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ATTCH 2 - IR Response - Ecological and Bushfire IR Response (Cardno)
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Our Ref : WE17035:KJD
Contact: John Delaney
Cardno (Qld) Pty Ltd
ABN 57 051 074 992
13 November 2017
Level 11
515 St Paul’s Terrace
Fortitude Valley QLD 4006
Australia
Kenlynn Pty Ltd
C/- Urban Systems Pty Ltd Locked Bag 4006
4/24 Kurilpa Street Fortitude Valley QLD 4006
WEST END QLD 4101 Australia
Attention: Mr Peter Cumming
Phone: 61 7 3369 9822
Fax: 61 7 3369 9722
www.cardno.com
Dear Peter
INFORMATION REQUEST (APPLICATION REF: RAL 17/0501) – RESPONSES TO ECOLOGY AND
BUSHFIRE ISSUES
In respect of ecological and bushfire related issues raised in an Information Request issued by the Noosa
Shire Council (Council) on the 7th of September 2017, we provide the following responses.
Vegetation
Protection of Community Assets and Resources
Coastal dune vegetation plays an important role as a first line of defence for storm surge and sea level
rise in the protection of community assets such as David Low Way. The site is located in a Coastal
Management District and a Coastal Protection Area. Protection of vegetation in this location is
important for site stability and protection of community assets.
Information Required
1. Demonstrate the development can provide suitable protection of community assets including
David Low Way, the dune systems, the adjacent vegetation, and accommodate storm surge,
sea level rise, and extreme storm events and allow for ambulatory changes to the head of
Burgess Creek. Include an assessment of the on-going use and the impacts on the fore dunes
through increased access, whilst not burdening regulatory services to manage the area. Also
include an analysis of the clearing required for provision of sight lines for safe access as
required in Item 13 of this Information Request.
Response
Coastal erosion, storm surge, sea level rise and Coastal Management District issues have been dealt with in
the material prepared by Dr Trevor Johnson and submitted in support of the Application. That material
demonstrates that:
a) there is no evidence of coastal erosion occurring on the Site;
b) Since at least 1958 the coastal erosion line lies well to the east of the property boundary, with the
maximum extent of erosion coming no closer than 70 m to the seaward boundary of the Site;
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Full text of sections 2 to 43 (of 71)
Section 2
: WE17035 2
13 November 2017
c) erosion evident from historical aerial photography is consistent with a maximum storm bite of 30m to
40m, with there being no evidence of long term erosion caused by littoral drift;
d) detailed numerical coastal erosion modelling presented in support of the Application, which takes into
account future climate change effects, demonstrates that the Site lies outside of the erosion prone
area as such the vegetation on the Site has does not play an active role in defending community
assets against coastal erosion; and
e) the proposed development will not have any adverse impacts on vegetation within those parts of the
coastal dune system to the east of the Site that is located within an erosion prone area.
In respect of Council’s request for “an assessment of the on-going use and the impacts on the fore dunes
through increased access, whilst not burdening regulatory services to manage the area” the following points
are noted.
a) The fore dunes to the east of the Site and David Low Way are traversed by a number of beach access
tracks that are used by residents of the Site and adjacent residential estates to the west of David Low
Way, including:
- two beach access tracks leading from the two dwellings on the Site that have been used by
residents of, and visitors to, the Site for over 30 years; and
- a formed beach access track, located approximately 300m to the south of the existing Site
entrance, which is likely to be the primary beach access for residents and visitors to the 100+
dwellings located to the immediate west of David Low Way.
b) The existing tracks leading from the Site to the beach are stable and are subject to a low level of use
in comparison to the beach access track to the south.
c) Even if the existing tracks to the east of the Site were utilised by residents of and visitors to the
additional four dwellings that are proposed, the level of use and associated potential for adverse
impacts to the dune system would be substantially less than the level of use of the formed beach
access to the south.
d) To address Council’s concerns regarding the potential environmental impacts and/or management
burdens associated with inappropriate forms of access to public land to the east of the Site by future
residents of and visitors to the Site, it is proposed that:
- a gate free fence would be established along the entire seaward boundary of proposed Lots
712 to 716 and along the seaward boundary of proposed Lot 711 up to the 50m Riparian
Buffer with the fencing to then extend along the southern boundary of the proposed Riparian
Buffer; and
- a requirement to maintain the fence in its original gate free condition will be included within
the terms of the Statutory Environmental Covenants that are to be established over the areas
where the fencing is proposed.
e) With these proposed access controls in place:
- future residents of and visitors to the Site will still have a reasonable level of access to the
beach via the formed beach access track located 300m to the south; and
- any reasonable concerns that Council may have regarding adverse outcomes associated with
increased levels of access to and use of the coastal dune system to the east of the Site have
been addressed .
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Section 3
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13 November 2017
Council has also requested “… an analysis of the clearing required for provision of sight lines for safe access
as required in Item 13 of this Information Request.” In respect of that issue the following responses are
provided.
a) In the absence of the proposed development approximately 0.40 hectares of vegetation extending
along the Site’s David Low Way boundary would be required to achieve required safe sight distances.
The approximate location and extent of that vegetation clearance is indicated on Vegetation
Management Plan - Construction Phase - Plan Ref WE17035-CVMP-001 presented in Annexure A.
b) The location and extent of vegetation clearance required to establish necessary sight lines, including
any associated earthworks, for the proposed shared Site access are also illustrated on Vegetation
Management Plan - Construction Phase - Plan Ref WE17035-CVMP-001 presented in Annexure A.
c) The 0.06 hectares of vegetation that requires clearance is:
- comprised of a mixture of native and non-native plant species growing in areas that have
previously been subject to disturbance associated with the establishment of David Low Way,
adjacent pathway and establishment of existing dwellings on the Site;
- is not vegetation of local or regional conservation significance; and
- is not vegetation located within the 50m wide Riparian Buffer Area.
d) The establishment of safe sight lines for the proposed shared Site entrance may, subject to detailed
design and survey, require the removal of an existing fig (Ficus obliqua) tree located to the south-east
of the existing Site entrance. If this fig tree cannot be retained in-situ it will be translocated to a
currently disturbed area (i.e. the existing Site entrance) which will be rehabilitated. Indicative details
concerning the location for that translocation and the manner in which it would be carried out are
provided in Vegetation Management Plan - Construction Phase - Plan Ref WE17035-CVMP-001-002
presented in Annexure A.
e) To ensure that the required vegetation clearance does not result in adverse impacts to scenic amenity
values of the Site locality, the proposed plan of development makes provision for a 10m wide vegetated
buffer along the Site’s David Low Way frontage. The retained and restored vegetation within this 10m
wide buffer will be the subject of a statutory Environment Covenant and a program of weed control
and rehabilitation works. Details concerning the legally binding vegetation management obligations
that will attached to these retained and rehabilitated areas of vegetation are provided in Vegetation
Management Plan – Operational Phase - Plan Ref WE17035-OVMP-001-002 presented in Annexure
B.
As detailed in the Ecological Assessment Report (Cardno, 8 August 2017) submitted in support of the
Application and confirmed below, the clearance of vegetation to establish necessary sight lines would not be
in conflict the Biodiversity Overlay Code.
Biodiversity Overlay Area – Environmental Protection
The planning scheme is designates the lot as having an Environmental Protection area. A review of
the supplied information does not adequately address this designation.
Information Required
2. Provide an analysis of the vegetation on the lot with regards to the Environmental Protection
designation and the Vegetation of Noosa Shire, Ed 2, 2003.
A detailed analysis of the vegetation on the Site against the criteria for classification as an Environmental
Protection Area and the Vegetation of Noosa Shire (Ed 2, 2003) has been provided in Table 5-3 in Section
5.3.1 of the Ecological Assessment Report (Cardno, 8 August 2017) submitted in support of Application. That
analysis demonstrates that the vegetation on the Site does not possess the attributes that warrant classification
as either an Environmental Protection Area or an Environmental Enhancement Area.
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Section 4
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At a meeting with Council held on the 18th of October 2017, Council clarified that its concern with the analysis
presented within the Ecological Assessment Report are that:
a) the vegetation on the Site is classified on relevant vegetation mapping as being comprised of remnant
RE12.2.14 - Strand and fore dune complex;
b) RE12.2.14 is listed as being a “rare or naturally restricted” vegetation community within the Vegetation
of Noosa Shire (Ed 2, 2003); and
c) on that basis the entire Site warrants classification as an Environmental Protection Area.
In respect of this particular issue the following points are noted.
a) The analysis presented in Table 5-3 in Section 5.3.1 of the Ecological Assessment Report (Cardno, 8
August 2017) specifically recognised the Vegetation of Noosa (Ed 2, 2003) classification of RE12.2.14
as being a “rare or naturally restricted” vegetation community.
b) An analysis of data concerning the extent and distribution of different vegetation types contained within
the Vegetation of Noosa (Ed 2, 2003) was undertaken to verify that the classification of RE12.2.14 as
a being a “rare or naturally restricted” vegetation community was in fact warranted.
c) The results of that analysis are summarised in Table 5-3 of the Ecological Assessment Report
(Cardno, 8 August 2017) and formed the factual basis of the submission that the classification of
RE12.2.14 as a being a “rare or naturally restricted” vegetation community is not warranted.
d) Given that Council was not satisfied with that previous analysis, a more detailed analysis of the data
presented in the Vegetation of Noosa (Ed 2, 2003) comparing the variation in extents of the 62 different
RE types classified as being either “rare or naturally restricted” or not, was carried out. The results of
that analysis, which excluded RE12.2.14 to avoid confounding the analysis, is presented in the Table
1-1.
Table 1-1 Extents of REs in Noosa Shire relative to their “rare or naturally restricted” status
Total Area within Noosa Shire (Hectares) – Sourced from Table 15.2 in
Vegetation of Noosa (Ed 2, 2003)
“rare or naturally
restricted” 0 Quartile 2nd Quartile 4th Quartile
1st Quartile 3rd Quartile
(Minimum) (Median) (Maximum)
No 12 367 702 1,651 2,588
Yes 4 25 55 107 3,668
Yes (RE12.9-10.1
4 25 53 102 267
adjusted)
The RE12.9-10.1 adjustment row presented in Table 1-1 is required due to the fact that RE12.9-10.1
is the most extensive RE within the Noosa Shire encompassing an area of 3,668 hectares and yet was
classified as being “rare or naturally restricted”, which it clearly is not.
The analysis presented in Table 1-1 confirms the previous findings that RE12.2.14, which has an
extent of 606 hectares, has an extent:
similar to the Median extent for all RE classified as not being “rare or naturally restricted”; and
more than twice the Maximum extent of REs classified as being “rare or naturally restricted”.
e) Furthermore, a more recent analysis of the conservation significance and associated protection
requirements for different vegetation communities within the Noosa Shire has been completed by
Ecological Australia Pty Ltd on behalf of Council and the findings of that assessment are presented in
the Noosa Biodiversity Plan - Biodiversity Assessment Report (December 2016). That report is “ the
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13 November 2017
supporting research document that ensures that the development of planning policy is based on
current scientific understanding of biodiversity values across Noosa.”
f) The analyses presented in the Noosa Biodiversity Plan - Biodiversity Assessment Report (December
2016) determined that the Noosa Shire contains a total of 43 vegetation (regional ecosystem)
communities of conservation significance including:
- seven REs that are classified as Endangered and twenty-four REs classified as Of Concern
by the Queensland State Government; and
- a further twelve REs considered to be regionally significant due to their naturally limited extent
within the shire (<150 ha pre-clear extent) or due to the substantial reduction in area of extent
post European settlement (<30% of pre-clear extent remains in Noosa).
g) RE12.2.14 is not one of the 43 vegetation communities of conservation significance identified within
the Noosa Biodiversity Plan - Biodiversity Assessment Report (December 2016).
