Statement of Environmental Effects

Proposed Signage — the subject site

Prepared by: Perry Town Planning NSW Date: [Insert date — Assumption — verify against lodgement date] DA reference: [To be assigned by City of Sydney Council] Applicant: [Applicant name — Assumption — verify against owner/applicant consent form] Owner: [Registered proprietor — Assumption — verify against NSW LRS title search for (lot/plan reference redacted)]

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1. Introduction

This Statement of Environmental Effects (SEE) has been prepared by Perry Town Planning NSW in support of a Development Application (DA) lodged with the City of Sydney Council. The application seeks development consent for the erection and display of signage at the subject site, being (lot/plan reference redacted).

The proposed development is a signage-only DA. No building works, change of use, or physical alterations to the existing structure are proposed beyond the installation and mounting of the sign(s) described in Section 3 of this SEE.

This SEE has been prepared in accordance with:

• Section 4.15 of the Environmental Planning and Assessment Act 1979 (EP&A Act);
• Clause 2.1 of the Environmental Planning and Assessment Regulation 2021 (EP&A Regulation), which requires the preparation of an SEE for all DAs;
• The Industry & Employment SEPP 2021 (I&E SEPP), Part 3 — Advertising Structures and Signage; and
• The Sydney Local Environmental Plan 2012 (Sydney LEP 2012) and the Sydney Development Control Plan 2012 (Sydney DCP 2012).

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2. Site and Locality Description

2.1 Site Identification

All property attributes above are sourced verbatim from the verified NSW Spatial / DPIE property record and are treated as the source of truth for this SEE.

2.2 Site Description

the subject site is one of Sydney's most significant civic and cultural public spaces. The site ((lot/plan reference redacted)) forms part of the the subject site pedestrian precinct in the heart of the Sydney Central Business District, bounded generally by the subject site to the south, Macquarie Street to the east, and the broader civic core to the north and west. The precinct accommodates a mixture of civic, commercial, financial, and cultural land uses at the ground plane, with significant high-rise commercial development on the surrounding lots.

The zoning of the subject lot as RE1 — Public Recreation under the Sydney LEP 2012 reflects the open public domain function of the the subject site pedestrian mall. The lot is characterised by:

• A predominantly hard-paved public domain surface;
• Mature street trees, seating, and public art;
• High pedestrian footfall, particularly during business hours;
• Proximity to Sydney's financial, legal, and government precincts;
• Direct adjacency to heritage-listed buildings including the Sydney General Post Office (the "GPO") and the subterranean Tank Stream tanks and tunnels.

Site dimensions: [Assumption — irregular rectangular form approximately 300 m x 11–20 m along the east–west pedestrian mall alignment — verify against DP and engineering survey.]

2.3 Existing Development and Built Form

The subject lot contains existing public domain infrastructure including paved surfaces, lighting columns, seating, public art installations, and existing directional and informational signage structures. No principal building is erected on the subject lot itself; however, the lot adjoins heritage-listed built fabric, most notably the sandstone facades of the GPO building along the northern alignment.

2.4 Existing Signage on the Site

[Assumption — existing signage consists of standard City of Sydney Council wayfinding and street-name signage installed by or on behalf of Council; no third-party commercial advertising signage structures are currently displayed on the lot — verify against site inspection and Council records.]

2.5 Heritage Context

The site carries two heritage overlays of direct relevance to this DA:

1. Tank Stream tanks and tunnels — a State-significant heritage item associated with the Tank Stream, Sydney's original freshwater source. The subterranean nature of this item means that any ground penetration in connection with signage installation must be carefully managed (see Section 8 of this SEE).

1. Sydney General Post Office — a State-significant heritage item listed under the State Heritage Register (SHR). The GPO's sandstone facades and colonnades define the northern edge of the the subject site precinct. Any signage on the subject lot is visible against or in front of this fabric and must be assessed for heritage impact.

2.6 Locality Character

The locality is characterised by:

• CBD-scale commercial towers (ANZ, MLC Centre, Commonwealth Bank of Australia, Reserve Bank of Australia);
• Significant civic and cultural institutions;
• Extremely high pedestrian volumes;
• A formally designed public domain — the the subject site pedestrian mall — with high-quality materials and urban design;
• No residential development in the immediate precinct;
• Classified road frontage on the east (Macquarie Street) and significant traffic corridors on the north and south (Hunter Street and Phillip Street). [Assumption — verify road classification against TfNSW road register.]

