bushfire assessment and recommendations · 2017-05-31 · under section 100b of the rural fires act...

Sydney Bushfire Consultants

_____________________________________________________________________ Bushfire Assessment – 60-70 Bournemouth Street Bundeena NSW 2230 Ref: 100B – 085 1 February 2016 Version 8 (Amendment to DA Copy) 1 of 52

Bushfire Assessment and Recommendations Proposed ‘Eco-Tourism’ Development Bundeena Coast Eco Lodge (RVA Australia Pty Ltd) Lot 3 Deposited Plan 213924 60 – 70 Bournemouth Street Bundeena NSW 2230 1 February 2016

Author:

BPAD-Level 3 Certified Practitioner BPD-PA-18593 FPAA Member No. 18593

Reviewed by:



Foreword The following report outlines a bushfire assessment & recommendations for statutory bushfire safety compliance for the proposed eco-tourism development, ‘Bundeena Coast Eco Lodge’, 60-70 Bournemouth Street, Bundeena NSW 2230. The basis and content of the report seeks to;

Provide recommendations for bushfire safety compliance to address the aim and

objectives of the NSW Rural Fire Service document ‘Planning for Bushfire

Protection’, (2006).

Provide recommendations as to the type of construction and design which should

be used (as applicable, retrospectively or otherwise) for the construction of the

new buildings, roadways, water supplies or utilities within the development site

and appropriate asset protection zoning.

Provide detailed information of the above for submission and consideration under

s100B (Bush Fire Safety Authority) of the NSW Rural Fires Act 1997.

Under Section 100b of the Rural Fires Act 1997 a bushfire assessment report must be prepared in accordance with Section A4.2 of ‘Planning for Bushfire Protection, (2006)’, and must consider relevant legislation.

It is not the intention of the bushfire assessment process to underestimate or completely remove all risks associated with bushfire. However, the assessment process attempts to mitigate the risk to a more ‘acceptable level’, given the nature of the development and inherent risks.

The nature of the subject development (i.e. an eco-tourism development located within bushland) make it subject to a real and present risk. The relevant fire services recognise the need for these facilities with specific legislation being drafted and adopted to address the unique nature of the developments. Some general concessions have been applied to ‘eco-tourism’, that don’t apply to other more traditional tourist accommodation facilities.

These are mainly related to removal of some requirements for APZs surrounding the actual accommodation (i.e. tents in this matter), and the introduction of a single ‘refuge building’, within a short travel distance that has a complying APZ, equivalent to those required for normal residential development, in this specific matter (as per NSW RFS Community Resilience Fast Fact 10/07 Version 3 March 2012).

‘Eco – tourism’ is still considered as ‘Special Fire Protection Purpose’ (SFPP) development under Section 100b of the Rural Fires Act 1997.

As such these developments are assessed by the RFS, and approval is determined after measuring the proposal against the bushfire planning provisions within ‘Planning for Bushfire Protection’ - NSW Rural Fire Service 2006 – (PBP 2006).



The NSW Rural Fire Service (RFS) then issue an approval, on bushfire specific grounds only, described as a ‘Bushfire Safety Authority’ (BFSA), allowing Council to move forward with general assessment of the development application. It should be noted that PBP 2006 is also a performance based guideline. As such the document provides for a performance based approach to each development control requirement. A set of ‘Acceptable Solutions’ are included for each bushfire protection measure, which provide for a simplistic ‘deemed to satisfy’ approach to compliance. However, a set of corresponding ‘Performance Criteria’ are also supplied for each bushfire protection measure, allowing for the demonstration of a performance based solution. The subject development will rely on a number of performance based solutions to achieve compliance. If a better outcome can be achieved, (e.g. better environmental outcomes), by using a performance based approach, it should not be considered, by any parties, as a lesser or non-compliant protection measure.

Whilst every effort has been made by the Author of the following report to ensure

the accuracy and relevance of bushfire risk & management for the subject site, it

must be remembered the phenomena of an uncontrolled wildfire and associated

emergency response activities largely remains un-predictable.

