I think this project is misleading and disappointing. My understanding is that the site currently has 82 social housing units. The new development will have 84 social housing units, and 140 private units. So the amount of social housing (affordable housing) isn't really going to change (only a change of 2 units). But the disruption for the current social housing residents will be enormous - they will all have to move out so that their homes can be demolished and rebuilt. In fact I understand that many have already been relocated.
In particular I think it is disappointing that more social housing is not being built and that the priority seems to be building 140 private units instead.
In terms of the design, I think that is also disappointing. Completely separating the social housing and the private housing into different buildings and different carparks seems wrong. The quality of the social housing apartments seems lower (e.g. in the renderings, the private units have nice glass balconies but the social housing apartments do not). The allocation of medium and large apartments also seems wrong - the private units will have a large number of 2 and 3 bedroom apartments, but the social housing will have almost none. Instead the social housing will be mostly 1 bedroom apartments only.
My understanding is that the social housing building will also have substantially less parking available - only 36 car parking spaces for the social building, while the private units get 200 car parking spaces. This seems very unfair, especially considering the severe lack of public transport in the area.
In terms of practicality, the carpark arrangement also seems problematic. To get to the carpark for the private units, it will be necessary to drive all the way around Jellicoe Park (due to the road being 1 way). On the other hand, the carpark for the social housing units will be relatively easy to access. That is about the only positive thing I can say about this proposal.

I strongly oppose proposal SDD-83256472. The original 4-storey plan was reasonable, but the revised 7–8 storeys (224 dwellings) is unsuitable for this location. The Heffron Rd–Banks Ave intersection is already dangerous, with no green-arrow turn and frequent near-misses and accidents. Congestion on Banks, Heffron and Park Parade makes it extremely difficult for residents around Jellicoe Park to access their homes due to traffic-light phasing and increased vehicle load. Weekends and peak periods already bring heavy use to the small park, creating unsafe conditions for pedestrians and drivers. Adding 224 dwellings will overwhelm local roads, parking, and amenities. Under the EP&A Act 1979, the consent authority must consider traffic impacts, safety and local amenity. This proposal fails to demonstrate that the local road network or open space can safely support this density. I request that the development be refused in its current form.

I am the owner-occupier of 62 Banks Avenue (approx. 110 m from the site), living here with my young family. I SUPPORT renewal and upgraded social housing at 68–80 Banks Ave and have lodged a detailed letter. My concern is HOW it is implemented and managed. Key points: (1) Traffic and public transport – Banks Ave already carries school, sport and commuter peaks. The TIA relies on theoretical bus capacity; I request post-occupation monitoring of traffic and bus loadings, with a mechanism for TfNSW and Council to require mitigation if thresholds are exceeded. (2) Servicing – if the Banks Ave lay-by proceeds, it must have strict limits on hours, truck types, queuing and noise, plus a 12–24 month operational review. (3) Construction, design and management – strong conditions are needed on construction impacts, design integrity on the Jellicoe Park edge, and estate management so the mixed-tenure outcome works well for existing and future residents.

I support the project

While affordable housing is necessary, the rebuilding of new block on Banks avenue could be limited to 3 or 4 storeys but also MUST HAVE PARKING SPACE/UNDERGROUND.
It is already very congested on sports day in this area, the local dwellers have to face a lot of parking incivilities in addition to the everyday danger of the speed that many drivers exercise in the area due to a lack of speed bumps.
The project must consider a sustainable solution to parking without adding a potential dangerous tension to the current situation regarding parking space.
The bordering streets are narrow (one car passage) and at least 2 are cul de sac. It's an absolute mess already on those sport days around Jellicoe Park. Not even mentioning the parking of boats or other trailers full of junk that constantly occupy the space.

My objection is based on concerns regarding:
1. Public transport
Public transport to the area is already under significant strain with the addition of many new dwellings to the Eastgardens area and no increase in bus services along bunnerong road. Current wait times are often prolonged with buses filling before reaching Heffron Road. Adding 200+ dwellings will only exacerbate this.
2. Traffic
Traffic around Jellicoe park is often heavy which, combined with high numbers of child pedestrians, is concerning. Adding 200+ dwellings will result in further congestion and a potentially dangerous situation.
3. Low density residential
This area is primarily a low density residential area. The proposed development is out of keeping with the neighbourhood.

To: NSW Planning Portal / Assessment Authority for SSD-83256472 (Banks Avenue Pagewood Affordable Housing)
Subject: Submission regarding Banks Avenue Pagewood Affordable Housing – concerns about impacts on existing residents

Dear Planning Assessment Team,
I write as a resident at 52 Park Parade, Pagewood — i.e. directly neighbouring the area proposed for the above development, and likely to be affected by its approval. While I appreciate the need for more housing, I have serious concerns about the impact on local amenity, traffic, and parking; therefore I object / request modifications to the proposal as currently exhibited. My concerns are as follows:

1. Insufficient on-site parking and overflow onto local streets
The surrounding local roads (Banks Avenue, Birdwood Avenue, nearby streets) already allow kerbside parking on both sides and are known to become congested during peak times.
Planning Portal
+1
Given the likely number of additional dwellings and associated vehicles, I believe on-site parking will be insufficient — leading to overflow parking pressure on streets near Park Parade, degrading current residents’ access and amenity.

