Project is ridiculous. Narrabeen, specifically ocean st is easily clogged with traffic and has very little parking during quieter time let alone Peak summer or during a surf contest. This proposed plan worsens both those areas significantly espically with only 9 guest parks ! The infrastructure will not hold. Additionally this plan breaks laws on height restrictions on buildings in the area. There is plenty of room in surround suburbs and areas of ocean street. Please relocate this plan, it will serve the narrabeen area and new residents of this build better.

I strongly object to this proposal. The proposed 6-storey height is way too tall for the area and will seriously impact traffic, parking, and the neighbourhood feel.
This is not in keeping with Narrabeen’s low-rise character and will destroy the area. The upper northern beaches does not want to be like deewhy or manly- it has inadequate infrastructure and the locals live here because of the quiet nature.

To the NSW Department of Planning, Housing and Infrastructure,

I write as a long-term resident living directly opposite the proposed “Indigo by Moran Seniors Living” development site at 156-164 Ocean Street, 81-81A Lagoon Street and 8 Octavia Street, Narrabeen. I strongly object to this proposal in its current form.

This overdevelopment will have significant, irreversible, and unacceptable impacts on the character, environment, and livability of the Narrabeen Peninsula.

1. Overdevelopment and Scale:
The proposed 5 to 6 storey structure is entirely inconsistent with the established low-rise coastal character of Narrabeen. It will dominate the landscape, overshadow neighbouring homes, and visually intrude on one of the Northern Beaches’ most beautiful and fragile coastal peninsulas.
The sheer bulk, density and height are inappropriate for a narrow sandy strip of land bordered by the lagoon and the ocean. A project of this scale belongs in a high-density urban centre, not within a small coastal community already under pressure from population growth and limited infrastructure.

2. Environmental and Ecological Damage:
The proposed tree removal, including mature pines and gum trees, represents an unacceptable loss of established canopy and wildlife habitat. These trees are home to numerous native bird species, providing essential nesting and feeding areas that cannot be replaced once destroyed.
Further, the Narrabeen Peninsula sits upon a fragile sandy soil system and a delicate water table. Large-scale excavation for three levels of basement parking risks destabilising this system, causing erosion, altered drainage, and long-term environmental damage to both Narrabeen Lagoon and the nearby beach ecosystem.
This proposal directly conflicts with the principles of sustainable coastal management and environmental protection contained in the Northern Beaches Council’s Local Environment Plan and Development Control Plan.

3. Aboriginal Cultural Heritage Risk:
Narrabeen is an area of profound Aboriginal cultural significance. The site sits within a landscape that holds deep connection to the traditional custodians of this land. Any excavation or large-scale development poses a real risk to undiscovered artefacts or sites of cultural importance.
A comprehensive, independent Aboriginal Cultural Heritage Assessment must be undertaken before any consideration of approval. To proceed without this would be a failure of due diligence and a disregard for our shared cultural heritage.

4. Traffic, Parking and Accessibility:
Traffic congestion in this part of Narrabeen is already severe. Ocean Street and Lagoon Street are narrow and heavily used by residents, pedestrians, and families accessing the lagoon and beach.

The addition of 149 independent living units and a 10-bed care facility will significantly increase local traffic, creating safety concerns and making an already limited parking situation untenable. The proposal’s provision of 192 car spaces is grossly insufficient given the number of residents, staff, visitors, and service vehicles expected.

As a young mother of two young children, the current limited street parking already affects my family’s day-to-day accessibility. This development will make it nearly impossible for residents like myself to safely park near our homes, an unacceptable social impact and one that has not been adequately assessed in the EIS.

5. Visual and Social Impact:
The proposed structure will visually overwhelm the existing streetscape and block natural light and sea breezes to surrounding homes. It will transform a calm, community-oriented neighbourhood into a congested, urban-style precinct.
The cumulative effect is the erosion of local character, resulting in the loss of the very qualities that make Narrabeen special: its sense of space, greenery, and coastal serenity.

6. Precedent and Planning Integrity:
Approval of a development of this magnitude will set a dangerous precedent for future high-density proposals on the peninsula. Once this character is lost, it cannot be regained.
The State should be protecting communities like Narrabeen from overdevelopment, not facilitating it through planning pathways that override local voices and council controls.