Notwithstanding the precautions adopted or referred to by this plan, it should

always be remembered that bushfires burn under a wide range of conditions and an

element of risk, no matter how small, will always remain.



Introduction

The following report has been commissioned by RVA Australia Pty Ltd, herein ‘the

proponent’, to provide a bush fire assessment and recommendations for bushfire

safety and design compliance for the proposed eco-tourism development,

‘Bundeena Coast Eco Lodge’, at 60-70 Bournemouth Street Bundeena, Sutherland

Local Government Area (Sutherland Shire Council), herein ‘the subject property’, or

‘the subject development’.

This assessment considers the subject development site on the basis of;

The subject development site and all surrounding land for at least 140m beyond (denoted as ‘Study Area’ by this report - denoted attached maps).

Site specific inspections undertaken on the 4/9/2014 and 10/9/2015.

The extent and location of the proposed eco-tourism development, inclusive of APZs and travel distances, is based on plans/ drawings prepared by RPS Australia East Pty Ltd, Sutherland (Job No. PR124192SU, Plan Ref: P13, Sheet Nos. 1 – 5, Issue G, Dated 22/01/2016).

Vegetation extent within the subject area has been derived from available aerial photo interpretation (API), Online Council mapping, relevant vegetation studies and on a site visit (4/9/2014 and 10/9/2015).

Terrain (slope) considered by this assessment is based on Department of Lands online information, supplied site plans of the subject property and a site visit (4/9/2014 and 10/9/2015).

Bush Fire Safety Authority (NSW Rural Fire Service Ref. D14/3551 Dated 26 June 2015)

‘Bundeena Coast Eco Lodge’ – Bushfire Evacuation Plan (Sydney Bushfire Consultants, Reference 100B – 085, Version 7, Dated 29/10/2015).

Plan of Management, Bundeena Coast Eco Lodge, RVA Australia Pty Ltd (February 2016).

Traffic Engineering Report by McLaren Traffic Engineering, Sutherland (Reference No. 15445.01FC - Preliminary Traffic Advice for Conciliation Discussions - 18th January 2016)

Ecological Impact Assessment by Cumberland Ecology, Carlingford Court (February 2016)

OEH Terrestrial Vertebrate Fauna of the Greater Southern Sydney Region – Volume 2 - Fauna of Conservation Concern & Priority Pest Species – July 2007

Due Diligence aboriginal heritage assessment by RPS Australia East Pty Ltd, Sydney, Reference PR124192, Dated 15/10/2014

Due Diligence aboriginal heritage assessment by Mary Dallas Consulting Archaeologists 60-70 Bournemouth St Bundeena DRAFT 28 January 2016



A desktop assessment using licensed or on-line spatial data resources available at the time of this report.

The subject development site has been identified as containing bush fire prone land,

hence NSW legislative requirements for new building or integrated land

development on bush fire prone lands is applicable.

For the purposes of this assessment, the subject development is considered an eco-

tourism development.

This requires compliance with both ‘Rural Residential’ planning controls and ‘Special

Fire Protection Purpose’ planning controls (herewith ‘SFPP’). Section 100B (6) (d) of

the RF Act defines tourist accommodation as requiring special fire protection.

Section 91 of the EP&A Act 1979 (in combination with the Rural Fires Act 1997

requirements for a section 100B - Bush Fire Safety Authority) classes a SFPP

development as integrated development. In this respect, the subject development is

considered ‘integrated development’, and as such has been assessed against the

requirements and principals (aim and objectives) as outlined in the NSW document

‘Planning for Bushfire Protection 2006’.

Planning for Bushfire Protection states;

‘The aim of PBP is to use the NSW development assessment system to provide for the

protection of human life (including firefighters) and to minimise impacts on property

from the threat of bush fire, while having due regard to development potential, on-

site amenity and protection of the environment.

