Dear Planning Committee,

I sincerely object to the revised monumental increase in scale and scope of development works to the site at 164 - 194 William Street, Woolloomooloo. The vast increase contravenes and disregards the Sydney Local Environment Plan representing housing planning and such an increase will totally degrade the William Street and surrounding precinct areas.

The bulk and scale of the proposed development contravenes the precedent of the Woolloomooloo Greenbans in which Juanita Neilsen tragically lost her life in the fight to preserve the integrity of the Woolloomooloo suburburban community and its scale in terms of development. The vast increase in the scale of the development will have significant detrimental impacts to the character of both Woolloomooloo and William Street in general. With follow on impacts to the suburbs of Darlinghurst and East Sydney.

Given that William Street is the main arterial transit for commuters and drivers from the Eastern Suburbs of Sydney to and from the CBD (Central Business District), the vast increase in traffic activity (far in excess of the design excellence former approval) will see a substantial increase in traffic congestion and reduction in traffic flow.

There are many grey areas omitted from the plans that have been submitted in regards to the development which leaves many avenues open to exploitation should the development be approved - an example of these under-explained or planned areas includes the inclusion of the privately owned “public park” and the so called park’s use in the development’s planning capability due to the fact that the privately owned and included park is not included or considered in the GFA (Gross Floor Area) of the development.

Thank you for your consideration of these grave planning concerns in order to preserve the integrity of the East Sydney and Woolloomooloo area.

The proposed development is fundamentally incompatible with the existing environmental, social and physical character of the Woolloomooloo precinct. It represents an unacceptable overdevelopment.
The development exceeds the original and indicative limits .
The development will result in significant, irreversible and unreasonable view loss for countless residential properties including my building and will lower the property value.
Views of iconic heritage such as the Sydney Harbour Bridge, Opera House and Harbour are part of the public good and their obstruction constitutes an unacceptable loss of visual amenity.
The adverse impacts on visual amenity, solar access, residential privacy, local infrastructure and the cumulative impact on the Woolloomooloo community are fundamental flaws that cannot be mitigated by conditions of consent.

Sincerely
Susan Foster

The height of the proposed building at 164-194 will have a significant impact on the outlook from our apartment. In addition to the planned redevelopment of the Holiday Inn, the overall impact will be to affect our views to both the north and the east.

1. The new design is much higher than approved project, this will block the sun, leave my building in the shadow.
2. Noise: such huge residential building in the small street will make the area much noisy.
3. Traffic: “Under Site Access and network - Vehicular access to the site is
currently obtained from Forbes Street and Dowling Street, with multiple
vehicular cross overs along Forbes Street.“ This is not true. There are not
multiple vehicular cross overs along Forbes Street.
Access to Dowling street, which is difficult now, will become even worse
because there will be extra vehicles; cars, and trucks servicing the new build.
If travelling from the east to reach Dowling Street, it will be very difficult
because of extra traffic traveling to the new build via McElhone and Cathedral
streets.
4. The effect of Social Wellbeing – homelessness in the area will be a major
concern in surrounding streets where people use the public park, which is
extremely small, yet part of the new build.
5. Wind assessment – if there is excessive height, which there is with the new
DA, Dowling street, McElhone street and Forbes street will have an unlimited
amount of extra wind which will be directed down these streets, from the north
and the south.

See attachment

As a local resident I am directly impacted by this proposal and I therefore make my objection for the following reasons:

Extremely poor community consultation:

There has been very little opportunity to consult with the developers and to find out relevant information. Questions have been asked and not responded to.

Previous proposals in the area for similar large-scale developments in the area have been refused and the reasons for these refusals have not been addressed in this latest proposal indicating that lessons have not been learned or previous concerns have been ignored. Eg. A 2018 proposal to redevelop the Kings Cross shopping centre site was withdrawn following significant community objection.

My second point relates to the one above:

Concerns over increased density in an already densely populated area.

