See DA proposal HERE

Ms Kiersten Fishburn
Secretary
NSW Department of Planning, Housing and Infrastructure
Submitted via the NSW Major Projects Portal
 
2 June 2025
 
Dear Ms Fishburn,

Re: Submission 10, 14 & 14a Stanhope Road, Killara (SSD-81890707)
 
Thank you for the opportunity to provide feedback on the State Significant Development Application proposal at 14 & 14a Stanhope Road, Killara (SSD-81890707).
 
Friends of Ku-ring-gai Environment (FOKE) have been strong advocates for the protection of
Ku-ring-gai’s neighbourhood character, environment, heritage and liveability for the past 30 years.
 
FOKE wishes to express its objection to the proposed development for the following reasons:



Statutory Context
The proponent has not taken into consideration mandatory statutory considerations which the consent authority is obligated to take into account when assessing and determining DA’s, and including:

• Ku-ring-gai Council’ LEP 2015 and DCP, as required under Section 4.15 of the EPAA Act 1979
• The Apartment Design Guide 
• The SEPP Housing Guide 2021

In FOKE’s view the SSD does not comply with ENVIRONMENTAL PLANNING AND ASSESSMENT ACT 1979 – SECT 1.3 Objects of Act a) (b), (c), (d), (e), (f), (g), (h), (i), (j).

Design Quality
The proposal:

• fails to demonstrate a high level of environmental amenity for the surrounding residential and sensitive land use – particularly in the regard to the high quality architectural and heritage listed homes surrounding the proposal.
• is too high and bulky (3 buildings, ranging from part 5/6 storey to 9/10 storey at the rear of the site). This will have negative impacts on shadowing / privacy / solar access / streetscape / character / amenity and views.
• overall size will of the proposed development is too large and as such will negatively impact on the neighbourhood context that surrounds it being 1-2 storey houses as well as excess traffic generated from the site.
  
  

Heritage

FOKE has recently written to the Heritage Council of NSW supporting the Heritage Nomination of 14 Stanhope Road, Killara under Criteria (b) and (d).

FOKE affirms that:

• No. 14 Stanhope Road has heritage value to community organisations such as Friends of Ku-ring-gai Environment (FOKE);
• It is featured on local heritage walking tours in Killara;
• It has a well-documented association with Dr Margot Hentze, a person of historical significance to New South Wales.

Please refer to the attached letter:

The proposal will also:

• negatively impact on the surrounding heritage, including the Stanhope Road Conservation Area
• negatively impact on heritage items at:
  • 2 Stanhope Road, Local Heritage listed
  • 4 Stanhope Road, Local Heritage listed
  • 5 Stanhope Road, “Rydal Mount”, Local Heritage listed
  • 6 Stanhope Road, Local Heritage listed
  • 7 Stanhope Road, Local Heritage listed
  • 12 Stanhope Road, Local Heritage listed
  • 18 Stanhope Road, Local Heritage listed
  • 21 Stanhope Road, “Delville”, Local Heritage listed.
    

Traffic

• The projected change in traffic generation potential of the site will have major negative implications on the road network, road capacity, vehicular access and street parking/loading. 
• Stanhope Road does not have the capacity to cope with additional proposed 195 car parking spaces entering and exiting it, as well being a significant entry and exit road to the Pacific Highway.
• Already there is insufficient street parking in the area. The proposed development will compound and entrench the unavailability of street parking and make it harder for cars and trucks driving over the railway bridge access to the eastern side of Stanhope Road.
• The additional traffic generated from the proposed development will create danger for drivers and particularly pedestrians. It will also endanger the safety of its occupants and neighbouring residents, particularly during emergency events, when emergency vehicles (ambulances, fire engines, police) may be required to assist them but may not be able to reach them to provide lifesaving services.
• The impact of the additional traffic that will be generated by the proposed development particularly during peak periods. with traffic entering and exiting the Pacific Highway.
  
  

Visual Impacts

The proposal will have negative visual impact on:

• Stanhope Road as it is one of Killara’s most significant heritage streets with its streetscape of magnificent trees (on the western side of the railway line) that make it one of the most visually aesthetic streets in Killara and Ku-ring-gai.
• It will have adverse impacts on neighbouring properties at 2, 4, 4a, 6, 6a, 8, 12 Stanhope Road, Killara.
• the loss of trees and ‘greenery’ and destroy this unique environmental heritage from Killara, which has been characterised by the ‘natural’ dominating the ‘built’ form.   As such the proposal will have a severely negative and irreversible impact on Killara’s character, heritage and environment.
  