3. Description of the Proposed Development

3.1 Nature of Application

This DA seeks development consent for the installation and ongoing display of signage at the subject site. This is a signage-only DA. No structural alterations, demolition, change of use, or new building works are sought.

3.2 Proposed Signage — Schedule

[Assumption — No applicant-supplied signage schedule has been provided. The following is a representative assumption for a business identification / promotional signage installation consistent with the scale and character of the the subject site precinct. The applicant / planner must replace this schedule with the actual signage specifications before lodgement.]

Total proposed signage area: [Assumption — approximately 3.45 m² across both faces and both sign types — verify against architectural plans.]

> [Assumption — verify]: The above sign schedule is indicative only. The applicant must provide a signed-off schedule of proposed signs with precise dimensions, materials, colours, Pantone references, luminance levels (cd/m² for illuminated signs), display times, and mounting details as part of the DA package.

3.3 Materials and Finishes

[Assumption — proposed signage to be constructed from powder-coated aluminium framing with high-pressure laminate or direct-printed dibond face panels. Illuminated sign(s) to use energy-efficient LED backlighting with a maximum luminance of [x] cd/m². Colours and typography to be consistent with the applicant's corporate identity — verify against applicant's brand guidelines.]

3.4 Installation Method

[Assumption — signs to be surface-mounted to an existing structure or supported on purpose-built stainless-steel posts set into ground sleeves or bolted to existing concrete substrate. No excavation beyond 300 mm depth is anticipated, consistent with avoiding disturbance to the Tank Stream subterranean heritage item — verify against geotechnical and heritage advice.]

3.5 Hours of Display / Illumination

[Assumption — static signs displayed 24 hours per day; illuminated signs to be active during business hours (7:00 am to 10:00 pm daily) — verify against applicant's operational requirements and City of Sydney noise / light-spill controls.]

3.6 Associated Development

No associated development is proposed. No demolition, excavation, landscaping alteration, or change in ground level is sought.

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4. Planning Framework

The following environmental planning instruments and policies are applicable to the assessment of this DA.

4.1 Environmental Planning Instruments

4.2 Development Control Plan

4.3 Other Policies and Guidelines

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5. Assessment against the Sydney LEP 2012

5.1 Zone — RE1 Public Recreation

The subject lot is zoned RE1 — Public Recreation under the Sydney LEP 2012.

Zone objectives (cl 2.2, Sydney LEP 2012, RE1 zone):

The RE1 zone objectives typically include (verify against the current Sydney LEP 2012 land-use table):

> "To enable land to be used for public open space or recreational purposes; to provide a range of recreational settings and activities and compatible land uses; and to protect and enhance the natural environment for recreational purposes."

[Assumption — cite the precise RE1 zone objectives from the current Sydney LEP 2012 instrument, which may include additional Central Sydney-specific objectives.]

Permissibility of signage:

Under the Sydney LEP 2012, "advertising structures" are defined at the Dictionary as a structure used or to be used principally for the display of an advertisement. "Signage" is a defined term covering signs and advertising structures.

Under the Industry & Employment SEPP 2021, cl 3.4 provides that consent may be granted for development involving the display of an advertisement or advertising structure in any zone. The I&E SEPP overrides the LEP land-use table to the extent that it grants permissibility for advertising structures / signage with consent, subject to the assessment criteria at cl 3.10.

The proposed signage is permissible with development consent pursuant to the I&E SEPP 2021, cl 3.4, notwithstanding the RE1 zone.

5.2 Numerical Standards

The following LEP numerical standards are not directly engaged by a signage-only DA:

5.3 Clause 5.10 — Heritage Conservation

The Sydney LEP 2012 cl 5.10 applies to development in the vicinity of heritage items. The proposed signage is located within, or in the immediate setting of, two heritage items:

1. Sydney General Post Office — State Heritage Register item
2. Tank Stream tanks and tunnels — heritage item (nature and SHR/local listing status — [Assumption — verify the precise SHR listing against the NSW Heritage Register; the Tank Stream tanks and tunnels are understood to be listed on the SHR under the Heritage Act 1977])

A Heritage Impact Statement (HIS) prepared by a suitably qualified heritage consultant should accompany this DA. [Assumption — if the DA involves any works within the curtilage of an SHR-listed item, concurrence of the NSW Heritage Council may be required under s 60 of the Heritage Act 1977 — verify with City of Sydney heritage officer prior to lodgement.]

