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State Significant Development

Response to Submissions

Indigo By Moran - 156 Ocean Street Narrabeen

Northern Beaches

Current Status: Response to Submissions

Interact with the stages for their names

  1. SEARs
  2. Prepare EIS
  3. Exhibition
  4. Collate Submissions
  5. Response to Submissions
  6. Assessment
  7. Recommendation
  8. Determination

Exhibition period extended by 1 day to 6 November 2025 due to technical issues with the NSW Planning Portal - Seniors living development

Attachments & Resources

Notice of Exhibition (1)

SEARs (1)

EIS (42)

Response to Submissions (1)

Submissions

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Showing 161 - 180 of 746 submissions
Arune Prual
Object
NARRABEEN , New South Wales
Message
My Concerns:

1. Inconsistent Building Character
The proposed six-storey luxury complex is entirely inconsistent with the established character, building height, and environmental context of Narrabeen. It fails to respect the scale, infrastructure capacity, and community identity that define the area.

2. Inadequate Parking and Traffic Impact
The development provides only 178 residential parking spaces, which is inadequate for a complex of this size. With two- to three-bedroom apartments, multiple vehicles per household are likely, alongside visitors, staff, and maintenance vehicles. Traffic and parking congestion are already significant along Lagoon and Ocean Streets. Given these existing pressures, it is strongly recommended that the NSW Government appoint an independent traffic engineering consultant—rather than relying solely on the developer’s assessment—to ensure impartial evaluation of the parking and traffic implications.

3. Loss of Aged Care Capacity
The proposal reduces the current 55 aged care beds and 35 assisted living units to a 10-bed facility, substantially diminishing available aged care support in the Northern Beaches region. This cannot reasonably be considered a “like-for-like” replacement or a genuine continuation of services for elderly residents.

4. Exploitation of Planning Provisions
The developers appear to be exploiting planning loopholes within the Seniors Housing SEPP to facilitate approval. The State Government has already identified suitable high-rise precincts—Brookvale, Dee Why, Mona Vale, Manly Vale, and Forestville—where developments of this scale align with the existing landscape and infrastructure. A six-storey luxury complex on Lagoon Street is incompatible with the surrounding built environment and the local community’s expectations.

5. Risk of Setting a Precedent
Approval of this proposal would likely set a concerning precedent, encouraging other developers to misuse the over-60s housing provisions to bypass standard planning controls or to develop major projects in this area that are not fitting with the current landscape. Developments of this type belong in the designated higher-density precincts, not within low-rise residential pockets such as Narrabeen.

6. Lack of Genuine Community Consultation
Community engagement for this project has been inadequate. Meetings have been poorly publicised, scheduled during working hours, and structured in ways that limit public participation. This approach does not reflect genuine consultation, especially for a development of such scale and potential impact.

7. Absence of Affordable Housing
The proposal does not include any affordable housing options, despite the growing need for accessible housing within the Northern Beaches community.

8. Environmental and Water Table Concerns
The construction of a three-level underground car park raises significant concerns about the local water table and potential impacts on surrounding properties.

9. Destruction of Vegetation and Habitat
The planned removal of trees is inconsistent with existing planning and environmental protections. Such destruction will have detrimental effects on local biodiversity and species habitats.

Community Position

Local residents are not opposed to development per se; rather, they support projects that are reasonable in scale, environmentally responsible, and respectful of the community’s character. The current proposal represents a major departure from these principles and risks setting a long-term precedent for unsympathetic, high-density development in this area.

If government and council decision-makers are to act in the best interests of the community, this project warrants serious reconsideration and will truly test that sentiment.

We trust that integrity, transparency, and respect for community values will guide the assessment process for this development.
Name Withheld
Object
WARRIEWOOD , New South Wales
Message
To whom it may concern,

I am submitting this objection to the Indigo by Moran development on Ocean Street due to the design's extreme overdevelopment of the site, as well as the lack of adherance to the area's height restrictions, the local area's character and surrounding buildings.

