Dear Secretary,



I am writing to formally object to the proposed development at 156 Ocean Street, Narrabeen (SSD-76220734).



As a long-term local resident of the Northern Beaches who drives along this street daily, I am extremely concerned about the scale, height, and overall inappropriateness of this proposed development within our residential community.



1. Excessive height and inconsistency with R3 zoning

The proposed building significantly exceeds the 8.5-metre height limit applicable to the R3 Low Density Residential zone. Such a height is entirely inconsistent with the established character of Ocean Street and its surrounding homes. Approving this development would undermine the integrity of the local planning controls that were designed to preserve the low-rise, coastal character of Narrabeen.



2. Out of scale with the surrounding area

The bulk and size of this proposal are not consistent with anything else in Narrabeen. This suburb has always been known for its village atmosphere and community feel, unlike nearby areas such as Dee Why where large apartment towers dominate. This development would visually and socially erode the charm that makes Narrabeen unique.



3. Overdevelopment and precedent for future density

This project represents clear overdevelopment of a small residential site and raises genuine concern that, if approved, it will set a dangerous precedent for similar high-density projects in areas not zoned or suited for such intensity.



4. Parking and local infrastructure strain

On-street parking is already scarce in this part of Narrabeen, particularly during weekends and holidays. The addition of a development of this scale will worsen congestion and parking pressure on local residents and visitors.



5. Removal of established native trees

The proposed clearing of several mature native pine trees is deeply troubling. These trees contribute to the environmental and visual character of the area and provide habitat for native wildlife. Their removal would represent a permanent loss to our local ecosystem.



6. Questionable classification and use of loopholes

It appears the developer is attempting to use a loophole to classify this as a “health facility” despite the inclusion of only ten beds. This is hardly consistent with the intent of a genuine health facility classification and appears to be a means to bypass standard local planning restrictions.



7. Inadequate community consultation

On behalf of the local community, I wish to express disappointment at the lack of proper consultation with residents and nearby businesses. My understanding is that developers are required to engage meaningfully with the community prior to submission, yet many locals were unaware of the proposal until late in the process.

Furthermore, it is unclear why the public exhibition period was shortened from 28 days to 14 days, reducing the community’s ability to respond. This decision appears to be another loophole that disadvantages residents and limits fair participation.






In summary, this proposal is inappropriate in height, scale, and use for its location. It threatens to disrupt the established character of Narrabeen, worsen local parking and congestion, and erode the trust between residents and the planning system.



I respectfully urge the Department to refuse approval of SSD-76220734 and ensure that Narrabeen retains its coastal, community-oriented identity.



Thank you for your attention to this matter.



Kind regards,

Sheridan Raphael
Northern Beaches Resident

I wish to lodge an objection to the proposed development being progressed by Retirement by Moran (Indigo by Moran) at 156 Ocean Street, Narrabeen. My objection is submitted in my capacity as an owner‐occupier residing in Ocean Street and reflects concerns relating to the scale, impact and process of the proposal.

Grounds of Objection

1. Excessive scale and out of character
The proposal for a 5–6 storey building with 149 units and extensive basement parking is significantly larger than the existing built context and out of scale with the rest of Ocean Street. Such scale risks overwhelming the coastal, open feel streetscape of Ocean Street and setting an undesirable precedent for the neighborhood.

2. Loss of light, privacy, views and character
The building’s height and bulk will block sunlight, reduce privacy and interrupt views for nearby homes. The visual dominance of such a large structure may reduce the open character of the area and impact on the “beachside village” feel of Narrabeen. It goes against the sense of space and light that makes this part of Narrabeen so special.

3. Traffic, parking and local infrastructure pressure
With its size and basement carparks, this project would bring much more traffic, both during construction and once residents move in. Ocean Street is already a busy area, and extra cars, service vehicles and visitor parking demand will make things worse for everyone living here.

4. Construction disruption and noise
A large‐scale development of this sort will generate major construction impacts, including noise, dust, vibration, heavy vehicle movements and prolonged onsite works.

From what I’ve seen and heard, there has been little genuine consultation with local residents. Many in the community feel that their concerns about height, traffic and neighbourhood character have not been properly heard or addressed.