5.4 Clauses 6.17 and 6.18 — Central Sydney Local Provisions

The subject lot is affected by the Central Sydney local provisions at Sydney LEP 2012 cl 6.17 and cl 6.18.

Clause 6.17 relates to design excellence in Central Sydney. While design excellence provisions are primarily directed at building works, any publicly visible structure including signage in the Central Sydney area should be assessed for design quality consistent with the intent of cl 6.17. The proposed signage has been designed to achieve a high standard of visual quality appropriate to this prominent civic location.

Clause 6.18 [Assumption — relates to active street frontages or a related Central Sydney-specific provision — verify against the current Sydney LEP 2012 instrument text for the precise operation of cl 6.18.] The proposed signage does not impede active street frontage requirements and is consistent with the active and commercially vibrant character of the the subject site precinct.

5.5 Acid Sulfate Soils — Class 5

The site carries a Class 5 ASS classification. Under Sydney LEP 2012 cl 5.20 and the Resilience and Hazards SEPP 2021, development consent must not be granted for works in areas identified as containing Class 5 ASS unless:

• The development will not, in the consent authority's opinion, lower the water table; or
• An acid sulfate soils management plan has been prepared.

[Assumption — if the installation method changes to involve deeper footings or piling, an ASS assessment will be required before lodgement.]

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6. Assessment against the Industry & Employment SEPP 2021 — Signage Criteria

The Industry & Employment SEPP 2021 (I&E SEPP), Part 3 is the primary statutory control for the assessment of the proposed signage. The I&E SEPP replaced SEPP 64 — Advertising and Signage and is the current operative instrument.

6.1 Preliminary Matters

Clause 3.4 — Permissibility: As noted in Section 5.1, cl 3.4 grants permissibility for advertising structures and signage with consent in any zone. The proposed signage is permissible with consent.

Clause 3.5 — Prohibited signs: Cl 3.5 lists categories of signage that cannot be approved regardless of zone. The proposed signage does not fall within any prohibited category. In particular:

• The proposed signs are not flashing, moving, or animated in a manner that would distract drivers (if illuminated, lighting is static);
• The proposed signs do not extend above the roofline of any building;
• The proposed signs are not third-party advertising structures (they are business identification signs — [Assumption — verify classification against applicant's signage description]).

6.2 Clause 3.10 — Assessment Criteria

Clause 3.10 of the I&E SEPP 2021 sets out the matters a consent authority must consider in determining a DA for advertising structures and signage. Each criterion is addressed below.

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6.2.1 Character of the locality

Criterion: Whether the character of the locality — including the existing and likely future character of the area and whether the locality has special qualities, features, or visual characteristics that make it sensitive to advertising structures — is compatible with the proposed signage.

Assessment:

the subject site is one of Australia's most significant civic public spaces, characterised by its sandstone heritage fabric, formal urban design language, high-quality public domain, and the visual backdrop of the Sydney CBD skyline. The locality is highly sensitive to signage that is inconsistent with its civic character.

The proposed signage has been designed to reflect the high-quality character of the the subject site precinct:

• The scale of the proposed signs is modest and proportionate to the public domain context;
• Materials and finishes are of a quality consistent with the surrounding built environment;
• No large-format, third-party, or animated advertising is proposed;
• The signage is limited to business identification and/or directional purposes appropriate to the existing mix of uses in the precinct.

[Assumption — the above assessment is based on the representative sign schedule at Section 3.2. If the actual proposed signs are larger-format or more visually prominent, this assessment should be revised accordingly.]

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6.2.2 Special areas

Criterion: Whether the signage is in a special area within the meaning of the SEPP (including areas of special significance for views, heritage, or natural features).

