No Local Benefit. Private luxury retirement development offering no affordable housing or community benefit
Overdevelopment: Six-storey, 149 apartment complex completely out of scale with Narrabeen's coastal character
Visual intrusion & Overshadowing: will block ocean views and overshadow neighbouring homes
Traffic & safety hazards: 300+ vehicles entering Lagoon Street will worsen congestion and reduce safety
Flood & Coastal risk: Located in a flood and erosion zone - unsuitable for dense development
Tree Removal: Removal of mature tres destroying coastal screening and local amenity
Environmental impact: Threatens fragile dune system and bird habitats including sea eagles and kookaburras
No local consultation or consideration by Developers.

I have lived in Narrabeen for 50 years - I walk past this site all the time as it is near my house - The size of this project just does not fit this area - it would be an eyesore - we watched Dee why being ruined 40 years ago - I would hate this to happen to Narrabeen - As for removing the Norfolk pines - how dare you even consider this - everything about this seems to be about how much money can be made instead of what is best for the area and the community- I totally oppose this development -

This proposal looks ridiculous to me. I can't imagine that anyone with any sense would support this proposal. A six storey humongous building on Narrabeen Beach is going to set a precedent. The impact on the neighbourhood is going to be inhumane. In addition to the visual impact and the noise, the blockage of sunlight will be catastrophic for a quiet and sunlit neighbourhood. Doesn't everybody have the right to sunlight? It is simply unbelievable that somebody could conceive the idea to build something like this in the Narrabeen Peninsula. We should save this beautiful environment, not destroy it.

Regards,
Extremely Concerned

I live on 179 Ocean street, just a block north of the proposed development. Street parking is already scarce in the area, Ocean street gets a lot of traffic during the day and I feel that this project is only going to make this worse. This development is too big for the area, too many units, the building is too high and it will impact the area in many levels. The whole community is against it, it will change Narrabeen’s character for the worse and I want to voice my opinion against it.

