My family and I are local residents who frequent Narrabeen beach. The parking at Narrabeen beach, along Ocean st and on all surrounding streets is already completely inadequate and in Summer it’s near impossible to get parking anywhere in the area.
The streets around the proposed development sight are popular for kids riding bikes, school kids walking, and people crossing back and forth to the beach, so we’re very concerned about the dangers of adding all these extra cars and increased traffic.
The current building height limit in the area is 9m and the proposed 25m is almost 3 times higher than this. This is completely out of character of the neighbourhood and will be an eye sore.

To whom it may concern,
I write to express my objection to proposed project SSD- 76220734- 156 Ocean street. I have lived in Narrabeen my whole life and am concerned about the negative impact that this development will have on the area. Personally we live within a block of the proposal with young children who ride their bikes and scooters along these streets. We are extremely worried about the negative impact this will have with increased traffic and large driveways creating unsafe conditions within the area for our children. This area does not have the infrastructure to support such a large development with already very limited parking and crowded narrow streets which are already at capacity with blind spots around driveways. If this proposal goes through as planned it will set a precedent for other large projects which will further destroy the area. This proposal is at least double the height of any of the surrounding buildings which is going to impact privacy, create significant shadowing across the surrounding area and standout like a massive eye sore.

To Whom It May Concern,
I strongly oppose the proposed Indigo by Moran seniors’ housing development at 156 Ocean Street, Narrabeen.
I am a local firefighter stationed at Narrabeen Fire Station, and I am deeply concerned about the implications this development will have for local residents, emergency services, and community safety.
1. Flooding and Coastal Hazard Risks
The proposed site lies within a known flood-prone and coastal erosion hazard area, as outlined in the EIS Appendices E & F (Flood and Coastal Hazard Reports). The development footprint extends into zones identified as high hazard under the Northern Beaches Council Flood Study and Coastal Zone Management Plan.
Given this, the proposal presents an unacceptable risk to both emergency service personnel and future residents, particularly as it is intended for an elderly demographic.
During even moderate rainfall, both Pittwater Road and Wakehurst Parkway are known to flood and close, isolating Narrabeen and cutting off access to Northern Beaches and Royal North Shore Hospitals.
This area is regularly subject to evacuation orders under State Emergency Service (SES) flood rescue protocols, with particular focus on the evacuation of high-care and vulnerable populations—precisely the demographic targeted by this proposal.
While the EIS acknowledges these risks, it fails to propose adequate mitigation strategies beyond basic floor height adjustments. Such limited measures do not address Narrabeen’s growing exposure to coastal erosion, sea-level rise, and storm surge events, and the proposal is therefore inconsistent with sustainable coastal planning principles.
2. Traffic, Parking, and Access Concerns
The Traffic and Parking Assessment (EIS Appendix J) substantially underestimates the likely volume of vehicle movements and parking demand generated by residents, staff, service vehicles, and visitors.
Ocean Street and Lagoon Street are already heavily congested, especially during weekends and local events. Adding a large seniors’ living complex will further:
Exacerbate traffic congestion
Reduce pedestrian and cyclist safety
Impede emergency vehicle access
These surrounding streets are narrow and not designed to handle the anticipated increase in traffic or parking demand associated with such a large-scale development.
3. Lack of Community Benefit and Character Impact
This proposal primarily serves a single demographic—wealthy retirees—and offers no benefit to the broader community struggling with housing affordability. It fails to address the pressing need for affordable housing for nurses, teachers, police officers, skilled tradespeople, and low-income workers.
From a personal and community perspective, the proposed development is out of character with the local area, inconsistent with its coastal village identity, and appears to be driven by commercial profit rather than community need.
In summary, I strongly urge Council to reject this proposal on the grounds of:
Severe and unmitigated flood and coastal hazard risks
Inadequate traffic and access planning
Lack of community benefit or social diversity
Inconsistency with local character and sustainable development objectives
Thank you for considering my submission.
Kind regards,

I feel developments like this are beneficial to the community as they free up housing that families can then purchase. They encourage the over 60's to be involved with like minded people which keeps them active and feeling valued. They provide a secure home which in turn gives families peace of mind.