While I recognise that providing more housing options for older Australians is a valid goal, this proposal is too large, too dense and too out of place for this part of Narrabeen and gives rise to significant adverse impacts for nearby residents, the local streetscape, amenity and character of Narrabeen. It risks permanently changing the look and feel of our neighbourhood and reducing the quality of life for existing residents. For those reasons I respectfully submit that approval should either be refused or only granted subject to substantial modifications.

Submission of Objection – SSD-76220734 (Indigo by Moran, 156 Ocean Street Narrabeen)
To: The Secretary, NSW Department of Planning, Housing and Infrastructure (DPHI)
From: Darren Geros – Resident & Property Owner, 1 Loftus Street and 143 Ocean Street, Narrabeen NSW 2101
Date: 2 October 2025
Project: State Significant Development – Indigo by Moran (Seniors Living)
Site: 156–164 Ocean St / 81–81A Lagoon St / 8 Octavia St, Narrabeen
1. Personal Context and Community Concern
My family have lived in Narrabeen for multiple generations and I own two nearby properties—my family home at 1 Loftus Street and another residence at 143 Ocean Street—both within direct proximity to the proposed Indigo by Moran site. As a long-standing local resident, I am deeply concerned by the excessive scale, lack of transparency, and minimal consultation associated with this application. This proposal represents an overdevelopment that would permanently alter the character, livability, and environmental integrity of our peninsula community.
2. Statutory Framework and Assessment Responsibilities
The development is declared State Significant Development (SSD) under section 4.36 of the Environmental Planning and Assessment Act 1979 (NSW). Despite its SSD status, the Department must still apply the section 4.15 evaluation criteria, which require consideration of:
• consistency with environmental planning instruments;
• likely environmental, social, and economic impacts;
• the site’s suitability for the proposed use; and
• the broader public interest.
In its current form, the application demonstrably fails to satisfy these obligations.
3. Non-Compliance with Applicable Planning Instruments
a) State Environmental Planning Policy (Housing) 2021 – The proposal fails to meet the design and amenity principles outlined for seniors housing, particularly those relating to contextual integration and resident comfort. The excessive bulk and height do not align with the surrounding low-density residential fabric.

b) State Environmental Planning Policy (Coastal Management) 2018 – The site sits within both the Coastal Environment and Coastal Vulnerability Areas. The 11.5-metre-deep excavation penetrates the water table, breaching Clauses 11 and 12 which mandate a precautionary approach to managing coastal hazards.

c) Northern Beaches Local Environmental Plan 2011 – The proposed 21.5m height conflicts with Clause 4.3 (Height of Buildings) and the objectives of the R2 Low Density zone, which aim to preserve the low-scale coastal character.

d) Northern Beaches Development Control Plan 2019 – The development breaches provisions concerning solar access, visual privacy, and landscape character. Loss of mature canopy vegetation contradicts Council’s Urban Tree Canopy Strategy and the environmental objectives of Part D6 of the DCP.
4. Deficiencies in the Environmental Impact Statement (EIS)
A. Incomplete and Misleading Information – The EIS omits or misrepresents key data relating to traffic generation, overshadowing, and flooding. Several reports rely on broad assumptions that understate the true extent of the project’s impacts on neighbouring properties and the environment.

B. Minimal BASIX Compliance – Sustainability documentation shows that BASIX targets are only marginally achieved. There is no evidence of passive solar design, natural ventilation strategies, or meaningful water reuse measures, contrary to Clause 3.6 of the Housing SEPP and DCP Section B5.

C. Traffic and Safety – The local road network is already constrained. The submitted Traffic Impact Assessment does not accurately model the cumulative effects of resident, staff, and service-vehicle trips during peak times.

D. Groundwater and Flooding – Deep excavation within a flood-prone coastal site is inconsistent with the Coastal SEPP’s requirement for a precautionary approach to development in hazard-prone areas.
5. Procedural and Governance Concerns
A. Lack of Community Consultation – There has been no meaningful consultation with the local community. Residents were not informed or engaged prior to lodgement, undermining public confidence in the planning process.

B. Inadequate Public Exhibition Period – The public submission window was unreasonably short given the scale and complexity of the project. A two-week period is insufficient for residents to review more than 40 EIS attachments and technical studies.

C. Absence of an Independent Design Review Panel – The lack of an independent design review process is concerning. An IDRP should have been convened for a development of this magnitude to ensure objective design scrutiny and accountability.