This has not been addressed. This development, together with the proposed developments at 134 William Street and 203-225 Victoria Street, Potts Point will bring in hundreds more vehicles and up to 1000 more people. Kings Cross will lose its unique social and cultural heritage. Also, increased traffic will add significantly to already very congested roads and infrastructure,

It seems that this proposal does not take into consideration the broader view that three major proposals are being considered at the same time.

In summary, previous applications for major developments have been rejected because of issues concerning the negative impact of increasing density in an already densely populated area. Also, the community has not been adequately consulted on a project that will have a massive impact on the community. The proposals makes some significant assumptions that must be challenged openly in a community forum.

The projected building is too high for this environment and would block the view from neighbouring apartment buildings.
The amount of projected affordable housing is insufficient considering the needs in the area. The proportion of affordable housing in whatever building size is approved for this site must be considerably increased.

I am writing to formally object to the proposed mixed-use development with in-fill affordable housing at 164–194 William Street, Woolloomooloo. My objection is based on a range of concerns regarding the adequacy of the documentation, the lack of detailed analysis, and the potential negative impacts on the local community and infrastructure.
1. Insufficient Documentation and Lack of Substantive Analysis
The documentation provided in support of this development is overly general and fails to include the necessary factual and quantitative analysis expected for a project of this scale. There is a notable absence of detailed assessments regarding traffic impacts, visual and aesthetic considerations, social and community outcomes, economic effects, flooding and drainage, easements, affordable housing mechanisms, noise, wind, and safety implications.
For example, page 17 of the SEARs Request notes:
“It is anticipated that the mixed-use development would deliver social and economic benefits associated with the delivery of a key site in the planned precinct, in addition to the creation of job opportunities.”
However, this assertion is not substantiated anywhere in the Environmental Impact Statement (EIS). The only reference to employment benefits concerns short-term construction jobs, which, according to the EIS itself, will not be sourced from the local area. This lack of evidence and specificity undermines the credibility of the proposal’s claimed social and economic benefits.
2. Inadequate Assessment of Public Transport Capacity
The EIS asserts that the site is well-located, with convenient access to train and bus routes. In reality, public transport services in this area are already operating at or beyond capacity during peak periods. There is only one train line serving the area, and bus routes 324 and 325 share the same route. The 311 bus is the only alternative service, and it does not travel along William Street.
The EIS notes a commitment to consult with Transport for NSW and Roads and Maritime Services, but there is no evidence that any such consultation has occurred. Furthermore, the cumulative impact of nearby proposed developments—such as those at 134 William Street, Woolloomooloo and 203–225 Victoria Street, Potts Point—has not been adequately considered. These projects, combined, will substantially increase the local population and place further pressure on already strained transport infrastructure.
A holistic, precinct-wide transport and infrastructure assessment must be undertaken. Evaluating 164–194 William Street in isolation is insufficient and misleading.
3. Private Transport and Traffic Impacts
The increase in private vehicles resulting from this development will place additional strain on an already congested road network. William Street is a key arterial route connecting the eastern suburbs to the city and is already prone to severe traffic congestion, particularly near the Eastern Distributor entries at William and Bourke Streets.
Local streets surrounding the proposed development are narrow and frequently reduced to single-lane access due to on-street parking. The multiple proposed entry points to the development’s car park are impractical in this context and will create additional congestion and safety risks.
The EIS relies heavily on assumptions about future transport strategies, such as the NSW Government’s Transport Strategy 2056, rather than presenting concrete, evidence-based traffic management solutions relevant to current conditions. The development should not proceed without a comprehensive traffic impact study demonstrating how the increase in vehicle movements will be safely and effectively managed.
4. Parking Provision
Parking availability is already extremely limited in Woolloomooloo, Darlinghurst, and Kings Cross. The proposed allocation of retail parking “for staff only” fails to consider the needs of visitors, customers, and residents. The lack of provision for adequate visitor and retail parking will inevitably lead to further congestion on surrounding streets and exacerbate the already critical parking shortage in the area.
5. Groundwater and Drainage Impacts
