I am writing to formally object the proposal on the basis that the proposed five-storey building is out of scale with the existing and historical built form of the area, and raises serious concerns about precedent, amenity, neighbourhood character and cumulative impacts.

1. Out of scale with existing built form and neighbourhood character
The Proposal seeks to replace a current two‐storey building with a five‐storey seniors living development. In contrast, the prevailing building heights in the locality of Narrabeen – especially along Ocean Street and surrounding mid-rise zones – are predominantly two to three storeys. A five‐storey building would markedly exceed the scale, creating a visually dominant form inconsistent with the character of the area.

Such a jump from two to five storeys would cause the building to dominate the streetscape and interrupt the relatively low-rise rhythm of Ocean Street, cast overshadowing to neighbouring properties and to the public domain (footpath, street, open space) and would increase visual bulk and massing, reducing vistas and openness that currently exist.

2. Precedent risk for other developments
Allowing a five‐storey development in this zone will inevitably establish a precedent that encourages other developments to seek similar heights. Once a five‐storey building is approved, it becomes very difficult to resist future applications seeking the same height or higher. This could lead to a gradual erosion of the low/medium-rise scale of Narrabeen, with attendant loss of character, amenity and sense of place.
3. Amenity impacts on neighbours and public domain
With increased height come increased impacts on:
- Overlooking: A five-storey building may allow line-of-sight to neighbouring private open spaces and living rooms that are not currently exposed under two or three storey development.
- Shadowing: Increased height and bulk may cast longer shadows onto adjacent dwellings, gardens, and perhaps nearby public open spaces, reducing sunlight and passive solar access.
- Bulk and scale: The visual intrusion of a large mass of five storeys may reduce the sense of openness of the street, increase wind impacts, reduce sky views and impact the human scale of the footpath/street interface.
4. Cumulative effect and future intensification
Approving this one large building may trigger a step change in density and scale in Narrabeen, encouraging further mid-rise and high‐rise developments. Over time, the cumulative effect will be a much denser, taller built environment than envisaged in the local context. This may place additional pressure on local infrastructure (traffic, parking, public domain, services) and change the character of the suburb irreversibly.

For the reasons above I urge the Department to refuse this Proposal or require significant scale reduction (both in storeys and building mass) and appropriate design refinement to ensure compatibility with the existing neighbourhood context of Narrabeen.

I strongly object to the proposed six-storey high-rise. It is completely out of character with our neighbourhood and would destroy residents’ privacy, sunlight, and quality of life in our beautiful area.

Our infrastructure is already stretched to the limit—roads, parking, and essential services cannot cope. It is hard enough here as it is. If developments like this are to go ahead, all infrastructure must be fully upgraded first—anything less is unacceptable.

This development is unwanted by the community and benefits only a few at the expense of the many. No one wants this. It will replace the sense of neighbourhood with congestion, noise, and diminished livability. I urge the council: listen to the residents who call this place home and reject this proposal before it irreparably harms our community.

I am strongly opposed to the proposed development for the following reasons.

Firstly, 14 days to raise concerns is completely biased towards the developer & unfair to residents! The NSW government is very short sighted if you don’t think we won’t remember this next election. But I suppose you don’t really care about losing your jobs? Just keep ticking those boxes!

As an Elanora resident I know how much traffic strain there presently is in this area of the Northern Beaches.

The current road infrastructure is already totally inadequate, particularly Pittwater & Powderworks Road, Mona Vale Road and Wakehurst Parkway. A further population increase as set out in this the proposal will only negatively impact even further the strained capacity of the ‘main’ roads aforementioned. Much has been promised over the years about upgrades of these roads only for those projects to be abandoned and still traffic flow continues to deteriorate year on year.

This already challenging situation would only be exacerbated during the development and construction phases of the proposed project and then continue when residents move in. It is not just those residents but also compounded by further additional traffic from those visiting the residents. Public transport is currently completely inadequate. The B1 bus service is already unable to cope with the number of commuters trying to use this service. To add more population to an area where the services provided cannot meet the current demand makes absolutely no sense.

It is obvious that Moran are aimed at providing higher end units (hence making more money). Where are the benefits to our aging community given the minimal aged care provisions. Looks like only the wealthy will be be to buy in Indigo?

The height of the development is not in keeping with the area. It basically represents overdevelopment with no set backs.

The extremely small number of visitor parking spaces is completely inadequate. This will lead to more parking issues for the local area which is already stretched.