More specifically, the objectives are to:

(i) afford occupants of any building adequate protection from exposure to a bush fire;

(ii) provide for a defendable space to be located around buildings;

(iii) provide appropriate separation between a hazard and buildings which, in combination with other measures, prevent direct flame contact and material ignition;

(iv) ensure that safe operational access and egress for emergency service personnel and residents is available;

(v) provide for ongoing management and maintenance of bush fire protection measures, including fuel loads in the asset protection zone (APZ);



(vi) ensure that utility services are adequate to meet the needs of firefighters (and others assisting in bush fire fighting);

(vii) provide for the special characteristics and needs of occupants (SFPP Development); &

(viii) provide for safe emergency evacuation procedures (SFPP Development).’

This assessment includes an analysis of the potential hazard persisting and affecting the subject development site and the standards and bush fire mitigation measures that should be introduced to address the objectives of PBP 2006 and AS 3959:2009 where applicable. Bushfire safety compliance, as purported by this report, for the subject development

site comprises a package of measures in combination including asset protection

zones, access and egress, construction standards, water supply, property

maintenance planning and evacuation planning.

The above measures have been derived from provisions (performance criteria and /

or acceptable solutions) as outlined within the document ‘Planning for Bushfire

Protection 2006 (PBP)’, engineered judgment, considered opinion, and previous

advice or determinations from the NSW Rural Fire Service Development Control Unit.

NSW Rural Fire Service Fast Fact 10/07 Version 3 March 2012 (Ecotourism) is also

considered for the purpose of this assessment and associated recommendations

The following bushfire assessment has been prepared in accordance with the NSW

Rural Fires Regulation 2008, Clause 44 - Application for a Bushfire Safety Authority.

Abbreviations

API Aerial Photography Interpretation

APZ Asset Protection Zone

AS1596 Storage & Handling of LP Gas

AS2419 Fire Hydrant Installations, Part 1: System Design, Installation &

Commissioning

AS3745 Emergency control organisation and procedures for buildings, structures

and workplaces for residential accommodation

AS3959 Australian Standard 3959-2009 Construction of buildings in bushfire-

prone areas

BCA Building Code of Australia

DEM Digital Elevation Model



DTS Deemed-to-satisfy building solutions as prescribed by the Building Code

of Australia

DP Deposited Plan

E East or Eastern

EPA Act NSW Environmental Planning & Assessment Act 1979

EWSS External Water Spray System

FDI Fire Danger Index

FRA Fuel Reduced Area

IPA Inner Protection Area (PBP 2006)

PBP NSW Rural Fire Service Planning for Bushfire Protection (2006), A Guide

for Councils, Planners, Fire Authorities and Developers, ISBN 0 9751033

2 6

N North or Northern

OPA Outer Protection Area (PBP 2006)

RF Reg. NSW Rural Fires Regulations 2002

RF Act NSW Rural Fires Act 1997

RFS NSW Rural Fire Service

S South or Southern

SEPP State Environmental Planning Policy

SFPP Special Fire Protection Purpose

W West or Western



Table of Contents Page

Forward 2 Introduction 4 1.0 Description of the property 9 1.1 Lot and deposited plan number of the subject property 9 1.2 Street address and locality map 9 1.3 Zoning of the subject land and adjoining land 9 1.4 Staging issues, if relevant and description of whole proposal 10 1.4.1 Staging issues 10 1.4.2 Proposal Description 10 1.5 Aerial or ground photographs including contours and cadastre 11 2.0 Classification of vegetation out to 140m from development 11 2.1 Structural description of vegetation (Keith 2004 & PBP) 11 2.2 Past disturbance factors and future uses that may alter vegetation in future 13 3.0 Assessment of effective slope to a distance of 100m 13 4.0 Identification of any significant environmental features 15 5.0 Details of threatened species, populations, endangered ecological communities

and critical habitat known to applicant 17 6.0 Details of aboriginal heritage known to applicant 17 7.0 Bushfire Assessment (including methodology) / fire modeling 18 8.0 Asset Protection Zones (including any management arrangements or easements

including those contained on adjoining lands 18 8.1 Bushfire vegetation management regimes (existing and proposed) 23 9.0 Siting and adequacy of water 26 10.0 Capacity of public roads 27 10.1 External public roads 27 10.2 Internal roads 30 11.0 Public roads link to fire trails and have two way access 31 12.0 Adequacy of access and egress for emergency response 31 13.0 Adequacy of maintenance plans and emergency procedures 31 13.1 Bushfire maintenance plan 31 13.2 Bushfire emergency procedures 32 14.0 Construction standards to be used 33 15.0 Adequacy of sprinkler systems 34 16.0 An assessment of how the development complies with acceptable solutions,

