107 Silver Street Marrickville NSW 2204

I am a resident of Silver Street, Marrickville, and am writing to formally object to the proposed apartment development at 107 Silver Street.

I support appropriate housing growth in Marrickville and recognise the importance of providing additional housing close to public transport. However, I believe this proposal represents significant overdevelopment of this particular site and would have an unreasonable impact on the surrounding residential community.

My key concerns are:

* Excessive height — the proposed building is approximately 32.82m, exceeding the underlying 22m height control and, importantly, the 28.6m height available after the full 30% affordable-housing bonus by approximately 4.22m.
* Grossly disproportionate scale — Silver Street, Calvert Street and Silver Lane are predominantly characterised by one- and two-storey houses and terraces. A building of this height and bulk would be completely out of scale with its immediate residential context.
* Excessive visual bulk and dominance — the proposal would fundamentally alter the established character of the neighbourhood, with a large apartment building towering over surrounding homes.
* Significant privacy and overlooking impacts — the elevated apartments would create substantial opportunities for overlooking into neighbouring homes, bedrooms, living areas, rear yards and private open space.
* Insufficient local road capacity — Silver Street, Calvert Street and Silver Lane are constrained residential streets already accommodating residents, parked vehicles, pedestrians and local traffic. A development of this scale will generate significant additional resident, visitor, delivery, servicing and waste-collection traffic.
* Serious construction impacts — as someone who actually lives on Silver Street, I am particularly concerned about how a development of this scale could realistically be constructed while maintaining reasonable access and wellbeing for existing residents.
Even relatively small residential renovations in the street have been incredibly challenging, with construction vehicles, deliveries, materials and trades vehicles creating significant access and parking difficulties.
A major multi-storey development would be on an entirely different scale, requiring cranes, concrete trucks, heavy vehicles, deliveries, waste removal and potentially repeated road occupation. There is a very real risk that Silver Street and surrounding roads would be blocked or severely restricted, potentially for extended periods.
* Resident wellbeing and access — this should not simply be treated as a construction-management issue to resolve after approval. Council should first be satisfied that the development can actually be constructed while maintaining reasonable access to homes, emergency access, pedestrian safety, parking and residential amenity throughout what could be a prolonged construction period.
* TOD policy does not justify maximum development on every site — the strategic objective of increasing housing near transport must still be balanced against the specific characteristics of the site, including local character, privacy, visual bulk, traffic, overshadowing and residential amenity.

I strongly believe additional housing can be accommodated on this site without accepting a development of this scale. A substantially lower building with reduced upper-level bulk, appropriate setbacks and better integration with the surrounding low-rise homes would provide a far more reasonable planning outcome.

I therefore respectfully request that Council refuse the proposal in its current form, or require a substantially reduced and redesigned development.

I support this development.

It replaces a single structure on a large lot with 24 apartments, including five affordable housing units, in a Transport Orientated Development precinct close to Marrickville metro station. Building more homes near public transport, with an affordable housing component, is exactly what Sydney needs to address the housing crisis and will help reduce car dependence. I encourage Council to approve this proposal.

I OBJECT TO THIS DA - More small, sub-standard "dog boxes" do not resolve the housing shortage; they manufacture the demoralising slum holes of tomorrow. It is an indictment on modern planning that historical housing commissions offer palatial proportions by comparison to the legal loopholes currently being handed to property developers.

This development delivers poor-quality, hyper-transient housing unsuited for Aussies, let alone anyone hoping to build a stable life or raise a family. A community is not built on micro-apartments where residents cannot realize their full potential, keep pets, or access green space. Australians suburbs need family-oriented housing with backyards, light, and air—not high-density pack-em-in blocks that sacrifice human dignity for developer profit.

Stop destroying our suburbs. I urge the council to reject this DA.

I oppose this development.

Unlike the copy and paste responses about increasing housing availability, I see this development as disproportionate to the site and is likely to increase noise, activity, waste, parking demand and impacts on surrounding residential amenity.

I ask Council to carefully consider whether the site can reasonably accommodate the proposed level of use without unacceptable impacts on neighbours and the surrounding area.

”
I am a resident of Calvert Street, Marrickville, and am writing to formally object to the proposed apartment development at 107 Silver Street in its current form.

I support appropriate housing growth in Marrickville and recognise the importance of providing additional housing in the TODs that are under 400 metres walk from public transport hubs, which 107 Silver Street isn’t quite.

That said, I also believe this proposal represents significant overdevelopment of this particular site and would have an unreasonable impact on the surrounding residential community.

My key concerns are:

* Excessive height — the proposed building is approximately 32.82m, exceeding the underlying 22m height control and, importantly, the 28.6m height available after the full 30% affordable-housing bonus by approximately 4.22m.

* Grossly disproportionate scale

— Silver Street, Calvert Street, Silver Lane and O’Hara are predominantly single or dual occupancy dwellings characterised by single storey Federation fronted houses and Victorian and Edwardian terraces.

A building of this height and development of this size is completely out of scale with its immediate residential context.

* Excessive visual bulk and overwhelming dominance

The proposal would fundamentally shatter the established Cadastral streetscape style and character of the immediate neighbourhood vicinity, with a large apartment building towering over surrounding homes.

* Significant privacy and overlooking impacts — the elevated apartments would create substantial opportunities for overlooking into neighbouring homes, bedrooms, living areas, rear yards and private open space, not to mention the Calvert Street public pavement in ways no other dwellings on the street are able.

* Insufficient local road capacity — Silver Street, Calvert Street and Silver Lane and O’Hara are constrained residential streets already accommodating residents, parked vehicles, pedestrians and local traffic.

A overdevelopment of this scale will generate significant additional resident, visitor, delivery, servicing and waste-collection traffic.

* Serious construction impacts —

As someone who actually lives on Calvert Street (which will be as affected as Silver street given the grand scale), I am concerned about how the major builds could realistically be constructed while maintaining reasonable access and wellbeing for existing residents in this residential nook.

Even relatively small residential renovations in the street have been incredibly challenging, with construction vehicles, deliveries, materials and trades vehicles creating significant access and parking difficulties and traffic jams.

A major multi-storey development would be on an entirely different scale, requiring cranes, concrete trucks, heavy vehicles, deliveries, waste removal and potentially repeated road occupation.

There is a very real risk that Silver Street and all the surrounding residential roads would be blocked, backed up, and severely restricted, potentially for extended periods.

* Resident wellbeing and access — this should not simply be treated as a construction-management issue to resolve after approval.

Council should first be satisfied that the development can actually be constructed while maintaining reasonable access to homes, emergency access, pedestrian safety, parking and residential amenity throughout what most certainly would be a prolonged construction period.

* TOD policy does not justify maximum development on every site within 800 metres of a transport hub.

The strategic objective (and spirit) of increasing housing (gentle density rise) near transport centres must be balanced against the specific characteristics of the subject site, including local street scape character, privacy rights (overlooking), overshadowing (solar blocking), overall FSR & visual bulk, traffic disruptions and maintenance of reasonable residential amenity.

I am a staunch ally for increased density, affordable housing and the creation of more family homes in Marrickville (within 800 metres of new Metro Stations) yet I also strongly believe that additional housing can be accommodated on this site without accepting a development that is off the charts with its scale.

A substantially lower building with reduced upper-level bulk, appropriate zone setbacks, and a simpatico and sympathy with all of the surrounding low-rise fronted homes would provide a far more reasonable planning outcome for the suburb, while still providing a density increase, and new dwellings and more parking amenities, providing the right number of parks are provided for the actual occupancy levels being built for.

I therefore respectfully request that Council refuse the proposal in its current form, or require a substantially reduced and redesigned development.

Objection to DA/2026/0724 – 107 Silver Street, Marrickville
I strongly object to the proposed 9-storey residential development at 107 Silver Street on the basis that its height, bulk and overall scale are excessive and do not provide an appropriate transition to the surrounding neighbourhood.
While additional housing is important, this proposal needs to respond appropriately to its immediate context. A 9-storey building of this scale would be visually dominant and substantially out of scale with the surrounding homes, streetscape and lower-scale buildings. The design should be more carefully integrated with the existing mix of residential properties and nearby shops rather than introducing such a significant and abrupt increase in height and building mass.

My key concerns are:

Excessive height and bulk: Nine storeys represents a substantial built-form change and would create an overly dominant presence within the surrounding neighbourhood.
Poor integration with surrounding homes: The proposal does not provide an appropriate transition between a high-density apartment building and the predominantly lower-scale residential properties surrounding the site.
Impact on neighbourhood character: The height and mass of the development would materially change the established streetscape and sense of scale in this part of Marrickville.
Visual dominance and amenity: The additional upper levels would increase the building's visual impact and have the potential to affect the outlook, privacy, daylight and sense of openness enjoyed by surrounding residents.
Loss of trees and landscaping: The removal of 9 trees is a significant concern, particularly when combined with the increased building footprint and intensity of development. Any redevelopment should retain as much established vegetation as reasonably possible and provide substantial replacement landscaping.
Relationship to nearby shops and homes: The development should respond to the existing fine-grain character of the area, with a more gradual transition in height and mass rather than a large, continuous building form.
Traffic, parking and construction impacts: A development of this scale will increase vehicle movements, servicing, deliveries, waste collection and construction activity in the surrounding streets, which should be carefully assessed against the existing local conditions.
I am not opposed to appropriate housing development on the site. However, the current proposal appears to seek a level of height and density that is not sufficiently responsive to its immediate surroundings.
I respectfully request that Council require the proposal to be substantially redesigned, with a reduced overall height and bulk, greater articulation and setbacks at the upper levels, appropriate transitions to neighbouring homes, and significantly improved integration with the existing streetscape and surrounding shops and residential properties.