Firstly, the height proposed at 21.2m is 8.8m over the allowable height limit for the area, even after accounting for the increase allowed under the SEPP (Housing for Seniors or People with a Disability) 2004. Any development above 12.4m above ground level represents a breach of planning laws, and is inconsistent with the Local Environment Plan and Development Control Plan, which are in place to ensure new developments are in keeping with the locale's context. The excessive height proposed will dominate the whole suburb, and lead to unreasonable overshadowing of the street and neighbouring properties; as well as a significant view intrusion for Narrabeen and surrounding suburbs, and will disrupt the visual transition between buildings - surrounding buildings are 1 to 3 storeys high throughout Narrabeen.
2. Narrabeen is exempt from the most recent state building height increase, as it was removed from the Stage 2 reforms after the council's submissions. This development is non-compliant with local or state development height controls, meaning Moran's height proposal is illegal. It is inappropriate for Moran to seek to circumvent this final policy.
3. Moran has made misleading representations in its proposal documentation, inaccurately depicting the 21.1m Indigo development as the equivalent height of the surrounding 2-storey dwellings of approx 6m high.
4. The proposal features inadequate setbacks and failure to provide height transition around surrounding buildings, which increases the visual and actual bulk of the proposed building, incompatible with the rest of Narrabeen and surrounding suburbs. A building of 21.2m is an inappropriate height when surrounding buildings are much lower density and max 3 storeys, and leads to unreasonable impacts for the public, including visual dominance, overshadowing and privacy concerns.
5. The proposal features inadequate parking provisions for the number of residents and staff that would be in the development at any one time; and contrary to the SEPP and Council's DCP. This will force traffic onto surrounding residential streets that are single lane width and exacerbate already scarce parking in the area. I am also concerned the increased traffic of approx 300 cars (if most dwellings have 2 vehicles, which one would assume for able over-60s) will increase traffic congestion in an already-stretched local area both east of Pittwater Road and the Northern Beaches north of Dee Why in general.
6. The proposal involves the removal of significant vegetation that is typical of Ocean and Lagoon Street, Narrabeen, some of which hold ecological value as habitat for native and endangered bird and animal life. Removing these trees represents an erosion of the visual character of the street, removes valuable urban canopy, and would remove any screening that currently softens the building form behind. The proposed removal of these trees and vegetation shows poor planning and incongruence to the natural setting of the suburb.
6. The bulk, scale and density of the development will alter local airflows for the surrounding houses, reducing natural ventilation for surrounding properties and creating the type of urban heat island effect that western Sydney is now trying to mitigate.
7. The density of the proposal is a significant overdevelopment of the site and is incongruous with the rest of the suburb of Narrabeen. Approval of this project in its current form would create an undesirable precedent for other developers to circumvent all state and local planning laws for the area, which would erode the suburb's established character and its natural environmental value. In recent years, many developers have purchased properties along this stretch between Ocean and Lagoon Street and have built 2-storey apartment blocks that are completely in-keeping with the area. This proposal by Moran is so far removed from current planning laws that it is impossible to imagine how it could pass in its current form.
In summary, I object to Indigo by Moran in its current form:
- The proposed building is excessively tall and not compliant with local or state height restrictions for Narrabeen.
- The proposed building is excessively dense and incongruent with the low-level residential buildings and 3-storey apartments that surround the site both east of Pittwater Road and throughout the suburb of Narrabeen.
- The proposed building uncompliant with setback controls.
The proposed building is inconsistent with the local character of the suburb and Northern Beaches north of Dee Why.
- The proposed building is environmentally destructive.
- The proposed building will increase traffic flows unsatisfactorily and impede on amenity of the area for current residents.
If these issues can be rectified by the state and the developer then I will gladly review another proposal.
Name Withheld
Object
ELANORA HEIGHTS , New South Wales
Message
Subject: Objection to Proposed Development – Indigo

Dear Planning Department,

I am writing as a life-long resident of Narrabeen who has recently moved to Elanora Heights to formally object to the proposed redevelopment of 156 Ocean Street Narrabeen. I visit this area daily for exercise and leisure, and I frequently dine at the surrounding restaurants and use the beach directly opposite the proposed site. My children attend school nearby.

While I understand the need for improved facilities in our area, this proposal represents a gross overdevelopment that is incompatible with the existing neighbourhood character and infrastructure.

1. Building Height and Visual Impact

The proposed six-storey structure is entirely out of scale with the surrounding environment. There are no buildings of comparable height or bulk in this area. The increased height will result in significant overshadowing, loss of privacy for neighbouring properties, and a drastic change to the visual landscape that currently defines our coastal community.