The EIS notes that “perimeter drainage will be installed to capture and divert groundwater” (p.16, Groundwater Impact). However, the documentation fails to identify the proposed discharge point, the route of diversion, or the receiving environment. This omission prevents any meaningful assessment of downstream impacts and is inconsistent with the requirements of the Environmental Planning and Assessment Regulation 2021, which mandates that EIS documentation include detailed information about potential environmental effects and mitigation measures.
Without a clear explanation of where the diverted groundwater will flow, it is impossible to determine whether the proposal will exacerbate local flooding, groundwater drawdown, or waterlogging on adjacent properties and streets. This is particularly concerning in Woolloomooloo, an area known for its complex subsurface hydrology and proximity to tidal influences. The redirection of groundwater without appropriate hydrological modelling or risk assessment could compromise the structural integrity of nearby buildings and public infrastructure.
In addition, the EIS does not address the cumulative groundwater impacts arising from other major developments currently proposed within the immediate vicinity, including 134 William Street, Woolloomooloo and 203–225 Victoria Street, Potts Point. Given that these sites share similar geological conditions and groundwater characteristics, a coordinated, precinct-wide groundwater management plan is essential. Assessing each site in isolation disregards the interconnected nature of the local water table and risks unanticipated environmental consequences.
In summary, the proposed groundwater and drainage strategy is inadequately detailed and environmentally unsound. Prior to any approval, the proponent should be required to submit a comprehensive hydrogeological assessment, supported by modelling of cumulative impacts and evidence that the proposed drainage design will not adversely affect surrounding properties, public infrastructure, or the broader catchment.
6. WIND
Page 16 of the Pedestrian Wind Assessment acknowledges that William Street is already subject to elevated wind conditions. Despite this, the EIS asserts that the proposed development will not exacerbate existing wind tunnelling effects. This conclusion appears inconsistent with both the site context and the built form proposed, given the height, bulk, and orientation of the buildings and their proximity to narrow street corridors.
At present, there are no suitable outdoor dining or gathering areas along William Street, largely due to the prevailing wind conditions. Unless the proposed development includes effective wind mitigation measures, such as appropriately designed awnings, podium setbacks, landscaping, or architectural wind breaks, the project will fail to deliver the active street frontages and pedestrian-friendly environment it purports to create.
In its current form, the development does not appear to alleviate or improve existing wind tunnelling effects, meaning that outdoor dining and public domain activation will remain impractical once the development is completed. Moreover, the persistent high wind levels make walking along William Street uncomfortable and uninviting, which will undermine the viability of the proposed retail and hospitality tenancies and diminish the intended social and economic benefits of the project.
A comprehensive wind mitigation strategy, supported by detailed modelling and physical testing, should be required to demonstrate that the proposal will contribute positively to pedestrian comfort, safety, and the overall quality of the public realm.
7. AFFORDABLE HOUSING
The proposal’s approach to “affordable housing” appears largely tokenistic and financially motivated, rather than a genuine effort to deliver long-term social benefit. The so-called affordable housing component is confined to less desirable sections of the development, lacking equitable access to amenity, natural light, and outlook. Furthermore, the maximum lease term of 15 years, after which the units revert to the developer for sale at market value, fundamentally undermines the intent of the State Environmental Planning Policy (Housing) 2021 and the Affordable Housing Act 2009, both of which are designed to secure enduring affordable housing outcomes.
While the EIS states that the proposal will “provide housing for low- to moderate-income earners,” the supporting Social Impact Study (p.39) identifies that the existing demographic profile of the area is dominated by Professionals (40.1%), Managers (24.8%), and Clerical and Administrative Workers (11%). This data suggests that the proposed affordable housing model is misaligned with the established social fabric of the community and may not meaningfully contribute to socioeconomic diversity or local housing need.
CONCLUSION
Given these deficiencies, the proposal in its current form cannot reasonably be approved. The documentation fails to meet the necessary standards of transparency and analytical rigour, and it does not adequately address the cumulative transport, social, and environmental impacts on the local community.
I therefore formally object to the development application for 164–194 William Street, Woolloomooloo, and request that it be rejected or deferred pending the submission of a of a revised proposal with comprehensive, evidence-based impact assessments and genuine community consultation.
WENDY BUSWELL

Please see my submission attached