The Northern Beaches Hospital capacity and capability has been the subject of much media coverage. To increase the residential population in the area can only place further strain on an already stretched medical facility that struggles to cope with its current load.

The current stormwater and sewage infrastructure already struggles to cope as has been evidenced during multiple heavy rain events. To add more residential developments to infrastructure that is unable to cope is counterintuitive and potentially puts property and infrastructure at risk.

We understand there is a need for more housing but this development is not the way forward.

These are just some my concerns and part of the basis for my strong objection to the proposed development.

I lived in near the proposed development site for 20 years and still live close by. I strongly object to the project. The proposed six-storey development represents a significant and unacceptable departure from the established planning, environmental, and social character of Narrabeen. While I support well-considered and appropriate development, this project fails to demonstrate compatibility with the local context, does not include adequate infrastructure capacity, and is not aligned with broader strategic planning objectives. I have outlined below nine key reasons why the proposal should be rejected.

1. Inconsistency with Established Character
The proposed building’s height, bulk, and architectural form are entirely out of scale with the surrounding low-rise environment. Narrabeen’s built character is defined by modest residential structures that integrate with the coastal and lagoon setting. Introducing a six-storey luxury complex into this context would fundamentally alter the area’s visual identity, overwhelm existing streetscapes, and place strain on infrastructure designed for smaller-scale residential use.

2. Inadequate Parking Provision and Traffic Implications
The inclusion of only 178 parking spaces for a development of this magnitude is grossly insufficient. Given the prevalence of multi-vehicle households in two- and three-bedroom apartments, along with the need to accommodate visitors, staff, and service vehicles, parking shortfalls are inevitable. Traffic congestion along Lagoon and Ocean Streets is already acute (and made worse on a seasonal basis with influxes of visitors to the local caravan park as well as regular council activity maintaining the lagoon) and this project would exacerbate existing safety and amenity issues.
 There are high numbers of pedestrians and recent focus has been on reducing traffic speed and volumes. This proposal is antithetical to those efforts. It is imperative that an independent traffic and parking assessment be commissioned by the NSW Government, rather than relying solely on the developer’s consultants, to ensure an objective and transparent evaluation of the traffic impacts. This assessment must be done at appropriate times to illustrate actual traffic volumes, not at “cherry picked” low traffic times that provide artificial results.

3. Loss of Aged Care and Assisted Living Capacity
The current facility provides 55 aged care beds and 35 assisted living units. The proposed redevelopment reduces this to a 10-bed facility, representing a dramatic loss of essential aged care capacity on the Northern Beaches. Such a reduction cannot reasonably be regarded as a like-for-like replacement or a continuation of existing services. It undermines the long-term availability of aged care accommodation at a time when community demand for these services continues to grow. It is apparent that this facility is about making money rather than caring for our local elderly and ageing population.

4. Misuse of Planning Provisions
There appears to be a deliberate exploitation of the Seniors Housing SEPP to facilitate approval of a project that does not meet the policy’s intent. The State Government has recently clearly identified appropriate precincts for high-density development—Brookvale, Dee Why, Mona Vale, Manly Vale, and Forestville—where the necessary infrastructure and urban context already exist. 
A six-storey luxury development on Lagoon Street does not belong in a low-rise coastal neighbourhood such as Narrabeen and is inconsistent with the SEPP’s strategic objectives.

5. Unacceptable Planning Precedent
Approving this application would set a highly undesirable precedent, effectively opening the door for other developers to circumvent planning controls through selective use of the Seniors Housing provisions. This would risk a gradual erosion of Narrabeen’s character and encourage inappropriate intensification in areas not designed to support it. High-density development should be confined to designated centres, not imposed within established residential neighbourhoods. Developers seek to capitalise on the area’s natural beauty and existing character to maximise their returns while destroying that very beauty and character in the process.

6. Deficient Community Consultation
The consultation process has been inadequate and cannot in any way be considered genuine community engagement. Public information sessions were poorly advertised, scheduled during business hours, and structured in ways that limited meaningful participation. For a proposal of this scale and potential impact, such token consultation falls far short of acceptable standards for transparency and inclusion. In addition, the developer has been using its mailing list to lobby for support for this proposal. This mismatch between the budget and advertising muscle of the developer against the individual residents seeking to ensure local development is appropriate must be acknowledged and managed.

7. Absence of Affordable Housing
Despite growing local need, the proposal offers no affordable or accessible housing component. A development of this size presents a clear opportunity to deliver social benefit through inclusionary housing measures, yet this has been disregarded. The project fails to respond to community priorities or broader housing policy objectives.

