Indigo By Moran - 156 Ocean Street Narrabeen

I do not want to see Narrabeen turned into Dee Why - once we approve one building this size, the next thing we know our neighbourhood will be full of high rise apartments. Not to mention our friends whose houses border this potential project. I oppose this project and will be protesting on Saturday to further support our neighbourhood.

I object to the proposed 149-apartment development at 156 Ocean Street, Narrabeen.

The project represents overdevelopment. Its bulk, height, and density are completely out of scale with Narrabeen’s lower-rise coastal character. The proposal removes all mature pine and gum trees along Lagoon Street, destroying the area’s natural screening. Excavation on the peninsula risks erosion and water table disruption, threatening native wildlife.

The design shows no meaningful setbacks, blocking long-standing ocean views and overwhelming surrounding homes. Traffic impacts will mean around 300 vehicles exiting onto Lagoon Street and only seven visitor spaces provided.

This is a private retirement project offering no public space, community benefit, or infrastructure improvements yet it is being fast-tracked as a State Significant Development.

I urge the Department to reject the proposal and require a smaller, environmentally sensitive design consistent with Narrabeen’s character.

Height and amount of dwellings in a small area will be major issues. A majority of unit style dwellings are only two stories three stories in this area so this is well above this from the plans. The height and amount of dwelling goes agains what is currently in the area. Parking is at a premium already. Traffic around this area is also a major concern due to the small streets and position opposite a popular beach. This will further create traffic congestion in this area. Parking is also major issue as these developments which never offer enough visitor parking for the size of this project which leads to little or no parking. There is little transport in the immediate area and it is far walk to a major transport hub. This project needs to be reduced to fit into the area and a large visitor carpark matching the amount of dwellings in this project.

Please add photo to written submission

7/150 Ocean Street,
Narrabeen, NSW, 2101

3 November, 2025

Re: SSD-76220734
Indigo by Moran - 156 Ocean Street, Narrabeen

To whom it may concern,

I am writing to convey my STRONG OPPOSITION to the proposed development at 156 Ocean Street, Narrabeen.

The proposal has been submitted as a State Significant Development. This development bears NO SIGNIFICANCE FOR THE STATE OF NEW SOUTH WALES, its residents or infrastructure. This SSD application is a blatant attempt by developers to bypass local planning and environment laws, and should be seen as such.
The development proposes a significant increase in the height of the building above existing restrictions. While these restrictions may be relaxed with justification, the developers have provided no such justification. The development provides NO BENEFIT TO THE LOCAL COMMUNITY; it will only add to the profits of greedy developers. Therefore, relaxation of the restrictions imposed by the existing SEPP and DCP are NOT WARRANTED.
My property at Unit 7, 150-152 Ocean Street is my major asset and forms a large part of my retirement plan. The loss of light and privacy, combined with the increase in traffic will see SEVERAL HUNDRED THOUSANDS OF DOLLARS wiped off the value of my property, while greedy property developers rake in millions.

My objection to this development centres on two major concerns, being the height of the proposed structure impacting loss of solar access and privacy. Additional significant concerns include impact on parking and traffic in the area.

Loss of solar access
The application states that the south side of the proposed development has been pushed back to limit solar loss. While this is true for one small part of the development it is not true for the southeast corner of the development which is using the existing building footprint. Therefore, an increase in height will substantially increase solar loss. The shadow diagrams provided show a considerable increase in shading over the property at 150-152 Ocean Street. There are major impacts to the back yard, clothesline and individual units, including indoor and outdoor areas.
Page 55 of the Visual Impact Assessment clearly shows how overbearing the development will be for the surrounding properties, including 150-152 Ocean Street. The development represents a substantial loss of blue sky outlook for the surrounding properties. The photomontage pictures show the building as a grey amorphous mass against a grey sky. They do not adequately demonstrate the full visual impact of glass, balconies and gaudy blue tiles/paint. The actual vista will be an eyesore which dominates the skyline of the Narrabeen peninsula. It is noteworthy that nearly all other buildings along Ocean Street are neutral colours.

Privacy
Privacy is a major concern. Units along the southern side of the proposed development will look straight into the bedrooms of the units at 150-152 Ocean Street, which are mostly comprised of full-width floor to ceiling glass. There is currently screening from some large trees, but they are unhealthy and nearing end of life. When they are removed, there will be no protection, and six storeys of windows and balconies will have unobstructed views into the bedrooms of 150-152 Ocean Street.
Additionally, any lots on the third floor or above (including the rooftop terrace) will have unobstructed views on to my roof top terrace. This represents a significant loss of privacy to an area where my young nieces could be sunbaking or entertaining friends.

