I wish to express my concerns regarding the proposed development and request that the following matters be carefully considered as part of the assessment process.

Firstly, the proposed building heights, ranging from approximately 58 metres to 110 metres, introduce significant fire safety considerations during both construction and long-term occupation. Fire suppression and emergency response in very tall buildings remain inherently challenging due to access constraints and the complexity of evacuation procedures. Recent high-rise fire incidents internationally have demonstrated the potential for fires to spread rapidly and result in substantial risks to life and property. Given the scale of the proposed development, it is important that the adequacy of emergency access, evacuation arrangements, and fire-fighting capabilities be thoroughly assessed.

Secondly, the development is expected to generate a substantial increase in traffic movements within the surrounding area. Herbert Street already experiences significant traffic volumes, particularly during peak periods. The addition of three large residential towers is likely to increase congestion, place further pressure on local intersections, and reduce the efficiency of the surrounding road network. Consideration should be given to whether the existing transport infrastructure can adequately accommodate the increased demand generated by the development.

The proposal may also have implications for the operation of nearby healthcare facilities, including the adjacent hospital precinct and Royal North Shore Hospital. Increased traffic congestion and construction-related disruptions may affect access for patients, staff, visitors, service vehicles, and emergency services. Given the importance of maintaining reliable access to critical healthcare infrastructure, the potential impacts on hospital operations and emergency vehicle movements should be carefully evaluated.

In addition, the proposed buildings are expected to result in significant overshadowing of neighbouring residential properties. In particular, residences located at 19–23 Herbert Street may experience a reduction in direct solar access to less than two hours per day. Access to natural sunlight is an important component of residential amenity, contributing to occupant wellbeing, energy efficiency, and overall living conditions. The loss of solar access for affected residents should be given careful consideration in determining whether the proposal achieves an appropriate balance between development outcomes and neighbourhood amenity.

For the reasons outlined above, I object to the proposal in its current form. The proposed building heights are excessive and result in significant impacts on traffic, solar access, and the surrounding community, including nearby critical healthcare infrastructure. I respectfully request that the proposal be revised to reduce the height and scale of the buildings and better minimise these impacts before any approval is granted.

Submission in Objection to Proposed Development
33–37 Herbert Street, St Leonards (SSD-88511459)

Date: 13/6/26

Re: Objection to Proposed Mixed-Use Development at 33–37 Herbert Street, St Leonards
I am writing to formally object to the proposed mixed-use development at 33–37 Herbert Street, St Leonards.
As a long-term resident of Dalleys Road, Naremburn, I have serious concerns regarding the scale of the proposal and its impacts on local traffic, infrastructure, residential amenity, neighbourhood character and overall quality of life for existing residents.

Traffic, Access and Parking
The proposal includes approximately 413 dwellings and 377 parking spaces, which will generate a substantial increase in vehicle movements throughout the surrounding road network. Herbert Street already experiences significant congestion during peak periods, and any increase in traffic will inevitably affect surrounding local streets, particularly Ella Street and Dalleys Road.
Ella Street already experiences lengthy queues on weekdays due to vehicles attempting to turn onto Herbert Street. Traffic regularly backs up beyond the nearby park during peak periods. The road is not designed to accommodate the level of traffic associated with a development of this scale.
Particular concern exists regarding the intersection of Herbert Street and Ella Street and the bridge crossing over the railway corridor towards Dalleys Road. The bridge is narrow, has a pedestrian footpath on only one side, and provides limited capacity for larger vehicles. Two trucks cannot comfortably pass each other on the bridge, creating both traffic and safety concerns.
There is also no dedicated pedestrian crossing providing safe access between the bridge, the footpath and Dalleys Road. Existing pedestrian infrastructure is already inadequate and will become increasingly strained as population density increases.
The proposal relies on a single vehicular access point from Herbert Street, concentrating traffic into one location and increasing the risk of congestion and delays.
Dalleys Road is also likely to experience increased impacts. The existing traffic-calming devices already create bottlenecks and delays for local traffic, particularly during afternoon peak periods. Additional traffic generated during both construction and operation of the development will place further pressure on a road network that is already struggling to cope.
The cumulative impact of existing congestion, nearby developments and this proposal has not been adequately addressed.
Parking is another significant concern. Streets throughout Naremburn and St Leonards are already heavily utilised by hospital staff and visitors seeking unrestricted parking. Residents regularly experience difficulty finding available parking near their homes.
The proposal does not adequately address where construction workers associated with a project of this scale will park during the estimated four-year construction period. Without a comprehensive construction parking management strategy, surrounding residential streets are likely to experience even greater parking pressure.

