Submission: Objection to SSD-76220734 – Indigo by Moran, 156 Ocean Street Narrabeen
To: The Secretary, NSW Department of Planning, Housing and Infrastructure (DPHI)
From: Jade Geros – Resident, 1 Loftus Street, Narrabeen NSW 2101
Date: 2 October 2025
Project: SSD-76220734 – Seniors Housing (Indigo by Moran)
Site: 156–164 Ocean St / 81–81A Lagoon St / 8 Octavia St, Narrabeen

1. Introduction & Local Context
I am a lifelong resident of Narrabeen and currently reside at 1 Loftus Street, immediately adjacent to the proposed site. Having lived in the area my entire life, I have an intimate understanding of its coastal character, flood vulnerabilities, and the lifestyle balance our community values. I strongly oppose the proposed 'Indigo by Moran' development due to its incompatibility with the established planning framework, excessive scale, and potential to cause lasting environmental, amenity, and infrastructure impacts.
2. Statutory Framework
The proposal is declared State Significant Development (SSD) under Section 4.36 of the Environmental Planning and Assessment Act 1979 (EP&A Act). Accordingly, assessment must be undertaken in accordance with Section 4.15 of the EP&A Act, having regard to: (a) relevant environmental planning instruments, (b) the likely environmental and social impacts of the development, (c) the suitability of the site, and (d) the public interest. Despite its SSD classification, the proposal must still demonstrate compliance with these statutory principles.
3. Inconsistencies with Key Planning Instruments
a) State Environmental Planning Policy (Housing) 2021 – Seniors housing must be designed for context and amenity. This development fails to achieve those standards, with excessive building height and inadequate transition to surrounding low-density residential dwellings.

b) State Environmental Planning Policy (Coastal Management) 2018 – The site lies within the mapped Coastal Environment and Coastal Vulnerability Areas. The proposed 11.5 m basement excavation into the water table conflicts with the SEPP’s precautionary approach to managing coastal hazards and flooding risk.

c) Northern Beaches Local Environmental Plan (LEP) 2011 – The proposal breaches the height and FSR objectives under Clauses 4.3 and 4.4 and is inconsistent with the R2 Low Density Residential zone intent to preserve low-rise character along the Narrabeen peninsula.

d) Northern Beaches Development Control Plan (DCP) – The design fails to comply with DCP objectives requiring protection of neighbouring amenity, solar access, privacy, and landscape character.
4. Deficiencies in the Exhibited Environmental Impact Statement (EIS)
A. Overshadowing & Solar Access – The exhibited shadow diagrams show significant off-site overshadowing between 9 am and 3 pm during mid-winter. This results in a measurable loss of sunlight to adjoining private open spaces, inconsistent with the DCP’s solar access objectives.

B. Visual Privacy & Building Separation – Upper-level apartments and terraces overlook nearby backyards and dwellings. Separation distances fail to achieve the Apartment Design Guide (ADG) benchmarks for 5–6 storey buildings (12–18 m minimum between habitable rooms and balconies).

C. Bulk, Scale & Character – At 21.5 m, the proposal exceeds the scale envisaged by the LEP. It introduces a monolithic, continuous façade that overpowers surrounding single and two-storey coastal dwellings, altering the visual identity of the area.

D. Traffic, Access & Servicing – The EIS underestimates daily vehicle movements from residents, staff, and service deliveries. Ocean, Lagoon, and Loftus Streets are narrow and ill-equipped to handle additional congestion, compromising pedestrian and cyclist safety.

E. Groundwater, Flooding & Coastal Hazard – The Flood and Coastal Hazard Reports confirm high groundwater vulnerability. However, the EIS lacks a comprehensive mitigation strategy to address dewatering, saline intrusion, and potential subsidence risks during excavation.

F. Tree Canopy & Biodiversity – The Arboricultural Impact Assessment identifies the removal of over 30 mature trees. Replacement planting on rooftops or within planters will not provide equivalent shading, habitat, or stormwater management benefits. The DCP’s Urban Tree Canopy targets are therefore not met.