2. Parking and Traffic Congestion

The proposal fails to provide adequate parking for both residents and staff. Parking in this area is already limited, particularly given the proximity to the beach and local restaurants, where demand is consistently high. The lack of sufficient on-site parking will inevitably push vehicles into surrounding residential streets, creating traffic congestion, safety risks, and obstructing accessibility for residents, visitors, and emergency services.

3. Infrastructure and Environmental Unsustainability

This development places an unsustainable strain on local infrastructure and amenities. The surrounding roads are narrow and not designed to accommodate the additional traffic volume associated with a facility of this size. Furthermore, the construction and long-term operation of a six-storey complex in a low-rise, coastal area raise serious questions about environmental sustainability and the capacity of existing utilities and services to cope.

4. Neighbourhood Character and Community Impact

The proposed building is incompatible with the established character of Narrabeen, where buildings are predominantly one to three storeys. This large-scale project threatens the visual harmony, privacy, and tranquillity that residents and visitors value. The community as a whole is outraged by the scale and nature of this proposal, which disregards the area’s existing planning context and coastal village identity.

In Summary

This proposal represents an incompatible, unsustainable, and inaccessible development that will negatively impact both residents and visitors. It undermines the existing character of our neighbourhood and will contribute to further traffic, parking, and environmental issues in an already pressured area.

I respectfully urge Council and state Government to refuse this application in its current form and to seek a more appropriate, community-focused design that complements the existing built environment.

Yours sincerely,
Alison
Kate Meaney
Object
CROMER , New South Wales
Message
Kate Meaney
5/11/25
To: The Secretary DPHI, Indigo By Moran - 156 Ocean Street Narrabeen
________________________________________
I am a long-term resident of the Northern Beaches Council area and I am writing to formally object to the proposed state-led project Indigo By Moran - 156 Ocean Street Narrabeen. As a resident who values our local environment, community character, and sustainable development, I am deeply concerned that this proposal is inconsistent with established planning principles and will have long-term negative impacts on both the local community and the surrounding natural environment.
________________________________________
1. Unsuitability
The proposed development is inconsistent with the Northern Beaches Local Environmental Plan (LEP) 2011 and the NSW Planning Policy framework, which emphasise that development should be compatible with the existing character, scale, and amenity of the surrounding residential area.
Narrabeen is primarily a low- to medium-density residential suburb, and inserting a large-scale, high-density luxury apartment complex will significantly disrupt the existing built form and visual landscape. The Environmental Planning and Assessment Act 1979 (EP&A Act) requires that development demonstrate ecological sustainability and social cohesion. The scale and bulk of this project are inconsistent with those principles.
The State Environmental Planning Policy (Housing) 2021 (SEPP (Housing) encourages diverse and affordable housing outcomes, not concentrated luxury developments that provide little to no community benefit. This proposal appears to cater to a high-income demographic and fails to address the pressing need for affordable or key-worker housing in the Northern Beaches region.
________________________________________
2. Parking Issues
Parking and traffic management in Narrabeen are already under strain, with Pittwater Road and Ocean Street experiencing congestion during peak hours. The Northern Beaches Transport Strategy highlights that sustainable development must not exacerbate traffic congestion or reduce local accessibility.
This project will increase on-street parking pressure, impede emergency vehicle access, and reduce pedestrian safety.
________________________________________
3. Wildlife Concern
Narrabeen and its surrounding ecosystems form part of a coastal wildlife corridor that supports a range of native species, including birds, reptiles, and small mammals. The proposed site lies within proximity to sensitive ecosystems such as Narrabeen Lagoon Catchment and associated vegetation communities protected under the Biodiversity Conservation Act 2016 (NSW).
Clearing or fragmentation of habitat for large-scale construction will disrupt local fauna movement and breeding areas. Increased lighting, noise, and human activity from a high-density complex will also have ongoing ecological impacts.
________________________________________
This proposed development is fundamentally unsuitable for its location. It conflicts with the intent of local planning instruments, fails to respond to the established character and infrastructure capacity of Narrabeen, and poses unacceptable risks to the local environment and wildlife.
I urge the Department to reject this proposal to ensure that any future development aligns with sustainable planning principles, the needs of the community, and the preservation of Narrabeen’s unique coastal character.
Georgina Brady
Object
Narrabeen , New South Wales
Message
Indigo by Moran is against the wishes of the community. The facilities and infrastructure on Ocean Street are not sufficient enough to provide for such a development. The already scarce parking on Ocen Street will be stretched further and will be worsened more so in the summer months. The development and increased traffic poses risks to residents and to the childcare centre on Lagoon street. The proposal jeopardises our already fragile local environment through the removal of trees and the site of Aboriginal Man, a site of Indigenous historical significance, will also be jeopardised. I am not opposed to the building of aged care facilities, however community input and voice should be at the forefront of planning in this way.
Peter Edgley
Support
Narrabeen , New South Wales
Message
My wife and I attended a talk and have received documentation on the propose 'Indigo by Moran" project here in Narrabeen.
We support the project and have no objection to the development. It has been well thought out and will not be an eyesore to the area; in fact, it will be an improvement based on the surrounding buildings and in particular the building on the existing site. It will have four levels of accommodation, two levels of parking and a roof top area of recreational facilities. Buildings of this type - providing accommodation the those over 60 years of age - tend to be far and few apart on the Northern Beaches. If the project goes ahead in its current design, we will be looking to acquire an apartment.
Regards, Peter & Louise Edgley
Catherine Bennett
Object
Sydney , New South Wales
Message
While I understand and support the need for more Seniors' Housing in the area, I object to the height of this building. It is not in keeping with the area and blocks views and light for the surrounding residences. I would support a scaled down version of this project with a lower profile.
Denise Jeffery
Object
Narrabeen , New South Wales
Message
1. This proposed development by Moran exceeds the height and bulk envisioned for this sensitive coastal setting, I currently live in apartment which has a limit of only 3 stories high. This five-storey massing is inconsistent with surrounding residential development, creating a sense of enclosure and loss of sky for nearby residents and public domain users.
2. The traffic and parking assessment (EIS Appendix J) underestimates vehicle movements and parking demands generated by residents, staff, service vehicles and visitors. Ocean Street and Lagoon streets are narrow local roads already under pressure, particularly during weekends and surf club events. The addition of a high turnover seniors housing complex will exacerbate congestion, reduce safety for pedestrians and cyclists and impede emergency access routes.
I therefore strongly object to this development at 156 Ocean Street Narrabeen for the above reasons
Name Withheld
Object
Narrabeen , New South Wales
Message
To all in charge of the proposed development Indigo - by Moran, 156 Ocean Street Narrabeen.