Scale, Character and Visual Impact
The proposed tower of up to 39 storeys represents a dramatic and inappropriate increase in scale compared with surrounding areas.
While the broader St Leonards precinct is evolving, nearby parts of Naremburn remain characterised by lower-scale residential development. The proposal fails to provide an appropriate transition between these neighbourhoods and the emerging high-density areas.
The bulk and height of the building will dominate the surrounding environment and significantly alter the visual character of the area. The development will create an overbearing presence when viewed from surrounding streets, homes and public spaces.
It is also notable that neighbouring properties surrounding the site are predominantly commercially zoned. Despite this, the proposal introduces a substantial residential population without adequately addressing how such a large residential development will integrate with the existing commercial context.

Overshadowing and Loss of Amenity
The Environmental Impact Statement acknowledges overshadowing impacts on surrounding properties. These impacts will result in reduced access to natural light, diminished solar access and future opportunity during winter months and a decline in overall residential amenity for neighbouring residents.
The practical effects of overshadowing should not be underestimated. In addition to affecting living areas and private open spaces, increased shadowing will impact established gardens and landscaping. In my case, an existing vegetable garden relies on direct sunlight and is likely to be significantly affected by the proposed building height.
The loss of sunlight will reduce the usability and enjoyment of private outdoor spaces and negatively affect the quality of life of surrounding residents.

Infrastructure Capacity
The proposal seeks to introduce more than 400 additional dwellings without a corresponding commitment to significant infrastructure upgrades.
Local infrastructure is already under pressure, including roads, schools, childcare facilities, public open space, health services and retail facilities. Local supermarkets already experience parking shortages and high demand. Additional population growth will further strain these services.
While proximity to public transport is frequently cited as a benefit, this alone does not remove the need for adequate supporting infrastructure.

Failure to Deliver Intended Housing Outcomes
A key justification for increased density within the St Leonards precinct has been the delivery of housing close to major employment centres, particularly the nearby hospital precinct.
Residents have been repeatedly advised that rezoning would assist in providing more accessible and affordable housing for essential workers. However, this proposal appears to be primarily another large residential development with only a limited affordable housing component.
Approximately 46 affordable housing units are proposed, representing around 10 per cent of the development, and these are only guaranteed for a limited period. This is a modest outcome given the scale of the project and the impacts imposed on the surrounding community.
The affordable housing provision is unlikely to meaningfully address the accommodation needs of hospital workers or deliver the broader housing outcomes that were used to justify increased density within the precinct.

Construction Impacts
The construction period is expected to extend for more than four years following excavation works.
During this period residents will be exposed to significant noise, vibration, dust, heavy vehicle movements and ongoing disruption to local access and amenity.
Construction traffic will place further pressure on already congested roads and create additional safety concerns for pedestrians and local residents. Access to nearby hospital facilities may also be affected during key stages of the project.
Site Constraints and Cumulative Impacts
The site is constrained by major stormwater infrastructure, proximity to the rail corridor and identified flooding risks within parts of the site. These factors raise questions regarding the suitability of such an intensive development in this location.
In addition, numerous large-scale developments are already proposed or underway throughout St Leonards and Crows Nest. While each development may appear acceptable when assessed individually, the cumulative impacts on roads, intersections, transport services and community infrastructure are substantial.
The combined effect of these developments has not been adequately considered and raises concerns about whether the area can sustainably accommodate this level of growth.

