Att 1 - North Coast Environmental Response to Items 6 & 7

                                                                                        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.




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