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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.
4
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).
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. Additionally, as a consequence of the removal of the truncated area within the north-
eastern corner of the development, this area is considered to be infrastructure and as such
the exempted clearing extent (24 metres) and the necessary clearing (12.4 metres) lines
have been identified in Figure 1c. The additional area of Category B regulated vegetation
that will be considered to be exempted development in this area is approximately 296
sq.m..
10. 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”.
11. Therefore, the necessary clearing is only that which is required to provide an acceptable
level of bushfire risk for the proposed development.
12. 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.
13. 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
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