I object to this development proposal for many reasons which I will outline below.
 
It is just way too big! The scale and bulk of the proposed development are completely inappropriate for its setting. It proposes to take up every bit of the site without adding anything to local amenities or general community good that might offset the loss of existing affordable housing or the unwelcome intrusiveness of the building. It overshadows public open space on Oxford Street and the residences that are around it. It’s all about taking away from the community for the profit of developers. Its social and environmental impact is both negative and destructive.
 
 
The proposed development violates the principles and values of the Paddington Heritage Conservation Area. People have fought hard over the years to save the demolition of Paddington’s unique environment. This heritage protection has been valued and admired since. People are grateful for it. The importance of the site of the proposed development to the history of white settlement in Paddington has been well documented. Most importantly the site has provided accommodation to those considered essential workers on local projects, be they building Paddington Barracks or staffing the local hospital.
 
Paddington does not need more luxury accommodation for wealthy people - there is plenty of that already.  Nor do we need any more shops - so many of those are already empty. But we do urgently need to increase and maintain existing affordable housing for those who work in the area. This ought to be the main priority for any development within this important heritage area. Indeed, it should be the priority for any government approval or support for any of the State Significant Development projects.
 
The proposed development decreases the availability of affordable housing in Paddington. It proposes the demolition of 27 affordable units and replaces them with 40 new, mostly luxury ones - including penthouses with rooftop swimming pools. Only 10 affordable housing units are included. In this area these will still be out of reach of most who need it and will revert to regular housing stock after 15 years.  We need permanent affordable and build to rent housing in Paddington.
 
The extensive demolition and excavation work (for the 4 levels of underground parking etc) will take some years and be incredibly intrusive on the local area. Again, the enormous public inconvenience is not offset by anything that the proposal contributes to the community. Given the character and history of Paddington, the proposal just looks ugly and is way out of place. Once it is there the character and unique aesthetic qualities of the area will be forever degraded. It needs to be rejected now.
 

Overall, the proposal represents a well-considered urban infill project that will deliver new housing, including a meaningful proportion of affordable housing, in a highly accessible inner-city location. The development aligns with current NSW Government planning priorities to increase housing supply in well-serviced urban areas while supporting vibrant local centres.

Housing supply and affordability

Sydney continues to face significant housing affordability and supply challenges. The proposal will provide 40 apartments, including 10 affordable dwellings managed by a community housing provider. The inclusion of affordable housing in a well-located inner-city neighbourhood such as Paddington is particularly valuable, as it helps ensure that essential workers and lower-to-moderate income households can access housing close to employment, services and public transport.

Developments that integrate affordable housing within mixed-tenure residential buildings contribute to more inclusive communities and support broader state housing policy objectives.

Appropriate urban infill in a well-located area

The site is located on Oxford Street, a major urban corridor that is well connected to employment centres, public transport, services and cultural institutions. Increasing residential density along such corridors is consistent with metropolitan planning strategies that encourage housing growth in locations with strong infrastructure and accessibility.

Providing additional housing in established urban areas helps reduce pressure for urban sprawl and allows residents to live closer to jobs, healthcare, education and public transport.

Activation of the Oxford Street frontage

The inclusion of ground-floor retail will help strengthen street activity along Oxford Street and contribute to the vitality of the local precinct. Active street frontages encourage pedestrian movement, improve passive surveillance and support local businesses.

Given the long-standing role of Oxford Street as a key urban high street, the introduction of new mixed-use development is appropriate and will help maintain the area’s economic and social vibrancy.

Design response and transition to surrounding context

From the available planning documentation, the proposal appears to incorporate several design elements that respond to the surrounding urban environment, including building setbacks, retention of street trees, and a transition toward neighbouring residential terraces.

Such measures are important given the proximity to heritage areas and the established residential character of surrounding streets. A well-designed contemporary building can coexist with heritage contexts while contributing to the evolution of the urban fabric.

Efficient use of a strategic inner-city site

The redevelopment of underutilised or aging building stock to provide new housing and improved urban outcomes is an appropriate planning outcome for a site of this scale and location. The proposal replaces a collection of older post-war buildings with a more efficient use of land while retaining elements that contribute to the local streetscape.