Based on the above facts and circumstances, we respectfully reiterate our assessments that an objective
analysis of available data, including that contained within the Vegetation of Noosa (Ed 2, 2003), clearly
demonstrates that:
a) RE12.2.14 is not a “rare or naturally restricted” vegetation community within the Noosa Shire; and
b) the classification of the Site as being an Environmental Protection Area, and the associated land use
and development constraints that flow from that designation, due to the presence of RE12.2.14 is not
warranted.
Information Required
3. Provide amended plans that show vegetation along the seaward boundary of all proposed lots
to a minimum width of 6.0m protected by covenant.
Response
The purpose of this information request is not clear, so it is assumed that this request is based on a desire to
ensure that any building established on the Site will not be exposed to an unacceptable levels of risk of damage
due to coastal processes (i.e. shore line erosion).
In that respect it is noted that the proposed plan of development includes provision for a minimum building
setback of 6m from the eastern (seaward) boundary of each lot. This building setback is also proposed to
provide an area of land between the eastern boundary and future dwellings that will be available for bushfire
and stormwater (infiltration) management purposes.
As detailed in the responses to Council’s Information Request Item 1, the retention of vegetation within a 6.0m
wide band along the seaward boundary of the Site is not required for coastal management purposes.
Furthermore, as detailed in the Bushfire Management Plan prepared in response to Council Information
Request Item 6, the maintenance of an Asset Protection Zone (APZ) at least 6m in width is required along the
eastern (seaward) boundary of the Site. Whilst the vegetated dune system to the east is not classified as a
bushfire hazard area pursuant to the Noosa Plan Natural Hazards (Bushfire) Overlay mapping, it does have
the potential to carry a low intensity bushfire under certain circumstances. The maintenance of an APZ is
therefore required to provide some separation between buildings and vegetated dunes to the east and access,
if required, for fire suppression and structure protection purposes.
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Biodiversity Overlay Area - Riparian Buffer
The site is mapped as a riparian buffer area and the Biodiversity Overlay code does not support new
development in these areas. The supplied information does not adequately address the riparian buffer
overlay code.
Information Required
4. Provide suitable planning and ecological grounds for the proposed development that increases
the scale and intensity of use within a Riparian Buffer area.
A detailed analysis of the Riparian Buffer area classification that has been applied to the entire Site within the
Biodiversity Overlay mapping is provided in Table 5-5 in Section 5.3.1 of the Ecological Assessment Report
(Cardno, 8 August 2017) submitted in support of the Application. Therein the following are demonstrated.
a) The Noosa Plan does not provide a clear definition of what constitutes a Riparian Buffer Area or the
criteria that were applied to classify and map Riparian Buffer Areas on Biodiversity Overlay mapping.
b) If one applies the related definitions that are available within the Noosa Plan, the extent of land within
the Site that could reasonably be considered a Riparian Buffer Area extends for a plan distance of
50m from the top of the bank of Burgess Creek, a permanent 2nd order freshwater watercourse that
traverses land to the north of the Site.
At a meeting with Council held on the 18th of October 2017, Council advised that the extent of the Riparian
Buffer Area within the Site was determined by reference to the “stream order” of Burgess Creek and associated
development setback specifications for different “stream order” classifications. Council also gave a
commitment to provide the Applicant with relevant material clarifying how these criteria were applied to the
Site. At the time of finalising this response no additional information had been provided by Council.
It is noted that the only references contained within the Noosa Plan to the relationship between “steam order”
and riparian buffer areas are presented as Probable Solution S5.5 to Specific Outcome 05 of the Biodiversity
Overlay Code, which states: For Forestry uses the cultivated area is separated from watercourses by a
distance not less than the distances identified below, measured from high water mark or the top of the bank,
whichever is the greater distance—
Feature Distance
Stream order 1 or 2 5m
Stream order 3 or 4 10 m
Stream order greater than 4 20 m
Whilst Probable Solution S5.5 is nominated with respect to forestry land uses and the proposed use of the Site
is for Urban (Detached Housing) purposes, in the absence of any other “steam order” based criteria it is
relevant to note that:
a) Burgess Creek has a steam order of 2 pursuant to the State “vegetation management watercourse
and drainage feature map” for which the corresponding nominated S5.5 setback distance is 5m;
b) the proposed development setback between the top bank of Burgess Creek and land to be actively
used for Detached Housing purposes is 50m; and
c) within the outer 10m of this 50m wide Riparian Buffer some building demolition works are proposed,
with areas of disturbance to be subject to a comprehensive program of rehabilitation works that will
extend across the entire 50m wide Riparian Buffer which will also be subject to on-going protection
and management under the provisions of a statutory Environmental Covenant.
It is also relevant to note that whilst State Code 16: Native vegetation clearing does not apply to the Application,
as the proposed clearance of Category B (Least concern) vegetation does not constitute assessable
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development as the clearance is for an urban purpose in an urban area, it does contain Performance outcomes
(PO) that are designed to protect the ecological values and functions of watercourses. Specifically PO 11
requires that “Clearing maintains the current extent of vegetation associated with any watercourse or drainage
feature to protect:
1. bank stability by protecting against bank erosion;
2. water quality by filtering sediments, nutrients and other pollutants;
3. aquatic habitat; and
4. terrestrial habitat.”
The 1st nominated Acceptable Outcome (AO) for PO11 is AO 11.1 which is based on the “stream order” of the
subject watercourse and requires that “Clearing does not occur in any watercourse or drainage feature, or
within the relevant distance of the defining bank of any watercourse or drainage feature in table 16.3.2 of this
code”. Relevant riparian buffer distances specified in Table 16.3.2 for a coastal bioregion are:
> 10m for a 2nd order stream; and
> 50 m for a 5th order or larger stream.
The proposed development’s 50m wide Riparian Buffer to Burgess Creek is substantially wider than the buffer
considered necessary by the State to protect the ecological values and functions of a 2nd order coastal
waterway, a fact that provides further support to our analysis that the classification of the entire Site as a
Riparian Buffer Area on the Biodiversity Overlay Map is not appropriate nor reasonably required to protect the
values of Burgess Creek.
In respect of the Council’s request for planning grounds for supporting the proposed development within an
area classified as a Riparian Buffer Area in the Biodiversity Overlay Map the following are noted.
a) From a planning perspective it is necessary to consider the specific conditions that exist at an individual
site to determine the nature of constraints that an overlay may reasonably impose to the use and
development of that site, rather than blindly relying upon broad scale overlay mapping that may contain
errors or anomalies at the site specific scale.
b) The site specific analysis of the broad scale Biodiversity Overlay mapping classification of the entire
Site as a Riparian Buffer Area presented in Section 5.3.1 of the Ecological Assessment Report
(Cardno, 8 August 2017) and supplemented by the “stream order” analysis presented above, confirms
that the Biodiversity Overlay mapping does not reflect actual environmental conditions on the Site.
c) Council’s decision making must be objective and give appropriate weight to Site specific information
submitted in support a development application and should not rely on broad-scale overlay mapping
classifications that are shown to contain errors and/or anomalies.
In respect of Council’s request for environmental grounds for supporting the proposed development within an
area classified as a Riparian Buffer Area in the Biodiversity Overlay Map the following are noted.
a) The proposed development does not involve the intensification of use within any part of the Site that
could reasonable be considered to function as a Riparian Buffer Area.
b) The proposed development will retain a vegetated buffer to Burgess Creek that is of sufficient width
and character to achieve Specific Outcome 05 of the Biodiversity Overlay which seeks to ensure that
“The biodiversity and ecosystem values of watercourses, drainage lines, wetlands and adjacent
riparian zones are protected by —
a) avoiding any new development in the riparian buffer area – with the proposal locating all new
development outside of the 50m wide vegetated riparian buffer to Burgess Creek and also
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removing existing residential structures and landscaping that are currently located within that
buffer area.
b) retaining aquatic and terrestrial habitat in riparian zones – with existing native vegetation, aquatic
and terrestrial habitats being retained and enhanced within the proposed 50m wide riparian buffer
zone.
c) maintaining wildlife corridors along watercourses and drainage lines for native fauna movement –
there will be no structures, fencing or other barriers established within the proposed riparian buffer
area that would interfere with the movement of native fauna.
d) avoiding edge effects and incompatible uses in riparian zones – the proposed riparian buffer will
not introduce edge effects or incompatible uses to the Burgess Creek riparian zone and in that
respect it is noted that:
- the Site has been used for residential purposes for a period of approximately 30 years;
and
- the outdoor recreational area associated with one of the existing dwellings on the Site is
located less than 50m from the top bank of Burgess Creek.
e) maintaining bank stability by minimising bank erosion and slumping – the proposed vegetated
riparian buffer to Burgess Creek will be sufficient to maintain the stability to the banks of this low
energy coastal waterway.
f) maintaining water quality by filtering sediments, nutrients and other pollutants – the proposed
development does not rely on the riparian buffer areas for the filtering of sediments, nutrients and
other pollutants. It is also relevant to note that Burgess Creek receives outflows of treated effluent
from the Noosa wastewater treatment plant and as such is not a pristine waterway.
g) removing undesirable plant species and replacing them with vegetation of local origin – the 50m
wide riparian buffer area will be the subject of:
- a comprehensive program of rehabilitation works that will involve the removal of existing
infestations of non-native plant species and their replacement with native plant species;
and
- a statutory Environmental Covenant that will require existing and future land owners to
appropriately manage weed species and indigenous vegetation within the riparian buffer
area, as detailed in Vegetation Management Plan – Operational Phase - Plan Ref
WE17035-OVMP-001-002 presented in Annexure B.
UXO
The site is located in an area with substantial potential for UXO. The development will increase the
amount of people living in a UXO area. UXO assessment and UXO rehabilitation can lead to clearing
protected vegetation.
Information Required
5. Provide further information regarding the UXO clearances required and the amount of
vegetation clearing necessary to render the site safe.
UXO clearances will be undertaken prior to the commencement of civil engineering works and will involve
vegetation clearance. The nature of vegetation clearance works required across the Site will vary depending
the nature of the approved uses for different sectors of the Site.
Within those parts of the Site approved to be developed for residential purposes (i.e. building envelopes,
access driveways and service corridors) the majority of existing vegetation will require removal to enable
detailed UXO inspections to be completed using ground penetrating equipment capable of detecting the
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presence of any UXO to a depth of approximately 3m below ground surface level. The locations of areas
where this form of UXO clearance will be required is illustrated in Vegetation Management Plan - Construction
Phase - Plan Ref WE17035-CVMP-001 presented in Annexure A.
Within the proposed Vegetation Retention and Habitat Enhancement Zone, as shown in Plan Ref WE17035-
CVMP-001, vegetation clearance for UXO inspections will be much more selective and is only required to
enable a visual inspection for the presence of UXO. To minimise impacts to native vegetation within the
Vegetation Retention and Habitat Enhancement Zone, the UXO clearance works will be carried out in
coordination with the initial weed control works that are to be completed as part of the Vegetation Retention
and Habitat Enhancement Zone which will subsequently be covered by a statutory Environmental Covenant.