Submission – Objection to Indigo by Moran Development
156 Ocean Street, Narrabeen – SSD-76220734
Prepared by: Concerned Local Resident
1. Introduction
I wish to formally object to the proposed Indigo by Moran seniors housing development at 156 Ocean Street, Narrabeen (SSD-76220734).
I am a registered nurse who works shift work, which means I require a quiet, stable, and comfortable home environment that allows for adequate rest at varying times of day.
Our property is located directly opposite the proposed development site, on the eastern side of Ocean Street. My gardens, living areas and bedroom windows face toward the site, and the proposed six-storey structure would block sunlight to our home for much of the day, significantly reducing natural light and altering the character and amenity of our residence and the broader streetscape.
This development is out of scale, inconsistent with the surrounding environment, and unsuitable for this sensitive coastal location. I respectfully request that the NSW Department of Planning, Housing and Infrastructure refuse the application or require a major redesign that aligns with local planning controls, community expectations, and coastal management principles.
2. Coastal and Flooding Risk
The site lies within a well-documented flood-prone and coastal erosion hazard area, as confirmed in the Environmental Impact Statement (EIS) Appendices E and F. It is subject to both lagoon flooding and coastal inundation risk, with parts of the proposed footprint encroaching into high-hazard zones identified in the Northern Beaches Council Flood Study and Coastal Zone Management Plan.
While the EIS acknowledges these hazards, it proposes only standard floor height adjustments, which are insufficient considering Narrabeen’s increasing vulnerability to sea level rise, storm surge, and coastal erosion. The deep excavation proposed for the basement carpark poses additional risks, including groundwater intrusion and structural instability, which could jeopardize neighbouring properties and the local ecosystem.
This proposal contravenes the Coastal Management SEPP (2018) and Coastal Management Act 2016, both of which require developments to avoid intensifying land use in hazard-prone areas and to protect coastal processes and ecosystems.
3. Traffic, Parking and Access
The Traffic and Parking Assessment (EIS Appendix J) significantly underestimates the traffic generation and parking demand associated with this project.
With 149 apartments but only 178 car spaces, the proposal will inevitably lead to overflow parking onto Ocean Street, Lagoon Street, Octavia Street, and Loftus Street — all of which are narrow residential roads already under strain, particularly during weekends, surf club activities, and school drop-off periods.
As a resident who uses Ocean Street daily, I already experience traffic congestion and parking scarcity. Additional vehicles from this development will impede emergency access, increase safety risks for pedestrians and cyclists, and diminish overall residential amenity.
4. Height, Scale and Visual Impact
The proposed six-storey (21-metre) height is grossly inconsistent with the surrounding built form, which is predominantly two to three storeys. The excessive bulk would dominate the Ocean Street streetscape and disrupt the low-rise coastal character of Narrabeen.
The Visual Impact Analysis (EIS Appendix L) confirms that the building would obstruct the view corridor between the lagoon and the ocean. Its uniform façade and elevated massing will block sunlight and open sky for nearby homes — including my own directly opposite — creating a sense of enclosure and constant overshadowing.
This outcome is inconsistent with the Northern Beaches LEP 2022 and DCP 2022, both of which seek to preserve coastal character and protect solar access for neighbouring dwellings.
5. Vegetation Loss and Biodiversity
The Arboricultural Impact Assessment (EIS Appendix H) identifies the removal of more than 30 mature trees and established vegetation. These trees provide essential shade, coastal resilience, and habitat for birdlife, contributing to both local amenity and environmental stability.
The loss of these trees would permanently alter the landscape and reduce canopy cover, which plays a vital role in mitigating heat and managing stormwater. Replacement plantings cannot replicate the ecological or visual value of the existing mature vegetation.
6. Overshadowing, Privacy and Amenity Impacts
The Shadow Diagrams (EIS Figures 5.3–5.5) show overshadowing extending beyond the site boundaries at 9am and 3pm in winter, affecting properties along the eastern side of Ocean Street.
My home — where I live and sleep — will be severely overshadowed for most of the day, resulting in substantial loss of natural light and warmth, which directly impacts my comfort and wellbeing, especially as someone working irregular nursing shifts and needing daytime rest.
This level of overshadowing breaches Clause 6.9 of the Pittwater LEP 2014, which seeks to preserve reasonable sunlight access for adjoining properties.
Further, upper-level balconies and terraces will enable direct overlooking into our home and front yard, compromising privacy in violation of the Residential Flat Design Code (RFDC) visual privacy provisions.
7. Additional Negative Local Impacts
Construction disruption: Prolonged excavation, piling and heavy vehicle traffic will generate significant noise, vibration, dust and access issues, severely affecting residents opposite the site.
Wind tunnelling: The building’s scale and exposure to coastal winds will likely create dangerous gusts and turbulence at street level.
Infrastructure strain: Local stormwater and sewer systems are already at capacity in this flood-prone area. A high-density project will exacerbate flood risk and infrastructure stress.
Emergency access: The narrow streets and limited evacuation routes will pose serious safety risks during storm or flood events.
Precedent risk: Approval would set a dangerous precedent for other large-scale developments along the Narrabeen coastal strip, undermining the existing planning controls that protect the area’s low-rise, community-oriented character.
8. Lack of Genuine Seniors Housing Benefit
Although marketed as “seniors housing,” the proposal consists mainly of high-end luxury apartments with only 10 assisted-living units included.
This fails to meet the intent of the Seniors Housing SEPP (2004), which is to provide affordable, accessible accommodation enabling older local residents to age in place.
Instead, the project serves a premium market segment, providing little social or community benefit, and is inappropriate for this environmentally sensitive coastal site.
9. Planning Non-Compliance and Precedent
The proposal conflicts with multiple statutory planning instruments, including:
Northern Beaches LEP 2022: Exceeds height, floor space ratio, and setback controls.
Northern Beaches DCP 2022: Inconsistent with desired coastal character and built form objectives.
Coastal Management SEPP 2018: Fails to protect visual amenity and environmental processes.
Seniors Housing SEPP 2004: Does not demonstrate compatibility with local context or accessibility standards.
Approval would undermine public confidence in the planning system and invite further overdevelopment along the Narrabeen coastline.
10. Conclusion
The proposed Indigo by Moran development is excessive, incompatible, and environmentally unsound. It would dominate the Narrabeen coastline, overshadow neighbouring homes (including my own directly opposite), strain local infrastructure, and erode the unique coastal character of the area.
As a long-term resident, homeowner, and nurse who works shifts, I will be personally and directly affected by the overshadowing, noise, and loss of amenity this project would cause.
I therefore urge the Department of Planning, Housing and Infrastructure to refuse SSD-76220734 – 156 Ocean Street, Narrabeen, or require a significant redesign that reduces height and scale, ensures genuine environmental and social responsibility, and respects the existing coastal community.
Sincerely,
Concerned Local Resident
153 Ocean Street, Narrabeen
30 October 2025

This second submission is being lodged to provide further and more detailed planning assessment regarding the proposed mix of housing types. While my previous submission raised general concerns, this document focuses specifically on the critical non-compliance of the development's proposed ratio of Independent Living Units (ILUs) to Residential Aged Care (RAC) beds with the underlying intent of Seniors Housing policy.

