Allen Telling
Object
Allen Telling
Object
Mona Vale
,
New South Wales
Message
Submission – Flood Risk Objection
Residential with In Fill Affordable Housing
159–167 Darley Street West, Mona Vale
Application Number: SSD-91496958
1. Executive Summary
This submission requests that the Planning Panel refuse or defer determination of SSD-91496958 on the basis that the proposal does not adequately address critical risks relating to flooding, groundwater interception, basement inundation, hydrostatic uplift, contamination pathways, and easement constraints. The Environmental Impact Statement does not provide the minimum technical evidence required to demonstrate that the development can be constructed or operated safely within a flood-affected catchment.
2. Flooding - Failure to Demonstrate Safety or Compliance
2.1 Absence of a Complete Flood Impact Assessment
The EIS does not include a compliant Flood Impact Assessment, 1D/2D hydraulic modelling, Flood Planning Level determination, overland flow path analysis, or flood storage assessment. Without these, the Panel cannot determine whether the proposal increases flood risk, obstructs overland flow, or meets the "no worsening" principle.
2.2 Three Basement Levels in a Flood-Affected Catchment
The proposal includes three basement parking levels, significantly increasing inundation risk, entrapment risk, structural failure under hydrostatic pressure, and pump failure during storm events. Planning requires that basement car parks must not flood in the 1% AEP event. The EIS does not demonstrate this.
3. Groundwater - High Risk and Insufficient Assessment
3.1 Groundwater Interception
A three-level basement is almost certain to intercept perched groundwater, shallow aquifers, and seasonal groundwater fluctuations, introducing long-term risks including continuous groundwater inflow, permanent reliance on mechanical pumping, drawdown impacts, and settlement of adjacent structures.
3.2 Missing Groundwater Documentation
The EIS does not include a Groundwater Impact Assessment, Dewatering Management Plan, hydrostatic uplift modelling, contamination risk assessment, or long-term pump-out strategy.
4. Structural & Safety Risks - Unresolved
4.1 Hydrostatic Uplift
No evidence has been provided that the basement slabs and retaining structures can resist uplift forces during high groundwater conditions, flood events, or pump failure.
4.2 Pump System Reliability
The EIS does not demonstrate compliance with industry requirements for dual pumps, backup power, alarm systems, and redundancy for 1% AEP events.
5. Easements & Drainage Constraints - Unclear and Unresolved
5.1 Existing Easements Not Identified
The site comprises five lots (Lot 1-5 DP 11108). The EIS does not clearly identify stormwater drainage easements, sewer easements, overland flow path easements, utility easements, or access easements.
5.2 Potential Obstruction of Natural Drainage
If the site contains or contributes to a natural drainage line or overland flow path, the proposed excavation and built form may obstruct lawful drainage, increase flood risk, or require new easements.
6. Environmental & Public Safety Risks
6.1 Contamination Pathways
If groundwater is intercepted, pollutants from vehicles may enter the water table unless the basement is fully tanked and sealed. The EIS does not demonstrate compliance with Sydney Water discharge requirements.
6.2 Evacuation Safety
The EIS does not provide a compliant Flood Emergency Response Plan. Basement flooding during storm events poses life-safety risks.
7. Determination Test for the Panel
Approval cannot be granted unless the Panel is satisfied that flood risk is managed, groundwater impacts are mitigated, basement structures can withstand hydrostatic forces, drainage constraints are resolved, and the development does not increase risk to neighbouring properties. The current EIS does not meet these thresholds.
8. Recommendation
It is recommended that the Planning Panel refuse SSD-91496958 or defer determination pending submission of a complete Flood Impact Assessment, Groundwater Impact Assessment, hydrostatic uplift modelling, Dewatering Management Plan, full easement mapping, and a compliant Flood Emergency Response Plan.
Residential with In Fill Affordable Housing
159–167 Darley Street West, Mona Vale
Application Number: SSD-91496958
1. Executive Summary
This submission requests that the Planning Panel refuse or defer determination of SSD-91496958 on the basis that the proposal does not adequately address critical risks relating to flooding, groundwater interception, basement inundation, hydrostatic uplift, contamination pathways, and easement constraints. The Environmental Impact Statement does not provide the minimum technical evidence required to demonstrate that the development can be constructed or operated safely within a flood-affected catchment.