As detailed in Plan Ref WE17035-CVMP-002, native vegetation within the Vegetation Retention and Habitat
Enhancement Zone will not be cleared unless specifically authorised by Council.
Issue - Bushfire
The development is located in a bushfire hazard area and increases the number of people living in a
hazard area.
Information Required
6. Provide a Bushfire Management Plan that complies with the Natural Hazards Overlay code of
the Noosa Plan.
A Bushfire Management Plan (Cardno, 2017) has been prepared in accordance with the Natural Hazards
Overlay Code of the Noosa Plan. That Bushfire Management Plan demonstrates that the proposed
development of the Site will not:
exposure future residents or their dwellings to an unacceptable risk of harm due to bushfire; or
place an undue burden upon emergency service personnel or resources during a bushfire incident.
Issue - Fauna
The site contains remnant vegetation which provides habitat and forage values for native fauna (refer
Fauna and its associated biodiversity values in Noosa Shire 2003). Insufficient information has been
provided regarding the fauna habitat values of the site.
Information Required
7. Provide a fauna assessment in accordance with Planning Scheme Policy 18 Ecological
Assessment Guidelines Section 7.
As requested an analysis of the report titled Fauna and Its Associated Biodiversity Values in Noosa Shire
(Ecotone Environmental Services, 2003), prepared for the Noosa Shire Council, has been completed. That
report provides a comprehensive analysis of:
a) the conservation significance of fauna species that occur within the Noosa Shire; and
b) the fauna habitat values of the different vegetation communities that occur within the Noosa Shire as
detailed in Vegetation of Noosa Shire (Ed 2, 2003).
The Fauna and Its Associated Biodiversity Values in Noosa Shire includes an analysis of the relative
importance of sixty (60) different vegetation types in terms of the number of fauna species of conservation
significance that each community is known to be associated with. Table 1-2 below provides a summary of that
analysis contrasting the number of fauna species associated with the primary habitat type that occurs on the
Site (i.e. RE12.2.14) against the number of fauna species associated with the diversity of other habitat types
within the Noosa Shire.
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Table 1-2 Non-native Flora Species of Management Significance Recorded Within the Site
Number of Species
Fauna group (reference Table from Ecotone
RE12.2.14 Median Min Max
Environmental Services, 2003)
All fauna species (Table 3.3) 95 305 47 376
Rare, threatened or otherwise significant fauna
21 70 20 110
species (Table 3.4)
Endangered fauna species (Table 7.1) 0 2 0 5
Vulnerable fauna species (Table 7.2) 5 6 2 11
Rare fauna species (Table 7.3) 1 8 1 12
Regionally significant fauna species (Table 7.4) 11 39 11 68
Locally significant fauna species (Table 7.5) 4 14 2 19
The summary provided within Table 1-2 indicates that RE12.2.14 is a form of vegetation that:
a) does not support a particularly high diversity of fauna species in general; and
b) is of relatively low importance in terms of providing habitat resources for the diversity of rare,
threatened or otherwise significant fauna species that are known to occur in the Noosa Shire.
In this respect it is also noted that areas of RE12.2.14 within the Site are even less likely to be utilised by full
range of fauna species typically associated with RE12.2.14 due to:
a) the impacts of the historic and existing use of the Site for residential purposes; and
b) the proximity of the Site to a major roadway (i.e. David Low Way) and residential development to the
west.
The Fauna and Its Associated Biodiversity Values in Noosa Shire does not identify the specific fauna species
that are associated with particular RE types, apart from in Table 3.7 which identifies the link between particular
RE types and species with “specialised or restricted habitat associations”. The particular fauna species that
are identified in Table 3.7 as being associated with RE12.2.14 are:
Beach Stone- curlew (Esacus neglectus);
Pied Oystercatcher (Haematopus longirostris);
Little Tern (Sterna albifrons); and
Ground Parrot (Pezoporus wallicus).
As detailed in the Ecological Assessment Report (Cardno, 8 August 2017) submitted in support of Application
only one of these species, the Ground Parrot (Pezoporus wallicus), has been recorded within a 2 km radius
of the Site. The preferred habitat type for this species in SEQ is described in the Commonwealth Department
of Environment and Energy SPRAT Profile as being comprised of “closed, subtropical graminoid heathlands
(consisting of grass-trees, with a high diversity of sedges, rushes and low shrubs), either moist or dry (Higgins
1999;McFarland 2005, pers. comm.). Within heathlands, dry habitats are used from mid autumn to late spring,
and wet habitats at other times. It is sometimes found in open Banksia woodlands with a heath understorey,
in closed fernland around shallow creeks on plains, or in sedges at swamp margins (Higgins 1999).” The Site
does not contain these forms of habitat and extensive areas of such habitat are located within the adjacent
sectors of Noosa National Park to the west of the Site and David Low Way. Whilst the other three species
may occasionally be encountered along the adjacent shoreline, the Site does not provide habitat resources
that are likely to be utilised by these speces.
I:\WE Jobs 2017\WE17035 - Castaways Beach\wp\IR Response\Ecology and Bushfire NSC IR Response V1.docx
Section 11
: WE17035 11
13 November 2017
The proposed plan of development will not, due to both its nature and scale, have any realistic potential to
significantly impact on local populations of any native fauna species for the following reasons.
a) The extent of fauna habitat disturbance/modification that would occur is negligible, with:
the Site having a total area of only 0.97 hectares;
of which approximately 0.35 hectares is occupied by existing dwellings and landscaped areas;
and
existing fauna habitats to be preserved and enhanced within approximately 0.33 hectares of
land that will be subject to Statutory Environmental Covenants.
b) The quality of the fauna habitat that would be permanently impacted by the proposed development is
low, having been subjected to substantial modification in the past associated with:
existing residential uses;
weeds; and
the construction and operation of a major roadway which extends along the entire western
boundary of the Site.
c) The proposed development does not introduce a new form of land use to the Site, with the Site having
been used for residential purposes for a period of approximately 30 years.
d) Extensive areas habitat similar to that which would have occurred on the Site prior to the
commencement of residential uses in the 1980s occur on public land in the Site locality, including
adjacent foreshore reserves and the Noosa National Park.
In respect of Council’s request to “Provide a fauna assessment in accordance with Planning Scheme Policy
18 Ecological Assessment Guidelines Section 7” the flowing responses are provided.
a) The Ecological Assessment Guidelines are guidelines which set-out the general nature of ecological
assessments that are recommended to inform the preparation and assessment of a development
application that triggers assessment against the Biodiversity Overlay Code of the Noosa Plan. Strict
adherence to the Guidelines is not mandatory and the nature and scale of desk and field based
investigations should be tailored to address the particular circumstances under investigation.
b) To complement the ecological (flora and fauna) assessment presented in the Ecological Assessment
Report (Cardno, 8 August 2017) a supplementary field survey was completed on 12 October 2017.
The scope and findings of that supplementary survey are summarised in Annexure C. The findings
of the supplementary survey are consistent with the findings of the previous survey work and findings
documented in the Ecological Assessment Report (Cardno, 8 August 2017).
c) The Ecological Assessment Report (Cardno, 8 August 2017) submitted in support of Application and
the further assessments provided herein are consistent with the Guidelines for the following reasons.
a. Relevant reference documents and information sources have been considered.
b. The assessments have been prepared by appropriately qualified and experienced ecologists.
c. The assessments are informed by an appropriate combination of desktop and field based
surveys and assessments which take into account the small size and disturbed nature of the
Site and the nature of the surrounding landscape.
d) The information that has been provided to Council concerning the ecological values of the Site and
the likely nature and scale of impacts to those values is considered to be sufficient to enable Council
to make an appropriately informed assessment of the proposed development.
I:\WE Jobs 2017\WE17035 - Castaways Beach\wp\IR Response\Ecology and Bushfire NSC IR Response V1.docx
Section 12
: WE17035 12 13 November 2017 In conclusion, it is our assessment that there are no grounds for Council to refuse the proposed development of the Site that could be reasonably based on the nature and scale of ecological impacts and any associated conflict with the overall outcomes sought for the Biodiversity Overlay Code. We trust that the responses provided herein are sufficient. Should you have any queries regarding same please do not hesitate to contact the undersigned. Yours faithfully John Delaney Senior Principal – Ecology and Bushfire For Cardno 0412 335 229 [email protected] Enc: Annexure A – Vegetation Management Plan - Construction Phase - Plan Ref WE17035-CVMP-001-002 Annexure B - Vegetation Management Plan - Operational Phase - Plan Ref WE17035-OVMP-001-002 Annexure C – Supplementary Ecological Survey Summary I:\WE Jobs 2017\WE17035 - Castaways Beach\wp\IR Response\Ecology and Bushfire NSC IR Response V1.docx
Section 13
WE17035
Annexure A
Vegetation Management Plan - Construction Phase
Plan Ref WE17035-CVMP-001-002
I:\WE Jobs 2017\WE17035 - Castaways Beach\wp\IR Response\Ecology and Bushfire NSC IR Response V1.docx
Section 14
Cr
DATE PLOTTED: 13 November 2017 3:42 PM BY : JOHN DELANEY
ee
k VEGETATION MANAGEMENT PLAN - CONSTRUCTION PHASE
Y
WA
Ed
ge
Objectives:
of Creek
W
Manage construction phase operations so as to:
D LO
Cov P
x protect indigenous vegetation and fauna habitat identified for
retention;
DAVI
x reinstate indigenous vegetation in areas subject to temporary
disturbance; and
711
x
Cov H
undertake a comprehensive program of weed control works.
Cov Q
712
COASTAL RESERVE
Specifications:
(COUNCIL MANAGED)
Cov J
Cov R
Vegetation management is to be implemented in accordance with the
713
Cov K
specifications provided in WE17035-CVMP-002.
Cov S
714
LEGEND
Cov L
Vegetation Clearance and Construction Zone : 0.60 hectares (62%)
T
Cov
715
Cov U
Cov M
Bulk Earthworks
Proposed
Water Meters
Vegetation Retention and Habitat Enhancement Zone: 0.33 hectares (34%)
716
7
Temporary Vegetation Clearance and Restoration Zone: 0.04 (4%)
Proposed Access Sight-line Clearance Vegetation Regrowth Management Zone : 0.06 hectares
Existing Access Sight-line Clearance Vegetation Regrowth Management Zone (for comparison purposes only): 0.04 hectares
Cov N
Cov V
Permanent Beach and Riparian Buffer Access Restriction Fencing
Temporary Vegetation Protection / Access Restriction Fencing
Cov T Statutory Covenant Reference Code
712 Lot Reference Number
CAD File: I:\WE Jobs 2017\WE17035 - Castaways Beach\Acad\WE17035-CVMP-001 v1.dwg
Translocation of Fig (if required)
XREF's: X-790400-EWK-Depth-OPT2; 116052 Lots; X-790400-LOTS
0 10 20 30 40 50m
SCALE 1:500 @A1
Drawn Date Client
JD 10 NOVEMBER 2017 KENLYNN PTY. LTD.
© Cardno Limited All Rights Reserved. Checked Date Project Status
LOT 71 ON MCH2854 CASTAWAYS BEACH
This document is produced by Cardno Limited solely for the
JD 10 NOVEMBER 2017
PRELIMINARY
benefit of and use by the client in accordance with the
Designed Date RESIDENTIAL SUBDIVISION NOT TO BE USED FOR CONSTRUCTION PURPOSES
terms of the retainer. Cardno Limited does not and shall not DATUM GRID Scale Size
Verified Date
assume any responsibility or liability whatsoever to any third Cardno (Qld) Pty Ltd | ABN 57 051 074 992
Level 11, 515 St Paul’s Terrace
Title
VEGETATION MANAGEMENT PLAN A.H.D. AS SHOWN A1
party arising out of any use or reliance by third party on the Approved
Fortitude Valley, QLD 4006 Drawing Number Revision
content of this document. CONSTRUCTION PHASE
Rev. Date Description Des. Verif. Appd.