Parking
The proposed car parking facilities are completely inadequate. In the Traffic Impact Assessment, Section 5: Parking Assessment, paragraph 5.1.1 states that the Northern Beaches Development Control Plan does not specify parking rates. THIS IS FACTUALLY INCORRECT. Appendix 1 of the Northern Beaches DCP mandates 1.2 spaces per 2-bedroom unit, 1.5 spaces per 3-bedroom unit and one visitor space per five units. This means that a minimum of 223 parking spaces is required for the proposed number of units.
Should the developers continue to argue that the proposed development, being ‘Seniors Housing’, is not specifically addressed in the DCP, I would point them to Part C Siting Factors - C3 Parking Facilities - paragraph 4, which states that when carparking rate is not specified, carparking must be adequate for the development, taking into account the objectives and requirements of the clause. I would argue that the proposed development is residential housing (regardless of whether the developers have made up a new category of ‘Seniors Housing’) and should be subject to the requirements of the Northern Beaches DCP in its entirety.
In reality, most retired couples will have access to two vehicles. Even allowing for only 50% having two vehicles will require 225 parking spaces to be provided, plus additional visitor parking which will need to be more than the four spaces and three disabled spaces proposed. The parking allocation proposed by the developers could support 90 units at most.
The parking situation on residential streets on the Narrabeen peninsula is currently above capacity. Any development that does not provide adequate parking for ALL vehicles will only add to the already overstressed situation.

Traffic
Section 6.5 of the Traffic Impact Assessment states that the bus stop at Ocean and Octavia is dangerous. Nearly all bus stops along Ocean Street are on corners. Neither Northern Beaches Council nor Transport for New South Wales have at any time expressed safety concerns or taken any action to correct any dangerous situation.
Notwithstanding that there is only one bus movements per hour (Traffic Impact Assessment Table 4-3) that would only stop for a few seconds, if at all. The developers propose moving the bus stop south (taking away existing street parking) and replacing the bus zone with a ‘No Stopping’ area (not replacing the lost parking spaces). This will effectively give the proposed development exclusive access to the entire street frontage at the cost of other residents.
The Preliminary Construction Traffic Management Plan is completely unrealistic. It proposes truck access via Lagoon and Ocean Streets with a circular pattern (utilising Loftus Street and Octavia Street) in a clockwise direction for trucks departing and an anti-clockwise direction for trucks approaching. This will mean that the side streets will have trucks passing in opposite directions. Even the most cursory investigation would show that ALL side streets between Wellington Street in the south and Malcolm Street in the north are barely a car width wide. Trucks will not be able to use them in ANY direction. In addition, trucks will not be able to approach the site along Ocean Street from the north due to narrow streets and load limitations.
Overall, the Traffic Impact Assessment is woefully inaccurate and requires substantial revision. For example:
• Table 4-1 lists Wakehurst Parkway as 2 lanes in each direction. THIS IS FACTUALLY INCORRECT as Wakehurst Parkway is one lane in each direction.
• Section 4.6 shows the crash history for the area. The listing of two (2) incidents DOES NOT CORRELATE with the extensive list of incidents that Northern Beaches Council recently presented to residents when considering reducing speed limits on the Narrabeen peninsula.
• Section 4.7 presents justification for the development based on traffic flows for Pacific Highway.
• Of the dozens of intersections in the area, including major branching points, Table 4-7 lists just two (2) intersections, one on Pittwater Road and the other a roundabout on back streets. This is clearly a subversion of the facts in order to present a favourable picture. Any resident can tell you that these are the intersections of least concern. Significant congestion occurs around the intersections at Pittwater Rd/ Wakehurst Parkway, Pittwater Road/Ocean St, Pittwater Rd/Gondola St, Pittwater Rd/Garden St. These are the local intersections that need to be included in a Traffic Impact Assessment.
• Under Section 8.3.1 it appears the developers are not planning to notify the residents of the adjoining properties on Loftus Street of the commencement of construction.
It is clear that whoever wrote the Traffic Impact Assessment had never visited the site nor even bothered to look at Google Maps. I recommend that the current SSD not be considered until an accurate Traffic Impact Assessment is provided.

Social
Another of the government’s priority projects is the provision of social and affordable housing. The current development proposal does not make any provision under this priority.

Summary
While I appreciate the government’s prioritisation of medium and high-density housing, the Narrabeen peninsula is two blocks wide and cannot physically support any additional development. Approval of this application will have disastrous effects on the area, and I implore the Department to reject this application.

Steven Faddy
3 November, 2025

This development is not inline with the skyline of Ocean st and will set a precedent for future developments. Destroying the charm of our coastal community.