2. Flooding - Failure to Demonstrate Safety or Compliance
2.1 Absence of a Complete Flood Impact Assessment
The EIS does not include a compliant Flood Impact Assessment, 1D/2D hydraulic modelling, Flood Planning Level determination, overland flow path analysis, or flood storage assessment. Without these, the Panel cannot determine whether the proposal increases flood risk, obstructs overland flow, or meets the "no worsening" principle.
2.2 Three Basement Levels in a Flood-Affected Catchment
The proposal includes three basement parking levels, significantly increasing inundation risk, entrapment risk, structural failure under hydrostatic pressure, and pump failure during storm events. Planning requires that basement car parks must not flood in the 1% AEP event. The EIS does not demonstrate this.
3. Groundwater - High Risk and Insufficient Assessment
3.1 Groundwater Interception
A three-level basement is almost certain to intercept perched groundwater, shallow aquifers, and seasonal groundwater fluctuations, introducing long-term risks including continuous groundwater inflow, permanent reliance on mechanical pumping, drawdown impacts, and settlement of adjacent structures.
3.2 Missing Groundwater Documentation
The EIS does not include a Groundwater Impact Assessment, Dewatering Management Plan, hydrostatic uplift modelling, contamination risk assessment, or long-term pump-out strategy.
4. Structural & Safety Risks - Unresolved
4.1 Hydrostatic Uplift
No evidence has been provided that the basement slabs and retaining structures can resist uplift forces during high groundwater conditions, flood events, or pump failure.
4.2 Pump System Reliability
The EIS does not demonstrate compliance with industry requirements for dual pumps, backup power, alarm systems, and redundancy for 1% AEP events.
5. Easements & Drainage Constraints - Unclear and Unresolved
5.1 Existing Easements Not Identified
The site comprises five lots (Lot 1-5 DP 11108). The EIS does not clearly identify stormwater drainage easements, sewer easements, overland flow path easements, utility easements, or access easements.
5.2 Potential Obstruction of Natural Drainage
If the site contains or contributes to a natural drainage line or overland flow path, the proposed excavation and built form may obstruct lawful drainage, increase flood risk, or require new easements.
6. Environmental & Public Safety Risks
6.1 Contamination Pathways
If groundwater is intercepted, pollutants from vehicles may enter the water table unless the basement is fully tanked and sealed. The EIS does not demonstrate compliance with Sydney Water discharge requirements.
6.2 Evacuation Safety
The EIS does not provide a compliant Flood Emergency Response Plan. Basement flooding during storm events poses life-safety risks.
7. Determination Test for the Panel
Approval cannot be granted unless the Panel is satisfied that flood risk is managed, groundwater impacts are mitigated, basement structures can withstand hydrostatic forces, drainage constraints are resolved, and the development does not increase risk to neighbouring properties. The current EIS does not meet these thresholds.
8. Recommendation
It is recommended that the Planning Panel refuse SSD-91496958 or defer determination pending submission of a complete Flood Impact Assessment, Groundwater Impact Assessment, hydrostatic uplift modelling, Dewatering Management Plan, full easement mapping, and a compliant Flood Emergency Response Plan.
Attachments
Garry Birch
Object
Garry Birch
Object
MONA VALE
,
New South Wales
Message
As a resident of 7 Kunari Place I strongly object to this development in it’s current form.
My main reasons for this objection are as follows:
A) Flood Risk and Stormwater Management
During any major rain event, the overflow drain/“creek” behind our property can’t cope with the quantity of water flowing into it from neighbouring streets and from the discharge of water from on-site stormwater detention pits including those located in already existing apartment blocks in Darley St. West. The result is that the “creek” breaks it’s banks and encroaches onto our properties. If this lack of stormwater management infrastructure is not addressed before the commencement of building the proposed development, the houses adjoining the “creek” will be exposed to major flooding events.
B) Sewer Management
The situation is made more serious by the fact that a lot of stormwater finds it’s way into the sewer system which then causes the sewer manhole covers behind our neighbour’s house and next to the reserve at the end of our street to blow out. The raw sewage then combines with the “creek” overflow and ends up in our gardens, sheds and swimming pools, therefore creating a major public health risk.
