Sydney Metro Pitt Street (South) Over Station Dev.

RE: Sydney Metro City & Southwest - Pitts Street (South) Concept
Development application for Over Station Development - SSD 8876

I write to express my significant concerns and objection to the
proposed Sydney Metro City & Southwest - Pitts Street (South) Concept
DA - SSD 8876.

I am a resident in the adjacent building "the Princeton" located at
304-308 Pitt Street, Sydney. The proposed concept development which is
currently on exhibition is a gross over development and will impact
the living amenity of residents in the Princeton through the loss of
privacy and solar light access to living areas.

The Secretary's Environmental Assessment Requirements ("SEAR") clearly
outline that the applicant was to address all Environmental Planning
Instruments ("EPI") including, but not limited to SEPP 65 - Design
Quality of Residential Flat Development and the Apartment Design Guide
("ADG"), Sydney LEP 2012 which is informed by the City of Sydney DCP
2012. Despite these clear instructions the applicant has conveniently
decided not to address the aforementioned EPI's or has concluded that
they simply will not comply. The SEAR's also outline in point 6
"Amenity" that the EIS shall "demonstrate the impacts of the proposal
on the amenity of surrounding residential development including
measures to minimise potential overshadowing, privacy and view
impacts". Whilst the impacts of the proposal on the amenity of
surrounding residential development has been demonstrated for Solar
Light access, the applicant has elected not to minimise the impact of
overshadowing or loss of privacy through reductions in the bulk of
building mass, or by increasing the separation between the proposed
development and existing residential development to the suggested
18-24 metres as prescribed by the ADG for building heights over 9
storeys, and the 12-18 metres from levels 5 to 8.

The ADG's state that the separation requirements are a minimum, they
are not a set-back provision and as such the full minimum separation
distance should be enforced so as to achieve the objectives of good
urban form and amenity within existing and proposed apartments.

Apartment Design Guide - Non compliance

Having reviewed the proposed concept it is clear that the following
elements have not been addressed and hence render the concept proposal
non-compliant when assessed in terms of the ADG:

ADG 3B - Overshadowing of neighbouring properties is minimised during
mid-winter. The Solar access studies undertaken by the applicant show
that currently Princeton apartments have 62 out of 116 apartments
achieving 2 hours of solar access to 1sqm of living room area between
9am and 3pm on the 21st June. Should the proposed concept be approved
in its current form this will see an additional 57 apartments lose
their 2 hours of solar access to 1sqm of living room area, at the 21st
June, reducing solar compliance for Princeton to 5 apartments out of
116 apartments. Simply put only 4.3% of the apartments in Princeton
will receive the required solar access as asserted by the ADG causing
a significant impact to the amenity of the residents at Princeton.

Further the ADG's stipulates that a proposed building should NOT
reduce solar access to more than 20% of neighbouring properties. The
proposal clearly non-compliant with this criteria proposing to reduce
solar access by more than 95% to existing residents in the Princeton
who currently receive 2 hours of solar access to 1sqm of living area
as at 21st June.

ADG 2F - Building Separation. Minimum building separation for the
proposed concept plan should be 18-24 metres for all levels above
level 9 and 12-18 metres for levels 5 to 8. Given Princeton apartments
have north facing habitable rooms/balconies, 18 metres would be the
required building separation should no habitable rooms/balconies be
south facing on the proposed concept development, however if habitable
rooms/balconies are proposed on the south facing façade of the
proposed building separation should be increased to 24 metres. The
proposed separation of 12 metres at the higher level, and 3 metres at
the lower level of 5 to 8 is insufficient to provide adequate privacy
and amenity and would significantly impact residents in Princeton. The
3m metre and 12 metre separation would also be non complaint with ADG
3F.

City of Sydney DCP 2012 - Non Compliance

As illustrated above there are significant impacts on the Amenity of
Princeton residents in particular in respect of privacy and solar
access which have not been enhanced as required by clause 4.2.3 of the
City of Sydney DCP 2012, and loss of solar access required by clause
4.2.3.1 of the City of Sydney DCP 2012.

Heritage Impact

The proposed development significantly impacts the existing Edinburgh
Castle Hotel which is listed as a Heritage item on the City of Sydney
LEP 2012. The proposal will dwarf the current heritage site, as the
proposal does not propose any setbacks from the Edinburgh Castle Hotel
as required under the City of Sydney DCP 2012.

Hyde Park Overshadowing

It should be of significant concern that the concept proposal will in
fact add additional overshadowing of Hyde Park as outlined in the
applicant's own Shadow study. Further overshadowing of Hype Park
should not be permitted as this would not only constitute additional
non-compliance with the Sydney LEP 2012 and the sun access plane
limits as outlined in clause 6.17 but would also have a considerable
detrimental impact on public amenity enjoyed by thousands and the
historic War Memorial.

Given Pitt Street South OSD proposal does not fall into Category A or
B under the provision of 6.18 and 6.19, there should be no additional
overshadowing of Hyde Park.



Meeting Representatives Sydney Metro

The above concerns have been brought to the attention of the
representatives of the Sydney Metro in a meeting held on 4th September
2018 at Princeton apartments. Unfortunately our concerns were
dismissed by the applicants representatives simply saying that we
could not expect to maintain solar access and privacy when living in
the CBD despite planning controls in the City of Sydney DCP, ADG's and
the SEAR's suggesting that these issues were to be minimised as part
of any proposal. They further suggested that as our building was built
to the boundary they were not required to provide the full separation
as per the ADG's, which is incorrect given the objectives of the ADG's
and recent case law in Land & Environment Court decisions.

Consultation

It is extremely disappointing that the state government continuously
promotes community consultation however does not practice what it
preaches. Community consultation is not presenting the final plan for
which the community has not been consulted on to determine what is
important to us. Community consultation is engaging the residents and
stakeholders and working closely with them to determine the best
outcome for all. We are seeking the applicant (government authority)
to undertake more community consultation specifically with the
residents who's amenity through the loss of privacy and solar light
are currently most impacted by this proposal. This is what should have
taken place initially but never did.


