Whilst understanding that Sydney needs more infill housing, and affordable housing, of which I am broadly in support, I object to the current form of the development proposed for the following reasons:
Height and setbacks of the newly proposed tower on cnr Dowling and William Street: Previously approved at 10 stories, the 8 additional stories proposed will be on the corner of William and Dowling Street, increasing the height from 33 to 61 metres and more than double the height of any of the other proposed towers and 45% above the SLEP. The second tower facing Dowling Street is also significantly higher. There is no increase on the Forbes Street side. What is described as step down to Dowling Street is as high as the previously highest tower proposed. That’s a “cliff face”, not a “step down” Much has been discussed on view sharing of the harbour and opera house. For those who cannot afford those exclusive harbour views, the current view from the windows and balconies of my terrace in Dowling Street is of the blue sky, this tower will obliterate any view of the sky from the front windows of my house and will be out of scale with the neighbourhood. It will concentrate additional noise in Dowling Street, from the increased development with the balconies facing Dowling Street and angled towards the harbour (or the existing residents). The additional height should be more evenly shared across the four towers, for equity of visual, sound and scale reasons. The proposal talks of balance it is not, it is more likely a way to maximise views and dollars for the developer.
The "privately owned, publicly accessible park" will in reality be primarily for the residents of the development. It has allowed the developer to design zero set back on Dowling, Forbes and William Streets. The lack of set back, hard materials and 80% increase in height in my street will create significant noise and visual bulk, right on the street. Zero set back and 66.3 metres high is not good design for those who live in the street, despite the assurances from developer.
The EIS notes “The proposal includes a lower-scale podium at the rear to transition to the lower scale of the HCA, with setbacks to mitigate potential impacts on adjacent residential developments.” However, there is no set back on the streets where adjacent residential developments are located. There should be.
I note in the EIS “Active street frontages along William Street and the publicly accessible, privately owned park are not to be compromised by required services and exhaust grills” which only leaves Forbes and Dowling Street for them to vent to. This should be faced into the development which is responsible for the services and grills not into the surrounding streets.
Impact on nearby houses in Dowling Street
There is no discussion of how the development will impact the people who live in these more than 120 year old houses, although a lot of comment on the lovely heritage environment. By design all terrace houses have bedrooms at the front of the house and less than 4 metres from the road. These Victorian terraces are not dust or noise proof, and making then so is prohibitively expensive, even if it were allowed by council. This will create significant noise, dust and damage impact both during construction and after for which the developer has shown no mitigation.
Construction Traffic Impact: Every time a truck comes into Dowling Street, it rumbles all the way down the short street, does a three (or more) point turn to get out near the rail line and rumbles down the other side. For the residents in bed, we hear every truck, every reversing alarm (for every point of the three or more point turns required to exit the street), and when they sit and idle their engines it is noisy and polluting. Remember the 140 year old terraces are not noise, vapour or dust proof.
The suggestion that Dowling Street would be a good thoroughfare for construction traffic, per Figure 44: Indicative Construction Vehicle Routes, is ill conceived. Large trucks actually cannot turn around in Dowling Street, and previously police have had to be called to enable them to reverse back into William Street which is extremely dangerous. With construction hours starting at 7, even on a Saturday, construction traffic would start congregating less than 4 metres from my pillow from 6am, with their engines idling for an hour, in preparation for the 7am start, for what will be 3+years . I request there is no access for construction vehicles into Dowling Street for safety and amenity reasons.
Given the car rental company previously located at the development site, has moved across the road, it is highly unlikely that “The proposed development will result in a noticeable reduction in weekday traffic compared to the existing car rental operation, which currently generates up to 350 vehicle trips per day”. Traffic will be in addition to that already existing and the department should not be confused. Indeed, the move from the previous site of No Birds Car Rental to 200 William Street has already increased traffic in Dowling Street.
There seems to be a suggestion that tradespeople would get public transport to the site. That is a fantasy given the tools they need to carry. I request there should be no construction parking except directly in front of the development in Dowling. Given the existing commercial and resident activities in the cul de sac street, the difficulty of safely exiting onto William Street, with high pedestrian activity, significant additional construction traffic, on top of the existing high demand residential and commercial parking would be dangerous.
I further request, given the high level of demand for street residential parking, and that the developer has advised there is sufficient parking, that no parking permits, or visitor parking permits bee issued to any residents.
I expect significant and expensive damage to my very old terrace from the vibrations and building works, especially as the proposed development will now be excavated to 4 basement levels. I would like the dilapidation process to be clearly documented to residents, including any dispute process and thank Michelle for her assistance explaining the general process. Old houses are notoriously expensive to properly and sympathetically repair and any repairs need to be of an excellent standard.
I note that the development has protection from unwanted noise and acoustic pathways for their new residents. My existing house has neither. For the three 3+ years of construction I will barely be able to open a window from the dust and noise. Once the wall of 18 stories of apartments is built I am sure there will still be significant noise as there seems no mitigation, no setback and significant scale.

