Formal Submission Letter – Objection to SSD-90337724
To:
NSW Department of Planning, Housing and Infrastructure
Major Projects Division
Re: Objection to SSD-90337724 – 1 King Street, Concord West
Dear Sir/Madam,
I am writing to lodge a formal objection to the proposed development at 1 King Street, Concord West (SSD-90337724). While I acknowledge the importance of housing supply and urban renewal, this project in its current form presents serious and unacceptable impacts on the local community. My opposition is based on clear evidence relating to road traffic congestion, rail commuter capacity, and broader community safety and livability concerns.
1. Road Traffic Congestion – King Street and Surrounding Streets
Existing Conditions:
• Traffic volumes in Concord West are already high, particularly during school pick-up and drop-off hours.
• The section of King Street adjacent to Concord West Station is not a through road, creating a natural choke point.
• The intersection of King Street and Pomeroy Street near North Strathfield is a well-documented bottleneck, with queues extending into surrounding streets during peak periods.
Evidence from EIS and Local Studies:
• The EIS acknowledges traffic impacts but proposes only minor operational adjustments such as signal timing changes.
• No structural upgrades (road widening, intersection redesign, or bypass creation) are proposed.
• Traffic Impact Assessments in similar projects (e.g., Concord Avenue proposals) highlight that without physical interventions, congestion worsens exponentially with new dwellings.
Projected Impact of SSD-90337724:
• With over 1,300 dwellings and associated retail/commercial activity, vehicle movements will increase significantly.
• School traffic will be directly affected, with longer delays and increased risks for children crossing congested intersections.
• Emergency vehicle access will be compromised in peak periods.
Conclusion: The project fails to adequately address the severe traffic congestion already present in the area.
2. Rail Commuter Capacity – Concord West Station
Current Situation:
• Boarding trains to the City from Concord West Station is already extremely difficult during peak hours.
• Rhodes Station commuters, due to overpopulation, fill trains before they reach Concord West, leaving little to no capacity for Concord West residents.
Evidence from EIS:
• The EIS assumes Concord West Station can absorb additional human traffic without upgrades.
• It highlights proximity to rail but does not propose station capacity improvements, pedestrian flow management, or service increases.
Projected Impact of SSD-90337724:
• Thousands of new residents will rely on rail transport.
• Without upgrades, overcrowding will worsen, reducing accessibility for existing residents.
• The project undermines its own claim of being a transit-oriented development, as the infrastructure cannot support the demand.
Conclusion: The project will exacerbate overcrowding, reduce accessibility, and compromise the viability of public transport in Concord West.
3. Broader Community Impacts
• Safety Concerns: Increased traffic and pedestrian congestion around schools and the station precinct pose risks to children and vulnerable community members.
• Infrastructure Deficit: The proposal does not include binding commitments to major traffic junction upgrades or rail capacity improvements, leaving critical infrastructure gaps unaddressed.
• Livability: The scale of the development is incompatible with existing transport infrastructure, threatening the quality of life for current and future residents.
4. Requested Action
Given these unresolved issues, I respectfully request that the Department of Planning, Housing and Infrastructure:
1. Reject the proposal in its current form, or
2. Require substantial revisions to include:
o Major traffic junction upgrades at King Street and Pomeroy Street.
o Rail capacity improvements at Concord West Station, coordinated with Transport for NSW.
o Binding commitments to infrastructure delivery prior to or concurrent with construction.
Closing Statement
In conclusion, SSD-90337724 represents a development of excessive scale for the existing transport infrastructure. Without meaningful interventions, it will impose unacceptable burdens on the Concord West community. I urge the Department to act in the best interests of residents, commuters, and school communities by rejecting or substantially revising this proposal.
Thank you for considering this submission.
Yours faithfully,
Marek Pionka
243 Queen Street, Concord West, NSW 2138
0435009565

Dear Planner
I object to the demolition and remediation proposal for 1 King Street for the reasons outlined below.

1. Excessive Noise Levels – NMLs Exceeded at ALL Sensitive Receivers
The Construction Noise Assessment confirms that predicted noise emissions will exceed the Noise Management Levels (NMLs) at every sensitive receiver. This is an alarming finding and, constitutes grounds for refusal or redesign.

1.1 Impacts on Residents
Exceeding NMLs means residents may be exposed to noise levels that are:
(a) 10–20+ dB above recommended thresholds, with worst-case scenarios predicting 60–89 dB around the site throughout the demolition and remediation program;
(b) Well above WHO safe community noise guidelines (50–55 dB outdoors)
At these levels, evidence shows increased risks of:
(a) Sleep disruption
(b) Elevated stress hormones
(c) Cognitive fatigue and reduced concentration
(d) Cardiovascular strain
(e) Reduced respiratory function
(f) Insomnia and chronic stress
The assessment also notes that demolition and remediation equipment (hydraulic hammers, bulldozers, jackhammers, air compressors, concrete breakers, heavy trucks) will create high-intensity, harmful noise spikes.

