I support the proposed retirement village development as it will provide much needed accommodation for older residents in our community, enabling them to live independently with access to care, support, and social interaction. This type of development promotes a strong sense of community, safety, and wellbeing for residents, while also easing housing pressure by freeing up existing homes for younger families. Unlike large, high density projects driven by profit, a retirement village offers a considerate and sustainable approach that complements the character of the area and contributes positively to the local economy through new employment and services.

The proposed retirement village development in Narrabeen represents a positive step forward for the local community. It will provide high quality, age appropriate housing that allows older residents to remain in the area they know and love, close to family, friends, and essential services. By creating a supportive and well designed environment, the development promotes social connection, wellbeing, and independence for seniors. In addition, the project will contribute to the local economy through job creation during construction and ongoing employment opportunities within the village. Compared to high density alternatives, a retirement village offers a more thoughtful and community-focused use of the land, aligning with Narrabeen’s character and long term needs.

Concern with the proposed height and size of this development - we have several other developments in Lagoon street and Ocean street which are not intrusive on neighbouring homes and properties and blend in well with the current community . This development will impact surrounding homes and take over their appeal and privacy as well as blocking sunlight.
Street parking is at a premium already and this development will add to already congested streets locally.
Narrabeen is a coastal suburb and its appeal is that it is low rise . The anticipated height of this development will open the doors for future larger developments which means we are losing that relaxed community living

Historically Narrabeen has been limited to 3 storey development. The precedent will destroy the family orientated precinct, whilst I do understand the requirement to increase density increasing the limited form 3 to 6 is extreme. Ocean street is a thoroughfare with ever increasing traffic and difficulty parking due to the beach access. Replacing a retirement / nursing home with high density expensive units will add nothing to the area, other than to increase the older affluent demographic. On the grounds of lack of amenity, parking, traffic and need I object to the size and scope of this project.

The Secretary, DPHI

Objection to SSD-76220734,156 Ocean Street Narrabeen NSW

I live in Lagoon Street Narrabeen, diagonally opposite the subject site to the north-west and I have major objections to the proposed development in its current form as lodged.

Traffic and Parking Accommodation:

Parking Accommodation
The proposal provides for 178 vehicular spaces on site for a combination of 149 two and three bedroom apartments, which includes staff and visitor parking, which in my estimation is totally inadequate.
Parking is already extremely difficult in the area surrounding the proposed development and further exacerbated during the summer months with outsiders seeking parking for beach access.
One would have expected 2 spaces per apartment at a minimum and likely an additional 28 visitor spaces, and 10 allocated staff parking spaces. How many staff are to be employed on site, with parking also required for regular contractors called to the property?
Parking provided totals 178 bays which includes only 4 visitor bays and only 3 staff parking bays, leaving 171 car parking bays for 141 apartments, which is not nearly enough!

Vehicular Traffic
The current road network around the subject property does not cope with the existing traffic, so cannot possibly cope with the increased traffic flows in and around the site.
Lagoon Street traffic is already a problem and both Octavia and Loftus Streets are narrow with parking provided at kerb on each side thus restricting vehicular movements to one direction at any one time.
The increased volume of vehicular movements in Lagoon Street will cause congestion of a great order and will also need to accommodate many additional delivery vehicles.

Conclusion
Under the circumstances, with the documents that have been made available, the current proposal should be refused as it does not:
1. Comply with Northern Beach Council Residential Code.
2. Narrabeen does not fall within the low and medium rise planning areas on the NSW Government Planning Portal, as Narrabeen is not an LMR Station or Centre.
3. The impacts on the local area for parking provisions are grossly inadequate and will not address the increase in population density or vehicular movement.
4. The surrounding streets cannot currently cope with the existing traffic, let alone the increased traffic generated by this development.
5. The proposed development sets a dangerous benchmark for further similar developments on the peninsula in the Narrabeen area, which will destroy the current ambiance and amenity of the local area.
Yours Faithfully,

Proprietor, Lagoon Street, Narrabeen NSW 2101

Typical northern beaches residents living under a rock, couldn't think of a better development, retirees downsizing and not having to leave their area and opening up more housing, it's beautiful development where residents can kick back and enjoy life without the worried of who's looking after the house whilst away on holidays and at home. I hope this development does go ahead the area needs a beautiful new building and bulldoze down the eyesore. cheers

The project has been poorly designed and does not align with the environment of Narrabeen and the Narrabeen peninsula. There are no buildings exceeding 3 storeys (above garages) in the vicinity.
Allowing a 6-storey high project to proceed is going to impact the neighbouring properties and neighbourhood negatively from building shading, overcrowding, lack of parking and visually.