I strongly object to the proposed concept Over Station development at
Pitt Street (South) and request the proposal be amended to comply with
planning controls and that certain elements of the south east portion
of the proposed development envelop be removed so as to increase solar
access to Princeton apartments. In addition to reduction in mass of
proposal, the envelope of the proposed building should adopt the
minimum separation requirements as per the ADG's so as to reduce the
significant impact on the amenity of Princeton apartments and their
residents through the significant loss of solar light access and
privacy. The reduction should also ensure that there is NO additional
overshadowing impact on Hyde Park and the area surrounding the war
memorial.

Please confirm receipt of this submission.

Dear Sir / Madam

Thank you for considering my below concerns regarding the proposed
development at 302 Pitt St.

My home is in unit 64 on Level 24 of 304-308 Pitt St (The Princeton),
and my apartment faces both East and North. As such, I currently enjoy
significant amenity from both sunlight and a city-wide view to the
North, which will be lost should the development proceed as planned.

Of general concern, is that documents describing the proposed
development significantly understate impact on my apartment as
detailed below, while there are further adverse effects seemingly not
considered in the available development documents. I am sure that
similarly negative impact will be experienced by all identically
orientated apartments in my building, comprising about one quarter of
residences. The same effects will impact my neighbors with apartments
on the direct North side of the building, so that considered together,
at least one half of residences will be badly affected, while another
quarter of residences facing West, will also have some loss of
amenity.

1) LOSS OF DIRECT SUNLIGHT AND EFFECT ON HEATING, LIGHTING,
ELECTRICITY USE, AND CARBON FOOTPRINT
The development will block all currently enjoyed Northern sunlight.
Current direct sunlight to my apartment permits minimum heating during
winter, with heaters only needed later in the day when existing
shadows are cast across my Northern windows. Direct sunlight also
reduces electricity use for lighting. The shadow cast by the proposed
development will require greatly increased electricity use for heating
and lighting, increasing the carbon foot print of my building at a
time that efforts should be directed towards reducing the use of
energy.

2) CURRENT DEVELOPMENT DOCUMENTS DO NOT CONSIDER LOSS OF INDIRECT
SCATTERED LIGHT, GREATLY UNDERESTIMATING IMPACT OF THE DEVELOPMENT
in addition to direct sunlight (1 above), I currently enjoy
substantial illumination from indirect light scatter from buildings
and the sky to my North. My North-facing living room windows don't
have direct sunlight in the afternoon, but there is still enough light
scatter to cast a shadow. Even towards sunset, enough light is
scattered into the room to see quite well. As such, I currently
harvest scattered light from across much of the city, but the proposed
building would reduce this to what little light might find it's way
down the shadowed Southern side of the new construction.

The effect is that it would be very much darker. Because of this, the
limited shadow analysis in the current proposal, greatly understates
the impact of the new development for all apartments with light from
the North. Notably, proposal documents suggest that only 'some'
apartments in my building would be affected. In practice, all
apartments with Northern light, that is about 75% of apartments, will
be adversely affected by loss of both direct and indirect scattered
light.

3) LOSS OF A CITY VIEW WILL REDUCE MY ENJOYMENT AND SENSE OF HUMAN
CONNECTION
I gain daily pleasure from my Northern view of the city. One reason I
moved to the city from my previous home in the suburbs, is that I
enjoy the sense of anonymous connection and belonging, that comes from
hubbub of city life. Whether rising in the morning, or walking through
the door at the end of the day, it is a joy to look out my windows,
and see myself part of the living city. During day, the signs of
people going about their business are everywhere, while at night,
office and apartment lights wink on and off, patterning the darkness
with human activity. This is a significant enjoyment I would lose,
were that outlook lost to the proposed development.

4) INADEQUATE SEPARATION FROM THE PROPOSED DEVELOPMENT
In addition to concerns outlined above (1 to 3), the proposed
development places the wall of the new building exceedingly close to
my own apartment. This would minimize direct and indirect light entry,
to very low levels. There may also be a negative effect on privacy,
currently largely protected by the distance from other windows in
other buildings.

5) MACHINE NOISE FROM THE NEW DEVELOPMENT AND IMPACT ON VENTILATION
There is currently significant noise from air conditioning machinery
in adjacent buildings, but the current separation from those buildings
makes the impact bearable. Were similar air conditioning installed on
the lower levels of the proposed development, as seems to be currently
planned, the close proximity of the building to my own windows would
raise noise levels to seriously unpleasant levels.

This would likely not be sufficiently ameliorated by closing the
windows alone, while doing so would prevent me from exploiting the
afternoon sea-breeze for ventilation and cooling, necessitating use of
energy consumptive air-conditioning. With regard to this, the new
development would likely disrupt airflow, further impacting
ventilation of my home.

6) REDUCED LIVABILITY OF THE CITY - A POOR PRINCIPLE AND OUTCOME FOR
DEVELOPMENT
From the above, the current development proposal badly underestimates
the negative impact of the development, and will reduce overall
livability of the city for about 75% of residences in my building
alone.

This must be seen in context of further large developments for
residential apartments in the immediate area, where the impact of this
new large development cannot yet be properly assessed because there
are no current residents available to consider impacts and express
concern.

Given efforts to make the centre of Sydney more attractive for
business and residence, the excessive infringement on livability that
the proposed development imposes on my own building, as well as on
others near by, sets very poor precedent for Sydney development, and I
believe will have the ultimate effect of reducing interest in CBD
living and investment.

I do believe that a more enlightened and considerate approach to
development, that takes proper and thoughtful account of the impacts
on, and needs of established residents, is required for successful
long-term development of the CBD. The current proposal, falls well
short of that level of consideration.

I object to the design of the application by Sydney Metro.

The government is using the Sydney Metro project as an excuse to
overdevelop land and air above planned stations.

This is exactly what happened earlier this year when the government
gave Sydney Metro special developer status and approved non-compliant
towers above the Martin Place station.

