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RESPONSE TO SARA IR - Attachment 1A - RFA24-059-SARA IR Response 310725

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Rob Friend & Associates Pty Ltd
Environmental Land Management Consultants
                                                                                             RF&A

                                                                  Office – Unit 4/3 Heaslop St
                                                                  Woolloongabba
                                                                  Postal - 28 Merton Road
                                                                  Woolloongabba Qld. 4102
                                                                  p - (07) 3891 9131
                                                                  f - (07) 3393 0388
                                                                  m - 0419-667346
Your reference: --                                                e - [email protected]
                                                                  w – www.robfriend.com
Our reference: --       RFA24-059
                                                                  ABN 83 097 068 114
Date: -                 31st of July 2025                         ACN 097 068 114

      Sarah Lawley
      Principal Planning Officer
      State Assessment and Referral Agency
      PO Box 1129
      Maroochydore, Qld 4558
      Dear Ms Lawley,

                             Re: - SARA Reference 2503-45382 SRA
      Response to Information Request - 561 Eumundi Noosa Road, Doonan

      Further to your Information Request for the proposed extension of the waste management area at
      the Doonan Waste Management facility, dated 26 May 2025.
      Item 1 of the Information Request states -
      Issue:
      The application material has not adequately demonstrated that the proposed development
      complies with the performance outcomes (PO)1-PO3 and PO4-PO18 requirements of state code
      16. In particular, insufficient details have been provided regarding the extent of vegetation that will
      become exempt clearing work if the development application is approved.
      It is unclear which plan provided with the application material most accurately reflects the new
      proposed development, and no digital data (e.g. shapefile) has been provided to show all new and
      relocated infrastructure. Additionally, it is unclear where the proposed new fence lines will be
      located.
      It is stated in ‘Attachment 4 - Environmental Offset and Reinforcement Planting Advice_6’ that
      ‘Noosa Council proposes to clear the Category X vegetation at Site A for a Resource Recovery
      Centre Expansion. The clearing of Category X vegetation on Site A does not require assessment
      under the Planning Regulation 2017 and the Vegetation Management Act 1999’. This statement is
      incorrect, as a material change of use application includes assessment of clearing as a result of
      the material change of use, as per the definition found in SDAP State Code 16: Native Vegetation.
      Assessable clearing includes clearing of vegetation that will become exempt clearing work if the
      development application is approved.
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The clearing as a result of the development will include essential management exemptions that will
become available once the development is approved, and this includes clearing for firebreaks and
safety buffers adjoining proposed infrastructure (other than fences, roads and underground
services) for a distance of 20m or 1.5 times the height of the tallest adjacent trees. This also
includes clearing to establish a necessary fence, if the maximum width of the clearing for the fence
is 10m.
Furthermore, the application material does not include any tree height data. If no tree height data is
provided, the assessable clearing for this development is calculated using the Technical
Description report for South-East Queensland for regional ecosystem 12.5.3 which states a
maximum tree canopy height of 30m, which when multiplied by 1.5, results in a firebreak width of
45m from the proposed building envelopes.
Action –
     Provide digital data that shows all new and relocated infrastructure within 45m of the
      category B vegetation, and all new fences located within 5m of the category B vegetation.
      Digital data should include a projected spatial reference (e.g. GDA94 or GDA2020) and
      preferably be in an ESRI compatible format (shapefile, geodatabase or KML).
        Please note: DWG and CAD drawing files are not sufficient as they are incompatible with
        ESRI spatial products.
     Provide tree height measurements for the tallest trees in category B areas adjacent to
      proposed infrastructure to identify the assessable clearing. Data to be provided to
      determine accurate tree heights should include pictures of the trees adjacent to the
      proposed infrastructure with an object of known height (survey staff) along with GPS
      coordinates identifying the exact location of the measured tree.
     If digital data confirms that vegetation clearing in category B is necessary for essential
      management. Specifically, a response to PO1 - PO3 and PO4 - PO18 of state code 16 will
      be required.
Response
Vegetation Mapping
    1. The Noosa Shire Council has placed a Property Map of Assessable Vegetation (PMAV)
       over all of the land fill and management areas (PMAV 2017/000924). This map identifies
       the extent of Category X Regulated Vegetation and the extent of Category B regulated
       vegetation under the property to which the PMAV has been made. It is noted that with
       respect to the areas of vegetation that may be required to be removed as a consequence
       of the proposed development, if approved, that the vegetation to the immediate west of the
       existing site is Category X Regulated vegetation.
    2. Further, there are areas that have been cleared along the current site’s northern and
       eastern boundaries and maintained as low grassy vegetation.
    3. To the north is a large polygon of Category B regulated vegetation or the Regional
       Ecosystem 12.5.3 - Eucalyptus racemosa subsp. racemosa woodland with Corymbia
       intermedia, E. siderophloia +/- E. tindaliae, E. resinifera, E. pilularis, E. microcorys,
       Angophora leiocarpa. Melaleuca quinquenervia is often a prominent feature of lower
       slopes. Minor patches (<1ha) dominated by Corymbia citriodora subsp. variegata
       sometimes occur. Occurs on complex of remnant Tertiary surfaces +/- Cainozoic and
       Mesozoic sediments. Not a Wetland. (BVG1M: 9g).
    4. The Technical Descriptions for various Regional Ecosystems in South-east Queensland
       Bioregion (2018 edition) describes the height the T1 stratum of RE12.5.3 has its tallest

