NSW Government Rezoning Proposal – Major Issues of Concern

The NSW Government Rezoning Proposal appears to be lacking several key studies and detailed reading of the technical documents that have been released reveal numerous inconsistencies with what is stated as fact in the Explanation of Intended Effect (EIE) and the Draft Design Guide (DGD). The list below can be used as a starting point for writing a submission. We suggest you focus on one or two of these issues in your submission, the ones that you feel most passionately about. Please put your concerns in your own words and writing style.

Please note, this is a list in development and will be added to and developed over time as we provide greater detail in each of the areas, so please continue to refer back to it. If you are comfortable writing a more Expert submission, see our Make a Submission page to download some example.

1. It won’t do anything to help the Housing Affordability crisis

• The requirement for 3% Affordable Housing for most developments is a token offering and will hardly offset the currently relatively lower cost units demolished to build these towers.
• The 3% can be made as a cash payment in lieu of actually building affordable apartments. This money is not received locally and could be spent anywhere in the state, not neccessarily in Woollahra or Edgecliff, again not helping local housing affordability.
• Developers will be building luxury new units, as these generate most margin. They will sell starting from $3.5 million and will only be bought by the wealthy.
• The NSW Government reports don't even realise that one of the sites they are proposing to rezone and allow 8 storeys to be built on in Moncur Street is actually the site of the only NSW Government-owned social housing in Woollahra. There is no funding proposed to rebuild the site, so the assumption must be that, if it is going to be developed, the Government will sell it off to a developer, further reducing the stock of affordable housing in the area, not increasing it.

2. No planned investment in new schools, other infrastructure or open spaces

• The proposal is to increase the Woollahra-Edgecliff population from 9,000 to 30,000. This will require both a new primary school and a new secondary school yet there is no provision for this in the short or medium term. The proposal states the Department of Education had been consulted and advised that new schools aren't needed in the short and medium term. No enrolment projections or any other type of study is provided to support this extraordinary claim.
• Similarly there is no Government investment planned for road upgrades (there is some mention of road widening but that would require compulsory acquisition which the Government has ruled out), water and sewerage (the Government's report admits the Woollahra water reservoir zone is at capacity and unsuitable to service additional demands and the sewers are insufficient. The one upgrade identifies, SP88 pump station is not funded in Sydney Water's current capital plan), additional parking, community centres, a new library, childcare centres, additional hospital beds, sporting facilities and sports fields, etc, all required for an additional 20,000 people. The Government's own paper indicates this is around $1.3 billion, excluding investment in additional schools or the Woollahra Station. There is no plan to pay for this.
• There is very little new open green space proposed, and what is stated as will be delivered relies on incorporating public open space into private developments as part of development consent. For example, the rezoning proposes that the Holdsworth Centre be demolished to create more green space in Moncur Reserve and that a new centre is build in one of the private developments in the new Woollahra Centre area. There is absolutely no guarantee that this new comminity centre or any other of these proposed additional open spaces will ever be built by private developers.

3. No proper transport studies

• TfNSW’s Transport and Accessibility Plan (TMAP) and its modelling is inadequate and superficial and didn't model specific intersections. The department admits it used Google Maps to assess traffic and they were unable to correlate traffic speed and congestion to standard performance metrics such as level of service and degree of saturation. Even so, the key observations identified existing congestion on the main arterial roads and at important intersections, including New South Head Road and Ocean Street.
• In comparison, the transport study commissioned by Woollahra Council for the 10,000 dwellings scenario found it would cause severe congestion, not just for locals but for other Eastern Suburbs residents using the major roads.

4. No new bus routes

• Currently plans assume that everyone living within 800 metres of Woollahra Station is fit and healthy and can walk everywhere, including up the very steep gradients from the lower side of the North or South Cliff Edge areas (east of Edgecliff Road) to catch the train. There are no new bus routes planned to transport residents along Edgecliff Road or along Wallaroy or Manning Roads to help residents in the densest development area to access Woollahra Station. In fact, conceptual drawings of what the station may look like don’t even include a bus stop for use in the future

5. Heritage is being destroyed

• Although currently listed items will be retained, large numbers of contributory items will be destroyed. It is not just listed items which create the heritage of an area but all the contributory items as well.
• Remaining listed building risks being overshadowed with poor transition as they are dwarfed by surrounding towers, losing their original context and diminishing their heritage contribution in a changed and unsympathetic setting.
• The heritage report itself appears heavily qualified, almost certainly reflecting significant unease about the proposed plans by these heritage experts.
• No consultation was undertaken with the State's Heritage Advisers, the Heritage Council of NSW, according to the Government's Heritage Report, which seems extraordinary, given the number of heritage listed properties in the area, including seven State-listed properties, the bulk and scale of the new buildings surrounding them, and the loss of large numbers of contributory items.