I STRONGLY believe that the planning approval for two towers over the
Pitt Street station should not be approved. The towers will introduce
significant shadowing from Autumn to Spring on Hyde Park in breach of
the LEP sun access plane designed to stop shadow creep on this
important public park from future CBD towers.

Alarmingly over a hundred homes in adjacent buildings will lose almost
all their winter sunlight.

This is an absolute disgrace. Sydney Metro should be ashamed at the
adverse impact they are leaving on the local community in respect of
this irresponsible overdevelopment.

The design of the overstation development in its current form should
be amended so that:

1. There are sufficient set backs

2. There is a sufficient separation of 18m-24m between Princeton Tower
and the overstation development (per Apartment Design Guidelines 2F)

3. More solar access for the residents at Princeton Tower instead of
what is contemplated in the current Solar Access Impact Study

4. There is less shadowing for the residents at Princeton Tower by
reducing the height and width of the proposed building so that it
complies with overshadowing requirements under Apartment Design
Guidelines 3B

Squeezing a large tower into a small space with insufficient setbacks
and insufficient separation between the neighbouring buildings is
reckless.

If Sydney Metro's application proceeds in its current form, it will
make them no better than a money grabbing selfish property developer.

I am an owner at 308 Pitt Street which neighbours the proposed
development.

Sydney Metro should respect good planning principles and be a good
neighbour.

They should not be using the Metro Station as an excuse to become a
greedy, reckless, profit driven developer in an attempt to offset the
development costs of the Metro. The size of the tower is the largest
possible shape they can cram onto the site.

Just because the government has a history of going overbudget with its
developments does not mean that they should try and recoup their
losses by taking as much airspace and land space as possible.

Sydney Metro's design will mean that over a hundred homes in adjacent
buildings will lost the majority of their winter sunlight. This was
admitted in Sydney Metro's Solar Access Impact Plan.

We can't let Sydney Metro just admit that they will block the light
from all these homes and do nothing. Where is the justice?

I am also shocked that Sydney Metro's design allows significant
shadowing on Hyde Park which is in breach of the Sydney LEP 2012 sun
access planes. Their own shadow study admitted that from Autumn to
Spring after 2.30pm, there will be reduced sunlight. This is wholly
unjust and unacceptable and must be stopped.

The objections to this development must be heard and published so
everyone can see the terrible impact of this overdeveloped
overstation.

Please do not approve such a high rise building with such a large
width right next to my home at 308 Pitt Street, enough is enough!!!

It is unnecessary to build so close to Princeton Tower. There must be
at least 18 metres to 24 metres worth of building separation between
my home and the new building.

Please respect the privacy of adjoining owners who work hard for a
living and own apartments in the CBD. It is horrible to think that
another building so close can look into our living rooms and bedrooms.
At least make Sydney Metro's building 18metres to 24 metres away as
per the Apartment Design Guidelines 2F.

There is no housing shortage in Sydney CBD. Developers and real estate
agents are finding it tough to sell apartments so why do we need to
build more in a site where it will ruin the amenity for hundreds of
adjoining residents?

I must add that we are also living near so many heritage listed items
such as the Sydney Water Board, former Speedwell house, City Fire
Station and Edinburgh Castle hotel.

The site is surrounded in heritage and sites of cultural interest. We
must protect our heritage by saying no to the current design of this
application until the above issues are addressed and properly dealt
with.

I object to the design of the building. It is too bulky and has too much
mass. The proposed overstation is overbearing and out of scale for
such a small site. Why does the overstation need to be so tall and so
wide?

This part of Sydney CBD has historically not been the home of
high-rise atrocities and should remain that way in order to preserve
the beautiful character of this pocket of the CBD. The Queen Victoria
Building, St Andrews Church, Edinburgh Castle Hotel, the Fire Station
on Castlereagh Street, the ANZAC War Memorial building and Townhall
are in very close proximity of the site and are all very low
buildings. Why would we now cram another unacceptably high density
over developed overstation above the Metro? It makes no sense to
increase the shadow creep over these beautiful historical buildings,
especially when we are so near Hyde Park.

There will be an adverse effect on the residential amenity of
neighbours. I own a unit at Princeton and know that if this
development is approved, all residents in our building will suffer
noise, disturbance, overlooking, loss of privacy and overshadowing
once the building is built. I know this from Sydney Metro's admission
that they intend to build 3 metres away from our building on the lower
levels and 12 metres away from the higher levels. How can we approve
this application when it is in flagrant breach of the Apartment Design
Guide 2F?

The loss of existing views from the north side of Princeton would
adversely affect the residential amenity of neighbouring owners.

The effect of this development (due to its sheer size and shape) means
that around 100 apartments at Princeton Tower will lose a lot of their
wintersun AND Hyde Park will also lose wintersun 6 months every year
after 2.30pm. This sunlight can never be returned if this approval
goes ahead. Removing sunlight from such a beautiful green park is a
crime to the local residents and tourists who enjoy this public space.
It is also a breach of the Sydney LEP 2012 sun access plane
provisions.

This is supposed to Sydney Australia; a city of livability with a
beautiful quality of life.

Keep high rises near other high rises and leave this pocket of CBD
alone. I do not wish to feel like I am living in a human ant colony.

I OBJECT TO THIS DEVELOPMENT.

If this development goes ahead, it will be concrete proof that the
government is attempting to override local community opposition to
overdevelopment. There is so much community anger and horror over the
colossal overdevelopment at Sydney Metro Pitt Street South.

The proposed development is surrounded by heritage buildings such as
the Edinburgh Castle Hotel, Castlereagh Street fire station and the
Sydney Water Board building. The proposed design represents a stock
standard corporate tower with no effort made to compliment the
heritage nature of the location.
The Edinburgh Castle Hotel has operated from the site from 1885. The
proposed development surrounds the corner site of hotel and does not
propose adequate setback from the heritage building. At a proposed 35
storeys the development dwarfs the 3 storey Edinburgh Castle Hotel. It
will remove any visual historical impact the hotel offers.