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      height of 30 metres with an average of 45 metres. This would permit under State Code 16
      and for existing infrastructure a 1.5 x clearing exemption of 45 metres (see Figure 1).
  5. The site was reinspected on the June 2025 and tallest tree observed within the 1.5 times
     area was a Eucalyptus racemosa (Scribbly gum) was 16 metres.
  6. If the tallest observed tree on the site was accepted as the basis for a 1.5 times setback,
     then the firebreak in accordance with the State Code 16 would be 24 metres instead of the
     tallest tree height for the Regional Ecosystem 12.5.3 as provided by the Regional
     Ecosystem Technical Descriptions (see Figure 1).
Exemptions
  1. We note that Category X regulated vegetation on freehold land is exempted from
     regulation for any purposes. Therefore, we maintained our view that no additional
     approvals by SARA / Department of Resources and as such no response to the State
     Code 16 is required.
  2. The Category x area is not mapped in the Noosa City Plan Biodiversity overlay and as
     such no approvals are required from the Noosa Shire Council.
  3. The definition of “Clearing as a result of a material change of use, 2 –
      “clearing of vegetation that will become exempt clearing work if the development
      application is approved. This includes any of the following examples:
      a.   clearing for routine management and essential management purposes associated
           with the approved development including clearing to maintain proposed infrastructure,
           facilities, roads, access routes, utilities, services and fences, and clearing to maintain
           the safety of persons and property that will be associated with the development
      b.   clearing for necessary fire breaks, fire management lines and associated with the
           development. This will be assessed as follows:
              i.   all built infrastructure other than underground services, roads and fences will
                   be assessed as requiring clearing for fire breaks and safety buffers with a
                   width of 20 metres or 1.5 times the height of the tallest adjacent tree to the
                   infrastructure, whichever is the greater. The extent of clearing assessed will
                   include any vegetation that may be required to be cleared for fire breaks
                   distances and safety buffers on adjoining land”.
  4. This definition provides for one of two options depending on the height of the adjacent
     vegetation, 1.5 times the height of the tallest vegetation or if that figure is less than 20
     metres then the clearing width is 20 metres.
  5. The site inspection determined that the maximum height of the tallest tree adjacent to the
     infrastructure was 16 metres, therefore the necessary clearing that could become exempt
     clearing work would be 24 metres.
  6. With regard to the Category B Regulated Vegetation of the Regional Ecosystem 12.5.3
     and with respect to what is existing “exempted clearing” under State Code 16, that up to 24
     metres from the current development is considered to be exempt clearing. This extent is
     shown on Figure 1 (the yellow line).
  7. With respect to the additional clearing which may be classed as exempted clearing as a
     consequence of the approved development, this will extend 24 metres into the Category B
     regulated vegetation 24 metres from the extent of that infrastructure. (see dark blue line in
     Figure 1).