Urban renewal projects of this nature support the long-term sustainability and functionality of inner-city neighbourhoods.

Conclusion

For these reasons, I support the approval of SSD-97528708. The project will deliver much-needed housing—including affordable housing—activate a key urban street, and make efficient use of a strategically located site within Sydney’s established urban area.

I encourage the Department to support the proposal, subject to appropriate conditions that ensure high design quality and careful management of construction and heritage interfaces.

Thank you for the opportunity to provide a submission on this proposal.

Object strongly as Paddington is a Heritage suburb. The charm & character will be destroyed by unsightly high rise.The narrow streets in Shadford & Gibbs will be congested if this building goes ahead. Not an appropriate site to build & will set a president & destroy the character of Paddington. It will not be affordable housing as only those on very night incomes could effort to rent / buy. Defeats the purpose as 27 units at 160 Oxford st have renters on a low income. The developers are only in it to make big $$ so go some where else not Paddington

Submission regarding SSD-97528708

Dear Sir/Madam,
My family live in Shadforth Street, Paddington .I visit the area weekly and wish to lodge an objection to the developer’s application SSD-97528708.

My family as local residents have direct experience of the area and can provide observations that are not captured in consultant reports. The day-to-day functioning of local streets, businesses and pedestrian activity is best understood by those who live and work here.

My primary concerns relate to the loss of affordable housing, traffic impacts associated with the proposed underground carpark, disruption to local businesses during construction, cumulative infrastructure impacts, and the protection of the Paddington Conservation Area.

Loss of affordable housing

The proposal appears to result in a net loss of affordable housing. At a time when Sydney faces a well-documented housing affordability crisis, reducing affordable housing in an inner-city location close to employment, transport and services is difficult to justify. Development of this scale should prioritise maintaining or increasing affordable housing supply.

Traffic and local street capacity

The traffic impacts appear understated in the application. Streets such as Gipps Street, Shadforth Street and Liverpool Street are narrow nineteenth-century residential streets that were never designed for the traffic volumes associated with a development of this intensity.

For readers unfamiliar with the area, these streets are constrained by parked cars on both sides, narrow carriageways, limited turning space and tight intersections. In practice, many operate as single-lane corridors. Deliveries, waste collection vehicles and ride-share activity already create congestion and safety concerns. Additional traffic from an underground carpark will increase these pressures.

Construction and business impacts

Oxford Street supports many small independent businesses that rely on pedestrian access and consistent street activity. A prolonged construction period risks significant disruption through reduced access, noise, dust and construction staging.

Cumulative impacts

The proposal should also be assessed in the context of other nearby changes, including the Oxford Street cycleway and the potential future redevelopment of Victoria Barracks. These projects will also affect traffic patterns and construction activity. The cumulative impact of multiple changes occurring simultaneously appears insufficiently addressed.

Heritage and character

Paddington’s heritage streetscape and fine-grain urban character are fundamental to its identity. Development within or near the Paddington Conservation Area must respect this scale and character.

For these reasons, I request that the concerns above be carefully considered when assessing SSD-97528708.

Yours sincerely,
Duncan Mathers

To whom it may concern
I object to the project because if this goes ahead there will be a permanent loss of Paddington’s heritage character, Overshadowing and loss of privacy for neighbours, Traffic chaos and parking congestion on local streets and years of severe disruption and heavy construction.

Importantly, it sets irreversible precedent that threatens our historic, low-rise streetscape, opening the floodgates for more high-rises. Many parts of Paddington - even beyond Five Ways - have been rezoned by the new state rules to enable more development.

I object to the proposed development at 160 Oxford Street, Paddington, seeking approval under the ‘infill affordable housing’ provisions of the NSW Housing SEPP.

This proposal is fundamentally incompatible with the heritage, character, and planning principles that have shaped Paddington for generations. It represents a clear overreach of scale and a misuse of planning incentives designed to promote genuine community benefit rather than developer advantage.

Paddington’s unique character is built on proportion, modest scale, and human-centred design.

Paddington is one of Sydney’s most admired suburbs precisely because of its low rise, medium density and heritage consistency. Its value; cultural, economic, architectural, and social comes from the delicate balance between built form and human scale.