Trees and Landscaping

• The proponent’s Arborist acknowledges the high significance of vegetation on site, identified as both Blue Gum High Forest (BGHF) and Sydney Turpentine Ironbark Forest (STIF) and that there is other several significant species on the site including 5 Eucalyptus saligna (Blue Gum trees), 1 Eucalyptus resinefera (Red Mahogany), 7 Waterhousia floribunda (Water gum), 1 Eucalyptus paniculata (Grey Ironbark), 5 Lophostemon confertus (Brushbox).
• Despite assurances that the trees will be protected on site, the community is used to ‘promises to protect trees’ followed reasons to remove them or that they’re health has been compromised by the building works. That the Arborist makes the following statement verifies community concerns:
  Should the recommendations not be viable or achievable for whatever reason, with factors outside the control of the Arborist and mainly due to other planning controls, then consideration must be given to the removal of single specimens. The loss of any tree is indeed unfortunate but not necessarily detrimental as there needs to be acknowledgement of the newly created built form and its overall impact to not just vegetation but the area in general. [page 9].
• Despite the Arborist being satisfied that no design changes or conditions need to be imposed for the retention of T1-T5, T8, T14 – T19 there is concern with the following sentence that however this will be “dependent on the proposed stormwater design for the site and must be reassessed a later stage”.
• There does not appear to be any setback for landscaping on the rear of the site (western corner).
• Nor does there appear to be any tree screening looking down on the two properties, that the proposal will tower over.
• The proposed building should be reduced to ensure that the canopy of T18 and T19 tree will have space.
  
  

Biodiversity

• The applicant’s biodiversity statement is grossly inadequate and ignores both Commonwealth and NSW environmental legislation to protect this endangered species:
  • “The site is identified as containing biodiversity values in the north-eastern and south-eastern corners as shown in Figure 19 below. The biodiversity values are understood to be associated with the Blue Gum High Forest which is a common tree found in the Ku-Ring-Gai area. These trees provide important habitat and shelter for native animals including the Grey-headed Flying Fox and Glossy Back Cockatoo which are both endangered species.”
• The Biodiversity Development Assessment Report is insufficient and does not pay sufficient attention of key threatening processes – of fragmentation of habitat, loss of trees, impact of construction and accompanying noise.
• The proposal is located in an important wildlife corridor connecting the Lane Cove National Park to the Garigal National Park via the garden suburb of Killara and as such is of environmental significance. It is also part of Ku-ring-gai’s Green Corridors, supporting biodiversity including its Critically Endangered Blue Gum High Forest and Sydney Turpentine Ironbark Forest (STIF).
• The ABC radio program, How many animals REALLY live in your house? https://www.abc.net.au/listen/programs/what-the-duck/animalsinyourhouse/103411034 identified over 1,150 unique species of animals, plants and fungi in one Brisbane suburban house that appeared to have minimal biodiversity.  Yet over a 12-month period it identified over 1,000 species. The applicant needs to provide a similar long term ecological study for 10, 14 & 14a Stanhope Road, Killara site. Its current report is grossly insufficient.
  
  
  
  
  
  
  
  
• The applicant’s Biodiversity Report does not acknowledge the environmentally sensitive land on the north-south railway line near Hill Street and its migratory birds, many of them endangered.
•  The proposal downplays the environmental sensitivity of the site. It is disappointing that the applicant does not provide a more thorough ecological report of the area.
  
  

Social Impact

• The proposal impacts on the existing residents whose homes and amenity are irreversibly negatively impacted. 
• The proponent offers no community benefits, however, impacts heavily on existing infrastructure and community services.
• The development will dramatically and negatively impact on the sense of community and what residents value about living in Killara.
• Already many residents feel a sense of ‘grief’ that their home and neighbourhood will significantly and irreversibly change due to the proposal.  
• The loss of trees and tree canopy impacting directly on residents and cumulatively on connectivity of canopy, impacts adjoining remnants of endangered and critical ecological communities and connecting National Parks. 
• The term ‘solastalgia’ perhaps may describe the feelings of many Killara residents, a scientific term that describes the emotional distress felt when existing residents witness the destruction and degradation of their local environment.
  
  

Affordable Housing

• The proposal fails to promote genuine and long term affordable housing with its provision to provide affordable housing for only a 15-year period.
• The TOD and in-fill affordable housing components of the proposal will be managed by a registered community housing provider (being Echo Realty). The number of affordable units (3) to be managed in perpetuity is insufficient considering the housing crisis, as is only 23 affordable units (only for a maximum of 15 years).
  
  

Insufficient Environmental and Infrastructure Studies

• The applicant fails to provide critical studies (e.g. ecological, traffic, parking, water, stormwater run-off, water pressure, sewerage, energy and utilities) to support the intensified SSD proposal of 3-10 storeys. Without these verified independent studies, the SSD risks unsustainable development, straining local infrastructure and exacerbating environmental degradation.
  
  

Conclusion

Friends of Ku-ring-gai Environment (FOKE) is of the view that the State Significant Development Application proposal at 10, 14 & 14a Stanhope Road, Killara (SSD-81890707) should be rejected as it will have a negative and detrimental impact on heritage, environment, traffic, urban design, neighbourhood character, visual amenity, liveability, tree canopy, open space, infrastructure and community benefit. As such FOKE requests that this SSD be rejected.

Thank you for considering FOKE’s submission.

It is to be hoped that the NSW DPIH will take on board our concerns and reject the proposal.

Yours sincerely,

Kathy Cowley

PRESIDENT

• cc Ku-ring-gai Mayor and Councillors
• cc Matt Cross MP Member for Davidson
• cc The Hon Alister Henskens SC MP Member for Wahroonga
• cc The Hon Paul Scully MP Minister for Planning and Infrastructure
• cc The Hon Scott Farlow MP Shadow Minister for Planning
  
  

References