Skip to main content

State Significant Development

Response to Submissions

Greenwich Hospital Redevelopment - Detailed Design

Lane Cove

Current Status: Response to Submissions

Interact with the stages for their names

  1. SEARs
  2. Prepare EIS
  3. Exhibition
  4. Collate Submissions
  5. Response to Submissions
  6. Assessment
  7. Recommendation
  8. Determination

Construction of a replacement hospital building complex, with integrated serviced seniors living buildings and a respite care facility.

Attachments & Resources

Notice of Exhibition (1)

Notice of Exhibition

Request for SEARs (2)

Scoping Report - 97-115 River Rd Greenwich
Attachment A - Preliminary Plans

SEARs (1)

SSD-13619238 Issued SEARs

EIS (48)

_Environmental Impact Statement
Architectural Plans
B_Urban Design Report
C_Secretary's Environmental Assessment Requirements
D_Landscape EIS Report and Plans
E_Construction Management Plan
F_Schedule of Conservation Works
G_Heritage Interpretation Strategy
H_Vegetation Management Plan
I_Biodiversity Development Assessment Report
J_Consultation Outcomes Report
K_Traffic and Parking Assessment
L_Green Travel Plan
M_Archaeology Updated Impact Assessment
N_Heritage Impact Statement
O_Updated Aboriginal Archaeological Impact Assessment
P_Visual Impact Assessment
Q_Wind Cover Letter
Q_Wind Study
R_Tree Impact Assessment Report
S_Tree Pruning Specification
T_Additional Site Investigation
U_Remediation Action Plan
V_Hazardous Building Materials Survey
W_Additional Geotechnical Investigation
X_Acid Sulfate Soil Assessment
Y_Salinity Investigation
Z_Noise and Vibration Impact Assessment
AA_Services Infrastructure Report
BB_Stormwater Management Report
CC_Flood Assessment
DD_Accessibility Report
EE_Waste Management Plan
FF_Crime Prevention Through Environmental Design
GG_Preliminary Dangerous Goods Screening Report
HH_Bushfire Protection Assessment
II_Lighting Statement
JJ_ESD Report
KK_Structural Statement
LL_Social Impact Assessment
MM_Quantity Surveyor's Report
NN_Site Survey
OO_Site Survey - Supporting Letter
PP_Road Safety Audit
QQ_Supplementary Visual Imapct Assessment
RR_SDRP Meeting Notes
SS_Section 10.7(2) and (5) Certificate 1
SS_Section 10.7(2) and (5) Certificate 2

Response to Submissions (1)

Request RTS Letter

Agency Advice (6)

TfNSW advice
DPE Water advice
HNSW (ACH) advice
Council submission
EHG advice
Sydney Water submission


Showing 1 - 10 of 10 submissions
Sydney Water
Parramatta , New South Wales
see attached
Name Withheld
Lane Cove , New South Wales
see attached
Lynne McLoughlin
Lane Cove , New South Wales
see attached
Name Withheld
Please refer to attached pdf file, 12 pages
Name Withheld
I object to this application and our comments are submitted on the attached files.

This submission is to be provided in lieu of my earlier submission provided for both SSD-8699-Mod-1 (concept mod) and the SSD-13619238 (detailed design).

The attached photo images show the full screening of our house from the Hospital provided by the vegetated embankment until it was completely cleared earlier this year. The images of the CAD drawings are from a 3D CAD model drawn up using the Hospital's documentation and go towards showing the excessive overviewing created by the Detailed Design.
Northwood Action Group Inc
NORTHWOOD , New South Wales
The Northwood Action Group Inc (aka NAG) is an active community group that delivers its newsletters to some 300 households in Northwood. NAG wishes to respond to the Environmental Impact Statement and other material lodged with the Department of Planning and Environment by HammondCare in relation to Detailed Design SSD 13619238 and Section 4.55(1A) Modification Application Concept Plan SSD 8699. Our objections for both SSD 13619238 and SSD 8699 are common and each objection lodged is identical as both development applications only relate to the Greenwich Hospital Development.
Our objections to SSD 13619238 and the current SSD 8699 are as follows:
1. This development should be separated into two distinct developments. Its predominately a multi-dwelling high rise housing development and a separate upgraded Hospital and ancillary care, not only a Hospital with ancillary Health Care Facilities. We ask that the approving authority reconsider the position that was previously taken in that this whole development was deemed an integrated health campus and separate this development into two parts.
Over 45% of the proposed FSR has been allocated to private apartment development. The very size of the private apartment component of this development clearly shows that there are two separate developments, and we ask the approving authority to treat this as is it clearly is:
a. A new Hospital with associated services such as dementia care and respite services.
b. Two senior living apartment towers
The purpose and use of the Hospital and the related Health facilities are clearly distinct from Seniors Living apartments. Further, the modifications proposed to the approved concept plan make the two senior living towers even further removed from being ancillary to the new Hospital. The adding of 15 three bedroom apartments shows clearly that the apartment towers are designed for long term residential use.
The convenient ploy of linking the car parking facilities for the two developments doesn’t make it an integrated campus. ‘Hospital in the Home or ‘Age in place’ is able to be provided in any independent residential development. Simply co-existing adjacent to a hospital does not change its nature.
One other argument raised by the proponent is that the funding for the hospital can be undertaken at least in part because of the funding generated by the residential towers. This funding rationale is not an argument to link the two developments as an integrated campus.