This proposal disrupts that balance completely.

An 8-storey luxury apartment tower is vastly out of proportion with the surrounding heritage streetscape. Its bulk, height, and massing would impose itself discordantly on a suburb that has long resisted overdevelopment.

Paddington is sought after because it avoided this very type of excess, thanks to decades of community advocacy and careful planning.

This development replaces genuinely affordable homes with luxury units

It is deeply concerning that 27 older, naturally low-rent studios, which provided truly accessible housing are slated for demolition, only to be replaced with a predominantly luxury apartment block.

The so-called 'affordable housing' component forms only a small fraction of the development and lacks clarity regarding:

depth of affordability

long-term management

whether the community will actually benefit from them

Paddington is losing real affordability to gain a handful of time-limited 'affordable' units, a net loss for low-income residents and key workers.
The majority of units will be luxury apartments not even dressed in the language of affordability.

The proposal attempts to justify a large, oversized, out-of-character building by branding it an ‘infill affordable housing’ project. In reality, all of the units will be high-end, high-priced luxury apartments ( 15% off the market price is not and should not be considered affordable).

Maximising developer profit is not, and should never be, a legitimate objective of the planning system. The role of a government planning department is to safeguard the public interest, not to enable private gain at the expense of heritage, character, or community wellbeing and it is inappropriate for planning incentives to be used in ways that primarily elevate developer returns.

The ‘affordable housing’ component is being used as a planning loophole, allowing the developer to seek additional height and density otherwise prohibited in this location.

Paddington’s streetscape, heritage, and residents should not be sacrificed for a small percentage of non-market units attached to a predominantly commercial, profit-oriented project.

A betrayal of the history of community protection in Paddington

Paddington stands today as a cohesive and human-scaled suburb because unions, communities, heritage advocates, and local residents fought for it during the 1970s and 1980s.

The builders’ labourers, in particular, placed Green Bans on developments that threatened to destroy its character. Those battles are part of the cultural DNA of this suburb.

It is therefore profoundly disappointing to see a Labour government now advancing policies and processes that:

override local planning controls.

enable height and density bonuses.

undermine heritage protections.

prioritise developer interests over community character and history.

The very movement that once defended Paddington from aggressive development is now through poor planning direction putting it at risk again.

This proposal contradicts the values that protected Paddington in the first place.

Heritage conservation must mean something, especially in a suburb like Paddington.

Paddington is one of Australia’s premier heritage conservation areas. Any development here should enhance, not erode, that status.

This project:

protrudes far above the prevailing roofline

visually dominates the streetscape

undermines the established pattern of development

destroys affordable legacy housing without sufficient replacement

brings a heavy, monolithic presence inappropriate in the suburb

A handful of ‘affordable units’ cannot justify the erosion of the heritage and proportion that define Paddington.

Precedent risk – one oversized development becomes a gateway for more

Paddington’s delicate character can be lost not through dozens of developments, but one precedent-setting approval.

Approving this building invites similar proposals along Oxford Street, each citing the same inflated height and scale.

Paddington does not need a creeping skyline. It needs preservation of what already works.

More retail is unnecessary and counterproductive

The proposal includes additional retail space in an area where there has historically been no retail and where many shops remain vacant.

High-rise development belongs in the CBD or appropriate urban zones

If Sydney needs more housing, tall buildings are more appropriate in the CBD or designated high-density areas, not in historic low-rise suburbs.

Given the way work patterns have changed post-pandemic, many office buildings in the city are underutilised. These could be:

Converted into residential units, bringing life to the CBD or, where unsuitable, demolished and rebuilt as modern residential towers

Sydney can accommodate high-density housing without destroying the character of heritage suburbs like Paddington. The choice is clear: reuse and concentrate tall developments in the city, preserve human-scale suburbs outside it.

Planning priority should be genuine affordability, not height trading

If the government’s goal is to increase affordable housing, there are far more responsible, community-aligned ways to do it:

Support purpose-built, modest-scale affordable housing.

Retain and upgrade existing naturally affordable dwellings.

Partner meaningfully with community housing providers on appropriate sites.

