RFI - Attachment 7B - SARA Bushfire Response.pdf

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demonstrate that all reasonable avoidance, minimisation and mitigation measures of development have been undertaken in
order to ensure that the proposed development will not impact koala habitat or MSES.
Action
It is requested that applicant provide further information on PO1 and PO5 of State code 25: Development in South East
Queensland koala habitat areas (State code 25) of the SDAP.
Provide a report prepared by an appropriately qualified ecologist that:
identifies the number of NJKHTs on site that are proposed to be impacted including those that could be impacted from
the future use of the site (e.g. infrastructure, excavation or fill) and as exempted development (as defined in Schedule 24 of
the Planning Regulation 2017) which would apply as a natural and ordinary consequence of the development.


Response

    •    A Bushfire Management Plan has been prepared by Rob Friend and Assocs. (Dated 24 Sept 2021), and
         is attached to this report.
    •    The findings are summarised as:
         ‘The development will occur primarily over land that is already cleared and be utilised for structures like
         tennis courts and landscaping. The hazardous vegetation retained in proximity to the development site
         is separated by Resort Drive, tennis courts and auxiliary parking which will provide a buffer between
         hazardous vegetation and proposed structures.’
    •    The Actions for bushfire mitigation include landscaping within the development footprint abutting
         determined bushfire hazards, including management of the understory.
    •    The BMP recommends two bands of understory management within the landscaping proposed for the
         development site, with a focus on selection of low flammability species for understory plantings. The
         basis of the managed vegetation zone is to provide separations from potential bushfire hazard area
         which are located outside of the property boundary.
    •    The BMP Landscaping within the property also includes detail on existing vegetation and management
         of vegetation into the future:
         ‘We further note that it is likely this landscaped area will be subjected to regular maintenance due to the
         type of development i.e. the boutique hotel and as such, the use of less flammable plant species would
         also be regularly maintained to ensure they perform the task of reducing the flammability of the
         groundcover and understorey within the landscaped area.’
    •    The management of understory vegetation less than 2m in height is to reduce potential surface and
         near surface fuel loads. Canopy fuels are unlikely to be involved in a bushfire at this site. As such the
         removal or interference with mature trees is deemed unnecessary.
    •    For the purpose of bushfire mitigation, no mature trees will require removal within the development
         footprint or immediate surrounds.
    •    With regard to the remaining trees identified on the Tree Removal Plan (Appendix E, Gondwana Ecology
         Group, 26 February 2021), these tress would not be require to be removed as the clearing of these
         trees would not be considered to the “necessary” as specified in the Panning Regulation 2017,
         Schedule 10, Part 10, division 3, subdivision 1, S16B.
    •    Further, while the tennis courts could be considered infrastructure, the retained NJKHT’s do not present
         a bushfire hazard to the tennis courts and as such they fail to be the basis of “necessary clearing” as
         defined for Essential management in Schedule 24, referring to exempt clearing work under Schedule
         21, Part 2 (c).




2107-23530 SRA | 61 Noosa Springs Drive | RF17-040                                                    18 November 2021
                                           Rob Friend & Associates Pty Ltd