The provision of affordable housing should be recognised, but it does not remove the need for the development to achieve an appropriate built form and protect the amenity and character of the surrounding neighbourhood.

For these reasons, I ask Council to refuse the proposal in its current form, or require a substantially reduced and redesigned development that is more compatible with its surroundings

🚨 URGENT PLANNING ALERT:

Save Our Streetscape

(107 Silver Street)

Stop the 1970s Brutalist Overdevelopment — Demand Measured Density Instead!

Attention residents of Meeks, Victoria, Queen, Calvert, Gladstone, Central, Cavey, O’Hara, Fernbank and Silver Streets.

The future of our local neighbourhood character is at stake.

A development proposal for the old, vacant church site at 107 Silver Street is threatening to bring out-of-scale overdevelopment just at the bleeding edge of the cusp of the Marrickville Station TOD precinct.

We need measured density, not architectural overreach.🏛️

🚨 URGENT PLANNING ALERT:

The Problem vs. The Better Solution

Developers want to replace the old historic church with a nine story tower block,

You read that right.

And in a harsh, 1970s Brutalist architectural style.

The towering column design completely clashes with the single and dual-dwelling, mainly single-storey fronted homes that make our neighbourhood peaceful and unique.

We can achieve a win-win for density and heritage without destroying our streetscape:

What Developers Want: A bulky, out-of-character Brutalist block that ignores surrounding homes.

What is Sensibly Possible:

Subdividing the existing church into 6 strata apartments with underground parking—a sixfold increase in housing supply!

The Community Benefit:

This could easily include two 3-bedroom affordable housing units, all built no higher than the apex of the existing church roof.

🚶‍♂️ What Have You Got to Lose?

If you love your peaceful, low-rise stroll down to the Woolworths Metro on Illawarra Road, now is the time to speak up.

Be state and council allies for increased housing density, but it done in a measured, respectful way.

.⏱️ Action Required:

The Power of 11 Submissions

Did you know it only takes 11 objection submissions during the community consultation phase to trigger a public council hearing?

Your voice carries immense weight.

Let’s get involved and protect Marrickville from developer overreach.

How to act right now:

Write to the Inner West Council referencing the development at 107 Silver Street.

State your position:

You support increased density, but demand the overreach be scaled back to match the height of the existing roofline and complement local architecture.

Share this alert with your immediate neighbours on your street group chats and local pages!

Read this “word salad” letter lodged in the 107 Silver Street DA, but before you do, take a breath and sit down.

IT’S THE NUCLEAR WEAPON BEING DEPLOYED SO WADE THRU IT

Okay then, here goes …

CLAUSE 4.6 VARIATION
SECTION 16(3) AFFORDABLE HOUSING REQUIREMENTS FOR ADDITIONAL FLOOR SPACE
RATIO (FSR)

STATE ENVIRONMENTAL PLANNING POLICY (HOUSING) 2021
Version 1.0

Date: 27 August 2026

1. EXECUTIVE SUMMARY

This submission under Clause 4.6 of the Inner West Local Environmental Plan 2022 (“IWLEP22”)
seeks a variation to Section 16(3) of State Environmental Planning Policy (Housing) 2021 (“SEPP
(Housing) 2021”), which pertains to the additional height of buildings bonus where an FSR
applies.

This Clause 4.6 has been prepared in relation to a development application for the demolition of existing structures and the construction of a nine (9) storey, 24 unit in-fill affordable housing residential flat building with rooftop communal open space, two (2) basement levels,
landscaping and site works at 107 Silver Street, Marrickville.

As detailed in this written request for a variation to the bonus height development standard under Section 16 of SEPP (Housing) 2021, the proposed development meets the requirements prescribed under Clause 4.6 of the IWEP22.

2. SITE DESCRIPTION
The subject site is commonly known as 107 Silver Street, Marrickville, and is legally defined as Lot 1 in Deposited Plan 1098631 and Lot 1 in Deposited Plan 1098624. The land is located at the southern end of the block and has three street frontages: Silver Street to the northwest, Calvert Street to the southwest, and Silver Lane to the southeast (and Central over the zebra crossing).

The site is rectangular and has the following key parameters:

• Site area: 676.6m2
• Silver Street (northwest) frontage: 22.4m
• Calvert Street (southwest) frontage: 30.48m
• Silver Lane (southeast) frontage: 22.4m
• Side boundary (northeast): 30.48m

The site is the location of a former Marrickville Baptist Church and is a part one, part two storey brick building positioned over both existing lots. The building has limited setbacks, including none on part of Calvert Street, all of Silver Lane and partly to the adjoining property.

107 Silver Street, Marrickville
Cl. 4.6 | Affordable Housing Requirements for Additional FSR (Section 16(3) of SEPP Housing)

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Figure 1: Site Aerial (Source: SDT Explorer)

The land slopes both north to south and east to west. The high point is in the northeast at RL 14.72, and the low point is in the southwest at RL 12.15, a difference of 2.57m.

The high point is noted to be along Silver Lane, furthest from the intersection with Calvert Street.

The land is zoned R2 Low Density Residential under IWLEP22.

However, it is also identified as
land within a Transport Oriented Development (TOD) Area.

Silver Street and Calvert Street are characterised as residential streetscapes.

Silver Lane is functionally a service lane.

The local character is primarily one or two storey dwellings or semi-detached dwellings.

The immediate adjoining properties are:

• Northeast: A single storey rendered dwelling with a tile roof and rear garage at 105 Silver
Street.

• Southeast: A brick detached dwelling and rendered semi-detached dwellings with tile
roofs and rear vehicle access at 35, 37 and 39 Gladstone Street.

• Southwest: A single storey rendered dwelling with a tile roof, a two storey dwelling with
tile roof and two storey terrace with metal roof at 56, 58 and 60 Calvert Street.

• Northwest: Two storey and single storey rendered and brick dwellings at 128, 126A and
126 Silver Street.

107 Silver Street, Marrickville
Cl. 4.6 | Affordable Housing Requirements for Additional FSR (Section 16(3) of SEPP Housing)

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The site is not identified as affected by any specific constraints such as bushfire, flood, environmentally significant land and the like.

107 Silver Street, Marrickville

Cl. 4.6 | Affordable Housing Requirements for Additional FSR (Section 16(3) of SEPP Housing)

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3. VARIATION SOUGHT: SECTION 16(3) AFFORDABLE HOUSING REQUIREMENTS FOR
ADDITIONAL FLOOR SPACE RATIO

The environmental planning instrument to which this variation relates is the SEPP (Housing) 2021.

The development standard to which this variation relates is Section 16(3), which reads as follows:

16 Affordable housing requirements for additional floor space ratio

(1) The maximum floor space ratio for development that includes residential development to
which this division applies is the maximum permissible floor space ratio for the land plus an
additional floor space ratio of up to 30%, based on the minimum affordable housing
component calculated in accordance with subsection (2).

(2) The minimum affordable housing component, which must be at least 10%, is calculated as
follows—

(3) If the development includes residential flat buildings or shop top housing, the maximum
building height for a building used for residential flat buildings or shop top housing is the
maximum permissible building height for the land plus an additional building height that is the same percentage as the additional floor space ratio permitted under subsection (1).

Example - Development that is eligible for 20% additional floor space ratio because the development includes a 10% affordable housing component, as calculated under subsection (2), is also eligible for 20% additional building height if the development involves residential flat buildings or shop top housing.

(4) This section does not apply to development on land for which there is no maximum
permissible floor space ratio.

As land within a TOD Area, the site is prescribed a FSR of 2.5:1 and a 22m building height under
Section 155 of Chapter 5 in SEPP (Housing) 2021.

Under Section 16 of SEPP Housing 2021, the permitted maximum height can be increased up to
30% based on the extent of the affordable housing component as calculated in Section 16(2).

The proposal uses the full 30% bonus permitted, which (in the context of this Clause 4.6) increases the maximum height to 28.6m.

4. EXTENT OF NON-COMPLIANCE

As above, the maximum permitted height is 28.6m under Section 16 of SEPP (Housing) 2021
where the full 30% bonus is achieved.

Affordable Housing Component
Pursuant to Section 16 of SEPP Housing 2021, the affordable housing component must be at least 15% of the GFA to utilise the full 30% bonus. The table below details the proposed affordable
housing component.

107 Silver Street, Marrickville
Cl. 4.6 | Affordable Housing Requirements for Additional FSR (Section 16(3) of SEPP Housing)

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TOD FSR/GFA +30% Bonus Required AHC Proposed AHC

2.5:1 / 1,691.5m2 3.25:1 / 2,198.95m2 15% / 329.85m2 15.2% / 335.6m2

Height of Buildings

Pursuant to Section 16(3), the maximum building height for a building used for residential flat
buildings is the maximum permissible building height for the development on the land plus an additional building height that is the same percentage as the additional floor space ratio
permitted under subsection

(1). The full 30% bonus is pursued, resulting in a bonus in height of 6.6m and a new maximum building height of 28.6m.

As mentioned, the proposed building height is 32.82m. A variation of 4.22m (14.8%) is proposed.

The elements exceeding the bonus building height relate to part of the roof slab and the rooftop communal open space, including bathroom facilities, weather protection and access (i.e. fire , stairs and lift). Refer to the height blanket and sections below.