The proposed development includes:

149 Independent Living Units (ILUs)

10 Residential Aged Care (RAC) Beds

This results in a ratio of nearly 15 ILUs for every 1 RAC bed.

1. Failure to Meet Seniors Housing Objectives

The relevant State Environmental Planning Policy (SEPP) that governs seniors housing aims to increase the provision of diverse accommodation and, crucially, high-level care for the community.

The core objection is that this ratio does not constitute a genuine effort to provide the community with necessary high-level aged care accommodation, but rather exploits planning incentives intended for care providers.

Exploitation of FSR Bonus: Seniors Housing developments are often granted floor space ratio (FSR) bonuses specifically to encourage the delivery of care suites. By including only 10 beds, the development appears to be strategically using the minimal care component to unlock increased development density for the luxury ILUs, thereby maximizing profit without addressing the local critical shortage of high-care placements.

Minimal Contribution to Care Needs: Given the scale of the 149-unit independent community, a 10-bed facility is insufficient to serve even the likely future needs of its own residents, let alone the broader community. The facility is demonstrably unable to replace the care capacity lost from any previous facility on this site or meet existing community demand.

Precedent Setting: Approval of this skewed ratio sets a harmful precedent, establishing that a development can be approved under Seniors Housing provisions with only a tokenistic care component, thus undermining the policy's objective to genuinely increase high-care accommodation.

2. Loss of Essential Care Capacity

The local area is facing an increasing demand for residential aged care. We understand that the site previously contained a greater number of aged care beds (e.g., 55 beds from the former Wesley Taylor Mission). The replacement of 55 beds with only 10 beds represents a massive net loss of 45 high-care placements for the community.

This proposed development, therefore, actively reduces the essential care infrastructure in the area, replacing it with luxury residential housing for independent living. This outcome directly contradicts the public interest and the humanitarian purpose of seniors housing legislation.

I strongly urge the Council/Authority to reject this DA on the grounds that the minimal provision of 10 Residential Aged Care beds alongside 149 Independent Living Units does not fulfill the spirit, intent, or community obligations of the Seniors Housing SEPP.

The development, as proposed, prioritizes luxury residential development over the genuine provision of essential high-level aged care. The application should be refused or, at minimum, required to significantly increase the number of Residential Aged Care beds to a level that is proportionate to the scale of the independent living component and reflective of local community needs.

I formally OBJECT to the proposed State Significant Development Application SSD-76220734 on the grounds detailed below. I request that the Department of Planning, Housing and Infrastructure refuse this application as proposed, due to its non-compliance with statutory planning controls, unacceptable amenity impacts, and detrimental effects on local character, infrastructure, and cultural heritage.

Grounds for Objection (Planning and Environmental Concerns)

My opposition to this development is based on the following specific planning and environmental grounds:

A. Visual Bulk, Scale, and Non-Compliance with Local Character

The proposed five-storey height and substantial massing of the development are inconsistent with the established low-to-medium rise residential character of the Narrabeen locale, particularly near the Narrabeen Lagoon/Beach interface.

Non-Compliance (if known): The proposal appears to rely on State Environmental Planning Policy (Housing for Seniors and People with a Disability) 2004 provisions that grant height and Floor Space Ratio (FSR) bonuses, which in this context results in over-development. The sheer scale and bulk of 149 units and extensive communal facilities will dominate the local streetscape, setting an undesirable precedent for future development.

Visual Impact: The excessive size and footprint of the building will create an unacceptable visual bulk, particularly when viewed from Ocean Street, Lagoon Street, and adjoining residential areas.

B. Traffic Generation, Parking Deficiencies, and Infrastructure Overload

The proposal for 192 basement car parking spaces, despite being a seniors housing development, represents a massive increase in vehicular traffic on local streets, specifically Lagoon Street (the main access point) and Ocean Street, while simultaneously failing to adequately plan for visitors.

Visitor Parking Deficiency: The provision of only 7 visitor car parking spaces for a development containing 149 Independent Living Units is grossly inadequate. This is a severe underestimation of demand for staff, service vehicles, and residents' family visitors.