Both the Council and Sydney Water are well aware of the ongoing problems and have made multiple attempts to partially rectify the problems. So far however they have only managed bandaid solutions that are mainly applied after the fact. Both organisations realise that some major infrastructure upgrades are necessary to come up with a permanent solution. So if a major State Significant Project is deemed appropriate for this area that is already unable to cope with stormwater and sewer management, it must include the necessary changes to the currently insufficient and inadequate infrastructure.
My main reasons for this objection are as follows:
A) Flood Risk and Stormwater Management
During any major rain event, the overflow drain/“creek” behind our property can’t cope with the quantity of water flowing into it from neighbouring streets and from the discharge of water from on-site stormwater detention pits including those located in already existing apartment blocks in Darley St. West. The result is that the “creek” breaks it’s banks and encroaches onto our properties. If this lack of stormwater management infrastructure is not addressed before the commencement of building the proposed development, the houses adjoining the “creek” will be exposed to major flooding events.
B) Sewer Management
The situation is made more serious by the fact that a lot of stormwater finds it’s way into the sewer system which then causes the sewer manhole covers behind our neighbour’s house and next to the reserve at the end of our street to blow out. The raw sewage then combines with the “creek” overflow and ends up in our gardens, sheds and swimming pools, therefore creating a major public health risk.
Both the Council and Sydney Water are well aware of the ongoing problems and have made multiple attempts to partially rectify the problems. So far however they have only managed bandaid solutions that are mainly applied after the fact. Both organisations realise that some major infrastructure upgrades are necessary to come up with a permanent solution. So if a major State Significant Project is deemed appropriate for this area that is already unable to cope with stormwater and sewer management, it must include the necessary changes to the currently insufficient and inadequate infrastructure.
Nick Sarkies
Object
Nick Sarkies
Object
MONA VALE
,
New South Wales
Message
The Secretary, Department of Planning, Housing and Infrastructure
Objection to SSD-91496958 Residential with in fill Affordable Housing 159-167 Darley Street West Mona Vale
I would like to submit my very strong objection to SSD-91496958 due to the scale, density, and visual impact of the development and for the following reasons.
1. Flooding and Stormwater Limitations
As a resident of Darley Street West for over 5 years, I have witnessed multiple flooding events in this small cul-de-sac affecting at least four to five townhouse complexes all along my street. In all these events, the torrent of water cannot be serviced by the current stormwater grates in the street, not only from the direct rain but the subsequent pump out from all the complexes. Consequently, the torrents re-enter the complexes drainage systems which backs up their ability to pump their own stormwater out causing basement flooding (image 001). This proposed development will be especially impacted being located down a steep hill, and its construction will create unknown effects of interference with water flow on surrounding properties.
2. Traffic and Parking report ref 24205
Darley St West is a small cul-de-sac with one entry/exit to a four-way intersection leading to busy Pittwater Road. It has a misaligned intersection causing a dangerous situation when turning right from Darley Street West as on-coming vehicles obscure vision, this also contributes to traffic build up in the street as only a limited number of vehicles can get through at a time which causes great stress. It is ludicrous for the Traffic and Parking report to suggest this development will not be traffic generating and it should go to the Transport of NSW for review for the following reasons:
Darley Street West is consistently parked out on both sides of the street making it single lane only (image 002). During demolition and construction large vehicles will cause traffic chaos, as will the extra volume of traffic of 164+ resident vehicles along with the general increase that higher density living brings with delivery vehicles, garbage collection, and other vehicle movements. This will cause great distress to myself and other residents in the street affecting sleep, health and amenity. The cumulative impact on traffic and parking that high density living on the already very busy Mona Vale town centre will also be significant and will be very dangerous in such a high pedestrian activity area with 3 nearby schools.
The impact of the demolition and construction vehicles is grossly understated in the report, the estimated truck movements are not even known yet and are to be confirmed later by the contractor. My lived experience tells me that the extra volume of large 18.5m bogey trucks lined up in the single lane cul-de-sac of Darley Street West will severely impact the safety and wellbeing of the current residents with restricted traffic movement, dangerously impeded sightlines and the ability to access our own homes with the bank up in traffic this will cause. This is inconsistent with Site Access and Loading section 7.4 stating neighbouring driveways would not be affected during demolition and construction. This could impact me and other residents for up to three years or more, a consistent build time with previous smaller constructions by the proponent in the area.
