164–194 William Street, Woolloomooloo Attention: Department of Planning, Housing and Infrastructure
Re: Objection to Proposed Development – Height Breach, View Loss, Design Failures, and Affordable Housing Outcomes
I write to object to the proposed State Significant Development at 164–194 William Street, Woolloomooloo. My objection is based on five key grounds:
1. The proposal breaches relevant planning controls for height
2. The site is located in a sensitive, high‑value view catchment that has not been properly considered
3. The design is poor, inequitable, and deliberately shifts impacts onto specific neighbours
4. The built form outcome is visually inappropriate
5. The proposal fails to achieve equitable affordable housing outcomes

Submission on Amended SSD-80211463
164–194 William Street, Woolloomooloo

I write to register my objection to the amended proposal and accompanying Response to Submissions currently being exhibited.

I am an owner-occupier in the Top of the Town building at 227 Victoria Street, Darlinghurst. I previously lodged an objection in November 2025. I am supportive of affordable housing and urban renewal in Woolloomooloo, but I object to the amended proposal.

I acknowledge the applicant has amended the design in response to selected concerns raised in November, but not all. I also acknowledge that a new visual impact report has been provided, including a revised desktop assessment of the impact on apartments in Top of the Town. Although my apartment (610) was not included, it did consider neighbouring apartments on Level 6. Still, no revised photomontage was provided for this building, and it is taken as a fait-a-compli that moderate impacts are acceptable. In my opinion, this assessment remains unfounded and inadequate.

It is clear that the amendments incorporated since November did not materially address my fundamental concerns about the overall scale of the development, and development yield remains substantially unchanged. As such, the returns to the developers through new high-end properties above the LDP height limit will substantially impact on existing residents views, property values and compound social inequity in the neighbourhood.

My original submission raised concerns about the analysis of alternative building arrangements undertaken by the applicant. Those concerns were not addressed. The assessment continues to assume that the affordable housing outcome can only be achieved through additional height above the current height limits. Insufficient consideration has been given to alternative approaches that could deliver affordable housing outcomes while remaining closer to the original envelope. A more suitable balance should be able to be achieved without breaching current height limits, I firmly believe.

Accordingly, I respectfully request that the Department require the developers to revert to the original approved proposal while still facilitating affordable housing outcomes, which will be a better outcome for the whole community.

Yours sincerely,
Stephanie Clarke
Darlinghurst Resident and Owner-Occupier

Please see attached application objection response.

I object to the proposal for Application No. SSD-80211463. An 18-storey building at that location along William Street will exacerbate the wind tunnel effect already afflicting this corridor. It is unpleasant enough having to walk next to so many fast moving vehicles passing through William Street.

I also object to the manner in which this application has been tendered initially as one thing, and then coming back as something completely different in the amended form. The original Development Application had a 6-storey building and a 10-storey building. The amended application has a 10-storey building and an18-storey building. I can't imagine how an 18-storey building will improve Woolloomooloo or how it will benefit anybody living within a 500 metre radius of it. It seems like a cash-grab to me.

The description of the affordable housing proffered by this development is disappointing. The units were not designed for the comfort if the residents, not having proper air-flow, outdoor space and exposure to direct sunlight.

I would support the development application if the the bulk of the building were kept to the existing size/dimensions of the Bayswater Car Rental which is scheduled for demolition. Any building higher than 5-storeys is going to block the sun getting to street level, particularly in the winter.

The proposed development is much higher than originally planned. There seems to be an endless amount of high rise developments being approved in the immediate area, and we are going to end up with no natural light , much like the CBD. I have lived in this area since 1995, and the development has always been steady and consistent up until recently. The impact on residents of surrounding buildings is going to be enormous if this development is approved as planned. The traffic congestion is going to be terrible because there will be hundreds of extra residents, but there will be minimal affordable housing. As seen in previous high rise developments in the area, who also claimed to be building affordable housing, the starting price is over the million dollar mark. In addition, this development will decrease the value of many local units by blocking the views of the harbour, bridge, opera house, etc. It will also block the sun on many of the same buildings. None of the residents of this area chose to live here because they wanted to live in a concrete jungle, otherwise we would live in the CBD. I am all for development, but the heights being proposed, and from my understanding, approved, are not in line with the ambiance of the area.

Hi,
I object to the project as it is too big. I think it should be reduced in size by 50%. The area is over developed; it is the most densely populated area of Australia. Dense, massive unit blocks should be spread out around Sydney and Australia. No more big unit blocks for Darlinghurst, Woolloomooloo, Potts Point, Rushcutters Bay area please. Please make it smaller.
Best regards
Patrick Strachan
0415323436

Document attached outlining objections.

I formally object to the proposed amended mixed-use development at 164–194 William Street, Woolloomooloo, currently on re-exhibition as State Significant Development Application SSD-80211463. As the occupier of Unit 701, Top of the Town, 227 Victoria Street, Darlinghurst, I am directly affected by this proposal.

The amended application does not resolve the fundamental concerns raised during the initial exhibition and, in several respects, is more intrusive than the original proposal. I urge the Department to refuse the application or require a substantial reduction in height and density.

1. The Proposed Height Is Far Beyond What Planning Controls Allow
Under the Sydney Local Environmental Plan 2012, the site is subject to maximum height controls of 35 metres on the William Street portion and 22 metres on the Dowling Street portion. Even with the 30% Housing SEPP bonus, the maximum permissible heights are 45.5 metres and 28.6 metres respectively.