Lack of Street Parking Capacity: The inevitable overflow parking will be forced onto surrounding local streets, which are already heavily constrained and lack available spaces. This area is already saturated with parking demand, especially during holidays and summer months, which will be severely compromised, directly impacting local resident amenity and access.

Traffic Congestion: Narrabeen is already a highly constrained traffic area due to its location between the ocean and lagoon. The proposed increase in vehicle movements during peak times will exacerbate existing congestion and compromise pedestrian and cyclist safety.

Infrastructure Strain: The concentration of such high-density living will place undue strain on existing local infrastructure, including sewerage, stormwater management, and power supply, which may not have the capacity to support the development's scale.

C. Site Suitability and Environmental Hazards (Flooding and Coastal Erosion)

The site is located adjacent to Narrabeen Lagoon and close to the beach, raising serious concerns regarding environmental risk.

Flood Prone Land: Given the site's proximity and history of inundation, the development’s proposed mitigation measures need to be scrutinised rigorously to ensure they do not merely displace flood risks onto neighbouring properties, particularly during severe weather events.

Coastal Risk: The long-term risk of coastal erosion must be fully accounted for, and I question the suitability of such a high-value, high-density development on such an environmentally sensitive site.

D. Loss of Amenity (Overshadowing and Privacy)

The height and setback of the proposed building will result in unacceptable impacts on the solar access and privacy of adjoining residential properties.

Overshadowing: The sheer height of the structure will cast significant new shadows over neighboring residential properties and their private open spaces, particularly during the winter months, reducing amenity and solar gain.

Loss of Privacy: The multiple levels and extensive balcony areas will result in unacceptable direct overlooking into the private living areas and rear yards of adjacent homes.

E. Cultural Heritage Significance (Narrabeen Man Location)

The site and its immediate vicinity are of immense cultural significance, specifically relating to the discovery site of the Narrabeen Man (Manly Council DA 2005/730).

Cultural Sensitivity: Any major construction, excavation (especially for the three-level basement), or site works in this area carries a high risk of disturbing or failing to adequately recognise Aboriginal cultural heritage. The proponent's assessment of this risk must be scrutinised to ensure all historical and archaeological obligations are met far beyond standard compliance, reflecting the site's unique importance.

Precautionary Principle: Given the sensitive nature of the location, the precautionary principle should apply, requiring a more cautious and less impactful development footprint to minimise the irreversible risk to potential cultural artefacts.

F. Loss of Existing Vegetation and Canopy Cover

The proposal necessitates the removal of a significant number of existing trees and mature vegetation across the consolidated site to accommodate the large building footprint and three-level basement.

Ecological and Amenity Loss: The mature trees provide essential canopy cover, contribute significantly to the leafy, green character of Narrabeen, and offer habitat for local fauna. The scale of removal is unacceptable and cannot be adequately compensated for by replacement planting, which will take decades to mature.

Arborist Report Scrutiny: I request strict scrutiny of the proponent's Arborist Report to ensure that all trees marked for removal are genuinely impossible to retain, especially those of high significance or health.

Visual Buffer: The loss of significant canopy cover will remove the natural aesthetic buffer between the massive proposed structure and the surrounding existing homes, making the development appear harsher and more imposing.

Conclusion and Request

For the reasons outlined above, particularly concerning the excessive visual bulk, critical deficiencies in parking, inadequate management of traffic generation, high environmental risk, and profound cultural heritage concerns, I urge the Department to refuse Development Application SSD-76220734.

Alternatively, should the Department be minded to approve the development, I request that significant amendments be mandated to reduce the overall scale (FSR and height), density, and basement excavation of the proposal to ensure it is more sympathetic to the surrounding environment, infrastructure limitations, and cultural sensitivities.

Thank you for considering my submission

Submission Objecting to DA SSD-76220734 — “Indigo by Moran”, 156 Ocean Street, Narrabeen
To: NSW Department of Planning, Housing and Infrastructure
SSD Planning Assessments
Re: Objection to State Significant Development Application, “Indigo by Moran”
Address: 156 Ocean Street, Narrabeen NSW
DA Number: SSD-76220734
Submitted by: Kylie & Tony
Date: 30/10/25

1. Introduction
We are long-term residents of Malcolm Street, Narrabeen, and wish to formally object to the proposed Indigo by Moran development at 156 Ocean Street, Narrabeen (SSD-76220734).
While we support quality, well-planned accommodation for seniors, this proposal represents a significant overdevelopment of the site, entirely out of scale with the surrounding residential character and infrastructure capacity of Narrabeen. The impacts on traffic, parking, safety, and neighbourhood amenity would be severe and ongoing.

