Mixed Use Development - 19A-21 Gordon Street, Coffs Harbour

As an architect and resident of Coffs Harbour I am appalled at this proposal. The exhibition period is too short to properly comment on everything that is wrong with this proposal. A lot of work by council and various professionals went into the preparation of our City Centre Masterplan. It is a good plan for our city which guarantees sensible design, heights and setback controls to create a vibrant and livable regional city centre. The recent CODA development is a good example of the masterplan working. One component of the design was stepping the building so that sunlight can still reach the footpath across the road on the southern side of Harbour Drive. This proposal for Gordon St has not only ignored the masterplan but completely disrespected the work that went into it, and our residents. It is a whole city block further north from Harbour Drive but it shows shadows extending further than CODA right across Harbour Drive. As an architectural proposal it is an embarrassment to our profession so I can only conclude it has been driven by the developer. Seeking such an enormous breach of the masterplan is a well used strategy to aim for double and settle for something less but still way outside the guidelines. This should be seen for what it is and the proposal rejected completely, not amended. The design shows no finesse and cannot be fixed by just making it shorter. I am also not impressed with the use of hired guns to provide cash for comment letters of support such as the one from Matthew Pullinger in Appendix W. Matthew's letter is a compilation of mission statements that offer nothing of value and could just as easily state the opposite with the same conviction. Everywhere Matthew writes the words 'positive, strong or merit', could be replaced with 'negative, weak or flaw'. Not once is the City Centre Masterplan referenced. I am gobsmacked a supposed respected architect could write such a letter if it wasn't for cash.

It will destroy the amenity of our new council chambers and library and any other building nearby. There has been no attempt at articulation, no effort to address overshadowing which has all the height and bulk of the building to the south of the site. It is one big monolith just plonked in the city centre and completely out of context with the city and its masterplan. In Matthew Pullinger's letter he states that if there is to be a precedent it needs to be a positive one which sets a benchmark. This proposal is a benchmark that should be avoided at all costs.

Objection
Whilst I support the provision of affordable housing and higher density development in the Coffs Harbour CBD, I object to the proposed development because it's height and bulkiness will impact the architectural integrity and amenity of the adjacent Yarrila Place building and because the proposal is not focused on affordable housing. Details of my objection are set out below along with recommendations to address the issues I have raised.

Impacts on Yarrila Place Require Significant Mitigation
The proposed development is located immediately adjacent to the Council's Yarrila Place building, which is an award winning architecturally designed building, designed to respond to and consider the existing height of building controls on its site and adjacent sites.

The proposal intends to override these controls to enable a building that was never envisaged when Yarrila Place was designed and constructed. Even though the design of the proposal includes a stepped setback from Yarrila Place, the setback is not adequate to preserve the architectural integrity and amenity of Yarrila Place.

Although changes to planning laws allow the NSW Government to switch off planning controls to enable such developments, the NSW Government needs to do this sensitively and responsibly, so the character of existing architecture is not significantly impacted. The wishes of the community and local government on the sense of place in regional cities must influence such decisions by the NSW Government and must not be ignored.

In the design principles, the Design Report identifies, 'the proposal lies between two of the city’s most recognisable civic and commercial landmarks, Coffs Central and Yarilla (sic) Place, demanding an architectural response that carefully navigates these identities while contributing to a cohesive and connected urban fabric', but the design does not adequately address these demands. It instead reconciles them by falling largely on the pressure of increased density, rather than the need for human scale public spaces. The current design ignores these demands as it will dwarf and substantially impact the architectural integrity of Yarrila Place. The design has attempted to respond to building separation, but this is not enough for the height and bulk proposed.

More Affordable Housing is Required in the Development
The proposed development includes 152 apartments, of which 40 comprise affordable housing. Hence, only 26% of the new dwellings created by the development will be for affordable housing. This is far from sufficient given the housing crisis facing NSW, particularly regional areas where housing costs have risen to be almost commensurate with those in cities when compared to regional wages and salaries.

Recommendations
In summary, I recommend:

1. The NSW Government only allows minor changes to the height of buildings map for the site to significantly reduce the
proposed development's height.
2. The proposed development be redesigned with a much greater setback to Yarrila Place that provides adequate separation
between the 2 buildings and maintains the architectural integrity and amenity of Yarrila Place, including, but not limited to:
a. reducing the height of the proposed development's lowest step to align with the bottom of the Yarilla Place first floor
windows, and
b. at least doubling the width of the lowest step to increase separation between the 2 buildings, and
c. reducing the height of the tower, so the proposed development does not dwarf Yarrila Place.
3. An independent expert report be prepared to consider the impacts of the proposed development on Yarrila Place and to
identify the necessary setback, height and design of the proposed development to effectively mitigate these impacts, so the
consent authority can make an informed decision.
4. The proposed development be redesigned to incorporate at least 50% affordable housing.