I strongly object to this project as it sets a precedence for over development. The Narrabeen peninsula is a rare part of the northern beaches that still has a character of smaller density residential area. If it goes over 2 or 3 stories development the whole area is too small to cope with such high density development. The traffic ans parking is already at capacity. There are other suitable areas to do larger density sites but along ocean st Narrabeen is NOt one of them . This area is unique and should be protected as heritage area to keep its unique surfing atmosphere and not a Dee why feel. Please do NOt allow this development.

Dear Secretary,

I am writing to formally oppose the proposed development at 156 Ocean Street, Narrabeen (SSD-76220734) by Indigo by Moran. As a concerned Northern Beaches resident and active community member, I strongly object to this proposal on the grounds that it represents overdevelopment, lacks local benefit, and poses significant environmental, visual, and safety impacts to our beautiful coastal community.





1. Excessive Height and Overdevelopment





The proposed six-storey, 149-apartment complex is completely out of character with the surrounding Narrabeen area, which is zoned R3 with a height limit of 8.5 metres. At 21.5 metres, this development more than doubles the existing height controls, setting a dangerous precedent for future high-density projects along our low-rise coastal strip. Narrabeen has always maintained a strong village feel and locals wish to preserve this unique identity. The size of development is much better suited to a Pittwater Road site, away from the low rise feel of Ocean Avenue.





2. Lack of Local Benefit





This proposal offers no affordable housing or community benefit. It is a private luxury retirement development targeting the cashed up over-60s market. Such exclusivity contributes nothing to local housing diversity or affordability and excludes the broader Narrabeen community. I understand housing is priority for State Significant Developments but this is not an appropriate scale for the area. I strongly oppose the idea that development of this size will bring any benefit to our street.





3. Traffic and Safety Hazards





The addition of 300+ vehicles entering and exiting via Lagoon Street will worsen already congested local roads and reduce safety for pedestrians, cyclists, and nearby residents. I regularly drive these roads as a local resident and parking is already a large problem around these streets. The area around Ocean, Lagoon, Loftus, and Octavia Streets is already under significant traffic strain. I often have to circle the block many times in order to find a park.





4. Visual Intrusion and Overshadowing





The bulk and scale of the development will overshadow neighbouring homes, surely the houses on Loftus street will be hugely impacted by the 21.5m height and have significant loss of sunshine. The size of this building will visually dominate the local skyline. Nothing in Narrabeen is of this size and it will not fit in with the causal local feel of this area. This intrusive form will erode the coastal character that defines Narrabeen and detract from the amenity of existing residents.





5. Environmental and Coastal Risks





The proposed site sits within a flood and coastal erosion zone, making it unsuitable for such a dense and tall structure. The deep excavation (11.5 metres below ground level) and coastal proximity pose serious risks to the local water table and stability of the dune system.





6. Destruction of Native Trees and Wildlife Habitat





The removal of mature native pine trees and other coastal vegetation will destroy habitat for local wildlife, including sea eagles, kookaburras, and native bird species, as well as eliminate the natural screening that provides aesthetic and environmental value.





7. Insufficient Community Consultation





Local residents were not adequately consulted in the planning or design stages of this proposal. The notification period was shortened from 28 days to 14 days. A development of this scale, should have to oblige by the standard rules in place and not use loopholes to duck and weave from what is standard practice. If they really wanted to know how the community felt- give us the standard time to respond. The community feels blindsided and excluded from meaningful participation in decisions that directly affect our neighbourhood’s character, safety, and environment.





8. Precedent for Future Overdevelopment





Allowing this proposal to proceed would open the door to further high-density, high-rise development across the Northern Beaches Peninsula, irreversibly changing the character of Narrabeen and threatening its fragile coastal balance. We need to protect Narrabeen and fight the overdevelopment. Our area has charm & we intend to keep it that way for generations to come. Change and development we accept, but not of this scale.





For all of the reasons outlined above, I respectfully urge the Department to reject or significantly scale down this proposal so that it aligns with the existing planning controls, local character, and environmental constraints of Narrabeen.



Thank you for considering the concerns of local residents who are deeply invested in protecting our coastal community.

Thank you again, for your time in reading my submission,

Brett Raphael
Northern Beaches Resident

Submission of Objection – SSD-76220734

156 Ocean Street, Narrabeen

To:
The Secretary
Department of Planning, Housing & Infrastructure (DPHI)

Re: Objection to SSD-76220734 – 156 Ocean Street, Narrabeen

I am a resident of Narrabeen and live at 190 ocean st Narrabeen, in close proximity to the proposed development at 156 Ocean Street. I use the surrounding roads, beach access and public domain daily and am directly affected by the proposal.