1.2 Impacts on St Ambrose Primary School Students
St Ambrose Primary School lies within noise impact area “S1,” placing young children—who are more vulnerable to noise—at significant risk. Potential impacts include:
(a) Impaired concentration and slower learning
(b) Heightened agitation or behavioural stress
(c) Noise-induced anxiety

These impacts are compounded by existing noise sources:
(a) Regular train movements at Concord West Station
(b) Loud playground activity
The cumulative effect will create an acoustic environment far beyond what is safe for children or nearby residents.

2. Vulnerable Household Members With Documented Medical Conditions
My household includes medically vulnerable individuals for whom the proposed noise levels pose serious health risks:
(a) one member suffers from chronic migraines, sleep difficulties, anxiety, and respiratory sensitivities;
(b) Another member is elderly (70+) and has high blood pressure, high cholesterol, and sleep-related health conditions.

Noise above NMLs may trigger:
(a) Blood pressure spikes
(b) Sleep deprivation and associated cardiac strain
(c) Anxiety attacks
(d) Exacerbation of respiratory and cardiac symptoms
These conditions make it unsafe for us to remain in our home during the high-impact demolition and construction works, and therefore we request a temporary relocation plan to be provided.

3. Dust, Asbestos and Contaminant Risks – Inadequate Assessment of Off-Site Spread
The demolition and remediation works will release:
(a) Airborne asbestos fibres
(b) Silica and construction dust
(c) Contaminated soil particles
(d) Diesel particulate from trucks and machinery

Key concerns include:
(a) No clear plan for containing contaminated dust during high-wind conditions
(b) No analysis of spread via wind, stormwater runoff, vibrations, truck tyres, or accidental spills
Airborne fibre and dust exposure poses serious long-term health risks, particularly for the elderly and those with existing respiratory conditions (including members of my household).

4. Lack of a Clear Construction Timeline
The application does not provide key project details, including:
(a) Start and completion dates
(b) Identification of high-noise periods
(c) Demolition and excavation phases
(d) Remediation stages
(e) Truck and machinery movement schedules
Residents—especially medically vulnerable households—require this information to plan for safety, temporary relocation, or alternative arrangements.

5. Traffic and Safety Impacts
The surrounding road network is already heavily congested during peak hours, particularly on:
(a) Concord Road
(b) Wallbank Street
(c) Pomeroy Street

Further concerns include:
(a) Narrow residential streets (King Street and George Street)
(b) High traffic volumes from buses, trains, and school drop-off/pick-up
(c) Limited parking on King and George Streets

The addition of heavy construction vehicles will:
(a) Increase road safety risks for children and parents
(b) Worsen congestion and delays
(c) Increase the likelihood of traffic conflicts
(d) Expose pedestrians to dust, emissions, and safety hazards

For the reasons outlined in this submission, I respectfully request that the proposal be rejected in its current form, amended, or conditioned to ensure the protection of nearby residents, schoolchildren, and vulnerable households. I urge the planning authority to prioritise community wellbeing and to require a significantly safer and more responsible approach before any approval is granted.

Thanks and regards,
Concord West Resident

We are very concerned about the demolition of this site, not only about the demolition itself but also and more with the prospect that the demolition will be the precursor that paves the way for the high rise building blocks

About the demolition of this site:

1: What if the excavation or other demolition activities causes any damage to our property, such as cracks, spills; we request an pre-demolition inspection report (dilapidation report) for our property before the any work gets started;
2: How will our privacy be protected during and after the demolition activities? George Street is the only street in and out for us. How will the disturbance be minimized, especially during school days?

About the high rise building block:

3: Is there any current DA for the high rise building construction after the demolition work please? Have council members or State Government members visited George Street around 3pm in a school day afternoon? I will go out of my way to object and protest this construction. Have you thought how this will affect the already disastrous traffic condition faced by local residents?

I object to State Significant Development consent for SSD 90337724. The SEARs gap analysis reveals deficiencies so significant that lawful determination is impossible. The EIS is high-level, generic, and fails to meet mandatory requirements under the Environmental Planning and Assessment Act 1979 (EPA Act) and the Secretary’s Environmental Assessment Requirements (SEARs). These gaps are not technical—they strike at the core of statutory obligations to consider cumulative impacts and the likely effects of the development as a whole.

Why Approval Cannot Lawfully Proceed

Section 4.15(1)(b) of the EPA Act requires consideration of the likely impacts of the development as a whole. Section 5.5 requires examination to the fullest extent possible of all matters affecting the environment. Limiting assessment to demolition and remediation fails to consider mandatory relevant considerations, including cumulative impacts, and risks jurisdictional error. Part 8 of the EP&A Regulation empowers the Department to deem an EIS deficient and seek further information under section 4.40 where form or content gaps exist. On the present record, those gaps are material and must be corrected.