For the reasons I have outlined, including overdevelopment, environmental harm, traffic and parking strain, Aboriginal heritage risk, and severe visual and social intrusion, I urge the Department to reject this application in its current form.

I call for the Minister for Planning and Public Spaces to require a full reconsideration of this proposal, including a downsized and environmentally responsible design that aligns with the character, infrastructure and values of the Narrabeen Peninsula.

Our community deserves thoughtful, sustainable planning, not the irreversible loss of our coastal environment, heritage, and liveability. Community before profit - always.

Alex McTavish
10/74 Lagoon Street
Narrabeen, NSW 2101

I would like to formally object to the proposed construction of a six-storey complex in an area where all existing buildings are limited to three storeys. The proposed structure would be entirely out of scale and character with the surrounding neighbourhood, which is composed primarily of low-rise family homes.

Such a large development would disrupt the visual harmony of the area and negatively affect the community’s established residential character. Moreover, the local demand is not for retirement residentials but for family homes that meet the needs of local families. Allocating this land for family housing would be far more appropriate and beneficial to the community than introducing an oversized complex that does not fit the existing environment and demand.

For these reasons, I urge the planning authorities to reconsider this project and instead promote development that aligns with the neighborhood’s scale, needs, and long-term vision.

Over development will cause infrastructure, parking, environmental and safety issues. This is not in keeping with what this peninsular can cope with.

This is not in line with the current council building regulations and exceeds the height limits

I have lived in the Northern Beaches area for over 25 years and strongly oppose the proposed project. It is an undeniable overdevelopment with an arrogant disregard for the community and a disdain for the generations before us who recognised a very special environment and worked together and through local council to protect and preserve it. I submit the following comments:
• 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.
• 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 a private residential facility providing premium lifestyle for the wealthy and does not provide affordable housing for our aging population. It is in effect a high-end residential apartment complex hiding behind aged care facilities for a small number of residents.
• 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. Existing mature trees must be protected.
• 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. The setback of the building from the boundary is inadequate.
• 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.

6 stories high is not in keeping with the feel or look of the area. Narrabeen is low rise buildings. Paved way for further high rise buildings which are unwanted in this quiet peaceful suburb. Ocean st a very busy road as is. Would mean more cars more traffic and the roads are in a terrible state as is.

