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Bushfire Addendum - Change Reps
NCES Ref: J001061
48 Kabi Road, Cootharaba, QLD
14th February 2025
Christian Youth Council
C/O Jack Lewis
Pivotal Perspective
Via email: [email protected]
Dear Jack,
RE: Request for Letter addressing the bushfire conditions 66, 87-94 of approved Other
Change Application - 131998.981211.5 - Group Farm Stay Accommodation and
Associated Supporting Infrastructure, located at 48 Kabi Road, Cootharaba, QLD
As requested, please find below my comments concerning Conditions 66 and 87-94 of the
approval.
Condition 66. Buses capable of evacuating all patrons during an emergency event are to
remain on site whilst the Group Farm Stay Accommodation is in operation.
NCES Comment.
It is understood that the applicant has reservations about the practicality and cost burden of
this condition.
The BHAMP and Bushfire Evacuation Plan identify the majority of the site, including the Group
Farm Stay Accommodation buildings and the emergency shelter in place golf club house, to
be not located within a confirmed Bushfire Prone Area or Potential Impact Buffer. Both building
areas are separated from the southerly adjacent hazardous bushland by in excess of 100m
of very low threat conditions (i.e. manicured golf course, orchards and short cropped
grassland) which means the effects of radiant heat flux emanating from the forest edge, should
it alight, do not cause pain to human skin.
It is noted it is only a short 420m walk across relatively level ground from the most eastern
short term accommodation building to the club house. Site occupants therefore have access
to at least two shelter in place options/assembly areas situated within a confirmed low bushfire
prone area whilst waiting for buses to access the site should an evacuation be triggered.
Equally, should the buses not be able to access the site in an emergency the shelter in place
options within the confirmed low bushfire prone area can be readily enacted.
Therefore, it could be argued that provision of on-site bus availability whilst the Group Farm
Stay Accommodation is in operation, represents an unreasonable condition for this site and
thus an unreasonable financial burden on the operation of the facility.
Condition 87. The development must be carried out in accordance with Bushfire Hazard
Assessment and Management Plan v4 prepared by North Coast Environmental Services
dated 06/09/2024, which must be amended to include:
a. Revised plans that incorporate the latest architectural plans that show the clamping
infrastructure wholly outside of the Noosa plan Bushfire hazard mapping potential impact
buffer.
b. Section 5.3 Water Supply is to be updated to include a minimum of 20,000 litres of dedicated
static water supply for firefighting purposes for each group of 7 cabins. The last paragraph of
this section needs to be updated as an error is present “shared between 2 cabins’ This should
read 7.
PO Box 385 Peregian Beach QLD 4573 / Email: [email protected]
ABN 60 625 108 625
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NCES Ref: J001061
48 Kabi Road, Cootharaba, QLD
c. Revised plans that demonstrate a minimum 10,000 litres of dedicated static water supply
for firefighting purposes is available at the shelter in place location.
d. Revised plans that incorporate the recommended fire access trail within Lot 394 M371117
(see Plate 23 of the Bushfire Hazard Assessment and Management Plan) and extending along
the southern boundary until it meets the eastern boundary of the subject site, before gaining
access to Road 176.
e. Detail that the fire access trail along the southern boundary is to be gated and used for
emergency access only.
The report must be resubmitted and approved by Council incorporating the above
amendments prior to the issue of any Development Permit for Operational Works.*
NCES Comment. The contents of Condition 87 are considered reasonable and the BHAMP
can be readily updated to satisfy this condition upon request.
Condition 88. The development must be carried out in accordance with Bushfire Evacuation
Plan v4 prepared by North Coast Environmental Services and dated 06/09/2024, which must
be amended as follows
a. Revised plans that that incorporate the latest architectural plans that shows the internal
evacuation route that connects directly between the shelter in place building and the clamping
infrastructure.
b. Section 8 Evacuation Triggers, to be updated to include:
i. Daily review of FDR forecasts for the Southeast Coast which are available from the Bureau
of Meteorology
ii. Evacuation of all guests and non-essential staff prior to the commencement of any day with
a forecast FDR rating of Extreme or Catastrophic.
c. Section 7 Evacuation Routes, to incorporate detailed plans of the secondary emergency
access and associated maintenance requirements.