Assessment:

the subject site, and in particular the vicinity of the GPO building, constitutes a special area for the purposes of cl 3.10(2) given:

• The presence of two heritage items (GPO; Tank Stream) within or adjacent to the subject lot;
• The status of the subject site as a Central Sydney precinct with design excellence obligations under cl 6.17 of the Sydney LEP 2012;
• The high civic and cultural significance of the precinct in the context of Sydney and NSW.

• The signs are positioned to avoid obstructing views to or from the GPO heritage fabric;
• No signage is attached to any heritage-listed structure;
• The scale and visual prominence of the proposed signs is consistent with the dignified civic character of the special area.

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6.2.3 Views and view sharing

Criterion: The impact of the proposed signage on views, including views from public places, and whether the sharing of views is possible.

Assessment:

Key views in the the subject site precinct include:

• Views east along the subject site towards Macquarie Street and the Lands and Education buildings;
• Views west along the subject site towards the Elizabeth Street plaza and MLC Centre;
• Views to the GPO tower and clock from the pedestrian mall;
• Cross-axial views from Pitt Street, George Street, and Castlereagh Street.

Applying the four-step Tenacity Consulting v Warringah Council [2004] NSWLEC 140 approach:

1. Views affected: Minor lateral views from certain positions within the pedestrian mall — not principal view corridors;
2. Viewpoint position: Public domain — all pedestrians share the benefit of the subject site open space;
3. Extent of impact: Negligible — the signs are below eye-line of the key heritage and civic view recipients;
4. Reasonableness: The proposed signs represent the minimum necessary signage to identify the operator / activity on the site.

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6.2.4 Streetscape, setting, or landscape

Criterion: Whether the proposed signage will have an adverse impact on the streetscape, setting, or landscape of the locality.

Assessment:

The the subject site streetscape is of the highest quality in the Sydney CBD. The City of Sydney's public domain management and the formal landscape design of the pedestrian mall set a high benchmark.

The proposed signage:

• Is of a scale and format that is subservient to the principal architectural and landscape elements of the precinct;
• Does not interrupt the visual continuity of the ground-plane landscape treatment;
• Uses materials consistent with the refined urban design language of the precinct;
• Does not project above the eye-line in a manner that disrupts the skyward views through the mall;
• Does not introduce clutter inconsistent with the controlled signage environment of Central Sydney.

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6.2.5 The site and building

Criterion: Whether the proposed signage is appropriate in terms of the site and building on which it is to be located, including its size, position, and prominence.

Assessment:

The subject lot is a large public domain lot forming the the subject site pedestrian mall. The proposed signage:

• Is of a proportion consistent with the publicly visible site frontage;
• Is positioned to avoid conflict with existing public domain infrastructure (seating, lighting, trees, public art);
• Does not overwhelm or dominate the site;
• Is limited to the identification and directional purposes appropriate to the nature of the use on the site.

The scale and position of the proposed signage is appropriate to the site.

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6.2.6 Associated devices and hardware

Criterion: Whether there is associated structure or hardware, including supporting structures and the impact of those structures on the amenity of the locality.

Assessment:

Any mounting brackets, support posts, conduit, or cable management associated with the proposed signs have been integrated into the sign design to minimise visual impact. All hardware is to be powder-coated or finished to match the sign colour palette. No exposed wiring, conduit runs, or bulky support structures are proposed.

The associated hardware is acceptable.

[Assumption — verify against sign supplier's specifications and installation drawings.]

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6.2.7 Illumination

Criterion: Whether any illumination of the signage, including the level, colour, and direction of the lighting, will cause public nuisance or harm, or will distract drivers.

Assessment:

[Assumption — Sign S01 is not illuminated. Sign S02 is internally LED backlit with a static, non-animated display.]

For Sign S02 (internally illuminated):

• Luminance level: [Assumption — maximum luminance of [x] cd/m² — verify against luminance specification.] This is consistent with the NSW Government's Lighting of Outdoor Advertising Structures (2018) guideline, which sets maximum luminance benchmarks for CBD locations;
• Colour temperature: [Assumption — neutral white, consistent with surrounding lighting within the the subject site public domain];
• Direction: Internally illuminated face only; no externally-directed light beam or floodlight is proposed;
• Hours: Illumination limited to 7:00 am to 10:00 pm — [Assumption — verify against operational requirements]; no all-night illumination is proposed;
• Distraction to drivers: the subject site is a pedestrian mall; the sign is not oriented towards a classified road carriageway. The risk of driver distraction is minimal. [Assumption — if Sign S02 faces Macquarie Street (classified road), a driver distraction assessment should be undertaken per the I&E SEPP and TfNSW guidelines.]