2. Increased traffic volume — congestion and safety concerns
Additional vehicles entering/exiting the development will add to local traffic, particularly on narrow local roads. This could increase congestion, delays, turning conflicts, and pose a safety risk for pedestrians (including children, given there are families with children nearby). Construction phase traffic will exacerbate this further.

3. Construction impacts on parking and local access
During any building works, the development may necessitate use of on-street parking lanes or works-zone space (as has occurred with similar nearby developments).
infoweb.bayside.nsw.gov.au
+1
This will further reduce available parking and access for existing residents — possibly for extended periods.

4. Loss of amenity and local character
A substantial increase in density may change the residential character of the area, increase noise, demand on local services, parking stress, and reduce the liveability currently enjoyed by residents at Park Parade and surrounds.

5. Lack of adequate supporting infrastructure / public transport options
While I note there is a bus stop on Bunnerong Road within walking distance of the site, many residents — including those with families or children — still rely on private vehicles. Without a significant uplift in transport infrastructure or parking capacity, the proposed increase in dwellings may lead to unsustainable pressure on streets.
Planning Portal
+1

Requested outcome / modifications:

Ensure sufficient on-site parking for all dwellings and visitors, so that local street parking and kerbside parking does not become oversubscribed.

Provide a clear traffic and parking management plan during construction, to avoid long-term disruption or displacement of resident parking.

Undertake a traffic impact assessment that robustly accounts for peak-hour traffic, turning movements, and cumulative effect on local streets (not just the development driveway).

Provide additional community benefit measures — e.g. improvements to road infrastructure, pedestrian safety, public transport, or dedicated visitor parking — to offset the increased density.

Thank you for considering my submission. I trust you will take careful account of the impacts on existing local residents and ensure that any development respects the amenity and liveability of Pagewood.

Yours sincerely

Lesley Janice Morcom
Resident
52 Park Parade
Pagewood NSW 2035

Having the carparking entry and exit points located on park parade is poor traffic management plans. To have an increase of 236 extra cars + visitors enter a one way high traffic flow area as in park parade when a street like banks ave which is two ways and aswell has the width to manage the traffic flow.
At the moment their is no driveways for stage 1 or stage 2 on park parade and perfect driveways already accessible on banks ave.

We also have a concern that although the traffic management plan has the correct number of carspots for the entire stages they are not split equally among the stages meaning apartment holders in stage 1 do not have sufficent car spots.

We also want to make sure the shadow of the builidng lets the sunlight on the jellicoe park playground we are concerned that in the afternoon the playground will no longer have sunlight.

Make sure the windows are double glazed to stop noise complaints from the sporting field activites.