The proposed envelope is an unusual, ugly shape wrapping around two
sides of the Edinburgh Castle Hotel.

My building at Princeton Tower at least has considerable architectural
merit. A large building mass in such close proximity would
substantially detract from its quality and impact.
In addition, it does not appear that the spacing afforded to the
Castlereagh Street Fire Station is adequate. The impacts on the
heritage significance of the surrounding buildings will be adverse and
entirely unnecessary.

The new building is proposing to be 3 metres away on the lower levels
and 12 metres away on the higher levels from Princeton Tower.

Take a look at Princeton Tower and you will see that from level 9 to
level 42 of our building, either a living room or bedroom will
directly look into the new proposed development. Princeton Tower is a
residential tower not an office tower and so privacy is even more
crucial to maintain.

So many professionals live in this this building and we come home
after a good days honest work in the CBD to relax and enjoy our family
life. This will be terribly impacted if this overdeveloped overstation
goes ahead because our privacy and amenity will be drastically
affected.

Surely Sydney Metro should adhere to the planning regulations set out
in the Apartment Design Guide which stipulates that they should be 18m
to 24 m away from an adjoining building?
This is a reckless development because Sydney Metro is only caring
about their commercial interest. This is a government body who should
be setting an example on how to respect the history of the surrounding
sites of cultural significance and neighbourhood amenity.

Many apartments in CBD have overcrowding issues, do we really want to
give another opportunity for rich foreign investors to buy apartments,
fill and overcrowd them with tenants and hurtle towards a difficult
future of high rise slums?

The least Sydney Metro can do is design a suitable development in
accordance with Apartment Design Guidelines and all applicable
planning controls. They have NOT done this.

Shame on you Sydney Metro for acting like a greedy, money grabbing,
air grabbing developer!

I wish to lodge an objection to the proposed over station development at
Pitt Street South Metro Station.

The current application represents an overdevelopment of the site and
does not comply with planning controls.

I was shocked to read the details of the application and the effect it
will have on the Princeton building. 49% of residents will lose access
to the required amount of sun exposure, privacy will be significantly
diminished and our views will be lost.

There is a reason we have planning controls and apartment design
guidelines and these seem to be ignored by Sydney Metro. Before Sydney
Metro compulsory acquired the site there was going to be a new hotel
at a modest size inkeeping with the neighbouring surrounds. Instead we
have a proposal for a massive tower block that has been designed to
maximum development potential at the cost of its neighbours.

The proposal also adds additional overshadowing to Hyde Park for half
of the year in the vicinity of the war memorial. This should be enough
reason for its refusal.

I ask that neighbours amenity be respected and design and planning
controls respected.

The proposed envelope for the over station development lodged by Sydney
Metro is a disgraceful overdevelopment which attempts to disregard
basic planning logic and guidelines in favour of packaging the site up
to the maximum physical extent possible and selling to the highest
bidder.

Sydney Metro are not a property developer and should not be granted
any exemption from planning regulations due to their status as a
public authority. The application shows their blatant disregard to
neighbouring amenity and a basic lack of competance, yet they are
afforded special treatment simply because the envelope is above a
metro station. This defies logic and is a blatent misuse of power.

Putting aside the complete disregard and non-compliance with the
Apartment Design Guide, City of Sydney Development Control Plan,
Sydney Local Environment Plan, Sydney Metro have elected to ignore
their own Design Excellence Strategy and OSD Design Guidelines which
they have the audacity to annex to their application. They have also
completely ignored the Secretary's Environmental Assessment
Requirements.

My objection to the proposed over station development is based on a
number of factors.

Firstly, the applicant has not complied with the Secretary's
Environmental Assessment Requirements which include State
Environmental Planning Policy No.65, Sydney Local Environmental Plan
2012 and the Apartment Design Guide.

Secondly, the applicant has failed to take into account the privacy
concerns to neighbouring residents.

Thirdly, the applicant has not taken the requisite heritage impacts
into account on the adjoining Edinburgh Castle Hotel site and
Castlereagh Fire Station site.

Fourthly, the application is littered with false information and a
baseless opinion, with supposed "expert" reports decending into mere
conjecture.

Fifthly, the applicant has ignored and disregarded its own design
quality guidelines.

We have asked the applicant to present us with further information to
properly assess the massive impact the development will have on our
building which they have failed to provide. We have been presented
with a proposal which will have devastating impact on our amenity and
been told that the applicant can simply proceed while not taking our
opinions into account. The applicant has not in any way been
transparent throughout the process.

If the application is approved in its current form the residents of
neighbouring buildings will properly oppose it in every way possible.
The applicant should be held accountable for their outrageous actions.

Numerous parts of the development application are incorrect and amount
to nothing more than unfounded opinion. Assertions such as the
proposed envelope being "a slender form" which is "considered to be
entirely reasonable" are insulting.

The application should be refused in its current form. The applicant
needs to approach this development in a reasonable manner within
established planning controls and take neighbouring resident's opinion
and amenity into account.

We object.

We have undertaken a detailed review of the Development Application
submitted by Sydney Metro and spotted numerous inconsistencies or
non-compliance with planning regulations.

We have compiled the bullet point list below for your convenience.

Given the extraordinary number of breaches of planning regulations
contained in this Development Application, we ask that this
Development Application in its current form be REJECTED.

