FOKE’s Covering Letter:

3 August 2026

Dear Members of Parliament, Mayor, and Councillors Ku-ring-gai Council,

RE: SSD-88009456 95-97 Stanhope Road Killara – Lourdes Retirement Village – Seniors Housing proposal

Please find attached a copy of the Friends of Ku-ring-gai Environment Inc. (FOKE) submission.

Submission Conclusion and Request

If this site was considered as a greenfield site in today’s environment, with awareness of the greater risks of climate change and likelihood of more frequent and intense fire events, this site would not be deemed suitable for the development of seniors housing or other vulnerable uses.

The financial drive to maximise investor profits by packing high-end high-density luxury apartments into a severe Category 1 bushfire flame zone must not override basic human safety and local planning frameworks. The proponent has failed to demonstrate a realistic, safely drillable, and independently verified evacuation plan that accounts for the combined vulnerabilities of both with multi storey seniors housing expansion and the existing nursing home.

The climate is changing. In the past decade Australia has experienced increased levels of bushfire frequency, unpredictability, and longer lasting and intense fire seasons in Australia. Climate change has not been considered in the bushfire risk analyses.

The culmination of the 2026 Royal Commission final review due Q3 2026 and the NSW Natural Hazards Policy updates creates an incredibly hostile regulatory environment for any aged care facility and seniors housing interfacing with Garigal National Park.

Because Garigal National Park features continuous, steep, and dense sandstone gully vegetation, it represents the highest possible fuel load configuration in the state. For facilities sitting anywhere from BAL-29 up to the BAL-40/Flame Zone (BAL-FZ) interface next to this specific park, the new 2026 controls impose strict, non-negotiable hurdles.

We urge the Department of Planning, Housing and Infrastructure (DPHI) to reject SSD-88004956 and the associated Clause 4.6 variation in its entirety. Any future redevelopment of this site must be strictly capped at a low-density, low-occupancy scale that matches the physical evacuation capacity of the existing local road infrastructure and preserves the critically endangered Ku-ring-gai urban canopy, endangered fauna and heritage character.

We conclude in registering our strongest formal objection to the proposed $247 million redevelopment of Lourdes Retirement Village in Killara. While we acknowledge the Levande’s attempts to modify the site layout, the fundamental reality remains unchanged: this proposal places a highly vulnerable, multi-storey seniors’ housing development directly inside a high-risk Category 1 Bushfire BAL40-FZ (Flame Zone) interface.

The conditional support offered by the NSW Rural Fire Service (RFS) relies on technical, performance-based engineering workarounds that fail to account for real-world human behaviour, medical vulnerabilities, and severe local infrastructure bottlenecks.

We urge the Department of Planning to reject this application based on the critical safety failures detailed below.

1. Inappropriateness of “Defend-in-Situ” / “Shelter-in-Place” Strategy for a Vulnerable Demographic
The RFS’s conditional position assumes the proposed 2-to-5 storey buildings can act as a “fire bunker” while a bushfire front passes. While concrete facades may survive a fire, the internal environment poses an immediate threat to life. Multi-storey seniors’ developments adjacent to high-fuel vegetation face intense, prolonged smoke logging. Frail aged care residents—many with severe respiratory or cardiovascular conditions—cannot survive heavy particulate and carbon monoxide intrusion. Furthermore, relying on staff to manage complex vertical airlocks, fire doors, and mechanical ventilation systems while grid power is lost and backup diesel generators are running under extreme heat is an unacceptable operational risk. A building solution on paper does not equate to human safety in a live crisis.

2. Inadequate Evacuation Infrastructure and Road Network Constraints
Lourdes Village is located at the terminus of Stanhope Road, a narrow, winding, dead-end street directly abutting the dense bushland of Garigal National Park. There is zero alternative egress. In a sudden bushfire event, emergency vehicles rushing in will face immediate, catastrophic gridlock with staff, private vehicles, and transport vans trying to flee. Evacuating a modern residential aged care facility requires specialised non-emergency transport vehicles and ambulances to move non-ambulatory and bed-bound patients. These heavy vehicles cannot safely manoeuvre or turn around on a narrow road blocked by RFS tankers. If Stanhope Road becomes blocked by fallen timber or intense radiant heat, hundreds of vulnerable citizens will be trapped in a known high-risk pocket.

The Department must also fully consider this proposal also from a community’s perspective – for it is the community who will ultimately bear the tragic consequence of loss of life if this proposal proceeds. 

The Department of Planning must recognize that a SSDA “performance-based building solution” on paper does not equate to human safety in reality. Relying on concrete, masonry and glass to protect vulnerable or non-ambulatory citizens feet away from a roaring Flame Zone is an abdication of the state’s duty of care.

The Department of Planning has a strict duty of care that supersedes a developer’s ability to tick minimum SSDA regulatory boxes on paper. The “Shelter-in-Place” model is entirely inappropriate for vulnerable citizens at the end of a dead-end road next to a National Park.

We strongly request that the Department prioritise human life over SSDA development yield and reject this State Significant Development Application in its current form.

Yours faithfully

Kathy Cowley

PRESIDENT

cc Mayor and Councillors Ku-ring-gai Council

cc Matt Cross MP Member for Davidson

cc The Hon Alister Henskens SC MP Member for Wahroonga

cc Nicolette Boele MP Member for Bradfield

cc The Hon Jihad Dib MP Minister for Emergency Services

cc The Hon Chris Rath MLC Shadow Minister for Planning and Public Spaces

cc Tanya Thompson MP Shadow Minister for Emergency Services

FOKE’s Submission:

3 August 2026