I wish to lodge a formal objection to SSD-76220734 on the grounds of inappropriate scale, land-use incompatibility, and unacceptable impacts on traffic, pedestrian safety, and local amenity. My objections are outlined below.

1. Incompatibility With Local Character

The proposed development is inconsistent with the existing built form and desired future character of Narrabeen.

The building scale and bulk significantly exceed the surrounding low-rise coastal fabric that characterises Ocean Street and nearby residential pockets.

The proposed height and massing would adversely impact the existing neighbourhood’s visual cohesion, introducing a dominant built form foreign to the area.

The structure will likely create excessive overshadowing and visual intrusion, particularly for properties along Ocean Street and for pedestrians on public domain pathways.

The proposal conflicts with planning intent that emphasises human-scale development and protection of the village-like coastal character.

As someone living within direct view of the site, I am concerned the proposal would permanently undermine the established visual qualities that define Narrabeen.

2. Unsuitability of the Site

The location is unsuitable for development of this density and typology.

The site is constrained by narrow road frontage, limited manoeuvring areas, and sensitive residential interfaces.

Immediate proximity to the beach environment necessitates development that respects environmental exposure, coastal hazards and evacuation vulnerability—this proposal does not appear to sufficiently respond to those constraints.

The building scale does not provide adequate transition to adjacent low-rise buildings, resulting in material privacy, overshadowing, and visual impacts to nearby residences.

The site’s position along an already constrained coastal corridor makes it an inappropriate setting for large-scale intensification.

The proposal is fundamentally incompatible with the physical and environmental characteristics of the site and surrounding residential context.

3. Traffic and Accessibility Impacts

The proposal introduces significant traffic and safety challenges in an area already facing congestion and limited access capacity.

Ocean Street and surrounding local roads are already under pressure from beach-related traffic, pedestrian activity, and recreational users.

Increased vehicle movements (including service and waste vehicles) will worsen congestion and queueing, particularly during peak coastal periods.

The proposal raises safety concerns for pedestrians and cyclists travelling between residences, recreation areas and beach access points.

The constrained road network makes safe vehicle ingress/egress challenging, with limited tolerance for additional traffic load.

As a resident who regularly walks or drives through this corridor, I am especially concerned about increased conflict between vehicles and vulnerable road users, including children accessing the beach.

Conclusion

On planning grounds—including incompatibility with local character, site unsuitability, and unacceptable traffic and access impacts—the proposal is not appropriate at 156 Ocean Street.

I respectfully request that the Department refuse SSD-76220734.

Thank you for considering this submission.

Yours faithfully,
Greg Gillespie

I am writing to express my formal and strong objection to the State Significant Development (SSD) application SSD-10271561 for a 5-6 storey seniors living development at 156 Ocean Street, Narrabeen.

As a resident of Ocean Street, my property is directly opposite the proposed site. This development, as currently proposed, will have a direct, severe, and unreasonable impact on my home, my family's amenity, and the local neighbourhood.

My objections are based on the following key areas:

1. Significant Loss of Privacy and Direct Overlooking
The most damaging impact of this proposal is the severe and irreversible loss of privacy to my home. The proposed 5-6 storey height and the placement of balconies, windows, and communal spaces will allow for direct lines of sight from the new development directly into my children's bedrooms, bathrooms, and primary living areas. This is not a minor infringement; it is a gross violation of our family's privacy and an unacceptable intrusion into our home. The feeling of being "watched" in one's own home is a significant detriment to mental health and residential amenity. The scale and height of this building make it impossible to mitigate this impact through screening or landscaping.

2. Overshadowing and Loss of Natural Light
The bulk, scale, and height of the development will cast significant new shadows over my property. I have grave concerns about the impact this will have on my home, particularly on the western side of my property. This overshadowing will directly impact our main living areas and garden, drastically reducing access to natural sunlight, particularly in the afternoons. This will not only reduce the amenity and enjoyment of our home but will also negatively impact our energy efficiency, requiring increased use of artificial lighting and heating.

3. Inadequate Parking and Exacerbation of Existing Chaos
The application provides insufficient parking spaces for the proposed 149 units (plus staff and visitors) and demonstrates a fundamental misunderstanding of the local area. Ocean Street and the surrounding residential streets already suffer from a critical and dangerous lack of parking. Our street is constantly choked with illegal, over-capacity parking, with cars parked illegally, across driveways and on corners with poor visibility. This existing chaos already poses a significant risk to pedestrians and other drivers, and on numerous occasions, has prevented our street from receiving council garbage collection as the trucks cannot safely access the street. This development will add dozens of cars (from residents, staff, and visitors) to this already failing situation, spilling them onto our local streets and making a dangerous situation unbearable. It poses a genuine risk of injury or accident.

