Save Gordon from UNSUSTAINABLE OVERDEVELOPMENT – FOKE

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NOTE: DEADLINE IS 11 SEPTEMBER 2025

Please see another submission written by a resident. PLEASE DO NOT COPY BUT ADAPT AND PUT IN YOUR OWN WORDS. IT IS IMPORTANT THAT THE SUBMISSION IS IN YOUR OWN WORDS

Submission: Objection to SSD 83478456 – Residential Development with Infill Affordable Housing

Address: 21–25 McIntosh Street & 55 Werona Avenue, Gordon, NSW
Date: …………………………….
Submitted to: NSW Department of Planning, Housing and Infrastructure

Resident Background

Write something about yourself and why this submission is important to you

1. Lack of Procedural Fairness & Premature State-Level Intervention

The proposal is being fast-tracked as a State Significant Development (SSD), bypassing Ku-ring-gai Council’s established planning processes. This undermines local governance and severely limits genuine community engagement.
The development is premature, arriving before the completion of the Council’s low-to-mid-rise housing strategy. With minimal public consultation, many local residents — myself included — only recently became aware of the proposal, leaving insufficient time to prepare meaningful submissions. This fails the procedural fairness test and contradicts the community-led planning ethos.

2. Incompatibility with Local Planning Controls & Character (SEARs 6)

The proposed 162-unit development is inconsistent with the Ku-ring-gai Local Environmental Plan (LEP) and Development Control Plan (DCP), which promote low-rise, fine-grained built form and aim to preserve the area’s garden suburb character.
The building height of up to 28.6m far exceeds the 8m height previously endorsed by Council in consultation with residents and also exceeds the 20m limit identified for the commercial zone in the town centre.
This proposal fails to satisfy SEARs 6 requirements for appropriate built form, bulk, scale, and streetscape integration.

3. Risks to Heritage Assets (SEARs 22: Environmental Heritage)

The site is adjacent to several heritage-listed properties:

Eryldene, 17 McIntosh Street (State-listed)
Rochester, 51 Werona Avenue (locally listed)
Other heritage buildings at 49 Werona Avenue and 14 Forsyth Street

The height and bulk of the development will result in overshadowing, visual intrusion, and contextual disconnection, especially for Eryldene, which holds state-level heritage significance.
The site sits within a designated Heritage Conservation Area (HCA). Council’s strategy clearly identifies the commercial town centre — not heritage areas — as suitable for increased density of this scale.
This proposal does not meet SEARs 22 requirements for protecting Environmental Heritage or the cultural context of heritage items.

4. Environmental Impact & Tree Canopy Loss (SEARs 14 & 16)

The development proposes removal of numerous mature trees. Even with replanting, this results in:

Loss of the area’s signature leafy character
Disruption of biodiversity corridors
Diminished urban cooling capacity, reducing climate resilience

Based on outcomes of similar SSDs, 50–60 mature trees may be lost, a likely parallel for this proposal.
This fails to uphold SEARs 14 (Trees & Landscaping) and SEARs 16 (Biodiversity).

5. Infrastructure Capacity & Traffic Concerns (SEARs 9 & 11)

The intersection of Pacific Highway, McIntosh Street, and Werona Avenue is already heavily congested during peak hours.
McIntosh Street is a major local access route from East Killara and East Lindfield, and the proposed development will exacerbate traffic delays, safety risks, and parking overflow.
No comprehensive plan is presented for upgrading key infrastructure — roads, stormwater, water mains, or utilities — to accommodate increased demand.
Stormwater infrastructure in the area is outdated; some Sydney Water mains are over 100 years old. The system has failed during recent heavy rain events, including along McIntosh Street where surface flooding is experienced on a more regular basis.
The development does not meet SEARs 11 requirements for adequate Water Management.
Critically, there is no cumulative impact assessment to account for the strain of this and other proposed SSDs in the local area.

6. Impact on Residential Amenity (SEARs 7 & 8)

Noise Impacts

· Construction Phase: High levels of noise from machinery, trucks, and site activity will disrupt nearby residents’ daily lives.

