The Hawks Nest Tea Gardens Progress Association has significant concerns regarding the proposed Sanderling Avenue Residential Flat Buildings development (SSD-82066472) in its current form, particularly in relation to its scale, height and intensity, and its consistency with the established coastal village character of Hawks Nest.

The submission acknowledges the need for appropriate housing growth and housing diversity within regional communities. However, it raises concerns that the proposal, as currently designed, represents a level of development intensity that may be inconsistent with the environmental, visual and social character of this sensitive coastal locality.

Key concerns raised include:

* Building height, bulk and visual prominence that may be inconsistent with the low-scale “below the canopy” planning vision for Hawks Nest.
* Consistency with the Hawks Nest Character Statement and MidCoast Council’s previously expressed concerns regarding visual intrusion, scale and overdevelopment.
* Potential visual impacts on the Bennetts Beach coastal landscape, Sanderling Avenue streetscape and surrounding bushland setting.
* Loss of mature vegetation, fragmentation of native wildlife habitat and cumulative biodiversity impacts within a sensitive coastal environment.
* Concerns regarding ecological connectivity and the adequacy of proposed biodiversity offset measures.
* Questions regarding the adequacy of Aboriginal cultural heritage assessment and consultation on Worimi Country.
* Bushfire evacuation, emergency access and long-term resilience considerations associated with increasing residential density in a constrained coastal interface area.
* Broader coastal resilience concerns, including cumulative urbanisation pressure and increasing infrastructure demand.
* Traffic, parking and infrastructure pressures, particularly during peak holiday periods, including concerns relating to the Singing Bridge, roads, drainage, sewer and water capacity.
* Questions regarding whether the development would meaningfully contribute to local housing affordability or key worker housing needs, given the likely premium coastal apartment market.
* Broader social impacts, including potential changes to local identity, increased urbanisation, pressure on community services and impacts on visitor experience.
* Significant cumulative and precedent concerns, including the possibility that approval could encourage further large-scale urban intensification within Hawks Nest.

The submission also raises concerns regarding the use of the State Significant Development (SSD) pathway, which many residents perceive as reducing the influence of local planning controls and community expectations in decisions that may permanently shape the future character of Hawks Nest.

The Progress Association respectfully requests that the Department carefully consider these issues and either:

1. Require substantial redesign of the proposal to better reflect the established character and environmental sensitivity of Hawks Nest; or alternatively,

2. Impose significant modifications and additional assessment requirements, including:

* reduced building height and density;
* increased setbacks and landscaping;
* greater retention of mature vegetation;
* improved visual integration with the coastal environment;
* further independent assessment of traffic, biodiversity, bushfire, coastal resilience, infrastructure and cultural heritage impacts;
* additional community consultation;
* and stronger consideration of cumulative and precedent impacts.

The submission ultimately argues that any future development on the site should remain genuinely consistent with the low-scale bushland coastal identity of Hawks Nest and ensure that environmental, infrastructure and community considerations are appropriately balanced alongside housing objectives.

I am concerned about the height of the development which will impact on the visual landscape of Bennetts Beach, Hawks Nest and provide too much artificial light to the islands off Bennetts Beach and therefore will impact on the wildlife such as the mutton birds and petrels.
I am also concerned that the development does not provide any affordable housing or employment for the younger residents of Tea Gardens and Hawks Nest which is imperative for our community to be sustainable.

Although I am objecting to this development, I am not necessarily opposed to a smaller scale development on this site.

This project seems to be aimed at satisfying a 'want' rather than a 'need' and the designation of the project as a State Significant Development does not reflect the context of the location and/or a pressing need. i.e. someone wants to make a motza from a block of land without reference to its surroundings rather than the community actually needing the development.

The charm of the Hawks Nest/Tea Gardens area is the 'village' atmosphere. There are limits on changes beyond which the character is no longer maintained. Developments should proceed within agreed 'limits of acceptable change'and as far as I can see, there is no consideration of this concept. I believe this development is not within limits of acceptable change and will be the 'thin edge of the wedge' for even less appropriate developments. Development of the block in a manner that sympathetic to the block's broader location could actually be beneficial and acceptable

Of particular concern is the vertical scale of the development which is not in keeping with the current housing options and village atmosphere of the rest of the Hawks Nest/Tea Gardens. The documentation glosses over the actual visual impact by showing best case visualisations - for example, possible roof reflections for the view from Yacaaba Headland are not considered.