Conclusion
While I support the need for additional housing and sensible urban renewal, I believe this proposal represents an overdevelopment of the site and fails to adequately respond to local conditions, infrastructure limitations and community impacts.
The proposed height, density and scale are excessive and will result in significant long-term impacts on surrounding residents through increased traffic congestion, parking shortages, overshadowing, loss of amenity and pressure on already constrained infrastructure.
I respectfully request that the application be refused or substantially revised to:
• Reduce the height and overall scale of the development
• Improve traffic, access and parking arrangements
• Provide greater infrastructure contributions
• Deliver a substantially larger and permanent affordable housing component for hospital staff and other essential workers
• Better respond to the surrounding residential and commercial context.

Thank you for considering this submission.
Yours sincerely,
Resident of Dalleys Road
Naremburn

I am writing as a local resident to formally lodge my strong objection to the proposed development application (SSD-88511459) at 33-37 Herbert Street, St Leonards.
As a resident in the immediate vicinity, I have serious concerns regarding the scale and the negative impacts this development will bring to our community. My specific objections are detailed below:
1. Neighbourhood Character and Site Overdevelopment:
The proposed two towers are completely out of proportion with the existing surrounding properties. At over 28 levels, the taller tower is more than twice the height of neighboring buildings, such as Herbert Towers (13 levels). The excessive building footprint leaves almost no room for open space or landscaping, representing a severe overdevelopment of the site.
2. Loss of Amenity and Privacy:
The height and design of the proposed structures will directly overlook the private living and dining areas of neighboring residents, causing a significant loss of privacy. Furthermore, the towers will cast severe shadows, drastically reducing natural light to our homes, balconies, and sunrooms. The mixture of residential and commercial use will also generate excessive traffic and late-night noise, disrupting the peace of our neighborhood.
3. Traffic Congestion and Public Safety:
The site is adjacent to Westbourne Street, which serves as the critical access route to the Birth Unit at Royal North Shore Hospital (RNSH). Adding approximately 400 residential units on this main road is highly irresponsible. The resulting traffic surge could cause dangerous delays and immense stress for expectant mothers on their way to the hospital. It will also compromise the safety of pedestrians, particularly the numerous staff members from RNSH, SBS, and Australia Post who commute through this area daily.
4. Inadequate Infrastructure and Parking:
The current plans do not provide sufficient on-site parking, which will inevitably lead to severe congestion and competition for street parking. Additionally, there are major concerns that the sheer scale of this development will overload our local stormwater, sewage, and utility systems.
For the reasons stated above, I urge you to reject this development application in its current form to protect the safety, privacy, and well-being of the St Leonards community.那

The overshadowing to housing in Naremburn will be significant. The amenity and visual impact is huge and in no way within keeping of the visual landscape of the area. The parking for an already congested area will remove parking for local residents - some of whom have no other parking options than on street parking. There is no provision for schooling to accommodate the size and scale of the development - children now need to attend school in Mosman because there is no school spots left in the local area. It does not adhere to the height Zoning in the area nor the crows nest TOD principles.