· Operational Phase: Increased human activity and vehicle use will raise baseline noise levels, impacting community tranquillity.

Overshadowing and Loss of Sunlight

· Despite tree planting proposals, the sheer bulk and height of the buildings will dominate the landscape and overshadow adjacent properties, reducing natural sunlight — especially in winter.

· This impacts residents’ wellbeing and energy usage, breaching SEARs 7 requirements for Solar Access.

Privacy & Overlooking

· Higher density and elevation will allow balconies and windows to overlook neighbouring properties, significantly reducing privacy.

Insufficient Green Space & Recreation Facilities

· Gordon’s east side already lacks adequate green space. The proposal does not include new public open space or contribute to accessible parks.

· The development provides no playgrounds, community gardens, or dog-friendly spaces, despite a major increase in population density.

Degradation of Community Wellbeing

· The combined impact of loss of light, privacy, noise, and green space reduces liveability and may harm long-term community cohesion.

7. Insufficient Demonstration of Public Benefit (SEARs 18: Social Impact)

While increasing affordable housing is important, this project does not provide long-term benefit proportional to the impacts it creates:

Only 2% of dwellings will remain affordable after the 15-year period
No additional public parks, transport links, or infrastructure upgrades are included
Heavy reliance on already overstretched community facilities
The long-term social benefit is minimal compared to the scale of the proposal.

8. Failure to Meet Ecologically Sustainable Development Goals (SEARs 15)

The proposal lacks clarity around sustainable design features, such as solar access maximisation, energy efficiency, and water-sensitive urban design.
In a climate-sensitive area like Ku-ring-gai, sustainable development must be a priority. This proposal does not meet SEARs 15 requirements.

9. Waste Management Deficiencies (SEARs 17)

High-density developments in this area have previously resulted in overflowing bins, inadequate street collection points, and illegal dumping.
The proposal lacks a clearly defined and accessible waste management strategy.
These issues directly affect local amenity and cleanliness.

10. Failure to Consider Cumulative Impact

The application does not consider the cumulative multiplier effect of other SSDs and future development applications in Gordon and nearby suburbs.
The combined impact of these projects — if approved — will severely strain infrastructure, increase congestion, and reduce local amenity.
A failure to assess this cumulative burden renders the proposal incomplete and inconsistent with responsible planning standards.

Conclusion & Request for Refusal

The SSD proposal at 21–25 McIntosh Street & 55 Werona Avenue should be refused for the following reasons:

It contradicts Ku-ring-gai’s LEP, DCP, and endorsed housing strategies
It poses significant risks to both local and state heritage assets
It will result in extensive tree canopy loss and biodiversity decline
It places unmitigated pressure on ageing infrastructure
It fails to deliver meaningful or lasting public benefit
It does not meet several SEARs requirements relating to Built Form, Amenity, Heritage, Environmental Design, Water Management, and Social Impact

I respectfully request that SSD 83478456 be refused in its current form. Any future proposal for this site should:

Align with Ku-ring-gai’s endorsed local planning frameworks
Be subject to transparent and inclusive community consultation
Respect heritage assets and the existing character of the area
Incorporate ecologically sustainable and climate-Re: Submission to State Significant Development
SDD-83478456 – Residential Flat Building with In-Fill Affordable Housing – McIntosh Street & 55 Werona Ave, Gordon
I object to the proposal on the following grounds:
This development cannot really be characterised as State Significant Development as there are already ample opportunities for increasing residential densities in Ku-ring-gai Council area and throughout Sydney.
The development is an overdevelopment of the site and out of proportion to the existing and likely future amenity of the locality.
The proposal document does not provide sufficient information or consideration of the social context, in that it fails to take into account the Ku-ring-gai TOD alternative developed by the Ku-ring-gai Council in consultation with the Department of Planning. The site of the subject is outside the proposed high density area and is in fact in a low density area.
The proposal in incompatible with the heritage conservation area on either side Along McIntosh Street. It is surprising and poor planning that part of the subject land represents an interruption to the contiguous conservation area on the south side of McIntosh street.
The subject development is total out of character with the iconic Eryldene property located one residential property to the west in both scale and size. While some of the adjoining and adjacent buildings are not necessarily historic, they are at least of a compatible size and scale with extensive landscaping afforded by the lower density of development.
The height of the building will cause server overshadowing and deprivation of sunlight enjoyed at the adjoining property. The extent of the overshadowing is exacerbated by the additional temporary affordable housing bonus. I am not sure that this will be of comfort to the residents of these dwellings. The presumption provided in the report that they these properties will receive at least three hours of solar access at mid-winter. The report fails to indicate the amount of solar access they get presently and what they would get if there was no affordable housing bonus. This information needs to be provided for transparency.
The proposed development and others proposed and planned for the area will have an adverse cumulative impact on the local road network without significant additional infrastructure. Traffic in the vicinity of Gordon Station and the arteries between the East Gordon hinterland and the Pacific Highway are already problematic. I raise the following issues:
1. The traffic study ignores the function of McIntosh Street as one of the few routes connecting the East Gordon to Arterial Road via Arthur Street, Kylie Ave and Wattle Street.
1. The Traffic Study, unlike the one submitted in respect of SDD-78775458 – (Residential Flat Building with In-Fill Affordable Housing – Park Ave Gordon), does not appear to recognise the arterial function of Rosedale Road between Park Ave and McIntosh Street.
1. The proposed access point is too close to the intersection of Park Ave and McIntosh Street for access and entry to be permitted on an unrestricted/uncontrol basis to this “collector road.”
1. The cumulative impact of increasing density in this area will result:
  1. In increased traffic congestion around the Gordon Train Station, reduced opportunities for on-street parking and increased congestion at the two access points across the Railway at the Werona Ave underpass and the Park Street overpass.
  1. the cumulative increase in cueing times at the intersection of the Pacific Hwy and Park Ave for vehicles wishing to access the Railway car park (west side), but more importantly the Pacific Highway.
Be supported by a comprehensive infrastructure and services strategy
Clearly demonstrate long-term public benefit
Critically, there is no cumulative impact assessment to account for the strain of this and other proposed SSDs in the local community and infrastructure.

Signed:

Please see another submission written by a resident. PLEASE DO NOT COPY BUT ADAPT AND PUT IN YOUR OWN WORDS. IT IS IMPORTANT THAT THE SUBMISSION IS IN YOUR OWN WORDS

Re: Submission to State Significant Development

SDD-83478456 – Residential Flat Building with In-Fill Affordable Housing – McIntosh Street & 55 Werona Ave, Gordon

I object to the proposal on the following grounds:

This development cannot really be characterised as State Significant Development as there are already ample opportunities for increasing residential densities in Ku-ring-gai Council area and throughout Sydney.
The development is an overdevelopment of the site and out of proportion to the existing and likely future amenity of the locality.
The proposal document does not provide sufficient information or consideration of the social context, in that it fails to take into account the Ku-ring-gai TOD alternative developed by the Ku-ring-gai Council in consultation with the Department of Planning. The site of the subject is outside the proposed high density area and is in fact in a low density area.
The proposal in incompatible with the heritage conservation area on either side Along McIntosh Street. It is surprising and poor planning that part of the subject land represents an interruption to the contiguous conservation area on the south side of McIntosh street.
The subject development is total out of character with the iconic Eryldene property located one residential property to the west in both scale and size. While some of the adjoining and adjacent buildings are not necessarily historic, they are at least of a compatible size and scale with extensive landscaping afforded by the lower density of development.
The height of the building will cause server overshadowing and deprivation of sunlight enjoyed at the adjoining property. The extent of the overshadowing is exacerbated by the additional temporary affordable housing bonus. I am not sure that this will be of comfort to the residents of these dwellings. The presumption provided in the report that they these properties will receive at least three hours of solar access at mid-winter. The report fails to indicate the amount of solar access they get presently and what they would get if there was no affordable housing bonus. This information needs to be provided for transparency.
The proposed development and others proposed and planned for the area will have an adverse cumulative impact on the local road network without significant additional infrastructure. Traffic in the vicinity of Gordon Station and the arteries between the East Gordon hinterland and the Pacific Highway are already problematic. I raise the following issues:
1. The traffic study ignores the function of McIntosh Street as one of the few routes connecting the East Gordon to Arterial Road via Arthur Street, Kylie Ave and Wattle Street.The Traffic Study, unlike the one submitted in respect of SDD-78775458 – (Residential Flat Building with In-Fill Affordable Housing – Park Ave Gordon), does not appear to recognise the arterial function of Rosedale Road between Park Ave and McIntosh Street.The proposed access point is too close to the intersection of Park Ave and McIntosh Street for access and entry to be permitted on an unrestricted/uncontrol basis to this “collector road.”
The cumulative increase in cueing times at the intersection of the Pacific Hwy and Park Ave for vehicles wishing to access the Railway car park (west side), but more importantly the Pacific Highway.
The affordable housing bonus does not compensate for the additional impact of the development on the community in perpetuity. The affordable housing proposal is inconsistent with the provisions of the Housing SEPP, in that, if the increase density permitted for affordable housing is 30% of the total development, then 50% of that needs to be for affordable housing, which according to S156 (2) needs to be managed by a registered community provider in perpetuity. The proposal is only to provide the affordable housing for a 15-year period, however, the bonus floor space will be in perpetuity. This is will clearly not contribute to long term housing affordability for service workers in the locality.