Tel: 07 3369 9822 Fax: 07 3369 9722
Web: www.cardno.com.au
WE17035-CVMP-001 1
Section 15
DATE PLOTTED: 13 November 2017 3:43 PM BY : JOHN DELANEY
g) If removal of the fig tree is required to achieve acceptable sight lines, the tree is to be translocated to the existing
CONSTRUCTION PHASE VEGETATION MANAGEMENT SPECIFICATIONS Site access way. Details confirming translocation requirements and methods, provided by an appropriately
qualified and experienced arborist, are to be contained within the detailed Operational Works plans and are to be
Key Definitions
submitted to Council for approval.
Environmental Weed means a plant species listed in the following standards and legislation or current updates:
h) Following completion of the UXO clearance inspections within the Vegetation and Habitat Protection Zone a
- Declared Restricted plants under the Biosecurity Act 2014. program of supplementary planting works is to be completed. Species selection and planting densities are to be
- Weeds of National Significance (WoNS). designed to reflect the structure and species composition of RE12.2.14 and RE12.2.5.
- Sunshine Coast Local Government Area Pest Management Plan 2012-2016 sections 6.2.2, 6.3.2, 6.4.2, 6.5.2 and 6.6.2, as
updated from time to time, a copy of which can be obtained from Council Offices. i) All mulch and plant stock used in the weed control and supplementary planting program is to be certified as weed
free.
Indigenous Vegetation means native vegetation which historically has naturally occurred in the local area.
j) Initial weed control and supplementary planting works are to be maintained by the developer for a period of 12
Native Fauna means native animals which historically have naturally occurred in the local area. months and thereafter are to be maintained in accordance with the terms and conditions of the Operational Phase
VMP (WE17035-OVMP-001 to 002).
Vegetation means: any tree, shrub, bush, vine, grass or other living or dead plant material on the Covenant Area other than existing
structures such as fences and poles existing at the Home when this Covenant comes into force and timber imported into the Temporary Vegetation Clearance and Restoration Zone
Covenant Area to be used for maintenance of such existing structures.
a) The alignment of the sewer connection located within the Temporary Vegetation Clearance and Restoration Zone is to
UXO means unexploded ordinance. be adjusted as required to minimise the loss of established trees.
Vegetation and Habitat Protection Zone
b) Where excavation / trenching works impact on the root systems of vegetation identified for retention then the following
work practices will be implemented:
A detailed Vegetation and Habitat Protection and Enhancement Plan is to be prepared for all land located within the Vegetation and
Habitat Protection Zone and the Temporary Clearance and Restoration Zone and is to be submitted in support of Operational
- Tree roots in excess of 50mm diameter should not be cut.
Works Applications. That Plan is to be prepared in accordance with the SEQ Restoration Framework (Chenoweth EPLA & Bushland
Restoration Systems, 2012). - Damaged tree roots should be saw cut back to a clean cut, and all cuts, nicks etc. are to be cleaned and trimmed to
green wood.
- Hand digging and tunneling should be used whenever possible to avoid cutting roots, especially under the canopy of
At a minimum the Plan will include provision for the following management measures.
trees.
- Trenches dug under the canopy of trees are to remain open for as short a time as possible.
a) Prior to the commencement of any vegetation clearance and earthworks the boundaries of the Vegetation and Habitat
- Trenches should be carefully backfilled, consolidated and watered in around roots to eliminate voids and exposed
Protection Zone shall be surveyed and clearly defined.
roots are to be kept moist and covered with Hessian for the duration of the exposure.
b) A 1.8m high temporary vegetation protection and access restriction fencing shall be established around the boundaries of m) Following completion of necessary vegetation clearance, earthworks, building demolition and civil engineering
the Vegetation and Habitat Protection Zone and along the alignment of the Permanent Beach and Riparian Buffer works - the Temporary Vegetation Clearance and Restoration Zone is to be revegetated in accordance with the
Access Restriction Fencing as indicated on Drawing Ref: WE17035-CVMP-001 prior to the commencement of broadscale specifications of the Council approved Vegetation and Habitat Protection and Enhancement Plan.
vegetation clearance, earthworks and building demolition works. This fencing is to be maintained for the duration of the
construction phase of development. Vegetation Clearance and Construction Zone and Proposed Access Sight-line Clearance Vegetation Regrowth
Management Zone
c) No storage of materials or equipment is to be permitted within the Vegetation and Habitat Protection Zone.
a) An accredited (holder of a current Rehabilitation Permit issued by the Environmental Protection Agency under Section
275(d) of the Nature Conservation Regulation 1994) wildlife spotter-catcher will be appointed to supervise and direct,
d) Access to the Vegetation and Habitat Protection Zone is prohibited except for authorized management and UXO if required to avoid injury or harm to fauna, the vegetation clearing operations.
clearance purposes.
b) Vegetation clearance works are to be carried out under the direction of the UXO clearance contractor.
e) An initial program of weed control works is to be completed within the Vegetation and Habitat Protection Zone to
remove existing infestations of Environmental Weeds and non-indigenous vegetation prior to the conduct of UXO c) Where felling of a tree may damage vegetation identified for retention, directional felling must be undertaken to direct
clearance inspections. All weed material is to be taken off-site for lawful disposal. tree fall away from the retained vegetation.
f) No additional vegetation clearance works are to be carried out within the Vegetation and Habitat Protection Zone for d) Cleared vegetation is to be removed from the Site for lawful disposal due to the high level of non-indigenous species
content and associated potential for spread of weeds if the material.
CAD File: I:\WE Jobs 2017\WE17035 - Castaways Beach\Acad\WE17035-CVMP-001 v1.dwg
the purpose of completing the UXO clearance inspections, UNLESS specifically authorised by Council.
Permanent Beach and Riparian Buffer Access Restriction Fencing
g) If removal of the fig tree required to achieve acceptable sight lines, the tree is to be translocated to the existing Site
access way. Details confirming translocation requirements and methods, provided by an appropriately qualified and
XREF's: X-790400-EWK-Depth-OPT2; 116052 Lots; X-790400-LOTS
e) At the completion of all civil works a 1.5m high, black, pool-style, gate free fence is to be established along the coastal
experienced arborist, are to be contained within the detailed Operational Works plans and are to be submitted to Council
and riparian buffer boundaries, as shown in Drawing Ref: WE17035-CVMP-001.
for approval.
Drawn Date Client
JD 10 NOVEMBER 2017 KENLYNN PTY LTD
© Cardno Limited All Rights Reserved. Checked Date Project Status
LOT 71 ON MCH2854 CASTAWAYS BEACH
This document is produced by Cardno Limited solely for the
JD 10 NOVEMBER 2017
PRELIMINARY
benefit of and use by the client in accordance with the
Designed Date RESIDENTIAL SUBDIVISION NOT TO BE USED FOR CONSTRUCTION PURPOSES
terms of the retainer. Cardno Limited does not and shall not DATUM GRID Scale Size
Verified Date
assume any responsibility or liability whatsoever to any third Cardno (Qld) Pty Ltd | ABN 57 051 074 992
Level 11, 515 St Paul’s Terrace
Title
VEGETATION MANAGEMENT PLAN A.H.D. AS SHOWN A1
party arising out of any use or reliance by third party on the Approved
Fortitude Valley, QLD 4006 Drawing Number Revision
content of this document. CONSTRUCTION PHASE
Rev. Date Description Des. Verif. Appd.
Tel: 07 3369 9822 Fax: 07 3369 9722
Web: www.cardno.com.au
WE17035-CVMP-002 1
Section 16
WE17035
Annexure B
Vegetation Management Plan - Operational Phase
Plan Ref WE17035-OVMP-001-002
I:\WE Jobs 2017\WE17035 - Castaways Beach\wp\IR Response\Ecology and Bushfire NSC IR Response V1.docx
Section 17
ee
DATE PLOTTED: 13 November 2017 4:08 PM BY : JOHN DELANEY
k
Y
VEGETATION MANAGEMENT PLAN - OCCUPATION PHASE
WA
Ed
ge
of Creek
Objective:
W
D LO
Maintain vegetation within designated covenant areas within Lots 711 to
Cov P 716 and other identified management areas in a manner, and at a
DAVI frequency, that will archive and maintain relevant:
50
m
Rip
x
ari
an
Bo
un
da
environmental protection and enhancement outcomes;
x bushfire risk management outcomes; and
A
ry
Emt
7 1
711 x safe intersection sight distance requirements.
Cov
Co
CovvH
Q
Specifications:
Emt B
Cov
712 Vegetation management is to be implemented in accordance with the
Cov J
COASTAL RESERVE
(COUNCIL MANAGED)
specifications provided in WE17035-OVMP-002.
Cov R
mt C
Emt
159
E m
7
713 CP 839188
Cov K
Cov S
mt D
Emt
Em
m
714 Cov L LEGEND
tE
T
Cov
Em
Building Envelope
715
71
155
vM
Co
Cov U
E tF
Emt Asset Protection Zone - Driveway
71
716
716
Covenant (Bushfire Risk and Stormwater Management) Area
Environmental Covenant (Habitat Protection) Area
Cov N Sight-line Clearance Vegetation Regrowth Management Zone
Cov V
Beach and Riparian Buffer Access Restriction Fencing
Cov T Statutory Covenant Reference Code
712 Lot Reference Number
CAD File: I:\WE Jobs 2017\WE17035 - Castaways Beach\Acad\WE17035-OVMP-001 rev 1.dwg
EMT F Easement Reference Code
XREF's: X-790400-EWK-Depth-OPT2; 116052 Lots; X-790400-LOTS
0 10 20 30 40 50m
SCALE 1:500 @A1
Drawn Date Client
JD 6 NOVEMBER 2017 KENLYNN PTY. LTD.
© Cardno Limited All Rights Reserved. Checked Date Project Status
LOT 71 ON MCH2854 CASTAWAYS BEACH
This document is produced by Cardno Limited solely for the
JD 6 NOVEMBER 2017
PRELIMINARY
benefit of and use by the client in accordance with the
Designed Date RESIDENTIAL SUBDIVISION NOT TO BE USED FOR CONSTRUCTION PURPOSES
terms of the retainer. Cardno Limited does not and shall not DATUM GRID Scale Size
Verified Date
assume any responsibility or liability whatsoever to any third Cardno (Qld) Pty Ltd | ABN 57 051 074 992
Level 11, 515 St Paul’s Terrace
Title
VEGETATION MANAGEMENT PLAN A.H.D. 1:500 A1
party arising out of any use or reliance by third party on the Approved
Fortitude Valley, QLD 4006 Drawing Number Revision
content of this document. OPERATIONAL PHASE - MANAGEMENT AREAS
1
Rev.
13/11/2017
Date
Minor text edits
Description Des. Verif. Appd.
Tel: 07 3369 9822 Fax: 07 3369 9722
Web: www.cardno.com.au
WE17035-OVMP-001 1
Section 18
DATE PLOTTED: 13 November 2017 3:58 PM BY : JOHN DELANEY
VEGETATION MANAGEMENT SPECIFICATIONS
Key Definitions OWNER'S OBLIGATIONS - Bushfire Risk and Stormwater Management Areas
Coastal Reserve means Lot 159 on CP839188.
