This project is significantly out of character for Narrabeen Peninsular and the Northern Beaches foreshore.
While I support residential care and seniors housing in the area, the scope and extent of this development is out of character, in particular the height of the building. The visual impact assessment indicates that the development will be visible from a large number of view points which will be detrimental to the area in general. It will be significantly higher than the surrounding buildings and change the character in ways we cannot yet predict.

I object to the development height and scope.

• The proposed development does not comply with Northern Beaches Council regulations and must be required to do so.
• The height and immense size of a six-storey building significantly exceeds council regulations and is completely out of scale and character with Narrabeen’s low rise coastal look, feel and charm. It is monstrous.
• It is an undeniable overdevelopment of the area with arrogant disregard for the community. A disdain for generations who came before us, recognised something special and worked together to protect it.
• The design completely ignores design principles for independent living medium density to provide two or three storey housing clusters where the scale and massing is articulated and separated to respect the character and pattern of the suburban surroundings.
• The design has no regard for surrounding dwellings and architecture and seems driven by the goal of maximising financial return for a private developer.
• It is in effect a high-end residential apartment complex hiding behind aged care facilities for a small number of residents. It is a private residential facility providing premium lifestyle for the wealthy and does not provide affordable housing for our aging population.
• The proposed removal of 24 high category trees and a further 45 low category trees is obscene. It destroys habitat for birdlife and wildlife and impacts visual screening. When we should be doing everything possible to reduce our carbon footprint the loss of so many mature trees is unconscionable. The typical solution offered by property developers to plant replacement trees is embarrassingly inadequate.
• It will be a visual intrusion for neighbouring properties and the wider local community. In short it will be an eyesore, obstruct views, impact sunlight and cast shadows.
• There are no proposed benefits to the local community. None.
• The increase in vehicles entering and exiting the facility daily will further strain already congested streets. It is dangerous.
• Excavation for a three level basement carpark risks disrupting the fragile nature of the Peninsula’s sandy soil and water table.
• Other than token landscaping, the design does not incorporate the Indigenous heritage of the area and the extensive excavation risks disturbing remains and artefacts of our First Nations peoples.
• The development falls well short of meeting community environmental and sustainability expectations. It should satisfy the requirements of a 5-star Australian Excellence Green Building Council Australia rating.
* Insufficient set back. The perimeter of the building is far too close to the boundary.

I wish to express my strong opposition to the proposal. A building of this size (5–6 Floor building complex) is completely out of character with the area. I live in Ocean Street and it is a low-rise, beachside community made up of family homes and small apartment complexes. A project of this size would, in my opinion, overwhelm the landscape, raise congestion, and destroy the relaxed coastal ambience.
As many have said, Narrabeen is not Dee Why.

I object to the Indigo by Moran project as it would set a concerning precedent for future developments in Narrabeen, effectively opening the door for more six-storey buildings in the area. Such large-scale developments are inconsistent with the existing low-rise, beachside character that defines Narrabeen’s family-oriented community. Allowing this project to proceed would fundamentally alter the coastal village atmosphere, overshadowing the natural landscape and undermining the sense of place that residents and visitors value so highly.

Objection to Proposed Development – Over 55s Housing (5 Storeys, 3 Basement Levels, Height 21.1m)

1. Inconsistent with Surrounding Character and Built Form

The proposed development is grossly inconsistent with the established character of Narrabeen and its surrounding coastal environment. The area is primarily defined by single and two-storey dwellings, complemented by a small number of low-rise residential flat buildings of two to three storeys. These buildings are designed with generous setbacks, landscaped frontages, and a visual connection to the natural landscape that reinforces the coastal village character of the suburb.

A five-storey building with three basement levels introduces an inappropriate level of intensity, bulk, and visual dominance. The height, form, and massing are entirely out of context with the existing built environment and will significantly detract from the visual harmony and human scale of the streetscape. The proposal would disrupt the existing transition between buildings, dominate its surroundings, and erode the established low-rise character that defines Narrabeen’s unique appeal.

