Indigo By Moran - 156 Ocean Street Narrabeen

I formally OBJECT to the proposed State Significant Development Application SSD-76220734 on the grounds detailed below. I request that the Department of Planning, Housing and Infrastructure refuse this application as proposed, due to its non-compliance with statutory planning controls, unacceptable amenity impacts, and detrimental effects on local character, infrastructure, and cultural heritage.

Grounds for Objection (Planning and Environmental Concerns)

My opposition to this development is based on the following specific planning and environmental grounds:

A. Visual Bulk, Scale, and Non-Compliance with Local Character

The proposed five-storey height and substantial massing of the development are inconsistent with the established low-to-medium rise residential character of the Narrabeen locale, particularly near the Narrabeen Lagoon/Beach interface.

Non-Compliance (if known): The proposal appears to rely on State Environmental Planning Policy (Housing for Seniors and People with a Disability) 2004 provisions that grant height and Floor Space Ratio (FSR) bonuses, which in this context results in over-development. The sheer scale and bulk of 149 units and extensive communal facilities will dominate the local streetscape, setting an undesirable precedent for future development.

Visual Impact: The excessive size and footprint of the building will create an unacceptable visual bulk, particularly when viewed from Ocean Street, Lagoon Street, and adjoining residential areas.

B. Traffic Generation, Parking Deficiencies, and Infrastructure Overload

The proposal for 192 basement car parking spaces, despite being a seniors housing development, represents a massive increase in vehicular traffic on local streets, specifically Lagoon Street (the main access point) and Ocean Street, while simultaneously failing to adequately plan for visitors.

Visitor Parking Deficiency: The provision of only 7 visitor car parking spaces for a development containing 149 Independent Living Units is grossly inadequate. This is a severe underestimation of demand for staff, service vehicles, and residents' family visitors.

Lack of Street Parking Capacity: The inevitable overflow parking will be forced onto surrounding local streets, which are already heavily constrained and lack available spaces. This area is already saturated with parking demand, especially during holidays and summer months, which will be severely compromised, directly impacting local resident amenity and access.

Traffic Congestion: Narrabeen is already a highly constrained traffic area due to its location between the ocean and lagoon. The proposed increase in vehicle movements during peak times will exacerbate existing congestion and compromise pedestrian and cyclist safety.

Infrastructure Strain: The concentration of such high-density living will place undue strain on existing local infrastructure, including sewerage, stormwater management, and power supply, which may not have the capacity to support the development's scale.

C. Site Suitability and Environmental Hazards (Flooding and Coastal Erosion)

The site is located adjacent to Narrabeen Lagoon and close to the beach, raising serious concerns regarding environmental risk.

Flood Prone Land: Given the site's proximity and history of inundation, the development’s proposed mitigation measures need to be scrutinised rigorously to ensure they do not merely displace flood risks onto neighbouring properties, particularly during severe weather events.

Coastal Risk: The long-term risk of coastal erosion must be fully accounted for, and I question the suitability of such a high-value, high-density development on such an environmentally sensitive site.

D. Loss of Amenity (Overshadowing and Privacy)

The height and setback of the proposed building will result in unacceptable impacts on the solar access and privacy of adjoining residential properties.

Overshadowing: The sheer height of the structure will cast significant new shadows over neighboring residential properties and their private open spaces, particularly during the winter months, reducing amenity and solar gain.

Loss of Privacy: The multiple levels and extensive balcony areas will result in unacceptable direct overlooking into the private living areas and rear yards of adjacent homes.

E. Cultural Heritage Significance (Narrabeen Man Location)

The site and its immediate vicinity are of immense cultural significance, specifically relating to the discovery site of the Narrabeen Man (Manly Council DA 2005/730).

Cultural Sensitivity: Any major construction, excavation (especially for the three-level basement), or site works in this area carries a high risk of disturbing or failing to adequately recognise Aboriginal cultural heritage. The proponent's assessment of this risk must be scrutinised to ensure all historical and archaeological obligations are met far beyond standard compliance, reflecting the site's unique importance.