I object to the above Development Application and respectfully request that the application be refused in its current form.
While I acknowledge the need for appropriate housing growth, development must occur in a manner that is consistent with the planning controls, neighbourhood character, and amenity of the St Leonards area that borders on Naremburn, as well as that of the wider Willoughby local government area.
My objections are outlined below.
1. Unacceptable Overshadowing and Loss of Residential Amenity
The proposed high-rise development will result in significant overshadowing of surrounding residential properties and private open spaces.
The scale and height of the building will reduce access to natural sunlight for neighbouring dwellings, gardens, balconies and outdoor recreation areas. This loss of solar access will adversely affect the enjoyment, comfort, energy efficiency and liveability of nearby homes.
Willoughby's planning framework places considerable importance on maintaining residential amenity and managing impacts such as overshadowing and overlooking. The proposal fails to adequately protect existing residents' amenity and exposes residents to overshadowing and privacy invasion; it does not provide good planning outcomes.
The reduction in sunlight access is particularly concerning given the established low and medium-density residential character of Naremburn, some of which is heritage listed, where access to sunlight and open space forms an important part of the area's amenity and appeal.
2. Excessive Height, Bulk and Scale
The proposed development is excessive in height and bulk when compared with the surrounding buildings. The thirty-nine storey twin towers are clearly much higher than existing buildings and contravene the vision for the Crows Nest TOD precinct. The building does not meet agreed transition heights from the highest transition on the Pacific Highway to the lower rise residential area to the north of the highway and especially the heritage area that borders on Henry Lane.
Rather than integrating with the existing streetscape, the development would dominate neighbouring properties and create a visually intrusive presence. The proposal is out of proportion with the prevailing character of the locality and would fundamentally alter the established scale of development within the surrounding area. A building this height should be confined to the area south of the Pacific Highway.
Willoughby planning controls seek to ensure that development responds appropriately to its context and does not overwhelm adjoining properties. The proposal fails this test and would result in an overdevelopment of the site.
3. Adverse Impact on Neighbourhood Character
The bordering area of Naremburn is characterised by a mix of heritage buildings, detached dwellings, medium-density housing and a leafy residential streetscape. The proposed development is inconsistent with these defining characteristics.
The height and mass of the building would diminish the existing character of the area and erode the visual qualities that make Naremburn a desirable residential suburb.
This proposal would not contribute to the positive characteristics of the area as it is overbearing and intrusive in the streetscape and for neighbouring properties.
4. Traffic and Parking Impacts
The proposal will place additional pressure on an already constrained local road network,(not to mention other unseen services such as sewerage and water pipes that are regulaly bursting and leaking in this area as it is).
The increased number of residents, visitors, service vehicles and deliveries will inevitably generate additional traffic movements, leading to further congestion on local streets and nearby intersections.
There is also a substantial risk that on-site parking provision will not adequately accommodate demand. Any overflow parking will increase competition for limited on-street parking and negatively affect existing residents.
The cumulative impact of additional traffic, vehicle manoeuvring and parking demand has not been satisfactorily addressed and is likely to reduce safety, accessibility and convenience within the local area.
5. Inconsistency with the Objectives of the LEP and DCP
The proposal appears inconsistent with the intent of the Willoughby Local Environmental Plan and Willoughby Development Control Plan. It is clearly outside the Crows Nest TOD Rezoning area, will dwarf all existing buildings in the area and detrimentally affect homes in the neighbouring area, including my own. The application is offensive regarding:
• Building height and scale
• Residential amenity
• Solar access and overshadowing
• Streetscape character
• Visual impact
• Context and neighbourhood character
Planning controls exist to provide certainty for both residents and developers. Approving a development that exceeds or undermines these controls would weaken the integrity of the planning framework and create uncertainty regarding future development outcomes.
6. Undesirable Planning Precedent
Approval of this application would establish an undesirable precedent for future developments in Naremburn and across the Willoughby local government area.
Future applicants would inevitably rely upon this approval to justify additional departures from established planning controls, resulting in increasing pressure for greater building heights and densities in locations where such development is inappropriate.
Approving this development that would effectively undermine the strategic planning objectives that have been developed through extensive community consultation and planning assessment.
7. Visual Impact and Streetscape Dominance
The proposal would create a visually dominant structure that is inconsistent with the established character of the surrounding area.
The building's scale, height and appearance would significantly alter important views, streetscape qualities and the human scale of the neighbourhood.
The development would be highly visible from surrounding streets and residential properties and would present as an overbearing built form that detracts from the existing visual character of Naremburn.
Conclusion
For the reasons outlined above, I respectfully submit that the proposal represents an overdevelopment of the site and would result in unacceptable impacts on surrounding residents and the broader community.
The development would:
• Create unreasonable overshadowing and loss of solar access;
• Adversely affect residential amenity;
• Increase traffic congestion and parking demand;
• Conflict with the objectives and intent of the Willoughby planning controls;
• Establish an undesirable planning precedent; and
• Result in a visually dominant and out-of-character building that diminishes neighbourhood character.
I therefore request that the application be refused in its current for, and not approved in any amended form that does not accord with the design principles of the Cros Nest TOD where developments must transition in in height bulk and scale from the Pacific Highway to the surrounding neighbourhood.