2. The proposed modifications increase the number of bedrooms by 22% from what has been approved in the Concept Plan. This intensification of use should not be allowed by the approving authority.
The modifications proposed are a blatant push to over-ride the approving authority requirement to lessen the bulk and scale that it approved previously. The arguments from the proponent that this is an immaterial change should be rejected. A 22% increase in the number of bedrooms is a major change to the proposal and should lead the approving authority to review the entire proposal as well as its prior approval. Further the introduction of fifteen 3 bedroom apartments change the nature of the apartment towers and the bulk and scale should be scaled back.

3. Permanent loss of land zoned SP2 infrastructure, for Health Services Facilities
This land has special purpose zoning benefits by virtue of its zoning use. Once this land zoning is over-ridden/ignored and used for privately occupied residential apartments, whether under a loan license agreement or other title type, or within any further subdivision, the land is permanently unavailable for the purpose for which is intended, i.e. Health Services Facilities. We also wonder whether one of the reasons HammondCare is going to use a licence model for the Senior Living Apartments is that this facilitates the saleability of an entire apartment building. The recent sale of the 99 year lease of 266 Longueville Road by Australian Unity to a developer could be a precedent. The modifications proposed to the approved concept plan further strengthen the argument that this will be a loss of land zoned for Health Services as the residential apartments are clearly for long term residential use akin to the surrounding area and not used for SP2 purposes.

4. Character of Multi-dwellings is inconsistent with LEP and desired character and feel of all surrounding residential zones R2
The Lane Cove LEP prohibits multi-dwelling housing in R2 Low Density Residential Zone. The entire area around the hospital site is zoned R2 and consist of low density residential properties. Not only is high rise residential development contrary to all the properties around this site, the skyline from Bob Campbell Oval and Gore Creek reserve will be dominated by these two residential towers.

5. Environmental Damage to E2 zoned bushland Reserve and waterways and community assets including Bob Campbell Oval is threatened by the two high rise senior living towers and associated underground works and access roads on the edge of this E2 land. This is exacerbated because of the intense slope from the site though the bushland reserve.
The Gore Creek Reserve adjacent to the Greenwich Hospital site is a key access corridor for native animals and birds to access the greater Lane Cove National Park. The Gore Creek Reserve provides direct access for animals and birds to connect from the Lane Cove National Park to the Harbour. A good example is the pair of breeding goshawks and their offspring that are currently nesting in the reserve. These beautiful animals have frequented the reserve over the last few years and continue to raise their young in the warmer months. These birds featured in the Lane Cove Bushland publication ‘The Golden Whistler’. These hawks are in addition to the more traditional bushland inhabitants such as powerful owls and tawny frogmouths that use the reserve as their wildlife corridor.

There appears to be no detailed environmental plan to rehabilitate bushland in the South Western portion of the site. It is stated that the area is weed infested and too difficult to survey. Refer to the letter from LTS Registered Surveyors. The proposal appears to be misleading in their bushland management, because there doesn’t appear to be any bushland management plan. How is the duty of care during construction and future management of the bushland corridor adjoining the site being managed? There is a lack of information as to how this bushland corridor will be preserved.
It is also stated in the Environmental Impact Statement, that ‘Vegetation Removal and Protection’ (p13), that the design will be integrated into the landscape. What is planned apart from around the hospital site itself? Surely if this development sits on the edge of a bushland corridor then it sits within the bushland landscape. There is clear duty of care to work with council staff and bushcare groups to maintain and protect this area for the future. We ask that a biodiversity study on the reserve be caried out and an arborist report on existing trees on the South Western slope that adjoins the Gore Creek wildlife corridor.

We would also like to know what provisions will be put in place to protect the bushland corridor during site preparation works, demolition of existing buildings and construction. Given the damage to bushland behind the Pathways development site at 4 Northwood Road the community is very concerned about what safeguards have been put in place to protect the Gore Creek wildlife corridor. We see a lot of words but little detail.