The ability for emergency vehicles to also access Darley Street West during demolition and construction is of great concern to me.
Section 4.4 Traffic Impact report states that the truck movement route will enter Mona Vale via either Pittwater Road or Mona Vale Road which is in sections a dangerous single lane road with no safety verges (image 003), ultimately turning left at Pittwater Road. They will then turn left at the next intersection at Barrenjoey Road (which locals consider the main road), and funnel straight through the middle of the high pedestrian area of the Mona Vale Town Centre through the already dangerously busy and congested roundabout at Bungan Street.
The18.5m bogey trucks will continue along Pittwater Road. This is not a 2 lane road as the kerbside parking is utilised along this entire stretch on both sides of the road, especially during the week, reducing it to a single lane road.
They will then turn left into Darley Street West. Due to the misaligned and narrow entry to Darley Street West they will not be able to navigate this turn, especially if a car is exiting the street. This will result in entire blockages of the 4-way intersection further impeding residents from accessing their own homes, particularly those residing near the intersection (image 004).
Emergency vehicles consistently travel along this section of Pittwater Road under siren. It is a major concern to me as access through this intersection could potentially be impeded by demolition and construction vehicles.
The report section 2.7 on parking also incorrectly states there is parking at the cul-de-sac end of the street, this is a no parking area and sign posted as such. The rest of the street is parked out on both sides every day so I disagree with the planning statement that on site visitor parking is not needed (image 005).
Section 2.5 in the report notes 3 easily accessible bus stops. None of the 3 noted bus stops are easily accessible, especially for prams or people with limited mobility. To access the Maxwell St bus stop (servicing 155 & 182) there is no footpath along the site frontage, Kunari Place or the pedestrian through link. You need to navigate up the steep hill of Kunari Place with no footpath. There is no pedestrian crossing available and it is dangerous to cross Park St at the crest of this hill, and dangerous to cross at the foot of the Park St hill due to a blind corner at Parkland Street (image 006). The same applies to access the bus stop on Pittwater Road servicing 156, due to the steep terrain of Darley Street West and no footpath at the site frontage. It is also over 1km to the B Line bus stop.
The “Maxwell St” bus stop is incorrectly referred to several times as “Raglan St” indicating that this is not a site-specific report and has been copied and pasted from another application.
There are a few statements in the CJT traffic and road report that are misleading and not consistent with the road's ability to handle increased traffic volume:
Barrenjoey Road closes down to just one lane at Newport and other than one small section remains so all the way to Palm Beach where the road terminates.
Mona Vale Road in one section closes to one lane with no safety verge (image 003). An upgrade will not be completed for several years, if at all.
The Greater Sydney regional plan of livability and transport is about maximising the benefits of infrastructure, public transport, walking, and cycling. This development is not relevant to that for the reasons below:
This is an overdevelopment in a small cul-de-sac with thin pavement width (none at all at the site frontage and through to the Kunari Place cul-de-sac and beyond).
Limited public transport – local bus services are very uncomfortable, slow, time-consuming services. The only major transport we have is the enhanced bus service of the B-Line which runs to the city only – not a 24hr rapid transport service or cross regional – which must use the same congested inadequate road network.
The cycling networks in the area are not dedicated bike lanes, not even shared bike paths. They are dangerous shared lanes with the road network, which I feel are too unsafe to use (image 007).
Two roads lead to Mona Vale. There’s very limited public transport, roads that flood and are bushfire prone, and the nearby water treatment plant at Warriewood is already under strain. This is not an area with adequate infrastructure to accommodate high density living.
3. Affordable Housing
I disagree with the concept of this development having affordable housing and the statement by Link Wentworth in their submission that the housing provided will support those with minimal resources. These units will be upmarket luxury 2–3-bedroom apartments and will be advertised as such (image 008 – nearby unit sold for $4.8m). Considering the high prices of Mona Vale, the subsidised rent will still be unaffordable for people with “minimal resources“.
The application suggests that 10 affordable housing units will be available across the 3 towers. This is incorrect. Only Block C will contain the “affordable” housing component so at the very least the other two blocks should not be given the bonus additional storeys and should be reduced in height.