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                                                     4


    8. This will result in the loss of 166.03 sq.m. of Category B regulated vegetation (green
       polygon). This additional clearing may be included within what is defined as a firebreak as
       part of the MCU under the State Code 16.
    9. However, we further note that the fact sheet provides with the following clarification with
       respect to a necessary firebreak or necessary fire management line. The fact sheet states
       in reference to what is necessary clearing “Landholders intending to operate under this
       exemption may only clear firebreaks and fire management lines where they are necessary
       to protect lives and property”.
    10. Therefore, the necessary clearing is only that which is required to provide an acceptable
        level of bushfire risk for the proposed development.
    11. The State Planning Policy, Natural Hazards, Risk and Resilience Technical Guideline
        indicates that an acceptable risk as achieve a Radiant Heat Flux of no greater than
        29kW/m2.
    12. The minimal separation distance that achieves a Radiant Heat Flux of 29kW/m2 is
        calculated using the Flamesol Method 2 minimal distance calculator with the local input
        values for the FFDI and attributed fuel load values for the mapped Vegetation Hazard
        Class. Table 1 below provides the minimal distance calculation that achieves the Radiant
        heat flux value of 29kW/m2.
Table 1 – Minimal distance Calculation
Doonan Waste Management Facility - Minimum Distance Calculator - AS3959-2018 (Method 2)
(Calculated July 25, 2025, 4:39 pm (MDc v.4.9))
               Inputs                                            Outputs
Fire Danger Index       48          Rate of spread                1.25 km/h
Vegetation              Forest      Flame length                  11.04 m
Classification
Understorey fuel load   21 t/ha     Flame angle                   53.5 °, 63.5 °, 72.5 °, 77.5 °, 78.5 ° &
                                                                  84.5 °
Total fuel load         24.2 t/ha   Elevation of receiver         4.35 m, 4.83 m, 5.1 m, 5.16 m, 5.13 m
                                                                  & 4.79 m
Vegetation height       n/a         Fire intensity                15,654 kW/m
Effective slope         .5 °        Transmissivity                0.879, 0.863, 0.841, 0.816, 0.803 &
                                                                  0.736
Site slope              .5 °        Viewfactor                    0.5971, 0.4385, 0.2966, 0.2007,
                                                                  0.1633 & 0.0445
Flame width             100 m       Minimum distance to < 40      9.1 m
                                    kW/m²
Windspeed               n/a         Minimum distance to < 29                      12.4 m
                                    kW/m²
Heat of combustion      18,600      Minimum distance to < 19                      18.2 m
                        kJ/kg       kW/m²
Flame temperature       1,090 K     Minimum distance to < 12.5                    26.3 m
                                    kW/m²
                                    Minimum distance to < 10                      31.5 m
                                    kW/m²
Rate of Spread - Mcarthur, 1973 & Noble et al., 1980
Flame length - NSW Rural Fire Service, 2001 & Noble et al., 1980

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Elevation of receiver - Douglas & Tan, 2005
Flame angle - Douglas & Tan, 2005
Radiant heat flux - Drysdale, 1999, Sullivan et al., 2003, Douglas & Tan, 2005


   13. Therefore, the minimal distance that achieves a Radiant heat flux of 29kW/m2 is 12.4
       metres and this spatially located on Figure 1 and the light blue line.
Conclusion
Based on the above analysis we can conclude that;
   1. The exempted clearing distance for the existing development and the proposed
      development is a clearing with of 24.0 metres.
   2. However, the only clearing that is necessary is that which achieves a radiant heat flux of
      29kW/m2 is 12.4 metres, the only clearing that is required of any area of category is that
      which is within 12.4 metres of the closest edge of the existing and proposed infrastructure.
   3. As the 12.4 metres necessary clearing distance for a necessary firebreak is less than the
      1.5 time the height of the tallest adjacent trees, this clearing is considered to be exempted
      clearing.