4. Impact on Traffic Flow and Pedestrian Safety
The addition of 149 dwellings, plus the associated staff and regular visitor traffic (medical, family, deliveries), will generate a significant increase in vehicle movements. Ocean Street is a local road that is not designed to accommodate this level of intensified traffic. This will lead to further congestion, rat-running through adjacent streets, and increased safety risks for children and other residents.

5. Other Relevant Objections
Beyond my primary concerns, I also object to the proposal on the following grounds:
Bulk, Scale, and Local Character: The proposed 5-6 storey height, bulk, and density are entirely inconsistent with the established low-rise coastal character of Narrabeen. It is an overdevelopment of the site that will visually dominate the streetscape.

Setting a Dangerous Precedent: Approving a development of this scale and non-compliance would set an undesirable and dangerous precedent for future development in the area, further eroding the character and amenity of our neighbourhood.

Non-Compliance with Planning Controls: The proposal appears to be seeking exemptions or represents an overdevelopment of the site, inconsistent with the intended local planning controls (LEP and DCP) for height, setbacks, and Floor Space Ratio (FSR).

The cumulative impacts of this proposed development are unreasonable, unacceptable, and will permanently damage the amenity of my home and the safety of the local area. The proposal prioritises developer profit over the privacy, safety, and well-being of the existing residents.

I strongly urge the Department of Planning to listen to the community and refuse this application.

Sincerely,
Damien Thomson
159 Ocean Street, Narrabeen

I am firmly opposed to the current proposal for the Indigo by Moran Seniors Living. The proposed height of 5–6 storeys is excessive for our low-rise neighbourhood and will adversely affect traffic, parking, and the local character. I respectfully request that the Department consider reducing the building height to a maximum of 2–3 storeys and decreasing the overall density to more appropriately align with our community.

Dear Planning Officer,

I strongly object to the proposed Indigo by Moran development at 156 Ocean Street, Narrabeen.

This project must not proceed as proposed. It is excessive in scale, out of character with the local area, and fails to meet community and environmental standards.

The six-storey height and bulk breach Northern Beaches Council limits and overwhelm the low-rise coastal character of Narrabeen.

It is clear overdevelopment, driven by profit rather than community need.

The design ignores surrounding homes and provides no genuine aged care or affordable housing — only high-end apartments disguised as aged care.

The planned removal of 69 trees (including 24 mature specimens) is unacceptable and will destroy habitat, shade, and visual amenity.
There are numerous bird species that nest in the trees marked for removal and in area surrounding including Osprey, White-Bellied Sea Eagle, Nankeen Kestrel, White faced heron, Yellow-tail Black Cockatoo, Glossy Black Cockatoo, sulfur crested Cockatoo, Superb Fairy Wren, pies butcher bird, Tawny Frogmouth, boobook, barking and powerful Owl, Rainbow Lorikeet, eastern Rosella and too many sea-birds to list including migratory species.

The visual impact will be severe, blocking views, light, and open space for neighbours.

Traffic and parking pressures will worsen, making Ocean Street more dangerous than it already is.

Excavation for a three-level basement risks damage to fragile sandy soils and the local water table.
Look to the nightmare that the sea wall has become on the foreshore properties at South Narrabeen.

The proposal fails to respect Indigenous heritage and lacks genuine environmental sustainability targets such as a 5-Star Green Building rating.


This is not responsible or community-minded development. It should be rejected or redesigned to comply with council planning rules and protect Narrabeen’s unique coastal character.

Sincerely,
Matthew Meadows
30A Addison Road, Narrabeen NSW

1. Parking and Traffic Impacts
The proposal fails to adequately address existing parking shortages and congestion in the area. The development’s scale will place further pressure on surrounding residential streets, which already experience limited parking availability.
2. Overdevelopment and Density
The proposed density is inconsistent with the established local character of Narrabeen. The bulk and scale of the development are excessive for the site and will result in a significant loss of amenity for nearby residents.
3. Insufficient Transport Infrastructure
Local transport networks, particularly bus and road services, are already under strain. The proposed increase in residents and vehicle movements cannot be sustainably supported by current infrastructure.
4. Pressure on Amenities and Services
Local amenities, schools, medical facilities, and community services are already operating near capacity. The additional population generated by this development would further reduce accessibility and service quality.
5. Loss of Landscaping and Significant Trees
The proposal includes the removal of much of the existing site landscaping and significant mature trees. This would result in a major reduction in local canopy cover, biodiversity, and visual amenity, contrary to Council’s environmental and sustainability objectives.
6. Construction Impacts on Ocean Street
Extended construction activities would have a long-term and detrimental impact on Ocean Street, including noise, dust, heavy vehicle movements, and restricted access for residents and pedestrians.
7. Excessive Building Envelope and Visual/Solar Impact
The proposed building envelope will cause substantial overshadowing and visual bulk impacts on surrounding properties. The height and massing are incompatible with the existing built form and will diminish residential amenity and solar access.
8. Carbon and Sustainability Concerns
The demolition and removal of the existing building will result in a significant carbon footprint. The proposal does not demonstrate a sustainable approach to reusing or retrofitting existing structures.

