FORMAL SUBMISSION – OBJECTION
Proposed Development: Bells Boulevard, Salt Village, Kingscliff
Authority: Tweed Shire Council
Dear Councillors,
I write to formally object to the proposed five-storey development at Bells Boulevard, Salt Village, Kingscliff.
This objection is made on planning grounds pursuant to Section 4.15 of the Environmental Planning and Assessment Act 1979 (NSW), having regard to environmental planning instruments, likely impacts, suitability of the site, and the public interest.
1. Non-Compliance with Height, Scale and Built Form Objectives
The original proposal for the site was three storeys (13.6m). The current proposal seeks five storeys (21m), representing a substantial intensification.
Under the Tweed Local Environmental Plan (TLEP) and applicable Development Control Plans (DCP), height controls and built form objectives are intended to:
Ensure development is compatible with surrounding character
Protect amenity of adjoining land
Maintain coastal village scale
Prevent visual dominance and bulk
The surrounding area is predominantly low-rise residential dwellings. A five-storey building at 21 metres is incompatible with the established and desired future character of Salt Village and broader Kingscliff.
The proposal fails the fundamental planning test of contextual response and does not demonstrate appropriate transition in scale.
Approval would set a precedent for similar height variations within the tourism precinct and adjacent residential zones, undermining the integrity of existing planning controls.
2. Inconsistency with Zone Objectives
Although located within a tourism precinct, the site is immediately surrounded by residential dwellings.
Planning principles require that development:
Achieve a reasonable interface between differing zones
Minimise land use conflict
Protect residential amenity
A five-storey structure creates an unreasonable bulk and scale interface with neighbouring low-density residential development. The tourism zoning does not justify an urban-scale outcome in a coastal village context.
Zoning permissibility does not equate to appropriateness of scale.
3. Overshadowing and Public Safety – Adverse Environmental Impacts
Under Section 4.15(1)(b), Council must consider the likely impacts of the development, including environmental and social impacts.
The proposed height will result in significant overshadowing of:
The nearby busy roundabout
Pedestrian areas
Road corridors
Overshadowing at a high-traffic intersection raises legitimate public safety concerns, including:
Reduced driver visibility
Increased accident risk
Pedestrian safety impacts
This is particularly concerning given:
The high seasonal tourist traffic
Children crossing to bus stops
Increased vehicle movements generated by the development
A development that introduces foreseeable traffic risk without infrastructure mitigation cannot be considered acceptable planning.
4. Traffic and Infrastructure Capacity – Failure to Demonstrate Adequate Services
Section 4.15 requires consideration of whether infrastructure is adequate to service the development.
The proposal will increase traffic along Casuarina Way and surrounding streets. There is no clear commitment to infrastructure upgrades to address:
Road capacity
Intersection performance
Pedestrian safety measures
Road maintenance burden
Drainage impacts
Tweed Shire Council already faces challenges maintaining road conditions, particularly after heavy rainfall events. Intensifying traffic loads without corresponding infrastructure improvements is inconsistent with orderly and sustainable development principles.
The cumulative impact of traffic generation must be assessed, not merely the isolated impact of this proposal.
5. Parking Deficiencies and Amenity Impacts
Parking provision appears inadequate when realistic vehicle ownership patterns are considered.
In practice:
Many dwellings will accommodate more than one adult.
Multiple vehicle ownership is likely.
Overflow parking will extend into surrounding residential streets.
The Salt Village precinct already experiences high parking demand from:
Resort guests
Hospitality patrons
Local employees
Spillover parking into narrow residential streets will diminish residential amenity and may impede emergency vehicle access.
Development must not externalise its parking burden onto existing residents.
6. Failure to Deliver Genuine Affordable Housing
The proposal references “affordable housing” provision. However:
Only two one-bedroom units are proposed.
Indicative pricing is approximately $900,000.
Market escalation suggests potential sale prices exceeding $1,000,000 upon completion.
Under NSW planning principles, affordable housing must be genuinely accessible to low-to-moderate income households or key workers.
A $900,000–$1,000,000 one-bedroom dwelling does not meet any reasonable definition of affordable housing.
The minimal provision does not justify the scale uplift sought.
7. Character and Public Interest
Section 4.15(1)(e) requires consideration of the public interest.
Kingscliff and Salt Village are characterised by:
Coastal village scale
Low to mid-rise built form
Relaxed, non-urban atmosphere
A five-storey building materially alters this character and introduces urban density inconsistent with the established identity of the area.
There is no precedent in Salt Village for a development of this magnitude. Approval risks incremental urbanisation contrary to community expectations and adopted planning strategies.
The public interest lies in protecting the character and amenity of established coastal communities.
8. Environmental Impact – Threatened Species
The locality is known habitat for Bush Stone-curlews (a threatened species in NSW).
Increased density, lighting, traffic and human disturbance may:
Disrupt nesting
Reduce habitat viability
Increase mortality risk
Under the Biodiversity Conservation Act 2016 (NSW), Council must consider impacts on threatened species and ecological communities.
Precautionary principles should apply where habitat is present.
Conclusion
Having regard to Section 4.15 of the Environmental Planning and Assessment Act 1979, this proposal:
Is excessive in height and scale
Is incompatible with surrounding residential character
Creates traffic and parking impacts without demonstrated infrastructure capacity
Raises legitimate public safety concerns
Fails to provide genuine affordable housing
Risks environmental harm
Sets an undesirable precedent
For these reasons, I respectfully request that Council refuse the application in its current form.
Should Council consider approval, the development must be substantially reduced to align with the original three-storey (13.6m) intent and the established coastal character of Salt Village.
Kingscliff’s identity as a low-scale coastal community should not be compromised by inappropriate intensification.
Kind regards
Terri de Rooy

