The NSW Government has released the detail on the planning reforms that will apply to people living within 800m of 171 town centres and train or light rail stations across metropolitan Sydney, the Central Coast, Illawarra-Shoalhaven and Hunter regions. Here’s what you need to know.
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.

I support the project

Please refer to the attached documents.

The submission property runs from 7 Long street to Tait street, just opposite a food manufacturing business.
# The blocks in question are surely in the 1 in 100 flood plain, therefore on the next big storm season any open tanks of sludge or refuse will be flowing out to the nearest stormwater drain, which is just outside the food manufacturing business across the road, potentially contaminating that site.
# also increase in processing will mean more smell/germs in the air. Some thing that should be avoided from a food production area across the road.
# If our long term tenant leaves because the De-sludging plant affecting his business, we will be seeking legal compensation.
# a three fold increase in trucks to this site, may affect traffic flow to such an arterial route to an industrial estate.

Hopefully the above reasons for our objection will be aired and taken seriously.

Kind regards

My submission is attached.