performance requirements and relevant specific objectives of chapter 4 of PBP 34 16.1 Performance Criteria/Acceptable Solutions compliance 34 16.2 PBP 2006 Specific Objective assessment 38 17.0 Bushfire safety and compliance recommendations 39 18.0 Conclusions 43 19.0 References 45 Appendix 1 Maps / Site Plans / Images Appendix 2 Site Photographs 4/9/2014



1.0 Description of the property

1.1 Lot and deposited plan (DP) number of the subject property

Lot 3 DP 213924.

1.2 Street address and locality map

‘Bundeena Coast Eco Lodge’, 60 – 70 Bournemouth Street, Bundeena NSW 2230.

Locality maps attached Appendix 1.

1.3 Zoning of the subject land and any adjoining lands

The subject land, at the time the DA was lodged, was zoned ‘Zone 12 – Special Uses

Recreational Camp’ under the Sutherland Shire Local Environmental Plan (2006).

Land to the E and the W of the subject site is within Royal National Park. Residential

development adjoins the subject site to the N were – ‘Zone 1 – Environmental

Housing (Environmentally Sensitive Land)’. Whilst the land directly S of the subject

site did have a deferred zoning of ‘5(a) Special Uses Sanitation Depot’ under the

Sutherland Shire Local Environmental Plan (2000).

Extract SSLEP (2006)

Subject Development

Site



It is noted that the zoning of the site is now ‘E2 – Environmental Conservation’ under

the new Sutherland Shire LEP 2015 (SSLEP 2015).

1.4 Staging issues, if relevant, and description of the whole proposal

1.4.1 Staging

Staging issues are not considered relevant to the subject development. For the

purposes of bushfire safety compliance, the subject development will not rely on any

temporary asset protection zone (APZ) easements / agreements within the subject

development site or on adjoining lands.

1.4.2 Proposal Description

As provided by the proponent at the time of this report, the following information is

based on;

The extent and location of the proposed eco-tourism development, inclusive of APZs and travel distances, is based on plans/ drawings prepared by RPS Australia East Pty Ltd, Sutherland (Job No. PR124192SU, Plan Ref: P13, Sheet Nos. 1 – 5, Issue G, Dated 22/01/2016).

‘Bundeena Coast Eco Lodge’ is proposed to be a low impact eco-tourism development. It will consist of 6 camping platforms (containing semi-permanent tents with private bathroom facilities), constructed on the edge of the bush land. It will also contain a combined Caretaker’s Accommodation / Office / Reception above a Local Refuge Building/ Utility Room, Garage and Storage Room, along with a separate Camp Kitchen / Dining Area (located remote from the main structure).

The ‘Local Refuge Building’ will comply with the APZ requirements and achieve construction requirements for residential buildings (i.e. APZ and construction levels to AS3959-2009) – in terms of the ‘Acceptable Solutions’ contained within S4.2.7 PBP 2006). ‘Bundeena Coast Eco Lodge’ is located on the SE edge of Bundeena Village and is generally encircled by the Royal National Park, close to the start of the ‘Coast Track’, a popular walking track through the national park. It is proposed to be constructed on land, previously owned by the scout movement, which was originally earmarked for the construction of a scout camp. The overall capacity/density of the ‘Eco tourism’ development will not exceed 12 persons at any time (over the 6 camp sites) and max. 3 – 5 staff members. In addition, the caretaker’s accommodation will also be located on the site. The subject development site will not be connected to the normal power supply grid,

and will rely on solar and modern waste heat driven generators with battery backup.



The subject development site is not connected to any domestic reticulated water

supply. Water supplies will be static (non reticulated) in the form of tanks on site.

The location of all static supplies, fire hose reel instalations and infastructure

designed for water supply are as otherwise denoted Appendix 1.