My unit is at 91 Lagoon Street, literally a few doors north of the proposed development, thankfully not next door to, adjacent to or opposite the development site. I have been living on Lagoon Street Narrabeen for just over 22 years now and love the local area, just as it is. Narrabeen is one of the few remaining beachfront areas that hasn't been devastated by highrise developments and should remain as such.

There are many reasons why I believe this development should not go ahead in its current design:
* Incompatibility with the local area - we currently have nothing above three levels - this would be an absolute eyesore, block sunshine, create wind tunnels, it just does not fit with the local environment.

* Increased traffic - over the last two years there have been many strategies explored by local government to reduce the traffic and minimise the flow of cars throughout this area of Narrabeen. A development of this scale will only add to the congestion and traffic flow. Squashing so many new residents in to these small streets will create incredible congestion!

* Lack of parking - parking is already an issue in this peninsula of Narrabeen, particularly through summer or whenever nippers or any surfing competitions are on. Parking is at a premium already, please don't reduce it for current residents even further! In terms of the proposed development plans - a measly 10 visitor parking spots is simply not enough!

* Safety - I chose to invest in the peninsula Narrabeen area to bring my young son up in an area away from highrise buildings and congestion, yet this development will be creating the complete opposite of that for our local area. The increased service vehicle traffic, let alone the increasing residential population of such an enormous development will create unsafe conditions for my son walking to and from school, to and from the local beach and lake. He will have to pass this development site and it's unsafe conditions to even walk to the local supermarket. There are so many young children living in this peninsula that will be directly impacted by being unable to walk safely on the street paths, particularly throughout the build time!

These are just the issues that directly relate to my family if this development were to go ahead. I am lucky not to be adjacent or directly opposite the site as the drawings do not accurately show the sun and shadow that will be created.

As for the poor residents at 83 Lagoon Street, being completely boxed in by the development, I am completely appalled! That poor family will be completely overshadowed and surrounded by a monstrosity over double the height of their two storey house, with setbacks that would devastate their privacy in their family home. Let alone imagining how this development will decimate their price value if they ever were to try and sell their property - the developers should truly be ashamed of themselves, so ridiculously money hungry. Let's be honest, this development is not for the benefit of our local community, it is for the development company to make money at the expense of our local residents.