4. Community
Contrary to the "Undertaking Engagement Guidelines for State Significant Projects”, the proponent has engaged with the community just once via a non-interactive webinar held on the 2nd October 2025 restricted to around 30 attendees. We were spoken at, not with, and given a limited time to submit written questions, many of which went unanswered including mine.
Many of the EIS statements indicate that there will be no impact to the community. This does not align with my lived experience of Darley Street West and the wider Mona Vale area. I did the right thing by downsizing my large 5 bedroom house to make it available to families and after extensive searching moved to a quiet, peaceful townhouse complex in the unique village of Mona Vale that would enhance my lifestyle. This overdevelopment and overpopulation of Darley Street West puts all that in jeopardy and will directly and negatively impact my amenity and well being.
In light of the above objections, I request that SSD- 91496958 Residential In-fill Affordable Housing at 159-167 Darley Street West be rejected or at the very least significantly scaled down.
Objection to SSD-91496958 Residential with in fill Affordable Housing 159-167 Darley Street West Mona Vale
I would like to submit my very strong objection to SSD-91496958 due to the scale, density, and visual impact of the development and for the following reasons.
1. Flooding and Stormwater Limitations
As a resident of Darley Street West for over 5 years, I have witnessed multiple flooding events in this small cul-de-sac affecting at least four to five townhouse complexes all along my street. In all these events, the torrent of water cannot be serviced by the current stormwater grates in the street, not only from the direct rain but the subsequent pump out from all the complexes. Consequently, the torrents re-enter the complexes drainage systems which backs up their ability to pump their own stormwater out causing basement flooding (image 001). This proposed development will be especially impacted being located down a steep hill, and its construction will create unknown effects of interference with water flow on surrounding properties.
2. Traffic and Parking report ref 24205
Darley St West is a small cul-de-sac with one entry/exit to a four-way intersection leading to busy Pittwater Road. It has a misaligned intersection causing a dangerous situation when turning right from Darley Street West as on-coming vehicles obscure vision, this also contributes to traffic build up in the street as only a limited number of vehicles can get through at a time which causes great stress. It is ludicrous for the Traffic and Parking report to suggest this development will not be traffic generating and it should go to the Transport of NSW for review for the following reasons:
Darley Street West is consistently parked out on both sides of the street making it single lane only (image 002). During demolition and construction large vehicles will cause traffic chaos, as will the extra volume of traffic of 164+ resident vehicles along with the general increase that higher density living brings with delivery vehicles, garbage collection, and other vehicle movements. This will cause great distress to myself and other residents in the street affecting sleep, health and amenity. The cumulative impact on traffic and parking that high density living on the already very busy Mona Vale town centre will also be significant and will be very dangerous in such a high pedestrian activity area with 3 nearby schools.
The impact of the demolition and construction vehicles is grossly understated in the report, the estimated truck movements are not even known yet and are to be confirmed later by the contractor. My lived experience tells me that the extra volume of large 18.5m bogey trucks lined up in the single lane cul-de-sac of Darley Street West will severely impact the safety and wellbeing of the current residents with restricted traffic movement, dangerously impeded sightlines and the ability to access our own homes with the bank up in traffic this will cause. This is inconsistent with Site Access and Loading section 7.4 stating neighbouring driveways would not be affected during demolition and construction. This could impact me and other residents for up to three years or more, a consistent build time with previous smaller constructions by the proponent in the area.
The ability for emergency vehicles to also access Darley Street West during demolition and construction is of great concern to me.
Section 4.4 Traffic Impact report states that the truck movement route will enter Mona Vale via either Pittwater Road or Mona Vale Road which is in sections a dangerous single lane road with no safety verges (image 003), ultimately turning left at Pittwater Road. They will then turn left at the next intersection at Barrenjoey Road (which locals consider the main road), and funnel straight through the middle of the high pedestrian area of the Mona Vale Town Centre through the already dangerously busy and congested roundabout at Bungan Street.
The18.5m bogey trucks will continue along Pittwater Road. This is not a 2 lane road as the kerbside parking is utilised along this entire stretch on both sides of the road, especially during the week, reducing it to a single lane road.