9. Flooding and Water Management
Narrabeen is a flood-prone area. Increased site coverage and reduced permeable surfaces may worsen local flooding and stormwater runoff, impacting neighbouring properties and the lagoon/ocean catchment.

10. Inadequate Setbacks and Privacy
The proposed building setbacks appear minimal, resulting in direct overlooking into adjacent residential properties and reduced privacy for both existing and future occupants.

11. Noise and Construction Management
Given the site’s proximity to residential dwellings, there is concern about prolonged noise, vibration, and dust during construction, with insufficient mitigation measures proposed.

12. Impact on Local Character and Heritage
The design does not respect the established coastal village character of Narrabeen. The height, façade treatment, and site coverage are inconsistent with the surrounding streetscape and heritage context.

13. Environmental and Coastal Impact
Given the proximity to Narrabeen Lagoon and the coast, potential impacts on local ecosystems, stormwater quality, and erosion control should be reassessed.

14. Lack of Community Consultation
There appears to have been limited meaningful community engagement prior to lodging this application. Local residents should have been consulted early, given the project’s scale and potential impact.

15. Overshadowing of Public Space and Streetscape
Beyond private solar impact, the proposal risks overshadowing footpaths, public open spaces, and vegetation along Ocean Street — reducing safety, walkability, and amenity.

16. Wind and Microclimate Impacts
The proposed building height and bulk may alter local wind patterns, creating downdrafts and turbulence at street level, impacting pedestrians and nearby dwellings.

17. Waste and Servicing Arrangements
Insufficient consideration appears to have been given to waste collection, delivery access, and emergency vehicle movement, which could cause congestion or safety risks on Ocean Street.

18. Non-compliance with Strategic or Zoning Intent
The proposal exceeds intended density, height, or FSR limits under the local planning instruments (LEP/DCP), conflicting with Council’s strategic vision for the area.

19. Precedent Risk
Approval would set a precedent for other over-scaled developments in Narrabeen, undermining existing planning controls and community expectations for the area’s future character.



For these reasons, I respectfully request that the application SSD-76220734 be refused or substantially amended to address these concerns

per attached letter

please find my objection to the Indigo/Moran proposed development in Ocean St Narrabeen