1. This proposal is in contrast to the design principles of the Crows Nest TOD.
2. The direct overshadowing and loss of privacy for me as a resident of Dalleys Rd is extreme and unacceptable
3. Traffic and congestion along Herbert St and Ella St is already extensive and this development will exacerbate this
4. The height of the building represents a major extension on existing high rises and is completely out of character of neighbouring three story restrictions dwarfing local homes and buildings.

I write to submit an objection to the proposed development at 33-37 Herbert St; St Leonards. I consider that the proposed development is a poor fit for the existing area, and is not aligned with the wider planning approach for development in the St Leonards area.

The proposed site is outside the TOD rezoning precinct, in the corner of the investigation area of the 2020 Crows Nest and St Leonards Planning package. The developer recognises that the application is outside the area of the TOD rezoning precinct, stating within the Scoping Study that it “aligns with the strategic vision of the St Leonards/Crows Nest TOD”. It may be debatable whether it aligns with the strategic vision, but it does not align with the location of the revised planning requirements More importantly, a project of this scope was not included in much of the assessment that was undertaken in support of the TOD.

The TOD is an important reference point, as the work undertaken at the time included consideration of amenity and transport use and corridors, alongside the impact of the wider community. As such, positioning a large development outside of this zone undermines the credibility of this work, and the capability of infrastructure to support the proposed development alongside those already specified in detail in the TOD.

Specifically, Dalleys Rd is the main avenue for the throughput for traffic from the Artarmon area to Crows Nest, as well as towards the M1 via Merreburn Avenue. Willoughby Council is attempting to maintain the community and pedestrian friendly nature of this street (which includes frontage onto important green space through Naremburn Park) through the usage of traffic calming measures.

The introduction of this new development will make the maintaining of traffic flows on this street difficult to the point of impossibility. Considering that much of this street is outside not only the TOD, but even the 2020 study area the application should directly consider how local amenity will be maintained consistent with such a large development.

The choice of location outside of the TOD is also at the edge of the existing mixed use zone from Herbert St from St Leonards Station. This is the transition point between mid-rise housing, industrial estate and low rise housing/green space. The TOD’s outline of expectation for a trend of heights that is highest at the station, and downwards towards stand alone houses is in contradiction with this application.

Building 1 in particular would exceed the existing height of all the buildings from the St Leonards Forum down Herbert St, creating an imposing edifice that does not transition to the low density industrial areas on the other side of Ella St and Herbert St, not to mention the housing on the other side of the train line. Height for the proposal should be consistent with nearby buildings, and not anchored to the developments directly on Pacific Highway, or above the Crows Nest metro station (all of which are within the TOD).

Thank you for the opportunity to make this submission, and I reiterate that the proposed development is a poor fit for the site, that does not align with the nearby residents as well as undermining the TOD for increased densification near transport hubs.

I wish to lodge an objection to the proposed State Significant Development (SSD) at 33–37 Herbert Street, St Leonards.

I support the need for additional housing in Sydney and recognise that higher-density development has an important role to play in well-located areas. However, development must be appropriately located, consistent with adopted planning frameworks, and designed to balance housing delivery with the protection of local amenity and infrastructure capacity. In its current form, this proposal fails to achieve that balance.