Points of Objection for Consideration by Adjoining Local Residents

· It is important for each resident/objector to provide a brief paragraph in any future objection as to how long the objector has lived in the immediate locality so as to hopefully demonstrate any points of objection are based on long term knowledge of the immediate locality. This point is very important to make as it is frequently the case that a long-term resident has greater knowledge than an outside consultant (including myself) of problems/concerns already existing in a locality which may be exacerbated by a proposed development. For example, issues such as traffic and parking and adequacy of services and facilities are a number of examples whenin a local resident/objector has an in-depth personal knowledge.

i. It is absolutely vital that each and every resident/objector only raise those points of objection that reflects the concerns of the individual resident. Local residents must not adopt a “scattergun” approach and only raise points of objection which accord with their personal opinions. In other words, each resident must focus on their individual points of objection.

ii. It is also vital for each resident not to adopt a proforma style reflecting the opinions of others. Each objection should be a personal objection and not copy the objections from other residents.

iii. An objection can not only include points of objection relating to impacts on individual properties but also include points of objection relating to impacts on the locality in general. For example, a particular impact may not directly impact the objector’s property but may impact the locality in general. For example, if an objector has concern relating to traffic and parking impacts arising from the proposed developments on the locality in general, this concern can be raised even though the property of the individual objector may not be directly impacted by traffic and parking concerns. In other words, it is valid for an individual objector to express concerns from a general “public interest” perspective even though a particular concern does not directly impact that objector’s property.

iv. As part of the process for each application, the Applicant is required to obtain from the NSW Government a set of the “Secretary’s Environmental Assessment Requirements” (SEARs’). Each application must address each “issue and assessment requirements” under the attached documents for the two applications. Each objector should examine the attached document and if an objector considers that the application do not address the SEARs’ requirements then the objector is entitled to say that each application is inadequate (or words to that effect).

· In terms of the attached SEARs’ documents, an objector should consider the following criteria and decide whether the applications address the address the following requirements contained in the SEARs’ documents:-

i. “5. Design Quality”. Of particular note is the requirement that a proposed development must achieve “a good design”. If the objector does not consider the proposed developments are “of good design”, the objector should say how each proposed development is not of a good design. If the objector considers that the proposed developments are of a good design, then obviously this issue should not be raised.

ii. In relation to “6. Built Form and Urban Design”, the 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. If the objector considers these criteria are met, then an objection should not be raised on this issue. If the objector considers that these criteria are not met, the objector should say how the proposed developments do need meet these criteria.