G. Construction Amenity – Prolonged excavation and construction works will generate unacceptable noise, vibration, dust, and truck movements in a quiet residential area, significantly impacting neighbouring residents for an extended duration.
5. Public Interest (EP&A Act s 4.15(1)(e))
The proposal offers no tangible public benefit or affordable housing contribution. Instead, it delivers a private, high-end development that imposes long-term environmental and amenity costs on the Narrabeen community. The development does not align with State planning objectives for sustainable, resilient, and context-appropriate growth.
6. Requested Determination
I respectfully request that the Department of Planning, Housing and Infrastructure:

1. Refuse SSD-76220734 on the basis of non-compliance with the EP&A Act 1979, Housing SEPP 2021, Coastal SEPP 2018, and the Northern Beaches LEP/DCP; or
2. Require a major redesign that includes:
• Reduction in height, bulk, and FSR;
• Setbacks meeting ADG visual privacy and solar access requirements;
• Deep-soil zones and retention of mature trees;
• Verified groundwater and coastal hazard mitigation strategies; and
• Comprehensive traffic, parking, and construction management plans.
7. Conclusion
As a lifelong Narrabeen resident, I urge the Department to uphold the intent of NSW planning policy and protect the character, safety, and amenity of the Narrabeen peninsula. This proposal is inconsistent with both the letter and spirit of the planning framework that governs coastal protection, urban character, and community well-being.

Signed,
Jade Geros
Resident – 1 Loftus Street, Narrabeen NSW 2101

I wish to formally object to the proposed six-storey over-60s residential development in Narrabeen for the following reasons:

1. Incompatible Building Height and Character
The proposed six-storey luxury complex is entirely inconsistent with Narrabeen’s established low-rise character. Its bulk and scale disregard the area’s environmental setting, existing streetscape, and community values. The development would dominate the local skyline and set an undesirable precedent for future high-density projects in an area not designed for such intensity.

2. Insufficient Resident Parking
The proposed 178 resident parking spaces are significantly inadequate. Based on the mix of apartments—46 three-bedroom, 59 two-bedroom with study, and 44 two-bedroom units—the realistic parking demand would exceed 240 spaces.
• 46 × 2 cars = 92 spaces
• 59 × (90% with 2 cars + 10% with 1 car) = approximately 112 spaces
• 44 × 2 cars (50%) = 44 spaces
This results in an estimated shortfall of around 70 spaces. Residents will inevitably use surrounding streets, where parking is already extremely limited, worsening congestion and safety issues.

3. Inadequate Parking for Aged Care Staff
Only three parking spaces are proposed for the 10-bed care facility staff. This is unrealistic, especially at shift change times when multiple staff members will be on-site. These vehicles will likely spill into residential streets, further straining the already overburdened parking supply.

4. Lack of Parking for Support and Maintenance Staff
The development fails to account for the parking needs of administrative, programming, maintenance, and trades staff who will service the complex regularly. With no allocated spaces, these vehicles will also rely on scarce street parking.

5. Reduced Aged Care Capacity
The proposal significantly reduces the site’s contribution to aged care, replacing the existing 55-bed facility and 35 assisted living units with only 10 care beds. This reduction removes vital local aged care options and increases demand for similar facilities elsewhere on the Northern Beaches.

6. Misuse of Seniors Housing Provisions
The proposal appears to exploit the over-60s housing planning provisions to gain approval for a large luxury development that would not otherwise comply with local planning controls. The State Government has designated Brookvale, Dee Why, Mona Vale, Manly Vale, and Forestville as suitable areas for higher-density housing. Narrabeen is not one of these zones and lacks the infrastructure to support this scale of development.

7. Unacceptable Precedent for Future Development
Approving this project risks setting a precedent that invites similar developments to bypass planning controls by labelling high-end apartments as “seniors living.” This would undermine local planning integrity and community expectations.

8. Lack of Genuine Community Consultation
The developer has not engaged in meaningful consultation with local residents. Community questions have been avoided, and feedback has not been transparently addressed. This lack of collaboration demonstrates disregard for local concerns and undermines community trust.

9. No Affordable or Community Housing
The development provides no affordable or accessible housing options. It caters exclusively to a luxury market, offering no benefit to local residents or key workers who are already priced out of the area.

10. Environmental and Water Table Concerns
The inclusion of a three-level underground car park raises serious concerns about impacts on the local water table, potential flooding risks, and damage to nearby properties. Given Narrabeen’s low-lying coastal environment, these issues warrant thorough investigation before any consideration of approval.

⸻

This proposal is inappropriate in height, scale, and intensity for Narrabeen. It will worsen parking and traffic pressures, reduce aged care availability, and erode the character of the local community. The lack of affordable housing, inadequate consultation, and potential environmental impacts further highlight that this development does not serve the public interest.

I therefore respectfully request that NSW Government refuse the development application in its current form.