* The application clearly does not comply with the Secretary's
Environmental Assessment Requirements, Environmental Planning
Instruments, State Environmental Planning Policy No 65, Sydney Local
Environmental Plan 2012 and the Apartment Design Guide;

* It also does not comply with the applicant's own Design Excellence
Strategy and OSD Design Guidelines;

* There are multiple references in the application to an alleged
covenant on Princeton's title regarding northern views being affected
by future developments. This is simply false and misleading. If the
applicant had the basic foresight to conduct a simple title search it
would reveal that there is no such covenant on title. Residents in
Princeton are not aware of this condition affecting ownership of their
property;

* Contrary to the applicant's assertion that a covenant should appear
on Princeton's title, Princeton did in fact have an easement for light
in respect of the applicant's title in 2012, which contradicts the
notion that owners in Princeton were put on notice that development to
the north could affect their views in the future. Owners had purchased
in Princeton taking comfort that an easement was in place protecting
their access to light;

* Section 4.9.1 of the Environmental Impact Statement states that the
fundamental principles for the OSD contained in the guidelines are to
"deliver a high quality built form that...minimises privacy and solar
access impacts on the surrounding residential uses". The proposed
development is clearly at odds with this statement;

* In section 8.4.2 northern facing windows in Princeton are referred
to as "typically secondary windows." This is demonstrably incorrect
and shows a basic misunderstanding of the English language. In
3-bedroom north facing apartments there is approximately 16m2 of north
facing windows in the main living areas and bedrooms;

* There are various references in the application to the
"non-complying building form of the Princeton Apartments." This again
represents a fundamental lack of understanding of basic planning
concepts. The Princeton building is an approved development that was
built in 1995 in compliance with planning controls. The Apartment
Design Guide that the applicant alleges Princeton does not comply came
into force in 1995, 20 years after Princeton was built;

* Section 8.2.1 compares this application to a previous approval of a
hotel at 302 Pitt Street with 2.4m separation with Princeton. In fact
this application was for a 16 storey commercial building which is in
no way comparible with the current application;

* Section 8.2.5 reference to the unreasonable outcome of placing
burden of compliance with the separation requirements on the proposed
development. The fact that Sydney Metro views compliance with the
Apartment Design Guide as unreasonable is worrying;

* Section 8.2.6 statement that an increase in western setback would
"not provide any significant benefits" is incorrect. There would
plainly be a considerable increase in views for Princeton residents if
additional western setbacks enforced;

* Section 8.2.8 compliance with the proposed envelope would not ensure
the over station development is adequately separated from surrounding
buildings where it does not comply with the Apartment Design Guide;

* The ratings given to the overshadowing effects on Hyde Park in
section 8.3 are incorrect and misleading with no definitions provided
of what "Minor" or "Negligible" actually mean. The effect shown in the
applicant's own diagrams show moderate additional overshadowing to
Hyde Park for an entire 6 months of the year;

* The reference to "some additional overshadowing" in section 8.3 is
false and misleading;

* "almost entirely confined within the areas already overshadowed" and
"the impact of the proposed building envelope would be negligible" in
section 8.3 are fale and misleading;

* The overshadowing impact assessment in section 8.3 is incorrect. The
reference to the development being a "worse case scenario" with the
"actual impact likely to be less" is dangerously incompetent. It is
extremely unlikely a developer would elect not to build to the maximum
envelope afforded in a development of this nature;

* The statement in section 8.4.2 that the proposed envelope is
"considered to be entirely reasonable" which "provides appropriate
building setbacks" is incorrect as it clearly breaches numerous
planning controls. It is alarming that the applicant considers that
breaching planning controls is "entirely reasonable";

* The quoted separation figures in section 8.6 are incorrect;

* Section 8.7 statement that "the expectation that the existing level
of solar access would be retained in perpetuity is unreasonable as
this would sterilise the adjoining site" again shows basic misuse of
the English language. A reasonable development on the site would not
affect the levels of solar access required under the Apartment Design
Guide. It should also be noted that the previous approved application
for a hotel to be developed on the site did not have a similar
catastrophic effect on solar access. The hotel was due to be built
before the site was subject to compulsory purchase for the Sydney
Metro;

* The proposal is not a "slender building form" as alleged in section
8.7;

* The statement in section 8.7 that the location of Princeton is such
that impact is "insensitive to the height of the proposal" is clearly
incorrect and shows a dangerous level of ignorance. Could a 9 storey
development have the same impact as a 35 storey development?

* Section 8.7 states that "a severe increase in of the proportion of
apartments failing to meet the relatively stringent `2 hours standard'
can be considered usual and expected" does not represent genuine
planning justifications and is also vague and unfounded;

* Section 8.7.2 states that the proposal would give rise to "some
impacts on solar access" in Princeton. Non-compliance affecting 57
apartments is more than "some" impact;

* In section 8.11 the applicant admits that they do not comply with
the heritage aspects of the Secretary's Environmental Assessment
Requirements;

* Assertions made throughout the application demonstrate a dangerous
level of ignorance regarding good planning and an inconsiderate
approach to neighbouring proprietors;

* We should resist the development of high-rise slums where
residential buildings are crammed too close together;

* As a public agency Sydney Metro should have particular regard for
the quality of life of Sydney's residents and should take full account
of local concerns;

* The applicant should not be allowed to maximise profit at the
expense of residents;

* An important planning fundamental is "The Precautionary Principle."
Allowing this development in its present form would be reckless and
damaging, and would be heavily criticised by future generations;

* Dangerous notion that residential amenity in current buildings can
be removed to promote profit in newer buildings by a public body;

* The applicant's own Design Quality Guidelines:

o purpose to guide the design of over station developments;

o "these guidelines provide a consistent framework for design across
the integrated station development" - consistency requires compliance;

o "enhance the overall experience in the city" - by overshadowing Hyde
Park for 6 months a year?

o "well integrated with the valuable inherited urban fabric of
existing places" - not well integrated;

o "Design will ensure protection of the public domain, especially
solar access to Hyde Park, and consideration of impacts on
neighbouring uses" - does not comply with either;

o "Consideration of privacy implications to surrounding residential
buildings, including the Princeton Apartments" - privacy implications
not addressed;

o "Where practicable, preserve sunlight access and views to the north
for neighbouring properties" - extinguishes sunlight and blocks access
to views;

o "Achievement of SEPP65 & ADG requirements" - reference to these
items as "requirements" which application does not comply with.

I own a unit on level 10 at Princeton Apartments. In true life, this is
actually floor 4 because our lobby on ground level is known as level
6).

I am truly horrified, shocked and appalled at Sydney Metro's design of
their overstation development. I understand from the development
application that the proposed new building could conceivably be a mere
3 metres away from my home.

