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APZ Fire Break Trail Tree Retention - 30 Pottery St Pomona 270526

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NCES Ref: J000864



27th May 2026

Brian Naismith
Via Email: [email protected]


Dear Brian,
RE: Vegetation Management Plan for APZ / Fire Break Trail Tree Retention - 30 Pottery
St Pomona
Please find herewith my response to the matters raised in RFI Item 12 for the OPW application
for 30 Pottery St Pomona.




Condition 25 of the higher order approval states:

‘The development must be carried out generally in accordance with Bushfire Hazard
Assessment and Management Plan v2 prepared by North Coast Environmental Services
dated June 2021…’.

Condition 25f (vi -vii) states:

vi. A Vegetation Management Plan (VMP) must identify all trees within the APZ
which are required to be removed for protection of any future structure within Lots
7, 8 and 9.
vii. The VMP must be submitted to Council for approval as part of the Operational
Works approvals.

A tree survey of the canopy trees located in the APZ’s for Lots 7-9, excluding trees located in
the footprint of the approved firebreak trail therein, has been completed by NCES to assist in
determining which trees are required to be removed for the protection of any future structures
within the Lots 7, 8 and 9, and to satisfy OPW RFI item 12.1. The results of the tree survey
are detailed on the plan titled ‘Tree Location Survey Proposed APZ 30 Pottery Street Pomona’
prepared by Brian Naismith (refer Appendix 1). Note, the firebreak trail extent has been
reduced to minimise the disturbance of significant habitat trees in Lot 9 and also facilitate
retention of a cluster of trees on the northern APZ boundary of Lot 7. The modification of the




                     PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
                                               1

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NCES Ref: J000864



trail is supported by NCES given it still facilitates suitable access to the covenant boundary of
Lots 7-9 and emergency services vehicles can readily turn around at the access handle
intersection with the fire break trail.

The Tree Location Survey identifies a total of 36 canopy trees including 2 significant habitat
trees host to numerous arboreal hollows; Tree no’s 1 and 2, are captured in the APZ.

Section 5.2 in the approved BHAMP states:




Section 5.6 in the approved BHAMP states:




The building envelopes on Lots 8 and 9 are situated immediately adjacent to their APZ’s. The
existing house on Lot 7 is situated approximately 7m from its APZ boundary. Numerous
surveyed trees are located within 6m of the approved building envelopes on Lots 8 and 9 and
therefore are required to be removed based on the specified criteria in section 5.6 above.

Retention of large eucalypt trees within proximity to dwellings is not desirable and should be
viewed with caution particularly in APZ’s. All surveyed trees in the APZ comprise Myrtaceae
species which will achieve significant heights in the range of 30-45m at maturity (i.e. tree no 2
was recorded at 30m height already). Large trees tend to exhibit long limb lengths quite often
in the order of 8-10m and large crown diameters which frequently interlock with adjacent trees.
This scenario represents high risk of facilitating a crown fire, should it occur, well into the
vertical column of the APZ. This scenario is not recommended given the extensive high-risk
fire run from the west and can be considered to facilitate an unacceptable risk.

Based on the above it is recommended:
    •   All trees within the APZ’s on Lots 7 – 9 be removed precluding the habitat Trees no’s
        1 and 2 in the south of Lot 9 and tree no’s 22-24 in the north of Lot 7. An echidna
        burrow was also identified just south of tree no’s 22-24 and should also be preserved.
        Tree no’s 1-2 and 22-24 are significantly removed from the Lot 9 and Lot 7 building
        envelopes respectively hence represent acceptable bushfire risk.
    •   It is recommended the fire break trail be constructed in a manner to ensure the viability
        of the trees and burrow to be retained. Guidance from a qualified arborist should be
        sought in this regard.
    •   The APZ’s in Lots 7 – 9, excluding fire break trail corridor, should preference
        manicured lawn conditions. Provision of low density, low flammability landscaping
        treatments in the APZ comprised of groundcovers and shrubs is acceptable where
        located >6m from the building envelopes and where it satisfies the AS3959 definition
        of low threat vegetation.




                    PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
                                              2

Page 3

NCES Ref: J000864



    •   No trees are replanted in the APZ unless they are located >10m from the building
        envelope, limbs do not encroach within 6m of the building, and they exclusively
        comprise low flammability species such as rainforest species or fruit trees.