Then it’s blah blah blah for ten pages and we pick up with…

“… It is also observed that the Housing Delivery Authority (HDA) pathway is illustrating even greater heights in the locality. Initial support has been received from the HDA for a residential
development of up to 23 storeys at 1-15 Byrnes Street, 31-41 O'Hara Street & 20-22 Central
Avenue (SSD-137348238).

That site is similarly zoned R2 Low Density Residential and is also located within the Marrickville Train Station TOD Area.

While the circumstances of that proposal are distinct from the subject development, it provides a relevant indication of the scale of development that is now being contemplated within the locality under the State Government's
housing delivery framework.

For the purposes of assessing the compatibility of the proposed variation with the character of
the locality, it is appropriate to recognise that the locality is undergoing a transition in built form and development intensity.

The planning framework establishes a future development potential of at least approximately 22m under the TOD provisions, increasing to 28.6m where the applicable affordable housing bonuses are utilised.

The character of the locality should consequently be interpreted not only by reference to the existing 1–2 storey built form, but also
having regard to the strategic planning framework that applies to the land.

The proposed variation is not considered to be incompatible with this emerging character for the following reasons:

• The 28.6m building height is permissible on the site and all adjoining properties.

• That this development may be one of the first developments to seek the increased
development density does not in itself make the proposal incompatible with the locality.

• The contravention of the building height is primarily serving the lift core and lobby to
enable access to the rooftop communal open space, including its balustrading.

These elements are less an additional storey and more ancillary components to a high rise
residential flat building that is contemplated for the site under current planning
legislation.
• A portion of the roof slab of the highest residential level does exceed the building height.
However, all unit GFA is within the intended envelope.
• The extent of this variation is a considerably more modest footprint than the level below,
reducing its visibility and impact.

From multiple vantage points (Silver Street and Lane),
the building will read as compliant.

107 Silver Street, Marrickville

Cl. 4.6 | Affordable Housing

Requirements for Additional FSR (Section 16(3) of SEPP Housing)

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107 Silver Street, Marrickville
Cl. 4.6 | Affordable Housing Requirements for Additional FSR (Section 16(3) of SEPP Housing)
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As illustrated in the above images, the primary element exceeding the height will be visible from
Calvert Street.

However, it is of modest sizing, visibility, aided by colour and finish treatment. It
will be an integrated part of the roof, rather than a storey exceeding the planning framework.

The absence of development of the permitted scale does not mean such development is
incompatible with the locality, and the planning framework set by the State Government has
deliberately created a new scale of development for the locality.
In this context, the proposed development is compatible with the planned character of the
locality, and is therefore considered to align with the objective.
(b) to minimise adverse impacts on local amenity,

The adverse impacts on local amenity of the proposed contravention are satisfactory as:
• Overshadowing impacts of the entire development are compliant with the requirements
under Part 2.7 of the Marrickville DCP 2011. No property that currently receives solar
access to its POS is reduced below 2 hours.

While not all living room locations are known,
no single property façade is affected for more than 2 hours except the front façade of 56
Calvert Street.

2 hours of solar access is still achieved to the affected front façade, ensuring compliance is achieved.

While the lobby is visible along Calvert Street, it has
a modest footprint compared to the level below and is coloured to reduce its prominence
further, blending into the sky.

The bulk of this structure is minimised to, in turn, minimise
adverse impacts of the variation on local amenity.

• Visual privacy has been carefully managed through strategic window placement and
• The key element exceeding the building height is the lobby access to the communal open

(c) angles, blade and solid walls to balconies, aluminium perforated screening, planter
boxes and setbacks, to minimise adverse impacts on local amenity.

Specific to the height
variation, the design of the communal open space, which exceeds the maximum building
height, ensures visual privacy is maintained for all adjoining properties through
balustrade design and planting locations providing separation from sensitive interfaces.

• There are no view loss impacts in consideration of this application.

To provide an appropriate transition between buildings of different heights.
The site has three street frontages, comprising Silver Street, Calvert Street and Silver Lane.

Only one property directly adjoins the site, being the single storey dwelling at 105 Silver Street to the north, which occupies the full block width between Silver Street and Lane. While 1-2 storey
development is also opposite in all directions, the site has a limited direct interface with buildings
of different heights.

The major element that exceeds the building height is the lobby providing access to the
communal open space.

The lobby is set toward the southern end of the building and fronts Calvert
Street, rather than adjacent to or visible from the single storey dwelling at 105 Silver Street.

The balustrading for the communal open space does exceed the building height at the interface with 105 Silver Street.
However, the design of the balustrading is deeply integrated with the entire
architectural expression of the building and forms part of the overall façade and roof design.

It does not present as an isolated additional element, which reduces the perceived additional bulk and scale.

The principal built form associated with the height variation is focused toward the southern portion of the site, fronting Calvert Street.

The width of Calvert Street provides physical and visual separation between the proposed building and surrounding 1-2 storey development, assisting in
the transition between buildings of different heights.

Similarly, the lobby is substantially set back from both Silver Street and Silver Lane, reducing its visual prominence from these interfaces, which positively contributes to the integration of the building with the surrounding development.

The combination of the site's three street frontages, limited direct adjoining interface, positioning of the lobby (the key varying element) away from the adjoining single-storey dwelling, and substantial setbacks to the other street frontages ensures that the height variation does not result in an abrupt or visually dominant transition between buildings of different heights.

Accordingly, inclusive of the proposed height variation, the development provides an appropriate transition between the existing buildings and the taller built form anticipated within the locality.

Given the above, the objectives of Clause 4.3 have been met notwithstanding the contravention
in height.

It is therefore submitted that compliance with the bonus height of buildings development
standard is unreasonable and unnecessary for the circumstances, given that the proposal is
consistent with the objectives of the development standard.

7. ARE THERE SUFFICIENT ENVIRONMENTAL PLANNING GROUNDS?
Pursuant to Clause 4.6(3)(b) of IWLEP22, it must be demonstrated that there are sufficient environmental planning grounds justifying a contravention of the development standard.
In the matter of Initial Action Pty Ltd v Woollahra Municipal Council [2018] NSWLEC 118, Preston
CJ stated:

“The focus of cl 4.6(3)(b) is on the aspect or element of the development that contravenes
the development standard, not on the development as a whole, and why that contravention
is justified on environmental planning grounds.

The environmental planning grounds advanced in the written request must justify the contravention of the development standard, not simply promote the benefits of carrying out the development as a whole: see
Four2Five Pty Ltd v Ashfield Council [2015] NSWCA 248 at [15].”

The environmental planning grounds include:

Provision of Affordable Housing
Big Property Group Pty Ltd v Randwick City Council [2021] NSWLEC 1161 at [39]-[40] determined that a contravention of the height of buildings development standard through the delivery of new affordable housing was properly described as an environmental planning ground within the
meaning identified by Preston CJ in Initial Action Pty Ltd v Woollahra Municipal Council [2018].

While all habitable floor area is located below the 28.6m bonus building height, strict compliance
with the building height would reduce the provision of affordable housing on the land.

Of note, the maximum FSR of 3.25:1 has not been achieved in the proposed design, falling some
70m2 short at 3.146:1.

A reduction in building height to achieve compliant height would eliminate

107 Silver Street, Marrickville
Cl. 4.6 | Affordable Housing Requirements for Additional FSR (Section 16(3) of SEPP Housing)

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GFA set aside for affordable housing under the in-fill affordable housing policy generally, but most
notably under Section 156 of SEPP (Housing) 2021.

Section 156 requires at least 2% of the GFA of the building to be used as affordable housing if a
residential flat building (among others) has a GFA of at least 2,000m2 in a Transport Oriented
Development Area. This GFA must be affordable housing in perpetuity.

The proposed 2,128.6m2 GFA has met the threshold for the provision of affordable housing in
perpetuity. Unit G02 has been allocated as the relevant unit.

As Level 8, the top residential storey, has a 157.8m2 GFA, removal of this storey alone will push
the development below the 2,000m2 threshold.
As the components contravening the building height have negligible impacts, the provision of affordable housing, particularly the unit in perpetuity, is deemed a suitable environmental planning ground in this instance.

Communal Open Space
The building height variation is almost entirely limited to the provision of rooftop communal open space through its lobby, accessible toilet, the lift and stair core structures, an awning and various planters and other structures supporting the use of the space for that purpose.

No unit GFA is sought above the bonus building height. Refer to Figures 4-6.

The primary function of the variation is to provide access to the communal open space. The
provision of this space on the roof serves tangible amenity benefits for residents of the affordable and non-affordable components, as:

• The communal open space is of a suitable and compliant size at 185.4m2 / 27% of the site
area.

• The communal open space is able to be a consolidated, meaningful space by locating it
on the roof, rather than on the ground floor (and thus decimating the interaction between internal and external spaces on multiple street fronts) or on a level within the envelope,
and creating a hole in a façade.

• The rooftop location enjoys year-round solar access and will receive this, factoring in
redevelopment around the site.

• Substantial landscaping is achieved as a result of its rooftop location.

• Considerable district views are available to the space.

Given the variation is largely attributed to the communal open space and the development does
not meet its maximum FSR and thus is not exceeding the permitted density, the environmental benefits of the variation are considered a suitable environmental planning ground.

Consistency with the Objects of the Act

The development, including its variation to building height, is consistent with the following
objects of Act under Section 1.3 of the Environmental Planning and Assessment Act 1979:

(b) to promote the supply, delivery and maintenance of housing, including affordable
housing,

(g) to promote good design, amenity and the proper construction and maintenance of built environments, including the protection of the health and safety of the occupants of
building and promote the orderly and economic use and development of land.