Strengthen, not weaken, heritage and scale protections.

Paddington is not the place for planning experiments that trade heritage for speculative construction.

Replicate Paddington’s success elsewhere, do not destroy the suburb that works.

Paddington is consistently recognised as one of Sydney’s most liveable suburbs because it offers:

human-scale buildings

mixed housing typologies

walkable streets

diverse residents and tenures

heritage and identity

a village-like atmosphere in an inner-city setting.

Rather than destroying this model, we should be replicating it in new suburbs across Sydney. Many communities envy Paddington’s charm and livability. The correct response is to build more human-scale, mixed-housing suburbs, not undermine the original.

This development moves Sydney in the opposite direction.

Conclusion:

This development is:

too tall

too dense

out of proportion

destructive to heritage

misleading in its claims

an inappropriate exploitation of affordable-housing provisions

Paddington is a suburb that works. Sydney needs more Paddingtons, high-rise solutions in the CBD, and better use of vacant commercial spaces for housing, not the destruction of an existing low-rise, human-scale, heritage-rich community.

Maximising developer profit has no place in responsible planning, and a government department should not be facilitating outcomes that elevate private returns while eroding long-standing community values, heritage protections, and the public interest.

Paddington remains one of Sydney’s most treasured suburbs because previous governments respected its character and communities fought to protect it. This proposal disregards that legacy, and I urge the Department of Planning to reject the application and urge you to join the fight to save our suburbs.

I strongly urge the Department of Planning to uphold the planning principles, community legacy, and human-scale character that make Paddington a uniquely valuable part of Sydney.

Warm regards,

Niki zubrzycki









Summary of Major Objections

The proposed 8-storey tower is completely out of scale with Paddington’s heritage, human-scale streetscape, and long-established planning principles.

The development demolishes 27 genuinely affordable, naturally low-rent studios and replaces them with predominantly luxury apartments, offering only a minimal and time-limited affordable housing component.

The “affordable housing” label is being used as a planning loophole to secure height and density far beyond what is appropriate for the suburb.

Maximising developer profit is not a legitimate planning objective, and the government should not facilitate private gain at the expense of heritage, character, or community wellbeing.

The project sets a dangerous precedent for further inappropriate high-rise development along Oxford Street.

Additional retail space is unnecessary in an area already characterised by vacant shops.

High-density development is more suitably located in the CBD or designated growth areas, not in historic low-rise suburbs.

The proposal undermines decades of community advocacy, heritage protection, and the unique character that makes Paddington one of Sydney’s most valued neighbourhoods.

Objection to SSD-97528708- 160 Oxford St, Paddington

Paddington has been my home for the past 55 years during which time Paddington has had many changes but most have been made without being detrimental to its heritage and amenity. The proposal to impose of an out of character tall bulky building under the guise of providing “affordable housing” (when in fact it will cause a loss of such housing) should be refused, inter alia for the following reasons:
1. It is located in the most historic part of Paddington and at Paddington’s main entrance detracting from that area and the rest of Paddington whilst the building will be visible from much further away.
2. The attractiveness of Paddington to tourists and shoppers will be reduced thereby affecting the small businesses in the area.
3. Not only while it is being built but then onwards it will cause loss of amenity to the neighbouring old buildings, historic Victoria Barricks and Oxford Street. This loss will include overshadowing, loss of privacy, building damage (eg water table changes, vibration; excavation etc causing cracking of walls), increased traffic in narrow streets, damage to or loss of trees on both sides of Oxford Street.
4. The proposal is gaming the system to avoid the controls Woollahra Council has in place to protect the heritage and amenity of the Paddington HCA. It is a money-making venture giving luxury residences to a few while the neighbouring residents and others will suffer.
5. There is a loss of “affordable housing” as the existing building has 27 small units at lower rents then mostly available in the area whereas there will only be 10 units for 15 years with rents purported to be “affordable”. But this ‘’affordability” is determined on market rental not on occupant’s income so that with market rentals in the inner city area -being high even if discounted they will still not be affordable to workers in service industries such as the nearby medical precinct.
6. The deep excavation for garaging the incoming residents’ cars will affect the underground water flows particularly down the floodplain at bottom of the hill which is already subject to damage from major storms.