The Gore Creek Reserve is of immense value for Lane Cove particularly with as a buffer against continuing further development in the area. We must preserve the existing bushland and its flora and fauna and not allow development along its border as envisaged by the hire-rise residential towers in the Greenwich Senior Living proposal.
6. Negative impact of Loss of Trees on and off the site compounding effect of Reserve tree death
Many mature trees are planned to be removed from the site. Although the proponents are planning to replace these trees, it is impossible to replace a mature canopy of trees. Any loss of mature trees impacts the core bushland corridor that currently exist on the western and southern boundary of the site and in the bushland zone E2 land which fills the area between the hospital site and Bob Campbell Oval. Currently the proposal notes that 85 trees will be removed from the site. The removal of these trees will be a loss that will take a generation to recover and worsen the visual and noise impact from the site.

7. Bushfire Prone land: danger to persons, subject site, nearby sites, public assets and infrastructure
The south-western Seniors block is on bushfire prone land and the proposal states that the proposal is ‘capable of compliance with the relevant bushfire requirements’. This proposal should not be approved where a development is only ‘capable of compliance’. It should be a requirement that a detailed fire assessment is conducted on bushfire prone land prior to any approval of a detailed design proposal. It is illogical to finalise the detailed design plans and then complete the bushfire assessment. We ask that the approving authority require the bushfire assessment be completed before it finalises the assessment of this DA.

8. Adverse impact on Traffic and local road network due to site intensification and the accumulated impact because of other high rise developments along River Road/Northwood Road.
The adverse impact of traffic on the area because of the modifications to the proposal and the accumulated impact of other high rise developments have not been considered in its entirety. The traffic assessment should be conducted to understand the cumulative effect of St Leonards South, 266 Longueville Road, 4 Northwood Road, Sports and Recreation Precinct which all have significa
LANE COVE , New South Wales
Please find attached submission.
Sincere regards

Chris Shortt
Senior Town Planner
Lane Cove Council
Name Withheld
GREENWICH , New South Wales
I am writing as a close neighbour of the proposed development.
Though we are broadly aligned with the concept, we still have a number of concerns associated with the project.
Privacy - we were kindly visited by a Hammond Care representative in April who walked through the details of the project and outlined the impacts to our property. We requested Drone imagery to understand the view the top levels of the proposed buildings would have into our back yard. As the mother of 2 young girls in a property with a swimming pool, it brings great discomfort to know our private family moments could be visible to the outside world. We have not yet received the images despite the request being made in April and many follow ups and so our privacy concerns still stand.
Could we understand what is being done from a building side to minimise the visibility into our backyard - whether that be placement of windows, or shading/shutters to reduce the visibility into our property?
We are still awaiting the drone images to understand the real privacy risk we are facing.
Construction - I understand the length of time of build will be around 5-7 years. This is an extremely long time for disruption to our lives especially with some hours of construction on the weekend. Even the week day hours will be noisy while working from home. Given the length of time, what mitigation plans have to put in plan to minimise the impact on the immediate neighbours. I would request and suggest a minimal of double glazing on the neighbouring properties to atleast reduce some impact while in their homes. I assume not much can be done for the impact while we are in our yards.
Are we able to understand the impact of dust and construction residue on neighbouring properties and what is being put in place to minimise that?
Additionally, given the length of time - are we able to consider the stages of the building concurrently, rather than consecutively to try and reduce the number of years of disruption. For this length of time, the construction will also be spanning major exams of my children and will be a distraction we would like to minimise.
Given the hours of construction between 7:30 and 5:30, I'm concerned about the impact on traffic on River Road. River Road is already at close to stand still traffic from 8-9 heading into the city and 5-6 heading back. Is there mitigation plans of other roads being planned to be used particularly during this peak traffic time on River Road?
Parking - Though the hospital provides a car park, as this is paid, we are concerned about the spillover of cars into the side streets. At the moment River Road is unrestricted parking and as residents, we would like to keep it that way as on the weekends our guests have somewhere to park. At the moment, parking on River Road during the weekdays is extremely rare (though legal) as it is an inconvenience to drivers especially during peak times. The residents respect this and so do not park on River Road in general and as a result are able to enjoy parking on the weekend when it is not inconvenient to drivers. The other benefit to the parking on RIver Road is that is assists with school pick ups and drop offs for Greenwich Public School.
If the paid parking pushes cars onto River Road the concern will be that the ability for free parking we currently have may be limited. This will have an adverse affect on the livelihoods of the neighbours and school. What plans are in place to ensure that parking does not spill over to River Road? Will there be free parking available so the side streets are not filled with hospital visitors?
Thank you for your consideration on some of the issues still outstanding for us regarding this propsal. Hope to hear from you soon.
Longueville (NSW) Residents Association Inc
LONGUEVILLE , New South Wales
The Longueville (NSW) Residents Association Inc wishes to object to the increase in the GFA of the proposed development on the following grounds:

1. Contravenes the condition of consent in SSD8699
2. The increase in the GFA of the development results in a larger bulk to the buildings
3. An increase in the GFA of the seniors living buildings will result in more vehicular traffic, noise, light spill and loss of amenity to surrounding properties.
4. The proposed increase in GFA (2,403m2) results in a site FSR of 0.8:1. The surrounding FSR is 0.5:1. This is 37.5% above the surrounding permissible FSR.
5. The proposal to increase seniors living units from 75 to 89 with 15 units to be 3 bedrooms. This results in a 19% increase to the number of units.
6. The applicant has not justified the reasoning behind building 3 bedroom units in seniors living and aged care facility where the average number of occupants to a dwelling is between 1 and 2. We see no justification for building 3 bedroom units at an aged care/seniors living facility.
7. The applicant has relied on outdated TfNSW traffic data from May 2021 to assess the traffic movements along River Road. We require a new traffic study be undertaken.
8. The visual impact on surrounding homes will be greater should the modifications be approved. We require further planting and privacy screening to reduce the impact on surrounding homes.
9. We require an Cumulative Impact Assessment (CIA) to be undertaken to determine the cumulative impact of the Greenwich Hospital and other developments currently proposed and under construction along River Road between Greenwich and Northwood. These include 266 Longueviile Rd, 4-18 Northwood Rd, Sport & Recreation facility at Lane Cove golf course, St Leonards South master plan and Greenwich Manor (cnr River Rd and Greenwich Rd) to name a few. The applicant may say it is not mandatory for them to prepare a CIA but the surrounding residents and local community say it is absolutely necessary as we will have to live with the consequences of this and the other developments for years to come.
10. It is our view that the proposed modifications which are namely an increase in the GFA are primarily designed to improve the profit return to the applicant. This in our opinion is not a valid reason to approve the changes proposed.

Yours sincerely
Longueville (NSW) Residents Association Inc
Name Withheld
GREENWICH , New South Wales
To Whom it May Concern,
I am a resident of St Vincents Road, Greenwich and will be directly impacted by what is eventually approved at the site of the redevelopment of the hospital. While I do not object to the concept of redevelopment of the site, I must comment on the severe disregard for the bulk and scale of the surrounding area that is Greenwich.
Greenwich is a suburban area with a strong dominance of trees over built form. We in Greenwich have specifically selected to live in this area due to this neighbourhood character. Furthermore, Greenwich is a smaller suburb with narrow streets. All of these elements appear to have been completely overlooked during preparation of the scheme for the hospital.

Firstly, I wish to object to the large number of trees proposed for removal adjacent to St Vincents Road in order to accomodate the new proposed Respite building. These trees offer the residents of St Vincents Road a large quantity of screening from the hospital as well as noise from River road. With the proposed removal of trees, not only will the new building become far more dominant visually for the residents, the proposal also includes a new building in this area meaning that the vegetation will be significantly disrupted and our privacy will be severely impacted.

Secondly, I wish to object to the respite building in this location. With the large bulk of the other areas, it seems unnessecary to encroach on the St Vincents Road residents with another building, closer than the existing campus of the hospital. This area should be preserved as bushland to afford the area the bushy character it currently posesses.

Thirdly, I wish to object to the overall bulk of the main building. St Vincents road generally has a 4 storey height limit, yet this building is far taller than this overall scale, making this unsatisfactory in its environment. St Vincents road is located at the base of two ridges, in a gully and a lot of our natural light is blocked by the eastern hill. We luckily receive significant western sunlight currently, which will be lost due to the dominating overbearing nature of the new development. I would propose a minimum of 2 storeys should be lost from the main building to bring the height in line with the surrounding structures. I also believe a large increase in vegetation is required to screen the building from river road and St Vincents road.

Finally, I would like to object to the general impact of this structure to the area. St Vincents Road is already overrun with staff and visitors parking for the hospital. This would only worsen should the hospital size be increased at this scale. River road is already a terrible road for traffic between the hours of 7:30am-10am and 3:00pm-7pm. With the increased traffic and pressure from the additional staff and visitors attending the hospital, significant road widening and traffic engineering would be required to resolve this issue ahead of any approval. Furthermore, the public school students cross the driveway to the hospital regularly to get to and from Greenwich. When additional cars are using this driveway for access, there will need to be resolution as to how to protect the safety of the children.

To conclude, the hospital bulk and scale is far too out of character for the area to be approved in its current form. I believe that the proposal should preserve the trees along the St Vincents road boundary, and be reduced in height by a minimum of 2 storeys. I also believe significant road works would be required to ensure safety and flow of traffic. Therefore I hope you reject the proposal in its current form

Thankyou for your time,


Project Details

Application Number
Assessment Type
State Significant Development
Development Type
Hospitals, medical centres and health research facilities
Local Government Areas
Lane Cove

Contact Planner

Megan Fu