There is insufficient parking provided. With only 1 parking space per unit and an additional 21 spaces, 12 of which are for volunteers, there will be significant pressure on public parking areas. The council run parking areas adjacent do not meet the need in holiday periods. We need readily available parking for the local businesses to encourage usage of the city centre. Most households have at least 2 driving adults per property and this proposal does not account for that need.

I support the project. Creating high rise housing opportunities, both affordable and open market, presents huge opportunities for the continual growth of the region, leading to better social and economic outcomes.

Hello,

I don't oppose the project per se. My objection is to the current height and density of the building.
Things that should be considered:
1) The height of the building – this is more than double any high rise in the seeable vicinity on the project
2) The density – not supported by infrastructure
3) Liveability of the spaces – the units are too small for anyone to live in this long term, which I think is the aim of the project.
To expand on the above points –
1. The height of the building
As the development committee is aware, the highest building in the area is CODA. This was completed in 2025 and stands at just 44 meters. This proposed project is 90 metres tall.
In the area, there are CURRENTLY just 2 ‘high rises’, CODA (12 floors) and Triton towers (7 floors). There is a significant difference when jumping to 26 floors as is proposed.
Coffs Harbour is not a city, it is a town. Lower population and lower density. As per the application in the Engagement Report, the population at the last census of Coffs Harbour was 78,759. This is hardly high density given the current square km of the Coffs Coast.

2. The Density
The proposed density of 157 units is concerning. The concerns are:
a) Parking – living in CODA, I notice that many residents had both a personal and business vehicle. Therefore a 1:1.07 ratio is insufficient when many units will be more than single occupancy. From the two levels residential levels presented in the Architectural drawings, there are 11 2-bedroom units, indicating perhaps a couple with at least 1 child. This would indicate 2 working adults, most likely (given the demographic of Coffs Harbour) that have a vehicle each.
b) Guest parking is insufficient given the number of units and that the Church will be located in the facility and have many perishers there on a weekly basis. Street parking is 8 spots, unless they are to park in the Council parking lot that also supports the shopping mall (revenue generating), Library (community facility), swimming pool (community facility) and the Ex-Services club.

3. Livability of the space –
The proposed living space being proposed is actually no bigger than a hotel room. For example Opal Cove resorts Ocean side rooms are between 31 and 34 sq metres. These contain a bedroom and a bathroom. The 2 bedroom apartments being proposed are 74-86 sq metres. These are to contain 2 bedrooms, 2 bathrooms, a living space, kitchen and laundry.
Let’s consider that people need to live in these spaces, not just occupy them.

As I mentioned, I am not opposed to a development on this site. I am opposed to the height and density of the building. It is not in keeping with the area and it is not creating liveable housing..only housing.

Regards,
Bronwen Hill

We support the Uniting affordable housing development proposal in principle. The CBD of Coffs Harbour is an ideal place for high rise housing. This is a rare opportunity to do something special. Our support comes with some provisos and a considered suggestions. Our volunteer-run organisation ArtsNational Coffs Coast provides ten illustrated arts talks to Coffs Coast audiences each year. We are part of a larger ArtsNational network and therefore attract high quality national and international experts to Coffs Harbour for each of our talks. We are a young chapter of ArtsNational, now offering our fourth year of arts talks, and building a growing membership and audience. We currently attract an average of 150 people to each talk, sometimes reaching 190. We work closely with Coffs Harbour Music Society and are about to offer joint events in 2026 and 2027. The Music Society attracts around 200 to each of its six annual concerts. Both societies hold our events in a private secondary school theatre some distance from the CBD. The reason is that there is no adequate performance/recital space within the Coffs Harbour CBD. The cultural centre, Yarilla Place, does not have an adequate presentation and performance space to offer the Coffs Harbour community. The absence of medium sized performing arts spaces in Coffs Harbour is a major deficiency for a growing regional city of our size. We invite the Uniting Church proposal to consider including a purpose-built performing arts space that could accommodate 250-300 people. Tiered seating, kitchen facilities, excellent acoustics and audio visual equipment, and comfortable breakout areas are recommended. The provision of this facility would add real benefit to the city and help animate the CBD in terms of diverse activity and the nighttime economy. In addition, we encourage an architect-designed building, sustainably built, affording the city beauty and design excellence. This is so important as it will be adjacent to the award-winning Yarilla Place. Imaginative landscape design is also critical and a sensitive and thoughful presentation facing Riding Lane at the rear of the building. The project is a wonderful opportunity for Coffs Harbour to step up to regional design leadership, acknowledging that there is extensive demographic change in the region and people want more than surf and sporting facilities, as evidenced by the growing numbers of local people attending our arts events. We encourage you to be bold and imaginative.