Precinct trading hours. The noise plan addresses outdoor dining from 10pm – midnight. COS own special entertainment precinct trading hours has standard hours for William Street until 10pm with extended hours to midnight only approved via a DA on a trial basis with a plan of management. I request that the development should only allow outdoor trading until 10pm unless they have a separate and approved DA.
Infrastructure
Is there a plan to work with NBN on the augmentation to telecommunications infrastructure required? Our internet availability is already patchy. I can see details for stormwater but not for telecommunications and request that specifically be addressed.

Lastly, we have a very active, happy and beloved urban possum population in Dowling Street. I have seen no study or discussion of how the construction and subsequent increase in ambient lighting will impact them and how this would be mitigated.

Thank you for considering the attached Planning Submission. This includes more accurate view assessments of the existing apartments within the SP.
Many apartments gain considerable residential amenity from the iconic Harbour land water and city views gained.
This proposal does not comply with expected density standards, is unreasonable in terms of planning and design outcomes and does not appear to demonstrate design excellence or consideration in line with Tenacity principles in terms of view equity/considered sharing. Please reconsider this scale and envelope. Details of planning concerns are detailed in the attached full document. Thank you. Natalie - Planner for SP

Thank you for considering the attached planning submission and view impact assessment provided by the strata
This proposal is excessive and results in unreasonable and severe/devastating view loss of iconic/water views from existing apartments which gain amenity from this outlook. View sharing does not seem to be considered in terms of design options/urban design and the proposal results in design issues and such considerable amenity and area impacts such as not to warrant support of Clause 4.6 to bonussed standards. Thank you for your consideration as to the attached assessment, Natalie
Details within, please be in contact if we can assist.