PLEASE DO NOT ALLOW THIS DEVELOPMENT TO PROCEED IN ITS CURRENT DESIGN!
Name Withheld
Object
NARRABEEN , New South Wales
Message
I wish to formally object to the proposed development due to the size and scale, it's too large and too high and is in stark contrast to the exisiting buildings around it.

I am opposed to the acquisition and demolition of the existing houses for this project as they can provide homes for people in the area.

There is already a problem with parking in the area and making the development to this scale will affect the parking and traffic in the area.

For these reasons, I respectfully request that the Council refuse this application in its current form.
Name Withheld
Object
Narrabeen , New South Wales
Message
My submission

To whom it may concern,

Thank you for the opportunity of submitting my concerns with the proposed multi
residential unit development on the corners of Lagoon, Octavia and Waterloo Streets
Narrabeen .SSD-76220734

I am the owner of the following properties:-
Unit 7/ 53 -53 Lagoon Street Narrabeen, Unit 17/ 53 -53 Lagoon Street Narrabeen and
Unit 9/11-21 Waterloo Street Narrabeen.

I invested in these properties in the 1990's and early 2000's on the understanding
that local Development Control plan restricted any future development to a maximum of
two storeys.
Now retired, I have been involved in the Architectural, building and development
industry for 50 years.
My experience is that Warringah and Northern Beaches councils have been
steadfast in maintaining the 8.5 m height limit in these residential zonings, and to
relax this requirement now will be highly detrimental to the peninsula.

Granted that I cannot object to the development in regard to loss of privacy, views,
sunlight etc... I am still very concerned with the increased traffic that will be generated.

I have personally witnessed a motor vehicle accident outside St Joseph's Catholic
and primary school in Lagoon Street in 2005 and am constantly warning friends and
family to be highly aware of speeding vehicles on the intersection of Waterloo and Ocean Street
whilst on foot to the beach.

The traffic report provided does indicate an accident history but only for the past 5 years
and only between Octavia and Tourmaline Streets.

As local residents, we can assure the report writers that there are many near misses
and unrecorded incidents always.

Concerns should also be raised that proposed CONSTRUCTION TRUCK ROUTES will be going past
St Joseph's Primary school to access Waterloo Street and Pittwater Road intersection.

The school zone should be avoided and alternative routes established, preferably northwards.

The traffic report advises that no site construction worker parking will be provided during
the initial stages of the works. Parking spaces in Lagoon and Ocean Streets are at a premium
and the local residents are entitled to a more accurate carparking plan for this period.


regards,

Nick Murdocca
9/11-21 Waterloo St,
Narrabeen.
Claudia Minogue
Object
Narrabeen , New South Wales
Message
I am writing to formally object to the proposed six-storey developement proposed for 156 Ocean Street, Narrabeen.

While I appreciate the need for thoughtful growth and development, this proposal is incompatible with the established character, scale, and amenity of our neighbourhood. The key grounds for objection are outlined below:
1. Excessive Height and Visual Impact
The proposed six-storey structure significantly exceeds the prevailing building height in the area, which is predominantly one to three storey / low-rise residential. Such a tall building would dominate the streetscape, overshadow nearby homes, and erode the human scale that defines our community’s character.
2. Overshadowing and Privacy Impacts
The development will create substantial shadowing over adjoining properties, reducing sunlight to private open spaces and gardens. The height and proximity will also lead to direct overlooking of neighbouring yards and living areas, resulting in a clear loss of privacy.
3. Traffic and Parking Concerns
A building of this size will introduce a sharp increase in local traffic and on-street parking demand. Existing streets are narrow and already congested, particularly during peak periods. The proposal’s parking allocation is inadequate and will worsen safety and access for residents.
4. Strain on Local Infrastructure
Essential services such as drainage, waste collection, and local amenities (schools, parks, and public transport) are already under pressure. Adding a high-density development will compound this strain and reduce overall livability in the area.
5. Approval of this project would set a concerning precedent for future over-development.
6. Environmental and Green Space Impacts
The loss of mature trees and reduction of open green space will negatively affect local biodiversity, increase heat retention, and detract from the area’s leafy character.
For the reasons above, I respectfully request that Council/Governments refuse the current proposal or require substantial amendments to bring it into alignment with the scale, amenity, and character of the neighbourhood.