This proposed 27 stories building is twice the height of ANY buildings in Coffs Harbour and will cause massive vehicular congestion in the CBD. The site is next to our New Library and Council Chambers in Yarrila Place which is frequented by numerous school groups, families and the elderly, the increase in traffic will have a huge impact on the safety and welfare of these citizens. The actual land area is modest but the massive height will cast a huge shadow over all the buildings both East and West. A more modest 12 storey building would be more appropriate in this very confined space.

I support the project, I believe it will significantly improve housing affordability and availability in the area

I would however like to see the number of units and storeys significantly increased as well as units set aside for essential workers.

I think this project is fanastic and just what Coffs Harbour needs (ie: more density in the CBD). However Coffs Harbour desperately needs a new light rail line from Sawtell to Woolgoogla going through the Coffs CBD. This project should've contributed funds to a new light rail line, as public transport is non-existent in the Coffs Harbour region. People want good public transport and large projects like this will generate large volumes of people who want to move around. Many projects of this size will be approved later on, so this project should be setting a precedent to support new light rail. Coffs Harbour does not want to make the transport mistakes the Gold Coast & Sydney made. Lets all learn a lesson form their mistakes. If new light rail isn't built or promoted now, (whilst land prices are cheaper) when will it be promoted?

I believe the proposed mixed-use development at 19A–21 Gordon Street will provide significant social, economic, and community benefits for Coffs Harbour. Socially, the project will increase the availability of housing, including affordable housing, helping to meet the needs of a growing and diverse population. The inclusion of community spaces, retail areas, a café, and a place of worship will create opportunities for people to connect, strengthen community relationships, and encourage a more vibrant and welcoming city centre for residents and visitors alike.

Economically, the development has the potential to create jobs during both the construction and operational phases. New businesses and increased residential activity will generate more customers for existing local shops, cafés, and services, supporting long-term economic growth. A larger residential population in the town centre can also encourage further investment, improve the viability of public infrastructure and public transport, and increase local spending, benefiting the wider community.

From a broader planning and community perspective, the development aligns with the goal of creating a more compact, walkable, and sustainable regional city. Higher-density housing in a central location reduces pressure for urban sprawl while making better use of existing infrastructure and services. It also demonstrates confidence in the future of Coffs Harbour, attracting investment and encouraging revitalisation of the city centre. Overall, I believe this development represents a positive opportunity to support the social wellbeing, economic prosperity, and long-term growth of the Coffs Harbour community for future generations.

Creating new housing needs to be a priority and a development such as this provides that. We are running out of space to go out, so we need to go up and the location of this development in the CBD is the best place for it as it is so close to services and retail outlets.

MUCH MORE SIGNIFICANT RESIDENTIAL DEVELOPMENT IN THE COFFS HARBOUR CBD IS ESSENTIAL FOR THE OVERALL SUCCESS OF THAT AREA.

Please see attached submission.
PLease note that I wish my name and contact details to be confidential

I applaud the quality of the architectural documentation but I recommend some changes to the design layout.
I support the size of the building proposal including the height on the basis that there is a huge demand for inner-City Housing, and there is currently a chronic shortage of affordable housing in Coffs Harbour. As a condition of approval of the application, a covenant (or similar) should be imposed to prevent any of the apartments being used for Air BnB (or any other form of short-term accommodation). I recommend that the number of floors allocated to affordable housing should be increased to at least five and preferably six. The Site Plan should be amplified to relocate the current position of the existing pedestrian crossing such that it does not conflict with driveway access into and out of the building. In recognition of the significant increase in housing density illustrated in the application, there should be a condition of consent requiring a voluntary planning agreement to be entered into to ensure a nearby increase in (public) passive recreation.

