I am writing to provide a submission on SSD‑80018208. My concerns relate to the scale of vegetation removal, the ecological and visual impacts on the regional corridor, and the proposal’s inconsistency with the strategic planning and environmental objectives that apply to State Significant Development (SSD).

1. Scale of Vegetation Removal

The proposal involves the removal of 509 trees within an ecologically sensitive and strategically important corridor. This represents an extreme and irreversible loss of canopy, habitat, and landscape character. Under the SSD framework, impacts of this magnitude require heightened scrutiny, particularly in relation to biodiversity, cumulative canopy loss, and long‑term environmental resilience.

2. Ecological and Biodiversity Impacts

The affected corridor forms part of a broader habitat network that supports species movement, ecological connectivity, and climate adaptation. The removal of more than five hundred trees risks fragmenting habitat, reducing biodiversity, and undermining the ecological function of the precinct. These impacts cannot be meaningfully offset within any reasonable timeframe, and the documentation does not demonstrate that avoidance and minimisation measures have been adequately explored.

3. Landscape and Visual Impacts

The existing canopy contributes significantly to the landscape character and visual amenity of the area. The proposed removal of 509 trees would result in a stark and permanent alteration to the visual environment. The visual impact assessment does not appear to adequately address the cumulative effect of such large‑scale canopy loss, nor does it demonstrate consistency with the landscape values identified in relevant strategic planning instruments.

4. Inconsistency with Strategic Planning and SSD Assessment Principles

SSD proposals must demonstrate alignment with State and local strategic planning frameworks, including objectives relating to:

• protection of biodiversity and ecological corridors
• enhancement of urban canopy and climate resilience
• preservation of landscape character
• minimisation of environmental impacts through avoidance and design alternatives
• the public interest test under the Environmental Planning and Assessment Act


The scale of vegetation loss proposed under SSD‑80018208 is difficult to reconcile with these objectives. The documentation does not provide sufficient evidence that the proposal meets the public interest test or that environmental impacts have been minimised in accordance with SSD assessment principles.

5. Request for Further Assessment and Design Review

Given the scale and significance of the impacts, I respectfully request that the Department:

• require a more rigorous assessment of biodiversity impacts and cumulative canopy loss
• ensure that avoidance and minimisation measures are properly explored, not merely offset
• consider whether the proposal, in its current form, satisfies the public interest and strategic alignment requirements of an SSD
• require the proponent to investigate alternative design options that materially reduce vegetation removal

The removal of 509 trees within an ecologically sensitive corridor represents an environmentally disproportionate impact that is inconsistent with the principles governing State Significant Development. I urge the Department to carefully consider the long‑term ecological, visual, and strategic implications of approving a proposal that would permanently diminish the environmental integrity of the area.

Thank you for the opportunity to provide this submission.

Yours sincerely,

The Greenhouse Gas Emissions Assessment and Mitigation Plan appears to show the project to have scope 1 and 2 emissions exceeding 100,000 t CO2-e per year in the first year, yet there is no independent review per the requirements in the NSW Guide for Large Emitters. There are many sections missing from the Plan which are required per the NSW Guide for Large Emitters, for example: "Describe, in tabulated form, scope 1 and 2 emissions for each financial year over the project life, based on maximum capacity and planned operational throughput for each stage of the project and each scenario".