Precautionary Principle: Given the sensitive nature of the location, the precautionary principle should apply, requiring a more cautious and less impactful development footprint to minimise the irreversible risk to potential cultural artefacts.

F. Loss of Existing Vegetation and Canopy Cover

The proposal necessitates the removal of a significant number of existing trees and mature vegetation across the consolidated site to accommodate the large building footprint and three-level basement.

Ecological and Amenity Loss: The mature trees provide essential canopy cover, contribute significantly to the leafy, green character of Narrabeen, and offer habitat for local fauna. The scale of removal is unacceptable and cannot be adequately compensated for by replacement planting, which will take decades to mature.

Arborist Report Scrutiny: I request strict scrutiny of the proponent's Arborist Report to ensure that all trees marked for removal are genuinely impossible to retain, especially those of high significance or health.

Visual Buffer: The loss of significant canopy cover will remove the natural aesthetic buffer between the massive proposed structure and the surrounding existing homes, making the development appear harsher and more imposing.

Conclusion and Request

For the reasons outlined above, particularly concerning the excessive visual bulk, critical deficiencies in parking, inadequate management of traffic generation, high environmental risk, and profound cultural heritage concerns, I urge the Department to refuse Development Application SSD-76220734.

Alternatively, should the Department be minded to approve the development, I request that significant amendments be mandated to reduce the overall scale (FSR and height), density, and basement excavation of the proposal to ensure it is more sympathetic to the surrounding environment, infrastructure limitations, and cultural sensitivities.

Thank you for considering my submission

It's destroying the intrinsic character of the Northern Beaches, a character where the natural environment dominates the built.This is particularly the case once past Dee Why, where one can see the results of the slippery slope once projects such as 156 Ocean St Narrabeen are allowed to be built. The current Minns Labor Govt will be condemned by history as the initiators of a developer-led process by which the distinctive character of various Sydney locations were subsumed by a bog-standard, one-size-fits-all built design standard. Or lack of a standard. It doesn't help that the two main protagonists - Minns and Scully - are both from south of the Harbour, an area characterised by brick, concrete, and structural approaches which do not share the typical greenery, biodiversity, and treed slopes north of the Harbour. Have they even visited, particularly from Narrabeen north to Barrenjoey and west to Ingleside? The current Planning initiative is one where the goose that laid the golden egg is killed. It will be remembered forever as the Minns- Scully destruction of what makes Sydney attractive. Further, this development has zilch to do with affordable housing; that will occur only by public ownership, not private development.

Submission Objecting to DA SSD-76220734 — “Indigo by Moran”, 156 Ocean Street, Narrabeen
To: NSW Department of Planning, Housing and Infrastructure
SSD Planning Assessments
Re: Objection to State Significant Development Application, “Indigo by Moran”
Address: 156 Ocean Street, Narrabeen NSW
DA Number: SSD-76220734
Submitted by: Kylie & Tony
Date: 30/10/25

1. Introduction
We are long-term residents of Malcolm Street, Narrabeen, and wish to formally object to the proposed Indigo by Moran development at 156 Ocean Street, Narrabeen (SSD-76220734).
While we support quality, well-planned accommodation for seniors, this proposal represents a significant overdevelopment of the site, entirely out of scale with the surrounding residential character and infrastructure capacity of Narrabeen. The impacts on traffic, parking, safety, and neighbourhood amenity would be severe and ongoing.

2. Traffic and Parking Impacts
The proposal includes three basement levels with 192 car spaces (only seven of which are for visitors). This design will inevitably force a large number of visitor vehicles to park on surrounding local streets such as Lagoon Street, Albemarle, Loftus, Octavia & Tourmaline Streets, and Ocean Street.
These streets already experience high levels of parking demand, particularly on weekends during spring and summer when the Narrabeen Lagoon Trail and beach attract large numbers of visitors. Local residents frequently struggle to find on-street parking, and this development would exacerbate that problem significantly.
Furthermore, all vehicular access is proposed from Lagoon Street, a narrow, heavily used road that lacks capacity for such an increase in traffic volume. The proposed continuous in-and-out flow from a three-level underground carpark will create congestion, delays, and safety risks for both drivers and cyclists.