iii. “7. Environmental Amenity”. This requirement requires a proposed development to address “amenity impacts”, such as Solar Access, Visual Privacy, View Loss, View Sharing and the like. Objectors should assess whether the proposed developments impact their individual properties in terms of the above criteria. If an objector considers that the objector’s property is adversely impacted, then there should be no objection raised on this issue. If, however, the objector considers that his/her property is impacted, then the point of objection should be raised. I note that the attached SEARs’ documents require each proposed development to achieve a “high level of environmental amenity from any surrounding residential or other sensitive land uses”. (emphasis added).

iv. “8. Visual Impact”. An objector should consider the Visual Impact on his/her property and if the objector is concerned with the proposed Visual Impact, the issue can be raised. It is important to note that an 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.

v. “9. Transport”. This requirement relates to a Transport Impact Assessment and a Construction Traffic (or Transport) Management Plan. Adjoining residents are well aware of the traffic and parking circumstances within their immediate locality and it is important that local residents raise matters of concern relating to existing traffic and parking which may be exacerbated by the proposed developments. It is highly likely that adjoining residents will have a greater knowledge of the traffic and parking circumstances in the immediate locality. If a resident considers that a proposed development is likely to exacerbate existing traffic and parking concerns, then this issue should be raised.

vi. “10. Noise and Vibration” relates to noise and vibration associated with construction and operational noise and vibration. If an individual objector’s property contains “sensitives receivers and structures” this issue can be raised. For example, if an adjoining property contains a childcare centre or the like then I would regard such a use as being “sensitive receiver”.

vii. “11. Water Management”. This issue relates to stormwater disposal and water quality management issues. Again, similar to traffic and parking, a resident may have evidence that the existing stormwater and wastewater systems are inadequate and that the proposed developments will likely exacerbate this likely inadequacy. If there are Council report(s) which confirm the current inadequacy of services, reference should be made to the Council report.

viii. “13. Contamination and Remediation” is an issue which is normally assessed by an appropriate contamination expert as a result of appropriate bore hole investigations and investigations of past uses on the subject site.

ix. “14. Trees and Landscaping” relates to impacts on existing trees and the required landscape plan. If a resident has a concern about likely tree loss and/or proposed landscaping, then this issue should be raised. Clearly, one of the wonderful features of your locality is its tree canopy. A significant loss of trees is obviously of concern.

x. “15. Ecologically Sustainable Development” requires ESD elements to be included in the proposed developments.

xi. “16. Biodiversity” relates to the issue of biodiversity provisions which should be included as part of the proposed developments.

xii. “17. Waste Management”. The issue of waste management can be the subject of points of objection if a resident has evidence of inadequate waste management provisions within the locality.

xiii. “18. Social Impact” relates to impacts generated by the proposed development in terms of social impact.

xiv. “19. Flood Risk” relates to flood risk. Evidence from an adjoining objector relating to past flood events and the likely impact of the proposed developments on flood risk can be raised as an issue.

xv. “20. Bushfire Risk” is unlikely to be an issue in dispute.

xvi. “21. Aboriginal Cultural Heritage” will only arise if there are elements of Aboriginal Cultural Heritage on or near the subject site.

xvii. “22. Environmental Heritage” relates to the impacts of the proposed developments on any elements of Environmental Heritage or Archaeological Heritage. This issue will only arise if the proposed developments are in proximity to adjoining Heritage Items, Heritage Conservation Areas or are within proximity of such items.

xviii. “23. Public Space” relates to public space provided as part of each proposed development. Issues such as the adequacy of the proposed communal open space area on the subject site and proximity to public open space in the locality can be raised. In relation to proposed communal open space on each of the development sites, the quality and area of the proposed communal open space can be raised if there is a concern. The objector should mention why the proposed communal open space on the subject site is of concern. In relation to proximity to public open space (that is parks), as a general guide, a walking distance of 400m is a general benchmark for public open space.

xix. “24. Hazards and Risk”. This requirement only arises should there be dangerous goods storages or underground high-pressure dangerous goods pipelines in the vicinity of the subject site. If an adjoining resident is aware of a hazard or risk which may impede the proposed developments, then this should be raised.

· Thus, the attached SEARs’ documents set out the requirements for assessment, but if a resident is aware of any other Planning matter which may be of concern, such matter can be raised, but the resident must provide well founded points of objection.

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9 September 2025