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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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                                                     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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