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Response to State Code 16
The information Request requires a response to a number of Performance Outcomes in Stage Code 16. The are provided in Table 2 below.
Table 2 – Stage Code 16
Table 16.2: General
                    Performance outcomes                           Acceptable                                     Response
                                                                   outcomes
PO1 Clearing of vegetation is consistent with any notice        No acceptable      No notice of compliance has been issued by the State
requiring compliance on the land subject to the development     outcome is
application, unless a better environmental outcome can be       prescribed.
achieved.
PO2 Clearing of vegetation is consistent with vegetation        No acceptable      The proposed and necessary clearing is consistent and less than that
management requirements for particular regulated areas          outcome is          which is exempted clearing.
unless a better environmental outcome can be achieved.          prescribed.
                                                                                   The clearing is to comply with the State Planning Policy to achieve an
                                                                                    acceptable level of bushfire risk for infrastructure and the clearing
                                                                                    necessary to achieve that is 12.4 metres from the closest edge of the
                                                                                    existing and proposed infrastructure.
PO3 Clearing of vegetation in a legally secured offset area:    No acceptable      The proposed clearing area is not in a legally secured offset area.
                                                                outcome is
    1. is consistent with the offset delivery plan; or
                                                                prescribed.
    2. is consistent with an agreement for the offset area on
       the land subject to the development application; or
    3. only occurs if an additional offset is provided.

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Table 16.3: Public safety, relevant infrastructure activities and / or consequential development of IPA approval
Performance outcomes                                                   Acceptable outcomes                          Response
Clearing avoids and minimises impacts
PO4 Clearing of vegetation and adverse impacts of clearing             No acceptable outcome is prescribed.            The proposed clearing is within the exempted
vegetation do not occur unless the application has demonstrated that                                                    clearing area and as such no additi0onal or
the clearing and the adverse impacts of clearing have been:                                                             adverse impacts would occur around the
                                                                                                                        proposed development.
    1. reasonably avoided; or
                                                                                                                       The clearing of the exempted clearing area
    2. reasonably minimised where it cannot be reasonably
                                                                                                                        has been avoided as the necessary clearing
       avoided.
                                                                                                                        for a necessary firebreak is such that it
                                                                                                                        provides a maximum radiant heat flux
                                                                                                                        exposure of 29kW/m2 for all infrastructure
                                                                                                                        within the existing and proposed
                                                                                                                        development.
                                                                                                                       The proposed necessary clearing to achieve
                                                                                                                        an acceptable level of bushfire has been
                                                                                                                        reduced from 2,116.84 sq.m. to 801.81 sq.m.
                                                                                                                       This clearing cannot be reasonably avoided
                                                                                                                        in this location
Clearing associated with wetlands
PO5 Clearing of vegetation within a natural wetland and/or within      AO5.1 Clearing does not occur in a natural      The proposed necessary clearing is within
100 metres of the defining bank of a natural wetland maintains the     wetland or within 100 metres of the              the mapped Regional Ecosystem 12.5.3
composition, structure and function of any regional ecosystem          defining bank of any natural wetland.            which is not mapped as a wetland regional
associated with any natural wetland to protect all of the following:                                                    ecosystem.
                                                                       OR
    1. bank stability by protecting against bank erosion;                                                              A natural wetland is mapped approximately
                                                                       AO5.2 Clearing within 100 metres of the
                                                                                                                        60 metres from the proposed clearing and as
    2. water quality by filtering sediments, nutrients and other       defining bank of any natural wetland:
                                                                                                                        such no clearing will occur within 10 metres