I support seniors housing on this site in principle. North Narrabeen needs high-quality downsizer options. However, the proposed 5–6 storey, ~149-unit scheme with three basement levels is far too tall and bulky for this coastal neighbourhood, and sets an unacceptable precedent for height and massing in a low-scale beachside suburb. The scheme fails the objectives of the planning framework regarding coastal character, amenity, flood and evacuation resilience, and cumulative impacts. Consent should be refused unless the height, FSR, setbacks and massing are substantially reduced to a maximum of three storeys with materially increased deep soil and landscape.
1. Introduction & Standing
I am a local resident of North Narrabeen with 15 years of expertise in strata and community management. I support seniors living as a land use and recognise the loss of aged care beds previously on the Wesley site; however, the current proposal’s scale is not compatible with its coastal context or surrounding two- to three-storey pattern. Public exhibition for SSD-76220734 commenced on 23 October 2025 and closes 5 November 2025.
2. Planning Framework & Objectives
Assessment must consider EP&A Act s4.15 matters, relevant SEPPs and local instruments, including:
• EP&A Act 1979 s4.15 (impacts, suitability of site, submissions, public interest).
• Resilience & Hazards SEPP (incorporating Coastal Management provisions) and the Coastal Management Act 2016 (coastal zone objectives, hazard resilience).
• Northern Beaches LEP/DCP (height/FSR objectives, built form/landscape, coastal character, view sharing, parking & access). Public material indicates R3 areas on the Beaches are typically 2–3 storeys, with higher limits only near nominated centres under State reforms. This site’s proposed 5–6 storeys would exceed the prevailing local scale.
3. Proposal Snapshot (Key Facts & Claims)
Based on exhibition material and public reporting:
• Use: Seniors housing/retirement village (independent living + limited care).
• Scale: 5–6 storeys, ~149 apartments, 3 basement levels.
• Site: 156–164 Ocean St, 81–81A Lagoon St & 8 Octavia St.
• Former use: ~55 aged care beds + 35 assisted living units (Wesley Mission).
• Status: State Significant Development, exhibition 23/10/25–05/11/25.
Position: Support the use, oppose the scale. Acceptable outcome: ≤ 3 storeys, reduced GFA/FSR, increased setbacks and deep soil, revised access and landscape.
4. Assessment & Grounds of Objection
4.1 Urban Design & Neighbourhood Character
The building height and bulk (5–6 storeys over large frontages) would read as a mid-rise precinct in a low-rise beachside suburb, eroding the established coastal character and view corridors to the ocean/lagoon. “Technical compliance” with any numeric control does not satisfy objectives to respect local character, landscape setting and view sharing. A three-storey envelope with stronger articulation and deeper setbacks is necessary to align with the area’s prevailing 2–3 storey rhythm.
4.2 Coastal & Flood Risk (Resilience)
Narrabeen is flood- and erosion-prone; evacuation and shelter-in-place performance for older residents must be conservative. Coastal/lagoon flooding, stormwater exceedance, and climate allowances should be tested against coastal management objectives and s4.15 (site suitability). The combination of deep basements and high resident density increases risk exposure during flood or utility outage events. A lower, lighter footprint (≤3 storeys), reduced car-park excavation and more deep soil would better support resilience and evacuation options.
4.3 Traffic, Access & Parking
Ocean St and the surrounding network experience peak congestion; seniors villages also generate frequent service trips and visitor parking demand. The likely on-street spillover and access safety issues at this location are understated when the proposal scales to 5–6 storeys and ~149 units. A reduced unit yield with a single consolidated driveway location, improved sightlines and higher onsite visitor parking is warranted to avoid unacceptable impacts.
4.4 Residential Amenity (Overshadowing, Privacy, Wind)
Mid-rise bulk adjacent to low-rise homes risks winter overshadowing of private open space, intrusive cross-views below acceptable privacy distances, and wind acceleration around ocean-front corners. The proposal’s height exacerbates these effects. A three-storey cap with increased upper-level setbacks and planted buffers would materially improve solar access, privacy, and wind comfort outcomes consistent with DCP objectives.
4.5 Environment, Landscaping & Urban Heat
Tree/canopy losses from basements and building footprint reduce local shade in a coastal microclimate that already experiences high glare and wind. Increased deep soil zones, canopy targets and permeable area are needed to mitigate heat and support biodiversity. These outcomes are difficult to achieve at 5–6 storeys on this site but feasible at ≤3 storeys with rebalanced site coverage.
4.6 Services, Infrastructure & Social Impact
While seniors housing is needed, the scheme emphasises premium independent living and results in a net reduction of genuine aged care beds compared with the former Wesley operation, contrary to community expectations about care availability on the Beaches. Height-driven yield does not automatically translate into social benefit if it undermines character, resilience and infrastructure capacity. A smaller scheme can still deliver meaningful downsizer supply.
4.7 Cumulative Impact & Precedent
Granting 5–6 storeys here would create a de facto benchmark for mid-rise forms beyond nominated centres under NSW’s housing reforms. Council has already warned that 4–6 storey envelopes are intended near specific town centres and transport nodes, not blanket coastal frontages. Allowing this height will invite “leap-frog” proposals and accelerate character change beyond strategic intent.
5. Response to Likely Proponent Arguments
• “Housing for seniors is needed” — Agreed; deliver it at appropriate scale. Need does not override failure to meet objectives for character, amenity and hazard resilience under s4.15.
• “Design excellence / within envelope” — Height alone is not the test; proposals must also achieve objectives (character, view sharing, coastal setting, landscape). A three-storey scheme is more likely to do so here.
• “Transport and parking are adequate” — Peak-period observations and the coastal cul-de-sac geometry indicate limited spare capacity; impacts scale with unit numbers. A smaller scheme mitigates risk.
6. Requested Outcomes
1. Refuse the application unless height, bulk and yield are reduced to a maximum of three storeys with increased setbacks, reduced site coverage, materially larger deep soil zones and a revised landscape plan.
2. Require updated flood/coastal and evacuation analysis reflecting conservative climate allowances and the specific vulnerabilities of seniors populations.
3. Require a revised traffic and parking assessment addressing visitor and service vehicle accumulation, safe access design and on-street spillover safeguards at the reduced scale.
4. Require a social impact addendum clarifying care provision relative to the former Wesley facility and demonstrating community benefit at the lower height.