Having another building so close to my home will mean more noise, less
privacy and less enjoyment of my home.

There will also be an adverse effect on the residential amenity of all
of my 116 neighbours.

We will not be able to escape the noise, disturbance, overlooking,
loss of privacy and overshadowing once the building is built.

I most definitely object.

The plans submitted in relation to the concept scheme application
propose a setback of 3m from the northern boundary of the Princeton
Apartments site up to RL71.

Above RL71 the concept plans show a setback of 12m to the northern
boundary of the Princeton Apartments site.
I understand that Sydney Metro's proposed building separation means
that they will not be complying with Apartment Design Guideline - 2F.

As well as the building being too close, the following detrimental
issues will arise from this overstation development. I believe these
issues can be overcome if the design of the building was shorter and
slimmer.

1. Loss of Solar Access

Only 4% of apartments will get the requisite minimum of 2 hours of
solar access between 9am and 3pm on June 21 (winter solstice) if the
development proceeds. This means that 96% of 116 apartments in my
building will not get the minimum solar access required under planning
instruments.

This is a horrible outcome. We need sunlight for wellbeing, mood and
to keep us warm. Who are Sydney Metro to put us in the shadows just
because they want to fit as many offices or apartments on to their
site? Where is there sense of community morality?


2. Shadow Impacts on Hyde Park

Clause 6.17 of Sydney LEP 2012 suggests that the building envelope is
compliant with the provisions of the clause however there are
overshadowing impacts on the park because the shadow study shows that
during the winter months, the shadow creep will mean that Hyde Park
will lose sunlight after 2.30pm during the winter months.

This must be stopped for the sake of public interest and enjoyment of
this beautiful park and to make sure the trees and vegetation do not
suffer due to the lack of sunlight.

3. Privacy

An extreme loss of privacy will be caused because of the reduction in
building separation. Provision of louvres or screens will not address
loss of privacy as these can be changed and/or removed. We require
minimum separation. We also pint out that there are no windows on the
southern elevation of the building.

4. View loss

There will be a narrowing of the view corridor to the north east and
complete loss of view from north facing apartments in the Princeton.
As my unit is on a lower floor I worry that we will be on the same
level as noisy plant and air conditioning equipment in the proposed
new building. This will diminish my enjoyment of my property because
of the extra noise and visual ugliness.

5. Sustainability

Sydney Metro has recommended that due to the reduction in solar access
and daylight lux levels in our apartments after the proposed building
is constructed, that we should all rely on artificial lighting. This
is an extremely undesirable outcome.

The new development will also negate the opportunity for our building
to install solar panels as an alternative source of power generation.

We therefore require that the building be made slimmer and shorter to
counter the above issues.

Until the building is made slimmer and shorter, this proposal should
be REJECTED.

I own a unit at Princeton Tower. There are 116 apartments in my building.
My amenity and all my neighbours will be greatly affected through loss
of solar light and privacy and the substantial overshadowing over our
living areas and bedrooms.

SYDNEY METRO MUST MAKE THE BUILDING SLIMMER AND SHORTER TO COMBAT
VARIOUS AMENITY ISSUES FOR THE ADJOINING OWNERS AT PRINCETON TOWER.

I have summarised in bullet point format the main issues below as to
why I OBJECT.

LOSS OF SUNLIGHT

* According to the applicant's Solar Access Impact if the development
is approved 5 out of 116 apartments (4.3%) will receive the required
access to direct sun as per the Apartment Design Guide;

* 57 people's homes will be substantially affected. A reduction in
number of apartments with sun exposure (per 1m2 of living room area
between 9am to 3pm on 21 June) from 62 apartments to 5 apartments (49%
reduction);

* Under Apartment Design Guide a proposed building should not reduce
solar access to more than 20% of neighbouring properties. The
applicant's proposal is more than double the maximum allowed under the
Apartment Design Guide;

* The practical effect will include heating and lighting costs
increasing thus increasing our carbon footprint;

* The application does not consider the impact of light scatter, which
has resulted in a gross underestimation of the impact on Princeton;

BUILDING SEPARATION

* Does not comply with requirement of part 2F Apartment Design Guide;

* Minimum separation is:

o Up to 4 storeys - 12m between habitable rooms, 9m between habitable
and non-habitable rooms. The proposed separation is 3m which is
non-compliant;

o 5-8 storeys - 18m between habitable rooms, 12m between habitable and
non-habitable rooms. The proposed separation is 3m which is
non-compliant;

o Above 9 storeys - 24 metres required as habitable rooms are on the
north boundary of Princeton and south boundary of proposed development
floor plans. Again the proposal is non-compliant.

* Where existing, approved building in place a development must comply
with minimum separation requirements which the applicant has failed to
do;

* Apartment Design Guide states that separation between building
contributes to the urban form of an area and the amenity within
apartments and open space areas;

* Apartment Design Guide states this is a separation requirement, not
a setback provision therefore the full minimum separation distances
must be enforced;

* Inadequate separation also increases the risk of fires spreading;

* Reduced separation will result in increased acoustic impacts;

* Lack of detail regarding plant location and specifications to
understand how/if this complies with relevant Australian Standards and
the NSW Environment Protection Authority noise generation/emission
standards;

* The reduced separation will reduce opportunities for Princeton
Apartments to access cooling north-easterly breezes leading to a
greater reliance on artificial cooling and reduced sustainability.

LOSS OF VIEW

* Proposed development in current form would cause a significant loss
of views to Princeton apartments;

* A large proportion of units would loss all views to northern aspect;

* Additionally it would cause substantial loss of views from Greenland
building including eastern aspect views to Hyde Park.

OVERSHADOWING OF HYDE PARK

* It is shocking that a public body would propose to add additional
overshadowing to Hyde Park for 6 months of the year;

* The Shadow Study provided by the applicant clearly shows additional
overshadowing over Hyde Park as a direct result of the proposed
development;

* In no circumstances should this be allowed and an independent study
should be conducted to verify the extent of overshadowing;

* Hyde Park is an extremely precious inner city open space that is
used greatly by residents and visitors;

* This park must be protected as it is increasingly common for cbd
residential buildings to have no private open space;

* Remaining access to sunlight must be protected especially in the
vicinity of the ANZAC memorial, which the proposed development casts
all of the additional shadowing;

FOR THE REASONS ABOVE I STRONGLY OBJECT.

