Information response

9      Written endorsement of the Emergency Response Plan from Queensland Fire &
       Emergency Services.
It is recommended that the evacuation plan be reviewed by or completed in conjunction with
QFES. Council may wish to include this as a condition of approval. The plan cannot be
completed in full at the present time as staff and residents have not yet been determined.
QFES would also be able to identify appropriate evacuation triggers as discussed above.

Issue – Bushfire
The proposed bushfire approach relies on achieving a radiant heat flux of 19 kW/m2 at
the building to justify the construction of this facility within the site. A dependence
on increased building design and construction standards for an aged care facility is
not considered appropriate. Additionally, the protection of the building from a
bushfire using construction standards does not take into consideration the impact a
fire and smoke has on residents.

Information Required
10     Provide additional justification of the location of this facility within the
       hazardous location to support the proposal for an aged care facility within an
       area identified as a Very High Potential Bushfire Intensity.
The submitted bushfire report recommends that the proposed building be constructed in
accordance with AS3959:2009 to mitigate against any potential flame, radiant heat or ember
attack. AS3959:2009 is only legally applicable to class 1 and 10 buildings under the National
Construction Code. In this respect the adoption of construction standards is voluntary.

The adoption of bushfire construction standards will greatly increase the ability of the
building to survive the passage of an uncontrollable wildfire. The proposed facility will also
be designed to combat any internal structural fires by including fire compartments, sprinkler
systems etc designed by a qualified fire engineer.
It should be noted that greater than 80% of buildings that have been destroyed by bushfires
in Australia have been destroyed by ember attack. Building construction methods are the
only appropriate method to mitigate against this within a bushfire prone area. BAL 19 is
designed to mitigate against ember attack and lower levels of radiant heat flux. It should be
pointed out that adopting a larger fire break such as 1.5 times the canopy height of adjoining
vegetation does not mitigate against ember attack, as burning embers can travel a far
greater distance than this typical width.
There is a strong argument to be made that adopting bushfire construction standards to
mitigate against wildfire is better than providing larger firebreaks as a building is less open to
change from season to season in terms of its maintenance, whereas a firebreak may not be
mown, resulting in an increase in fuel loads etc and is therefore a less reliable mitigation
measure. Passive protection measures such as permanent features (houses, driveways,
walls etc.) are more reliable than active mitigation measures such as landscape
maintenance, firefighting intervention, sprinkler systems etc.

The recommendations within the bushfire report appropriately address the hazard by
mitigating against known bushfire behaviour attack mechanisms, creating defendable space
for fire authorities, adopting appropriate emergency response arrangements for staff and
residents, designing landscapes that help mitigate rather than exacerbate bushfire risk,
providing water supply and other facilities to combat fires and including education to
increase community resilience. The proposed mitigation measures combine to reduce the
residual risk to more than acceptable levels.