- Building shading
The impact of a 6-storey structure on neighbouring properties is immense as demonstrated in the shadow diagrams. The loss of sun in winter for neighbouring properties is unmeasurable and will negatively impact the wellbeing of neighbours. I note that the shadow diagrams conveniently fail to show shadowing at sunrise and sunset at all times of the year. Considering the location of the proposed development, it would have been appropriate to show shadowing at sunrise, when residents are outside before work, and at sunset when residents are outside after work. It is possible that the shading would also be extending onto the beach and will not only impact neighbours, but all residents in general. It is hard to tell as a study at 6pm-7pm on the 21st December has not been provided.
The shadows at 3pm on the 22nd of June are completely unacceptable and show how the buildings across the Ocean Street will be losing sun sometime between 2pm and 3pm. This is a major loss of sun at a time of year when every minute is crucial.
The neighbours at 71 Lagoon St and 3 to 9 Loftus St will also be highly impacted in the middle of winter.

- Overcrowding
It is not possible to tell how many beds are currently available within the existing facility, however I assume that a doubling of the building height will lead to a doubling to tripling in residents.
The Narrabeen peninsula has a distinct character which is very family orientated with mostly individual homes and small apartment blocks. Adding 149 units goes against the character of the area and will negatively impact cafes, supermarkets and restaurants nearby which are not geared to cater to an enormous crowd. As a reference, the neighbouring 4-storey apartment buildings on Ocean Street have 10-15 units each. The impact of the new facility would rival the construction of 10 of blocks of units of that size, which I am sure would be knocked back by council. The facility is not located directly adjacent to a traffic hub, so does not line up with the new government guidelines of allowing additional development near transport hubs.

- Parking
There are 178 resident parking spaces planned, but only 7 visitor spaces according to the Traffic Impact Assessment. If each of the 149 units were to receive a visitor on the weekend, there would be a requirement for 149 visitor spaces. The provision of 7 is inadequate and will lead to a greater strain on neighbouring parking, which is already difficult and at a premium. The submission does not address how it plans to facilitate parking for staff, as it is unlikely that 3 staff spaces will be sufficient for 149 units plus 10 care units.

- Visual impact
The 3D view loss study shows that the proposed development is expected to double the height of the building. The visual impact assessment conveniently does not show any photomontages taken from the beach directly adjacent to the development, the nearest view being View 3 where it is visible that the new development will significantly impact the visual aspect of the neighbourhood. View 2 from Ocean Street shows how disproportionately inappropriate the development is compared to the scale of neighbouring buildings.

For the project to be submitted as a State Significant Development is purely a loophole to avoid proper review and endorsement by the local council and to have it assessed by the NSW Department of Planning. At a guess, this is purely because the developers are aware that any locals involved in the assessment of this project would knock a project of this size back in a heartbeat. It does not provide any new affordable housing for the younger generations, who are already struggling to live in the area which has become more and more unaffordable over the years. The development will lead to a loss of character of the local area, overcrowding, shading and will purely disfigure the local community.

I strongly oppose the development and hope it does not get approved to proceed in its current state.
A redevelopment in similar scale and height to the existing would be more appropriate and more welcome for the community. Affordable housing for young professionals and couples would be more appropriate and welcomed by the community.

I am a resident of Narrabeen and live within 100m of the proposed development. I wish to lodge an objection to the Proposed Development – Over 55s Housing (5 Storeys, 3 Basement Levels, Height 21.1m) at 156 Ocean St, Narrabeen due to the following reasons:

1. It is inconsistent with Surrounding Character and Built Form.

The proposed development is grossly inconsistent with the prevailing character of the surrounding area, which is defined by:
    •    Single and two-storey residential dwellings, and
    •    Low-rise residential flat buildings predominately of two to three storeys.

A 5-6 storey building with three basement levels introduces an inappropriate level of intensity, bulk and scale that is out of context with the established built environment. The height, form, and massing are inconsistent with the pattern of development in the locality and detract from the visual harmony and human scale of the streetscape.

This proposal will dominate its surroundings, disrupt the visual transition between buildings, and erode the established residential character contrary to the planning objectives for the zone.

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 increase allowed under the State Environmental Planning Policy (Housing for Seniors or People with a Disability) 2004.
Such a substantial variation:
    •    Represents an unjustifiable breach of planning controls,
    •    Results in significant visual intrusion and view loss, and
    •    Undermines the integrity of the local planning framework.