I also endorse all the points set out in the objection submitted by The Paddington Society and its recommendation that this proposal be refused. The impact of the proposal on heritage and amenity is far too high for the little, if any net social benefit.
Yours faithfully
Francis Walsh

To Whom It May Concern,

I am writing as a local resident of Paddington to formally object to the Development Application for 160 Oxford Street, Paddington — a proposed 14-level ultra-luxury residential tower with an excavated carpark for 83 cars.

I object on the following grounds:

1. HERITAGE & CHARACTER
Paddington is one of Sydney's most beloved and historically significant neighbourhoods, defined by its Victorian terrace houses, human-scale streetscape, and coherent heritage character. A 14-storey tower at this location would be wholly incompatible with that character. No amount of design merit can reconcile a building of this scale with the low-rise fabric that defines and gives Paddington its identity. Once lost, that character cannot be recovered.

Sydney has too often seen this story play out — neighbourhoods that were once distinctive and cherished, diminished by developments that are completely out of place and out of character with their surroundings. We have watched it happen across the city and the community of Paddington is asking that we not repeat that mistake here.

2. PRECEDENT FOR FURTHER OVERDEVELOPMENT
This is perhaps my greatest concern. Approving this development would set an irreversible precedent, effectively signalling that Paddington's heritage streetscape is open to high-rise development wherever an applicant can claim the affordable housing bonus. With large parts of the suburb already rezoned under new state rules, approval here could open the floodgates to a wave of similar proposals that would fundamentally and permanently transform the neighbourhood. The community deserves assurance that planning decisions consider cumulative impact, not just individual applications in isolation.

3. TRAFFIC & PARKING
Oxford Street and the surrounding local streets already experience significant congestion. An excavated carpark servicing a luxury high-rise will generate substantial additional vehicle movements, with construction traffic adding years of severe disruption to residents, pedestrians, and businesses. The local road network is simply not equipped to absorb this.

I urge the Department to give genuine weight to community concerns and reject this application. I ask that this submission be recorded and considered as part of the formal assessment process.

Yours sincerely,
Nick Oxby, 40 Hopewell St Paddington

FORMAL OBJECTION
SSD-97528708 — Mixed-Use Development (Infill Affordable Housing)
148-160 Oxford Street, 6 Shadforth Street and 13 Gipps Street, Paddington NSW 2021

I formally object to State Significant Development Application SSD-97528708. I am the owner-occupier of a heritage terrace in Paddington, within metres of the proposed site.

My objection rests on four grounds, the first two of which I do not believe other submissions will raise, and each of which is individually sufficient for refusal.

GROUND 1: THIS APPROVAL WOULD CREATE SYSTEMIC RISK ACROSS PRIVATE MORTGAGE MARKETS
Paddington's Heritage Conservation Area designation is not a planning abstraction. It is the underwriting basis for billions of dollars in mortgage debt secured against approximately 7,000 properties. Banks do not lend on Paddington terraces in spite of their heritage status; they lend because of it. Every valuation, every loan-to-value ratio, and every insurance premium in this suburb is premised on the State's implicit covenant that heritage character will be preserved. If the Infill Affordable Housing provisions can override that covenant here, opposite Victoria Barracks and in the heart of Little Paddington Village, they can override it on every comparably zoned parcel in the suburb. The moment that signal reaches the market, valuations will reprice across thousands of properties.

I ask directly: has the Department sought advice from APRA or the RBA on this systemic exposure? Has it modelled the effect on mortgage instruments secured against Paddington's heritage stock if this precedent is set? These are not rhetorical questions. They must be answered before this application can be lawfully assessed.

GROUND 2: THIS DECISION WOULD ERODE THE STATE'S OWN TAX REVENUE AND COUNCIL RATE BASE
Council rates across Paddington are assessed against land values. NSW land tax is assessed against land values. Both are directly sustained by the heritage framework that this approval would fatally compromise. The Department is therefore not being asked to make a planning decision in isolation. It is being asked to make a decision that would, as a foreseeable consequence, reduce the revenue of both the Council of the City of Sydney and the NSW Office of State Revenue across an entire suburb, in perpetuity.