I disagree with the development because it is too wide, too tall and too
close to Princeton Apartments at 308 Pitt Street.
If the application proceeds I will lose my view, my privacy and my
sunlight.

I own an apartment on level 11 and worry that there will be a lot more
disturbance, dust and noise from the station ventilation plant of
Sydney Metro's proposed new building because it will be roughly on the
same level as my unit.

The development application shows that there will be a building
separation of 3 metres from the lower levels of the unit. I cannot
enjoy my property if this development is approved.
The lack of detail regarding plant location and specifications on the
lower levels of the Applicant's proposal make it difficult to verify
whether their proposal complies with relevant Australian Standards and
the NSW Environment Protection Authority noise generation/emission
standards.

Please rethink this development application and consider the damaging
and devastating effects.

I am old and it saddens me to think of the future of my home and the
other 116 apartments in my building.

I oppose the proposed Sydney Metro Overstation Development concept
application as it presently stands.

The grounds for my objection should be no surprise to the applicant as
they have acknowledged the various blatant breaches of planning
controls and failures to address certain items in the SEAR in their
application.

I am extremely disappointed in the lazy attitude of the applicant
displayed throughout the application. They acknowledge that separation
requirements, privacy concerns, solar access, overshadowing, heritage
requirements have all been significantly breached. Their justification
for doing so?

Incorrect assertions of the development can be reasonably expected in
the city (no evidence provided in support), comparisons with previous
approvals for buildings less than half the size (16-storey hotel at
302 Pitt Street), describing the envelope being a slender form,
incorrect references to covenants on title (did they even try to
verify this baseless claim by conducting a title search?) to name a
few.

The applicant's own Design Excellence Strategy and OSD Design
Guideline have been set out and consequently completely ignored. They
refer to the Apartment Design Guide as a "requirement" in their own
guidelines then in another part of the application states that they
will not comply with the ADG and that they shouldn't have to.

The sheer volume of inconsistencies in the application is staggering.
The applicant appears to be of the view that due to the length of the
documents and amount of information provided no-one will actually
properly consider the contents or fact check the assertions made. It
seems the applicant's track record and competency in relation to
projects to date has also transferred to their role as a potential
developer.

The application needs to be amended to allow the required separation
under the ADG at all levels, a reduction on height to remove excessive
overshadowing onto Princeton and onto Hyde Park, a reduction in size
to comply with ADG and heritage requirements. The applicant also needs
to engage properly with the community and take their concerns into
account.

I strongly object to the gross overdevelopment as set out in the Sydney
Metro application for an over station development at Pitt Street
South.

I question why Sydney Metro even have the authority to lodge this
application as it is clear from the contents that they lack the basic
knowledge and experience to properly address the requirements they are
subject to. It truly appears they are out of their depth.

At least they have managed to identify the various obligations and
regulations they propose to breach, although this is largely due to
the direction of the SEAR and not through any competence of their own.

It's hard to believe that without residents taking action against this
application it could potentially be rubber stamped and decided
internally. I wonder how many developers have leverage on this process
and question the independency of the applicant. We have a situation
where a public body is acting as a developer with little to no
accountability to the public, with the only real motivation being
profit to offset the cost of the metro development (and who knows what
else).

This is disgraceful and needs to be brought to light for the broader
public.

The application needs to be rejected in its current form. It fails to
comply with the SEAR, the ADG, various other planning controls and the
applicant's own design guidelines.

I strongly oppose the concept over station development lodged by Sydney
Metro.

The proposed envelope is far too close to Princeton in breach of the
ADG. Sydney Metro state in their own design guidelines that the ADG
are requirements they must comply with. Separation requirements need
to be respected otherwise it will lead to a myriad of negative
impacts.

The development will overshadow Princeton to a devastating degree. It
will also cast additional overshadowing to Hyde Park in the vicinity
of the war memorial for 6 months in a year. Both neighbouring amenity
and public amenity have been disregarded here in the pursuit of
profit.

Princeton will lose the minimum required amount of solar access to 57
apartments. 57 families will lose sunlight because Sydney Metro
doesn't want to comply with planning controls.

Princeton will also lose all northern views. In place we will see a
concrete wall crammed as close to our building as possible.
The application takes no account on the effect of the privacy of
Princeton residents. Sydney Metro's attitude appears to be this can be
dealt with at a later date when they have sold the site and it is
someone else's problem. This is not how planning decisions should
work.

There is no respect shown to heritage buildings which surround the
development site. Due to the proximity of Edinburgh Castle Hotel and
Castlereagh Fire Station this demands that heritage regulations be
followed. It is bad planning (and a lack of common sense) to place a
35-storey building over a 3-storey heritage building in circumstances
where the development is "cut around" the heritage building and will
loom over it to negate any heritage impact it might have.

Representatives of Sydney Metro have been extremely unhelpful in
addressing any of our concerns. Promises of further diagrams,
information and rationale have been broken. False statements have been
made orally and in writing. Complete disregard for community feedback
has been demonstrated.

Planning controls exist for a reason. They were designed to protect us
from private developers exploiting building potential in our great
city. The same controls need to apply to public authorities. Public
authorities should be more accountable to residents and visitors. A
sensible, measured approach needs to replace the greed and disregard
as is evident in this application.

I ask that you take my views into account and reject this application
on this basis.

I was initially excited to find out that a new metro station was being
built next door to our building. My excitement was then replaced by
apprehension at the news that Sydney Metro were also acting as a
developer in applying for approved for an over station development. My
fears have been confirmed when reading the contents of the development
application.

To set out all of the non-compliance issues, false statements and
incorrect assertions would almost take a document the length of the
application submitted. I will attempt to summarise them below.