2. Traffic and Parking Impacts
The proposal includes three basement levels with 192 car spaces (only seven of which are for visitors). This design will inevitably force a large number of visitor vehicles to park on surrounding local streets such as Lagoon Street, Albemarle, Loftus, Octavia & Tourmaline Streets, and Ocean Street.
These streets already experience high levels of parking demand, particularly on weekends during spring and summer when the Narrabeen Lagoon Trail and beach attract large numbers of visitors. Local residents frequently struggle to find on-street parking, and this development would exacerbate that problem significantly.
Furthermore, all vehicular access is proposed from Lagoon Street, a narrow, heavily used road that lacks capacity for such an increase in traffic volume. The proposed continuous in-and-out flow from a three-level underground carpark will create congestion, delays, and safety risks for both drivers and cyclists.

3. Cycling and Road Safety Concerns
The Traffic Report supporting this DA incorrectly suggests that Lagoon Street has a dedicated cycling path. This is inaccurate, cyclists currently share the road with vehicles, and the road width is limited. The increased vehicle movements from this development, including service vehicles and residents’ cars, would create a serious safety hazard for cyclists, pedestrians, and residents accessing driveways.
Given the popularity of the Lagoon Trail and Narrabeen’s cycling routes, this is a critical safety concern that must not be overlooked.

4. Scale, Height and Visual Impact
The proposed 5 to 6 storey building would be a visually dominant structure sitting atop a hill, looming over surrounding low-rise residential homes. It would create significant overshadowing, loss of privacy, and an overbearing presence entirely inconsistent with the coastal village character of Narrabeen.
This design is comparable in mass and bulk to the Northern Beaches Hospital, an institutional-scale development wholly inappropriate for this sensitive, low-rise coastal environment. The proposal fails to respect the established character and topography of the area.

5. Congestion and Access Constraints
Traffic flow along Lagoon Street and connecting roads such as Malcolm Street is already constrained. The section of Lagoon Street near Malcolm Street narrows to a single car width, regularly causing bottlenecks and queues, particularly during peak periods. This also includes the section of Malcolm Street from Ocean Street. Any additional volume from this development would worsen congestion and impede access for residents, emergency vehicles, and visitors.
The cumulative impact of this development, in conjunction with existing congestion during weekends and summer months, would significantly reduce the livability and safety of the surrounding community.

6. Conclusion
For the reasons outlined above, we strongly object to the Indigo by Moran proposal in its current form. The scale, bulk, and traffic generation far exceed what can be safely and reasonably accommodated within the existing road and community infrastructure of Narrabeen.
This development would:
• Intensify already severe parking and congestion issues
• Compromise cyclist and pedestrian safety
• Visually dominate and overshadow surrounding residential areas
• Disrupt the existing low-rise coastal character of Narrabeen
We respectfully request that the Department refuse this development application or require substantial redesign to reduce height, density, and traffic impacts in line with the existing scale and safety of the neighbourhood.

Yours faithfully,
Kylie & Tony
Malcolm Street, Narrabeen NSW

I have lived in Narrabeen for 49yrs the development is in no way sympathetic to the area or character, parking is already minimal let alone in summer with narrow streets throughout. lack of transport options, impact on surrounding residents is huge with no compensation for loss of value. The precedent this could set could have the potential to destroy the area and village nature. Dee Why has been lost and destroyed. Traffic is already horrendous through the Wakehurst parkway Pittwater road and Powderworks road as all are clogged every morning. The six story height is purely for greed not necessity this in no way helps the so called housing crisis as it is age specific.

The proposal is to have a six story building. There are no buildings in our area taller than 3 stories. It is absolutely going to ruin our neighbourhood. It is going to increase traffic and put a load on parking (the proposed building is not going to have sufficient parking for its residents), especially in summer. Narrabeen is a quiet, low key residential area. Up to now the current retirement home (that the developers are proposing to pull down to put their six floor opulent building on) blended into our neighbourhood. Having a senior housing development is not the issue it is the size & scale of the proposal that is the issue. I think it is pure greed. Thank you. Cheryl Rae. Concerned resident