The 416 Group aims to represent residents of Killara and Lindfield who live west of Lady Game Drive. Its particular objectives are to work to ensure that current and future developments and activities do not degrade the natural assets of the area and that quality of life is maintained. More information about the group is here: https://www.416group.org.
The 416 Group area is poorly served by bus. The author of this submission lives 800 metres from the nearest bus stop and there are no footpaths. Residents in the area are dependent on their cars and use Lady Game Drive to travel north or south and have experienced steadily increasing congestion at the junction of Lady Game Drive and Delhi Rd at Fullers Bridge which is one lane each way. In the morning peak Lady Game Drive backs up more than 1km from the Delhi Rd junction. This congestion has grown as commercial and residential development has occurred on Delhi Rd, North Ryde. For this reason, we do not support any further development on Delhi Rd until infrastructure has been built to support it. Having said data centres with relatively few full-time staff are the least-worst kind of development and also are supported in principle as being consistent with Macquarie Park masterplan and being important to Australia's future prosperity.
The proposed development is too large and in particular through destruction of mature tress impacts on important natural bushland along the Lane Cove River corridor and the Great North Walking track which adjoins the site. The location of the access road and the Ausgrid STSS are problematic.
Why Mature Trees Matter
The mature trees along the river are vital. They provide shade, nesting hollows, help keep the area cool, and support a wide range of wildlife—including nesting birds, possums, insects, and even the ospreys that live just across the river. Their roots help reduce erosion. Young trees simply can’t do all this. It takes decades for them to grow and offer the same benefits. Removing the mature trees would leave a big gap in the ecosystem that can’t be quickly fixed.
A Home for Wildlife
The Lane Cove River is a rich and diverse habitat, home to many native and even threatened species, such as the powerful owl. The tall tree canopy helps animals move safely through the area and connects patches of bushland. If these trees are removed, it will break those connections and make it harder for wildlife to survive. It also increases risks from predators, noise, and light. The back up power generation located to "minimise impact on commercial and residential" maximises impact on the natural environment.
Problems with the Replacement Plan
Planting small native trees doesn’t make up for the loss of mature habitat. Young trees are fragile and need a lot of care to survive. The scale of this tree removal would change the landscape dramatically, and not just in how it looks—it would affect the whole ecosystem. We ask that this proposal and look for ways to protect the existing mature trees. They are not just part of the scenery—they are essential to the health of the river and the life it supports.
We propose a smaller development footprint which minimises the destruction of the forest. This may be achieved by reducing the floor area of the development, and/or placing more facilities underground and/or increasing the height. This would also increase the resilience of the project to bushfire. The 1994 Lane Cove Valley wildfire almost reached this site.

I object to the loss of trees and therefore habitat that will be impacted by the project. These are important buffer zones next to Lane Cove National Park and Great North Walk that are inhabited by wildlife and fauna.

This plan going ahead will result in the removal of 509 trees (Page 9 of EIS - Julius Avenue Data Centre 240625) that are part of the important habitat corridor right next to the Park and the Great North Walk near Fairyland.

Heat island effects, loss of animal habitat, bushfire risk and noise are other issues.

There is loss of habitat for three threatened fauna species, namely: Large-eared Pied Bat Chalinolobus dwyeri, Little Bent-winged Bat Miniopterus australis and Large Bent-winged Bat Miniopterus orianae oceanensis, and four threatened plant species, being Darwinia biflora, Deyeuxia appressa, Hibbertia spanantha and Rhizanthella slateri.

While I understand our increasing need for data centres, what I've read in the environmental report concerns me as someone who regularly walks and works in my local forests (I work full-time as a bush regenerator, for context).

As outlined on page 133 (p.146 in the pdf doc), 6.1.9, this project will have significant impact on biodiversity, including on endangered species. The regrowth at the site after the 2009 bedrock removal will be of local natives that will be difficult to replace (even if the same species are located, seed from other sites won't be as well suited and won't grow as well, the same biodiversity will not be achieved, and the unknown fungal communities that make our forests function will be greatly reduced or no longer present). Although the presence of woody weeds in the area is unfortunate, these can be removed with minimal work if council decides; but even if they weren't, lantana and privet are commonly used as habitat by tens of species of small birds and lizards, insects and all their predators.

I agree with the report that the endangered Darwinia biflora is almost certainly present on site (though I'm less familiar with the presence of bent-wing bat species, that doesn't mean they're not there). I've personally found it in many similar enriched sandstone forests, just like the hectares this project proposes to remove.

Moreover, the noise, air and water pollution, the rubbish, erosion and even things as small as food scraps discarded by workers, will all affect many more hectares of forest, not just the ones proposed to be removed. Weeds creep in from disturbance, meaning bush regenerators like me will need to be called in in the future, and more money will need to be spent on maintaining the forest around the proposed data centre. Local predators and pollinating birds will leave because of the noise, unbalancing ecosystems and letting local populations of plants die without their natural pollinators. Increased run-off will inevitably get into local creeks, further reducing water quality. A few years ago, I found a platypus in nearby St Ives - they live in far lower-quality waters than we used to think - and the creeks there and the ones in Ryde all feed into each other. That is to say, projects like this one have extraordinarily more far-reaching consequences than you may realise.