Attention: Ms Michelle Niles, Department of Planning, Housing and Infrastructure
Re: SSD-80211463 for 164-172, 174-194 William Street WOOLLOOMOOLOO NSW 2011
Mixed use development with in-fill affordable housing, 164 - 194 William Street, Woolloomooloo
Dear Ms Niles,
I am a property owner and resident at Strata Plan 20087 (5-15 Farrell Avenue, Darlinghurst) and will be severely affected by the proposed development at 164-172 and 174-194 William Street Woolloomooloo.
I live in [redacted] of Palisades at 5-15 Farrell Avenue. The building has wonderful views of the Sydney city skyline that include the Sydney Harbour Bridge, the Opera House, and the Domain/ Botanic Gardens. These views are a key component of the value of the apartments and are a major part of the pleasure of living here. It is why people choose to live in this area and many have remained in the area long term for this very reason.
In relation to the Planning Secretary’s Environmental Assessment Requirements, the Visual Impact Analysis would be severe at best. Both proposed alternative developments for the William street site will have a significant impact on the views from our building and in turn will impact our quality of life dramatically. The “Infill Housing” proposal creates a solid blockage of all the significant views mentioned above as well as having a very detrimental impact on the view in general. The outcome of this using the Tenacity/Scale/Value metrics in the Visual Impact Assessment would fall into the Severe zone at best with a score of 12 to 14 out of 15. The scale of this building is completely out of keeping with the local buildings. The “Alternative Massing” proposal will be marginally better, reducing the impact to the low end of severe with a score of 10 to 12. However, the immensity of this main tower dwarfs all other building in the precinct and destroys any sense of cohesion in the area.
The scale of both these options is completely inconsistent with the existing buildings on and around William Street and with the current height provisions for the area. It will destroy the outlook of most of the current residential buildings on the southern side of William Street and will completely overshadow the low-level housing in Woolloomooloo. The proposed developments seem to be vastly different to the original approved concept which, despite its size, was more in keeping with the local scale of buildings.
The scale of the development also potentially opens the door to the development of further oversized buildings along William Street which will completely destroy the inner- city living atmosphere and turn it into a characterless housing precinct. This will destroy the unique feeling of the area which has attracted people to live here.
There is an obvious need for further inner-city housing including affordable housing, however, it is imperative that it be done sensitively, with reasonable scaling and uplift and not at the expense of those who already reside in the area. It is important that the Department of Planning Housing and Infrastructure consider the impact that this and future development will have on existing housing in the area and ensure an outcome for future development that is balanced for all concerned.
FSR and Height objectives refer to protection of amenities, and require developments to be respectful of character and view sharing. The proposed changes to the original design are a clear breach of the balanced approach required. There will be major impact on existing residents with loss of views and overshadowing, resulting in a lessened living quality for many.
People are drawn to live in this inner-city part of the city of Sydney because of its history, its unique character and its sense of place, and the city itself benefits in a broader sense. Over-sized and ill-conceived development will rapidly destroy this forever. For this reason, it is imperative that this proposal be carried out with a view to being respectful of the needs of current residents as well as providing housing for others in the future.

Yours sincerely,

[Name Withheld]
5-15 Farrell Avenue, Darlinghurst

To:The Secretary NSW Department of Planning, Housing and Infrastructure
Major Projects Assessments
GPO Box 39, Sydney NSW 2001
Via: NSW Planning Portal – Major Projects Submission
Date: 12th November 2025
Subject: Submission on SSD-80211463 – 164–172 and 174–194 William Street, Woolloomooloo (“Bayswater” Development)
From:
Joanna Bridle
Unit 17, 1–5 Rosebank Street
Darlinghurst NSW 2010

Objection to Proposed Development – Loss of Views and Associated Amenity Impacts
I am the owner and resident of Unit 17, 1–5 Rosebank Street, Darlinghurst. My apartment faces north-east and currently enjoys established views towards the city, Sydney Harbour Bridge and the Woolloomooloo ridgeline. These views form an important component of the visual amenity and residential character of my dwelling and the wider Rosebank Street precinct.
Having reviewed the Environmental Impact Statement (EIS) prepared by Urbis for the above project, I wish to raise strong objection to the proposed development on the following grounds:

1. Significant Loss of Established Harbour Views
The EIS (refer Visual Impact Assessment, Appendix S) identifies that the site occupies a highly visible ridgeline position on William Street, within a “sensitive visual catchment with views available to the Sydney Opera House, the Sydney Harbour Bridge, the Domain and St Mary’s Cathedral.”
From my property at 1–5 Rosebank Street, these view corridors currently pass directly over the subject site. The proposed 18-storey building height (RL 57.9 m) and expanded bulk permitted under the Housing SEPP uplift will obstruct or substantially diminish the existing visual connection to the Harbour Bridge and city skyline.
The NSW Land and Environment Court’s established Tenacity Consulting v Warringah [2004] NSWLEC 140 “view-sharing principles” confirm that existing views of iconic public landmarks—such as the Harbour Bridge—should be reasonably retained and that development should seek to balance densification objectives with equitable view sharing. The EIS provides insufficient quantitative assessment of view loss from nearby residential receivers, particularly to the south-west (Rosebank Street and Barncleuth Square).