Should you have any queries regarding this matter please do not hesitate to contact me.
Sincere regards,

Joshua Lee - Director
B. Sc. AES (Ecology, Land & Water, Pollution & Health), mFPAA.
Email: [email protected]




                    PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
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Page 4

NCES Ref: J000864



APPENDIX 1 – TREE LOCATION SURVEY




                    PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
                                              4

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                                                                                            24 23
                                                                                                            22                      28
                                                                                                                               34             30
                                                                                                                                                        31
                                                                                                                     21             36
                                                                        BURROW                                                                     29   32
                                                                                                                                         27
                                                                                                                                                    33

                                                                                                      20
                                                                                                                     25
                                                                                                           19
                                                                                                                     26
                                                                                                       18
                                                                                                                                                                                 SE
                                                                                                                                                                            H OU
                                                                                                                                                                          K
                                                                                                                                                                     OC                        R
                                             Existing                                                                                                           BL                           CA RT
                                             Access Track                                                       16                   35
                                                                                                                          17                                                                  PO

                                                                                            14            15
                                                                        rail
                                                                      eT




                                                                                       13   12
                                                                     Fir




                                                                                                          11
                                                                                                                                                                    TIO               7
                                                                    e




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                                                                 wid




                                                                                                  10
                                                                6m




                                                                                            8
                                                                                                  9
                                                                               7
                                                                                                                           BU
                                                                                                                          EN ILDIN
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                                                                                                                               LO
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      8                                                                            6




                                                                                                 3. 5 m
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                                                                                                                          Acce
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                                     wid
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                                                      5
                 17.2m from Lo




                                                                                            BUILDING
                                                                                            ENVELOPE

      TPZ
                                         4

2
SRZ
                                         3
                                                                        9

                                                          TPZ

            SRZ
                                                                                                                                         6
             1                                                              17.2m from Lo
                                                                                                t 9 envelope
                                                                  SEWE
                                                                       R




                                                                           & DRAIN
                                                                                       AGE EA
                                                                                              SEMEN
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                                                                                                                                               Cadastral & Engineering
                                                                                                                                                Surveying Consultant
                                                                                                                                              Gympie & Sunshine Coast

                                                                                                                                               E-MAIL                                     PHONE
                                                                                                                                               [email protected]                  0477 925 871

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Pt No East North Type DBH Canopy Diam Crown Height Comments
1 484908.3 7084046 BLACKBUTT 2000 20s es HABITAT
2 484900.6 7084059 GREY GUM 700 10S 30 HABITAT
3 4849133 7084057 TURPENTINE 450 8 15
4 484914 7084063 PINK BWOOD 300 6 1S
5 484917.8 7084077 PINK BWOOD 550 10 15
6 484929 7084091 BLACKBUTT 600 10 20
7 484927.9 7084097 PINK BWOOD 220 5 15
8 484933.3 7084098 BLACKBUTT 700 10 15
9 484935,7 7084098 TURPENTINE 280 10 15
10 484937.9 7084100 TURPENTINE 600 8 20
11 484937.6 7084101 TURPENTINE 320 8 15
12 484933.1 7084102 TURPENTINE 160 6 8
13 484930.1 7084103 TURPENTINE 220 3 8 BESIDE DEAD
HOLLOW _ TRUNK
14 4849333 7084105 BLACKBUTT 170 5 8
15 484937.8 7084105 TURPENTINE 250 7 10
16 4849415 7084108 TURPENTINE 175 3 7
17 4849423 7084108 BLACKBUTT 150 4 6
18 484937.1 7084114 TURPENTINE 175 6 10
19 484938 7084116 STYBK 2X300 10 10 DOUBLE TRUNK
20 484938.5 7084118 PINK BWOUD 350 10 18
2l 4849408 7084123 TURPENTINE 150 8 10
22 484938,3 7084127 TURPENTINE 2X250 17 15 DOUBLE TRUNK
23 484936.2 7084128 TALLOW 2X300 le 20 DOUBLE TRUNK
24 484934.9 7084128 TURPENTINE 250 6 8
25 4849409 7084116 PINK BWOOD 300 150 100 10 15 TRIPLE TRUNK
26 484941 7084114 TURPENTINE 2X150 6 10 DOUBLE TRUNK
27 484947,1 7084123 MAHOGANY 500 12 20
28 484947,.5 7084127 PINK BWOOD 350 10 1S
29 484950.6 7084122 TURPENTINE 150 5 8
30 4849508 7084126 TURPENTINE 400 10 15
31 484952.6 7084125 BLACKBUTT 400 10 10
3e 484952.7 7084123 STYBK 250 8 10
33 4849515 7084121 STYBK 400 15 18
34 484944.4 7084125 TURPENTINE 2e5 10 15
35 48494611 7084107 MAHOGANY 450 20 2s
36 484945.4 7084124 TURPENTINE 250 10 15
0 50 m 100 m 150 m ’
O ! ! L50/mm | ! L100 |mm | ! ! 150 [mm
Client: LEAPE Sheet of BRIAN
Plon No: ff Sheet 2 scle: £21000 2 | 2 NAISMITH/

 

 

 

 

 

 

 

 

 

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