To whom it may concern,

I am writing to formally object to the proposed SSD development in Narrabeen, Indigo by Moran.

As a local resident (Loftus Street) in my 60s who is deeply invested in the future of our community, I fully support thoughtful growth, genuine social housing initiatives, and considered planning. However, this proposal is neither responsible nor aligned with the local planning framework or community character.

KEY CONCERNS:

1. Height and Zoning Breach

Narrabeen was re-zoned by the NSW Government only last year to a maximum of three storeys for housing. Yet this proposal seeks six storeys—double the permitted height.
This is inconsistent with the process that led to the zoning decision and sets a dangerous precedent for future development that ignores planning controls.

2. Misuse of “Social and Diverse Housing” Classification

From my understanding, this proposal is being processed under Social and Diverse Housing provisions and considerations. However, only 10 of 149 units are designated for assisted living. The remaining apartments are forecasted to be sold at around $3 million plus each.
It is difficult to see how luxury apartments qualify as “social or diverse housing,” and it looks like a planning loophole is being used to by-pass appropriate scrutiny.

3. Significant Light and Privacy Impacts

A six-storey structure of this scale will overshadow neighbouring properties, impact natural light, reduce privacy, and negatively affect the amenity of long-standing family homes.

4. Water Table & Structural Impact

Narrabeen’s water table sits at approximately 15 metres—where our bore currently draws from. A three-storey underground garage with major foundations is an evident environmental and geotechnical risk.
There has been inadequate assessment provided on how this will affect groundwater, especially in such a sensitive location.

5. Inadequate Parking Provision

Only seven visitor parking spaces for 149 units is unrealistic and irresponsible. Our streets already experience heavy parking pressure, and this will inevitably push overflow parking into an area that has very limited street capacity. A garbage truck can barely squeeze down our neighbouring side street, Loftus Street, at the best of times. We already feel the squeeze of inadequate parking.

6. Increased Traffic and Disruption and Flow

The development will significantly increase traffic on Lagoon Street and Ocean Street. Ocean Street carries consistent traffic for much of the day (with a natural increase at peak times). It is also an arterial road, assisting traffic that needs to move both north and south daily towards the peninsula and the city.

Both the construction phase and long-term occupation will create congestion and safety risks for residents, pedestrians and families.

7. Community Character and Precedent

This proposal does not reflect the established character of Narrabeen. Allowing a six-storey build here opens the door to further inappropriate height creep across the suburb—effectively undoing the careful zoning work completed just last year!

RELEVENT POLICY CONTEXT:
(Please let me know if incorrect as is taken from policy documents that may have been further updated since)

To support my objection, I highlight key relevant NSW planning policies:

The State Environmental Planning Policy (Housing) 2021 (“Housing SEPP”) is the principal state instrument governing residential development in NSW.
The Low and Mid‑Rise Housing Policy (LMR Policy) is embedded via Chapter 6 of the Housing SEPP (through the Amending Instrument from 28 February 2025).
Under this policy:
For designated “low and mid-rise housing inner areas” (within about 400 metres of a town centre or transport node), the consent authority must be satisfied that residential flat buildings are up to six storeys (and up to approx. 22 m height) in specified locations.
For “outer areas” (up to 800 m from centres) the cap drops to four storeys (approx. 17.5 m) for residential flat buildings.

Importantly, these state-wide controls are minimums and do not override local zoning controls which impose lower height limits and protect amenity, character and infrastructure capacity. Local Environmental Plans (LEPs) and Development Control Plans (DCPs) remain fundamentally relevant.

Local council planning documents within the Northern Beaches Council area show that deviations of more than ~90% above maximum permitted height have been treated as significant non-compliance.

In this case, not only is the proposal well above the local maximum of three storeys, but the contextual characteristics of the site (water table, street capacity, parking, traffic, amenity) aggregate to show that this development is inconsistent with both the policy intention and the local planning framework.

CONCLUSION:

I am not opposed to development, progress or genuine social housing. I want to see Narrabeen thrive. But development must respect planning controls, the environment, the community and the character of the area.

This development should be scaled appropriately to the legislated three-storey limit (or whatever local zoning direct states). Allowing six storeys here undermines that process.

I strongly request that this proposal be rejected in its current form. A revised plan—adhering to the three‐storey zoning consistent with community expectations and government guidance—would be far more acceptable.

Thank you for considering this objection. I trust that the planning process will uphold fairness, transparency and the principles intended by the recent rezoning and state policy.

Yours sincerely,

Susan Ansell

The development is inconsistent and in breach of the State Planning Guidelines and should be modified to ensure compliance

Please refer to attached submission.
Thanks