The proposal will facilitate additional supply of affordable housing, and housing in general, as a direct consequence of the variation sought, including an affordable unit in perpetuity.

The application delivers a good design that respects its locality, adjoining land, and achieves a
high level of amenity to residents and maintains it to the adjoining properties, inclusive of the
portions contravening the building height that are centralised or focused away from adjoining properties.

The development is an orderly and economic use and development of land.

For the reasons above, there are sufficient environmental planning grounds to justify the
contravention of the development standard.

8. IS THE VARIATION WELL FOUNDED?
It is considered that this has been adequately addressed within this written submission. In
summary, this Clause 4.6 Variation is well founded as required by Clause 4.6 of the IWLEP22 in that:

• Compliance with the development standards would be unreasonable and unnecessary in
the circumstances of the development;

• There are sufficient environmental planning grounds to justify the departure from the
standard;

• The development meets the underlying objectives of the standard to be varied (Part 2,
Division 1 of SEPP Housing 2021; and the merit assessment of

Clause 4.3 Height of
Buildings of the IWLEP22);

• The breach does not raise any matter of State or Regional Significance.

Based on the above, the variation is considered to be well founded.

9. GENERAL

Clause 4.6 also states that:

(6) Development consent must not be granted under this clause for a subdivision of land
in Zone RU1 Primary Production, Zone RU2 Rural Landscape, Zone RU3 Forestry, Zone RU4 Primary Production Small Lots, Zone RU6 Transition, Zone R5 Large Lot
Residential, Zone C2 Environmental Conservation, Zone C3 Environmental
Management or Zone C4 Environmental Living if:

(a) the subdivision will result in 2 or more lots of less than the minimum area specified
for such lots by a development standard, or

(b) the subdivision will result in at least one lot that is less than 90% of the minimum
area specified for such a lot by a development standard.

(7) (Repealed)

(8) This clause does not allow development consent to be granted for development that
would contravene any of the following :

(a) a development standard for complying development,

(b) a development standard that arises, under the regulations under the Act, in connection with a commitment set out in a BASIX certificate for a building to which State Environmental Planning Policy (Building Sustainability Index: BASIX) 2004 applies or for the land on which such a building is situated,

(c) clause 5.4,

(caa) clause 5.5,

(ca) clause 6.27(4),

(cb), (cc) (Repealed)

(cd) clause 6.31.

This variation does not relate to the subdivision of land in the stated land use zones. The variation is not contrary to subclause (6).

Should the exception to the development standard sought under this submission be supported by Council, the Council must retain a record of the assessment of this submission.

The development proposed is not complying development.

A BASIX certificate has been submitted with the application.

The development does not rely on or conflict with any of the clauses referenced in (c) and (cd).

10. CONCLUSION

The proposal does not strictly comply with the height of buildings bonus under Section 16(3) of SEPP Housing 2021. Having evaluated the likely effects arising from this contravention, we are
satisfied that the objectives of

Clause 4.6 of the IWLEP22 have been met, as there are sufficient
environmental planning grounds and the objectives of the standards are still met.

Consequently, strict compliance with this development standard is unreasonable and
unnecessary and the use of Clause 4.6 of the IWLEP22 to vary this development standard is
appropriate in this instance.

Based on the above, it is sensible to conclude that strict compliance with the bonus provisions is unnecessary and that a better outcome is achieved for this development by allowing flexibility in the application.

Darren Laybutt
Senior Town Planner
GAT & Associates
E: [email protected]
P: 02 9569 1100
Ref. P3903

Benson McCormack Architecture - the designers behind 107 Silver - is an architectural studio located nearby in Lilyfield, in Sydney’s Inner West.

BMA are known for designing residential and mixed-use urban infill projects across Sydney's Inner West.

Apparently, BMA projects emphasise contextual masonry, community integration, and sustainable density, whatever that is supposed to mean.

That idea reminds me of an old Jerry Seinfeld joke: “What is the Limited sign on a Ford car about? … Limited to how many people will buy one I guess?!?”

(cue canned laughter)

Notable Inner West BMA Projects:

Wave (Marrickville): A mixed-use development featuring 34 apartments and ground-floor retail built around a central courtyard, using soft curved concrete and face brickwork.

Mosaic (Marrickville): A multi-residential and retail building featuring oversized layouts, detailed brickwork, and a large communal terrace on Illawarra Road.

The Bakery (Marrickville): An urban infill project replacing an old industrial foundry with five sensitively designed terrace houses near Henson Park.

Kindred (Marrickville): A contemporary 39-apartment residential and retail development on Marrickville Road.

Art House (Marrickville): A live-work apartment and retail project on Hutchinson Street.

BMA Studio Office HQ Details:

Studio 5, 505 Balmain Road, Lilyfield NSW 2040

+61 2 9818 0777

[email protected]

Be informed as you consider your position on 107 Silver, the old Baptist church on the corner of Calvert opposite Central and serviced by Silver Lane …

… In the official NSW Planning Spatial Viewer maps for the State Environmental Planning Policy (Housing), every square millimetre of 107 Silver Street, Marrickville sits entirely inside the 400m Transport Oriented Development (TOD) boundary.

Because the TOD zone boundary is drawn as a perfect radial circle extending out from a fixed reference point at Marrickville Station, the property - including the rear corner facing Silver Lane - is safely clear of the 400-metre cutoff mark.

However, being completely inside the TOD boundary zone does not give a Slick architect’s design a free pass to ignore standard building restrictions.

Sit with that last bit a moment before reading on.

Recent Inner West Architectural Excellence & Design Review Panel (AEDRP) records and planning alerts specifically concerning 107 Silver Street highlight why a 33-metre + flat roof structure faces massive compliance roadblocks:

1. The Height & Bulk Problem

The TOD SEPP sets a mandatory maximum height limit of 22 metres (approx. 6 storeys) for residential flat buildings in this zone.

Even if a developer should secure the maximum 20% affordable housing height bonus by dedicating 10% or more of the building's Gross Floor Area (GFA) to affordable housing, the ceiling caps out at 26.4 metres (roughly 7 storeys).

Demanding a 33-metre structure introduces massive non-compliance issues regarding upper-level bulk, overshadowing, and visual impact on the surrounding streetscape.

2. Inner West Panel Directives

A pre-DA proposal (PDA/2025/0247) submitted for this exact address - seeking a 7-storey flat residential building -already faced significant scrutiny.

Council planners and independent panel assessments have heavily reinforced that the TOD policy is not a tool to justify maximum development at any cost.

Any design on the old church lot must legally balance the state up-zoning with the immediate context of low-rise neighbouring homes, requiring appropriate setbacks, tapering, and a scale much lower than a 33-metre square block.

3. Absolute Airport Ceilings

Because Marrickville is located directly underneath the Sydney Airport Obstacle Limitation Surfaces (OLS) flight path, there is a hard, legal altitude limit enforced by federal aviation laws.

A 33-metre structural height combined with the natural elevation of Silver Street will likely penetrate the protected airspace buffers.

No amount of local planning or state affordable housing bonuses can override air traffic control safety restrictions.

Hold the developers to account for overreach and think about what is fair and reasonable in technical terms to achieve a far “better outcome” in the development moving forward.

Make your voice be heard by making a submission after visiting the subject site and using the QR code on the fence notice that will easily allow you to submit that your position is:

1. Oppose
2. Support
3. Neutrality (Why? Who knows?)

Go check it all out before it’s too late to do anything about the construction of a tall tower block.

Amongst a heap of other things, of the many mature, healthy, tall trees this development will fell for overdevelopment, 6 - repeat - six, are acknowledged by the contracted arborist assessor as having “moderate to high” importance and therefore of value and worth not destroying.

That said, just one Tuckeroo Tree - barely 4 metres tall - will get to survive this cull.

Just one, and one of the smallest too.

Well that’s not balanced canopy management now is it?

C’mon neighbours!

Push back before October comes and it’s Of all the many trees this development will fell for overdevelopment, 6, I repeat six are acknowledged by the contracted arborist assessor as having “moderate to high” importance.

And hey! It’s just one Tuckeroo - barely 4 metres tall - that gets to survive the cull and live on.

Well that’s not really any sort of balanced canopy protection right there, now is it?

C’mon neighbours! Push back on this overreach before October hits and it’s too late.

Just TEN MORE days until that super-slim “community consultation” window slams shut!

🚨 URGENT:

Stop the 33-Metre Monster Tower at 107 Silver Street!

🚨A massive development has been lodged for 107 Silver Street, Marrickville—and Inner West Council is keeping the neighbourhood completely in the dark!

The Secret:

Council only mails people who share a direct fence.

I live just 260 metres away on Calvert Street and got zero warning.

I only found out by walking past a tiny sign!

The Reality:

A developer is trying to cram a 9-storey tower containing 24 flats onto a single block because it is within 400 metres walking of Marrickville Station (by just a few precious centimetres).

What is planned will soar over 33 metres high, destroying 9 mature trees and overwhelming our street network and probably disturbing the landing and taking off planes of Sydney’s main airport.

The Loophole:

The over-developers are using overreach to overexploit the state government’s Transport Oriented Development (TOD) 400m zone rules.

By including a tiny 10% slice, sliver, meagre portion of affordable housing (units to count on just the one hand), the developers (by way of their architects BMA) are claiming a massive "bonus" height allowance and still breaching that bonus limit by more than 4 metres!

SERIOUSLY!