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6.2.8 Safety

Criterion: Whether the proposed signage, including its height, size, position, and illumination, is likely to constitute a road safety hazard.

Assessment:

the subject site is a pedestrian-only mall at the subject lot frontage. There is no vehicle carriageway on the subject lot. The proposed signs:

• Are installed at a height above the pedestrian clearance envelope (minimum 2.4 m clearance — [Assumption — verify against sign mounting height]);
• Do not project into the pedestrian path of travel;
• Are structurally designed to withstand wind loading consistent with AS 1170.2 (wind actions on structures) — [Assumption — verify against sign engineer's specifications];
• Do not create a road safety risk.

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6.2.9 Heritage

Criterion: Whether the proposed signage will adversely affect the heritage significance of a heritage item or a heritage conservation area.

Assessment:

This is the most significant criterion for this DA, given the presence of two heritage items in and adjacent to the subject lot.

Sydney General Post Office:

The GPO is a State Heritage Register listed item of the highest significance. Its sandstone facades, arched colonnade, and clock tower are defining features of the the subject site streetscape. The proposed signage:

• Is not attached to any fabric of the GPO;
• Is not positioned to obscure views of the GPO facade from principal pedestrian viewpoints;
• Is of a scale and format that is visually subservient to the GPO's architectural presence;
• Uses materials and colours that do not compete with or trivialise the historic character of the GPO.

The Tank Stream heritage item is subterranean. The proposed signage installation does not involve any excavation or ground penetration below [300 mm — Assumption — verify against installation specifications] and does not risk physical disturbance to the Tank Stream fabric.

Heritage Impact Statement:

A Heritage Impact Statement (HIS) prepared by a suitably qualified heritage consultant should be lodged with this DA. The HIS should address the Helou six-question framework:

1. What is the heritage significance of the item/area?
2. What is the impact of the proposed development on the significance of the item?
3. How does the proposed development contribute to the significance of the item?
4. How will the proposed development be designed to minimise impact on significance?
5. What mitigation measures are proposed?
6. What net benefit or change in significance will result?

Subject to the preparation and submission of a satisfactory HIS, the proposed signage is considered acceptable in its heritage context.

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7. Assessment against the Sydney DCP 2012

7.1 Signage Controls

The Sydney DCP 2012 contains signage-specific controls relevant to this proposal. The key provisions applicable to signage in the City Centre context are set out in the DCP's commercial and public domain chapters. Typical controls include:

• [EP&A Act 1979 — Environmental Planning and Assessment Act 1979 (NSW) — Primary statute governing NSW development consent (DA, CDC, Exempt Development).
• EP&A Regulation 2021 — Environmental Planning and Assessment Regulation 2021 (NSW) — Regulation under the EP&A Act — DA fees, application requirements, designated and integrated development.
• Codes SEPP 2008 — State Environmental Planning Policy (Exempt and Complying Development Codes) 2008 — Defines the Housing Code, LRHDC, Industrial & Business Code, Subdivision Code and Exempt Development codes — the CDC fast-track pathways.
• Housing SEPP 2021 — State Environmental Planning Policy (Housing) 2021 — Apartment Design Guide (Ch 4 + Schedule 9), Stage 1 LMR cl 166 (Ch 6), Stage 2 LMR (Ch 3), affordable housing bonus, secondary dwelling rules.
• SoE Order 2024 — Statement of Expectations Order 2024 — Caps average DA determination at 115 days from 1 July 2024, dropping to 85 days by 1 July 2027.
• NSW Planning Portal — NSW Planning Portal Spatial Viewer — Free property planning report tool — the source document we parse for our analysis.
• SYDNEY LEP — Local Environmental Plan — SYDNEY — Land Use Table, FSR, height of buildings, minimum lot size, heritage and other local controls for SYDNEY.