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Attachment 1 - Amended advice form Rob Friend and Associates
Attached to the e-mail Applicant Response to SARA Advice Notice - 132005.638.04.
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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).
7. There is an area within the north-eastern corner of the existing facility that contains a
truncation, see Figure 1a below. The vegetation immediately adjacent to this area and
within the truncation is covered by the PMAV and is mapped as Category X regulated
vegetation. Further, this truncation will be removed with the proposed development
extending to the perpendicular corner in the north-eastern corner of the facility.
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 15.78 metres (16 m has been adopted) (see Attachment 1 – tree height
comparison Photograph. Note the height model is 1.72 metre in height), 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
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