The proposal substantially exceeds these controls. The William Street East building is proposed at 68.8 metres, with an apex of RL +89.65, which is more than 51% above the maximum permissible height after the Housing SEPP bonus. The Dowling Street building also exceeds its controls by up to 22.7%.

These are not minor variations. The proposed Clause 4.6 variation has not demonstrated that compliance is unreasonable or unnecessary. A preference for a taller design is not sufficient justification for exceeding development standards by this extent. I request that the Department refuse the variation and require compliance with the permitted heights.

The approved Concept Development Application contemplated buildings of 5, 6 and 10 storeys, with a maximum height of RL57.9. The current proposal is substantially larger and seeks to relinquish the Concept DA rather than amend it, removing an important safeguard.

2. The Development is Incompatible with the Heritage and Character of the Area
The site directly adjoins the Woolloomooloo Heritage Conservation Area, which contains Victorian terraces, former warehouses and fine-grain built fabric of significant heritage value. A 68.8-metre tower beside two and three-storey heritage buildings does not provide an appropriate height transition.

Given the scale of the proposal and its proximity to a recognised heritage conservation area, I request that the Department obtain independent heritage advice before any determination is made.

3. Noise, Wind and Amenity Concerns
The proposal includes rooftop communal areas and terraces on multiple buildings. Elevated outdoor spaces can transmit noise across neighbouring residences, particularly during late-night use. If approved, strict operating conditions should apply, including curfews on amplified music and gatherings after 10pm on weeknights and 11pm on weekends.

The Pedestrian Wind Assessment acknowledges reduced pedestrian comfort compared with the approved concept envelope and localised wind increases at laneway entrances. These impacts undermine the claimed public benefit of new laneways and open spaces and further support refusal of the height variation.

4. Traffic, Parking and Infrastructure Impacts
The proposal includes 227 dwellings, significant retail floor area, 340 car parking spaces and 298 bicycle spaces, with vehicular access via Forbes Street. This will add pressure to an already congested area adjacent to William Street.

The EIS identifies other nearby development proposals, including 134 William Street and 203–225 Victoria Street. The cumulative traffic, infrastructure and visual impacts of these developments have not been adequately assessed. A proper cumulative impact assessment should be required.

5. The Assessment Process Lacks Independence
I am concerned that many key assessment documents, including the EIS, Visual Impact Assessment, heritage assessment, social impact assessment, Clause 4.6 reports and response to submissions, were prepared by Urbis Ltd, engaged by the proponent. The peer review of the Visual Impact Assessment was also conducted by Urbis, which does not constitute independent review.

The Department’s Request for Further Information indicates that the original Visual Impact Assessment was inadequate. I request independent expert review, including an independent Visual Impact Assessment by an unconflicted firm, before any determination is made.

For these reasons, I formally object to SSD-80211463 and request that the Department:

1. Refuse the application or require substantial height reductions to comply with the permitted heights, including the Housing SEPP bonus;
2. Refuse the Clause 4.6 height variation;
3. Commission an independent Visual Impact Assessment, including photomontages from relevant levels within 227 Victoria Street;
4. Require independent heritage advice on the impact of the proposed tower on the Woolloomooloo Heritage Conservation Area;
5. Require a cumulative impact assessment addressing nearby State Significant Development proposals;
6. Impose strict operating conditions on rooftop communal areas, including noise curfews; and

The proposal is excessive in height and density and would adversely affect local amenity, views and heritage character. I urge the Department to require a substantially redesigned proposal that complies with the planning framework, or to refuse the application.

Please see my letter attached. Thank you

I vehemently object to the proposed development in its current form on the basis of excessive height exceedance and resulting visual impacts.

1. Excessive height beyond planning controls
The proposal materially exceeds both the SLEP building height limits (22m/35m) and the SEPP-adjusted limits (28.6m/45.5m), with proposed heights of up to ~35.8m in the north and ~70m in the south. This represents a significant departure from the planning framework, not a minor or site-specific variation.

2. Insufficient justification for the uplift
The rationale that height is “redistributed” across the site does not justify the overall quantum of additional height. This is a design choice rather than a constraint, and there is limited evidence that a compliant scheme would produce worse outcomes.

3. Demonstrated visual impacts
The Visual Impact Assessment identifies a meaningful number of moderate to severe impacts, including impacts to Harbour Bridge, Opera House and harbour views from surrounding properties. These impacts are not limited to minor or peripheral changes, and in some cases affect high-value views. Views from our building, the Elan, have not even been considered. Around 25% of the apartments will have their views materially impacted over St Marys and the Sydney City skyline. In addition to the Holiday Inn development, it is frankly quite absurd and how little the NSW Government considers surrounding residents - given this is housing for high net worth individuals, and not actually delivering housing for those who need it. If the development matched the height of the existing William Street buildings, it would not impact thousands of residents.

4. Inconsistent with planning objectives
The proposal does not adequately satisfy the objectives of the height controls, particularly in relation to: A) appropriate scale relative to context, B) equitable view sharing and C)limiting amenity impacts on surrounding properties.

5. Overreach beyond affordable housing bonus
While affordable housing is supported, the planning framework already allows a 30% height bonus. The additional exceedance goes materially beyond this and is not sufficiently justified by public benefit.

Overall, the extent of height non-compliance and the associated visual impacts are excessive and not supported by the justification provided. This application needs to be refused in its current form, or amended to materially reduce building heights in line with the SLEP and SEPP controls.