The amount of accommodation proposed will impact on the current village infrastructure. For example, access to Hawks Nest is already compromised by a single bridge that is in need of major repairs. It is not suitable for cycling, mobility scooters or even pedestrians in its current state and this development will exacerbate this issue.

There is definitely a potential impact on the flora and fauna of this area, especially given its location between a large area of relatively natural bushland and the Myall Lakes National Park. The development will impact the existing corridor between the aforementioned areas.

I am also concerned that there are errors in the documentation that I have been able to detect - for example one of the views purports to be looking east when it is actually looking west. Only a minor error admittedly, but what other more consequential errors or incorrect statement are there that I do not know are wrong.

In summary this development does not meet the pub test when it comes to purported State significance, actual community needs, impact on the current character of the Hawks Nest/Tea Gardens locale, impact on the existing infrastructure, impact on the natural environment and its inappropriate scale. It feels as though this development is being foisted on the community for reasons other than being essential or significant

This submission is in relation to the proposed residential apartments proposed for the beachfront on Sanderling Ave, Hawks Nest.
I object to this proposal for the following reasons:
• Its scale, with 104 units, is out of proportion to the built environment of the local area. It is a high-density multi-storey development on the edge of the beachfront, with no other multi-storey developments or apartment blocks in the area.
• In holiday periods there could be as many as 400-500 people residing in the apartments. Existing infrastructure is already inadequate for holiday periods, and this development will make a bad situation worse.
• The development is too close to the beach and just behind the sand dunes. Sand dunes are not stationary landforms and will be eroded away or move as sea levels rise as they are forecast to. A development of this scale in such a sensitive coastal position is just a recipe for future problems and unnecessary expenses.
• The Coastal Risk Assessment report for the development is out of date – it was completed six years ago in June 2020, and climate change and sea level forecasts have changed since then. The proposal should be rejected because this report is out of date and it is not based on the latest forecasts for climate change induced sea level rise.
• The development is far too tall and bulky and will dominate the local natural environment. The maximum height of the proposed roof is15.25m. The permitted level in the LEP is 12m with 13.2m allowed if there is a lift. The HDA advise they will accept 14.5m and then the developer wants even a higher roof. All this sounds like a developer pushing the boundaries to make more profit, not good design in a sensitive area.
• The buildings could be visible from the beach, especially from the northeast. The beach is a wonderful untouched landscape with no visible infrastructure for many kilometres north of the surf lifesaving club.
• Buildings on the Gold Coast in a similar proximity to the beach have problems with basement drainage. The basement is RL2.5 AHD. Even without a sea level rise, the basement will be at risk of flooding.
• The development will not help with the housing crisis. There is a large, approved development in Tea Gardens (Parry’s Cove) and a manufactured home development in Tea Gardens under assessment, both of which could cope with any increased housing needs. The selling price of these units will be far too high to help with the housing crisis. It is most likely that this development will be mostly used as holiday homes and for short-term rentals.
• The fact that the developer wants to build the development in stages indicates that there is not an existing market for such a large development.
• If approved, there should be a time limit on completing the whole development, rather than leaving it as an uncompleted zombie development.

The Board & Management of Hawks Nest Golf Club believe the proposed Residential Flat Buildings at Sanderling Avenue represent a positive and appropriate development outcome for the area.
The development will:
• Support the local economy;
• Make efficient use of serviced land;
• Contribute positively to the streetscape and community;
• Increase housing choice and supply; and
• Align with contemporary planning objectives.
For these reasons, we respectfully support the application and encourage the Planning Minister to approve the proposal.

This submission supports the Sanderling Avenue Residential Flat Buildings proposal (SSD-82066472) based on its superior architectural design, considered traffic management, much needed boast to the towns commercial enterprises and employment opportunities for younger semi-skilled local workers PLUS a significant contribution to alleviating regional and NSW housing shortages.

Supporting Submission: Sanderling Avenue Residential Flat Buildings
To: NSW Department of Planning, Housing and Infrastructure
Project: Sanderling Avenue Residential Flat Buildings (SSD-82066472)
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1. Exceptional Architectural Merit: Bulk and Size
• Design Excellence: The proposal showcases high-quality architectural design that harmonizes with the coastal landscape, utilizing modern materials and finishes that enhance the aesthetic of the Hawks Nest area. Conceptually, the gently curved and softened built form was inspired by the site's surrounding Hawks Nest coastal environment; the sand dunes, Yacaaba Headland and the immediate shoreline.