I trust that Council/Governments will uphold the principles of sustainable, community-focused planning that protect the qualities residents value most about Narrabeen.
Northern Beaches Council
Object
DEE WHY , New South Wales
Message
Attachments
Joe Malvisto
Object
NARRABEEN , New South Wales
Message
I refer to the proposed Indigo by Moran development at 156 Ocean Street, Narrabeen, currently under consideration by the State Government.

With the proposed development, there must be clear evidence provided addressing the impact of additional vehicle numbers on the surrounding road network and parking capacity. Specifically, the submission should include:

The projected number of additional vehicles expected to be generated by the development;

A detailed parking analysis demonstrating where these vehicles will be accommodated; and

Confirmation that the proposed parking arrangements are fully compliant with all relevant Australian Standards, including but not limited to AS2890.1.

It is important that the applicant’s submission quantifies the number of vehicles associated with each dwelling or allotment, and clearly shows that sufficient off-street parking has been provided to prevent overflow into surrounding streets.

At present, Octavia Street and Lagoon Street are already heavily congested, with vehicles parked on both sides of the roadway. This results in sections where only a single vehicle can pass through at any given time, creating daily traffic and safety challenges. The development submission must demonstrate through engineering assessment how these impacts will be mitigated and what specific design measures will prevent further congestion.

We request that this parking and traffic assessment be prepared by an independent engineering consultant, not directly engaged by the developer, to ensure the findings are objective and impartial.

Additionally, we note community concerns that the subject site may have cultural heritage significance, including potential Aboriginal artefacts historically present in the area. The applicant should provide evidence of cultural heritage investigations undertaken and outline what provisions or mitigation measures are proposed to protect or acknowledge such heritage values.

Given the existing parking limitations and heritage sensitivities, it is critical that these matters are fully addressed in the DA documentation before approval is considered.
Attachments
Name Withheld
Object
NARRABEEN , New South Wales
Message
PROPOSAL: Construction of a new 5-storey seniors housing development (149 ILUs and 10 RCF rooms)

I object to SSDA SSD-76220734 for the proposed seniors housing development at Narrabeen on the grounds that the excessive scale, bulk, and complexity of the environmental risks are unacceptable, failing to mitigate adverse impacts on the locality and its residents, as demonstrated by the project’s own Environmental Impact Statement (EIS).

1. Gross Non-Compliance with Height Standard and Adverse Impact on Local Character
The proposed development fails to respond appropriately to the low-to-medium density residential character of the area, resulting in unacceptable bulk and scale.
• Excessive Height Breach: The maximum permissible building height is 12.3m, derived from the Warringah Local Environmental Plan 2011 (WLEP 2011) base height of 8.5m plus the 3.8m bonus permitted under Clause 87 of the Housing SEPP. The proposal seeks approval for a building height of 21.1m. This constitutes a variation of 8.8m or 71.5%. This monumental departure from the planning control is unreasonable and unnecessary, particularly given that the surrounding residential context is primarily characterized by single and two-storey dwelling houses, with maximum building heights generally limited to three or four storeys along Ocean Street. The significant height increase cannot be visually integrated into the existing character, undermining the principles of good design cited in the EIS.
• Insufficient Justification for Bulk: While the EIS claims the bulk is necessary for amenity and landscape integration (courtyard and pine tree retention), the ensuing 5-storey form (with 3 basements) results in a Gross Floor Area (GFA) of 22,131m², substantially intensifying the residential use beyond what the locality can reasonably absorb without adverse impacts.

2. Unacceptable Environmental and Geotechnical Risk
The sheer scale of excavation required for this project introduces unacceptable risks related to ground stability, water management, and contamination.
• Deep Excavation and Groundwater Risk: The proposal requires bulk excavation to a depth of 10.9m below natural ground level to accommodate the three basement levels. The Geotechnical Investigation confirms that this excavation will intercept permanent groundwater within the marine sand profile, requiring dewatering. Furthermore, the site is located within a Class 4 acid sulfate risk zone. Excavation and dewatering on this scale carry a high risk of adverse impacts, including structural distress to neighbouring structures, soil erosion, and potential settlement of foundations if not perfectly managed.
• Contamination and Remediation: The Detailed Site Investigation (DSI) confirmed the presence of Asbestos Containing Material (PACM), asbestos-impacted fill, and lead-impacted soil on site. While a Remedial Action Plan (RAP) is prepared, the EIS confirms that additional work is needed following demolition to address "data gaps" and better delineate the contamination. This suggests the full extent of the complex remediation required, coupled with the deep excavation and dewatering in a Class 4 acid sulfate zone, is not fully confirmed pre-approval, elevating the risk to workers, the surrounding community, and the natural environment (South Creek / Narrabeen Lagoon).