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Performance outcomes                                                        Acceptable outcomes                           Response
         pollutants;                                                             1. does not occur within 10 metres of        of the defining bank of any natural wetland.
                                                                                    the defining bank of any natural
    3. aquatic habitat;                                                                                                      The proposed necessary clearing will
                                                                                    wetland; and
                                                                                                                              comnply with AO5.2 2 and table 1 of the
    4. terrestrial habitat.
                                                                                 2. does not exceed widths in                 State Code 16 in that the necessary clearing
                                                                                    reference table 1 in this code.           is less than 20 metres in width.
PO6 Where clearing of vegetation in a regional ecosystem                    No acceptable outcome is prescribed.             The clearing will not occur within a regional
associated with a natural wetland does not maintain the composition,                                                          ecosystem associated with a wetland
structure and function of the regional ecosystem, and cannot be
avoided and has been mitigated, an offset is provided for any
acceptable significant residual impact.
Clearing associated with watercourses and drainage features
PO7 Clearing of vegetation within a watercourse and/or drainage             AO7.1 Clearing does not occur in any of          No clearing will occur within or around the
feature and/or within the relevant distance (listed in reference table 2)   the following areas:                              defined bank of a watercourse or drainage
of a watercourse and/or drainage feature, maintains the                     1. inside the defining bank of a                  feature.
composition, structure and function of the regional ecosystem
                                                                               watercourse or drainage feature;              The proposed necessary clearing complies
associated with the watercourse and/or drainage feature to protect
                                                                               and                                            with the requirements of Table 2 of the State
all of the following:
                                                                            2. within the relevant distance of the            Code 16.
1. bank stability by protecting against bank erosion;
                                                                               defining bank of any watercourse or
2. water quality by filtering sediments, nutrients and other pollutants;       drainage feature in reference table 2
                                                                               of this code.
3. aquatic habitat;
4. terrestrial habitat.                                                     OR
                                                                            AO7.2 Clearing within any watercourse
                                                                            or drainage feature, or within the relevant
                                                                            distance of the defining bank of any
                                                                            watercourse or drainage feature in
                                                                            reference table 2 of this code:
                                                                                 1. does not exceed the widths in

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Performance outcomes                                                 Acceptable outcomes                           Response
                                                                             reference table 1 of this code; and
                                                                         2. does not occur within 10 metres of
                                                                            the defining bank, unless
                                                                            clearing is required into or across
                                                                            the watercourse or drainage
                                                                            feature.
PO8 Where clearing of vegetation in a regional ecosystem             No acceptable outcome is prescribed.             No clearing will occur in a Regional
associated with a watercourse and/or drainage feature does not                                                         Ecosystem associated with a watercourse or
maintain the composition, structure and function of the regional                                                       a drainage feature
ecosystem, and cannot be avoided and has been mitigated, an
offset is provided for any acceptable significant residual impact.
Connectivity
PO9 Regional ecosystems on the subject land and any adjacent         AO9.1 Clearing occurs in accordance with         All necessary clearing will not occur or result
land retain sufficient vegetation to:                                reference table 3 in this code.                   in impacts to the coastal regional ecosystem
1. maintain ecological processes; and                                                                                  as specified in Table 3 of State Code 16.

2. ensure the regional ecosystem remains in the landscape
   despite threatening processes.
Soil erosion if the local government is not the assessment manager for the development application
PO10 Clearing of vegetation does not result in accelerated soil      AO10.1 Clearing only occurs if an erosion        The proposed necessary clearing will not
erosion within or outside the land the subject of the development    and sediment control plan is developed            result in Accelerated spoil erosion as the
application.\                                                        and implemented to prevent increased soil         cleared area will be grassed and maintained
                                                                     erosion and instability resulting from the        by Noosa Shire Council
                                                                     clearing.
Salinity
PO11 Clearing of vegetation within 100 metres of a salinity          AO11.1 Clearing does not occur within            no clearing will occur within 100- metres of a
expression area does not contribute to or accelerate land            100 metres of a salinity expression area.         salinity expression area.

