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Att 1 - North Coast Environmental Response to Items 6 & 7
Attached to the e-mail 002892 - MCU26_0047 - 122 Musa Vale Road_ Cooroy - Information Response.msg.
NCES Ref: J001465 17 July 2026 Russell Green RG Strategic Via email: [email protected] Dear Russell, RE: Response to Noosa Council RFI Items 6 & 7 Bushfire to support proposed MCU Short Term Accommodation application for 122 Musa Vale Rd Cooroy QLD. As per your request, I have reviewed the Council Information Request, the site plans, existing BAL Report by Daniele Steele, and conducted a desktop review of site conditions and available site photography. Based on the review undertaken please find below my response to Items 6 and 7 of the RFI. Item 6 The proposed Material Change of Use from a secondary dwelling to short-term accommodation does not inherently alter the bushfire classification of the site under the Bushfire Resilient Communities (BRC) Technical Reference Guide (QFES 2019) methodology. The BRC methodology determines bushfire hazard based on physical site characteristics including vegetation hazard class, fuel loads, slope, landscape position, separation distances and radiant heat exposure. These parameters are unaffected by a change in the planning use of an existing building. The proposed development does not involve additional clearing, earthworks, changes to vegetation, alterations to separation distances or relocation of the existing approved dwelling. Accordingly, the bushfire hazard classification applicable to the site remains unchanged. A site-specific Bushfire Attack Level (BAL) assessment previously prepared by Bushfire Assessment Queensland assessed the existing dwelling location using the AS3959-2018 Method 2 assessment whilst adopting fuel loads and FFDI specified under BRC methodology. The BA assessment determined the required construction standard to be BAL-12.5. BAL-12.5 corresponds to a design radiant heat exposure of up to 12.5 kW/m², which is substantially below the 29 kW/m² radiant heat flux benchmark generally accepted by Council and adopted by the Queensland State Planning Policy guidance for non- vulnerable uses. Short-term accommodation is not considered a vulnerable use in the same manner as hospitals, aged care facilities, schools or childcare centres. Consequently, the existing BAL-12.5 construction standard provides a level of radiant heat exposure well below the benchmark generally accepted for non-vulnerable development. Accordingly, subject to the existing BAL construction requirements continuing to be maintained, the proposed use does not trigger a different bushfire classification, nor does it introduce additional building construction requirements. Item 7 A separate Bushfire Hazard Assessment and Management Plan is not considered necessary to demonstrate that the proposed Material Change of Use can achieve an appropriate level of bushfire safety. Unlike development involving new buildings or subdivision, the proposal relates solely to the use of an existing lawfully approved dwelling. The physical characteristics of the site remain unchanged, including the building location, surrounding vegetation, access arrangements and available defendable space. The following matters demonstrate that the proposal maintains an appropriate level of bushfire safety. PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625 1
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NCES Ref: J001465
Building Siting and separation
The existing BAL assessment concluded that the dwelling achieves a BAL-12.5 construction standard
based on the existing vegetation, fuel loads, slopes and separation distances. Consequently, the
existing BAL-12.5 construction standard provides a level of radiant heat exposure well below the
benchmark generally accepted for non-vulnerable development. The degree of separation to validate
the BAL-12.5 construction appear to be clearly available about the dwelling based on interpretation of
aerial imagery and a collection of site photographs provided by the applicant. It is therefore reasonable
to conclude this separation will be available about the use for the life of the development. Plates A-D
illustrate the cleared conditions maintained about the dwelling.
Plate A - Hard stand area next to north (centre image) and west (RHS image) elevations
Plate B Low threat landscaping and lawn adjacent to south elevation
PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
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NCES Ref: J001465
Plate C Low threat landscaping and lawn adjacent to north elevation
Plate D Low threat landscaping and lawn adjacent to north -east elevation
Safe access and evacuation
The dwelling is accessed via the existing internal driveway connecting directly to Musa Vale Road. The
access route traverses managed, low-threat grassed areas and established infrastructure before
reaching the public road network. No changes are proposed to this access arrangement. It is noted the
access and evacuation route is considerably shorter than at for the existing approved short term
accommodation dwelling situated at the rear of the property.
The existing driveway provides a practical evacuation route for occupants and access for emergency
vehicles. Based on the available information, the access arrangement appears capable of facilitating
evacuation and emergency response without reliance on travel through hazardous vegetation within
the site.
PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
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NCES Ref: J001465
Firefighting water supply
Council has requested confirmation that a minimum of 5,000 litres of dedicated firefighting water is
available. The proposed use contains an existing round plunge pool located adjacent to the north-east
corner of the dwelling with a reported approximate storage capacity of 6,500 litres. The pool is readily
accessed from the hard stand area, and, on this basis, the proposed development exceeds Council's
nominated minimum firefighting water supply requirement. The pool water is not used for any other
purpose beyond bathing hence can be considered to be reliably available for dedicated fire fighting use.
Transfer of existing short-term accommodation approval
It is relevant that the site already benefits from an approval for short-term accommodation associated
with the existing five-bedroom dwelling. As part of this application, that approval will be relinquished
and transferred to the existing one-bedroom small dwelling. Accordingly, the proposal does not create
an additional short-term accommodation use on the property but simply relocates the approved use to
a substantially smaller building.
In practical terms, the proposal is likely to result in a reduction in the number of guests able to occupy
the site at any one time for short-term accommodation purposes. Consequently, the proposal is not
expected to increase the concentration of people exposed to bushfire risk and may, in fact, reduce the
potential number of occupants requiring evacuation during a bushfire event. This further supports the
conclusion that the proposal does not materially alter the bushfire risk profile of the site.
Overall conclusion
The proposed use does not alter the site's bushfire hazard classification, increase bushfire intensity,
modify vegetation, change the existing defendable space established for the dwelling or alter the
bushfire risk profile of the site. The existing BAL-12.5 assessment demonstrates that the dwelling has
been designed for a radiant heat exposure significantly below the 29 kW/m² benchmark generally
adopted for non-vulnerable development. Existing access arrangements provide a practical evacuation
route via the internal driveway to Musa Vale Road through predominantly low-threat maintained areas,
while the existing swimming pool provides in excess of the 5,000 L firefighting water volume requested
by Council.
Accordingly, the proposal maintains an appropriate level of bushfire safety and preparation and
submission of a detailed Bushfire Hazard Assessment and Management Plan appears unnecessary. It
is however recommended that a Bushfire Evacuation Plan should be prepared and made available on
the premises to assist occupants in the event of the local bushfire. It would be reasonable that provision
of the BEP can be set as a condition of approval on the provision the BEP is submitted to and approved
by Council prior to commencement of the use.
Should you have any queries regarding this response please do not hesitate to contact me
Sincere regards,
Joshua Lee – Director B. Sc. AES (Ecology, Land & Water, Pollution & Health) mFPA
Ph: 0406 626913, Email: [email protected]
PO Box 385 Peregian Beach QLD 4573 | ABN 60 625 108 625
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