💥 CALL TO ACTION: WE NEED EVERYONE TO ACT NOW!

💥Copy, paste, and blast this text immediately into your local WhatsApp chats, Facebook groups, and activist collectives like Save Marrickville.

Developers count on our silence to slip these mega-monoliths through.

Tools like PlanningAlerts are the only way to bridge the gap and stop these closed community briefings from hiding the truth.

Don't let the development aggression ruin Marrickville's local character.

Look at the architectural blueprints, track the critical submission deadlines, and log your official planning objection on the 107 Silver Street PlanningAlerts Page.

Also go to 107 Silver Street, take in the surroundings, then use the QR code on the fence to make a submission straight to the council case officer Camille.

You have ten days to have your voice heard people. Don’t waste it!

🚨 THE TOD MEGA-TOWERS ARE COMING:

66 Calvert Street is up for sale! 🚨

Brace yourself, Marrickville.

Directly across the street from the massive proposal at 107 Silver Street, 66 Calvert Street has hit the market - and hungry developers are licking their lips.

The Reality:

66 Calvert Street sits squarely inside the NSW Government’s Transport Oriented Development (TOD) 400-metre station zone.

Let that sink in.

The Threat:

This zone strips away local council protections to allow high-density, mid-rise apartment blocks with fast-tracked approvals.

The Next Fight:

If we don’t stand up against 107 Silver Street right now, 66 Calvert Street will be the next domino to fall into a massive wall of overdevelopment.

💥 DON'T LET THEM ALL KEEP US IN THE DARK BEING FED BS LIKE MUSHROOMS! 💥

Copy, paste, and blast this warning into your local WhatsApp chats, Facebook groups, and neighbourhood collectives like Save Marrickville.

Developers rely on neighbors not realizing what TOD zoning actually means until the bulldozers turn up.

Use PlanningAlerts to monitor this site the second a developer lodges a plan for 66 Calvert (in the corner of Central Ave.)

Get ahead of the game.

Track the 66 sale, look at the zoning disruption that is permissible.

And above all else, get ready to keep on fighting like hell for our suburb on PlanningAlerts.

Don’t forget, motivated developers rely on local apathy and timelines fatigue.

Nine storeys is ludicrous!

It's seven storeys too much.

🚨 THE TECH EXPERTS HAVE SPOKEN:

3 Weak Spots to Deny the 107 Silver Street Tower!

🚨professional town planners have audited the massive 9-storey, 24-flat mega-tower proposed for 107 Silver Street, Marrickville.

They found the critical technical flaws developers don't want the public to know about.

Council must reject a DA if it fails these technical tests.

Here are the exact weak spots we need to flood into our objections to scale back this project:

🚗 Traffic Chaos & Gridlock:

This tower will paralyze the already dangerous Silver St / Central Ave / Calvert St / Silver Lane intersection behind the Gladstone.

The planners confirm this build forces a critical need for new traffic lights and zebra crossings to cope with the permanent change to through-traffic.

🌊 Water, Sewage & Flood Risks:

We are in a known flood-prone zone.

The plans fail to sufficiently show how the sewer, water supply, and stormwater networks can handle 24 extra households without backing up into neighbouring properties.

🗑️ Bins, Air Traffic & Pollution:
Where do bins for 24 flats go on a corner tower block that faces three slim streets?

Nowhere safe.

Plus, the 33-metre height triggers serious air traffic control constraints and traps local air pollution.

💥 CALL TO ACTION:
WEAPONISE THIS DATA NOW! 💥

Copy, paste, and blast these technical facts into your local WhatsApp chats, Facebook groups, and resident collectives like Save Marrickville.

Don't let the developers and architects and council hierarchy hide behind a closed community briefing.

Grab these points, head to the 107 Silver Street Inner West Portal Page, and file your official objection using these exact technicalities before the “community consultation” deadline slams shut!

From Inner West Panel Meeting February 25, 2026

Architectural Excellence & Design Review Panel
Meeting Minutes & Recommendations

Site Address: 107 Silver Street MARRICKVILLE NSW 2040

Proposal:

Demolition of the existing structures (the former church) and the construction of a 7 storey
residential flat containing (at least) 16 units and 2 basement levels

Application No.: PDA/2025/0247

Meeting Date: 3 February 2026

Panel Members:

Diane Jones (Chair)
Jean Rice
Peter McGregor

Apologies: -

Council staff:

Kaitlyn Attard
Thomas Irons
Rory Toomey
Sinclair Croft
Helen Wan

Declarations of Interest:
None

Applicant or applicant’s
representatives to
address the panel:

Glenn McCormack (Director, Benson McCormack Architecture)
Daniel Martins (Student of Architecture, Benson McCormack
Architecture)
Darren Laybutt (Town Planner, GAT & Associates)

Inner West AEDRP – Meeting Minutes & Recommendations

Page 1 of 3
Background:

1. The Architectural Excellence & Design Review Panel reviewed and discussed the proposal with
the applicant through an online conference.

2. The Panel acknowledges that the proposal is subject to Chapter 4 – State Environmental Planning
Policy (SEPP) Housing 2021 - Design of residential apartment development - and the NSW
Apartment Design Guide (ADG) applies to the proposal. Additionally, the Panel reviewed the proposal in terms of design excellence as required by the Inner West Local Environmental Plan 2022 – Clause 6.9.

3. The Panel notes the proposed development is a Transport Oriented Development (TOD) site,
with the maximum height and FSR requirement increased to 22m and 2.5:1 under Chapter 5
Transport Oriented Development of the SEPP, notwithstanding that the land zoning remains R2
Low Density Residential.

Discussion & Recommendations:

1. Site Planning and Urban Design:

a. The Panel discussed the opportunity for the development to be built to the northern boundary, adjoining 105 Silver Street, noting the emerging pattern of zero-lot-line development in the
area.

Extension to the boundary wall could set a valid precedent for the precinct and give
opportunities for a simpler built form with better street interfaces and residential amenity.

b. The applicant should ensure that the 3m setback associated with the deep soil zone is
functional and capable of supporting substantial trees. Further the design should be amended to provide tree planting along Silver Lane.

c. The Panel appreciates the thorough and well considered urban design analysis and requests that the plans and sections of the surrounding buildings/proposed envelopes be shown on the next set of application drawings (as well as in the models).

2. Ground Plane Configuration and Landscape Design:

a. The Panel encourages the applicant to strengthen the development’s relationship with the public realm, noting that street activation in the current design is limited. The Panel
recommends the following strategies:

▪ Enhance active street frontages beyond the lobby, for example with individual
residential entries, ensuring compatibility with the streetscape and supporting future pedestrian movement patterns.

▪ Consideration of a primary entry from Silver Street associated with common spaces to cultivate a stronger sense of arrival and/or reworking the current lobby design to
integrate a community-oriented meeting space that creates a more generous and welcoming entry.

▪ The organisation of communal open spaces should be improved to ensure they are
meaningfully integrated with circulation areas and visually connected throughout the
ground plane.

b. c. The proposed car lift is supported by the Panel given the limited site area.

The Panel requests the applicant provides a clear waste management strategy demonstrating bin arrangements and the method for transferring waste to the street.

d. Further clarification in relation to the requirement of street-facing services including sprinkler assemblies, hydrant boosters and the like should be provided, given that these elements can significantly impact the street presentation.

They should be coordinated with engineering input.

Inner West AEDRP – Meeting Minutes & Recommendations

Page 2 of 3

3. Architectural Resolution:
a. b. c. d. The Panel notes that the current elevation to Calvert Street should be reconsidered to avoid a visually defensive character.

The applicant is encouraged to increase glazing and lower
window sill heights to articulate the façade at a human scale and create a more generous,
visually engaging street interface with greater opportunities for passive surveillance.

The Panel encourages the applicant to further model the rooftop pods and communal open space to minimise their perceived visual weight and sense of detachment.

The Panel suggests that the overall clarity of the proposal could be improved by the
rationalisation of the floorplan stacking that is currently giving a complex building form on a
relatively small site.

There may also be opportunities to use the podium for a different
residential typology such as town houses, which would be compatible with the individual
entries suggested in point 2a above.

The location and treatment of the AC plant should be provided and clearly indicated on the
drawings.

Conclusion:

1. 2. Recognising its independent, expert and advisory role, the Panel notes the careful urban design analysis of the proposal and the apartment designs achieving solar access, cross ventilation and well-located balconies.

In order to obtain the Panel’s full endorsement, the matters outlined in this report should be positively addressed by the applicant.

Given the number of detailed matters requiring further refinement and resolution, particularly in relation to the overall architectural and landscape design expression and character, the interface
with the street and the design of communal open space, the Panel requests that developed
design material be submitted for further review as part of another pre-DA meeting.

Inner West AEDRP – Meeting Minutes & Recommendations

Page 3

3. Architectural Resolution:
a. b. c. d.

The Panel notes that the current elevation to Calvert Street should be reconsidered to avoid a
visually defensive character.

The applicant is encouraged to increase glazing and lower
window sill heights to articulate the façade at a human scale and create a more generous,
visually engaging street interface with greater opportunities for passive surveillance.

The Panel encourages the applicant to further model the rooftop pods and communal open space to minimise their perceived visual weight and sense of detachment.

The Panel suggests that the overall clarity of the proposal could be improved by the
rationalisation of the floorplan stacking that is currently giving a complex building form on a
relatively small site.

There may also be opportunities to use the podium for a different
residential typology such as town houses, which would be compatible with the individual
entries suggested in point 2a above.

The location and treatment of the AC plant should be provided and clearly indicated on the
drawings.

