Ground water is being disturbed. We cannot continue to disturb the already soft sand base Rose Bay sits on. New basements have already shown areas of flooding. The Eastern Suburbs is already over developed. There is substantial parcels of land in the West to develop new homes. All development in the Eastern Suburbs will create is income for greedy developers and agents not to mention substantially more traffic to the area. Enough

We are writing to object to the proposed development at 23–31 Dover Road. We know Sydney needs more housing and that suburbs naturally evolve, but after reading what we can about this proposal, we feel it would place too much pressure on Rose Bay without enough thought about how the area will cope in the long run.

Traffic remains our biggest concern. Rose Bay funnels through just two roads, and they are already slow and crowded at busy times. An extra 49 apartments and more than 60 parking spaces — alongside other developments underway or planned nearby — will inevitably add more cars. With nowhere for that extra volume to go, it feels likely that congestion will increase, travel times will stretch, and the general ease of moving around the suburb will decline. A proper cumulative traffic study, looking at the whole area rather than a single site, seems essential before anything is approved.

We are also uneasy about the scale of excavation required. Large underground car parks bring trucks, vibration, dust and long periods of construction noise. Once digging starts, it cannot be undone, and any unforeseen impacts on neighbouring properties or groundwater are difficult to fix later. These risks deserve more certainty now — not after consent has already been granted.

The loss of mature trees is concerning as well. These trees make the area cooler, softer and more pleasant, especially during the warmer months. They handle water in heavy rain, support local wildlife and contribute to the calm streetscape many of us value. Replacements will take decades to develop the same presence, and by then the character of the area may already have changed.

The overall size of the proposed building matters too. An eight-storey structure in this location will be visually dominant, alter the balance of the street and shift the feel of the neighbourhood permanently. Developments of this scale need to sit comfortably within their surroundings, and at present, it is difficult to see how this one does.

In short, our concern is not about change itself, but about the pace and intensity of it. Traffic pressure, loss of greenery, lengthy excavation and a noticeably taller built form all combine to reshape Rose Bay in a way that may not be fair or livable for the community that remains.

We hope this proposal is reconsidered or significantly improved so that future growth protects the qualities that make this suburb a place people want to stay.

The project height is excessive.
It would change the character of Rose Bay

It would set a precedent for other unsuitable projects.
The Visual Impact Assessment is sadly biased and prejudiced.
The attachment hereby explains the above view in more details. It is also sent by email to:
[email protected] in case.
Thanks

Submission Upload Request for [SSD-86017721] – CSE Ref No. [P-1585478]

Dear Minister

for many decades it has been understood that the Rose Bay and Double Bay "settlement areas", as defined by Woollahra Council, were characterised by loose, sandy, alluvial soils, that were not amendable to basements that sit into the water table. For this reason some years ago Council included in their DCP restrictions on basement car parks. However, as property values have soared in the Eastern suburbs, there has been increasing pressure from the development lobby for developments in the area to include multi-level basement car parks.

The problem with allowing this subterranean excavation into the water table is the effect it has on the surrounding water table, extending to properties a significant distance away. In short, in order to create a deep concrete pool which forms the foundation for a build of this magnitude, de-watering of the site must occur. As water is amorphous, de-watering this site will also result in the de-watering of surrounding land many tens of meters away. The effect of de-watering is essentially to reduce, in a short time frame, the soil bearing capacity under the foundations of nearby buildings and homes, resulting in differential settlement and structural cracking. This is what occurred at "Mascot Towers".

It is entirely foreseeable that this mega-development, as well as a swathe of similar development applications that will be presented to Council and the State Govt. under the LMR, will cause these same problems. Woollahra Council has a list of many properties that have already suffered structural damage as a result of disturbances in the water table.

1. As the Minister is on notice that approving this application is likely to cause damage to surrounding properties, will the Minister indemnify surrounding properties against any damage that may eventuate?

2. Will the Minister insist that a fund be set aside by the developer to deal with damage that may be incurred by the development?

Or will we be left with a suburb of "Mascot Towers"? Will the onus fall, once again, on innocent owners to pursue developers for restitution.

Sometimes, Minister, the old ways are the best ways. There should be no excavation into the water-table.

I urge you to significantly reduce the depth any development is allowed to excavate into the shallow water tables of Rose Bay and Double Bay.

Please refer to the Draft Amendment No 37 of the Woollahra Council DCP introduced to mitigate these foreseeable problems.

Re: Objection – SSD-86017721 (23–31 Dover Road, Rose Bay)
State Significant Development Application

Dear Sir/Madam,

I am writing to lodge a formal objection to SSD-86017721. My concerns relate primarily to geotechnical, flooding, environmental and traffic impacts associated with the proposal.