2. Deficiency in Receiver Selection and Photomontage Methodology
Further, the report restricts its analysis to a single ground-floor apartment within my complex, ignoring nine other apartments spanning four storeys that have substantially broader and higher-value view exposure. Upper-level apartments enjoy panoramic views of the Harbour Bridge, Opera House and city skyline that are entirely unassessed. By omitting these dwellings, the report materially misrepresents the extent of impact and cannot be relied upon to determine view loss under accepted planning principles.
A full, independent, and transparent reassessment must be undertaken from all relevant vantage points, including upper-level receivers within 1–5 Rosebank Street. This reassessment should use existing-condition verified photomontages (not incremental or comparative imagery alone) to accurately depict the magnitude of view loss from each affected dwelling and to enable proper application of view-sharing principles.

3. Excessive Height and Bulk Inconsistent with Local Character
While the site benefits from Housing SEPP incentives for affordable housing, the proposed 5.16:1 FSR and tower height up to 18 storeys significantly exceed the prevailing built form in the immediate locality (typically 4–10 storeys). The resultant visual massing will dominate the ridgeline and is inconsistent with the established scale transition between Darlinghurst and Woolloomooloo.
The Concept DA (D/2022/139) previously approved a maximum envelope of approximately 10 storeys. The uplift of 30% in both height and floor space under this SSDA introduces substantial additional bulk beyond the earlier design competition envelope, materially increasing the extent of view obstruction for surrounding properties.

4. Visual Impact Assessment Deficiencies
The EIS claims that the massing “preserves key view corridors, maintaining view sharing,” yet no verified photomontages are provided from representative residential receivers along Rosebank Street, Liverpool Street, or the Rosebank Heritage Conservation Area. The omission of such analysis means that the conclusion of “acceptable view sharing” is not substantiated. Our view will be lost entirely.
The Department’s Visual Impact Assessment Guideline (2023) and Apartment Design Guide (Objective 3J-1) require a transparent, receiver-based assessment of key viewpoints. I request that the Department require supplementary verified photomontages from representative Rosebank Street dwellings, including Units 9-12 and Units 17–20 at 1–5 Rosebank Street, to accurately depict the magnitude of view loss. These are the top 2 floors along our building that face William st.

5. Cumulative and Precedent Impacts
The EIS acknowledges several concurrent major projects in the immediate area (Table 6), including proposals at 134 William Street and 45–53 Macleay Street. In aggregate, these developments will contribute to substantial skyline densification and cumulative visual bulk visible from Darlinghurst ridges. The Bayswater proposal, as the tallest structure in its block, would establish a dominant precedent for excessive height that undermines the intent of the City of Sydney LEP 2012’s height controls and view corridor protection policies.

6. Request for Design Amendment
In light of the above, I respectfully request that the Department require the proponent to:
1. Reduce the height of the William Street tower by at least five to six storeys to preserve equitable view sharing and maintain consistency with the approved Concept DA envelope.
2. Provide additional view impact analysis from Rosebank Street and Darlinghurst receivers using existing-condition verified photomontages for all materially affected apartments (including upper level dwellings).
3. Commission an independent visual impact auditor (appointed by the Department) to verify photomontage methodology, receiver selection and the application of Tenacity view-sharing principles.
4. Demonstrate compliance with the Tenacity view-sharing principles, particularly regarding the reasonableness of view retention to significant public landmarks.

Conclusion
While I recognise the importance of delivering affordable housing and urban renewal in inner-city areas, this should not come at the unreasonable expense of established residential amenity and the visual quality of Sydney’s inner-east ridgeline. The current proposal represents an overdevelopment of the site that fails to achieve an appropriate balance between housing objectives and environmental and visual impact controls.
I therefore request that the Department require substantial design amendments and an independent, receiver-based reassessment of visual impacts prior to any determination of SSD-80211463.
Yours sincerely,

Joanna Bridle
Unit 17, 1–5 Rosebank Street
Darlinghurst NSW 2010