How to write a SSDs Submission? Address the SEARs.


Important – respond to the Planning Secretary’s Environmental Assessment Requirements (SEARs) document
  • In your submission response, refer to the Secretary’s Environmental Assessment Report (SEARs)
  • Address each point you are concerned with under the section titled ‘Issue and Assessment Requirements ‘.

A resident / objector should consider each of the criteria and decide whether the DAs address the following requirements contained in the SEARs’ documents.

Design Quality

If you believe the SSD is not of good design, state why this doesn’t meet the criteria.

Built Form & Urban Design (solar access, visual privacy, view loss, etc)

If the resident / objector considers that their property is impacted, then the point of objection should be raised.

Note, the SEAR’s documents require each proposed development to achieve a “high level of environmental amenity from any surrounding residential or other sensitive land uses”.

The resident / objector should make an assessment as to whether the height, bulk, scale, separation, setbacks, interface and articulation are appropriate for each development site and the locality.



Visual Impact

A resident / objector must consider the likely anticipated visual bulk contemplated by the TOD legislation. But mere compliance with the numerical controls under TOD does not mean that the Visual Impact of each proposed development is reasonable. There may be circumstances on an objector’s property which renders the proposed development generating an unsatisfactory visual Impact. For example, an objector’s property may have a certain aspect which will be significantly impacted by the proposed building envelope. If, however, the sight lines and views from an individual property are not adversely impacted then this issue should not be raised.



Other important points to consider

Raise matters of concern relating to existing issues that may be exacerbated by the development, including:

  • Transport – heavy traffic, limited parking, trains at full capacity
  • Noise and vibration – construction and operational. If a resident / objector’s property contains ‘sensitive receivers and structures’ this could be an issue raised ie. childcare centre
  • Water management – stormwater disposal and water quality management issues
  • Trees and Landscaping – significant loss of trees a concern
  • Flood risk – raise issue and / or provide any evidence of possible flood risk
  • Environmental Heritage – relevant to us as the proposed developments are in proximity to adjoining Heritage Items and Heritage Conservation Areas
  • Public Space – ie. parks adequacy and proximity in the locality and state why this is of concern. As a general guide, a walking distance of 400m is a general benchmark for public open space.
Make sure you:
  • Provide a brief paragraph as to how long you have lived in the immediate locality demonstrating your points of objection are based on personal long term in-depth knowledge and experience of the immediate locality.
  • Focus on individual points of objection for your property or neighbourhood.
  • Write your submission in your own words. DO NOT submit AI generated documents and/or a pro-forma style approach
  • If you do not have a Major Projects account on the NSW planning portal website, you will need to create an account online. It is recommended you do this well in advance to avoid IT issues / system delays.


Council confirms that:

Council confirms that Council’s Local Environmental Plan and Development Control Plan are applicable DA considerations and will be referred to in council submissions, in addition to the TOD SEPP.  Council will as part of its submissions be considering each SSD DA against the heads of consideration set out in Section 4.15 of the Environmental Planning and Assessment Act 1979. These are mandatory statutory considerations which the consent authority is obligated to take into account when assessing and determining DA’s, and include the below:

  • Provisions of applicable SEPPs (including SEPP 65 Design Quality of Residential Apartment Development along with the Apartment Design Guide, SEPP BASIX and SEPP Biodiversity and Conservation 2021)
  • Provisions of applicable instruments (KLEP 2015)
  • Provisions of applicable policy documents (Ku-ring-gai DCP)
  • The likely impacts of the development on the natural and built environment (such as biodiversity/ecological/riparian impacts, impacts on privacy, amenity, solar access and bulk and scale and traffic generation impacts)
  • The suitability of the site for the proposed development
  • Ecologically Sustainable Development principles


In preparing its submissions, Council will also where applicable include:

Multi-disciplinary inputs such as:

  • Landscaping and Trees
  • Ecology
  • Stormwater and Development Engineering
  • Urban Design
  • Heritage

Please encourage all your neighbours to lodge submissions

Have your say for the best positive outcome for the community.

It is advised if a fund can be raised by residents, to engage a town planner to prepare and lodge a technical report and/or other reports such as a heritage report (if the DA is impacts a number of heritage items or the development is located within or in the locality of a Heritage Conservation Area (HCA)) or any other technical reports (e.g. traffic, parking, infrastructure) to counter or answer the developer’s reports.

Copy your submission to:

Mayor and councillors                          councillors@krg.nsw.gov.au

Ku-ring-gai Council                               housing@krg.nsw.gov.au

Matt Cross MP                                      davidson@parliament.nsw.gov.au

The Hon Alister Henskens SC MP        wahroonga@parliament.nsw.gov.au

The Hon Scott Farlow MLC (Shadow Minister for Planning)   scott.farlow@parliament.nsw.gov.au



We hope the above list of considerations may assist in some way in the preparation of your submission.





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