Project Name: Mixed Use Development, 19A–21 Gordon Street, Coffs HarbourApplication Number: SSD-51610403
I believe Coffs Harbour is a beautiful city, but this height will destroy it for the following reasons:isual Impact and Character: A 90-metre tower completely destroys the low-rise coastal aesthetic of Coffs Harbour and ignores the 44-metre limit set in the local planning rules.Precedent Setting: Approving this massive height creates a dangerous precedent that allows future developers to ruin the skyline with towers that do not fit a regional city.Overshadowing Public Space: The sheer height will create massive shadows, blocking natural sunlight to nearby streets, shops, and public areas, ruining the city's open, sunny feel.Strain on Infrastructure: Dropping 150 apartments into the middle of Gordon Street will cause severe traffic congestion and parking issues that the current local roads cannot handle. this height also impact all the surrounding residential views from the mountains to the sea. it impacts the whole aesthetic of a greener city that coffs harbour is wanting to aspire to .

SUBMISSION
PROPOSED RESIDENTIAL, COMMERCIAL AND CHURCH DEVELOPMENT 19A-21 GORDON STREET, COFFS HARBOUR
While I support the Uniting Church development to a certain extent, I object to the development for the following reasons:
• Height
The height of 90m is excessive for Coffs Harbour. Council has a current height limit of 44m. I am only aware of one building of 44m height in the City Centre, that being CODA.
To exceed the Council’s height limit by more than double is too much. It is time the State Government respected Council rules and not come barging in and deciding what is good for our city, as they have done with the proposed Jetty Foreshore Planning Proposal. The only good thing I will say is that the City Centre is the place for these residential developments, not our foreshores.
• Parking
The Traffic and Parking Assessment states that City of Coffs Council’s DCP specifies there will be an overall parking requirement of 235 spaces. All these spaces should be provided as part of the development, and not require the use of on-street parking spaces and the adjacent multi-storey car park.
There is already a huge amount of pressure on car parking in that area, given the number of businesses, medical centres, Yarrila Place etc. Adding more pressure from the Uniting church development should not be permitted. It will drive a further decline in the City Centre as people find it easier to shop at the Plaza, where there is no shortage of parking.
• Retail Premises
While I understand the need for the actual Uniting Church areas, I do not see the need for any other retail premises. There are a large number of retail spaces in the City Centre already that are unoccupied. Since the introduction of CODA, the situation has not changed. There has been no further demand for retail spaces and the City Centre is slowly dying. Additional retail premises are not necessary.

The development 19A-21 Gordon St, on the corner of Grafton and Vernon Streets in the CBD of Coffs Harbour, would be very beneficial to the city CBD area. Units, for short-term or longer-term accommodation, for locals or visiting business people, or for tourist apartment rental or sale, are very minimal in the heart of the city. Only one new high-rise for accommodation, and retail, exists at present, to cater for the above.
This development also fits with Coffs Harbour City Council planning for the future of this growing city. Being located mid-way between Newcastle and the Gold Coast, it is also of State value. The Affordable Accommodation component likewise, is urgently needed, particularly for younger income earners and professional career people.
The developer, the NSW/ACT Uniting Church, as the local community is aware, provides a range of welfare and charitable services, and has had the strong support of local businesses in the CBD for many years.
A timely addition to Coffs Harbour city centre, and in-line with high-rise development currently taking place just down Harbour Drive at the beach and harbour. We support the project.

We currently have a crisis in the city centre with drug addicted and mental health issues, we do not want to encourage more afforadable housing as they come with these types of people. By allowing this development you will be turning Coffs Harbours city centre into a getto and devalue suppounding property prices and their ability to conduct buisness. We already have affordable housing in the city centre area; 40 affordable housing apartments at 3-9 Duke Street, I do not know how many in Moonee street and confirmed approval for 12 affordable housing apartments at 94 Albany Street and the approval of 60 affordable apartments at 211A-215 Harbour Drive will be more than enough for one small city centre area. The proposed 40 affordable apartments will encourage more socially unacceptable behaviour to congregate around the city centre, especially with the church offering a soup kitchen. The height of the building of 25 to 30 storeys is utterly ridiculous and not in keeping with Coffs Harbour's surrounding property heights. There are many country areas that would welcome new residents to help keep their community alive, including the schools and shops and community services. If peple do not have jobs in Coffs Harbour they should move to one of the many many country towns and secure affordable housing there and even get a job there.

We support the project, but we have problems with the applicant's proposal to change the height of buildings from 44m to 90m. We appreciate the need for the height limit to be increased, however by doubling the height limit it will set the building totally out of sync with the rest of the city. We believe a more realistic height of 60m would be more in tune for a regional city such as Coffs Harbour.