They will then turn left into Darley Street West. Due to the misaligned and narrow entry to Darley Street West they will not be able to navigate this turn, especially if a car is exiting the street. This will result in entire blockages of the 4-way intersection further impeding residents from accessing their own homes, particularly those residing near the intersection (image 004).
Emergency vehicles consistently travel along this section of Pittwater Road under siren. It is a major concern to me as access through this intersection could potentially be impeded by demolition and construction vehicles.
The report section 2.7 on parking also incorrectly states there is parking at the cul-de-sac end of the street, this is a no parking area and sign posted as such. The rest of the street is parked out on both sides every day so I disagree with the planning statement that on site visitor parking is not needed (image 005).
Section 2.5 in the report notes 3 easily accessible bus stops. None of the 3 noted bus stops are easily accessible, especially for prams or people with limited mobility. To access the Maxwell St bus stop (servicing 155 & 182) there is no footpath along the site frontage, Kunari Place or the pedestrian through link. You need to navigate up the steep hill of Kunari Place with no footpath. There is no pedestrian crossing available and it is dangerous to cross Park St at the crest of this hill, and dangerous to cross at the foot of the Park St hill due to a blind corner at Parkland Street (image 006). The same applies to access the bus stop on Pittwater Road servicing 156, due to the steep terrain of Darley Street West and no footpath at the site frontage. It is also over 1km to the B Line bus stop.
The “Maxwell St” bus stop is incorrectly referred to several times as “Raglan St” indicating that this is not a site-specific report and has been copied and pasted from another application.
There are a few statements in the CJT traffic and road report that are misleading and not consistent with the road's ability to handle increased traffic volume:
Barrenjoey Road closes down to just one lane at Newport and other than one small section remains so all the way to Palm Beach where the road terminates.
Mona Vale Road in one section closes to one lane with no safety verge (image 003). An upgrade will not be completed for several years, if at all.
The Greater Sydney regional plan of livability and transport is about maximising the benefits of infrastructure, public transport, walking, and cycling. This development is not relevant to that for the reasons below:
This is an overdevelopment in a small cul-de-sac with thin pavement width (none at all at the site frontage and through to the Kunari Place cul-de-sac and beyond).
Limited public transport – local bus services are very uncomfortable, slow, time-consuming services. The only major transport we have is the enhanced bus service of the B-Line which runs to the city only – not a 24hr rapid transport service or cross regional – which must use the same congested inadequate road network.
The cycling networks in the area are not dedicated bike lanes, not even shared bike paths. They are dangerous shared lanes with the road network, which I feel are too unsafe to use (image 007).
Two roads lead to Mona Vale. There’s very limited public transport, roads that flood and are bushfire prone, and the nearby water treatment plant at Warriewood is already under strain. This is not an area with adequate infrastructure to accommodate high density living.
3. Affordable Housing
I disagree with the concept of this development having affordable housing and the statement by Link Wentworth in their submission that the housing provided will support those with minimal resources. These units will be upmarket luxury 2–3-bedroom apartments and will be advertised as such (image 008 – nearby unit sold for $4.8m). Considering the high prices of Mona Vale, the subsidised rent will still be unaffordable for people with “minimal resources“.
The application suggests that 10 affordable housing units will be available across the 3 towers. This is incorrect. Only Block C will contain the “affordable” housing component so at the very least the other two blocks should not be given the bonus additional storeys and should be reduced in height.
4. Community
Contrary to the "Undertaking Engagement Guidelines for State Significant Projects”, the proponent has engaged with the community just once via a non-interactive webinar held on the 2nd October 2025 restricted to around 30 attendees. We were spoken at, not with, and given a limited time to submit written questions, many of which went unanswered including mine.
Many of the EIS statements indicate that there will be no impact to the community. This does not align with my lived experience of Darley Street West and the wider Mona Vale area. I did the right thing by downsizing my large 5 bedroom house to make it available to families and after extensive searching moved to a quiet, peaceful townhouse complex in the unique village of Mona Vale that would enhance my lifestyle. This overdevelopment and overpopulation of Darley Street West puts all that in jeopardy and will directly and negatively impact my amenity and well being.
In light of the above objections, I request that SSD- 91496958 Residential In-fill Affordable Housing at 159-167 Darley Street West be rejected or at the very least significantly scaled down.