The Owner must:
Environmental Weed means a plant species listed in the following standards and legislation or current updates:
x Declared Restricted plants under the Biosecurity Act 2014. a) take reasonable measures to only use, or allow to be used, the Covenant Area in a manner that provides for
x Weeds of National Significance (WoNS). bushfire risk reduction and stormwater management.
x Sunshine Coast Local Government Area Pest Management Plan 2012-2016 sections 6.2.2, 6.3.2, 6.4.2, 6.5.2 and 6.6.2, as updated from time to time, a copy of which can be obtained
from Council Offices.
b) not, or permit another person to, have a fixture, improvement, or structure placed, constructed or erected in
Indigenous Vegetation means native vegetation which historically has naturally occurred in the local area. the Covenant Area that:
Native Fauna means native animals which historically have naturally occurred in the local area.
i. is made of combustible materials; or
Owner means the entity described in Item 1 of Form 31 and includes in the case of a corporation its successors in title and assigns and in the case of a natural person or persons ii. interferes with access for bushfire suppression or management purposes.
their successors in title and each of their executors, administrators and assigns.
Vegetation means: any tree, shrub, bush, vine, grass or other living or dead plant material on the Covenant Area other than existing structures such as fences and poles existing at the Home c) not, or permit another person to, have placed or present or stored in the Covenant Area the following:
when this Covenant comes into force and timber imported into the Covenant Area to be used for maintenance of such existing structures. garbage, waste or other material that is combustible or which may otherwise interfere with access for bushfire
suppression or management purposes.
OWNER'S OBLIGATIONS - Habitat Protection Areas
The Owner must:
d) not introduce, or allow to be introduced, and take reasonable measures to remove, any Vegetation in the
a) take reasonable measures to only use, or allow to be used, the Covenant Area in a manner that maintains and protects the Indigenous Vegetation and
Covenant Area which is:
Native Fauna habitat values within the Covenant Area.
i. combustible mulch;
b) not, or permit another person to, have Indigenous Vegetation in the Covenant Area trimmed, pruned, lopped, poisoned, harvested, picked, cut down, ii. a climbing vine, shrub or a tree; or
mown, moved, removed, grazed by domestic stock or in any way damaged or destroyed, whether by act or omission, unless by natural processes (e.g. fire,
storm, decay) or as reasonably required to preserve public health and safety or to maintain underground services established within an approved iii. an Environmental Weed.
easement.
e) remove, trim, prune, lop any vegetation that extends into the Covenant Area from the adjacent Coastal Reserve
c) not, or permit another person to, have a trail, path, fence, access or access way made, laid out or other constructed element in the Covenant Area, apart or Riparian Buffer (Lot 711 only) and lawfully dispose of that material outside of:
from underground services established within an approved easement.
d) notify the Council in writing of any substantial damage to Indigenous Vegetation within the Covenant Area (whether by natural occurrence or otherwise) i. the Covenant Area;
within 14 days of becoming aware of the damage occurring and rehabilitation of damaged areas is to commence within 30 days of notification or such ii. the Coastal Reserve; and
other time as agreed by Council. iii. the Riparian Buffer (Lot 711 only).
e) not introduce, or allow to be introduced, and take reasonable measures to remove, any Vegetation in the Covenant Area which is:
f) maintain all ground cover vegetation within the Covenant Area at a maximum height of 150mm at all times.
i. not Indigenous Vegetation, unless agreed to by Council; or
ii. an Environmental Weed. g) establish and maintain permanent Covenant Area boundary markers made of steel or concrete posts at each
corner and at intervals of no greater than 20m.
f) not, or permit another person to, have either placed or present or stored in the Covenant Area the following: fill, soil, rock, rubbish, ashes, garbage, waste
or other material that is foreign to the Covenant Area and does not reflect the conditions of growth naturally encountered by the Indigenous Vegetation of
the Covenant Area. h) maintain the continuous 1.5m high pool style beach and riparian buffer access restriction fencing that was
established along the coastal and riparian buffer boundaries, as shown in Drawing Ref: WE17035-OVMP-001,
g) not, or permit another person to, allow the Covenant Area to be used for the disposal of treated or untreated effluent from any sewage or greywater prior to the sealing of survey plans.
systems.
i) not, or permit another person to, remove or modify any section of that coastal and riparian buffer area
h) establish and maintain permanent Covenant Area boundary markers made of steel or concrete posts at each corner and at intervals of no greater than boundary fencing, including establishment of any gate, for the purpose of facilitating access to the adjoining
20m.
coastal reserve or riparian buffer.
Notwithstanding the above, if Indigenous Vegetation in the Covenant Area poses a serious and imminent risk to human safety, including bushfire risk:
COUNCIL'S OBLIGATIONS - Coastal Reserve and David Low Way
a) the Indigenous Vegetation may be cut down or trimmed so as to remove the risk:
CAD File: I:\WE Jobs 2017\WE17035 - Castaways Beach\Acad\WE17035-OVMP-001 rev 1.dwg
Council is obligated to:
i. as directed by an authorized officer of the Queensland Fire and Emergency Service without the prior written consent of the Council; or a) maintain vegetation growing within the David Low Way reserve such that safe intersection sight distances are
ii. otherwise with the prior written consent of Council, whose consent will not be unreasonably withheld provided an Arborist report or Bushfire report is
maintained at the shared entrance to Lots 711 to 716 at all times; and
submitted and supports, to Council's satisfaction, the need for requested works.
XREF's: X-790400-EWK-Depth-OPT2; 116052 Lots; X-790400-LOTS
b) the Indigenous Vegetation which is cut or trimmed must be left in the Covenant Area so that natural regeneration processes may occur unless it would in b) maintain bushfire fuel loads within the adjacent sectors of the Coastal Reserve, particularly the contribution
the Council's reasonable opinion, constitute a serious fire hazard. that non Indigenous Vegetation makes to available fuel loads, are managed so as not to present an
unacceptable risk to residents of Lots 711 to 716.
Drawn Date Client
JD 6 NOVEMBER 2017 KENLYNN PTY LTD
© Cardno Limited All Rights Reserved. Checked Date Project Status
LOT 71 ON MCH 2854, CASTAWAYS BEACH
This document is produced by Cardno Limited solely for the
JD 6 NOVEMBER 2017
PRELIMINARY
benefit of and use by the client in accordance with the
Designed Date RESIDENTIAL SUBDIVISION NOT TO BE USED FOR CONSTRUCTION PURPOSES
terms of the retainer. Cardno Limited does not and shall not DATUM GRID Scale Size
Verified Date
assume any responsibility or liability whatsoever to any third Cardno (Qld) Pty Ltd | ABN 57 051 074 992
Level 11, 515 St Paul’s Terrace
Title
VEGETATION MANAGEMENT PLAN A.H.D. AS SHOWN A1
party arising out of any use or reliance by third party on the Approved
Fortitude Valley, QLD 4006 Drawing Number Revision
content of this document. OPERATIONAL PHASE - MANAGEMENT SPECIFICATIONS
1
Rev.
13/11/2017
Date
Minor text edits
Description Des. Verif. Appd.
Tel: 07 3369 9822 Fax: 07 3369 9722
Web: www.cardno.com.au
WE17035-OVMP-002 1
Section 19
WE17035
Annexure C
Supplementary Ecological Survey Summary
I:\WE Jobs 2017\WE17035 - Castaways Beach\wp\IR Response\Ecology and Bushfire NSC IR Response V1.docx
Section 20
WE17035 1
13 November 2017
ANNEXURE C ‐ Supplementary Ecological Survey Summary
Date: 12 October 2017
Duration: 3:00 pm to 7:15pm – 4.25 hrs
Weather: Overcast 8/8ths cloud cover. Wind above 15 knots from the NE. Occasional light drizzle.
Survey Team: Mr David Wassman (Senior Ecologist)
Methods:
Survey effort was targeted towards detection of flora and fauna species of formal
conservation significance previously recorded in the Site locality as detailed in Appendix B ‐
Significant Wildlife Species Likelihood of Occurrence Assessment of the Ecological Assessment
Report (Cardno, 8 August 2017) submitted in support of Application.
Surveys involved educated traverses of the Site focussed around existing habitable structures,
within the riparian zone and along the banks of Burgess Creek and amongst the dense ground‐
layer, particularly when in close proximity to shrubs and trees.
Where available logs, litter and similar features were turned or otherwise disturbed in an
attempt to flush out fauna. Decorticating bark was also removed from some vegetation,
particularly dead Casuarina equisetifolia and Banksia integrifolia with a particular focus on
geckos and other arboreal reptiles.
Call playback to assist with detection of the following fauna species:
‐ Acid frogs; an
‐ Ground parrot.
Spotlight transects were run generally landward to seaward with additional transects along
the banks of Burgess Creek.
Field surveys were completed in accordance with our existing permits:
> Scientific Purposes Permit WISP12206812; and
> Animal Ethics Approval CA 2015/10/906.
Results:
No flora species of formal conservation significance were recorded within or adjacent to the
Site.
The following additional fauna species were observed within the Site and adjoining coastal
reserves:
- Rainbow Bee‐eater (Merops ornatus)
- White‐cheeked Honeyeater (Phylidonyris niger)
- Black‐faced Cuckoo‐shrike (Coracina novaehollandiae)
I:\WE Jobs 2017\WE17035 ‐ Castaways Beach\wp\IR Response\Annexure C ‐ Supplementary Ecological Survey Summary.docx
Section 21
WE17035 2
13 November 2017
- Brown Gerygone (Gerygone mouki)
- Silvereye (Zosterops lateralis)
- Pacific Black Duck (Anas superciliosa)
- Purple Swamphen (Porphyrio porphyrio)
- Common Ring‐tailed possum (Pseudocheirus peregrinus)
- Burton's lizard (Lialis burtonis)
None of these fauna species are threatened species.
A number of canine and macropod scats observed. All scats were considered to be very old
as evidenced particularly by the degraded state of the canine scats. One canine scat that had
apparent hair and bone fragments within it was sent to Barbara Triggs for analysis. The results
of this analysis indicate that the scat was deposited by either a Fox (Vulpes vulpes) or Cat (Felis
catus) and contained only hair and teeth of Rabbit (Oryctolagus cuniculus).
While direct mammal observations were limited to the Ring‐tailed possum a number of small
dedicated ‘runs’ within the undergrowth were observed. It is possible that these are
‘movement corridors’ for small bodied mammals such as the Bush rat (Rattus fuscipes), Fawn‐
footed Melomys (Melomys cervinipes) or the introduced Black Rat (Rattus rattus) or Brown
Rat (Rattus norvegicus).
Conclusions:
The findings of this supplementary ecological survey are consistent with the findings of
previous survey work detailed in the Ecological Assessment Report (Cardno, 8 August 2017)
submitted in support of Application.
Fin.