I imagine this project will go ahead regardless - I'm a bit cynical I'm afraid - but I'd like to thank you for reading and considering my voice. We have so little bushland left, and while I'd be happy for this project to go ahead on a lot that needed development, or somewhere else already cleared, I can't help but object to its location here. Thank you.

I strongly object to this project as the construction will result in the removal of 509 trees that are part of the important habitat corridor next to Lane Cove National Park and the Great North Walk. It will also result in increased urban heat island effects, loss of animal habitat, bushfire risk and noise pollution. Habitats for three threatened fauna species are at risk, namely: Large-eared Pied Bat Chalinolobus dwyeri, Little Bent-winged Bat Miniopterus australis and Large Bent-winged Bat Miniopterus orianae oceanensis, and four threatened plant species are at risk, being Darwinia biflora, Deyeuxia appressa, Hibbertia spanantha and Rhizanthella slateri.

I am concerned that there will be significant noise from the proposed development impacting the natural bush land and Lane Cove River. I have frequently heard noise (continuous droning sound) from a data centre located in Lane Cove West (Apollo Place) when I walk on the Great North Walk on the other side of the Lane Cove River. I can only imagine how intrusive noise from the proposed data centre at Julius Avenue will be. The proposed data centre at Julius Avenue is approximately 500m from the existing Lane Cove West data centre. There must be a cumulative noise impact if there are two data centres located so close. I don't see that this impact has been adequately considered in the current development proposal. This will not only affect people using the national park for recreation but will likely affect the native fauna.

I object to this proposal because of the proposed loss of trees and habitat right on the edge of the Lane Cove National Park making it a major threat to the Park. It is also an area mapped as Threatened Ecological Community, coastal enriched sandstone moist forest which I believe should be sufficient to decline this massive development.

The Lane Cove National Park is an invaluable asset, heat sink and lung for Sydney and has been shown to be enormously important to huge numbers of people, especially during Covid. I also immensely value it. I volunteer my time to weed and help bush regeneration. My neighbours and friends also value this wonderful natural asset we have in Sydney. This park is under enormous pressure as it has such a high edge to area ratio and urban impacts around the edge are very significant. This is proposal impacts where the park is at it's narrowest and any connecting bush is vital to protect and hinder any further degradation of the Park.

The EIS says a total of 509 trees are proposed for removal but 200 trees are of low retention value, that means 309 trees are of retention value , a huge number, have walked into this site from Richardson place on the path and it is beautiful resilient native bush with mature trees and tree hollows with a diverse healthy native understorey. I note Ryde Council has also a minuted meeting where Councillors express their concerns over the amount of tree removal and the replacement ratio.

Other points - Is the EIS completed by someone independent of the development company? It is not obvious this is the case. There are also discrepancies in the report leading to questions of it's validity, eg regarding the size of the land, 29ha at the beginning, where other places refer to 2.6-2.9 ha. There does not appear to be any attempts by the developer to 'avoid' impacts to native vegetation and threatened species which must be done. The rocky outcrop found on the site is significant habitat to threatened microbats, large bent-winged, little bent-winged and large-eared pied bat. Caves and rocky outcrops cannot be offset.

Finally, I cannot understand why a huge $1.5 billion project cannot be located elsewhere on unused and vacant/unoccupied blocks in Macquarie Park where there is ample evidence of both. A Data centre can be located anywhere and does not need to use a very sensitive and ecologically important site for the build.

We are scared. You are actively killing organisms and contributing to climate change. 500 trees may seem to small to powerful people like you but that's evil and inconsiderate it's a disgustingly high toll and will take integral oxygen from our atmosphere, increase global warming and contribute to the impending fatal consequences of climate change, the inevitable erosion and death of our world and all in it. You are stripping the lives and habitats of innocent animals support the balance of our precious ecosystem and will slowly die off and unable to sustain life at all and eventually it will harm us too. You are undoing all our communities efforts to try survive and using up energy and water that is sacred and our community truly needs and snatching it off those already suffering, and families can barely provide it for basic adequate standard of living for individuals under their care. Its horrifying you are even considering and planning to contribute to this, please stop, you have no idea the danger and harm you are doing to the earth and all life on it, every action makes a huge difference, and this could just be the undoing of all of it, please stop immediately, for the wellbeing, safety, and maintenance of life on earth that's already falling apart.
Kind Regards,

Madison Mulhearn (17 years old)