Summary of submissions
1. The development application should be refused on the grounds of breach of clause 4.3 of Warringah LEP 2011 (WLEP) and s87 State Environmental Planning Policy (Housing) 2021 (Housing SEPP) and / or adverse visual impact.
2. The community consultation period should be extended.
Breach of clause 4.3 WLEP and s87 Housing SEPP
3. As acknowledged within the development application, the proposed development has a height of 21.1m. Clause 4.3 WLEP only permits building heights of 8.5m and s87 Housing SEPP only permits an additional 3.8m; a total of 12.3m. The proposed development is 8.8m above the maximum permitted development height (and over twice as tall as buildings normally permitted under clause 4.3 WLEP).
4. Clause 4.3 WLEP states its objectives are:
(a) to ensure that buildings are compatible with the height and scale of surrounding and nearby development,
(b) to minimise visual impact, disruption of views, loss of privacy and loss of solar access,
(c) to minimise any adverse impact of development on the scenic quality of Warringah’s coastal and bush environments,
(d) to manage the visual impact of development when viewed from public places such as parks and reserves, roads and community facilities.
5. The applicant has applied to vary the height conditions under clause 4.6 WLEP on the grounds that:
(a) compliance with the development standard is unreasonable or unnecessary in the circumstances, and
(b) there are sufficient environmental planning grounds to justify the contravention of the development standard.
6. In its clause 4.6 variation request (at A12), the applicant purports to rely upon the third test set out in Wehbe v Pittwater Council (2007) 156 LGERA 446, that “The underlying objective or purpose would be defeated or thwarted if compliance was required and therefore compliance is unreasonable”. The applicant asserts at 6.2 of A12 that, “The elements that sit above the height control, including 28 seniors living units, and primary amenity elements such as the rooftop communal space are essential for the successful delivery of the overall project. Without these elements, the development would not be delivered, which would thwart the underlying objective and purpose of delivering additional and diverse housing in the current housing ‘crisis’ of NSW.”
7. The applicant then goes on to set out the need for additional seniors housing and to compare the proposal with a theoretical “comparison scheme”.
8. It is submitted that the applicant has not demonstrated that the underlying objective or purposes would be defeated or thwarted if compliance was required. The development could be designed to have fewer independent living units whilst still providing the necessary amenity elements and without breaching the height control. A revised development would still contribute to the provision of a significant number of additional senior independent living units. The applicant has not provided any evidence that a development with fewer independent living units could not be delivered (although the applicant’s profits may be impacted.)
9. The development only proposes to contribute 10 residential care beds, bringing it within the definition of a state significant development without contributing significantly to the need in this area.
10. It is submitted that the applicant has not demonstrated that there are sufficient environmental planning grounds to justify contravening the development standard.
11. In particular, it is submitted that the significant adverse visual impact of the proposed development (see further below) clearly contravenes the stated objectives of clause 4.3 WLEP. Compliance with that development standard is not unreasonable or unnecessary. The clause 4.6 variation request should be refused.
Adverse visual impact
12. The height and scale of the proposed development is out of character for this residential area, which is zoned R2 (including within the areas opposite the proposed development on the West side of Lagoon Street and East side of Ocean Street) or R3.
13. In relation to the visual impact from Lagoon Street, it should be noted that the topography to the West of Lagoon Street slopes steeply down from street level towards the lagoon. The topographic map at 4.7 of A35 is misleading, because the colouring of the different elevation levels is not clearly differentiated. The houses on the West side of Lagoon Street opposite the proposed development are generally built at 4 – 8m, whereas the development is at 9 – 10m. This has the result that the top storey of the 2 storey houses on the West side of Lagoon Street are at around the same height as a 1 storey house on the East side of Lagoon Street. This exacerbates the visual impact of the proposed development from Lagoon Street.
14. In relation to the few and scattered existing 3 and 4 storey buildings in the vicinity (see 4.6 of A35), it should be noted that it is the short end of the buildings that are adjacent to the streets, lessening the visual impact from the street. In any event, the existence of a small number of poorly designed, older, non-height standard compliant buildings, should not be used to justify continued poor development.
15. It is submitted that the conclusions within the visual impact assessment report (A37) in relation to the visual sensitivity, magnitude of change and overall visual impact rating from different viewpoints should not be accepted. The visual sensitivity of local streetscapes has been dismissed as “negligible”; however, the current, leafy streetscapes with glimpses to the lagoon and ocean are highly valued by both local residents and visitors, who walk or cycle along the surrounding streets to use the beach or lagoon. Even clearly very sensitive areas such as the popular Narrabeen Headland Walkway with its expansive views (View 8) have been inappropriately classified as of only “moderate” sensitivity. Further, the ratings in relation to magnitude of change and overall visual impact are not supported by the diagrams of the indicative extent of the proposed development and the photomontages; it is evident from those diagrams and photomontages that there will be a very significant visual impact on the surrounding streetscape and a significant impact from more distant viewpoints. Further, it should be noted that the photomontages insert images of the proposed development in pale grey within wide angle photographs with grey skies. The visual impact of the actual building against a blue sky would be significantly greater.
16. The visual impact of the proposed development is exacerbated by the closeness of the proposed 5 – 6 storeys to the site’s boundaries and its unbroken form. Further, only the Ocean Street side has any significant landscaping on the perimeter of the site. The internal landscaping will not be visible from the street. This differs from the existing buildings on the site, where only the ends of the buildings are visible from Lagoon Street and Octavia Street with landscaped areas in between.
17. It should also be noted that the visual impact on certain individual properties, including 156 – 164 Ocean St (see A36) and the bungalow at 71 Lagoon Street, would be extreme.
18. It is submitted that overall the proposed development would have a significant adverse visual impact and the development application should not be approved in current form.
Community consultation
19. The community consultation period following publication of the development application of only 14 days is inadequate. Some community members have busy lives and will be unable to complete a submission within that time period. Others will not yet have heard about the development proposal. The 14 day period is insufficient to allow the community to spread awareness and encourage further submissions.

I object to this project due to the size and the amount of levels of this project. Building should be rebuilt at the same size it is currently