The State would be destroying its own tax base to deliver a windfall profit to a single developer. Has the Department sought advice from the NSW Valuer-General or Treasury on this exposure? If not, the assessment is materially incomplete.

GROUND 3: AFFORDABLE HOUSING LEGISLATION CANNOT LAWFULLY BE USED TO DESTROY AFFORDABLE HOUSING
The site currently provides 32 genuinely affordable dwellings. This proposal replaces them with 12 token units and 32+ luxury apartments, representing a 55% net reduction in affordable housing delivered under affordable housing legislation. The Infill Affordable Housing provisions exist to increase affordable supply, not to demolish it. An approval premised on the contrary interpretation is legally indefensible and would not survive judicial review.

GROUND 4: THE STATE CANNOT REPUDIATE A PROMISE IT HAS ALREADY CASHED
The NSW Government created the Paddington Heritage Conservation Area. It has since collected stamp duty, land tax, and Council rates, all calculated against values the heritage designation created. Buyers, including me, have purchased in direct reliance on the State's representation that this protection is durable. The State cannot now deploy a separate legislative instrument to demolish the protections it sold to the public as permanent, without acknowledgement, without compensation, and without any strategic assessment of the cumulative impact on the suburb. To do so would expose this decision to legal challenge and would represent a fundamental breach of the public trust the heritage framework was designed to maintain.

REQUESTED OUTCOME
I request that SSD-97528708 be refused. I further request that before any application on this site proceeds, the Department commission a suburb-wide strategic heritage assessment of the cumulative effect of the Infill Affordable Housing provisions on the Paddington Heritage Conservation Area, and seek independent advice from the NSW Valuer-General and Treasury on the revenue consequences of the precedent this decision would set.

Paddington's heritage was a promise made in law. I am asking the Department to keep it.

I expressly reserve all rights to seek judicial review of any decision to approve this application, and to pursue any other legal remedies available to me as an affected landowner.