1.5 Aerial or ground photographs of the subject land including contours and

existing and proposed cadastre

Ground / site photography of the subject property are appended to this report

(Appendix 2 – Site Photos, 4/9/2014).

Aerial photography (oblique / boundary overlay) is as appended to this report

(Appendix 1).

Contours as shown / considered by this report are derived from the Department of

Lands SIX Viewer Digital Elevation Model (DEM) data (10m Contour Interval)

(Appendix 1).

2.0 Classification of vegetation out to 140m from the development

2.1 Structural description consistent with the identification key in Keith D

(2004) and PBP

Vegetation extent (bushfire hazard) within the study area is derived from aerial

photo interpretation (API) and an inspection of the subject property on the

4/9/2014. Vegetation communities were also confirmed by reference to the

Sutherland Shire Council online vegetation mapping system.

Council vegetation mapping generally appears to have excluded the subject site.

However, an ecological due diligence report was completed by Ecological Australia

Pty Ltd (Reference No.13SUTECO-0055 Dated 14 August 2014), which confirmed that

the site generally contained a ‘Coastal Freshwater Lagoon’ in the bottom of the

valley, ‘Coastal Sandstone Gully Forest’ throughout the lower valley, transitioning to

‘Coastal Sandstone Ridgetop Woodland’ on the upper reaches then to ‘Coastal

Sandstone Plateau Heath’ on the exposed plateaus. This is generally in line with the

above mentioned Council mapping.



As shown above, the subject development site contains varying types / structures of vegetation. The eco-tourism development is proposed to be located within an area of ‘Sydney Sandstone Ridgetop Woodland’ (to be modified to establish an APZ), overlooking a valley of ‘Sydney Sandstone Gully Forest’ on the sloping ground running into the wetlands. All vegetation within the immediate area, due to its structure, would be consistent with, and has been assessed as, ‘Dry Forest’ vegetation.

2.2 Past disturbance factors and any future intended land uses that could alter

the vegetation classification in the future

Considering the zoning and uses of lands adjacent to the subject property, i.e. urban

residential construction to the N and bush land to the S, E & W, it is reasonable to

assume that the bushfire risk to the subject development will not increase any

further over the life of the development.

3.0 Assessment of the effective slope to a distance of 100m

Slope analysis (used by this assessment) is derived from 10m grid digital elevation

model (DEM) and a general inspection of the subject development site. This includes

deriving contours for each 10m change in elevation and the approximate areas of

slope / gradient based on PBP slope classes.

The development site, around the proposed tent sites, and running down into the

wetlands is typical sandstone geology, with large sandstone outcrops, ledges and

drop-offs.

Whilst the majority of the development will be located on the flatter sections within

the upper reaches of the site (i.e. along the S boundary), slopes within the persistent

vegetation generally range up to 15 - 18 degrees down slope.

It is noted that limited areas within the Northern extent of the APZ exceed 18

degrees down slope, over short distances (slopes up to 18.8 degrees downslope

overall). Council has expressed concerns (Contention 4 Bushfire Safety) that relate

vegetation maintenance procedures and soil stability, within the lower reaches of

the IPA, will not be achievable, due to the slopes exceeding 18 degrees’ downslope.

The proponent is confident that appropriate vegetation maintenance procedures can

be effectively carried out in these areas, using a series of hand held tools (manual or

powered).



Considering the location of existing roadway access and maximum acceptable slope

gradient (as defined in PBP, <10 degrees’ for unsealed roadway or <10 degrees’

average grade), slope within or adjacent to the subject development site will not

constrain the location of existing vehicle access roadway or the maintenance of

proposed asset protection zones as otherwise recommended by this report.

4.0 Identification of any significant environmental features

For the purposes of bushfire safety compliance, this assessment notes that the subject property contains large areas of native vegetation. Some vegetation, within the lower sections (NE) of the site is known as ‘Coastal Freshwater Lagoon’, which is a component of ‘Freshwater Wetlands on Coastal Floodplains’. There are also patches of Coastal Sand Bangalay Forest. Both these vegetation groups are considered an Endangered Ecological Communities under the NSW Threatened Species Conservation Act 1995. However, it is not a recommendation of this assessment to remove or alter any of the EEC vegetation within the study area, as part of the bushfire protection measures.