To: Kieran Thomas, Director – Housing Delivery Assessments
CC: Fiona Dowler

RE: Submission for SSD-83069459 – 4-8 Bells Boulevard, Kingscliff

Dear Mr. Thomas,

I am the registered proprietor of a lot within SP 73905 (9 Gunnamatta Ave, Kingscliff). I declare that I have made no reportable political donations in the previous two years and accept the Department’s disclaimer and declaration conditions.
While I hold a position of general support for the redevelopment of the subject site, I request that the following planning concerns and proposed conditions of consent be addressed:
1. Building Height and Bulk (Tweed LEP 2014 & DCP Compliance)
The proposal seeks a departure from the established three-storey height limit (approx. 13.6m) mandated by the Tweed Local Environmental Plan (LEP) and the original 2003 Masterplan consents for the Salt Beach Precinct. I submit that the proposed five-storey scale at a height of 21.5 metres represents an inappropriate "abrupt change in scale" (per the NSW Apartment Design Guide) and is inconsistent with the "desired future character" of the locality. The proposed development fails to align with the intended scenic landscapes, neighborhood character, and locality plans of the Kingscliff area. The proposals do not transition smoothly to neighbouring properties and causes a sharp, noticeable contrast in bulk when compared to neighbouring properties. To allow this proposal would set an unwanted and undesirable precedent. Establishing a precedent of this kind makes it increasingly difficult to uphold future planning regulations. Over time, the cumulative effect of approving buildings that exceed height limits would fundamentally erode the coastal village character of the Salt precinct and Kingscliff, undermining a low-rise identity that has been meticulously planned and protected. In addition the additional two storeys would significantly compromise the western vista and solar access for residents of SP 73905.
2. Traffic and On-Site Parking Provisions
The Environmental Impact Statement (EIS) lacks a definitive schedule of uses for the retail/commercial components. Without a confirmed GFA breakdown—specifically regarding high-intensity "Food and Drink Premises"—the current parking assessment likely understates the required rate under the Tweed DCP. I request that the Department require a revised parking study to prevent overflow into the private parking and residential streetscape of Gunnamatta Avenue. Kingscliff already faces significant on-street parking pressure, especially during peak times. Any lack of on-site parking will likely push vehicles into neighbouring residential areas, congesting streets and diminishing the local quality of life.
3. Restriction as to User (Short-term Rental Management)
To safeguard the development’s contribution to permanent housing stock, I request the imposition of a Public Positive Covenant or a Section 88B instrument (Conveyancing Act 1919) on the title. This should restrict use to permanent residential occupation, ensuring the development does not pivot to Short-Term Rental Accommodation (STRA), which would bypass the intent of the Housing Delivery Assessment.
4. Lapse of Consent and Project Delivery
Given the site’s 20-year history of vacancy and its status as a "derelict site," I urge the Department to consider a shortened "Lapsing of Consent" period or a staged construction condition to ensure the timely delivery of the built form and the remediation of the local amenity.