• Thoughtful Massing: The bulk and size of the buildings have been carefully designed using well defined and aged architectural principles , with the four-storey structures designed to create a "stepping" effect, significantly reducing the visual impact from the local street levels ,I.E Sanderling Avenue , Tuloa Avenue, Booner and Yamba Streets, plus the wide expanse of the adjoining golf course, compared to the existing block-style developments that in part dominate Hawks Nest . A number of these existing block style developments are visible from the Hawks Nest surf beach.
• This project is clearly shown, in the attached documents and renders ..see APPENDIX 10 - Landscape & Visual Impact Assessment to NOT be beach visible.

• Site Integration: The development is designed to integrate with the neighbouring golf club and golf course rather than dominating it, providing a high-quality, resort-style aesthetic that increases the value of the surrounding area as well as supporting the commercial job producing activities with the golf clubhouse.
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2. Minimal Traffic and Infrastructure Impact
• Contextual Traffic Growth: While representing a significant increase in local density, the 104 apartments with their potential slightly older demographic occupiers are expected to generate low peak-hour traffic additions, aligning with expected infrastructure capacity and mitigating high-density bottlenecks.

• Strategic Location: The location on Sanderling Avenue allows residents to access the golf course and local beach without needing to utilize the main town traffic routes, reducing the overall trip frequency. The Golf Club House offers a number of visitor hospitality amenities such as a 7-day bar, coffee shop and restaurant

• Improved Parking Infrastructure: The proposal includes significant upgrades to the adjacent Hawks Nest Golf Club carpark, providing a net positive to parking infrastructure for the wider community.

3. Impact on Existing Hawks Nest Infrastructure

• The Hawks Nest Sewage Treatment Plant multimillion dollar upgrade is due for completion mid-2027 , significantly increasing the treatments plants capacity to support the anticipated Hawks Nest/Tea Gardens housing growth.
• Secondly the Hawks Nest/Tea Gardens water treatment works, and electricity supply substation have , within the past 15 years been upgraded to handle anticipated 40+ year population growth in both towns


4. Easing the Housing Shortage
• Increased Housing Supply: The 104 apartment units offer much-needed, high-quality diverse housing options in a region with limited supply.

• Local Demographic Shift: Many of these apartments are likely to be purchased by permanent residents (including downsizers from the local area), allowing them to vacate larger existing homes.

• "Filter Down" Housing Effect: By freeing up existing dwellings , the project assists in easing the critical housing shortage for families and newcomers elsewhere both in the MidCoast and general NSW community.

5. Enhance local liveability: The Sanderling Hawks Nest project will significantly enhance local liveability, offering a vital and much needed economic and social boost at a critical time for our Hawks Nest community. While the recent closures of the local newsagent, marine centre, and women's dress shop underscore the urgent challenges facing our village, this proposal acts as a direct countermeasure to further decline. Instead of detracting from the town, the project introduces fresh investment, revitalises public spaces, and stimulates commercial activity. By creating new jobs and gathering spaces, it directly addresses current economic vulnerabilities and strengthens the social fabric of Hawks Nest for residents and visitors alike.

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Conclusion
The Sanderling Avenue proposal is an exceptionally designed development that offers a necessary solution to local ,regional and statewide housing demands while adhering to high architectural standards with absolute minimal environment impacts , minimum existing infrastructure, or traffic impacts to the existing 1800+ dwelling Hawks Nest town. Boosting the local economy and ongoing employment opportunities particularly for semi-skilled younger local workers.

