Submission of Objection – SSD-76220734 (Indigo by Moran, 156 Ocean Street Narrabeen)
To: The Secretary, NSW Department of Planning, Housing and Infrastructure (DPHI)
From: Tianah Geros – Resident & Architect, 1 Loftus 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. Context and Purpose
As both a long-term Narrabeen resident and a practising architect specialising in residential design, I write to express strong objection to the proposed Indigo by Moran development. The proposal, as exhibited, demonstrates significant non-compliance with NSW planning policy and fails to achieve the standard of design quality expected under the State Environmental Planning Policy (Housing) 2021. Its excessive height, monolithic form, and disregard for coastal constraints result in unacceptable impacts on local amenity, neighbourhood character, and environmental sustainability.
2. Legislative and Assessment Framework
This project is classified as State Significant Development (SSD) under section 4.36 of the Environmental Planning and Assessment Act 1979 (NSW). Under section 4.15 of the same Act, the consent authority must consider the relevant planning instruments, the likely impacts of the development, the suitability of the site, and the public interest. When assessed against these statutory tests, the development clearly fails to meet the necessary thresholds for approval.
3. Conflict with Statutory Planning Instruments
a) State Environmental Planning Policy (Housing) 2021 – The proposal does not satisfy design quality principles for seniors housing relating to context, scale, amenity and architectural merit. Its height and bulk are incompatible with adjoining low-density dwellings, contrary to the objectives of contextual design.

b) State Environmental Planning Policy (Coastal Management) 2018 – The site lies within the Coastal Environment and Coastal Vulnerability Areas. Excavating 11.5 metres below natural ground level directly into the water table contravenes Clauses 11 and 12 of the Coastal SEPP, which require development to minimise coastal hazard risk and maintain the natural function of the coastal zone.

c) Northern Beaches Local Environmental Plan 2011 – The proposal exceeds the intended scale and intensity of development permissible in the R2 Low Density Residential zone. The 21.5m building height is inconsistent with the LEP Height of Buildings Map and the objectives of Clause 4.3, which seek to maintain a low-rise coastal character.

d) Northern Beaches Development Control Plan 2019 – The DCP requires new development to protect adjoining properties’ access to sunlight, privacy, and outlook, and to contribute positively to streetscape character. The application breaches these standards and provides insufficient landscape setbacks and deep-soil zones.
4. Design and Technical Deficiencies Identified in the EIS
A. Solar Access and Overshadowing – The Shadow Diagrams show that the proposal casts significant shadows across adjacent dwellings between 9am and 3pm in winter. The EIS fails to provide a solar access compliance table or to demonstrate compliance with DCP Part D6 sunlight provisions.

B. Privacy and Building Separation – As an architect reviewing the plans, I note that habitable rooms and balconies directly overlook neighbouring private spaces. Setbacks of less than 10m fall well short of the Apartment Design Guide’s Objective 3F requirements of 12–18m for 5–6 storey buildings.

C. Bulk and Urban Character – The building lacks articulation, modulation, and roof variation, creating a visually dominant form inconsistent with the Housing SEPP’s Design Principles 1 (Context) and 2 (Built Form and Scale).

D. Traffic and Servicing – The Transport Assessment underestimates the operational impacts of service, visitor, and staff vehicles on the constrained local street network, exacerbating safety risks for pedestrians and residents.

E. Groundwater and Flood Risk – The proposed basement extends into the lagoon-influenced water table, introducing risks of groundwater draw-down, saline intrusion and structural buoyancy, contrary to the Coastal SEPP and Council’s Floodplain Management Study.

F. Landscape and Biodiversity – The Arborist Report identifies substantial loss of mature canopy trees that provide important habitat and shade. Replacement with planter-box vegetation fails to meet the intent of Council’s Urban Tree Canopy Strategy.

G. BASIX and Environmental Performance – The proposal only marginally meets minimum BASIX targets and lacks meaningful passive design measures. It relies heavily on mechanical systems, with poor cross-ventilation, suboptimal orientation and limited renewable energy integration, conflicting with the sustainability objectives of the Housing SEPP and DCP Section B5.