I strongly suppport this project - I am originally from the Gold Coast & spend quite a lot of time each year holidaying in this area (for the past 20 years). Generally I stay at Peppers Resort but find the surrounding retail amenity to be quite underwhelming. This project will be bring more diverse living options to the area (given how expensive houses are now in Kingscliff/Casuarina) & it will also bring some much needed amenity (particularly wellness which I think fits the area very well & is currently underuspplied).

the proposed building is way higher than the allowed height limit on the Tweed Coast , we dont need anything higher as the 3 storey limit makes the Tweed coast unique , I am a builder who is pro development , but current hight limit needs to be enforced.
the Developer has mentioned affordable housing in his submission , that statement is not for first home owners , the units will be priced in the millions. he wants retails shops but there is an abundance of retail shop in the tweed that are sitting vacant .

I object to the existing DA and list some but not all of my concerns in this summary. more detail details in the attachment below:

1. Excessive height
2. Retail in an area where all the existing shopping locations have ongoing long-term vacancies which they are unable to fill – more people shop online & more retail shops or medical offices are simply not required.
3. Visually, this proposal sits at the entry to Salt Village & will detract from the planned and effective streetscape because of its height and bulk
4. I object to a change of zoning
5. Parking provisions are woefully inadequate, And the developer has removed 27 street spaces and not replaced them plus the two levels of basement parking are inadequate.
6. Traffic;.The loading Bay and general garbage/facilities area is directly opposite MANTRA which is a tourism accommodation hub. Our local tourist guests do not need the disturbance of garbage vans and excessive use of the loading zone early morning or at night; perhaps the use of the loading zone could be limited to 9 to 5.
6B . Insufficient detail has been provided about the traffic flow and the effect on neighbours peaceful enjoyment in their homes. Further, given the lack of parking planned if this were to go ahead, people would park in the surrounding streets which generally are not as wide as metropolitan streets, and this would affect local residents.
6C The main road is Casuarina Way, which is single lane in both directions and this additional traffic will put tremendous pressure on the road, and There is not repeat not an alternative route from the south. From the north we have a single lane road leading to the bridge over Cudgen Creek which again is insufficient.
7. Tourism Implications A lot of time and $1 billion went into developing the Salt precinct hence it success as a village atmosphere holiday destination. Changing the zoning and increasing the height limitations for additional resident accommodation will change the feel of the area and our visitor profile will most likely decrease. If people want a Gold Coast experience they will go there but we don't want them thinking we are becoming the Gold Coast, because we are an attractive alternative to it . What research and data has been done to convince us that our tourists will continue?
8. Additionally employment – a lot of local people people rely on the tourism industry for their livelihood – reference Tweed Council's tourism figures Plus Tourism NSW tourism figures. We do not want to jeopardise jobs because of a downturn of visitors because of a zoning change.
WE ARE TOURISM AND WE WANT TO STAY TOURISM FOCUSED
9. Affordable housing: This is laughably insufficient and ridiculous.
10. Lastly, the lack of community consultation is both alarming and needs to be noted. We are all aware that this is the first of many possible changes to the Tweed Coast & the fact the department has not Advertise this DA through the local paper, member of Parliament, local television etc. Plus only emailed residence within a 2 to 500 meter radius is an error that needs addressing. I feel the Pause button needs to be pressed and the department must let all the local community know about this zoning change and height increase and give them all the opportunity to respond.

FINALLY, I would ONLY support a DA that has a maximum of three stories; keeps the current zoning; and has a similar visual impact as to the rest of the Salt complex. In my opinion the developer needs to keep two floors of underground parking; needs to reduce the height of the building to 3 stories, and lose the ground floor retail or service facilities completely.

As a concerned member of the Kingscliff community, I believe this development is inconsistent with the established character, environmental conditions, and infrastructure capacity of the area. My objection is based on the following grounds:

1. Incompatibility with Local Character
Kingscliff is valued for its low-rise coastal village character. The scale, bulk, and height of the proposed development are excessive and will dominate the streetscape, undermining the established urban form and village identity of the area.