3. Cycling and Road Safety Concerns
The Traffic Report supporting this DA incorrectly suggests that Lagoon Street has a dedicated cycling path. This is inaccurate, cyclists currently share the road with vehicles, and the road width is limited. The increased vehicle movements from this development, including service vehicles and residents’ cars, would create a serious safety hazard for cyclists, pedestrians, and residents accessing driveways.
Given the popularity of the Lagoon Trail and Narrabeen’s cycling routes, this is a critical safety concern that must not be overlooked.

4. Scale, Height and Visual Impact
The proposed 5 to 6 storey building would be a visually dominant structure sitting atop a hill, looming over surrounding low-rise residential homes. It would create significant overshadowing, loss of privacy, and an overbearing presence entirely inconsistent with the coastal village character of Narrabeen.
This design is comparable in mass and bulk to the Northern Beaches Hospital, an institutional-scale development wholly inappropriate for this sensitive, low-rise coastal environment. The proposal fails to respect the established character and topography of the area.

5. Congestion and Access Constraints
Traffic flow along Lagoon Street and connecting roads such as Malcolm Street is already constrained. The section of Lagoon Street near Malcolm Street narrows to a single car width, regularly causing bottlenecks and queues, particularly during peak periods. This also includes the section of Malcolm Street from Ocean Street. Any additional volume from this development would worsen congestion and impede access for residents, emergency vehicles, and visitors.
The cumulative impact of this development, in conjunction with existing congestion during weekends and summer months, would significantly reduce the livability and safety of the surrounding community.

6. Conclusion
For the reasons outlined above, we strongly object to the Indigo by Moran proposal in its current form. The scale, bulk, and traffic generation far exceed what can be safely and reasonably accommodated within the existing road and community infrastructure of Narrabeen.
This development would:
• Intensify already severe parking and congestion issues
• Compromise cyclist and pedestrian safety
• Visually dominate and overshadow surrounding residential areas
• Disrupt the existing low-rise coastal character of Narrabeen
We respectfully request that the Department refuse this development application or require substantial redesign to reduce height, density, and traffic impacts in line with the existing scale and safety of the neighbourhood.

Yours faithfully,
Kylie & Tony
Malcolm Street, Narrabeen NSW

Narrabeen is part of the world renowned Sydney’s Northern Beaches, famed not just for the beaches but the surrounding scenery clothed in trees and bush that define the skyline . It should remain so and not become “ The Gold Coast “ which over time it will inevitably morph into . Six storey buildings will become ten then twenty and beyond and the whole essence of the area will be lost for ever . Quite apart from the certainty of streets , where parking not just for the residents but all Sydneysiders who come to enjoy the beaches , will become constant traffic jams and no longer a joy for young families .
I strongly feel the decision to go beyond 3 storeys will in time be the beginning of destruction of the scenic heritage of Sydney in the years to come .
It must be worth saving lest the coast line becomes a never ending mass of skyscrapers where the only beneficiaries are the developers.
I desperately hope the decision will be to reject the proposal for 6 storeys of this development.

My Objections to this Project are stated in the attachment

We need to stop over developing and approving high rises in Narrabeen. The traffic is horrific , we don’t have the infrastructure including the removal of our hospital in Mona vale. Ocean st is all virtually under construction. We can’t work from home due to the noise.

I think a 6-storey building is too high. This area typically has 3-storey as highest building. I’d support 3-storey.