The proponent has not advised of any other constraint, restriction or burden over

the subject property limiting the management of vegetation for the purposes of land

development and associated asset protection zone maintenance, apart from local

planning legislation contained within or appended to the various Sutherland Shire

Council LEPs (i.e. any local tree preservation orders etc.)

Based on a brief desktop assessment of the subject property, the following table

outlines significant environmental features potentially affected by the subject

development.

Table 1.0

Present within

Subject

Property

Present within

Study Area

Comment

Native Forest /

Vegetation

Yes Yes Native vegetation is located within

the subject development and lands

adjoining the subject development,

within the study area.

Some vegetation within these areas

are classified as ‘Endangered

Ecological Communities’ (Threatened

Species Conservation Act 1995)

Given the proposal is for an eco-

tourism resort, the retention of

native bush land forms an important

aspect of the overall development.



Table 1.0

Present within

Subject

Property

Present within

Study Area

Comment

It will be a recommendation of this

assessment to remove only minimal

vegetation only, to create safe APZ

areas and egress routes from the

camp sites to the refuge building.

Riparian Corridor Yes Yes The subject property contains an

area of Coastal Freshwater lagoon.

Some drainage lines feed into the

lagoon that run through the subject

site. However, it is not proposed to

remove any of the vegetation from

within any area that could be

considered a riparian zone as part of

this development or for the proposed

bushfire protection measures.

SEPP 14 – Wetland No No

SEPP 26 – Littoral

Rainforest

No No

SEPP 44 – Koala

Habitat

No No

Areas of Geological

Interest

Undetermined Undetermined

Environmental

Protection Zones

Yes

Yes

The SSLEP 2015 has now been

enacted. The zoning of the subject

site is now ‘E2 – Environmental

Conservation’ with use eco-tourism

Steep Lands (>18°) Yes Yes Very limited areas only

Land Slip Area No No

Flood Prone Area No No Although, riparian areas, creeks etc.

are noted in study area.

National Park Estate No Yes Adjoining the Royal National Park

State Forest No No

Apart from the above, no other known environmental features have been noted,

recorded or advised of as part of this assessment.



5.0 Details of threatened species, populations, endangered ecological

communities and critical habitat known to the applicant

For the purposes of bushfire safety compliance, this assessment notes that the subject property contains large areas of native vegetation. Some vegetation, within the lower sections (NE) of the site is known as ‘Coastal Freshwater Lagoon’, which is a component of ‘Freshwater Wetlands on Coastal Floodplains’. There are also patches of Coastal Sand Bangalay Forest. Both these vegetation groups are considered an Endangered Ecological Communities under the NSW Threatened Species Conservation Act 1995. However, it is not a recommendation of this assessment to remove or alter any of the EEC vegetation within the study area, as part of the bushfire protection measures.

Given the proposal is for an eco-tourism resort, the retention of native bush land

forms an important aspect of the overall development. It will be a recommendation

of this assessment to remove only minimal vegetation only, to create an APZ area

and safe egress routes from the camp sites to the refuge building.

It is considered established that the threatened species Eastern Pigmy Possum is

present at the subject site.

OEH Terrestrial Vertebrate Fauna of the Greater Southern Sydney Region – Volume 2 - Fauna of Conservation Concern & Priority Pest Species – July 2007 concludes on p159:

“-Habitat for the Eastern Pygmy-possum is widespread within the Study Area and the species does not seem to occur in isolated subpopulations in this Region. It should therefore be considered to be a moderate conservation priority. -Heath-leaved Banksia is killed by fire and will not flower for several years after a burn. Retaining refuge areas of this (and others identified in the model as high-quality Eastern Pygmy-possum habitat) in an unburnt state for over eight years would be beneficial, as recommended by Tulloch (2003). “ The current NPWS fire management plan with regular hazard reduction burns is not consistent with the above recommendation. The mechanical hazard reduction works of the current proposal are actually the preferred method of vegetation management in the context of the Eastern Pygmy Possum.