To the Department of Planning, Housing and Infrastructure,
RE: Formal Submission of Objection to State Significant Development Application SSD-83256472 Location: 68-80 Banks Avenue, Pagewood Applicant: NSW Land and Housing Corporation (operating as Homes NSW) Council Area: Bayside Council Consent Authority: Minister for Planning and Public Spaces
I am writing to formally object to the proposed State Significant Development (SSD-83256472) at 68-80 Banks Avenue, Pagewood. As a neighbouring resident and frequent user of the local amenities, including Banks Avenue and Jellicoe Park, I hold significant concerns regarding the scale, density, and impact of this proposal.
While I support the renewal of social housing, the current proposal prioritises private market yield over public benefit, creates severe traffic inequities, and represents a gross misuse of taxpayer funds.
________________________________________
1. Introduction and Overview
The application seeks to demolish existing structures to construct one 7-storey building (social housing) and two 8-storey buildings (private market) comprising 224 dwellings. This represents a massive intensification of the site, shifting from a 2-3 storey walk-up context to high-rise towers.
This submission outlines critical flaws in the proposal regarding traffic management, amenity loss, excessive bulk, environmental degradation, and a fundamental failure to deliver value for money.
2. Poor Value for Money and Mismanagement of Public Assets
Beyond the physical impacts, the economic rationale for this development is deeply flawed and fails the public interest test regarding the use of taxpayer funds.
• Disproportionate Cost vs. Benefit: The project requires an estimated $160 million capital investment to fully demolish and rebuild the site. Spending this magnitude of public money to achieve a net gain of only two social housing dwellings (increasing from 82 to 84 units) is fiscally irresponsible. A comprehensive renovation of the existing buildings could likely achieve better living standards for tenants at a fraction of the cost, without the environmental waste of demolition.
• Inefficient Privatisation: It is economically unjustifiable to privatise and sell off over 60% of this public land (140 units) to the private market, only to return the essentially the same number of social housing units in a significantly reduced footprint.
• Diminished Asset Value: Not only is the public retaining less land, but the asset quality is being degraded. We are trading family-sized social housing units for predominantly 1-bedroom units.
• Taxpayer Value Test: Surely, this proposal does not pass the test for value for money for the NSW taxpayer. It appears to be an exercise in asset stripping rather than genuine housing renewal, sacrificing long-term public land capability for a short-term private development yield.
3. Traffic and Parking Impacts
The Transport Impact Assessment (TIA - Appendix M) characterises the development as having a "low" impact. This conclusion contradicts the daily reality of residents and fails to account for specific local conditions.
• Invalid Traffic Baseline (Winter vs. Summer): The TIA relies on traffic counts conducted on Thursday, 5 June 2025. June is in the middle of winter. This data is statistically irrelevant for assessing impact on a suburb defined by its sporting amenities. It fails to capture the peak demand during summer and shoulder sporting seasons when Pagewood Botany Football Club (PBFC) and other users utilise Jellicoe Park. During these times, parking is already fully occupied up to and beyond Birdwood Avenue.
• Existing Congestion & Meriton Overflow: Banks Avenue is already heavily congested, functioning as overflow parking for the high-density Meriton Pagewood Centro developments. Adding 224 dwellings without adequate parking will make street parking impossible for existing residents.
• Inequitable Parking Allocation & Support Services: There is a severe disparity in parking provision:
o Private Market (140 units): Allocated 200 spaces.
o Social Housing (84 units): Allocated only 36 spaces and zero visitor parking.
o Impact on Care: This low provision fails to recognise that social housing tenants often require dedicated parking for essential support services (e.g., carers, support workers, Meals on Wheels). By providing zero visitor parking, these critical workers will be forced to compete for saturated on-street parking, hindering care for vulnerable residents.
4. Excessive Bulk, Scale, and "Double Dipping"
The proposed scale is entirely out of character with the immediate R2 Low Density Residential surrounds.
• Exploitation of Height Bonuses: The applicant is utilising the 30% height bonus provisions under the Housing SEPP, raising the control from 22m to 28.6m.
o The Inequity: This bonus is intended to incentivise affordable housing. However, the applicant is applying this bonus across the entire development, meaning the 140 private market units are gaining extra height and views off the back of a "social housing" application.
o Non-Compliance: Despite utilising this massive 30% bonus, the proposal still exceeds the expanded limit, reaching 29.4m. This "double dipping" on height variations indicates an overdevelopment of the site that refuses to respect even generous planning envelopes.
• Bait-and-Switch Consultation: During initial public consultation, the community was presented with concepts for a four-storey development. The jump to 7 and 8 storeys is a betrayal of that initial engagement.
5. Loss of Amenity (Solar Access and Views)
The proposal significantly degrades the amenity of the surrounding area and future residents.
• Overshadowing Jellicoe Park: The sheer bulk of 8-storey towers will cast shadows over the park and neighbouring homes from 2:00 PM onwards, reducing the usability of the public open space during peak after-school hours.
• Internal Amenity Failure: The Architectural Plans (Sheet AR-DA-01A-XX-02) explicitly state that the Market Building Communal Open Space is "NON-COMPLIANT" regarding solar access. If the density is so high that the developer cannot even achieve compliant amenity for their own "premium" private communal spaces, the site is objectively over-massed.
6. Reduction of Public Housing Capacity
A critical examination of the "Social Housing Snapshot" reveals a reduction in actual capacity to house families:
• Net Loss of Family Housing: The proposal replaces 82 existing social dwellings with 84 new ones. However, the new mix is heavily skewed toward 1-bedroom units (63%). By replacing older 2-3 bedroom walk-ups with 1-bedroom units, the total number of bedrooms available for families in need is decreasing.
• Privatisation of Public Land: Approximately 70% of the site's yield (140 units) is being converted into private market housing. This is public land that should be utilised to maximise public housing, not sold off for private profit.
7. Environmental Impact
The environmental cost of this development is unacceptably high.
• Tree Removal: The proposal requires the removal of 65 trees, including 9 trees identified as having "High Retention Value". This represents an immediate and significant loss of canopy cover and local habitat that will take decades to replace.
8. Flawed Consultation Process
The consultation process has been inadequate and dismissive of community sentiment.
• Misleading Reporting: The Consultation Report (p.19) states that low attendance indicates "general community support". This is disingenuous; low attendance was a result of short notice and the fact that residents were originally shown a 4-storey plan. To interpret silence as support for an 8-storey tower is a manipulation of the facts.
________________________________________
Conclusion
This proposal represents an overdevelopment of the Pagewood site that privileges private market yield over social housing capacity, local amenity, and taxpayer value. It will choke local streets with traffic, overshadow Jellicoe Park, destroy mature tree canopy, and spend $160 million to effectively reduce family housing capacity.
I strongly urge the Department to refuse the application in its current form. I request that Homes NSW return to the drawing board to design a development that:
1. Is limited to a maximum of 2-4 storeys (consistent with original consultation).
2. Retains 100% of the land for public housing use.
3. Represents genuine value for money by investigating renovation options rather than demolition.