#1. Inconsistent with the Strategic Planning Framework for the Area

The proposal seeks approval for a 39-storey twin-tower development on a site that is outside the core high-rise area envisaged under the recently adopted Crows Nest Transit-Oriented Development (TOD) planning framework.

The Crows Nest TOD Precinct Design Guide establishes a clear principle that the highest-density development should be concentrated around the St Leonards and Crows Nest centres and transition down in height, bulk and scale toward surrounding residential neighbourhoods. The proposal site sits beyond the primary high-rise spine along the Pacific Highway and is separated from the intended high-rise precinct.

Approving a 39-storey tower in this location would undermine the carefully planned height transition strategy that formed part of extensive community consultation and planning work. It would create an isolated high-rise development that is inconsistent with the intended urban structure for the precinct.

#2. Excessive Height and Visual Impact

The proposed development would significantly exceed the scale of surrounding buildings and become the tallest building in the immediate vicinity.

The visual impact of a 39-storey tower in this location would be substantial. Rather than reinforcing the established skyline around the St Leonards commercial centre, the proposal would extend high-rise development further north into a lower-scale residential area. This would alter important local views and create an intrusive visual presence that is out of character with the surrounding neighbourhood.

The proposal represents a significant expansion of the high-rise residential core rather than an orderly transition from it. Such an outcome would set an undesirable precedent for future proposals seeking similar departures from the adopted planning framework.

#3. Overshadowing and Loss of Residential Amenity

The proposal would generate significant overshadowing impacts on surrounding residential properties.

Access to sunlight is a fundamental component of residential amenity. The shadow diagrams referenced in the exhibition material indicate a substantial loss of solar access to neighbouring properties. Increased overshadowing will affect outdoor spaces, gardens and living areas, reducing the quality of life for existing residents.

Given the scale of the proposed towers and their location adjacent to established residential areas, the overshadowing impacts appear disproportionate and inconsistent with good urban design outcomes.

#4. Privacy and Overlooking Impacts

The proposed building height and proximity to surrounding residential properties will create significant overlooking and privacy concerns.

A development of this scale will introduce direct views into nearby homes and private open spaces from numerous levels across the towers. This will diminish privacy for existing residents and fundamentally change the residential character of the surrounding area.

The scale of these impacts is difficult to reconcile with the objective of ensuring that new development contributes positively to local amenity.

#5. Traffic, Parking and Infrastructure Impacts

The proposal includes approximately 413 additional dwellings while providing only 322 residential parking spaces.

This shortfall is likely to increase demand for on-street parking in surrounding residential streets. Herbert Street, Ella Street, Reserve Road and nearby local roads already experience congestion and parking pressures. Introducing hundreds of additional dwellings without sufficient parking provision is likely to exacerbate these existing issues.

More broadly, the proposal would introduce a substantial increase in population without clear evidence that supporting local infrastructure has the capacity to accommodate growth of this scale. Local schools are already experiencing enrolment pressures, and the addition of hundreds of new dwellings is likely to place further demand on both primary and secondary education facilities.

Similarly, the surrounding road network is already heavily utilised, particularly during peak periods. Additional residents will place greater pressure on roads, intersections, pedestrian infrastructure, public transport access points and local community facilities.

While increased housing supply is important, it should be coordinated with the timely provision of supporting infrastructure. Development of this scale should not proceed without demonstrating that local schools, transport networks and community infrastructure can adequately support the resulting population growth.

#6. Unacceptable Planning Precedent

Approval of this development would establish a precedent for similarly scaled developments outside the intended high-rise zone.

One of the key purposes of strategic planning is to provide certainty regarding where growth should occur and what form that growth should take. If a development of this magnitude is approved outside the designated TOD high-rise core, it will become increasingly difficult to resist similar proposals elsewhere, undermining confidence in the planning framework and the extensive consultation that informed it.

The cumulative effect of such precedents could fundamentally alter the character of surrounding residential neighbourhoods in a manner never contemplated by the adopted precinct planning.