8. Environmental and Water Table Risks
The excavation required for a three-level basement car park poses serious risks to the local water table and the structural stability of nearby properties. The area’s hydrology is sensitive, and inadequate assessment of these impacts could result in long-term environmental and engineering problems.

9. Removal of Vegetation and Habitat Loss
The proposal involves the removal of mature trees and vegetation that contribute to local biodiversity and amenity. This is inconsistent with current environmental protection principles and will diminish habitat for native species, further degrading the ecological character of the area.

Conclusion: Community Position and Conclusion
Local residents are not opposed to responsible development. The community supports projects that are moderate in scale, environmentally responsible, and respectful of Narrabeen’s established character and infrastructure limits. This proposal does not meet those criteria.

Approving it would compromise the integrity of the planning framework and erode public confidence in the decision-making process. The project warrants serious reconsideration and refusal on planning, environmental, and social grounds.

I trust that the Panel’s assessment will be guided by principles of integrity, transparency, and alignment with community values—and that this proposal will be rejected accordingly.

To: NSW Department of Planning, Housing and Infrastructure
Re: Submission on SSD-76220734 – Indigo by Moran, 156 Ocean Street, Narrabeen.

Dear Sir/Madam,

I write on behalf of the residents (including my family and friends who live on Ocean Street) and stakeholders of the Pittwater electorate and the Northern Beaches, to object to the proposed development of Indigo by Moran.

While I recognise the demand for appropriate seniors housing within our community, the current design and scale of this proposal are not acceptable and should be significantly amended. The objection is structured below with reference to relevant issues and asks for corrective actions.

Issue

1. The Northern Beaches community is experiencing demographic ageing and there is indeed a requirement for more seniors housing. This proposal is therefore not objectionable in principle.
2. However, the current scheme is out of character with the surrounding area: the proposed five storeys to be constructed, significant bulk and height fail to respect local scale and context. The documentation notes that the proposed height (approximately 21.1 m) seeks to exceed a local height limit of 12.3 m by about 70%.
3. The local road network, already under pressure, cannot sustain the additional traffic load the development will bring. The site will generate substantial vehicle movements, including independent living units, resident vehicles, staff and service vehicles.
4. The proposed height and massing will dominate the streetscape, impact views, and set an undesirable precedent for further large-scale development in the Pittwater and Northern Beaches region.
5. The amenity of existing residents surrounding the development will be adversely impacted through overshadowing, loss of privacy and overpowering scale.

⸻

Relevant Standards / Context

- The Planning Portal records this as a “State Significant Development” application.
- The local height limit for the site is 12.3 m, yet the application seeks to reach roughly 21.1 m.
- The community consultation period was limited, and there are concerns residents were unable to scrutinise the full 2,100-page documentation comfortably.
- The site is in Narrabeen, one street back from the beach, in a context of low to mid density development.

⸻

Application of Issues to Facts

While the demand for seniors housing is acknowledged, the development must still integrate sensitively into the local environment. The proposed number of storeys is well above the local height and scale norms, compromising streetscape and view corridors.

The existing local infrastructure, especially roads servicing Narrabeen and the wider Northern Beaches, is already under strain from growth. A large development of this nature will exacerbate traffic congestion, parking pressures and servicing demands unless significant upgrades accompany it, which are not clearly provided for.

By permitting such a large and tall development here, a precedent is set for similar high-density schemes, eroding the character of the area and undermining community expectations of scale.

The combination of high-end independent living units, extensive amenities (cinema, rooftop terrace, heated pool etc) in a multi storey form suggests a luxury scale rather than a modest seniors housing model aligned with community-need and context.

⸻

Requested Outcomes / Conditions

1. The building height must be reduced substantially so that it aligns with the local height control of 12.3 m or at most only modestly above it, for example a three to four storey outcome rather than five.
2. The bulk and massing should be stepped back, especially on the Ocean Street frontage and towards neighbouring lower scale dwellings, to lessen visual impact and better integrate with the local built form.
3. Adequate traffic, parking and servicing studies must be submitted, with identified works to upgrade the road network and mitigate the impact of increased vehicle movements.
4. A revised amenity and landscaping plan should preserve key view corridors, minimise overshadowing and respect the Norfolk Pine trees referenced in the development documents.
5. The developer should provide evidence of genuine community consultation, and the decision-making process should allow adequate time and access to documentation for residents to make informed submissions.
6. Any approval should attach binding conditions that tie allowable height and storey count, visual bulk, traffic load, parking and infrastructure upgrades to consent, so that future changes do not likewise escalate.