⸻

1. Excavation and Groundwater Impacts

Michael Hall , senior compliance officer at the Building Commission NSW stated in a letter to the Rose Bay Residents action group the following:
"Thank you for contacting the Building Commission NSW and for the information you have provided which has further
deepened our understanding of the geology of the Rose Bay area. In response to your concerns we will increase the
scope of our monitoring activities to include low and medium-rise housing developments in the Rose Bay area where
a development consent has been issued.
Low and medium-rise housing developments are assessed by local council under the State Environmental Planning
Policy (Housing) 2021, also known as the Housing SEPP, in conjunction with Council’s Development Control Plan
(DCP) which deals with matters not contained in the Housing SEPP, such as excavation and off-street parking.
In response to excavation concerns, Woollahra Municipal Council at its meeting on the 12 August 2024 resolved to
approve the Woollahra Development Control Plan 2015 (Amendment No. 31) to introduce controls to reduce
excavation and this took effect on 24 August 2024. These controls limit the volume of excavation to the numerical
value of the site area so that for example, a 1000 square metre site is limited to 1000 cubic metres of excavation, a
2000m2 site is limited to 2000m3 of excavation and so on. Our observations of recent approvals issued by Woollahra
Municipal Council in the Rose Bay area indicate that these are allowing for at least twice the volume of excavation
permitted under Council’s DCP to accommodate for basement car parking which appears to have led to your
concerns.
The Building Commission NSW is of the opinion that development controls are already in place to address your
concerns and that any structural risks relating to low and mid-rise housing can be addressed through strict compliance
with the Housing SEPP and the Woollahra Development Control Plan 2015, which are outside of our jurisdiction and
are matters legislated for Woollahra Municipal Council to consider.
We note that Woollahra Municipal Council as the relevant authority is currently taking action to address your concerns
because on the 25 August 2025 Council resolved in their Ordinary meeting to submit these concerns to Council’s
General Manager and it appears the outcome is currently pending.
We really do appreciate the information you have provided because this has given us a greater understanding of Rose
Bay and will be valuable for our building compliance and monitoring activities."

The proposal involves excavating well below the groundwater table. Groundwater in this area is recorded at approximately 2.7–4.2 metres, yet the development seeks to dig 7–8 metres, directly into very loose to loose sands. Excavations of this depth pose credible risks, including:
• instability and settlement of nearby buildings
• groundwater movement and long-term subsidence
• potential liquefaction under stress

Critically, no cumulative impact assessment has been undertaken, despite multiple concurrent proposals in the Rose Bay basin. Woollahra Council is in the process of commissioning a broad hydro-geotechnical review for the State Government for this very reason. Council operates seven car parks and none are underground, reflecting the area’s constraints. A previous proposal on Kiora Lane abandoned its underground parking due to these risks. The GHD (2024) Hydro-Geotechnical Study for Rose Bay clearly identifies the locality as unsuitable for deep excavation.

The application considers the site as if it exists in isolation, overlooking:
• a history of substantial structural damage within the Rose Bay settlement zone
• adjacent sites seeking equally deep excavation under LMR amalgamations
• the interconnected nature of the groundwater system beneath Rose Bay’s low-lying streets

This omission is a major flaw in the assessment.

⸻

2. Flooding Constraints

The parcel is mapped as high-risk floodway. Constructing basements in a floodway is inherently hazardous. Risks include:
• inundation and entrapment
• obstruction of overland flow paths
• pedestrian safety hazards

Even elevated car parks in the local area (e.g. Harris Farm’s upper basement) already show signs of groundwater intrusion. These garages regularly flood after rainfall, illustrating the true water table behaviour—contradicting the DA’s assumptions.

⸻

3. Irreversible Environmental and Structural Risks

Groundwater drawdown and subsidence, activation of Acid Sulfate Soils (ASS), and impacts on foreshore ecosystems are not reversible once they occur.

The site contains Class 4 Acid Sulfate Soils, with the Preliminary Site Investigation identifying potential ASS at only two metres below ground level. The proposed excavation extends well beyond this depth, placing the works firmly within the risk zone. Deep excavation in groundwater can:
• trigger ASS reactions, releasing acidic contaminants into the aquifer, which flows toward Royal Sydney Golf Course
• allow contaminants to move toward the harbour and foreshore
• degrade local ecosystems

⸻

4. SEPP Housing (LMR) Uplift Does Not Apply

Although the site falls within 400 metres of shops, SEPP uplift is prohibited on high-risk land. This site meets multiple exclusion criteria:
• geotechnical instability
• groundwater impacts
• location within a floodway
• cumulative excavation risk

It is inappropriate to apply LMR uplift in these conditions.

⸻

5. Removal of 27 Mature Trees

The proposal involves clearing 27 established trees, removing critical shade, habitat, stormwater buffering and heat-reduction benefits. In a soft-soil environment like Rose Bay, tree removal also undermines soil stability. There is no analysis of how excavation, groundwater interference or ASS disturbance would affect the remaining vegetation.