6. The built form is not justified and the amenity protections are discretionary

• The proposal requires building an additional 142 towers (building over 9 storeys) for 20,000 people, quadrupling the current density to that of Elizabeth Bay, in an area much larger and without the harbour views.
• Maximum heights move from a current range of 5 to 34 metres, roughly 1 to 12 storeys, to a range of 5 to 121 metres, roughly 1 to 34 storeys. This is not confined to 2 tower sites - 9 key site blocks carry proposed heights of 100 metres or more. This is a precinct-wide change in typology imposed on an area already 77 per cent medium to high density.
• The protections offered against that built form are discretionary, and the Design Guide says so. Despite stated Guiding Principle requiring good solar access to streets and parks to be maintained and requiring solar access to existing dwellings and to areas not proposed for change to be protected, Provision 3 then permits development adjacent to identified public spaces to "result in a net increase in overshadowing of that space" where it complies with the built form envelope controls.
• There are no shadow diagrams provided for remaining buildings, only diagrams of sunlight on new buildings. There is a major risk that, with the density proposed, despite the principles stated above, remaining building, included heritage listed, will be in permanent shadow.
• Creating dangerous high wind canyons remains a real risk. The Wind Study says winds were only considered qualitatively and wind-tunnel testing would be required. This is for a proposal for 34-storey towers on an exposed ridge line and no proper testing has been done.
• Best practice planning principles require a gradual transition between area of different height. Gradual transitions are non-existent in this plan with tower blocks of various heights build all over the precinct next to existing low or medium rise dwellings.
• The impact on private views was considered outside the assessment of the Visual Impact Assessment, totalling ignoring impacts on all local residents. The report states that future assessments of impacts on private views will be undertaken in due course, but this will be after the rezoning, when it is too late.

7. Flooding, Geotechnical and Environmental studies are incomplete

• Flooding – The Design Guide Guiding Principles state that redevelopment in low-lying or flood-affected areas should be limited. However:
• The master plan then rezones Cliff Edge South around the Lough Playing Fields, with site-specific provisions conceding the constraint by requiring vehicle and pedestrian access from the upper street level to avoid flooding. Nine flood corridors run through or adjacent to development sites. The principle and the plan do not reconcile.
• Significant parts of the rest of the area are in an identified Flood Planning Area (20% of the total area, including the Cliff Edge), but there have been no studies done.
• Geotechnical – the technical study is only based on a desktop review and a site walkthrough but somehow concludes no precinct-specific controls are required, recommending a precinct-wide hydrogeological study as future work. The Cliff Edge South and North are steep sites. Approving dozens of deep basements on a steep sandstone ridge beside operating rail tunnels, on a desktop study that expressly defers any analysis, is not a sound proposal.

• Tree Canopy – the Government’s announcement states there will be no net loss of tree canopy in the precinct. However:
• The Ecological biodiversity assessment records existing canopy at 32.45 per cent and projects a decline to 29 per cent from direct impacts, including removal of up to 194 street trees. Again the detailed documents disagree with the Government's statements.
• There is no recognition of the importance of biodiversity corridors connecting green spaces and the impact rows of towers will have on these. Building typologies with smaller footprints and limited site coverage are required to preserve this canopy, not what is proposed in this rezoning.

8. Economic Feasibility

• The Economic Impact Assessment is unusually candid. Against 9,000–10,000 theoretical homes, realistic take-up is about 4,800 over 20 years  - approximately half of the target number - of which only around 2,400 are additional to what would happen anyway. The reasons given are high land values, small fragmented lots, heritage constraints, and owners unwilling to sell and combine sites. If the realistic number is half the target 10,000, why isn't the Government recalibrating the proposal and planning for 5,000 new dwellings (or is that what its already doing and why there is no funding in the short or medium term for all the infrastructure required).
• The recent AFR article (9 September 2026) interviewing developers and real estate agents questions the level of demand for what will have to be luxury apartments, the willingness of developers to invest if they fear there will be a glut of new apartments on the market, and the reality that there are only a limited number of construction companies with the specialist skills to build 34 storey towers.

9. Need for a phased rezoning approach

• Currently all rezoning is planned to come into effect at the same time. In the proposal, most of the new public infrastructure and facilities depend on them being delivered privately by developers as part of their development agreement for a particular site. But in many cases, this infrastructure will require design and coordination across several adjacent development sites. Without taking a phased approach, concentrating development in one area first where sites can be planned together, much of the infrastructure risks never being build.

10. Aboriginal heritage sensitivity and potential sensitivity

• Aboriginal heritage potential was mapped across the LGA in 2021. A substantial portion of the rezoning area is considered an area of Aboriginal heritage sensitivity or an area of potential Aboriginal heritage sensitivity, with the cliff adjacent to the station site notably sensitive. Best practice would require an impact assessment where excavation or impacts to exposed sandstone is to occur these areas, but there is no mention of this in the Draft Design Guide.