⸻

Conclusion
In summary, the principle of providing increased seniors housing in the Northern Beaches is supported. However, the current design for Indigo by Moran fails to respect local height controls, neighbourhood character, and infrastructure capacity. Accordingly, the application should either be refused or redesigned substantially to reduce height and bulk, ensure infrastructure can cope, and align with the community’s expectations for scale and amenity.

Thank you for your attention to this submission.

Firstly, given the rezoning earlier (per the Northern Beaches Council website in February) this year by the NSW State Government, Narrabeen was excluded from permissible areas whereby buildings could reach up to 6-storeys. To overrule this later in the same year undermines that entire process, and is disingenuous to the local community.

Additionally, in my opinion, to have had the independent review process removed shortly before this project was announced to push ahead, is a disturbing reflection on where the State Government’s ‘consultation’ procedures lie, and undermines fair community consultation.

This proposal:

Is of inconsistent building character:

The proposed six-storey luxury complex is entirely inconsistent with the established character, building height, and environmental context of Narrabeen. It fails to respect the scale, infrastructure, and community identity that define the area.

Has inadequate parking facilities:

The development provides only 178 residential parking spaces, which is inadequate for a complex of this size. With two- to three-bedroom apartments, multiple vehicles per household are likely, alongside visitors, staff, and maintenance vehicles. Traffic and parking congestion are already significant along Lagoon and Ocean Streets. Throughout the year, as it stands with the boats and trailers that are infrequently patrolled by council, parking spots are scarce.

Without proper, independent investigation into the effects on traffic, this does not act in the interest of the local community or those that would be affected in neighbouring streets.

Has reduced aged-care capacity that is not like-for-like:

The proposal reduces the current 55 aged care beds and 35 assisted living units to a 10-bed facility, substantially diminishing available aged care support in the Northern Beaches region. This cannot reasonably be considered a “like-for-like” replacement or a genuine continuation of services for elderly residents.

Is particularly alarming given it undermines the rezoning rulings that occurred earlier in the year:

The NSW State Government has already identified suitable high-rise precincts—Brookvale, Dee Why, Mona Vale, Manly Vale, and Forestville—where developments of this scale align with the existing landscape and infrastructure. A six-storey luxury complex on Lagoon Street is incompatible with the surrounding built environment and the local community’s expectations.

Has offered a lack of genuine community consultation:

Community engagement for this project has been inadequate, with many local residents finding out through discussions amongst the local community. Meetings have been poorly publicised, scheduled during working hours, and structured in ways that limit public participation. This approach does not reflect genuine consultation, especially for a development of such scale and potential impact.

Raises environmental and water table concerns:

The construction of a three-level underground car park raises significant concerns about the local water table. With neighbouring properties either side, this threatens future potential impacts.

Threatens the destruction of vegetation and habitat:

The planned removal of trees is inconsistent with existing planning and environmental protections. Such destruction will have detrimental effects on local biodiversity and species habitats.

Opposes the community’s position:

The current proposal represents a major departure from suitable development that focuses on appropriate scale in line with existing infrastructure.

If government and council decision-makers are to act in the best interests of the community, this project warrants serious reconsideration.

The planned Indigo development by Moran at 156 Ocean St Narrabeen, with 149 proposed residential units plus various other facilities, is far too large for the site.

There was no planned mid rise housing development mentioned to the community for Narrabeen, as part of the recently announced changes in State planning laws, and the site is also located over 800 metres from any ‘town centre’.
The development is 6 storeys high, which is over twice as high as any nearby complex. It is not in line with the character of the surrounding area at all, and it is going to cause significant traffick and parking issues, where parking is already limited.

The building itself will tower over nearby homes and remove significant sunlight from nearby areas and cause significant dust and dirt during construction.

The starting price of several million dollars per residential unit is not in line with the concept of creating affordable housing for NSW at all, since most senior couples will not be able to afford a 2 bedroom unit for 3 million dollars. It will cause wealthy outsiders to move into sleepy Narrabeen, who can afford to live here. Locals may have to move outside the area to find accomodation.