Please accept this letter as my objection to the proposed development at 160 Oxford
St Paddington, SSD-97528708
I have lived in Paddington 26 years and currently reside with my husband and 2 children. My
children (19 and 17 years old) have lived their whole lives in Paddington.
While I appreciate the need for urban renewal and investment along Oxford Street, I believe
this proposal, at eight storeys above ground and four levels of basement parking, represents
overdevelopment that will have significant and irreversible impacts on the amenity,
character, and infrastructure of the surrounding heritage neighbourhood.
1. Excessive Height and Scale
The proposed eight-storey height is wholly inconsistent with the existing built form of
Paddington, which is defined by two- to four-storey terraces and heritage shopfronts. The
bulk and mass of this proposal will dominate the streetscape, overshadow nearby properties,
and visually overpower the fine-grained character of Oxford Street, Shadforth Street, Gipps
Street, Liverpool Street and Glenmore Road.
2. Overdevelopment and Density
The inclusion of 40 apartments on this site indicates an excessive residential density, far
beyond what the local infrastructure and road network can reasonably support. This intensity
of development is irreconcilable with the established character of Paddington, a recognised
Heritage Conservation Area, and risks undermining the area’s distinct architectural and social
identity.
Given that Toohey Miller has experience in large-scale commercial projects, the decision
to propose 8 storeys in this heritage conservation area appears more yield-driven than
context-sensitive.
3. Inadequate Infrastructure and Traffic Impacts
The proposed four-storey underground car park containing 83 spaces will generate substantial
traffic along Oxford Street and surrounding laneways. The current street network and
intersections are already congested, particularly during peak hours. The excavation and
operation of a basement of this scale may also cause structural vibration, noise, and safety
risks for adjacent heritage buildings. I save personally seen many cars hit wing mirrors and
small delivery trucks get stuck in those streets. I just don’t see how it could accommodate
such increased traffic.
4. Excessive excavation
I am deeply concerned about the excessive excavation and what that will do to Paddington's
aged infrastructure and the beautiful trees on the both sides of Oxford St.
5. Heritage and Visual Character
As a long time resident, I can attest that Paddington’s heritage character is a cornerstone of
its identity and tourism appeal. The proposed design and height will erode this character,
1
creating a visual disconnect with the surrounding low-rise terraces and heritage façades.
Modern bulk, excessive glazing, and the sheer scale of the structure are incompatible with
the conservation values protected under the Woollahra DCP and the Oxford Street Heritage
Conservation Area provisions.
6. Construction Impacts and Amenity
A construction period extending from 2025 to 2029 will cause prolonged noise, dust, and
disruption to residents and nearby businesses. Given the narrowness of local streets,
construction traffic management, material storage, and safety must be fully addressed
before any consent is considered. The expected noise during rock excavation will exceed
85–100 dB for several months, with vibration levels posing significant risk to adjoining
properties within 10 metres of the site — well above thresholds set for heritage structures
under AS 2187.2:2020 and DIN 4150-3 vibration guidelines.
7. Response to NSW Government Housing Targets and the National Housing Accord
I acknowledge and support the NSW Government’s commitment under the National
Housing Accord to increase housing supply and deliver 377,000 new homes by July 2029. I
also recognise the importance of providing diverse and affordable homes in well-located,
serviced areas.
However, the proposed development at 160 Oxford Street does not represent a responsible
or context sensitive implementation of these objectives. Instead, it exemplifies an
opportunistic intensification of a constrained heritage site, where scale and density are
being used to maximise private profit rather than deliver genuine public benefit or
sustainable housing outcomes.
(a) Misalignment with Strategic Planning Intent
The Government’s housing targets must be delivered through strategic planning, in areas
identified for increased density under existing Local Environmental Plans, Local Housing
Strategies, and Transport Oriented Development precincts.
Paddington is a Heritage Conservation Area, not a designated growth precinct. The
Woollahra Local Housing Strategy (2021) identifies modest, incremental infill, not major
redevelopment, as the appropriate way to contribute to housing supply while protecting the
area’s established character.
Accordingly, an eight-storey mixed-use tower in this sensitive setting is inconsistent with
both local and regional housing strategies.
(b) Minimal Contribution to Genuine Housing Diversity or Affordability
Although the proposal cites 15% “affordable housing”, the remaining 85% of the
‘approximately 40 apartments’ are expected to be high-end dwellings targeting the luxury
market. This does not meet the definitionof diverse or affordable housing envisioned
under the State Environmental Planning Policy (Housing) 2021 (SEPP Housing 2021).
2
The affordability component appears to serve primarily as a planning incentive to justify
height and density that exceed local controls, an approach inconsistent with the objectives of
the National Housing Accord, which emphasise equitable and sustainable growth, not
developer yield.
(c) Lack of Infrastructure Capacity
Paddington’s narrow streets, limited parking, heritage-era utilities, and constrained public
transport already operate near capacity. The Government’s housing targets do not justify
developments that overburden existing infrastructure or create localised congestion,
pollution, and amenity loss.
Clause 1.2(2)(f,g,h) of the Woollahra LEP 2014 requires that development provides for a
range of housing, employment, recreation and community services and facilities in a manner
that is sustainable and compatible with local infrastructure capacity. This proposal fails that
test.
(d) Conflict with Heritage and Sustainability Objectives
Both the NSW Housing Accord Implementation Plan (2024) and the Greater Sydney Region
Plan - A Metropolis of Three Cities require that new housing respect local character, heritage
values, and good urban design principles. Delivering density at any cost, particularly in one of
Sydney’s most intact heritage precincts, contradicts those strategic objectives. True
sustainability requires a balance between growth, place identity, and community well-being.
Conclusion
For the reasons outlined above, I respectfully request refusal of the proposed development
at 160 Oxford Street, 6 Shadforth Street, 142-148 Oxford Street and 13 Gipps Street in its
current form. Should approval be considered, I ask that substantial amendments be required
to:
• Reduce the building height and bulk to align with local character,
• Limit basement excavation and car parking scale,
• Strengthen heritage design requirements,
• Provide genuine mitigation of construction and traffic impacts, and
• Reassess infrastructure capacity and public benefit claims.
This development, as proposed, would irreversibly alter the historic and residential fabric of
Paddington.
Thank you for considering my submission.