The excessive height produces unreasonable overshadowing, bulk, and scale, inconsistent with the height objectives of the Local Environmental Plan (LEP) and Development Control Plan (DCP), which seek to ensure new development is compatible with its context and protects neighbouring amenity.

3. View Loss for Neighbours and Public Areas

The development will cause substantial view loss to neighbouring residents and members of the public.
Specifically:
    •    The height and bulk of the proposal will obstruct existing private views to key vistas and landscapes.
    •    The building will impede public view corridors available from streets and nearby open spaces.
    •    The photomontages provided by the applicant are misleading, as they fail to accurately depict the relationship between the proposed height (RLs) and existing neighbouring dwellings, incorrectly suggesting that a 21m building is similar in height to a 6m two-storey dwelling. The proposed development of 5-6 storeys, can in no way look anywhere remotely similar to the height limit of the 2 storey shop on the north east corner opposite this site. Height shadow images within the submission, make it appear visually similar in height. This is one of many examples that can be given of images being misleading in the proposal.

This misrepresentation of scale and visual impact significantly underplays the true extent of view obstruction the proposal will cause.

4. Inadequate Setbacks and Failure to Provide Height Transition

The proposal incorporates inadequate side and rear setbacks, which:
    •    Exacerbate the perception of bulk and massing,
    •    Fail to provide an appropriate transition in scale to neighbouring lower-density dwellings, and
    •    Lead to unreasonable amenity impacts (visual dominance, overshadowing, and privacy loss).

There has been no attempt to step the building or articulate façades to reduce perceived bulk and scale. This approach results in a structure that dominates its surroundings rather than integrating sensitively with them. Three street frontages will be affected.

5. Removal of Significant Vegetation

The proposal involves the removal of a large number of established and significant trees, some of which may hold heritage or ecological value.
This loss:
    •    Erodes the landscape character and natural setting of the area,
    •    Removes valuable habitat and urban canopy, and
    •    Eliminates screening vegetation that currently softens the visual impact of built form.

The unnecessary extent of tree removal demonstrates poor site planning and disregard for the environmental and aesthetic value of existing vegetation.

6. Adverse Microclimatic Impacts (Wind and Heat)

The development’s excessive bulk and placement will alter local airflows, resulting in:
    •    Reduced natural ventilation for surrounding dwellings,
    •    The elimination of prevailing breezes that currently mitigate summer heat, and
    •    A stagnant microclimate likely to exacerbate urban heat island effects.

These impacts will diminish residential amenity for neighbouring properties and reduce environmental sustainability outcomes for the locality.

7. Insufficient Car Parking and Traffic Impacts

The proposal includes inadequate parking provision for both residents and staff, contrary to the requirements of the SEPP 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 to accommodate higher volumes.

The proposed three basement levels may also result in construction disturbance, noise, and traffic management issues over an extended period.

8. Overdevelopment and Over-Intensification of the Site

The proposal represents a clear overdevelopment of the site, with a density, height, and scale far exceeding what is suitable for the locality.
The development:
    •    Fails to respond to the site constraints,
    •    Over-intensifies the use under the guise of “Over 55s housing”, and
    •    Does not deliver genuine benefits or design excellence that would justify such an excessive variation.

Rather than enhancing housing diversity, the proposal compromises residential amenity, environmental quality, and visual character. Current Council regulations do not allow developments over maximum 2-3 storeys in height.

9. Cumulative and Precedent Impacts

Approval of this proposal would create a highly undesirable precedent, encouraging other developers to seek similar non-compliances in height, bulk, and scale.
Over time, this would erode the established low-density character of the locality and diminish the visual and environmental quality of the broader area.

10. Visual Impacts

Many of the images and shadowing projected, are extremely misleading. They do not appear to depict what the true impact will be of how this will appear to affect the streetscape, and immediate community area. Assessments within the report of “Negligent” in relation to Viewpoint Sensitivity is an extremely subjective use of language. There is a constant presence within the development submission, that it is in some way positive to the streetscape. This is not achievable at 5-6 storey’s.

Conclusion

In summary, the proposed Over 55s development is:
    •    Excessively tall and bulky,
    •    Inconsistent with the existing and desired character of the area,
    •    Non-compliant with height and setback controls,
    •    Environmentally destructive, and
    •    Likely to generate significant amenity, parking and traffic impacts.

The application represents an over-intensification of the site and should therefore be refused.
If Council is minded to consider approval, the proposal must be significantly redesigned to:
    •    Comply with the maximum height and setback controls,
    •    Retain significant vegetation,
    •    Reduce visual and environmental impacts, and
    •    Provide adequate parking and genuine height transitions to adjoining properties.