This form of development directly contradicts the planning objectives for the area, which aim to preserve the local character, maintain visual cohesion, and ensure new developments respond sensitively to their context.

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2. Non-Compliance with Height Controls

The proposed building height of 21.1 metres exceeds the permissible height limit by 8.8 metres, even after considering allowances under the State Environmental Planning Policy (Housing for Seniors or People with a Disability) 2004. Such an extensive breach of planning controls represents an unjustifiable variation that undermines the intent of the Local Environmental Plan (LEP) and Development Control Plan (DCP).

The height variation will result in excessive bulk, unreasonable overshadowing of nearby properties, and significant visual intrusion. This scale of development does not respect the established or desired future character of the area and sets a dangerous precedent for further non-compliant proposals. Allowing such a major deviation would undermine the integrity of local planning controls designed to protect community amenity and ensure balanced development.

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3. View Loss for Neighbours and Public Areas

The proposed height and scale will cause considerable view loss to both neighbouring residents and the broader community. Private views toward Narrabeen Lagoon, the beach, and surrounding natural vistas will be obstructed. Public view corridors available from key streets and open spaces will also be compromised.

Furthermore, the photomontages and visual assessments supplied by the applicant are misleading. They fail to accurately depict the relationship between the proposed height (RLs) and existing dwellings, creating the false impression that a 21-metre building is comparable in height to a two-storey home. This misrepresentation significantly underplays the actual visual impact of the proposal. The development would permanently diminish the visual quality and open feel that make this part of Narrabeen so special to residents and visitors alike.

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4. Inadequate Setbacks and Failure to Provide Height Transition

The proposed side and rear setbacks are inadequate and exacerbate the perception of bulk and massing. The building fails to provide an appropriate transition in height and scale to neighbouring lower-density homes, resulting in significant visual dominance, overshadowing, and privacy impacts.

There has been no attempt to step the building or articulate its façades to reduce perceived bulk. The result is a monolithic structure that looms over surrounding properties and fails to integrate sensitively with its context. This lack of design refinement directly contradicts the objectives of the DCP, which require new development to achieve an appropriate built form transition.

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5. Removal of Significant Vegetation

The development will result in the unnecessary removal of mature trees and significant vegetation that contribute to the visual and ecological character of the area. Some of these trees may hold heritage or environmental value, and their removal will have long-term negative consequences.

This vegetation currently softens the built environment and provides valuable shade, privacy screening, and habitat for wildlife. Its removal will erode the natural landscape setting of Narrabeen and increase the urban heat load in the area. The lack of meaningful retention or replacement of vegetation demonstrates poor site planning and a disregard for environmental sustainability.

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6. Adverse Microclimatic Impacts (Wind and Heat)

The bulk and orientation of the proposed building are likely to disrupt existing wind patterns and airflow, reducing natural ventilation for nearby properties. Prevailing sea breezes that currently moderate summer heat will be obstructed, creating stagnant air pockets and contributing to the urban heat island effect.

This will not only reduce comfort levels for nearby residents but also increase local temperatures and decrease environmental performance outcomes. Developments of this scale should incorporate thorough environmental and climatic assessments, which appear lacking in this case.

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7. Insufficient Car Parking and Traffic Impacts

The development fails to provide adequate parking for residents, visitors, and staff, contrary to SEPP and DCP requirements. This shortfall will inevitably result in overflow parking onto nearby residential streets, intensifying existing parking pressures and creating safety concerns.

Additionally, the proposed three levels of basement parking will generate significant construction impacts, including heavy vehicle movements, noise, dust, and potential traffic disruption for an extended period. These impacts will be highly disruptive to the surrounding community and incompatible with a quiet residential setting.

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8. Overdevelopment and Over-Intensification of the Site

The proposal represents a clear overdevelopment of the site. The density, height, and scale far exceed what is reasonable or appropriate for this location. The building footprint covers too much of the site, leaving limited open space or landscaping opportunities.

Under the guise of “Over 55s housing,” the proposal over-intensifies the use of the land without providing genuine community or design benefits that would justify its impact. True housing diversity should enhance local amenity, not diminish it. This development compromises both residential quality and environmental sustainability.