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Performance outcomes                                                 Acceptable outcomes                           Response
degradation through either of the following:                                                                          the necessary clearing will not result in
                                                                                                                       waterlogging and/or salinity of groundwater or
1. waterlogging;
                                                                                                                       surface water or the soil under which the
2. the salinisation of groundwater, surface water or soil.                                                             necessary clearing will be undertaken.
Conserving least concern regional ecosystems - Minimising clearing of areas temporarily required to enable construction of the infrastructure
PO12 Clearing of vegetation for temporary use areas to construct     AO12.1 Clearing for temporary use areas          The proposed necessary clearing is not
necessary infrastructure, such as temporary use roads or access      to construct necessary infrastructure does        within a least concern regional ecosystem.
tracks, maintains the composition, structure and function of least   not occur in a least concern regional
concern regional ecosystems.                                         ecosystem.
                                                                     OR
                                                                     AO12.2 Total clearing for temporary use
                                                                     areas to construct necessary infrastructure
                                                                     in any regional ecosystem combined
                                                                     does not exceed the widths prescribed in
                                                                     table reference table 1 of this code.
                                                                     OR
                                                                     AO12.3 Total clearing for temporary use
                                                                     areas to construct necessary infrastructure
                                                                     in any regional ecosystem combined
                                                                     does not exceed areas prescribed in table
                                                                     reference table 1 of this code.
PO13 Where clearing of vegetation in a regional ecosystem for        No acceptable outcome is prescribed.             The proposed necessary clearing is not for a
temporary use areas to construct necessary infrastructure does not                                                     temporary use or infrastructure but to ensure
maintain the composition, structure and function of the regional                                                       the existing and proposed development is at
ecosystem, and cannot be avoided and has been mitigated, the                                                           an acceptable level of bushfire risk as
cleared area is rehabilitated.                                                                                         required under the State Planning Policy,
                                                                                                                       Natural Hazards, Risk and Resilience.

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Performance outcomes                                               Acceptable outcomes                          Response
Conserving endangered and of concern regional ecosystems
PO14 Clearing of vegetation maintains the composition, structure   AO14.1 Clearing does not occur in an            Necessary clearing for a necessary firebreak
and function of endangered regional ecosystems and/or of           endangered regional ecosystem or an of           will occur withi9n an area of Endangered
concern regional ecosystems.                                       concern regional ecosystem.                      Regional Ecosystem, that being the
                                                                   OR                                               RE12.5.3.

                                                                   AO14.2 Total clearing of endangered             The proposed clearing is for approximately
                                                                                                                    801.81 sq. m. and as such the RE12.5.3, a
                                                                   regional ecosystems and of concern
                                                                                                                    sparse structural as described in the
                                                                   regional ecosystems combined does not
                                                                   exceed the widths prescribed in table            Regional Ecosystem Description Database
                                                                                                                    (REDD) and comply with the maximum
                                                                   reference table 1 of this code.
                                                                                                                    clearing area specified in Table 1 of State
                                                                   OR                                               Code 16.
                                                                   AO14.3 Total clearing of endangered
                                                                   regional ecosystems and of concern
                                                                   regional ecosystems combined does not
                                                                   exceed areas prescribed in table reference
                                                                   table 1 of this code.
PO15 Where clearing of vegetation in an endangered regional        No acceptable outcome is prescribed.            The necessary clearing within the
ecosystem or an of concern regional ecosystems does not                                                             endangered regional ecosystem 12.5.3 can
maintain the composition, structure and function of the regional                                                    not be mitigated as its necessary clearing for
ecosystem, and cannot be avoided and has been mitigated, the                                                        a necessary firebreak around infrastructure.
cleared area:                                                                                                      The area, 801.81 sq.m. will be maintained as
1. is rehabilitated; or                                                                                             a native grassland to the extent that native
2. where the cleared area cannot reasonably be rehabilitated, an                                                    grasses will recolonise the area.
   offset is provided for any acceptable significant residual                                                      No offsets are proposed as the clearing is
   impact.                                                                                                          considered to be exempted clearing.
Essential habitat excluding essential habitat for Phascolarctos cinereus (koalas) if development is assessable under Schedule 10, Part 10 of the Planning
Regulation 2017