#7. Circumvention of Local Planning Controls

I am concerned that the use of the SSD pathway in this instance effectively bypasses local planning controls and previously expressed planning outcomes.

According to publicly available information, less intensive development proposals for the site were previously rejected. The SSD process should not be used to override carefully considered local planning controls without a compelling strategic justification.

Where local councils and strategic planning frameworks have established clear expectations regarding building height, scale, transition and character, these considerations should continue to carry substantial weight in the assessment process.

#Conclusion

While I support increased housing supply and recognise the importance of transit-oriented development, this proposal is in the wrong location and at the wrong scale.

The proposed 39-storey twin-tower development:

• Is inconsistent with the planned height transition principles of the Crows Nest TOD framework.
• Creates excessive visual impacts and is out of scale with the surrounding area.
• Results in significant overshadowing and privacy impacts on nearby residents.
• Exacerbates existing traffic and parking pressures.
• Places additional strain on local schools, roads and community infrastructure.
• Establishes an undesirable precedent for further high-rise expansion outside the intended precinct core.
• Undermines confidence in the strategic planning process and local planning controls.

For these reasons, I respectfully request that the Department refuse the application in its current form. At a minimum, the proposal should be substantially reduced in height and scale to better align with the adopted planning framework, surrounding context and infrastructure capacity.

Thank you for considering this submission.

To the Department of Planning, Housing and Infrastructure,

I am the owner and resident of an apartment within Block D of 15A Herbert Street, Naremburn, which sits opposite the proposed development at 33–37 Herbert Street, St Leonards, across the rail corridor.

I object to the proposal in its current form and request that the Department require substantial design modifications before granting approval.

1. Significant Loss of Sunlight and Residential Amenity

My primary concern is the substantial loss of natural light that the proposed development will cause to apartments within Block C and D of 15A Herbert Street.

The existing apartments have benefited from access to sunlight and daylight since their construction in the 1990s. Based on the height, scale and positioning of the proposed towers, it appears that a significant proportion, if not all, of this natural light will be blocked once the development is completed.

Access to sunlight is a fundamental component of residential amenity. Reduced daylight impacts residents’ wellbeing, enjoyment of their homes, energy consumption and overall quality of life. The proposal appears to place an unreasonable burden on existing residents in order to maximise development yield on the site.

I request that the Department carefully review the overshadowing impacts on neighbouring properties and require a design outcome that better protects access to sunlight for existing residents.

2. Alternative Design Solutions Are Available

I do not oppose redevelopment of the site in principle. However, I believe there are reasonable alternative design solutions that would significantly reduce impacts on neighbouring residents.

These include:

* Relocating the tallest tower elements further north along Herbert Street to increase separation from existing residential buildings at 15A Herbert Street, particularly noting there is no housing past 15A Herbert St.
* Introducing greater spacing between tower elements to allow sunlight penetration and maintain visual corridors.
* Reducing tower bulk and massing where it directly interfaces with neighbouring residential premises.

The current design appears to prioritise development intensity over the protection of existing residential amenity. A revised design should seek a more balanced outcome.

3. Excessive Bulk and Scale

The proposal’s scale and massing will have a significant impact on surrounding residential properties.

The cumulative effect of the tower height, building bulk and proximity to neighbouring apartments will create an overbearing built form that is inconsistent with maintaining reasonable levels of amenity for existing residents.

The Department should require a design that better balances increased housing supply with the legitimate expectations of existing residents who have occupied neighbouring properties for decades.

4. Extended Construction Impacts

The documentation indicates a construction period exceeding four years.

This represents an exceptionally long period of disruption for surrounding residents. Residents will be subjected to:

* Construction noise and vibration;
* Dust and air quality impacts;
* Traffic and access disruptions;
* Reduced enjoyment of their homes and surrounding public spaces; and
* Ongoing disturbance over an extended period.

I am particularly concerned that construction activities are proposed not only during weekdays but also on Saturdays between 8:00am and 3:00pm.