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9. Cumulative and Precedent Impacts

If approved, this development would create a dangerous precedent for future applications seeking similar non-compliance. Allowing such excessive height and bulk in a low-rise coastal suburb would encourage further overdevelopment, gradually eroding Narrabeen’s distinctive character and environmental quality.

Once the precedent is established, it becomes increasingly difficult for the planning authority to resist similar proposals, leading to long-term and irreversible change inconsistent with community expectations and planning intent.

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10. LMR Stage 2 – 2025 Reforms Context

Under the State Government’s recent Low and Medium Rise (LMR) Housing Reforms, only certain town centres within 800 metres of key hubs are eligible for increased height limits up to 21 metres. Following extensive consultation and community objection, four centres—Warriewood, Narrabeen, Newport, and Belrose—were specifically excluded from Stage 2 of the reforms due to their coastal sensitivity and existing low-rise character.

The current proposal by Moran seeks to introduce a 21-metre-high development into an area intentionally excluded from these reforms. Allowing such a proposal effectively overrides the State’s own policy decision and disregards community consultation outcomes. This represents an unfair and inappropriate advantage inconsistent with broader planning fairness and transparency.

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11. Lack of Consultation

As a nearby resident, I have received no direct notification or letter drop regarding this proposal. This raises serious concerns about the adequacy of community consultation. A development of this magnitude should not proceed without clear and transparent engagement with all affected residents.

The application should not be determined until the State is satisfied that meaningful consultation has occurred, ensuring all impacted parties are informed and given a genuine opportunity to make submissions.

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12. Conclusion

In summary, the proposed Over 55s development is excessively tall, bulky, and inconsistent with the established and desired character of Narrabeen. It breaches height and setback controls, removes valuable vegetation, and will generate significant traffic, environmental, and amenity impacts.

This proposal represents an over-intensification of the site and is contrary to the planning objectives that protect Narrabeen’s coastal village identity. The development should be refused.

If the State is minded to consider approval, it must require substantial redesign to ensure the proposal:
    •    Complies with height and setback controls,
    •    Retains significant trees and vegetation,
    •    Minimises environmental and visual impacts, and
    •    Provides adequate parking, setbacks, and a genuine transition to adjoining properties.

Narrabeen deserves development that enhances its beauty, liveability, and community character—not one that destroys it.

The General Manager
Northern Beaches Council
Attention: Development Assessment Team

Subject: Objection to Development Application – Over 55s Housing Development (5 Storeys, 3 Basement Levels, Height 21.1m), 156 Ocean St Narrabeen - SSD-76220734
Dear Sir / Madam,
I write to formally object to the proposed Over 55s residential development at 156 Ocean St Narrabeen on the following planning and amenity grounds. The proposal, as currently designed, represents a substantial departure from the planning controls, established character, and community expectations for this area.