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Performance outcomes                                                   Acceptable outcomes                        Response
PO16 Clearing of vegetation in a regional ecosystem that is an         AO16.1 Clearing does not occur in             The proposed clearing is considered to be
area of essential habitat maintains the composition, structure and     essential habitat.                             exempt development under Schedule 10,
function of the regional ecosystem for each protected wildlife                                                        Part 10, Division 2, s16A (2) and Division 3,
                                                                       OR
species individually.                                                                                                 subdivision 1 s16B (2)(a) of the Planning
                                                                       AO16.2 Clearing in essential habitat           Regulation 2017 for areas mapped as a
                                                                       does not exceed the widths prescribed in       Priority Koal Area (PKA).
                                                                       reference table 1 of this code.
                                                                                                                     The necessary clearing for a necessary
                                                                       OR                                             firebreak is exempted development but
                                                                       AO16.3 Clearing in essential habitat           despite that, the necessary clearing will be
                                                                       does not exceed the areas prescribed in        less than that specified in Table 1 of State
                                                                       table reference table 1 of this code.          Code 16.

PO17 Where clearing of vegetation in a regional ecosystem that is      No acceptable outcome is prescribed.          The necessary clearing for a necessary
an area of essential habitat does not maintain the composition,                                                       firebreak is exempted clearing and as such
structure and function of the regional ecosystem, and cannot be                                                       no offsets are required.
avoided and has been mitigated, an offset is provided for any
acceptable significant residual impact for each protected wildlife
species individually.
Acid sulfate soils if the local government is not the assessment manager for the development application
PO18 Clearing of vegetation does not result in, or accelerate,         AO18.1 Clearing does not occur in land        The clearing proposed is in a land zone
disturbance of acid sulfate soils or changes to the hydrology of the   zone 1, land zone 2 or land zone 3.            identified as land zone 5.
location that will result in either of the following:
                                                                       OR
1. aeration of horizons containing iron sulphides;
                                                                       AO18.2 Clearing in land zone 1, land
2. mobilisation of acid or metals.                                     zone 2 or land zone 3 in areas below the
                                                                       five metre Australian Height Datum only
                                                                       occurs where:
                                                                       1. mechanical clearing does not disturb
                                                                          the soil to a depth greater than 30

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Performance outcomes   Acceptable outcomes                      Response
                           centimetres; and
                       2. acid sulfate soils are managed
                          consistent with the soil management
                          guidelines in the Queensland Acid
                          Sulfate Soil Technical Manual.

Page 14

If you have any further questions, please contact me directly or via Council’s Town Planner, Mr
Shane Adamson of Adamson Town Planning.
Yours faithfully,




Rob Friend
Director
Rob Friend & Associates Pty Ltd

Page 15

15

Figure 1 — exempted and necessary clearing line work.

Page 16

Doonana Waste Management Facility                                                                                                                                                                                A product of

Existing exemped clearing (yellow) and additional exemption (white line) aqrea is 235.53 sq.m. which is exempted development
26°26'6"S 153°1'26"E                                                                                                                                 26°26'6"S 153°1'32"E




                                                                                                                                                                                  Legend located on next page




                                                                                                                                                                                      Setback lines

                                                                                                                                                                                      1.5 times Tree height (45m)
                                                                                                                                                                                      (existing development)


                                                                                                                                                                                      1.5 times tree height (45m)
                                                                                                                                                                                      proposed development




                                                                                              24.02 m
                                                                                  24.00 m




                                                                                                                               24.01 m
                                                                 24.0 12.40 m




                                                                                                24.01 m
                                                                 24.0




                                  16
                                                                  24.