The EIS frames these works as the first stage of an eight-tower, forty-storey redevelopment. Approving this SSD in isolation would pre-empt and bias the main project assessment and lock in outcomes before the full scope of impacts is tested. This approach conflicts with the State Significant Development Guidelines, which warn against piecemeal approvals that undermine transparent and lawful decision-making. Concord West should not be sacrificed as a gateway for high-rise at the expense of its human-scale streets, green canopy, and family-friendly character.

I attach a tabulated document (“SEARs Compliance and Gap - 1 King St Concord West Demolition”) outlining the key SEARs failures and gaps, and I make mention of the following which holds close to my heart.

Key SEARs Failures

• SEARs Item 9 – Transport and Accessibility: No Transport Impact Assessment under TfNSW GITA. No modelling of intersection capacity, pedestrian safety, or cumulative traffic impacts. Haul routes lack enforceable controls.
• SEARs Item 13 – Flooding and Water Management: Interim flood risk untested. Drainage and erosion controls are conceptual only, contrary to SEARs and the Blue Book (Managing Urban Stormwater: Soil and Construction).
• SEARs Item 14 – Contamination and Waste: Acid sulfate soils and groundwater risks deferred. No robust monitoring, waste tracking, or EPA sign-off.
• SEARs Item 15 – Social Impact and Amenity: No Social Impact Assessment. No visual analysis, solar access, privacy, or wind assessment. Community feedback selectively disclosed, breaching procedural fairness.

Real-World Impacts Ignored

Concord West is not an abstract planning concept—it is a living community. I walk my dog daily. Anyone with a reactive dog knows how stressful sudden changes can be. Construction detours push us onto narrow paths crowded with extra foot traffic. Temporary fencing blocks familiar routes. There is often no safe place to pause when another dog approaches. These disruptions are real and affect wellbeing.

After heavy rain, I have watched water sheet across roads and flood footpaths. Without proper drainage and erosion controls, demolition will send runoff with sediment and contaminants into our streets and waterways. The EIS does not address these patterns we see in real life.

Litter and rubbish from construction already creep into gutters and parks. Add hundreds of workers and heavy vehicles, and the chokehold on vehicle access will be complete. Emergency vehicles will be delayed. Parents walking children to school will face unsafe conditions. This is not inconvenience—it is a direct impact on safety, health, and livability.

Procedural Fairness and Accessibility

The EIS fails to comply with guideline expectations by omitting a full Social Impact Assessment and providing no evidence that community feedback was meaningfully considered. It is implausible that only one impact was identified. The attached correspondence (“Email Confirmation from Billbergia Post Seminar” and “1 King Street_Concord West_Webinar Q&A summary”) confirms multiple questions and concerns raised by residents, yet these are not reflected in the EIS. Selective disclosure breaches principles of procedural fairness and erodes trust.

Residents with limited English proficiency or accessibility needs are excluded when materials and consultations are not provided in multiple languages or accessible formats. I have contacted both the proponent and DPHI on several occasions regarding accessibility concerns, yet these issues remain unresolved. The seminar date for community members was also incorrectly publicised (see attached “CALD Communities and Incorrect Seminar Dates”), compounding confusion and exclusion. These omissions amount to unfair treatment and breach of trust. If the consent authority proceeds without addressing these gaps, it risks judicial review for failure to consider mandatory relevant considerations and denial of natural justice.

The planning portal also displayed an incorrect submission closing date, which misled community members and compromised their ability to participate fully in the process, see attached (“Planning Portal Incorrect Submission Closing Date”). This error further undermines transparency and procedural fairness. I raised this issue directly with Liam Frayne. In addition, the EIS itself contained an erroneous reference to “Waterloo works” and omitted an appendix, as evidenced in the attached email correspondence (“Incorrect Waterloo Project Reference and Missing Appendix”). These errors are not trivial—they reflect systemic gaps in accuracy and accountability that erode trust in the process and deny the community a fair opportunity to engage.
Relief Sought

Refuse or defer determination until a single integrated assessment of the entire redevelopment is completed. If approval proceeds, it must be conditioned with enforceable requirements:

1. A full Transport Impact Assessment under TfNSW GITA, complete access design pack, Construction Workforce Travel Plan, and public exhibition of the final CTMP.
2. Detailed drainage and flood emergency plans, climate scenario testing, and Council sign-off prior to works.
3. Strengthened remediation obligations including acid sulfate soils and groundwater management, imported fill validation, EPA IWTS tracking, and independent auditing.
4. Transparent community reporting of milestones, validation results, and incidents.
Concord West deserves planning that respects its scale, protects its amenity, and tests cumulative impacts holistically—not a staged approval that pre-decides outcomes. Please refuse or defer this SSD until the full impacts are lawfully and transparently assessed.

Best regards
Louise