I object to the proposal on the following grounds:
1. The location is unsuitable for large scale development being in a coastal erosion zone on a narrow peninsula. It will threaten the fragile dune system.
2. The proposed three story car park will be below the water table risking not only this development but surrounding homes.
3. The traffic impact will be disastrous for the local community as there is only one narrow road in and out of the location to exit the peninsula.
4 Narrabeen is not a city centre and has limited amenities, not even a local doctor, so residents would be forced to use their cars or other transport for basic amenities.
5.The development is overwhelming for a narrow peninsula.
6. The development is unaffordable to most and is simply a luxurious high end development for the benefit of a privileged few to the detriment of the locals and essential workers.

It’s a complete over development of the area and the infrastructure will not cope. Less parking, more people, cars and traffic in an already overpopulated suburb. Not to mention the ridiculous height of this eyesore. Listen to the people. What has happened to our beautiful Northern Beaches?

This development goes 100% against our community values, 3 years of construction and 100 years of an eye sore is not what alines with community needs or wants, zero consultation with home owners or community groups/ organisations
The size of this mega structure would create a shade shadow which will rob residents of vital sunshine, which is the life blood of living by the beach
The environmental impact with be devastating to the local bird life which live in and around the address intended for construction not to mention the impact to the local roads which includes local schools and community clubs
This is the most unreasonable proposal of development I’ve heard of in my 55 years of life and I will definitely not be voting for this government next election
I only hope this proposal can be reduced to an appropriate 3 story level
Cool heads prevail

I am writing as a resident of Narrabeen to express my strong objection to the proposed six-storey development "Indigo by Moran". While I understand the need for thoughtful development to accommodate population growth, this proposal is wholly inappropriate for our community, for the character of Narrabeen, and for the environmental and cultural integrity of the Northern Beaches.

1. Exceeds established height limits
Narrabeen has a clearly defined 11-metre height restriction for good reason, to preserve the low-rise coastal character of the suburb and maintain harmony with the natural landscape. A six-storey building dramatically exceeds this limit and would undermine years of careful planning and community consultation.

2. It's out of character with Narrabeen
This proposal is not in keeping with the area’s relaxed coastal identity. Narrabeen’s charm lies in its human scale — a village feel framed by the lake and ocean. A large, high-density development would stand out as an eyesore and erode the character that defines our community.

3. Dangerous precedent
Allowing a single developer to bypass local controls through the State Significant pathway would set a damaging precedent, inviting further high-rise projects and permanently altering the skyline and livability of Narrabeen, casting shade over homes, beaches and public spaces. We already have to live with the repercussions of decisions made in the 70s where high-rise buildings were approved along the beach front. Approval of this project is a pathway towards more visual eye-sores.

4. Community impact
The development would place additional pressure on already limited infrastructure — roads, parking, and public amenities, and most of all, public transport which is in dire need of improvement — without contributing meaningfully to local needs or the environment.

5. Conclusion
This proposal is inconsistent with local planning controls, out of step with the community’s vision, and detrimental to the identity of Narrabeen. I urge the Department to reject this application and uphold the 11-metre height limit that protects the area’s unique character.

Sincerely,
Tim French
Resident of Narrabeen, NSW

Submission: Objection to SSD-76220734 – Indigo by Moran, 156 Ocean Street Narrabeen
To: The Secretary, NSW Department of Planning, Housing and Infrastructure (DPHI)
From: Jade Geros – Resident, 1 Loftus Street, Narrabeen NSW 2101
Date: 2 October 2025
Project: SSD-76220734 – Seniors Housing (Indigo by Moran)
Site: 156–164 Ocean St / 81–81A Lagoon St / 8 Octavia St, Narrabeen