I:\WE Jobs 2017\WE17035 ‐ Castaways Beach\wp\IR Response\Annexure C ‐ Supplementary Ecological Survey Summary.docx
Section 22
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
Bushfire
Management Plan
Lot 71 on MCH 2854,
Castaways Beach
WE17035
Prepared for
Kenlynn Pty Ltd
13 November 2017
13 November 2017 Cardno i
Section 23
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
Contact Information
Cardno (Qld) Pty Ltd
ABN 57 051 074 992 Document Information
Level 11 Green Square North Tower Prepared for Kenlynn Pty Ltd
515 St Paul’s Terrace
Project Name Lot 71 on MCH 2854,
Locked Bag 4006
Castaways Beach
Fortitude Valley Qld 4006
File Reference Bushfire Management
Telephone: 07 3369 9822 Plan_V1.docx
Facsimile: 07 3369 9722 Job Reference WE17035
International: +61 7 3369 9822 Date 13 November 2017
[email protected]
www.cardno.com.au
Author(s): Effective Date 13 November 2017
John Delaney, Senior Principal –
Ecology & Bushfire
Document History
Version Effective Date Description of Revision Prepared by:
A 4/11/2017 Draft for client review JD
1 13/11/2017 For client use JD
© Cardno. Copyright in the whole and every part of this document belongs to Cardno and may not be used, sold, transferred, copied
or reproduced in whole or in part in any manner or form or in or on any media to any person other than by agreement with Cardno.
This document is produced by Cardno solely for the benefit and use by the client in accordance with the terms of the engagement.
Cardno does not and shall not assume any responsibility or liability whatsoever to any third party arising out of any use or reliance by
any third party on the content of this document.
WE17035 | 13 November 2017
Section 24
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
Glossary of Terms and Abbreviations
AHD Australian Height Datum (AHD) - A common national plane of level corresponding approximately to
mean sea level.
Asset Anything valued by the community that may be at risk of harm from bushfire, including: people,
houses, crops, heritage buildings and places, infrastructure, the environment, businesses and forest
resources.
APZ Asset Protection Zone – An accessible fuel reduced area surrounding a built asset or structure which
fire suppression activities may be carried out.
AS3959 Australian Standard 3959 – Construction of buildings in bushfire prone areas
BAL Bushfire Attack Level, as defined in AS3959, a means of measuring the severity of a building’s
potential exposure to ember attack, radiant heat and direct flame contact, using increments of
radiant heat expressed in kilowatts per metre squared, and the basis for establishing the
requirements for construction to improve protection of building elements from attack by bushfire.
An unplanned fire. A generic term that includes grass fires, forest fires and scrub fires. At times
Bushfire referred to as wildfire.
Bushfire Hazard The potential severity of a bushfire, which is determined by fuel load, fuel arrangement and
topography under particular climatic and weather conditions.
Bushfire Risk The likelihood of a bushfire igniting, spreading and causing damage to the community or the assets
they value and the consequences that arise therefrom.
Bushfire Risk A systematic process that provides a range of treatments which contribute to the wellbeing of
Management communities and the environment, which suffer the adverse effects of wildfire/bushfire.
Ember Attack Attack by smouldering or flaming windborne debris that is capable of entering or accumulating
around a building, and may ignite the building and other combustible materials and debris (e.g.
garden mulch, pine fencing).
QFES Queensland Fire and Emergency Service
QRFS Queensland Rural Fire Service
WE17035 | 13 November 2017
i
Section 25
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
Table of Contents
Glossary of Terms and Abbreviations i
1 Introduction 1
2 Site Context 2
3 Proposed Plan of Development 5
4 Bushfire Hazard and Risk Assessment 6
5 Bushfire Hazard and Risk Management 9
5.1 Lot Layout and Access 9
5.2 Water Supplies 10
5.3 Building Design 10
5.4 Landscape Design 12
5.5 Property Maintenance 13
5.6 Community Awareness 13
5.7 Responsibilities 14
6 Conclusion 15
7 References 17
Figures
Figure 1 Site locality (Source: Google Maps ©)
Figure 2 Aerial photograph of the Site (circa 2017)
Figure 3 Historical aerial photograph of the Site (circa 1990)
Appendices
Appendix A Natural Hazard: Bushfire & Acid Sulfate Soils Overlay (Map OM4.4)
Appendix B Plans of Development
Appendix C Bushfire Management Plan Ref: WE17035-BAR-001
Tables
Table 4-1 Noosa Plan Natural Hazards (Bushfire) Overlay Map for the Site locality 6
Table 5-1 Bushfire Attack Level Setback Assessment – Bushfire Prone Areas 11
WE17035 | 13 November 2017
ii
Section 26
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
1 Introduction
Cardno was commissioned by Kenlynn Pty Ltd to prepare a Bushfire Management Plan (BMP) for a proposed
Reconfiguration of a Lot (RoL) application for Lot 71 on MCH 2854 situated at number 2, David Low Way,
Castaways Beach in the Noosa Shire (the Site).
The Site is partially located within a Bushfire Hazard Area as defined by the Noosa Plan Eastern Beaches
Natural Hazard: Bushfire & Acid Sulfate Soils Overlay (Map OM4.4), dated 3 July 2017, which is reproduced
in Appendix A. The Planning Scheme designation of part of the Site as being within a Bushfire Hazard Area
triggers the requirement for:
> assessment of the proposed development of the Site against the Natural Hazards (Bushfire) Overlay
Code of the Noosa Plan; and
> any residential buildings1 established on the Site to be designed and constructed in accordance
with the specifications of the Building Code of Australia (BCA) and association provisions of
Australian Standard AS3959-2009 Construction of buildings in bushfire prone areas.
This BMP:
complements the findings of a bushfire hazard assessment contained with the Ecological and Bushfire
Assessment Report (Cardno, 8 August 2017) that was submitted in support of a RoL Application
submitted to the Noosa Shire Council on 11 August 2017 (Application Ref: RAL17/0501); and
responds to Item 6 of an Information Request issued by Noosa Shire Council on 7 September 2017
which states “Provide a Bushfire Management Plan that complies with the Natural Hazards Overlay
code of the Noosa Plan.”
In accordance with Council’s request and Noosa Planning Scheme Policy 1 (PSP 1) this BMP has been
prepared in general accordance with Appendix 8 of the State Planning Policy 1/03 Guideline: Mitigating the
Adverse Impacts of Flood, Bushfire and Landslide.
1
Class 1, 2 or 3 building as defined in the Building Code of Australia.
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Section 27
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
2 Site Context
The Site is 0.97hectares in extent and is located in Noosa Shire Council Local Government Area. The general
location of the Site is shown in Figure 1 and an aerial photograph of the Site is presented in Figure 2.
Figure 1 Site locality (Source: Google Maps ©)
Figure 2 Aerial photograph of the Site (circa 2017)
The Site is freehold land that has a ‘Detached Housing’ land use designation pursuant to the Noosa Plan.
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Section 28
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
The Site is partially cleared and supports two existing dwellings and associated infrastructure, which have
been present on the Site since the late 1980s, a period of approximately 30 years, as is evident from the
historical aerial photography presented in Figure 3.
Figure 3 Historical aerial photograph of the Site (Ref: QAP4912, circa 1990)
There is no physical evidence of bushfire having occurred within or immediately adjacent to the Site in recent
years. Whilst there are some indications of past fire (i.e. fire scarring on older trees) within the Site and
adjoining coastal dunes, those fires are likely to have predated the use of the Site for residential purposes in
the late 1980s and the subsequent development of adjacent land to the west for residential purposes in the
mid to late 1990s.
The Site is located approximately 100m westward from the active beach zone (i.e. Castaways Beach) and the
intervening land supports a relatively narrow (~ 100m wide) coastal dune system that supports patches of
weed dominated coastal woodland-low open forest and large areas dominated by low growing grass, vine and
herbaceous species.
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Section 29
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
The Site is bounded by:
> Burgess Creek to the north;
> a relatively narrow band of vegetated coastal dune system, located within a Council managed
reserve, and Castaways Beach to the east;
> similarly vegetated and undeveloped land to the south and south-east; and
> David Low Way and residential development to the immediate west; and
> Noosa National Park further to the west.
A single fire hydrant is located within the eastern edge of the David Low Way frontage to the Site.
The closest fire station to the Site is the Noosa Heads Fire Station situated at 2 Langura St Noosa Heads (ph
07 5473 8484), which is less than 5km distance and 5 minutes travel time from the Site. Other QFES fire
stations less than 15km from the Site include:
> Tewantin Fire Station, 2 Hilton Terrace Tewantin (ph 07 5480 5465); and
> Coolum Fire Station, 25 Elizabeth St Coolum 4573 (ph 07 5453 5322).
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Section 30
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
3 Proposed Plan of Development
The proposed plan of development involves subdivision of the Site to create a total of six (6) residential lots,
ranging in extent from 946m2 to 3,336 m2. All lots would be accessed from a single shared entry/exit point on
David Low Way. All of the lots would be serviced by reticulated water and sewerage infrastructure, and
underground electricity and telecommunication services.
Further details concerning the proposed plan of development are provided in Appendix B.
Approximately 38% of the Site would be the subject of Environmental Covenants, established under the
provisions of the Land Title Act 1994, that requires:
> the retention and protection of native flora and fauna habitat;
> the rehabilitation of any areas subject to temporary disturbance during the construction phase of
development; and
> the ongoing management of non-native plant species.
As detailed in the Ecological and Bushfire Assessment Report (Cardno, 2017) submitted in support of the
Application, the proposed development does not involve the clearance of vegetation of conservation
significance located within or adjacent to the Site.
From a bushfire risk management perspective notable features of the proposed plan of development include:
> each of the lots have a defined building envelope which is setback from designated bushfire hazard areas
to the west of the Site by a distance of over 30m;
> each of the lots will be serviced by a reticulated water supply for bushfire suppression and structural
protection purposes if required, including the establishment of an additional fire hydrant within the David
Low Way reserve;
> provision of a formed access to each of the proposed lots that is designed to meet QFES requirements;
and
> the establishment and maintenance of building setbacks and a 6 metre wide asset protection zone around
the internal perimeter of the Site to:
- physically separate dwellings from areas of retained vegetation within the Site and the adjoining
coastal reserve to the east; and
- preserve physical access to these areas for fire suppressing purposes if required.
It is also noted that the proposed plan of development relies on the on-site treatment of stormwater runoff
using combined infiltration and bio-retention basins within each of the proposed lots. These basins would
occupy an area of approximately 100m2 and are proposed to be located in the eastern boundary of each lot,
such that any overtopping for extreme events will occur as shallow sheet flow into the beach dunes. These
shallow basins would be vegetated with low growing native grass and sedge species and could be safely
located within the proposed APZs that will be maintained along the eastern frontage of each lot.
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Section 31
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
4 Bushfire Hazard and Risk Assessment
Pursuant to the on-line Noosa Plan Natural Hazards (Bushfire) Overlay mapping extract presented in Table 4-
1:
> the north-western sector of the Site is classified as being within the 100m wide Potential Impact
Buffer to areas of vegetated land to the north-west of the Site and west of David Low Way that have
been assessed as having Medium – Very High potential bushfire intensities; and
> the narrow band of sparsely vegetated coastal dune vegetation to the north, east and south of the
Site is not classified as a Bushfire Hazard (Medium to Very High Potential Bushfire Intensity) Area2.
Table 4-1 Noosa Plan Natural Hazards (Bushfire) Overlay Map for the Site locality
Legend
Assessment of the potential risks of harm to the two existing, and proposed future dwellings, on the Site due
to bushfire it is necessary to consider:
> the position of those dwellings relative to designated bushfire hazard areas;
> the conditions under which a medium to high intensity fire is likely to occur within the Site locality
and how those conditions may affect the movement of the bushfire through the landscape and the
associated potentials for Site dwellings to be exposed to direct (e.g. fire front and associated flame
and high radiant heat) or indirect (e.g. ember attack) forms of bushfire attack; and
> the fire suppression and asset protection infrastructure and assets within the Site locality that would
be available for use in response to a bushfire incident.