2. Excessive Height and Density
The proposal appears to push or exceed planning controls intended to protect community amenity. Approving variations to height or density limits risks setting an undesirable precedent for future overdevelopment in Kingscliff.

3. Traffic and Parking Impacts
Bells Boulevard and surrounding streets already experience congestion, particularly during peak tourist periods and school hours. The additional vehicle movements generated by this development will worsen traffic conditions, reduce pedestrian safety, and increase parking pressure in nearby residential streets.

4. Flooding and Stormwater Concerns
Kingscliff is a low-lying coastal community with known flooding constraints. Increasing hard surface areas and building intensity may exacerbate stormwater runoff and flood impacts on neighbouring properties. In the context of climate change and more extreme weather events, this risk must be taken seriously.

5. Loss of Residential Amenity
The proposed development will likely result in overshadowing, overlooking, increased noise, and loss of privacy for nearby residents. These impacts will diminish quality of life and reduce the enjoyment of surrounding properties.

6. Construction Impacts
The scale of construction will result in extended periods of noise, dust, heavy vehicle movements, and general disruption, significantly affecting neighbouring residents and local businesses.

7. Limited Demonstrated Community Benefit
It is unclear whether the development delivers genuine long-term benefits for the broader Kingscliff community, particularly in relation to affordable housing, infrastructure upgrades, and environmental protection.

For these reasons, I respectfully request that this development application in its current form is rejected. At a minimum, substantial amendments should be required to reduce height, bulk, traffic impact, and environmental risk to ensure the proposal aligns with Kingscliff’s planning framework and community expectations.

Kingscliff’s character, safety, and environmental integrity must not be compromised by overdevelopment.

Submission – Objection
State Significant Development
Mixed-Use Development – 4–8 Bells Boulevard, Kingscliff

Submitter: Caitlyn Morrison

1. Introduction

I am a frequent visitor to Kingscliff and have strong personal and community connections to the area. I lodge this submission to formally object to the proposal in its current form.

This submission is based on concerns regarding planning compliance, infrastructure capacity, and the long-term protection of Kingscliff’s established coastal character.

Key Concerns
• Non-compliance with established height controls
• Traffic and cumulative infrastructure impacts
• Parking spillover and pedestrian safety risks
• Bulk and incompatibility with local coastal character
• Lack of demonstrated economic need for additional commercial floor space
• Inconsistency with applicable strategic planning objectives

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2. Statutory Considerations

Under Section 4.15 of the Environmental Planning and Assessment Act 1979, the consent authority must consider environmental planning instruments, likely impacts, site suitability, submissions made, and the public interest.

Relevant planning instruments include the Tweed Local Environmental Plan 2014 and the North Coast Regional Plan 2041. These frameworks exist to guide sustainable growth while protecting the character and function of coastal communities.

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3. Height and Built Form

The proposal seeks development up to approximately five storeys (~18 metres), which exceeds prevailing local height controls.

Height controls are not arbitrary. They exist to:
• Maintain coastal character
• Protect residential amenity
• Ensure orderly and consistent development outcomes

Granting a site-specific height uplift risks undermining planning integrity and creating an undesirable precedent for future developments within the precinct.

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4. Commercial Floor Space – Lack of Demonstrated Need

The proposal includes approximately 1,500m² of additional retail/commercial floor space.

There is currently no publicly demonstrated evidence of unmet commercial demand within the Kingscliff/Salt precinct. Observable vacancies within the area suggest that existing commercial supply has not yet been fully absorbed.

Strategic planning principles require commercial expansion to respond to demonstrated demand and contribute to sustainable economic growth. Introducing additional retail supply without robust economic justification risks:
• Increasing vacancy rates
• Undermining existing local businesses
• Creating long-term economic inefficiencies within the precinct

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5. Traffic and Infrastructure Capacity

The addition of approximately 70 dwellings plus retail floor space will significantly increase vehicle movements within an already constrained coastal road network.

Given the existing seasonal congestion and peak-period traffic pressures, cumulative impacts must be assessed holistically rather than in isolation.

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6. Coastal Character and Public Interest

Kingscliff is defined by its low-rise, human-scale coastal character. The proposed scale introduces a level of urban intensity that is inconsistent with established planning intent for the area.