1. Introduction & Local Context
I am a lifelong resident of Narrabeen and currently reside at 1 Loftus Street, immediately adjacent to the proposed site. Having lived in the area my entire life, I have an intimate understanding of its coastal character, flood vulnerabilities, and the lifestyle balance our community values. I strongly oppose the proposed 'Indigo by Moran' development due to its incompatibility with the established planning framework, excessive scale, and potential to cause lasting environmental, amenity, and infrastructure impacts.
2. Statutory Framework
The proposal is declared State Significant Development (SSD) under Section 4.36 of the Environmental Planning and Assessment Act 1979 (EP&A Act). Accordingly, assessment must be undertaken in accordance with Section 4.15 of the EP&A Act, having regard to: (a) relevant environmental planning instruments, (b) the likely environmental and social impacts of the development, (c) the suitability of the site, and (d) the public interest. Despite its SSD classification, the proposal must still demonstrate compliance with these statutory principles.
3. Inconsistencies with Key Planning Instruments
a) State Environmental Planning Policy (Housing) 2021 – Seniors housing must be designed for context and amenity. This development fails to achieve those standards, with excessive building height and inadequate transition to surrounding low-density residential dwellings.

b) State Environmental Planning Policy (Coastal Management) 2018 – The site lies within the mapped Coastal Environment and Coastal Vulnerability Areas. The proposed 11.5 m basement excavation into the water table conflicts with the SEPP’s precautionary approach to managing coastal hazards and flooding risk.

c) Northern Beaches Local Environmental Plan (LEP) 2011 – The proposal breaches the height and FSR objectives under Clauses 4.3 and 4.4 and is inconsistent with the R2 Low Density Residential zone intent to preserve low-rise character along the Narrabeen peninsula.

d) Northern Beaches Development Control Plan (DCP) – The design fails to comply with DCP objectives requiring protection of neighbouring amenity, solar access, privacy, and landscape character.
4. Deficiencies in the Exhibited Environmental Impact Statement (EIS)
A. Overshadowing & Solar Access – The exhibited shadow diagrams show significant off-site overshadowing between 9 am and 3 pm during mid-winter. This results in a measurable loss of sunlight to adjoining private open spaces, inconsistent with the DCP’s solar access objectives.

B. Visual Privacy & Building Separation – Upper-level apartments and terraces overlook nearby backyards and dwellings. Separation distances fail to achieve the Apartment Design Guide (ADG) benchmarks for 5–6 storey buildings (12–18 m minimum between habitable rooms and balconies).

C. Bulk, Scale & Character – At 21.5 m, the proposal exceeds the scale envisaged by the LEP. It introduces a monolithic, continuous façade that overpowers surrounding single and two-storey coastal dwellings, altering the visual identity of the area.

D. Traffic, Access & Servicing – The EIS underestimates daily vehicle movements from residents, staff, and service deliveries. Ocean, Lagoon, and Loftus Streets are narrow and ill-equipped to handle additional congestion, compromising pedestrian and cyclist safety.

E. Groundwater, Flooding & Coastal Hazard – The Flood and Coastal Hazard Reports confirm high groundwater vulnerability. However, the EIS lacks a comprehensive mitigation strategy to address dewatering, saline intrusion, and potential subsidence risks during excavation.

F. Tree Canopy & Biodiversity – The Arboricultural Impact Assessment identifies the removal of over 30 mature trees. Replacement planting on rooftops or within planters will not provide equivalent shading, habitat, or stormwater management benefits. The DCP’s Urban Tree Canopy targets are therefore not met.

G. Construction Amenity – Prolonged excavation and construction works will generate unacceptable noise, vibration, dust, and truck movements in a quiet residential area, significantly impacting neighbouring residents for an extended duration.
5. Public Interest (EP&A Act s 4.15(1)(e))
The proposal offers no tangible public benefit or affordable housing contribution. Instead, it delivers a private, high-end development that imposes long-term environmental and amenity costs on the Narrabeen community. The development does not align with State planning objectives for sustainable, resilient, and context-appropriate growth.
6. Requested Determination
I respectfully request that the Department of Planning, Housing and Infrastructure:

1. Refuse SSD-76220734 on the basis of non-compliance with the EP&A Act 1979, Housing SEPP 2021, Coastal SEPP 2018, and the Northern Beaches LEP/DCP; or
2. Require a major redesign that includes:
• Reduction in height, bulk, and FSR;
• Setbacks meeting ADG visual privacy and solar access requirements;
• Deep-soil zones and retention of mature trees;
• Verified groundwater and coastal hazard mitigation strategies; and
• Comprehensive traffic, parking, and construction management plans.
7. Conclusion
As a lifelong Narrabeen resident, I urge the Department to uphold the intent of NSW planning policy and protect the character, safety, and amenity of the Narrabeen peninsula. This proposal is inconsistent with both the letter and spirit of the planning framework that governs coastal protection, urban character, and community well-being.