D. Precedent and Cumulative Impact – Approving a structure of this scale would set a dangerous precedent for future developments along Ocean Street and the Narrabeen Lagoon corridor, threatening the established character of the Northern Beaches.
6. Public Interest and Planning Principles
Under section 4.15(1)(e) of the EP&A Act 1979, planning authorities must act in the public interest. This proposal does not deliver affordable or environmentally responsible housing and serves primarily private commercial interests. It fails to align with the objectives of the Housing SEPP 2021, the Coastal SEPP 2018, and the Northern Beaches Community Strategic Plan 2040.
7. Requested Determination
I respectfully request that the Department:
1. Refuse SSD-76220734 due to its non-compliance with the EP&A Act 1979, Housing SEPP 2021, Coastal SEPP 2018, Northern Beaches LEP 2011, and DCP 2019; or
2. Require a comprehensive redesign that:
• Reduces height, scale, and excavation depth;
• Improves BASIX and sustainability outcomes;
• Demonstrates no-worsening overshadowing or privacy impacts;
• Retains and protects existing trees and deep-soil landscaping;
• Is subject to review by an Independent Design Review Panel; and
• Undergoes renewed community consultation with an extended exhibition timeframe.
8. Conclusion
As both a resident and property owner directly affected at 1 Loftus Street and 143 Ocean Street, I strongly oppose this proposal. It represents an over-scaled and environmentally risky development that is inconsistent with the established planning framework and contrary to the public interest. I urge the Department to refuse the application in its current form to preserve the integrity, character, and safety of the Narrabeen community.

Signed,
Darren Geros
Resident & Property Owner
1 Loftus Street and 143 Ocean Street, Narrabeen NSW 2101

I strongly object to building such a large multi Storey development in North Narrabeen. The traffic around Ocean Street is bad enough. If you add a six or more story building it is going to be absolutely ridiculous. I strongly object.

I object to this project as it is way out of developments in the surrounding area, it will tower above the suburb and cause a massive impact on traffic flow in an already very busy area. It will further impact the environment of the surrounding beach area.

This is not a development for the community’s best interests, it is a development for the profits of the developer.

As a lifelong member of the 2101 community, I am writing to express my strong opposition to this project which is out of character with the local community and I believe will have a detrimental impact on our local area.
The proposed development is simply too large for our area. As some of the local opposition notices say- this is Narrabeen NOT Dee Why. There is a height restriction of the existing houses and units which gives a sense of openness and enhances the local environment. The proposed development to be located on Lagoon, Ocean and Octavia Streets is out of character with the surrounding housing. Those streets do not have 5/6 storey unit blocks. It is uncharacteristic for those streets. My concerns relate not only to the aesthetics of the site but the increase in population density would lead to increased traffic congestion and have a detrimental impact on the surrounding houses/units.
If this development is approved it will set a precedent for future higher rise/multi-storey developments and will change the face of Narrabeen.
I strongly urge you to reconsider this proposed housing development.
Kind regards
Vanessa Cheeseman

I object to te project in its present form for the following reasons:
1/ the over-development as a six-storey complex with so many units is certainly not consistent with the local beachside area, and I am unsure why this type of development is entitled to not obey the local rules as other developments have to.
2/ the visual impact is overwhelming for the surrounding streets by the overall height, maybe 4 storeys would surfice and a reduction in the number of units to suit. (I agree we do need extra retirement sites in the area, so can agree to a smaller scale going ahead)
3/ The traffic implications of an addittional 300 people to the site, is also a cause for concern. I have lived on Ocean Street for 47years and seen great changes occur, but this is just so out of character for the street.
We already have traffic issues with it being used as a alternate run , so as to miss 7 sets of traffic lights on Pittwater road,
last Thursday I waited 10minutes with my dog to just cross the road outside my house, there was just so much through traffic, and we cannot cope with any extra.
I would love to see a much smaller scale project go ahead, consistant with heights already in place, not 6 stoteys, it will look so out of place no matter how well designed it will be.
I feel they are being a little greedy!!!

I live in the street and the current traffic conditions are not only busy but are dangerous for the amount of families and children with the increased traffic flow.
This type of development is too high for the area and will detract from the current buildings
It should be no more than 3 levels high.

I have serious concerns about the lack of appropriate time frames for consulting the residents and the lack of detailed consideration of the environmental and psychological consequences of the project.