Reasons for objection
1. Traffic and Road Safety Concerns
The proposed development will significantly increase local traffic volumes on Ocean Street and the surrounding residential roads. This area already faces congestion, limited parking, and safety concerns due to narrow street layouts and proximity to local schools and amenities. The addition of vehicles from staff, residents, visitors, service deliveries, and emergency vehicles will place further strain on local infrastructure

2. Construction Impacts on Surrounding Homes
The proposal for a six-storey complex will involve deep excavation and heavy construction equipment operating over an extended period. Surrounding properties are in very close proximity, raising several concerns:
• Noise pollution: from machinery and pile-driving during excavation, affecting sleep and daily life.
• Dust and air pollution: impacting health, especially for children, elderly individuals, and those with respiratory issues.
• Vibration and structural risk to surrounding buildings: Prolonged vibration during deep foundation works can compromise the structural integrity of adjacent buildings, leading to cracking or movement in foundations and walls.
• Access and safety: Construction vehicles and machinery will occupy limited street space, further restricting parking and pedestrian safety.

3. Height, Overshadowing, and Environmental Impact
The surrounding homes and developments in this neighbourhood are predominantly two to three storeys high, forming part of the low-rise, unique coastal character of Narrabeen. The proposed six-storey building would be entirely inconsistent with the local built environment.
Such an oversized structure will:
• Block natural sunlight to neighbouring homes and gardens.
• Reduce passive solar access, increasing residents’ energy use and carbon footprint.
• Alter the local microclimate and disrupt natural ventilation patterns.
• Diminish the area’s visual and environmental amenity by overshadowing public and private open spaces.
This represents a clear case of overdevelopment, likely to cause both environmental degradation and reduced quality of life for surrounding residents.

4. Suitability for Elderly Residents and Community Connection
The Indigo by Moran website promotes luxury amenities including a heated 25-metre pool, resident cinema, temperature-controlled cellar, fitness centre, library, landscaped gardens, and a rooftop pavilion for entertaining and social activities. While these features may sound attractive, they raise serious concerns when applied to a small, 9,234 m² site (less than one hectare).
Facilities of this scale are suitable for a large, low-density retirement village built on expansive land, not for a compact site in a residential street surrounded by family homes.
Fitting so many features onto a small parcel of land necessitates vertical expansion to six storeys, leading to overcrowding and disconnection from the local community.
It is also important to recognise that this is not an aged-care facility, but an independent retirement living complex. Residents, typically aged 60 and over, are generally healthy and active. They benefit most from regular interaction with the community, visiting local shops, engaging in outdoor recreation, and maintaining social links.
However, a high-rise, enclosed structure with extensive on-site facilities risks isolating them from the wider neighbourhood.
This model creates a “self-contained bubble” rather than encouraging integration with the community, which is essential for older adults’ mental and emotional wellbeing.
Scaling down the facilities to a more community-focused level would remove the need for excessive building height. A three-storey design, in keeping with surrounding buildings, would still deliver comfortable, accessible housing for seniors while promoting connection to nature, sunlight, and local life.

5. Inconsistency with Local Character and Planning Intent
The Narrabeen area is characterised by low-rise residential dwellings with coastal charm and natural light. The scale and intensity of this proposed development are out of harmony with that character.
The proposed six-storey structure will dominate the streetscape, alter the visual aesthetic, and set a concerning precedent for future high-density developments in low-rise areas.
This conflicts with the Environmental Planning and Assessment Act 1979 principles of maintaining local amenity, character, and sustainability.

6. Cumulative Environmental and Social Impacts
The Environmental Impact Statement does not adequately address the cumulative effects of this project. The increase of residents, staff, and visitors will increase strain on:
• Local traffic and parking capacity.
• Waste collection and management services.
• Water and energy infrastructure.
• Noise levels and air quality during and after construction.
Furthermore, the loss of sunlight, increased density, and reduced open space will affect both human health and urban biodiversity, contradicting the NSW Government’s environmental sustainability goals.

Conclusion
This project, while described as a premium seniors’ living development, raises significant issues relating to:
• Traffic congestion and road safety;
• Noise, dust, and structural risks during construction;
• Overshadowing and environmental degradation;
• The wellbeing and community connection of elderly residents; and
• Destroy the unique low-rise, coastal character of Narrabeen.
For these reasons, I respectfully request that the Department of Planning, Housing and Infrastructure reject this proposal