In respect of the most likely nature of, and responses to, bushfires in the Site locality that could potentially
threaten the Site the following points are noted.
a) The major area of bushfire prone vegetation in the Site locality, and within which a high intensity
bushfire is most likely to occur, is associated with Noosa National Park situated over 400 m to the west
of the Site.
b) The conditions under which a high intensity bushfire are most likely to develop and threaten housing
in the Site locality are associated with a prolonged period of below average rainfall and on days
characterised by hot, dry westerly winds.
2
Whilst not supporting vegetation able to sustain bushfires with a Medium – Very High intensity, the vegetated dunes adjacent to the Site
would be capable of carrying a low intensity fire under suitable conditions.
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
c) The Site is separated from designated bushfire hazard areas within the adjacent sectors of National
Park by established residential housing associated with the Castaways Beach and Sunrise Beach
communities. These communities have a much greater exposure to the bushfire and QFES, National
Parks and Council personnel and resources would be directed towards the defence of these
communities if they, and thereafter the Site, were threatened by a bushfire originating within the Noosa
National Park and being driven in an easterly direction by hot, dry westerly winds.
d) A fire moving in an easterly direction towards the Site through the relatively narrow band of vegetation
(100-250m in width) centred on Burgess Creek, that extends eastward from the Noosa National Park,
would also pose a potential threat to the established communities to the west of David Low Way. As
such QFES, National Parks and Council personnel and resources would be directed towards the
defence of these communities. The most likely tactics that would be employed to contain the bushfire
within the National Park would be to use a combination of direct and indirect methods of attack
including the use of dozers to reinforce existing fire trails, back burning, direct aerial and ground attack
on the fire front and flanks, and suppression of spot fires.
e) David Low Way provides a further line of defence against the eastward movement of a medium to high
intensity fire towards the Site, driven by hot dry westerly winds.
f) The relatively narrow (i.e. ~50m) band of vegetation situated between the western edge of David Low
Way and established residential areas of Castaways Beach, but outside of the designated Bushfire
Hazard Area, is generally located upslope or cross-slope from the Site. If that vegetation becomes
engaged in a bushfire it would present a relatively low threat to dwellings of the Site due to its slope
position and the presence of David Low Way.
g) A bushfires that directly threatens existing or new dwellings on the Site would:
- most likely originate from spot-fires originating from a high intensity bushfire within larger areas
of bushland to the west;
- have a relatively short fire run length;
- most likely be a backing fires (i.e. approaching the Site against the prevailing wind direction);
and
- therefore be of a relatively low intensity.
In summary, the proposed plan of development will result in the establishment of four (4) additional residential
dwellings on the Site which will have some exposure to potential adverse effects associated with medium to
high intensity bushfire occurring within identified bushfire hazard areas to the west (e.g. smoke, ember attack).
There is also some risk of exposure to low intensity spot fires that may established within retained areas of
vegetation within the Site or the adjacent coastal reserve to the east.
The level of risk of harm that future residents and their properties would be exposed to is:
> relatively low and less than that to which many existing residents to the west of David Low Way are
exposed;
> less than that to which existing residents of the two dwellings on the Site would be exposed due to
the fact that new dwellings located within the 100m wide Potential Impact Buffer would need to be
designed and constructed in accordance with AS3959(2009) Construction of buildings in bushfire
prone areas; and
> would be further mitigated by:
provision of a reticulated water supply which would be available for fire suppression
purposes if required;
provision of a formed access to each of the residential lots that has been designed to cater
for the movement requirements of Queensland Fire and Emergency Service (QFES)
appliances if required;
the maintenance of a fire trail / asset protection zone around the internal perimeter of the
Site to provide physical separation between vegetated areas of the Site and adjoining
coastal reserve; and
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Section 33
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
the active management of existing weed infestations within those parts of the Site where
existing vegetation will be retained and enhanced for conservation purposes.
It is also noted that the vegetation within the adjoining sectors of Council managed coastal reserve supports a
highly level of weed infestation. In additional to the widely recognised adverse ecological effects of weeds,
the high biomass of weed species can create unnaturally high fuel loads. This in turn has the potential for
weed infested vegetation to carry higher intensity fires with an associated increased potential for adverse
impacts to the ecological values of the area and increased risks to adjacent residents. In that respect it is
recommended that Council give consideration to the direction of resources towards the management of
existing weed infestations within the adjoining reserve, which is classified in the Noosa Plan as being an area
of high ecological value.
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Section 34
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
5 Bushfire Hazard and Risk Management
Bushfire within the identified bushfire hazard areas to the west of the Site and David Low Way, is likely to occur
at some time in the future due to one or more causes, including arson, accidental ignition, lightning strike and
embers originating from a larger bushfire within the Noosa National Park. Whilst this has the potential to
expose future residents and their dwellings to some risk of harm, in an area such as the Noosa Shire it is not
possible to eliminate all risk of harm to people and property due to the occurrence of bushfire. Rather the
relevant risk management objective is to ensure that residents are exposed to an acceptable level of risk taking
into account the particular characteristics of a proposed development and the community/landscape within
which it is located.
The appropriate mitigation and management of bushfire hazards and risks involves the integration of the
following bushfire hazard mitigation measures during the design, construction and occupational phases of
urban development.
a) Ensuring development design, including the layout of roads and driveways, and the location, size and
orientation of buildings is responsive to bushfire hazards.
b) Appropriate fire-fighting and management infrastructure is provided, including an adequate and accessible
water supply, fire breaks and maintenance/access trails.
c) Specifications and materials for building design and construction are in accordance with AS3959 (2009) –
Construction of Buildings in Bushfire Prone Areas and the Building Code of Australia.
d) Management of potentially hazardous vegetation taking into account the conservation values of that
vegetation and the important role that fire plays in the functioning of many Australian ecosystems.
e) Landscape design and maintenance requirements.
f) Community awareness, education and training.
g) Identification of parties to be responsible for specific bushfire management tasks and actions.
The following sections detail the manner in which the proposed development seeks to ensure that an
acceptable level of risk to human health and property is maintained in the event of a bushfire occurring in the
general locality.
5.1 Lot Layout and Access
The nature of the interface between urban development and bushfire hazard areas has a critical influence on
the likelihood of harm occurring to people and property in the event of a bushfire. The provision of appropriate
building setbacks and a defendable space between areas of potentially hazardous vegetation and adjacent
dwellings is essential to ensuring that the level of risk of harm to people and property associated with exposure
to flame, radiant heat, embers and smoke is maintained at an acceptable level. In addition to building setbacks,
the provision of a lot layout that facilitates safe access routes for bushfire response personnel and safe
evacuation routes for residents, if required, is essential.
In respect of the above David Low Way, located between the Site and designated bushfire hazard areas to the
west, provides:
an effective fire break that would restrict a fire front driven by hot dry westerly winds from approaching
the Site;
an effective fire control / containment line which QFES would use during a bushfire incident; and
a safe and effective access route to the Site in the event of a bushfire incident to deploy QFES
personnel and equipment and if required an egress route for residents of the Site.
Within the Site individual lots would be accessed by an internal 6 m wide driveway which is sufficient to
accommodate the movement requirements of QFES fire appliances typically used in residential areas. This
access will also provide separation between future dwellings and the 10m wide strip of vegetation that is to be
maintained along the David Low Way frontage of the Site.
Within individual residential lots a 6m wide Asset Protection Zone (APZ) will be established and maintained:
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Section 35
Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
> along the entire length of the eastern boundary of proposed Lots 712 to 715;
> along the eastern boundary of proposed Lot 716 up to its intersection with the 10m wide strip of
vegetation to be maintained along the David Low Way frontage of the Site;
> along the eastern boundary of proposed Lot 711 up to its intersection with the 50m Riparian Buffer; and
> to the south of the 50m wide Riparian Buffer within proposed Lot 711 up to its intersection with the 10m
wide strip of vegetation to be maintained along the David Low Way frontage of the Site.
These APZs are to be maintained as a low fuel environment that will provide:
> physical separation between dwellings and areas of vegetation contained within the Riparian Buffer
Area and the coastal reserve to the east of the Site; and
> access around the perimeter of buildings to undertake fire suppression / property protection actions if
required.
To ensure that future residents are aware of and maintain the management requirements for these APZs they
will be the subject of Environmental Covenants registered against the title of individual lots. Details concerning
these obligations are provided within Vegetation Management Plan - Operational Phase - Plan Ref WE17035-
OVMP-001-002 presented in Appendix C.
5.2 Water Supplies
All of the proposed lots will be serviced by a reticulated water supply that makes provision for:
> establishment of an additional fire hydrant to supplement the existing fire hydrant located within the
David Low Way reserve to ensure that fire hydrants are available along the interface between urban
development and areas of potentially hazardous vegetation located at intervals not greater than 120m
in accordance with QFES (2014) guidelines; and
> flow and pressure characteristics that are suitable for fire-fighting purposes, with a minimum pressure
and flow of 10 litres a second at 200 kPa.
5.3 Building Design
Any Class 1, 2 or 3 buildings situated within 100m of designated Bushfire Hazard Area identified within the
Planning Scheme will need to be designed and constructed in accordance with Australian Standard AS3959
(2009) – Construction of Buildings in Bushfire Prone Areas. In general the standards for new homes
construction in bushfire prone areas includes:
> a concrete slab;
> exterior walls, roof, veranda or deck constructed from non-combustible materials;
> sealed wall and roof joints to guard against ember attacks;
> shutters made from aluminium (or other non-combustible material);
> toughened glass windows;
> fire-resistant-timber door frames, with a weather strip at the base; and
> metal (rather than plastic) external trimmings such as vents, guttering and downpipes.
Using Method 1 and Table 2.4.5 of AS3959 (2009) a preliminary analysis of the minimum setback distances
required to achieve the various AS3959 (2009) Bushfire Attack Level (BAL) standards has been completed for
the designated Bushfire Hazard Area to the west of the Site based on the following:
> Vegetation Type: Group A - Low Open Forest (RE12.2.5); and
> Effective Slope: Downslope 0 to 5 degrees3.
3
Mapped Bushfire Hazard Areas to the west of David Low Way are largely cross-slope relative to the Site but with a slight upward grade
under the influence of a westerly wind.
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
The building setbacks required to achieve each of the AS3959 (2009) BAL standards are summarised in Table
5-1.
Table 5-1 Bushfire Attack Level Setback Assessment – Bushfire Prone Areas
Minimum Building Setback
AS3959 (2009)
Risk description as per AS3959 (2009) Required (m)
BAL Category
Low The risk is considered to be VERY LOW. 100
There is insufficient risk to warrant any specific
construction requirements under AS3959.
12.5 The risk is considered to be LOW. 34
There is a risk of ember attack.
Construction elements are expected to be exposed to a
heat flux not greater than 12.5 kW/m2.
19 The risk is considered to be MODERATE. 24
There is a risk of ember attack and burning debris
ignited by wind borne embers and a likelihood of
exposure to radiant heat.
Construction elements are expected to be exposed to a
heat flux not greater than 19 kW/m2.
29 The risk is considered to be HIGH. 16
There is an increased risk of ember attack and burning
debris ignited by wind borne embers and a likelihood of
exposure to an increased level of radiant heat.
The construction elements are expected to be exposed
to a heat flux not greater than 29 kW/m2.