For nearby residents, weekends are often the only opportunity to enjoy their homes without work commitments. Regular Saturday construction over a period of more than four years will significantly diminish residential amenity and quality of life.

If the project is approved, the Department should impose strict conditions to minimise construction impacts and ensure residents are adequately protected throughout the construction period.

Conclusion

While I support the need for additional housing in appropriate locations, I do not believe the current proposal achieves an appropriate balance between development outcomes and the protection of existing residential amenity.

I respectfully request that the Department:

1. Refuse the proposal in its current form; or
2. Require substantial design amendments that:
* Reduce overshadowing impacts on 15A Herbert Street;
* Improve tower separation and sunlight access;
* Reposition tower elements further north on the site;
* Reduce bulk and scale adjacent to existing residential buildings; and
* Strengthen measures to minimise construction impacts on neighbouring residents.

Thank you for considering my submission.

Dear Mr Keiran Thomas,

I am sorry I have re-submit this as I have to re-arrange the order of importance underneath, my apologies.

I have been a resident in Herbert Tower A, 19-23 Herbert Street over 20 years. The location of Herbert Tower A is right next to 33-37 Herbert Street, St Leonards (“the Site”). I set out below my objections based on the following grounds:

1 Traffic and infrastructure
- Traffic congestion and safety: As 33-37 Herbert Street is right next to Westbourne Street which leads up to the Birth Unit in the Royal North Shore Hospital, it is totally irresponsible to build another 400 units on a main road that leads to the Birth unit of a major hospital (map is attached for ease of reference). This development could cause dangerous traffic increases and enormous stress and delay for mothers on way to the Birth Unit. Furthermore, this could create negative impact on pedestrian safety especially for staff from RNSH, SBS, Australia Post and other commercial units nearby and this was recognised and implemented by NSW Transport for Herbert Street to be a 40K Zone area.
- Insufficient parking: The plans do not provide adequate on-site parking and this could lead to congestion for street parking.
- Drainage and infrastructure: There are major concerns that the development will overload the local stormwater, sewage or utility systems etc.

2 Residential Amenity
- Overlooking and loss of privacy: Balconies or upper-story windows of the Site look directly into private dining living spaces of Herbert Tower A.
- Overshadowing: The new structure will cast shadows on Herbert Tower A, reducing natural light into our home or outdoor areas eg balconies and sunrooms.
- Noise and disturbance: The proposed use residential/commercial will generate excessive traffic, noise and late-night activities and will jeopardise the tranquillity of Herbert Street.

3 Neighbourhood Character and Design
- Visual bulk and scale: The 2 towers (“the Site”) are out of proportion with the neighbouring properties on Herbert Street – the taller Tower (right next to Herbert Tower A) has over 28 levels which is twice the heights of Herbert Towers A and B (13 Levels).
- Site overdevelopment: The footprint of the Site takes up too much of the block, leaving little room for open space and landscaping right next to the neighbouring property i.e. Herbert Towers at 19-23 Herbert Street.

Suggestions:

(a) Open space:
A semi-private courtyard in the size of at least 20 sqm be built between the Site and Herbert Tower A in order to create more open space and reduce density in the area. I attach 2 photos of the latest design from their developer – showing a big courtyard being placed between their 2 towers. I would suggest that they swap the courtyard to be placed in between the Site and Herbert Tower A to create more space and light for the neighbouring residents in Herbert Tower A.

(b) Heights:
In order to reduce the density in the area, the heights of the 2 towers should be restricted to similar heights as the existing buildings.

(c) On-site parking:
On-site parking within the Site should be built and made available to all residents in the Site. 2 levels of underground parking should be built which is the same as Herbert Towers. In this way, the Site will not overtake the heights of the nearby buildings.

(d) Commercial Use:
This should be restricted as this could create excessive traffic, noise and late-night activities.

I also attach photos and map for ease of reference.

Thank you very much for your precious time and kind attention to the above.

Kindest regards
Christina Chiu