The public interest is not served by overriding established planning controls without clear, transparent, and strategic justification demonstrating long-term community benefit.

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7. Requested Determination

I respectfully request that the consent authority:

• Refuse the proposal in its current form; or
• Require a substantial reduction in height and bulk;
• Require an independent economic impact assessment demonstrating genuine commercial need;
• Ensure cumulative traffic and infrastructure impacts are fully assessed and addressed prior to any approval.

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Sincerely,
Caitlyn Morrison

SUBMISSION REGARDING THE PROPOSED DEVELOPMENT AT 4–8 BELLS BOULEVARD, KINGSCLIFF

I wish to lodge a submission objecting to key aspects of the proposed development at 4–8 Bells Boulevard, Kingscliff. My concerns relate to the proposed building height, parking provision, traffic impacts, affordable housing outcomes and the overall impact on the surrounding area.

This submission is not an objection to development in principle. Appropriate development can contribute positively to Kingscliff when it aligns with established planning controls and respects the character and capacity of the local environment. However, the scale and intensity of this proposal go beyond what has historically been permitted or supported in this area and risk setting an undesirable precedent.

Current Height Limit in Kingscliff and the Salt Precinct

Under the Tweed Local Environmental Plan 2014, the maximum building height that applies to mixed-use and town centre areas in Kingscliff, including land within and adjacent to the Salt precinct, is 13.6 metres. This height limit reflects a deliberate planning intent to maintain a low-rise coastal village character consistent with the existing built form.

The proposal seeks approval for buildings of up to 18 metres, or five storeys. There is no precedent for development of this type and height within the Salt precinct or the surrounding Kingscliff area. Existing development has consistently complied with established height limits and built-form controls.

Excessive Building Height and Departure from Planning Controls

A five-storey development represents a clear departure from the established planning framework. The proposed height significantly exceeds the current height limit and is inconsistent with the scale and character of surrounding development.

While the height increase has been described as modest, an increase from 13.6 metres to 18 metres is substantial in planning terms and materially alters the bulk, scale and visual impact of the development.

Approving a development of this height would undermine the intent of the existing planning controls and weaken confidence in their ongoing application.

Precedent and Cumulative Impact

Approval of this proposal would set a precedent for future developments seeking similar or greater height variations. Once such a precedent is established, it becomes increasingly difficult to resist further departures from the planning framework.

The cumulative impact of approving developments that exceed established height limits would fundamentally alter the character of the Salt precinct and Kingscliff over time, moving it away from the low-rise coastal village identity that has been carefully planned and maintained.

Parking Provision and Likely Shortfall

While the proposal includes basement parking, there is insufficient confidence that the number of spaces provided will adequately meet demand generated by residents, visitors, retail uses, staff and service vehicles.

Kingscliff already experiences pressure on on-street parking, particularly during peak periods. Any shortfall in on-site parking is likely to result in spill-over into surrounding residential streets, reducing amenity for existing residents and increasing congestion.

Traffic Impacts and Side Street Congestion

A development of this scale will generate increased traffic volumes, including private vehicles, deliveries, ride-share services and service vehicles. Bells Boulevard and surrounding streets are local roads designed for a coastal village environment and may not be suitable for intensified traffic levels.

Increased traffic is likely to impact pedestrian safety, cyclist movement, parking availability and overall neighbourhood amenity, particularly in nearby side streets.

Affordable Housing Contribution

The proposal includes only two affordable housing units. While affordable housing is important, this level of provision is minimal in the context of a development of this size and does little to address local housing affordability pressures.

The limited number of affordable units suggests a minimal compliance approach rather than a meaningful contribution to housing diversity or community need.

Impact on Surrounding Character and Amenity

Taken together — excessive height, parking pressure, traffic impacts and limited affordable housing provision — the proposal risks detracting from the existing character and amenity of the area. Rather than integrating sensitively with its surroundings, the scale of the development has the potential to overwhelm the existing built form and undermine the qualities that define the Salt precinct.

Conclusion

For the reasons outlined above, I respectfully object to the proposed development in its current form. I request that the height be reduced to align with the existing 13.6-metre limit, that parking and traffic impacts be more rigorously addressed, that affordable housing provision be meaningfully increased, and that greater weight be given to the long-term character and liveability of Kingscliff and the Salt precinct.