I have lived in Narrabeen for 49yrs the development is in no way sympathetic to the area or character, parking is already minimal let alone in summer with narrow streets throughout. lack of transport options, impact on surrounding residents is huge with no compensation for loss of value. The precedent this could set could have the potential to destroy the area and village nature. Dee Why has been lost and destroyed. Traffic is already horrendous through the Wakehurst parkway Pittwater road and Powderworks road as all are clogged every morning. The six story height is purely for greed not necessity this in no way helps the so called housing crisis as it is age specific.

The proposal is to have a six story building. There are no buildings in our area taller than 3 stories. It is absolutely going to ruin our neighbourhood. It is going to increase traffic and put a load on parking (the proposed building is not going to have sufficient parking for its residents), especially in summer. Narrabeen is a quiet, low key residential area. Up to now the current retirement home (that the developers are proposing to pull down to put their six floor opulent building on) blended into our neighbourhood. Having a senior housing development is not the issue it is the size & scale of the proposal that is the issue. I think it is pure greed. Thank you. Cheryl Rae. Concerned resident

I don’t want this built because I want to keep my suburb normal and not developed like Dee why

No local benefit, private luxury development with no affordable housing. Overdevelopment completely out of character and scale with the location . Visual intrusion and overshadowing pf neighbourhood. Traffic and safety hazards with more than 300 additional cars on local streets. Development located in flood and erosion zone. Will require removal of mature trees destroying habitat and coastal screening. A threat to fragile dune systems and bird habitats. Destroys the beaches character that attracts tourists to visit and holiday at local caravan park. No local consultation by developers.

I am objecting to the proposal,
1. The height is not what is required in the planning rules. It is higher than regulation and the surrounding area.
2. Bulk and scale is way above what is allowed to any other land owner in that area, I am currently building in that area and was not allowed certain items on a 2 storey building as the bulk and scale of it did not meet surrounding buildings
3. Shadowing effects neighbouring properties and does not provide the required sunlight as per regulations
4. Of the 149 units only about 10 are provided for aged care? How can this be built using aged care guidelines and preferences?
5. Car parking and street parking - Council has already expressed urgent action is need for car parking around that area recently and had done reports that state car parking was already an issue? There are definately not enough car spots for the 2 and 3 bedroom units that they are building with I believe only 7 visitor spots?
6. Building does not fit with the local character of the area, this area was not approved in the new LMR guide. Narrabeen was not fit to be able to handle developments of this size, so was not approved by the State Govt in the recent legislation just implemented. So how is this proposal been submitted when the State Govt has already rejected LMR developments of this nature?