3. Failure to Protect Aboriginal Cultural Heritage
The proposed 10.9m deep excavation poses a direct and significant threat to registered Aboriginal heritage in the immediate vicinity.
• Proximity to Burial Site: The site is located approximately 30m north of the registered AHIMS site 45-6-2747, a 4,000-year-old Aboriginal burial site.
• Risk from Excavation: The Aboriginal Cultural Heritage Assessment Report (ACHAR) explicitly identifies that the excavation of the proposed basement could have a significant impact on potential Aboriginal archaeological resources. While mitigation measures are proposed (such as further archaeological excavation and approval), the risk of serious and irreversible harm to significant heritage, compounded by the proximity and the extreme depth of the required works, weighs heavily against the suitability of the proposal in its current form.

4. Poor Internal Amenity for Vulnerable Residents
The design demonstrates a measurable failure to provide basic solar amenity to a significant portion of the seniors housing units.
• No Solar Access for 22 Units: Despite the stated compliance with the Apartment Design Guide (ADG) overall, the EIS confirms that 22 Independent Living Units (ILUs)—15% of the total proposed units—will receive no direct sunlight between the hours of 9 am and 3 pm during the winter solstice. For seniors living, a vulnerable demographic whose health and wellbeing is significantly supported by access to sunlight and heat, approving units with zero solar access represents a deficiency in environmental amenity that must be rejected.

5. Adverse Impacts on Local Infrastructure and Environment
The cumulative construction and operational impacts are inadequately mitigated and impose unreasonable burdens on the public domain.
• Traffic Generation and Public Transport Disruption: The development is anticipated to generate 25 vehicle trips per hour (vtph) during the PM peak period, which the Traffic Impact Assessment (TIA) notes is higher than the average for Seniors Housing. To accommodate the development's operational needs and improve safety, the proposal requires the relocation of the bus stop at the corner of Ocean Street and Octavia Street. This significant intervention demonstrates that the development's intensity immediately strains existing public transport infrastructure and requires the alteration of the public domain simply to enable the development to function.
• Mass Tree Removal: The emphasis on landscape design is contradictory to the requirement for the removal of 69 trees (including 24 considered significant) to facilitate the project. This massive loss of vegetation diminishes the ecological value of the site and conflicts with the objective to enhance urban tree canopy.

Request for Refusal:
Based on the cumulative and individual severity of the issues identified—specifically the massive height transgression of 71.5%, the unacceptable geotechnical/contamination risks associated with the 10.9m deep excavation in an acid sulfate zone, the proximity risk to the 4,000-year-old burial site, and the poor internal amenity for 15% of the future senior residents—the proposed development is not in the public interest.
I respectfully request that the application SSD-76220734 be refused.
Name Withheld
Object
FRENCHS FOREST , New South Wales
Message
Narrabeen Ocean St is on a spit of sand - digging deep foundations will destabilise the fragile sand mass further and lead to major erosion impacting other residents.
Plus high rise complexes are unsightly and not in keeping with the area.
Deb Richardson Bull
Object
Narrabeen , New South Wales
Message
This development is too big for the location proposed.
6 floors is too many and it will overshadow the surrounding area
The location is basically a sand spit at high risk of coastal erosion, overpopulation of this area is not advisable.
This project is described as providing affordable housing - but not for those that need it. It is young families that need affordable housing on the northern beaches not wealthy retirees.
This design creates no public open space for the community - the green space is in the centre of the site and the rest of the community sees no benefit just high storeys and increased traffic flow.
7 visitor spaces is not enough- if people are in the later stages of their lives they will likely receive regular visits- where are these visitors going to park?
The increase in residential units created by this development will cause increased congestion, not withstanding that the older generation don’t understand roundabouts and there are about 6 to navigate along ocean street plus two school zones.
Martin Kelly
Object
NARRABEEN , New South Wales
Message
I support the construction of more (affordable) retirement living on the Northern Beaches but strongly object to the scale and height of the development 'Indigo by Moran' at 156 Ocean Street, Narrabeen.