1. Inconsistent with Surrounding Character and Built Form
The proposed five-storey building, incorporating three basement levels, is grossly inconsistent with the prevailing character of the surrounding locality, which is defined by:
Predominantly single and two-storey residential dwellings, and Low-rise residential flat buildings of two to three storeys.
The excessive height, bulk, and massing of the development introduce an inappropriate intensity that is out of context with the established built form. The proposal will dominate its surroundings, disrupt the visual transition between buildings, and erode the low-scale residential character that the Local Environmental Plan (LEP) seeks to preserve.
2. Non-Compliance with Height Controls
The proposed height of 21.1 metres exceeds the permissible height limit by 8.8 metres, even after accounting for the variation allowed under the State Environmental Planning Policy (Housing for Seniors or People with a Disability) 2004 (SEPP Seniors). Such a significant non-compliance: Represents an unjustifiable breach of statutory planning controls, Results in unacceptable visual intrusion, overshadowing, and view loss, and Undermines the integrity of the local planning framework. The proposal clearly fails to satisfy the height objectives of the LEP and Development Control Plan (DCP), which require new development to be compatible with its context and to protect neighbouring amenity.
3. View Loss for Neighbours and Public Areas
The excessive height and bulk will cause substantial view loss for adjoining residents and the public domain. In particular:
Private views to key landscape vistas will be obstructed,
Public view corridors from surrounding streets and open spaces will be diminished, and The applicant’s photomontages are misleading, as they understate the relationship between the proposed building (at RL 21.1m) and surrounding dwellings, implying a false equivalence with two-storey houses of approximately 6m height.
This misrepresentation conceals the true scale and visual impact of the proposal.
4. Inadequate Setbacks and Lack of Height Transition
The proposal provides insufficient side and rear setbacks, exacerbating perceptions of bulk and massing and failing to provide an appropriate transition in scale to adjacent low-density dwellings. The absence of building articulation or stepping results in a monolithic built form that dominates its surroundings rather than integrating sensitively with them. This outcome is contrary to the DCP’s urban design principles, which seek to minimise visual bulk and protect neighbouring privacy, solar access, and outlook.
5. Removal of Significant Vegetation
The development involves the removal of a substantial number of established and mature trees, some of which may possess heritage or ecological significance.
This loss: Erodes the landscape character and green canopy of the area, Removes important habitat and biodiversity value, and Eliminates screening vegetation that currently mitigates built form impacts. The unnecessary extent of vegetation removal demonstrates poor site planning and disregard for the environmental and aesthetic value of existing trees.
6. Adverse Microclimatic Impacts (Wind and Heat)
The proposal’s excessive bulk and siting will significantly alter local airflows and microclimatic conditions, leading to:
Reduced natural ventilation for surrounding dwellings,
The loss of cooling breezes, and The creation of heat traps contributing to the urban heat island effect.
These impacts will detrimentally affect neighbouring residential amenity and environmental sustainability.
7. Insufficient Car Parking and Traffic Impacts
The proposal provides inadequate parking for residents, staff, and visitors, contrary to the requirements of both the SEPP Seniors and Council’s DCP. This shortfall will:
Force overflow parking onto surrounding residential streets,
Exacerbate existing parking scarcity, and Increase traffic congestion and safety risks on local roads not designed for higher volumes. Furthermore, the excavation of three basement levels raises significant concerns regarding construction traffic management, noise, and vibration impacts over an extended construction period.
8. Overdevelopment and Over-Intensification of the Site
The development constitutes clear overdevelopment, with a density, height, and floor space ratio far exceeding that suitable for the site and locality. It fails to respond to site constraints and does not deliver genuine public benefit or design excellence to justify the magnitude of variation sought. Instead, it results in unacceptable environmental, visual, and amenity impacts.
9. Cumulative and Precedent Impacts
Approval of this application would establish an undesirable precedent, encouraging similar non-compliant developments across the locality. Over time, this would erode the low-density character and residential amenity that define the Narrabeen area.
10. Inconsistency with LMR Stage 2–2025 Reforms
The Northern Beaches LMR Stage 2–2025 planning reforms introduced increased height allowances (up to 21m) for specific town centres within 800m of major centres such as Dee Why, Mona Vale, and Manly. Following community consultation, several areas—including Narrabeen—were specifically excluded from these reforms in recognition of community objections to excessive density and height increases. This development, at 21.1m, effectively seeks to impose those same higher density outcomes on an area that was expressly excluded. To permit such a proposal would grant an unfair advantage and undermine the intent of the State’s planning reform outcomes.
11. Lack of Consultation
As a nearby resident, I did not receive any notice, correspondence, or letter drop regarding this development proposal. This raises serious concerns about the adequacy and fairness of the public notification process. The development should not be determined until the State and Council are satisfied that all affected residents have been properly notified and provided a reasonable opportunity to review the proposal and make submissions.
12. Conclusion
In summary, the proposed development is:
Excessively tall and bulky;
Inconsistent with the existing and desired character of the area;
Non-compliant with key planning controls;
Environmentally destructive through unnecessary tree removal; and
Likely to generate significant amenity, traffic, and environmental impacts.
The proposal represents an over-intensification of the site and should therefore be refused.
Should the State or Council be minded to consider approval, the proposal must be substantially redesigned to:
Comply with the maximum height and setback controls;
Retain significant vegetation and improve landscaping outcomes;
Reduce visual and environmental impacts; and
Provide adequate parking and a sensitive height transition to adjoining properties.
Yours faithfully,
Chris Girling