The report must be resubmitted to Council incorporating the above amendments prior to the
issue of any Development Permit for Operational Works.*
NCES Comment
The contents of Condition 88a, b(i) and c are considered reasonable and the BHAMP can be
readily updated to satisfy these conditions upon request.
Condition 88b(ii) seeks to add an FDR ‘Extreme’ trigger for site evacuation along with the
recommended ‘Catastrophic’ trigger. FDR ‘Extreme’ occurs when the FDI is between FDI 50-
100 whilst FDR Catastrophic occurs when the FDI gets to 100+. The Australian Fire Danger
rating System website; https://afdrs.com.au/, advocates the following management protocols
for each FDR.
PO Box 385 Peregian Beach QLD 4573 / Email: [email protected]
ABN 60 625 108 625
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NCES Ref: J001061
48 Kabi Road, Cootharaba, QLD
(Source www.afdrs.com)
As per the image above, pre-emptive evacuation of a site is only referenced under FDR
Catastrophic. Therefore, Condition 88b(ii) is inconsistent with the AFDRS official advice.
It is further noted the site has been assigned an FDI 47 (FDR High) by QFES which means
climatic conditions asscoiated with FDI 47 are expected to have a 5% chance of occurring in
a given year. It can be assumed then that the chances of climatic conditions associated with
FDI 50 (FDR Extreme) occurring in a given year would be less than 5%.
Condition 89. The site must be provided with water storage reservoirs for emergency
firefighting purposes in accordance with the amended Bushfire Hazard Assessment and
Management Plan. Such storage must be provided in addition to the water supply capacity
required for the use and must be provided in the form of a static water supply tank. If by
rainwater tank, water storage for firefighting purposes must be provided either in a separate
rainwater tank or a reserve section in the main water supply tank on which:
a. the domestic take off from the tank is at or above the required amount of water required by
the amended bushfire management plan; and
b. standard rural fire brigade fittings are fitted to the tank outlet for access by four wheel drive
rural services vehicles.
NCES Comment
The contents of Condition 89 are considered reasonable and the BHAMP can be readily
updated to satisfy these conditions upon request.
Condition 90. The site must be provided with an auxiliary power supply such as a petrol driven
fire fighter pump (or generator), together with a hose of sufficient length to easily reach around
to all sides of the building.
NCES Comment
The contents of Condition 90 are considered reasonable.
PO Box 385 Peregian Beach QLD 4573 / Email: [email protected]
ABN 60 625 108 625
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NCES Ref: J001061
48 Kabi Road, Cootharaba, QLD
Condition 91. A copy of the Bushfire Hazard Assessment and Management Plan listed within
this Decision Notice must be provided to the nearest fire authority.
NCES Comment
The contents of Condition 91 are considered reasonable.
Condition 92. Certification must be submitted to Council from a qualified person* which
certifies that the development has been constructed in accordance with the bushfire
management conditions of this Decision Notice.
NCES Comment
The contents of Condition 92 are considered reasonable.
Condition 93. The development must be managed in accordance with the Bushfire
Evacuation Plan listed within this Decision Notice.
NCES Comment
The contents of Condition 93 are considered reasonable.
Condition 94. A copy of the Bushfire Evacuation Plan for the development must be provided
to the nearest fire authority.
NCES Comment
The contents of Condition 94 are considered reasonable.
Should you have any queries regarding this matter please do hesitate to contact me.
Sincere regards,
Joshua Lee - Director
B. Sc. Australian Environmental Studies (Ecology, Land & Water, Pollution & Health)
mFPAA, mESA
Mobile: 0406 626 913 | Email: [email protected]
PO Box 385 Peregian Beach QLD 4573 / Email: [email protected]
ABN 60 625 108 625
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