1. Overshadowing:

- Failure to comply with 3B of the ADG;

- Additional overshadowing to Hyde Park for half the year (April to
September).
2. Solar access:

- Failure to comply with the required levels of sunlight to living
areas as set out in the ADG;

- A reduction in compliance to 4.3% of all apartments in Princeton;

- Failure to comply with 4.2.3 of the City of Sydney DCP 2012.
3. Separation:

- Failure to comply with 2F of the ADG;

- Proposed 3m separation at lower levels should be 12m up to 4 storeys
and 18m from storeys 5-8;

- Proposed 12m above storey 9 should be 24m.

4. Loss of views:

- Complete loss of views to Princeton north facing apartments;

- Incorrect assertion of Princeton planning approval being subject to
a covenant on title. No evidence provided (simple title search).

5. Privacy:

- No substantive privacy considerations despite the SEAR direction and
Sydney Metro design guideline requirements;

- Failure to comply with 4.3.2 of City of Sydney Development Control
Plan 2012.

6. Heritage:

- No consideration of surrounding heritage buildings including
Edinburgh Castle Hotel or Castlereagh Fire Station;

- Insufficient setbacks to heritage buildings.

New development in Sydney is undoubtedly a positive thing. When rules,
guidelines and regulations are not followed it can easily turn into
something negative.

This application is a prime example of how not to approach
development.

Disregard to all rules, neighbor concerns, public amenity and the
heritage and history of this great city sets a dangerous precedent.

This application needs to be reviewed by an independent body.

Perhaps Sydney Metro should engage professionals with experience in
this field to guide them accordingly.

We cannot allow this application to be approved.

Definitely no. There are 116 apartments at Princeton Tower right next
door to the proposed project.

If this development application is approved then this will be a
travesty to everyone living at Princeton. This is especially so for
the neighbours on the north side because they will be directly facing
the new building which in my view is far too large in size for the
building footprint.

Every single unit on the north side of Princeton will completely lose
their view and by consequence their privacy, sense of security and
amenity.

It is ridiculous and unlawful for this development application to
proceed in its current form.

Sydney Metro admits in its own application:

1. They will cause extra shadowing on Hyde Park during April, May,
June, July, August and September

2. They have failed to obey the Hyde Park Sun Access Plane regulations
under the Sydney LEP 2012

3. They have failed to obey part 3B of the Apartment Design Guidelines

4. They have failed to obey to give Princeton the required levels of
sunshine into the living areas as required by the Apartment Design
Guidelines.

5. In relation to sunlight, Sydney Metro have admitted that only 4.3%
of apartments at Princeton will get the required levels of sunshine
into the living areas as required by the Apartment Design Guidelines
once their development is built.

6. This means 57 apartments which currently enjoy the required levels
of sunshine into their living areas under the Apartment Design
Guidelines will lose the solar access as recommended under the
Apartment Design Guidelines.

7. They have failed to obey part 2F of the Apartment Design Guidelines
because they only want to leave 3m - 12 m building separation between
Princeton Tower and their monstrosity.

8. As per the Apartment Design Guidelines Part 2F, Sydney Metro should
ensure that they have a 24 metre building separation because their
building has over 9 storeys

To recap, I object!

No because not enough setbacks and building separations.

Sydney Metro have given no thought whatsoever to the surrounding
heritage buildings such as the Fire Station on Castlereagh Street
which is immediately behind the proposed building and the Edinburgh
Castle Hotel which is immediately adjacent next door to the north.
From looking at the design plans. Sydney Metro have not given enough
setbacks to these two heritage buildings.

There is also insufficient separation between Princeton and Sydney
Metro's building which means that it is unlawful under the Apartment
Design Guidelines 2F. The lack of building separation and appropriate
setbacks between Princeton and Sydney Metro's building is even more
damaging because there are 116 homes in this tower.

I understand around half of these homes will be directly affected
because they will overlook the new Sydney Metro Building.

This means there will be a general loss of amenity for me and my
neighbours and we will lost views, privacy and sunlight.

How can this development proceed when Sydney Metro have not considered
privacy for their neighbours despite this being a criteria under SEAR
and the Sydney Metro design guideline requirements?

I want to make it clear that I do not oppose the overstation
development as a concept in itself but I do oppose the sheer size,
bulk, width and height.

Sydney Metro has described their building as slim. I disagree. They
can make it slimmer by ensuring that their proposal has the correct
building separations under the Apartment Design Guidelines 2F as well
as the correct setbacks.

I whole heartedly OBJECT to this development because it is a damaging
proposal.

A private commercial developer would be made to follow all the
planning requirements and guidelines so what makes Sydney Metro think
they can get away with not following legislation? Are they above the
law?

Sydney Metro's development application admits to breaching the
following instruments:

* Secretary's Environmental Assessment Requirements
* Environmental Planning Instruments
* State Environmental Planning Policy 65
* The Apartment Design Guidelines
* The Sydney Local Environmental Plan 2012

Sydney Metro must be sent back to the drawing board to come up with a
better design so that it does not affect its adjoining neighbours so
drastically.

Allowing this development to go ahead would be a terrible injustice
and could open up the floodgates for even more skyscrapers to be built
in Sydney CBD around Hyde Park and right next to residential towers
with no regard to appropriate setback provisions and correct building
separation distances.

Sydney Metro is a public corporation which is accountable to people.

Sydney Metro should have an extra special regard for the quality of
life of Sydney residents (more so than the average commercial
developer). Sydney Metro has a duty to address in detail the local
concerns with this overdeveloped overstation.

Sydney Metro's website says that customers are at the centre of Sydney
Metro,.

Don't forget that these same customers are the ones who would like to
walk through Hyde Park without being overshadowed during the months of
April to September (inclusive) after 2.30pm without a loss of
wintersun.

These same customers are also the ones who would not like to live 3
metres to 12 metres away looking directly into an overdeveloped
overstation.

The development proposal is too close Princeton and too large for the
building envelope. Unless the building separations are at least 24
metres from Princeton, I will forever object.