FOKE’s Covering Letter:

5 August 2026

Dear Members of Parliament, Mayor, and Councillors

RE: SSD-98363228 Montefiore Seniors Housing 19-25 College Crescent and 15-19 Link Road St Ives

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

Because this application is lodged for full development consent and not as a concept proposal, the exhibited documents must be capable of supporting construction as approved. On the evidence set out above they are not.

The proposal does not comply with the operative deep-soil provisions of the Housing SEPP 2021; the headline deep-soil percentage is internally inconsistent within the EIS and does not survive the six-metre width test in section 107(f); the engagement program did not reach the residents most directly affected and the community groups it names; the built form exceeds adjacent R4 heights at the northern boundary and does not comply with the ADG transition building separation and it does not deliver the transition to R2 that the SEARs require; the visual impact material is drawn from long-range public-domain viewpoints rather than the R2 dwellings most affected and the balconies and living rooms in the Alcove complex that will actually lose amenity; the transport assessment does not model public patronage of the allied-health premises as a distinct trip class, and the shared Masada entrance is not modelled against school-peak conditions and access pathway and bus stop standards under Housing SEPP cll. 93–94 and DSAPT / AS 1428.1–.2 have not been incorporated at the SEARs stage or demonstrated in the exhibited EIS and the applicant concedes that at least two nominated public transport routes fall outside the 400 metre safe pedestrian route required by cl. 93; the basement is oversized at 260 spaces against the Housing SEPP minimum of 192 and KDCP minimum of 134, with the applicant expressly attributing part of the oversupply to displaced Masada College parking (to be considered in an unexhibited “future Masada Site Masterplan”) and to the publicly-accessible allied-health premises; and on the applicant’s own Table 13 rate and Table 15 split, a reduction in ILU count together with refusal or restriction of publicly-accessible allied-health reduces traffic on both College Crescent and Link Road without any redistribution between the two accesses; the publicly accessible allied-health facilities are held out for use by the general public but characterised in the alternative as either ancillary to seniors housing or as a stand-alone community health service facility, and the proposal cannot be both; and the bushfire assessment addresses only limb (a) of PBP Step 1 and does not address limb (b), notwithstanding classified vegetation on adjoining land opposite the south-east corner where the Class 9c residential care facility is proposed.

Each of these matters is a SEARs obligation, a statutory provision, or both. Taken individually, they are unresolved. Taken together, they mean the exhibited EIS does not discharge the SEARs and the proposal, as exhibited, is not in a form the consent authority can lawfully or safely approve. The development contrary to the applicant’s claims results in unreasonable negative Amenity impacts on neighbouring properties and the streetscape.

FOKE has requested that the application be refused in its current form. In the alternative, if the Panel is disposed to proceed, FOKE asks the Panel to require the applicant to address the matters set out in the Requested Panel Actions above, by supplementary information, amended reports and, where necessary, redesign and to re-exhibit the amended application for public comment before determination

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

cc Nicolette Boele MP Member for Bradfield

FOKE’s Submission:

August 2026