I write in objection to the proposed ‘State Significant Development’ (SSD) at the Sanderling Avenue site, Hawks Nest. I am a resident of Hawks Nest who also currently holds position as a democratically elected Councillor with MidCoast Council. My main reasons for objection are as follows:
1. “Housing Crisis” excuse is invalid:
This project will not make any helpful contribution to easing the 'housing crisis' in NSW, mainly due to the fact that the domiciles to be constructed will not be any more affordable that those currently on the market, and will not be sold for any less than the going market price. As the State Government currently lacks any capacity to directly regulate housing prices (rental or purchase), the default strategy has been to increase supply. In Hawks Nest, the added number of high-cost, luxury beachfront residences that this project seeks to create will not enter the real estate market any lower than market value, and will also not apply any other downward pressure on real estate elsewhere. Any claim such as “house owners will downsize to the new units, freeing houses on the existing market” may be conceivable, but whatever housing is left upon the local market (let alone across the state), will not become even remotely more affordable. An ‘offset’ concept elsewhere will exert no real change on the local market, either.
2. Not in keeping with local character:
The Sanderling Avenue project, if approved and built, will have buildings up to and over the typically regulated height of a four-storey edifice. No such buildings exist anywhere nearby, making this resort-style luxury complex utterly out of character for the local area. The site of the proposed development is environmentally sensitive coastal bushland very close to an ocean beach. This concept raises multiple legitimate environmental concerns that MidCoast Council and many other submissions would have made perfectly clear. None of the local residents’ concerns have been adequately addressed, no serious local input has been sought nor considered, and none of the true local impacts have been properly assessed. Part of the proof for this is in the fact that this very submission period had to be extended from the bare minimum of 14 days to 28 days, at the direct behest of local residents and groups.
3. Local economic impact:
While the Sanderling Avenue project may bring limited short-term work to local tradespeople during construction, there is no enforceable guarantee that local tradespeople will be directly involved. Further, the only realistically foreseeable jobs this project might create, longer-term, would largely be hospitality and service jobs, making no difference to the existing extreme seasonality of the local economy. There is also no reason to believe that permanent residents of this development would spend any more at existing local businesses, even at the adjacent Hawks Nest Golf Club, due to the very likely insular nature of the proposed domiciles, and the limited, protracted take-up of the domiciles themselves, potentially leaving the area with a white-elephant edifice that brings nothing of extra value to the area. A concern regarding the overlap of land boundaries has also arisen, with the potential to cut off the Golf Club from its main supply delivery route as a small but significant portion of the development’s land currently overlaps that route, perhaps forcing acceptance.
4. Severe traffic concerns:
This proposed Sanderling Avenue development, if approved, will increase local traffic radically beyond current or manageable levels. Sanderling Avenue itself has no line markings, kerbs, nor gutters, and two-way passing traffic is already problematic. The avenue is very close to the singular intersection that brings traffic into town from the bridge, meaning that any traffic problems along Sanderling Avenue could very quickly back up onto the bridge itself, snarling up traffic into the rest of Hawks Nest. No proper nor appropriate traffic management plan has been produced. Traffic studies done thus far have been perfunctory and tokenistic, and not at all considered the busiest times of the year, nor of the day, and in no way accounting for the fact that in peak holiday periods the area’s population quadruples. Even significant upgrades to the surrounding local roads will quickly prove fruitless, as these roads are simply too small to accommodate the exacerbated traffic resultant if even a fraction of the new domiciles at this location become inhabited. Any given unit could easily require several car spaces, but there is simply not enough room on the site. Any proposal for underground parking at the site will immediately prove woefully inadequate, and parking will likely overflow into the Golf Club’s carpark, or down Sanderling Avenue, further constricting that roadway.
5. Not in keeping with the purpose of ‘State Significant’:
This project has made it onto the SSD list by way of technicalities, including the overall value of the project, and the number of alleged ‘domiciles’ it will create. The SSD concept was originally conceived to expedite affordable living situations for citizens of NSW, not to expedite luxury beachfront accommodation projects such as this one. Being strategically located at easy walking distance between an 18-hole golf course and an ocean beachfront, this project cannot objectively be considered to fit into the purpose of the SSD process. There is no reason to believe that young families, workers, nor anyone other than the relatively well-off could buy into the development. I am aware that MidCoast Council has extreme reservations about the validity of this Sanderling Avenue development for many reasons, more than enough for Council to have to decline it, were it to be presented as an appropriate Development Application (DA) to Council. As such, should this project be passed by the SSD process, it will set the bar for any and all future such projects to leapfrog local Councils and get luxury developments approved anywhere and everywhere in the state.

This project is NOT a State significant development. There is no supporting infrastructure in transport, medical, educational or retail. It will never be permanent housing if apartment owners choose to short term rent to take advantage of the golf course next door. It is not affordable housing with price ranges from $1.5 million for a studio apartment to $5.2 million for a penthouse. Please see my attached submission in full. Thank you.