The local community has not been properly consulted at all about this massive construction, apparently the largest retirement living complex in Sydney by Moran, in the small, quiet suburb of Narrabeen and my neighbours and I only just found out about this proposal this week, and submissions are closing tomorrow !) and it appears council’s power to oversee/authorise new development has been taken away and passed onto the State planning department.
The developer Moran is offering an open house invitation to the public on 13 November, to discuss this development, one week after the closing deadline for submissions of objections by the public to this development has been passed !

Why are we paying council rates when council’s authority to oversee and approve/decline developments like these has been diminished, in order for State Planning to rush through a multitude of massive concrete constructions, to meet its planning deadlines for NSW ‘affordable’ housing in time ?

The Northern Beaches area is being overdeveloped in a hurry, with significant projects going ahead in Manly, Mona Vale, Bayview, Fenchs Forest, Forestville to name a few; yet little thought seems to have gone into effects on environment and excess traffick on our roads, with no improvement in infrastructure to complement. The site itself is surrounded by narrow roads.

The land upon which the development is to be built, is in a slip and flood zone, not at all suitable for further high rise development….(refer the sea wall, which was recently built at Collaroy Beach, next to Narrabeen, to protect houses from flooding and tidal waves, costing millions of dollars!).
This heavy complex is essentially being built on unstable sand.

A drive from Narrabeen to Warriewood or Dee Why is already taking 45 minutes at peak hour now. This can only get worse. A car drive to the CBD may become a day journey if this level of development continues on the Northern Beaches !

Please stop this massive construction (and others in the area), or at least allow for a much smaller complex (eg up to 3 storeys high) to be built here, to complement the character of this beautiful beachside suburb.

Thank you
Kind regards,
S

Dear Sir/Madam,
I am writing to formally object to the proposed development known as Indigo by Moran (SSD-76220734), located at 156-164 Ocean Street, 81-81A Lagoon Street & 8 Octavia Street, Narrabeen.
As a long-term resident of this area, my family and I have lived here for over 60 years, I am deeply concerned about the irreversible impact this development will have on our natural coastal environment, community character, and ecological heritage.
🌲 Loss of Iconic Pine Trees
The proposed removal of the mature Norfolk Island pines is particularly distressing. These trees are not only a visual hallmark of Narrabeen’s coastal identity but also provide critical habitat for native birdlife and contribute to the ecological stability of the area. Their removal would permanently alter the landscape and diminish the natural beauty that has defined this community for generations.
🏗️ Excessive Scale and Height
The proposed six-storey buildings are grossly out of scale with the surrounding low-rise coastal village character. The bulk and height will dominate the skyline, overshadowing neighbouring properties and disrupting the visual harmony of the area. This is inconsistent with the Coastal Design Guidelines 2023, which emphasise development that is sympathetic to the existing built form and natural setting.
🌊 Conflict with Coastal Management Legislation
The site falls within the Coastal Environment Area and Coastal Use Area as defined under the Coastal Management Act 2016 and the Resilience and Hazards SEPP (2021). These planning instruments aim to:
• Protect and enhance natural coastal processes and environmental values (Coastal Management Act 2016, s3(a)) [legislatio...nsw.gov.au]
• Avoid and minimise exposure of communities to current and future coastal hazards (Resilience and Hazards SEPP, Direction 4.2) [planning.nsw.gov.au]
• Ensure development is appropriate and does not adversely impact the coastal environment (Coastal Management SEPP, now incorporated into the Resilience and Hazards SEPP) [planning.nsw.gov.au]
The scale of excavation, proximity to the lagoon, and intensification of use on a sensitive coastal site raise serious concerns about erosion, stormwater runoff, and loss of biodiversity. The proposal appears to contravene the objectives of these policies by prioritising high-density development over environmental protection and community wellbeing.
🏘️ Community and Cultural Impact
This development threatens to erode the very fabric of our community. Narrabeen has long been a place where families grow, generations stay connected, and the natural environment is cherished. The proposed project prioritises commercial interests over the social and cultural values of the local community, which are explicitly protected under the Coastal Management Act 2016 (s3(b)).
🙏 Request for Reconsideration
I respectfully urge the Department to refuse this application in its current form. Any redevelopment of this site must:
• Retain and protect the existing pine trees
• Respect the low-rise character of the area
• Comply with the intent and objectives of the Coastal Management Act 2016 and Resilience and Hazards SEPP
• Genuinely engage with the community, not just through promotional sessions but through transparent, inclusive consultation
Let us not allow short-term development to permanently damage a place that has taken generations to become what it is today.