H. Construction Amenity – Extended excavation and construction will result in prolonged noise, vibration and truck movements on narrow residential streets, which is unacceptable for this locality.
5. Public Interest and Design Quality Principles
Section 4.15(1)(e) of the EP&A Act requires consideration of the public interest. This proposal fails that test. It offers limited community benefit while imposing significant social, environmental, and visual impacts. The project also fails to meet the NSW Government Architect’s ‘Better Placemaking’ and ‘Design for Aged Care’ guidelines, which emphasise human-scaled, sustainable, and contextually responsive design.
6. Requested Determination
It is therefore respectfully requested that the Department of Planning and Housing refuse consent for SSD-76220734. Alternatively, any resubmission should include:
• A reduced height and built form to align with LEP and DCP controls;
• Full compliance with ADG privacy and separation benchmarks;
• Verified no-worsening solar outcomes for adjacent properties;
• Retention and protection of mature canopy trees and expanded deep-soil landscaping;
• A robust coastal hazard and groundwater management plan;
• Genuine sustainability and BASIX improvements beyond minimum thresholds.
7. Conclusion
From both a professional and resident perspective, this proposal represents an overdevelopment of a highly sensitive coastal site. It fails to demonstrate design excellence, sustainability, or contextual fit, and does not align with the statutory requirements of the EP&A Act 1979 or associated SEPPs and LEPs. I strongly urge the Department to refuse the proposal in its current form and to uphold planning principles that protect the unique character of Narrabeen’s coastal community.

Signed,
Tianah Geros
Architect & Resident
1 Loftus Street, Narrabeen NSW 2101

Im a local resident and i reject to the proposed development it will be out of character for the suburb and will be a disaster with traffic and parking this building will look so out of place and this development should not continue

Please refer to the attached document that outlines my objections to the overdevelopment of this site.

Keep the street level as is - a 3 Storey retirement village is more than fair enough. 6 storey is far far to much

I wish to formally object to the proposed development of a Six Storey High Rise in Narrabeen at 156 Ocean Street. While I understand the need for sustainable housing growth, this proposal raises serious concerns regarding its impact on the local community and environment.
Our Narrabeen doesn’t need this development and I believe it will completely destroy the atmosphere in which we have created over the years.

I am concerned about this project for the following reasons:

1. LACK OF LOCAL CONSULTATION AND RELEVANCE: This development should not be classified as a 'Significant Development' as it is far from being affordable housing, and is instead yet another cash-grab by a greedy developer. Bypassing council and fast-tracking the project and demonstrating no regard for local residents is unreasonable.

2. POOR PLANNING AND DESIGN AND OVERDEVELOPMENT: The scale of the project is intrusive and not in keeping with the area. It will block views for many existing residences and exacerbate already congested traffic and parking problems. The lack of set-back from the street/footpath makes the building imposing and will create a lack of green-space.

3. ENVIRONMENTAL AND CLIMATE-CHANGE IMPACT: The removal of mature pine and gumtrees not only ruins the streetscape, but destroys crucial nesting habitat for native birds and possums and diminishes carbon capture. The loss of canopy adds to an already warming planet. The scale and depth of the project will disrupt the fragile sandy soil and water table. Not only are the above an immediate concern, imagine the impact multiplied across the peninsula once the precedent is set.

I am not against them developing this site, but please limit it to 2-3 storeys, set it back from the street, review architecture and design so that it is attractive, organic and inclusive. And most importantly, ensure that it retains and adds native flora and habitat for local wildlife – including green space and shade for humans.

On an overarching note:
– if we want to build affordable housing, perhaps government needs to be manage it themselves instead of handing the reigns to developers who are just in it to make a profit.
– perhaps we need to look at decentralising instead of jamming everyone into Sydney, and spoiling our unique and beautiful suburbs.
– invest in proper town planning instead of adhoc, poorly designed buildings, erected by greedy behemoths, that lead to disjointed, ugly suburbs.

Thanks

This building is way too big for the Narrabeen peninsular, the area cannot cope with the extra traffic and people.
It will be an eyesore towering above all other units and houses in the street.
I ask the developers go back to the design and make it fit in with the area.
I strongly object to this project

I am writing to formally object to the proposed development on Ocean Street, Narrabeen.

This development is not in keeping with the existing character and scale of the area, which is primarily made up of low-rise residential properties that reflect Narrabeen’s coastal village atmosphere. The proposed height, bulk, and density of the project would significantly alter the visual appeal and community feel of the neighbourhood.

In addition, traffic congestion is already a serious issue in the surrounding streets, particularly along Ocean Street and Pittwater Road. The existing road infrastructure is struggling to cope with current volumes, especially during school drop-off times, weekends, and peak commuter hours. The additional vehicle movements generated by this development—both during construction and once operational—will only worsen these conditions, compromising road safety and accessibility for residents and pedestrians alike.