HEIGHT OF BUILDINGS. Under WLEP 2011 for land zoned R3 Medium Density Residential clause 4.3, the objective is "to ensure that buildings are compatible with the height and scale of surrounding and nearby development,” and “minimise visual impact, disruption of views, loss of privacy and loss of solar access”. This project runs in contradiction to the objective. By seeking to increase the height over the permitted 8.5m, the development will have a major visual impact, major disruption of view, major loss of privacy and will be in no way compatible with the height and scale of surrounding and nearby developments/properties. In seeking a variation, the developer has shown in the circumstances no reasonable justification. The variation would not represent an orderly and economic use of the land in a manner that is appropriate when considering the site’s context, and as such, is not justified on environmental planning grounds. According to Part 5 (Housing for seniors and people with a disability) of Chapter 3 of the Housing SEPP part b "a height of not more than 3.8m above the maximum permissible building height" is not automatically providing the developer an extra 3.8m of height to build, it is potential development consent for additional floor space ratio IF (emphasis added) the development will result in a building with "a height of not more than 3.8m above the maximum permissible building height". The SEPP does not provide exception/consent to override the maximum height of buildings by the LEP and doesn't provide an automatic building height bonus. Under the Objectives of the Standard - the proposed development a) does not ensure that buildings are compatible with the height and scale of surrounding and nearby development, b) does not minimise visual impact, disruption of views, loss of privacy and loss of solar access, c) does not minimise adverse impacts of development on the scenic quality of Warringah’s coastal and bush environments, d) poorly manages the visual impact of development when viewed from public places such as parks and reserves, roads and community facilities. The developer states “the fundamental purpose of the development is to renew an existing closed (and therefore unfeasible) aged care facility with a contemporary and high-quality seniors living development that will provide this essential housing typology in the northern beaches and within private market expectations”. Given there are already approximately +70 nursing homes/ aged-care homes on the Northern Beaches it can be inferred this is not an undersupplied area with regards this type of facility. A compliant development could potentially deliver a high number of Living Units (ILU) and aged care facility for seniors. The underlying objective or purpose would not be defeated or thwarted if compliance was required and therefore compliance is reasonable. The elements that sit above the height control, including 28 seniors living units, and amenity elements such as the rooftop communal space are not essential for the successful delivery of a sensible, community engaged project. The developer then tries to use a different justification by saying without these elements, the development would not be delivered, which would not achieve a now different underlying objective and purpose of “delivering additional and diverse housing in the current housing ‘crisis’ of NSW”. Again, given the number of aged care facilities on the Northern Beaches the generic use of an all-in NSW housing ‘crisis’ to help justify a height control variation is misleading. A subject scheme that breaches the height control has a number of impacts that result in a poorer design outcome for local residents/community when compared to a height compliant scheme (that is why there are height restrictions in place by LEPs). None of the elements of the design above the height control, are essential to successfully achieve a development that meets the objectives of the zone and deliver seniors living housing in Narrabeen. As such, the breach of the height control is not consistent with local community, council, state or federal objectives and should not be supported in this instance. Although there are residential apartment buildings that are above the current height control these are old developments and few/far between - some dating back to the 1960s. The current controls have been carefully considered by local government with the Narrabeen topology, groundwork, traffic, amenities, power/water infrastructure and coastal land area in mind. The design of the proposed development is in no way keeping with the demographics of the area. Sufficient consideration has not been made to protect the amenity of the neighbouring properties or surrounding residents. The development establishes a negative design response for the future built environment of Narrabeen. The elements that sit above the current height control can easily be incorporated under the height control on a large site such as this. Non-compliance with the development standard will result in adverse planning impacts beyond those anticipated in a strictly compliant development. There will be loss, significant and iconic views; adverse privacy impacts; adverse visual impacts and overshadowing to residential properties, particularly related to the building elements that sit above the building height control. The development has not been designed to carefully protect the environmental amenity of surrounding properties, and it does not create a contemporary form that establishes the future desired character for the medium density residential zone in the area through design futures. Surrounding developments are impacted by such a large project and significant view loss and high visual impact. For the reasons discussed above, it is contended that there are insufficient environmental planning grounds to justify the contravention to the development standard in the circumstances of the case, particularly given that the design does not provide a tailored and well considered response to the site’s constraints and articulation. The assessment above confirms that compliance with the maximum Height of Buildings development standard contained in Clause 84 is reasonable. It is also noted in Clause 84 section (iii) If the development results in a building with more than 2 storeys, additional storeys must be set back within 45° planes from all side and rear boundaries. The proposal delivers a development that is not appropriate for its context considering the breaches to development standards and therefore has insufficient environmental planning grounds to permit a variation. Therefore, compliance with the development standard is reasonable and necessary in the circumstances.
PRACTICAL CONCERNS. The increased population density from this development will put pressure on an already struggling local traffic system. It adds risk to all who travel in the area, including pedestrians and cyclists, who frequent our streets.
NORFOLK PINES. The developer states "The most unique and defining feature of this site is the presence of numerous large important Norfolk pine trees running along the entire Ocean St frontage.” They are planning to remove mature native pine trees along Lagoon Street. These trees are a critical part of our natural ecosystem, and their removal would be a considerable loss to our community's natural landscape. Such actions echo disregard towards environmental preservation, which should be at the forefront of urban planning.
COMMUNITY ENGAGEMENT. It should be noted the community feedback sessions were marketed/promoted as promotion for potential buyers/residents as opposed to a constructive consultation with existing residents and the community. The strength of feeling evident in current petition and quality of online submissions to this portal will provide council and local government feedback to this effect. Comments to the developers during the community information session supports a compliant height build and less imposing project:- “Size or scale of buildings(height) so that it blends with the surroundings (not overscale).”, “Keeping it low, not too high-rise.”, “I am not interested in a highrise property.”, “open space”, “Maintaining the ‘laid back’ style of the Northern Beaches”, “the building should be welcoming and encourage the wish to be a resident”, “Location, security, amenities, social, brand new, single level.”, “A space which is socially and environmentally friendly which blends into the local area.”. The only comment relating to justification for height was “I look forward to some height for views”. It is also noted that the photomontages used in the developer’s documents use overlays that are grey/translucent, use wide angles and do not accurately represent the visual impact of such a large, oversize building on the local area. Effective decision-making requires engaging with and respecting the voices of local residents, not circumventing them. No direct consultation/engagement has been had with adjacent homeowners (i.e. east side of Ocean Street for example).
CONCLUSION. Whilst a sensible project that remediates / redevelops the existing site within current planning controls and engages the local community would be welcome, the plans for this current project are a huge overreach and will negatively impact the local community. I object to the current project.