⸻

6. Traffic and Safety Concerns

The Dover Road / Ian Street roundabout already operates as one of Rose Bay’s most heavily trafficked intersections. Key pressures include:
• high pedestrian movement
• childcare drop-offs
• beach and recreation visitors
• school traffic
• supermarket and delivery vehicles, rideshare and taxis
• bus and service vehicle movements

The DA proposes parking for 66 cars and 7 motorcycles, adding further congestion in an area that already becomes gridlocked during peak periods. Despite being labelled a “town centre” only “30 minutes from the city”, in reality peak-hour travel regularly exceeds 45–60 minutes.

⸻

For these reasons, I strongly oppose SSD-86017721 and request that the application be refused.

Kind regards
Tom Boycott

I am objecting to this project because of the following reasons:
- We are sitting on a water table and excavation into the water table will cause catastrophic damage to the area.
- There has been no reporting done on the accumulative effect with so many development sites excavating into the water table.
- Our roads, schools and infrastructure cannot handle any more, it is already at its limit. There is no room to expand. We are far enough away from a hospital so adding more residents into the area with increase the already heavy traffic to these emergency services.
- These developments do not support a quality of life for all the existing residents in the area. There have been numerous buildings with damage to them due to recent developments over the last few years with buildings cracking.

The site is a high-risk low lying area.
There are already several other excavations occurring in the area. Further excavation will only add to the vulnerabilities of the suburb. We are experiencing this already further up the hill in Vaucluse and we have none of the proposed scaled of development. The water table is vulnerable in the area as it is. We have had a constant stream of water running in our street for over 1mth by excavation damage done by another development.
A deep two-storey basement compromises safety as it cuts into groundwater, there is also a risk of surrounding properties subsiding.
The surrounding roads will be choked with traffic as the current infrastructure cannot already support the current traffic demands in the area.
Rose Bay is a low-laying basin and flooding can be worsened through deep excavation. Rose Bay is already vulnerable and not suitable for this style of development and excavation. Environment affects as a result of this development / excavation will have irreversible effects which is of grave concern to residents and business owners who will be majorly affected.

This development is too large for the area and does not support the infrastructure it is not in line with the rest of the buildings which are only 4-5 stories. It’s also compromising the water table by going 2 basements below. This will
Potentially result in cracking of surrounding buildings. As in 24 balfour rd when the building couple blocks down hit water table with underground garaging and building 22 balfour had to get underpinnings due to cracking of walls. I know as I lived through this in 1998

Subject: Strong Objection to Proposed 8-Storey Development

I am writing to register my firm and deeply frustrated objection to the proposed 8-storey building and two-level basement planned near my apartment and within our village community. This development is completely out of scale, out of character, and frankly out of touch with the realities of this area.

There is not a single building of comparable height anywhere nearby, and for good reason: the neighbourhood was never designed to accommodate such an oversized and intrusive structure. Dropping an 8-storey tower into a low-rise village community is reckless and shows a disregard for the people who already live here and for the environment we depend on.

I am also alarmed by the serious risks posed to the Rose Bay surroundings, particularly given the excessive excavation required for two basement levels. The site sits extremely close to my building, raising legitimate concerns about vibration, structural impacts, prolonged noise, and construction safety. This scale of excavation is not only unnecessary but dangerous, and it threatens the stability of neighbouring buildings.

Equally concerning is the impact on our already fragile water systems. Rose Bay has well-documented issues with groundwater movement, stormwater capacity, and runoff management. Excavating deeply and imposing an 8-storey mass above it will place enormous pressure on these sensitive systems. Increased strain on groundwater pathways, altered water flow, and potential flooding or seepage issues represent real, tangible risks that residents should not be forced to bear. The proposal fails to demonstrate how these risks will be responsibly managed—or if they can be managed at all.

Beyond the construction risks, the sheer height and bulk of the proposed building are wholly inappropriate for this neighbourhood. It will dominate the skyline, overshadow surrounding homes, strip residents of privacy, and fundamentally alter the character of the area in ways that are neither necessary nor welcome.

Furthermore, the development sits next to an already high-traffic, heavily burdened road, and the addition of 49 new dwellings will only amplify congestion, noise, parking strain, and pedestrian risks. This proposal would push population density to an uncomfortable and unsustainable level for those of us who already live here. The existing infrastructure simply cannot absorb this level of intensification.

In short, this application represents overdevelopment at its worst—disruptive, excessive, and inconsiderate of the community and environment it would damage. I strongly urge that this proposal be rejected in full to protect the safety, liveability, and integrity of our neighbourhood. I have every confidence the right decision will be made for the community.