1. I strongly oppose the proposed development . North Narrabeen is rapidly becoming an increasing flood risk zone with past development decisions in the area being regretted because of their potential flood and wave action erosion.
2. The density that will occur with so many residences in such a small footprint will increase unbearably the pressure on the already narrow and restricted surrounding street network. These streets are barely coping with present local traffic and are under increasing pressure during weekends and holiday periods where non resident traffic and parking are at their peak.
3. The removal of established tree and canopy cover goes against all common sense in a rapidly increasing heated environment.
4. Some already local highly overdeveloped suburbs have been for years showing the signs of deterioration and become 'dead suburbs' . Far removed from the present beauty of the area that assists in local and visiting mental health.
5. The height is far in excess of existing local planning laws and will set a precedent that greedy developers will use to promote further highrise for their personal gain.
6. The height will undoubtedly create completely unreasonable shading footprints on surrounding residences and again creating a precedence that won't be able to be contain.
I cannot object strongly enough to the enormity of this ugly proposal.

I wish to object to the proposal on the grounds of height - six storeys is out of scale and character with Narrabeen. It will set a precedent to build more highrise along the coast and elsewhere in Narrabeen, and increase traffic congestion. Narrabeen is already in a flood-risk zone and not a good area to encourage increased density.
I urge NSW Planning to reject this proposed development.

The developers did not seem to consult the local residents. The height and size of the development does not suit and is not in keeping with the rest of the area.

North Narrabeen is not Dee Why, we do NOT want highrises here
This should never have been given approval in the first place

Submission to the NSW State Planning Authority – Objection to Proposed Development in Narrabeen
I am a local resident living at 5/81 Ocean Street, Narrabeen, and I am writing to object to the proposed development currently under consideration in Narrabeen.
My concerns are based on three key issues: traffic impact, excessive height and visual amenity, and parking and congestion.
1. Traffic Impact
Narrabeen is already under significant traffic pressure, particularly along Ocean Street, Pittwater Road and the surrounding feeder streets. Congestion is common during peak hours, school drop-off and pick-up times, and weekends. The proposed development will:
    •    Increase vehicle movements well beyond what the current road network can reasonably support
    •    Add to congestion at nearby intersections that are already operating at or near capacity
    •    Create further safety risks for pedestrians, cyclists, and schoolchildren
There is no realistic evidence that the local road infrastructure can absorb this increase without further degrading traffic flow and community safety.
2. Height and Visual Impact
At six storeys, the development is excessively tall for the Narrabeen area and inconsistent with the existing neighbourhood character. The height would:
    •    Set a damaging precedent for high-rise development in a low-scale coastal suburb
    •    Dominate the streetscape and overshadow nearby properties
    •    Visually obstruct the natural coastal aspect that defines Narrabeen’s character
The proposal fails to respect the coastal village identity of the suburb and would have a negative aesthetic impact on both residents and visitors.
3. Parking and Local Congestion
Parking is already a known issue in the area, particularly during weekends, school holidays, and periods of good beach weather. The development would:
    •    Bring more vehicles than the site can reasonably accommodate
    •    Spill additional parking into already constrained local streets
    •    Increase competition for parking for existing residents and businesses
It is unreasonable to approve a development that will worsen a well-documented parking shortage for the local community.

Request
Given the documented and foreseeable impacts on traffic, amenity, and community infrastructure, I strongly oppose the development in its current form. I request that the State Planning Authority reject this proposal or require substantial changes that address the concerns above, including:
    •    Reducing the height to align with existing local character
    •    Demonstrating a realistic and independently reviewed traffic and parking impact plan
    •    Ensuring any approved development does not worsen congestion, safety, or liveability for current residents

we do not need more traffic through here, we do not need ugly massive buildings in our beautiful local area. let’s keep it the way it is.

Please find attached my formal objection along with a brief summary below.

I strongly object to the proposed SSD for Indigo by Moran on the following grounds:

- Excessive height: The proposed 6-storey building is ~72% above the SEPP height limit and inconsistent with the area’s 2-storey character, obstructing views and harming visual amenity.
- Non-compliant setbacks: The proposal fails to meet SEPP setback requirements, increasing bulk, overshadowing, and privacy impacts.
- Traffic and access issues: The driveway location on Lagoon Street will cause congestion in residential streets; access should be via Ocean Street instead.
- Tree loss and inadequate deep soil: 69 of 82 trees are to be removed (including 13 Category A1 protected trees), severely reducing canopy cover and neighbourhood character - they also recognise significant importance to First Nations people.
- No community consultation: Moran provided no opportunity for public input before submitting this SSD, showing disregard for community engagement.

The development is inconsistent with SEPP controls, out of scale for the location, and detrimental to the amenity of Narrabeen residents. I request the Department refuse the proposal or require a significant amendment.