Indigo By Moran - 156 Ocean Street Narrabeen | Planning Portal - Department of Planning and Environment

Kind regards,

I oppose the Indigo by Moran development as it is a massive overdevelopment for the site at 156 Ocean Street, Narrabeen. The massive height will overshadow properties and will create loss of existing views. The depth of the development into the local water table will not help the area which is prone to flooding. The removal of mature trees in unacceptable due to loss of habitat. We recently relocated to North Curl Curl after residing in Narrabeen where we had a resident bilby in the garden and we are in the coming months relocating back to Narrabeen. Please scale the development back to an acceptable height for the area and in the process move the building from the perimeter of the street to the middle of the site to prevent overshadowing for neighbouring properties and the street scape.

I write to formally object to the approval of the above proposal on the grounds of unacceptable geotechnical risk posed by the proposed three level basement excavation combined with six above ground storeys. The site sits on an elevated, narrow peninsula of sandy marine soils with no natural retaining landform; combined with the limited geotechnical assessment provided, the proposal presents an unacceptable risk to neighbouring properties. The surrounding marine ecosystem is fragile and at real risk of contamination and degradation from excavation, dewatering and construction related disturbance. I call for an independent geotechnical review that assesses impacts beyond the site boundary, including potential effects on adjacent land, buried services and nearby coastal waters.

Summary of primary concerns
• Limited investigation depth: The geotechnical investigation’s maximum termination depth is 16.78 mbgl, so conditions below 16.78 m are not characterised. This leaves the presence (or absence) of competent bearing strata, the full groundwater regime and potential long term settlement unresolved.
• Sandy, permeable soils with limited analysis: The site is underlain by sandy, permeable soils. The report does not present robust dewatering drawdown modelling, lateral displacement analyses, or mapped settlement influence contours extending to adjoining property lines.
• No independent review or safeguards: The geotechnical documentation lacks an independent peer review, quantified monitoring trigger/action levels, and enforceable remediation or insurance provisions to protect neighbouring properties and the environment.

Additional evidence for independent geotechnical analysis
The proposed basement excavation offsets are approximately:
• 0.6 m from the north western boundary
• 3.0 m from the southern boundary
• 4.6 m from the western boundary
• 6.0 m from the northern boundary
• 10.0 m from the eastern boundary

These shallow offsets mean the excavations are expected to extend into the zone of influence of neighbouring properties and/or adjacent infrastructure on all boundaries. Given the recorded soils and groundwater conditions, this proximity substantially increases the risk that excavation, temporary support works or dewatering will cause settlement, lateral soil movement or damage to adjacent foundations, retaining walls, buried services and public infrastructure. There is also a material risk of sediment and contaminant pathways being created or exacerbated toward the nearby coastal environment.

Requested actions and conditions
I request that approval be refused or, at minimum, that determination be deferred until the following are completed and publicly released:
1. Independent geotechnical peer review of the entire site investigation, analyses, temporary/permanent retaining design and dewatering strategy.
2. Additional intrusive investigations (boreholes/CPTs) extending beneath the proposed excavation toe and across the likely influence zone to neighbouring foundations and infrastructure.
3. Quantified dewatering and consolidation modelling showing drawdown radius, worst case seasonal scenarios and predicted settlements plotted to neighbouring property lines and critical utilities.
4. Lateral displacement and settlement influence contour plans plotted on a site plan showing predicted movements at adjacent foundations, boundary lines and services.
5. Binding Monitoring and Contingency Plan with inclinometer, settlement plate and piezometer locations, clear trigger/action levels, independent third party monitoring and mandatory remediation obligations.
6. Financial surety or developer funded remediation bond and proof of insurance to cover repair costs for any damage to adjoining properties or public infrastructure caused by the works.
7. Certified temporary works and excavation sequencing plan (including toe details, retaining wall design and anchor/pile lengths) peer reviewed by an independent chartered geotechnical/structural engineer.
8. Public disclosure of the final geotechnical report, peer review findings and ongoing monitoring data before any excavation permit is issued.

Conclusion

The limited, non independent assessment provided to date creates an unacceptable risk of significant adverse impacts to neighbouring properties and to the fragile marine environments just metres from the excavation area. Approving a three level basement with minimal boundary offsets and an investigation that terminates at 16.78 mbgl would impose an avoidable risk of damage to surrounding properties, infrastructure and the coastal ecosystem. The consent authority must require comprehensive additional investigation, independent peer review, enforceable monitoring and remediation measures, and financial surety before any approval is granted.