Objection to Proposed Development – Over 55s Housing (5 Storeys, 3 Basement Levels, Height 21.1m)

1. 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 of two to three storeys

A five-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.

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 monolithic structure that dominates its surroundings rather than integrating sensitively with them

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

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. LMR Stage 2-2025

On the Northern Beaches, the new State Government LMR controls apply to all residential zoned land within 800 metres walking distance of:
• Balgowlah Stockland Shopping Centre
• Dee Why Town Centre
• Forestville Town Centre
• Forestway Shopping Centre
• Frenchs Forest Precinct (Warringah Road)
• Manly Town Centre
• Manly Vale Town Centre
• Mona Vale Town Centre
• Warringah Mall Shopping Centre

Following Northern Beaches Council submissions, four town centres that had originally been proposed to be included in the Stage 2 Reforms have been excluded: Warriewood, Narrabeen, Newport and Belrose.

The zones were excluded after significant community consultation and objections over the density and height changes in these four areas which was ultimately accepted by the State demonstrating acceptance of the submissions including that Narrabeen should not be part of the Stage 2 Reforms. The reforms introduced increased heights for developments up to 21 metres.

The application by Moran seeks to impose on Narrabeen a development at heights that are available under the Stage 2 Reforms where this area has been excluded from the Stage 2 Reforms. It is not appropriate to permit a 5 level development that will be almost double the permissible height for buildings in the area. It seeks an unfair advantage and a use that is significantly beyond that available to others in the community.

11. Lack of consultation

As a nearby resident I have received no notice of the development by correspondence or letter drop which brings into question the effectiveness of the public consultation.

The Development Application should not be considered until the State is satisfied there has been adequate and appropriate consultation and everyone that will be affected by the development has been consulted, has had an opportunity to make submissions after understanding the nature of the proposed development and have had the opportunity to object to the development.

12. 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 and traffic impacts

The application represents an over-intensification of the site and should therefore be refused.

If the State 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.

The project would change the area into a high density with high rise buildings.
Affecting the life style and the value of the properties in the area.
There are areas where the proposed construction would be better suited.

This project completely ruins the neighbourhood. The roads on the Narrabeen peninsula are already over congested, as is the beach. There is simply not enough infrastructure to support this project.

the project will far exceed area height restrictions and be an eyesore in the neighbourhood, and that's just once it's built.

The construction process will make it nightmarish for the existing residents to commute along Ocean St.

definitely not in Narrabeen

Major Projects

Dear Paulina Wythes,

The project does not comply with the current building height limits and maximum footprint of building in relation to the site.

Private property development by the Moran family does not constitute a State Significant Development. If this is a loophole for private developers to by-pass local council building regulations, then it must be stopped immediately.

Regards,
Thomas Hayes

I wholeheartedly reject this proposal. Residents do not support this. Parking, roads and infrastructure already cannot keep up. The community says no to the high rise and expansion of this project. We only support the current number of dwellings and people.

As long-term residents of this neighborhood, we have had the former seniors living accommodation as direct neighbours and agree that this site is a good location for a future senior accommodation redevelopment, however, we object to the proposed development size.
The bulk, scale, density, and height of the proposed development is excessive and does not align with the established or desired future streetscape character of the area.
There is no reason, unique or otherwise, why a fully compliant solution to Development Standards and Controls cannot be designed for this site. The proposed development represents an overdevelopment of the site and an unbalanced range of amenity loss impacts that result in adverse impacts on our neighbouring property. There is considerable amenity loss to our home due to the inadequate setbacks and over height proposal. The proposed building height of 21.1m represents an 8.8m or 71.5% departure from the Development Standard with Bonus Provisions [8.5m + 3.8m]. This is totally unreasonable in an 8.5m LEP HOB zone. The proposal is approximately 8,586sqm GFA in excess of HOB control, representing 39% of the proposed GFA, and representing 58 apartments of the proposed 149 apartments. The proposal is contrary to Section 4.15(1)(a)(iii) of the Environmental Planning and Assessment Act 1979 as it will have unacceptable impacts upon the amenity of our property, specifically with regard to solar access and excessive overshadowing by the non-compliant built form. The application shadow diagram does not include the large north facing window in our living room which currently receives full sun all day in winter but it is proposed to be completely without sunlight all day in winter. This is a completely unacceptable loss of amenity and against the application standard of 2 hours of sunlight per day. The loss of privacy from this over height proposal is severe, the increased noise pollution from this high and close proposal is severe, the visual impact of this proposal from our home is severe, and the increased light spill pollution from this high and close proposed development is severe.
In the applicant’s Site Isolation Advice document point 3, it states ‘Indigo is committed to continue to work collaboratively with adjoining property owners including discussing and implementing design measures to minimise adverse impacts on the neighbouring site’s amenity and future development potential’. There was no consultation with us prior to exhibition. There has been no negotiation with us prior to exhibition.The proposed development results in an encroachment beyond the prescribed building envelope. This non-compliance is indicative of an unacceptable built form and contributes to the severe amenity loss.
The design fails to comply with the building envelope measured at the side boundary. A significant proportion of the upper levels of the proposed development falls outside this building envelope. Together with the breach of the height limit, the building
envelope breach will result in view loss, excessive bulk and scale, and significant visual impact.
For these reasons, we object to the proposed development's bulk, scale, height, density and the fact that it is not in character with our neighbourhood. Changes need to be made to ensure it meets SEPP.
We request amended plans to be submitted to better address impacts upon our property. We ask The Department to seek modifications to this SSDA as the proposed development does not comply with the planning regime, by non-compliance to
standards and controls, and this non-compliance leads directly to amenity loss to our property. A compliant building design would reduce the amenity impacts identified.

Secretary, DPHI, and reference the project clearly: Objection to SSD-76220734 – 156 Ocean Street Narrabeen.
I live on Wellington St (near Ocean St.) Narrabeen, only a few streets down from this proposed development on Ocean St. Myself and my family regularly use Ocean St as a main route in and out of the area. This development is a major overdevelopment for the area, creating substantial additional traffic on streets that are already overused due to congestion on other roads. As well as causing extensive traffic difficulties it is a real danger to kids and other pedestrians who use this road as a key access point to the beach. Parking is already a major issue in the area and this will increase that proble dramatically. Finally, the actual size of this proposed development is out of character for developments within the Narrabeen area.
I request that the State Department of Planning do not allow such development in this area.

High rise apartments do not belong in Narrabeen. If one goes up, it is inevitable that more will and we will end up like Dee why. There are already issues with street parking and congestion on ocean street.

Submission attached objecting to the design of the development