As proposed at 5-6 levels and 21m high it's far taller than any other development on the Narrabeen Peninsula and would set a dangerous precedent. Most apartments here are 2 to 3-storeys.

I have attached an image of the nearby Salt development in Lagoon Street, Narrabeen, as an example. It's a quality development, two levels high with breaks in the facade, completed three or four years ago.

Re Indigo, it appears the developers are testing boundaries by trying to get their plans through as if Narrabeen was a designated town centre under the TOD scheme.

But the fact is the State Govt recently decided Narrabeen would not become a TOD town centre after due consideration.

On this basis alone, the DA as it stands should be rejected because it undermines this recent ruling by the State Govt, which legally prevents developments of this height and scale on the Narrabeen Peninsula.

A related issue is massing. The development as proposed occupies the whole block with an unbroken 5 to 6-storey wall of apartments fronting each of the four streets, dominating the local streetscape, overshadowing neighbours and impacting their privacy.

There is no line of sight through the development, it's a solid mass designed to maximise the apartment yield rather than considering the local street and aesthetics.

Based on the site history, location in the heart of Narrabeen and the risk of setting a legal precedent that will change the area forever, I believe 3-4 storeys, with the fourth-storey recessed as it is in the current design, is the most equitable outcome for all concerned.
Attachments
Silvia Windsor
Object
NARRABEEN , New South Wales
Message
I am a resident who lives very close by this proposed development. I am opposed to the development in its current format for the following reasons:

The current premises is an age care facility but the new premises has very few age care beds. It appears to be a high end residential development with a quasi aged care element thereby not meeting the needs of aged care recipients thereby not meeting the urgent national need for aged care facilities and beds. Actually this change will add to the problem!

The property is massive and is incompatible with any other surrounding property on the street in the vicinity. This will change the amenity and add significant strain to parking on and already stretched Street.

Our house floods every time there is significant rainfall due to run-off from the street as there is completely insufficient stormwater drainage. This new structure will add even further pressure to flooding on the street due to its size and surface area during significant rainfall.

We have not been consulted with at all from the developer which is unsatisfactory given our very close proximity.

If this building is granted an approval a precedent will have been set which will ultimately change the face of Ocean Street Narrabeen forever with future large scale developments being sought.

This large development will cast significant shadowing, loss of privacy and importantly loss of sunlight and views for many of the surrounding houses which is an unfair and unacceptable loss given the cost of property in this area. Such a loss is bound to impact property values.

Given the depth of this new development, what are the guarantees of protection of the water table and any possible erosion impacts given we are all built on sand on this street?

Are there any significant impacts to wildlife or fauna or resident’s Gardens on the street caused by shadowing and removal of habitat when currently large trees are removed?

This development poses many substantial impacts to existing residents on Ocean and Lagoon st and A much more improved and negotiated outcome has to be discussed thoroughly with our community and impacts all heard and thoroughly considered and addressed.

Silvia Windsor
Sue Freshwater
Object
NARRABEEN , New South Wales
Message
5th November 2025
The Secretary,
DPHI
RE: Objection to SSD-76220734 – 156 Ocean Street Narrabeen 2101

Dear Sir/Madam,
We are long time residents of Narrabeen and use Ocean Street and the adjacent streets daily both for driving and morning walks. Our grandchildren are members of North Narrabeen Surf Club and are frequent users of Ocean Street to access their weekend sport at the beach. We believe the increased traffic, both residential and service vehicles will create unsafe conditions for both adults and children in the local area and for those who travel to Narrabeen to visit our beautiful beach.
This oversized development is way too big for the local area that already does not have sufficient parking to accommodate the local residents, visiting locals and tourist visiting the famous beach at North Narrabeen.
Regards
Sue and Barry Freshwater
M 0412 909 131
303/20 Wellington Street
Narrabeen NSW 2101

Pagination

Project Details

Application Number
SSD-76220734
Assessment Type
State Significant Development
Development Type
Seniors Housing
Local Government Areas
Northern Beaches

Contact Planner

Name
Najeeb Kobeissi