Conclusion:

1. 2. Recognising its independent, expert and advisory role, the Panel notes the careful urban design analysis of the proposal and the apartment designs achieving solar access, cross ventilation and well-located balconies. In order to obtain the Panel’s full endorsement, the matters outlined in this report should be positively addressed by the applicant.

Given the number of detailed matters requiring further refinement and resolution, particularly in relation to the overall architectural and landscape design expression and character, the interface with the street and the design of communal open space, the Panel requests that developed
design material be submitted for further review as part of another pre-DA meeting.

Developing a multi-story Transport Oriented Development (TOD) project at 107 Silver Street, Marrickville—especially given its tight footprint and location right on the edge of the TOD boundary transitioning into extensive low-density housing—presents a minefield of inevitable planning friction.

When assessing or drafting a Development Application (DA) for this site, the following non-compliance issues and planning hurdles are nearly impossible to avoid:

1. Solar Access, Overshadowing, and Visual Privacy (ADG Compliance)Because the state's TOD controls allow heights of up to 22 to 24 metres (approx. 6–7 storeys), dropping a building of this scale directly adjacent to hundreds of metres of single- and dual-story family homes makes compliance with the NSW Apartment Design Guide (ADG) incredibly difficult.

Overshadowing: A mid-rise building will severely impact the mandatory solar access required for the private open spaces and north-facing windows of neighbouring low-density properties.

Visual Privacy: Achieving the required ADG boundary setbacks to prevent direct overlooking into adjacent backyards and living spaces is nearly impossible on a standard-sized urban block without heavily compromising the building's floor plate.

2. Site Context, Infrastructure, and Servicing ConstraintsAccording to the Inner West Council's Architectural Excellence & Design Review Panel (AEDRP) evaluation specifically for 107 Silver Street, the site's compact area (689 m²) and surrounding narrow streets spark immediate compliance red flags:

Waste Management: Demonstrating a compliant waste management strategy - specifically how large bins are stored and moved to the narrow street for collection without obstructing traffic or creating an eyesore - is a primary pain point.

Street-Facing Services: Fitting necessary high-density infrastructure like fire hydrant boosters, sprinkler assemblies, and substation elements without violating streetscape presentation rules is highly problematic on this restricted corner.

Vehicle Access: Because of the tight boundaries, standard ramp configurations fail compliance, forcing developers to rely on complex alternatives like car lifts.

3. Lot Width and Building SetbacksMinimum Lot Width: The NSW TOD framework introduces a minimum lot width requirement of 21 metres.

If the site's dimensions fall short on its primary frontage, a formal Clause 4.6 variation request is mandatory just to progress.

Deep Soil Zones: High-density developments require a specific percentage of the site to be dedicated to deep soil for mature tree canopy planting.

Balancing a massive TOD floor space ratio (FSR) of 2.5:1 with deep soil compliance on a small lot is an architectural paradox.4.

Heritage and Character Transitions

Protection:

Community and council groups (such as Save Marrickville) have continuously pushed to safeguard the historic and period character of areas like Silver Street.

Abrupt Interface:

Even though the state's TOD policy overrides parts of the local Local Environmental Plan (LEP), councils heavily scrutinize "edge effects"—where a 6-story wall meets a 1-story cottage. A failure to provide a stepped, sympathetic setback transition will result in a non-compliance rejection under local DCP streetscape rules.

"Design Excellence" is the strategic play for the developers of 107 Silver Street (the old church).

For developers trying to push the boundaries of state-mandated Transport Oriented Development (TOD) Under Clause 6.9 of the Inner West Local Environmental Plan (LEP), demonstrating design excellence is a baseline legal trigger to unlock density.

Hammer that phrase into your mind because it’s the key to all this: design excellence, design excellence, design excellence!!!

You see, the developer behind 107 Silver Street has weaponised this strategy to propose a 9-storey building (24 units) on a tiny sub-700 m2 lot size, using that powerful legal password to overdevelopment:

"Design Excellence"!!!

Design Excellence is exactly the strategic play for developers trying to push the boundaries of state-mandated Transport Oriented Development (TOD) frameworks.

Under Clause 6.9 of the Inner West Local Environmental Plan (LEP), demonstrating design excellence is a baseline legal trigger to unlock density (= more house/more occupants).

The developer behind 107 Silver Street has weaponised this strategy to propose a 9-storey building (24 units) on a tiny 676sqm footprint, utilising affordable housing bonuses and pushing 4 metres past the allowable TOD height limit.

However, the community, the Inner West Council, and objectors have a powerful, nuclear counterplay to neutralise this strategy.

The Nuclear Counterplay:

"The Contextual Veto"The core rule of planning law in New South Wales is that Design Excellence is not an abstract beauty pageant.

A building cannot achieve "design excellence" if it completely destroys the amenity and context of the ground it sits on.If you are fighting this development, the atomic counter-argument is built on three pillars:

1. Weaponise the "Edge Effect" (The Context Failure)Under LEP Clause 6.9, the consent authority must evaluate whether the building form improves the amenity of the public domain and protects surrounding solar access.

The Counter:

107 Silver Street sits directly on the bleeding edge of the TOD boundary.

Dropping a 9-storey wall directly flush against single- and dual-story family homes represents a catastrophic failure of transitional urban design.

The Argument:

No amount of premium architectural cladding or "gorgeous aesthetics" can substitute for proper transitions.

If a design creates an unacceptable, abrupt interface that robs decades-old homes of light and air, it fails the statutory definition of design excellence as a matter of law.

2. The Internal Paradox
(The Architectural Excellence Panel’s Own Words)

Council's Architectural Excellence & Design Review Panel (AEDRP) already reviewed the preliminary plans for (PDA/2025/0247) and handed the opposition their ammunition:

The Site is Simply Too Small:

The AEDRP noted the site's footprint is incredibly restricted.

To cope, the developer is forced to use a car lift instead of a functional ramp, and the required 3-metre deep-soil zones are physically squeezed to their absolute structural limits.

The Nuclear Angle:

You cannot claim a building achieves "design excellence" when its basic programmatic elements (waste management, vehicle circulation, and tree canopies) are relying on awkward architectural compromises just to function on a deficient lot.

3. State vs. Local "Grip"

(The Inner West Council LEP Amendment)

In mid-2026, the Inner West Council actively moved to amend LEP Clause 6.9 to formalise and mandate independent Design Review Panels.

Council did this specifically to tighten its grip on large-scale developments.

The Counter: Opponents are leaning on this policy shift to argue that the developer's 9-storey scale yields a highly transient, poor-quality living environment.

By focusing on "human scale" and the local character of Silver Street - a street historically preserved with period cottages - the community can legally argue that the proposal violates the LEP's baseline character protections footprint, utilising affordable housing bonuses and pushing 4 metres past the allowable TOD height limit.

However, the community, the Inner West Council, and objectors have a powerful, nuclear counterplay to neutralize this strategy.

The Nuclear Counterplay: "The Contextual Veto"The core rule of planning law in New South Wales is that Design Excellence is not an abstract beauty pageant.

A building cannot achieve "design excellence" if it completely destroys the amenity and context of the ground it sits on.

If you are fighting this development, the atomic counter-argument is built on three pillars:

1. Weaponise the "Edge Effect" (The Context Failure)

Under LEP Clause 6.9, the consent authority must evaluate whether the building form improves the amenity of the public domain and protects surrounding solar access.

The Counter: 107 Silver Street sits directly on the bleeding edge of the TOD boundary.

Dropping a 9-storey wall directly flush against single and dual-story family homes represents a catastrophic failure of transitional urban design.

The Argument:

No amount of premium architectural cladding or "gorgeous aesthetics" can substitute for proper transitions. If a design creates an unacceptable, abrupt interface that robs decades-old homes of light and air, it fails the statutory definition of design excellence as a matter of law.2.

The Internal Paradox (The Architectural Excellence Panel’s Own Words)

Council's Architectural Excellence & Design Review Panel (AEDRP) already reviewed the preliminary plans for (PDA/2025/0247) and handed the opposition their ammunition:

The Site is Simply Too Small:

The AEDRP noted the site's footprint is incredibly restricted. To cope, the developer is forced to use a car lift instead of a functional ramp, and the required 3-metre deep-soil zones are physically squeezed to their absolute structural limits.

The Nuclear Angle: You cannot claim a building achieves "excellence" when its basic programmatic elements (waste management, vehicle circulation, and tree canopies) are relying on awkward architectural compromises just to function on a deficient lot.

3. State vs. Local "Grip" ( using "Design Excellence" is exactly the strategic play for developers trying to push the boundaries of state-mandated Transport Oriented Development (TOD) frameworks. Under Clause 6.9 of the Inner West Local Environmental Plan (LEP), demonstrating design excellence is a baseline legal trigger to unlock density.

For example, the developer behind 107 Silver Street has weaponised this strategy to propose a 9-storey building (24 units) on a tiny 676sqm footprint, utilizing affordable housing bonuses and pushing 4 metres past the allowable TOD height limit.However, the community, the Inner West Council, and objectors have a powerful, nuclear counterplay to neutralize this strategy.

The Nuclear Counterplay:

"The Contextual Veto”

The core rule of planning law in New South Wales is that Design Excellence is not an abstract beauty pageant.

A building cannot achieve "design excellence" if it completely destroys the amenity and context of the ground it sits on.

If you are fighting this development, the atomic counter-argument is built on three pillars:

1. Weaponise the "Edge Effect" (The Context Failure)Under LEP Clause 6.9, the consent authority must evaluate whether the building form improves the amenity of the public domain and protects surrounding solar access.

