Proposed Development at 156 Ocean Street Narrabeen

I object to the scale of the proposal and its impact on the surrounding environment.
It is grossly out of proportion compared with the local community.
It substantially exceeds the LEP height restrictions by over 70%, as stated in the Clause 46 Variation Request.
The various supporting reports gloss over or minimize the many impacts of the proposal.

Submission to vary Clause 46.
• Contains generalized statements and legal references that do not justify height variation
• Whilst the need for additional aged care on the northern beaches is justified, this can be achieved in other ways other than increasing height. Other sites need to be considered.
• The suggestion that the height restriction is unreasonable and unnecessary has not been supported in the request
• The statement “variation allows for the orderly and economic use of the land in a manner which is appropriate considering the site’s context and is such justified” is not supported. It confirms that the variation is requested to increase the financial benefits to the developer
• The alternative complying design suggested clearly shows limited architectural input leading to a very bland design…intentional??
• Good aspects of the proposal can be incorporated can incorporated into a complying design
• Existing large Norfolk Island pines identified by First Nations and local residents, are presented as mitigation for increased height….this is not a valid argument
• Supporting documents report no impact over a range of elements related to increased height….this clearly inaccurate
• “Proposal delivers appropriate context” is meaningless

Traffic Impact
• All construction traffic to be diverted into Lagoon St via narrow connecting roads is not appropriate. These roads will need to be rebuilt and funded by Northern Beaches Council(NBC)
• Does recently adopted NBC Local Traffic Management Plan consider impacts of this development
• Currently parking on Lagoon and surrounding streets is a premium. This development with exacerbate the situation. Providing only 3 staff parking bays reinforces this
• Green Travel Plan is full of generalised and aspirational statements not connected to current reality.
• The statement that the proposed development “will not present any adverse traffic implications” is so divorced from the real world that it puts the credibility of the whole report at risk

Stamped Drawings
• Cover Sheet photos confirm the substantial visual impact of the over sized development
• Context drawings clearly show the dominance of the proposal over adjacent residents and the adjacent environment
• The retention of a few Norfolk Island pines will not hide the intimidation of the proposed building

Visual Impact Assessment
• It is inaccurate for the Executive Summary to suggest that the proposal will not have significant visual impact. This is not supported in the report
• Photomontage generally gives a deceptive impression of the visual impact, for example View 02 indicates a much lower height dominance compared to View 03
• View 04 probably gives a more realistic visual impact although camera angle and location could still be deemed deceptive
• The suggestion that driving passed will have only a brief impact overlooks the impact will have on the amenity of the walkers and cyclists
• The statement that the proposal is generally consistent with surrounding buildings is grossly inaccurate

The project is not in keeping with equity of visual access by other properties. This is because of the excessive height being 5or6 storeys. There are no other such properties in the location. The shading of neighbouring properties will reduce their equity of living in their properties with overlooking destroying their privacy.
Further the excessive number of residents will lead to gridlock around this area. Staff contractors suppliers etc..
This excessive sized development will destroy the local community beach feel of Narrabeen and will open the development process for further excessive developments thus destroying the local community.

N/a

The proposed 6 storey strucure is totally unsuitable for the area - it is a local, residential area and there are no other 6 storey buildings around that area. It is ludicrous that a building this size is even thought of for this area.
The original facility was for aged care and when it was sold, it was supposed to be for another aged care facility. This planned structure only has capacity for 10 beds. It is NOT a similar facility offering aged care.
The proposed plans show insufficient parking for residents / staff. Increased number of cars will also add to congestion in the area and cause added parking concerns in the surrounding streets. The building will impact shade on neighbours, views will disappear, the value of surrounding houses will drop and it will heavily impact the already stretched street, electricity and sewer infrastructure.
There has been insufficient community consultation - people living in the area want a say.

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.

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.

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