Narrabeen doesn’t not have the infrastructure, roads or parking space to support a building of this size. The size and design is also in total opposition to the rest of the area and community standards. Narrabeen is a quiet, spacious, relaxed suburb. This project will threaten that. As a nearby resident, myself and my neighbours will be directly impacted by the works and the influx of people this project will bring if completed. As it is, Narrabeen has tight streets, limited parking and crowded housing. Narrabeen cannot support this project, it’s simply not sustainable for our small community.

I strongly object to this proposal for the following reasons:
There was no meaningful community consultation before the proposal was submitted. The developers in trying to argue that marketing events they held were "community consultation meetings" is deceitful and underhand as the meetings they held were about trying to sell the proposed apartments to senior citizens. The meetings discussed what facilities potential senior residents wanted in the building and did not canvass the impact the proposal would have on the community as a whole and the nearby residents. The only people they invited to the meetings were over 55 year olds interested in purchasing an apartment. The meetings excluded other residents.
The developers should be required to hold genuine community consultation meetings before further consideration is given to this proposal, ideally chaired by staff from the Northern Beaches Council
The project as submitted does not conform with the current zoning requirements namely a maximum of 2 stories plus roof top gardens/terraces.
There is no provision within the proposal for low income housing or low entry cost retirement living.
The project proposes 5 stories of apartments plus roof top gardens, terraces and entertainment areas which if agreed will overwhelm the surrounding built environment and the current features of the area.
The current 2 story retirement village is set in a park like environment which from each of the 3 street frontages presents as a low key structure and is in keeping with much of the surrounding buildings,
The proposal as is presents as a very high wall of apartments (3 times the current height) on 3 street frontages with minimal gardens and lawns to the street. The garden courtyard as proposed is entirely encompassed by the proposed buildings denying nearby residents and passerby's the current park like environment. It is in fact a very high walled and gated stand alone city isolating the proposed apartments and their residents from the nearby environment.
The proposal is it stands if approved will inevitably result in pressure to build further 6 story buildings in the area changing the very nature of the area and in contravention of both the Northern Beaches Council intentions and the desires of the vast majority of the residents in the area.
The proposal to excavate 3 underground levels for car parking will as evidenced by the plan itself extend below the existing groundwater table and disrupt the normal flow of water to the lagoon and noting the possible impact this will have on the nearby lagoon and its wildlife.
It is also noted that there will be a maximum of 7 visiting car spaces for 149, 2 and 3 bedroom units. Clearly inadequate and as such will result in further increasing the difficulty of parking on the street. Only 4 electric vehicle charging stations are provided which is clearly inadequate for 149 apartments and will result in increased crowding and delays at the local public charging stations.
The above is also provided as an attachment.

We used to live very close by to this development for 6 years so know the area and street well, there is no way this small coastal penisula can cope with the size of this development. Traffic and parking is already horrendous, even with parking for residents if they have visitors there would be no where to park. Can’t even imagine the environmental factors of the height of this building on the surf and beach. We also drive our daughter to school a few blocks from here it is hard enough getting parking and doing kiss and ride with current parking. It is such a beautiful area because it has not been developed with high rises. The community does not want this at all!

I object to the size of the development. 6 stories is far too large and would change the charming feel that narrabeen has. I would not be opposed to a 3 story development which is in line with all the other buildings in the area currently. Added to my concerns is the congestion it will cause in the area due to added traffic, adjoining streets loftus and Octavia are very narrow and will not handle added congestion very well. Additionally it will increase traffic and danger hazards for children at nearby st Joseph’s primary school. Narrabeen is not the correct location for a high density 6 story development.