The Counter: 107 Silver Street sits directly on the bleeding edge of the TOD boundary.

Dropping a 9-storey wall directly flush against single- and dual-story family homes represents a catastrophic failure of transitional urban design.

The Argument: No amount of premium architectural cladding or "gorgeous aesthetics" can substitute for proper transitions. If a design creates an unacceptable, abrupt interface that robs decades-old homes of light and air, it fails the statutory definition of design excellence as a matter of law.

2. The Internal Paradox (The Architectural Excellence Panel’s Own Words)

Council's Architectural Excellence & Design Review Panel (AEDRP) already reviewed the preliminary plans for (PDA/2025/0247) and handed the opposition their ammunition:

The Site is Simply Too Small:

The AEDRP noted the site's footprint is incredibly restricted. To cope, the developer is forced to use a car lift instead of a functional ramp, and the required 3-metre deep-soil zones are physically squeezed to their absolute structural limits.

The Nuclear Angle: You cannot claim a building achieves "excellence" when its basic programmatic elements (waste management, vehicle circulation, and tree canopies) are relying on awkward architectural compromises just to function on a deficient lot.

3. State vs. Local "Grip" (The Inner West Council LEP Amendment)In mid-2026, the Inner West Council actively moved to amend LEP Clause 6.9 to formalise and mandate independent Design Review Panels.

Council did this specifically to tighten its grip on large-scale developments.

The Counter:

Opponents are leaning on this policy shift to argue that the developer's 9-storey scale yields a highly transient, poor-quality living environment.

By focusing on "human scale" and the local character of Silver Street - a street historically preserved with period cottages -the community can legally argue that the proposal violates the LEP's baseline character protections

The Inner West Council LEP Amendment)

In mid-2026, the Inner West Council actively moved to amend LEP Clause 6.9 to formalise and mandate independent Design Review Panels.

Council did this specifically to tighten its grip on large-scale developments.

The Counter: Opponents are leaning on this policy shift to argue that the developer's 9-storey scale yields a highly transient, poor-quality living environment.

By focusing on "human scale" and the local character of Silver Street—a street historically preserved with period cottages—the community can legally argue that the proposal violates the LEP's baseline character protections

I am a resident of Gladstone Street with a property that backs onto Silver Lane. While, I am supportive of housing growth, I believe this proposed development is not in the best interests of people in the local area. It breaches the height requirements for housing in this residential area and does not enhance the area rather it negatively impacts it creating privacy, light and noise issues as well as affects the overall character of the area Marrickville is valued for. The local area does not have the capability to cope with additional traffic and parking. It is already difficult to park and navigate driving around the streets as it is. There are pedestrians, children and older adults in the area. The disruption to residents of construction would also be significant. Additionally, the Grey Headed Flying Fox, which is listed as a vulnerable species, flies across this area at dusk and additional light, noise and dust may affect them.

Just over the street on Calvert, 68 Calvert Street, Marrickville sold on 27 August 2026.

That said, although it is highly unlikely to have been bought by a developer for a standalone high-density project.

The transaction data and property specifics show this is a standard residential asset rather than a developer's play:

Immediate Rental Listing:

Right after the sale, the property was immediately listed for lease by The Agency Inner West for $1,200 per week, with an availability date of 10 October 2026.

Developers rarely put a site straight back onto the long-term residential rental market if they intend to demolish it quickly.

Tiny Footprint:

The property at 68 is a standard freestanding 3-bedroom home on a very small block of just 196 m².

Unlike the 676 m² block at 107 Silver Street, a 196 m² plot is structurally impossible to develop into a multi-story TOD building on its own.

The Only Exception
(Site Amalgamation):

The only way a developer has a play here is if 68 Calvert Street was quietly purchased as part of a site amalgamation strategy (buying out a row of multiple consecutive neighbours to patch together a large enough site to trigger TOD minimum lot sizes).

If it was bought by a developer, it's a long-term land-banking play while they try to buy the rest of the block (the next door neighbours and their next door neighbours.

Otherwise, it was simply snapped up by a standard private investor capitalising on Marrickville's booming rental market.

The 400m Inner Circle TOD:

The 68 Calvert Street property is a brief walk from the upgraded Marrickville Train Station, comfortably well inside the 400m state planning trigger zone, meaning it inherits the 22-to-24-metre height allowances (approx. 6 storeys) and the high-density 2.5:1 Floor Space Ratio (FSR).

The Amalgamation Target: Because it sits within the active zone but features a tiny 196 m² footprint, it cannot be developed alone due to the strict 21-metre minimum lot width rule.

The Neighbourhood Context: Calvert Street runs parallel to the rail line corridors.

This makes the entire row of low-density cottages prime real estate for a developer looking to quietly buy up 3 to 5 continuous blocks to create a massive high-density master lot.

If a developer did snap up 68 Calvert Street, putting it immediately back on the rental market for $1,200 per week is a classic, tactical land-banking move.

It generates immediate yield while they negotiate off-market buyouts with the direct neighbours on the last block until Illawarra Road.

Following the aggressive planning push across the road at 107 Silver Street - where a developer is using affordable housing bonuses to force through a 9-storey tower block on a tiny footprint - a clear blueprint has been set for our neighbourhood.

However, a secondary tower cannot legally happen as a standalone project at 66 or 68 Calvert Street alone.

Despite sitting securely inside the Marrickville Transport Oriented Development (TOD) zone, these two corner blocks are legally landlocked by narrow geometry.

A multi-storey tower block here can only proceed if developers successfully target, secure, and amalgamate the immediate next-door neighbours on Calvert Street).

Why They Need the Neighbours

(The 21m Rule)

The NSW Government's TOD SEPP introduces a strict, non-negotiable minimum lot width requirement of 21 metres for any residential flat building.

The 66 and 68 Calvert Deficit:

On its own, 66 Calvert Street features a front facade of only 7 metres and 68 has less.

Even with lucrative 22-to-24-metre height allowances on paper, it is physically and legally restricted to a maximum of 2 storeys under local Inner West Council controls.

The Amalgamation Play:

To replicate the 107 Silver Street play and trigger the massive 2.5:1 Floor Space Ratio (FSR), a developer must stitch three properties together to cross that 21-metre finish line, so to speak.

Under the Inner West Development Control Plan (DCP), trying to cram an on-site electrical substation, gas meter banks, and a main telecommunications distribution frames (MDF) as well as find water and sewage and stormwater solutions on a very tight and busy residential corner intersection without ruining the street facade breaches multiple strict planning codes.

Here is an objection email template that includes technical references to infrastructure code breaches that you can copy, paste and send off to Council this week.

Subject: Formal Objection: DA/2026/0724 – 107 Silver Street, Marrickville NSW 2204 – Unwarranted Clause 4.6 Variation, Critical Utility Failures, and Severe Site Over-Development

To: [email protected]

Attention: The General Manager / Assessing Planning Officer

Dear Sir/Madam,

I am writing to lodge a formal objection against DA/2026/0724 for the proposed 9-storey development at 107 Silver Street, Marrickville.

While the community acknowledges that the State Environmental Planning Policy (Housing) grants a 30% height bonus for providing infill affordable housing, the applicant has flagrantly exceeded even this generous state mandate.

The maximum legal height allowed under the cumulative TOD framework and affordable housing bonus is 28.6 metres. By proposing a building height of 32.82 metres (9 storeys), the developer is seeking a further 4.22-metre non-compliant height extension.

This requires a Clause 4.6 variation that fails basic planning tests and must be refused by the Inner West Local Planning Panel (IWLPP).

The application represents an unsustainable over-development of a restricted 676 m² corner plot, failing on the following specific technical, utility, and statutory grounds:

1. Failure of the Clause 4.6 Height Variation (The 4.22m Overrun)

The applicant's Clause 4.6 Variation Request fails to prove that compliance with the 28.6-metre standard is "unreasonable or unnecessary".

The additional 4.22 metres serves no public benefit; it is a developer cash-grab that directly drives a catastrophic "edge effect" failure.

Dropping a 32.82-metre vertical mass immediately adjacent to extensive swathes of single- and dual-story family homes completely obliterates the mid-winter solar access and visual privacy of low-density properties on Silver Street.

2. Electricity, Gas, and Communications Infrastructure Code BreachesCramming infrastructure for 24 high-density apartments onto this micro-footprint creates direct non-compliance with the Inner West DCP guidelines regarding active street frontages and visual amenity:

Substation Blight:

A 9-storey building triggers a heavy power draw that will necessitate an on-site Ausgrid kiosk substation.

Under Ausgrid standard NS156 and DCP controls, these cannot be hidden deep inside basements.

Because the site footprint is tiny, the applicant is forced to place this bulky, industrial infrastructure directly on the Silver Street or Silver Lane boundary, violating codes that ban dominant utilities from destroying streetscape presentation.

Gas Meter and MDF Room Clutter:

Squeezing massive gas meter banks and primary telecommunication distribution nodes (MDF) onto the ground floor leaves no space for architectural integration.

This forces structural layout compromises that expose ugly ventilation panels and steel utility doors directly to the public domain, breaching DCP streetscape design mandates.

3. Aging Water Infrastructure and Capacity Restrictions

Marrickville’s aging combined utility networks are under severe load pressure.

Sydney Water has maintained an increasingly tough stance regarding water and wastewater capacity connections for high-density developments in this specific pocket of Marrickville.