No local benefit, private luxury development with no affordable housing.
Overdevelopment completely out of scale with local area.
Visual intrusion and overshadowing of neighbourhood.
Traffic and safety hazards with more than 300 additional cars on local streets.
Development located in a flood and erosion zone.
Will require removal of mature trees destroying habitat and coastal screening.
A threat to fragile dune systems and bird habitats.
No local consultation by developers

This development is breaking height restrictions and sets a precedent for future high development in the area to be passed through which is not what the community and area needs! There has been no community consultation!

The scale of the project will deface Narrabeen ocean st.
Narrabeen has managed to retain a village essence but allowing this monstrosity, we are opening the gate to more projects on this scale, therefore killing the value of the town.

This project is not environmentally friendly and involves the removal of trees critical to the ecosystem. And we don't need any more obtrusive six-storey high rises.

I have lived on Ocean Street my entire life and I now live across the road from the development with my partner and newborn baby. I strongly oppose the proposed 6 storey, luxury seniors complex for a number of reasons:
1) current building is three storeys high and is unobtrusive. The proposed 6 storey, 149 unit complex is not only a visual intrusion but too big for our community resources such as supermarkets and roads
2) no community benefit - the luxury apartments provide no benefit to the community. As a young family we prioritise outdoor spaces, community hubs and amenities. The proposed complex instead brings safety risks to our children with increased traffic on Ocean and Lagoon streets. There’s also no affordable housing included in the building complex that would add value to our community
3) cost and size of apartments - predominantly two and three bedroom apartments seem large for retirement complex and seniors living. Most seniors are looking to down size from three bedroom houses or units. The proposed price point also seems unrealistic for most seniors in the community and adds to the housing crisis of our communities vulnerable members
4) Traffic and safety hazard - increasing population leads to more people and carbon the road. This is not only a hazard to children walking to school and playing, but to elderly people, animals and the actual quality of the roads
5) environmental impact - tree removal required for the development impacts the wildlife already living at the current site, reduces future habitat of wildlife and threatens the fragile dune systems
6) flood and coastal erosion - development is located in flood and erosion zone which deems it unsuitable for dense development. This is why local council rejects DA proposals of this size

It's not compatible with the neighbourhood. It will bring traffic, parking and infrastructure issues. It is too big. It could be considered the beginning of the region's deterioration.

The size of the proposed development footprint upon the land allotment is excessive in the extreme.
The rise in storeys is completely out of keeping with the surroundings.
No consideration has been given to the inevitable increase in traffic in local streets.
There has been no contribution to local infrastructure in the development proposal to support such a massive development.
This site has significant cultural history being the site of ‘The Narrabeen Man’ and excavation to this site on the scale proposed may like have devastating results for such an important historic site.
Removal of long established trees with destroy wildlife habitat as well as shade and street scape.