40 The risk is considered to be VERY HIGH. 12
There is a much increased risk of ember attack and
burning debris ignited by windborne embers, a
likelihood of exposure to a high level of radiant heat and
some likelihood of direct exposure to flames from the
fire front.
The construction elements are expected to be exposed
to a heat flux not greater than 40 kW/m2.
Flame Zone - FZ The risk is considered to be EXTREME. < 12
There is an extremely high risk of ember attack and
burning debris ignited by windborne embers, and a
likelihood of exposure to an extreme level of radiant
heat and direct exposure to flames from the fire front.
The construction elements are expected to be exposed
to a heat flux greater than 40 kW/m2.
Each of the proposed Lots has a defined Building Envelope as shown in Drawing Ref WE17035-BAR-001
presented in Appendix D. The nearest of these Building Envelopes to designated Bushfire Hazard Areas is
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
located on proposed Lot 711, which is separated from the adjacent Bushfire Hazard Area to the west by a
buffer at least 33m comprised of:
> cleared areas of the David Low Way reserve ( > 17 m);
> the 10m wide band of vegetation contained within Covenant Area P within Lot 711; and
> the 6m wide formed access way and APZ .
This corresponds to the adoption of a maximum BAL-19 standard in respect of a dwelling located on Lot 711
within the defined building envelope in order satisfy BCA and AS3959(2009) minimum requirements. The
design and construction of dwellings on all other lots to a BAL -19 standard would also satisfy BCA and
AS3959(2009) minimum requirements.
Notwithstanding the above it is noted that:
> the specific BCA and AS3959 BAL requirements for each lot will need to be confirmed once all
relevant conditions of approval for the proposed development are available; and
> individual home owners may choose to adopt a higher AS3959 BAL rating than is required for the
design and construction of their dwelling.
5.4 Landscape Design
Inappropriate landscape designs in bushfire prone areas (i.e. any land within100m of bushfire prone vegetation
with a Medium to Very High hazard rating) may expose a dwelling to increased levels of ember attack, radiant
heat and flame contact. However well-placed designed landscaping with appropriate plant species may
actually help protect houses by:
> reducing the amount of radiant heat received by a house;
> reducing the chance of direct flame contact on a house;’
> reducing wind speed around a house;
> deflecting and filtering embers; and
> reducing flammable landscaping materials within the defendable space.
All vegetative material can burn under the influence of a bushfire, as such landscape design in bushfire prone
areas should give careful consideration to:
> species selection;
> species planting proximity to assets and access paths relative to their flammability; and
> avoidance of both horizontal and vertical continuity of vegetation.
In general “mesic” plant species that have a higher leaf moisture content, less bark and a lower rate of leaf
drop will assist with reducing available bushfire fuel loads thereby assisting in reducing the likelihood and
severity of bushfire attack.
The landscaping of building envelopes within each of the proposed lots should make use of native mesic plant
species in combination with adherence to the following guidelines.
> Establish and maintain lawn or paved areas such as paths and/or a pebble garden with herbs near to
the house, including the defined APZs.
> No planting of trees or shrubs within the define APZs to allow clear access and minimise canopy
overhang of roofs and associated accumulation of leaf litter.
> Outside of the APZs, space tree and shrub plantings to avoid the creation of a continuous bands of
vegetation that may carry fire.
> Prune lower limbs of trees to a height of 2m above ground level.
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
> Avoid using conifers, paperbarks (i.e. Melaleuca species), stringy-bark and ribbon-bark eucalypts in
landscape plantings.
> Avoid using organic mulch with preference given to non-flammable mulches such as scoria (light weight
volcanic stone), pebbles, recycled crushed bricks.
> Regularly water landscape plantings to maintain plant health and moisture levels.
> Utilise non-combustible materials for fencing and retaining walls.
5.5 Property Maintenance
Damage to property by bushfire may be caused by radiated heat, direct flame contact or most commonly by
burning embers landing in, on, or around buildings and starting small spot fires which may destroy the property
long after a fire front has passed.
Prior to the on-set of the bush fire season4 each year the following property maintenance works should be
carried out within each of the properties:
> ensure each APZ is cleared of combustible materials and obstructions and vegetation is maintained at
a height < 150 mm;
> mow all other grassy areas and maintain at a height < 300mm;
> undertake weed management works within the defined Environmental Covenant areas and remove
vegetative material of non-native origin from the subject area;
> remove excess ground fuels and combustible material including long dry grass, dead leaves and
branches from all other parts of each property;
> remove leaf litter and any other combustible materials from the roofs and gutters of all buildings;
> keep areas under decks, fences, fence posts, gates and trees raked and cleared of potential fuels (i.e.
dry grass, leaves, litter etc);
> ensure all roof tiles, roof sheeting, screens and glass on windows and doors, and painted surfaces are
in good condition giving particular attention to repairing any gaps to ensuring that the entry of embers
through gaps is prevented;
> ensure doors are fitted with draught seals and well maintained;
> ensure any LPG cylinders are located to minimise exposure to direct flame and radiant heat and have
their relief values pointing away from buildings;
> ensure that door mats are of non-combustible material;
> check water supplies, hydrants, taps and hoses are accessible and in good working order; and
> prune back any vegetation that may be interfering with safe access and use of driveways, pathways and
roadways.
Specific property maintenance obligations will be imposed within the designated Covenant (Bushfire Risk and
Stormwater Management) Areas under the terms of a statutory covenant. Details concerning these obligations
are provided within Vegetation Management Plan - Operational Phase - Plan Ref WE17035-OVMP-001-002
presented in Appendix C.
5.6 Community Awareness
All prospective purchasers of the individual lots should be provided with clear advice, by the Developer,
concerning the following.
4
In south-east Queensland the bushfire season typically extends from spring (August-September) to mid-summer (January). The greatest
danger occurs after the dry winter/spring period, before the onset of the rainy weather common in summer. The worst conditions occur
when deep low-pressure systems near Tasmania bring strong, dry, westerly winds to the coast, as occurred in the major New South
Wales fires in January 1994. (Source: Bureau of Meteorology).
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Lot 71 on MCH 2854, Castaways Beach
a) Individual lots that are located within 100m of a designated Bushfire Hazard Area and which are subject
to the building design and construction requirements of requirements of AS3959 Construction of buildings
in a bushfire prone area.
b) The requirement for a lot specific AS3959 Bushfire Attack Level (BAL) assessment to be carried out to
confirm the particular BAL standards that would apply to each façade of a dwelling to be constructed on
each lot.
c) The content of this BMP.
5.7 Responsibilities
The Developer is responsible for implementing all of the bushfire management measures specified in Sections
5.1 to 5.2 and 5.6 herein.
Future property owners and occupiers are responsible for:
> the design and construction of dwellings in accordance with AS3959, if required, as per Section 5.3;
> the appropriate landscaping and maintenance of their properties in general accord with Sections 5.4
and 5.5; and
> ensuring that they have an appropriate level of bushfire awareness and preparation in general accord
with the Queensland Fire and Emergency Services guidelines such as those available at:
www.ruralfire.qld.gov.au.
Council is responsible for the maintenance of vegetation, particular weed infestations, within the adjacent
public parklands and road reserves to ensure that excessive fuel loads do not establish within these areas
resulting in avoidable increases in the potentials for adverse environmental and public health and safety .
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
6 Conclusion
Kenlynn Pty Ltd proposes the subdivision of urban land comprised of Lot 71 on MCH 2854 (the Site) situated
at 2 David Low Way, Castaways Beach to establish a total of six residential lots. The Site has a history of use
for residential purposes with two dwellings having been present on the Site for a period of approximately 30
years.
The proposed plan of development will result in the establishment of a small number (i.e. four) of additional
residential dwellings on the Site which will have some exposure to potential adverse effects associated with
medium to high intensity bushfire occurring within identified bushfire hazard areas to the west (e.g. smoke,
ember attack). There is also some risk of exposure to low intensity spot-fires that may established within
retained areas of vegetation within the Site or the adjacent coastal reserve to the east. In this respect it is
noted that in an area such as the Noosa Shire it is not possible to eliminate all risk of harm to people and
property due to the occurrence of bushfire. Rather the relevant risk management objective is to ensure that
residents are exposed to an acceptable level of risk taking into account the particular characteristics of a
proposed development and the community/landscape within which it is located.
The level of risk of harm that future residents and their properties would be exposed to is considered to be
acceptable given that the levels of risks are:
relatively low and less than those to which many existing residents to the west of David Low Way are
exposed;
less than that to which existing residents of the two dwellings on the Site would be exposed due to the
fact that new dwellings located within the 100m wide Potential Impact Buffer would need to be
designed and constructed in accordance with AS3959(2009) Construction of buildings in bushfire
prone areas; and
would be further mitigated by:
- provision of a reticulated water supply which would be available for fire suppression purposes if
required, including establishment of an additional fire hydrant within the David Low Way frontage
to the Site;
- provision of a formed access to each of the residential lots that has been designed to cater for the
movement requirements of Queensland Fire and Emergency Service (QFES) appliances if
required;
- the maintenance of an asset protection zone around the internal perimeter of the Site to provide
physical separation between vegetated areas of the Site and adjoining coastal reserve and access
for fire suppression purposes if required; and
- the active management of existing weed infestations within those parts of the Site where existing
vegetation will be retained and enhanced for conservation purposes.
It is also assessed that the addition of four new dwellings to an identified urban area that has been actively
used for residential purposes for a period of approximately 30 years and which is well serviced by fire fighting
infrastructure and resources, would not place an undue burden on QFES resources.
Given the above facts and circumstances, it is the conclusion of this assessment that future dwellings on and
residents of the Site would not be exposed to an unacceptable risk of harm due to bushfire. Furthermore the
proposed development of the Site in general accord with the recommendations of the BMP would achieve the
relevant overall outcomes sought from the Natural Hazards Overlays Code, including:
a) development in areas at risk from natural hazards is compatible with the nature of the natural hazard
so as not to place people, property, economic activity, social wellbeing and the natural environment at
risk;
b) development is resilient to natural hazard events by ensuring siting and design accounts for and
minimises potential risks of natural hazards to people and property;
c) development supports, and does not unduly burden disaster management response or recovery
capacity and capabilities;
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
d) development directly, indirectly and cumulatively avoids a material increase in extent and severity
of natural hazards and does not significantly increase the potential damage on the site or to other
properties;
f) natural processes and the protective function of landforms and vegetation are maintained in natural
hazard areas;
h) for bushfire hazard areas—bushfire risk mitigation treatments are accommodated in a manner that
avoids or minimises impacts on the natural environment and ecological processes.
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
7 References
Australian Standard AS3959-2009 Construction of buildings in bushfire prone areas.
DTMR (2013). Road Planning and Design Manual (2nd Edition) - Queensland Practice. Prepared by the
Queensland Department of Main Roads and Transport.
QFES (2014). Fire Hydrant and Vehicle Access Guidelines for Residential, Commercial and Industrial Lots.
Development design guidelines prepared by the Queensland Fire and Emergency (Rescue) Service.
State Planning Policy 1/03 – Guideline Mitigating the Adverse Impacts of Flood, Bushfire and Landslide.
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Bushfire Management Plan
Lot 71 on MCH 2854, Castaways Beach
Lot 71 on MCH 2854, Castaways Beach
APPENDIX
A
NATURAL HAZARD: BUSHFIRE & ACID SULFATE
SOILS OVERLAY (MAP OM4.4)
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The text continues on section 44.