Signed,
Jade Geros
Resident – 1 Loftus Street, Narrabeen NSW 2101

I wish to formally object to the proposed six-storey over-60s residential development in Narrabeen for the following reasons:

1. Incompatible Building Height and Character
The proposed six-storey luxury complex is entirely inconsistent with Narrabeen’s established low-rise character. Its bulk and scale disregard the area’s environmental setting, existing streetscape, and community values. The development would dominate the local skyline and set an undesirable precedent for future high-density projects in an area not designed for such intensity.

2. Insufficient Resident Parking
The proposed 178 resident parking spaces are significantly inadequate. Based on the mix of apartments—46 three-bedroom, 59 two-bedroom with study, and 44 two-bedroom units—the realistic parking demand would exceed 240 spaces.
• 46 × 2 cars = 92 spaces
• 59 × (90% with 2 cars + 10% with 1 car) = approximately 112 spaces
• 44 × 2 cars (50%) = 44 spaces
This results in an estimated shortfall of around 70 spaces. Residents will inevitably use surrounding streets, where parking is already extremely limited, worsening congestion and safety issues.

3. Inadequate Parking for Aged Care Staff
Only three parking spaces are proposed for the 10-bed care facility staff. This is unrealistic, especially at shift change times when multiple staff members will be on-site. These vehicles will likely spill into residential streets, further straining the already overburdened parking supply.

4. Lack of Parking for Support and Maintenance Staff
The development fails to account for the parking needs of administrative, programming, maintenance, and trades staff who will service the complex regularly. With no allocated spaces, these vehicles will also rely on scarce street parking.

5. Reduced Aged Care Capacity
The proposal significantly reduces the site’s contribution to aged care, replacing the existing 55-bed facility and 35 assisted living units with only 10 care beds. This reduction removes vital local aged care options and increases demand for similar facilities elsewhere on the Northern Beaches.

6. Misuse of Seniors Housing Provisions
The proposal appears to exploit the over-60s housing planning provisions to gain approval for a large luxury development that would not otherwise comply with local planning controls. The State Government has designated Brookvale, Dee Why, Mona Vale, Manly Vale, and Forestville as suitable areas for higher-density housing. Narrabeen is not one of these zones and lacks the infrastructure to support this scale of development.

7. Unacceptable Precedent for Future Development
Approving this project risks setting a precedent that invites similar developments to bypass planning controls by labelling high-end apartments as “seniors living.” This would undermine local planning integrity and community expectations.

8. Lack of Genuine Community Consultation
The developer has not engaged in meaningful consultation with local residents. Community questions have been avoided, and feedback has not been transparently addressed. This lack of collaboration demonstrates disregard for local concerns and undermines community trust.

9. No Affordable or Community Housing
The development provides no affordable or accessible housing options. It caters exclusively to a luxury market, offering no benefit to local residents or key workers who are already priced out of the area.

10. Environmental and Water Table Concerns
The inclusion of a three-level underground car park raises serious concerns about impacts on the local water table, potential flooding risks, and damage to nearby properties. Given Narrabeen’s low-lying coastal environment, these issues warrant thorough investigation before any consideration of approval.

⸻

This proposal is inappropriate in height, scale, and intensity for Narrabeen. It will worsen parking and traffic pressures, reduce aged care availability, and erode the character of the local community. The lack of affordable housing, inadequate consultation, and potential environmental impacts further highlight that this development does not serve the public interest.

I therefore respectfully request that NSW Government refuse the development application in its current form.