The developer has failed to demonstrate that the local network can absorb the exponential capacity spike of 24 high-density units without risking downstream system backups.

Furthermore, any multi-level basement excavation on this restricted site risks encroaching upon or damaging localised utility lines running along property boundaries, which creates permanent access and maintenance barriers for utility workers.

4. Non-Compliant Servicing and Traffic Architecture (AEDRP Alignment)As explicitly warned by Council’s Architectural Excellence & Design Review Panel (AEDRP) during preliminary evaluations (PDA/2025/0247), this tight footprint cannot functionally support a 9-storey scale.

The proposal relies on structural compromises that breach local DCP requirements:

The Car Lift Paradox: Because the restricted site area prevents a compliant, standard basement vehicle ramp, the developer is forced to rely on a mechanical car lift system.

This introduces severe traffic queuing problems, vehicle idling noise, and ongoing severe operational vulnerabilities and risks on a narrow residential street.

Unworkable Waste Management: Storing and wheeling dozens of heavy bins onto a narrow footpath on collection night creates an immediate pedestrian hazard, traffic obstruction, and haphazardly visual eyesore.

5. Failure to Satisfy Inner West LEP Clause 6.9 (Design Excellence)

A building cannot claim "Design Excellence" if its volumetric mass creates an unacceptable, jarring transition with its surrounding neighbourhood context.

Approving this overstep would set a highly dangerous precedent for the Marrickville TOD boundary, signalling that state caps are a starting floor for negotiation rather than a legal ceiling.

Conclusion

The developer is already receiving an unprecedented state density bonus.

The Inner West Planning Panel must exercise its full discretionary power to protect the Marrickville community, refuse the Clause 4.6 variation, and require the applicant to scale back the building to a fully compliant, physically workable 6-to-7 storey envelope.

I request to be kept formally notified of all future panel meeting dates and determinations regarding this application.

Yours sincerely,
[Your Name]

[Your Address]

[Your Contact Number]

A Reasonable Counter-Proposal for 107 Silver Street to Consider

We must face facts: high rise development will happen on this site.

But we the community are not powerless if we rally in a strategic way.

So consider taking this position:

Be Pro-Density, But Anti-Greed

As a community, if we are staunch allies of increased density in Transport Oriented Development (TOD) zones we will get further.

By completely supporting the state's vision for sustainable urban growth and the creation of critical affordable housing near Marrickville Station we can and will ensure we get compromises.

And the crux of the argument has to be this to be effective: density must be built within reason.

The current developer proposal (DA/2026/0724) for a solid 9-storey, 32.82-metre concrete tower block on a tight 676m² corner plot is not reasonable density - it is a predatory cash-grab that abuses state rules to over-spec a residential street.

We can align and unite behind an organised , legally viable Community Counter-Proposal to present to the Inner West Local Planning Panel (IWLPP) and their Assigned Expert Town Planner Assessor.

This is a compromise that delivers density while protecting local sunlight access and precious privacy rights.

The Community Counter-Proposal Framework

Instead of a flat rejection, we can demand that Council force the developer to amend their plans to a compliant, scaled back, high-amenity design.

Our specific, numbers-driven compromise fixes the severe architectural failures of the current application:

Scale Back to 18 Units/ 6 Storeys:

This compromise strips away the developer’s non-compliant 4.22-metre height overrun and aligns the building's concrete massing with the actual state-mandated baseline height limit of 24 metres.

The "Sunlight Carrot" (4m Open-Sided Roof Awning):

We can band together to ask the council to “reward” the allocation of 3 of the 18 flats as affordable housing, suggesting the support of a 4-metre open-sided pergola-style roof awning “bonus” bringing the top structure to 28 metres.

Because a pergola style roof awning is completely open-sided, this would satisfy the developer's height parameters while allowing morning and afternoon sunlight to pass through, dramatically mitigating the catastrophic overshadowing on Silver, Gladstone, and Calvert Streets.

Protecting Privacy (High Rooftop Garden Walls):

To prevent 24-metre-high visual intrusion into adjacent backyards, the communal rooftop garden must feature high, non-transparent acoustic and visual privacy screens.

Fixing the 52-Bin Waste Crisis:

We can demand, together, that the 52 waste bins 18 flats will need all be entirely recessed inside the building footprint along Silver Lane.

This forces the developer to handle their own high-density infrastructure on-site, preventing an illegal, dangerous bin blockade on our narrow footpaths.

How the Amalgamation Rules Protect Us

The developer at 107 Silver Street can only attempt this because their former-church lot features a rare 21.3m width that barely scrapes past the state's mandatory 21-metre minimum lot width rule.

Down the road on Calvert Street, standalone properties like 66 and 68 Calvert cannot replicate this tower block play without two neighbouring houses becoming part of the land parcel up for development (to get that 21 m facade, you see?)

Because Central Avenue physically divides 66 and 68, they cannot be amalgamated across the road either (ever).

Under the TOD SEPP, those individual blocks (66 & 68) remain legally trapped at a 9.5m local height cap unless developers manage to buy out multiple consecutive homes on the exact same side of the street.

What to Do Now

When submitting your formal objections to the Inner West Council, do not just say "no" to the development.

Copy and paste this 18-Unit / 24m Structural Cap Compromise into your submission.

By offering a legally viable, pro-density alternative that fixes active code breaches, we the community, can give the Council’s Planning Panel the exact legal ammunition they need to compel the developer to scale this project back to a more reasonably conceived super-structure.

Right now, to force a Council Public Planning Panel Hearing to determine the first phase of this DA’s fate, more than ten unique objections/oppositions must be lodged before the community consultation ends in just a few short days.

So for now, just get as many households in the area making submissions based on factual impacts to get that decision made in public and not behind closed doors.

“ impacted by overshadowing/loss of sunlight”

“Impacted by overlooking/loss of privacy”

“Impacted by an increase in waste bin pick ups on Silver Lane that will go from the handful of bins the church had, to over 50 a week being collected every week”

It’s all about the impact, ultimately.

Here’s a letter template everyone should feel free to copy, paste, and personalise:

Subject: Formal Objection: DA/2026/0724 – 107 Silver Street, Marrickville NSW 2204

To: [email protected]

Attention: Assessing Planning Officer of DA/2026/0724 (107 Silver Street, Marrickville)

Dear Sir/Madam,

I formally object to DA/2026/0724 at 107 Silver Street on the grounds of severe over-development.

While I support reasonable density within Transport Oriented Development (TOD) zones, this specific 9-storey proposal represents an unacceptable breach of local and state planning controls.

I request that the Inner West Local Planning Panel refuse the Clause 4.6 variation and compel the developer to scale the project back to the following compliant community compromise:

* Scale and Massing: Limit the development to 18 units over 6 storeys, capping the main concrete structure at the state baseline of 24 metres to mitigate catastrophic morning and afternoon overshadowing on Silver, Gladstone, and Calvert Streets.

* The 28m Solar Compromise: In exchange for providing 3 affordable housing flats, allow a maximum 4-metre open-sided roof awning (bringing the structural top to 28 metres), allowing sunlight to pass through to adjacent properties.

* Privacy and Infrastructure: Mandate high, non-transparent privacy walls on the 24m rooftop garden to prevent overlooking, and require all 52 waste bins to be fully recessed within the building footprint on Silver Lane to avoid non-compliant footpath obstruction.

The current 4.22-metre non-compliant height overrun fails the "Design Excellence" requirements of Inner West LEP Clause 6.9 and must be rejected in its current form.

Please keep me notified of all panel meeting dates regarding this application.

Yours sincerely,

[Your Name]
[Your Address]
[Your Contact Number]

🚨 PLANNING ALERT:

Overdevelopment on Calvert Street Threatens Endangered Flying-Fox Corridor!

Inner West Council is reviewing a bunch of development proposals on Calvert Street, Marrickville that directly threaten the Grey-headed Flying-fox, a federally protected species but none quite as massive as 107 Silver - the old church!.

Local tree removal and intensive building footprints will disrupt a critical biodiversity corridor - fact.📍

The Issue: Wolli Creek to Marrickville Flight Path

Every evening at dusk, thousands of flying-foxes stream out from their nationally significant roosting camp at Wolli Creek/Turrella Reserve to feed.

The protected species primary nightly foraging flight path cuts directly over Marrickville and Calvert Street and Silver Street specifically.

The mature eucalyptus, fig, angophora, and Australian Native trees in our private and public open spaces act as vital "stepping stones" for the protected species’ food and rest.

Removing these trees for concrete driveways, carports, and high-density nine-story tower block footprints destroys the
Rare flying fox colony’s urban feeding canopy.🛑

How These Plans Breach Environmental Rules & Protocols

Overdevelopment explicitly undermines strict environmental protections across all three levels of government:

Federal Law (EPBC Act 1999):

The Grey-headed Flying-fox is listed as Vulnerable.

Bypassing the cumulative impact of urban canopy destruction violates the National Recovery Plan for the Grey-headed Flying-fox.

NSW State Law:

(Biodiversity Conservation Act 2016): It is an offence to deliberately degrade the habitat of a threatened native animal without a Biodiversity Conservation Licence.

Inner West Council Rules (Marrickville DCP 2011):

Section 2.13 (Biodiversity) specifically protects the Grey-headed Flying-fox.

Overdevelopment that deletes deep-soil zones and introduces high-voltage poles or night-lighting violates the council's own biodiversity corridor targets.🗣️

Take Action:

Object to Protect Our Canopy

We need the community to flood Council with objections before the submission windows close.

You can easily object right now!

Just email the Council with one paragraph, simple.