PLANNING & ENVIRONMENT REPORT - RAL22/0027 - Final Report

AO1.1
      Development which will materially increase the number of people living or congregating on
      premises, including reconfiguring a lot, is not located within a medium or high bushfire hazard
      area.
AO7
      Each residential lot:

        a) includes a building envelope, identified on a plan of subdivision;
        b) is of sufficient size and shape to allow for efficient emergency access to buildings for
           fire fighting appliances (e.g. by avoiding battle-axe/hatchet lots and long narrow lots
           with long access driveways to buildings);
        c) where more than 2500m², achieves setbacks from hazardous vegetation in line with
           Bushfire Attack Level 29 requirements as per AS3959; and
        d) is designed so that buildings and structures are sited in locations of lowest hazard
           within the lot and elements of the development least susceptible to fire are closest to
           the fire hazard.
AO8.3

      Bushfire management measures are carried out on the subject property and not any
      adjoining property.
The proposed 1 into 2 lot subdivision is located in a high bushfire hazard area as identified by the
Bushfire Hazard Overlay (refer to Figure 3). The creation of a battle-axe lot within this area
increases the number of people living or congregating on the premises. The submitted Bushfire
Risk Assessment and Management Plan includes a nominated building envelope. The proposed
building envelope’s suitability (i.e., located outside of 29kW/m2) is flawed as it relies on a firebreak
on the adjoining land being managed by QPWS.
The application does not comply with the Acceptable outcomes and therefore is to be assessed
against the corresponding Performance Outcome.
The corresponding Performance Outcome seeks:
PO1
      Development maintains the safety of people and property from the adverse impacts of
      bushfire.
PO7
      Lot design and building siting minimises bushfire hazard risk to people and property.
In assessment against the Performance Outcome regard is given to the State Planning Policy 2017
(where not integrated in the Noosa Plan 2020) in determining whether the above Outcomes are
met.
The submitted Bushfire Risk Assessment and Management Plan identifies a building envelope
which achieves <29kW/m2 radiant heat flux. The material provided indicates that a separation of
16.7m from the northern boundary, and 11.3 from the western boundary would be required to
achieve 29kW/m2 to a designated building envelope and achieve the QPWS requirements of ‘fire
mitigation measures, including the establishment of fire protection buffers and/or building setbacks
consistent with urban interface requirements are placed on the subject land’. However, to achieve
this the building envelope relies on the separation distance afforded by the National Parks and
Council reserves buffers to achieve the appropriate 29kW/m2 separation from the hazardous
vegetation, as detailed in Figure 5.
In similar circumstances QPWS have previously advised that the severity of a potential bushfire is
to be based off factors within the landholders’ control, not based off third-party maintenance of a
firebreak to such a standard. The calculated exposure limits are therefore incorrect. A revised
assessment of the required separation distance from the hazardous vegetation, which was
undertaken by Council’s Senior Environment Officer, concludes an area of approximately only