                                       6.0
                                               24.0




                                                                                                                                                 m
                                                                      02




                                          3
                                                                      0m
                                                                       1m




                                       23 sq



                                                                                            12.41 m




                                                                                                                                        .02
                                                                        12.41 m




                                                                                                                                                                                      State Code 16 additional
                                                                         m




                                                                                                                               12.41 m
                                                  0m




                                         .9     m




                                                                                                      12.41 m




                                                                                                                                      m
                                                                                                                                     24
                                                       12.41 m




                                            9
                                              m




                                                                                                                                    1
                                                                 23.9                                                                            m                                    clearing for a firebreak




                                                                                                                                  .4
                                                                     9m                                                                     41
                                             12




                                                                                                                                         12.




                                                                                                                               12
                                              .40
                                                  m




                                                                                                                                                                                      Radiant heat flux 29kW/m2
                                                                                                                                                                                      Acceptable level of bushfire
                                                                                                                                                                                      risk (12.4m) = Necessary clearing
                                                                                                                                                                                      for a necessary firebreak




                                                                                                                                                                                                                 0             10 metres
                                                                                                                                                                                                                     Scale: 1:600

                                                                                                                                                                                                                   Printed at: A3
                                                                                                                                                                                                               Print date: 28/7/2025
                                                                                                                                                                                                     Not suitable for accurate measurement.
                                                                                                                                                                                                  Projection: Web Mercator EPSG 102100 (3857)
                                                                                                                                                                              For more information, visit https://qldglobe.information.qld.gov.au/help-info/Contact-
                                                                                                                                                                                                                       us.html
                                                                                                                                                                             Includes material © State of Queensland 2025. You are responsible for ensuring that
                                                                                                                                                                             the map is suitable for your purposes. The State of Queensland makes no
                                                                                                                                                                             representation or warranties in relation to the map contents and disclaims all liability.
                                                                                                                                                                             If imagery is displayed, imagery includes material © CNES reproduced under license
                                                                                                                                                                             from Airbus DS, all rights reserved © 21AT © Earth-i, all rights reserved, © Planet Labs
                                                                                                                                                                             PBC, 2023




                                                                                                                                                                              Department of Natural Resources and Mines, Manufacturing, and Regional
26°26'11"S 153°1'26"E                                                                                                                                26°26'11"S 153°1'32"E                            and Rural Development

Page 17

Doonana Waste Management Facility
Existing exemped clearing (yellow) and additional exemption (white line) aqrea is 235.53 sq.m. which is exempted development
   Legend                                                                                                                          Attribution



                                                                                                                               Includes material © State of Queensland (Department of Resources); ©
     Vegetation management            Land parcel label - gt 10                                                                Commonwealth of Australia (Geoscience Australia); © 21AT, © Earth-i, all rights
                                                                                                                               reserved, 2025.
     regional ecosystem map           ha
     labels                                                                                                                    © State of Queensland (Department of Resources) 2023

                                                                                                                               © State of Queensland (Department of Natural Resources and Mines,
                                      Land parcel label - gt 1000                                                              Manufacturing and Regional and Rural Development) 2025
     Category A or B area             ha
                                                                                                                               © State of Queensland (Department of Resources) 2024
     containing endangered
                                                                                                                               © State of Queensland (Department of Natural Resources and Mines,
                                      Places: My Places(1)                                                                     Manufacturing and Regional and Rural Development) 2024
     Category A or B area                  My Place 3
     containing of concern
                                      Roads and tracks
                                           Motorway
     Category A or B area that             Highway
     is least concern
                                           Secondary

                                           Connector
     Category C or R area
                                           Local
     containing endangered
                                           Restricted Access Road

                                           Mall
     Category C or R area
     containing of concern                 Busway

                                           Bikeway
                                           Restricted Access
     Category C or R area that
                                           Bikeway
     is of least concern
                                           Walkway
                                           Restricted Access
     Land parcel                           Walkway
            Parcel                         Non-vehicular Track

     Land parcel - gt 1 ha                 Track

            Parcel                         Restricted Access Track

     Land parcel - gt 10 ha                Ferry

            Parcel                         Proposed Thoroughfare

     Land parcel - gt 1000 ha         Green bridges
            Parcel

     Land parcel label                Bridges


     Land parcel label - gt 1 ha      Tunnels


                                      Railway stations

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