No other threatened species, populations, endangered ecological communities or

critical habitat has been noted, recorded or advised of as part of this assessment.

For the purposes of this assessment, the proponent has not provided nor indicated

there to be any other threatened species issues or occurrence potentially affecting

the subject development site, recommended APZ or fuel reduced surrounds.



6.0 Details of Aboriginal heritage known to the applicant

A ‘due diligence’ aboriginal heritage assessment has been carried out on the site

(RPS Australia East Pty Ltd, Sydney, Reference PR124192, Dated 15/10/2014). This

assessment concluded that ‘no aboriginal objects or places have been identified

within the project area’.

The site is located within an area noted as ‘Medium’ in the local ‘Archaeological

Sensitivity Map’. As such Aboriginal heritage issues are addressed as part of the

overall development application process.

For the purposes of this assessment, the proponent has not provided nor indicated

there to be any items or issues of Aboriginal heritage potentially affecting the subject

development site.

Likewise, this assessment has not considered any past studies, surveys for the area

or any documentation supplied to council in relation to any items or issues of

Aboriginal heritage potentially affecting the subject development site.

A second more substantial ‘due diligence’ aboriginal heritage assessment has been

carried out on the site by Mary Dallas Consulting Archaeologists and La Perouse Land

Council representatives in January 2016. This assessment confirmed the findings of

RPS and that no further assessments of aboriginal heritage are warranted. (Mary

Dallas Consulting Archaeologists 60-70 Bournemouth St Bundeena DRAFT 28 January

2016)

7.0 Bush fire assessment (including methodology)

Methodology for this site assessment for bushfire attack and recommended

mitigation measures (setback distances and construction standards) are based on

PBP 2006 (Appendix 2 & Addendum: Appendix 3).

NSW RFS Fast Fact 10/07 Version 3 March 2012 (Ecotourism) is also considered for

the purposes of defining construction standards and asset protection zone areas for

Eco-tourist facilities.

The Sutherland Shire LGA is designated as potentially having an FDI of 100 as a 1:50

year event (PBP Appendices 2 – Table A2.3).



8.0 Asset protection zones (including any management arrangements or

easements including those contained on adjoining lands)

Considering the category of development (Eco-Tourism), the minimum specified APZ

/ setback distances determined for bushfire safety compliance are derived on the

basis of PBP 2006, specifically Appendix 2 – Table A 2.4. Although, technically

considered a ‘SFPP’ development, NSW RFS Fast Fact 10/07 Version 3 March 2012

(Ecotourism), providing guidance specifically for Eco-tourism development, states

the following in regard to APZ requirements:

‘Ecotourism developments are to provide a safe refuge area that can accommodate all proposed occupants and adhere to standard residential subdivision requirements for asset protection zone and construction standard specifications in accordance with Section 4.1.3 of PBP 2006’. Further PBP 2006 gives further guidance for eco tourism developments regarding APZs, egress routes and overall suitable protection measures. They are as follows: ‘A major challenge arises with ‘eco-tourism’ facilities in which accommodation has traditionally been built into a remote bushland environment. Eco-tourism aims to foster environmental and cultural understanding, appreciation and conservation, be ecologically sustainable and based on relatively undisturbed natural areas. Clearly this can conflict with bush fire safety objectives, which aim to reduce a building’s vulnerability to ignition from heat radiation, flame or embers and to provide safe access and a minimum defendable space for firefighter safety. Access can also be problematic and the requirements for access possibly across adjoining properties will need to be carefully assessed. This should recognise the risk faced by fire fighters trying to gain access and occupants trying to evacuate to safer areas -see page 39 (S4.2.4 page 29)’. ‘Where eco-tourist facilities are planned they should have low accommodation levels (generally less than 12 persons) so as to facilitate relocation and emergency planning, and be located within 100 metres of a public road or 50 metres from a major refuge away from any forested or heathland areas (S 4.2.7 Page 38)’.

‘at least one building should be used as a local refuge area and comply with the APZ’s and construction requirements for residential buildings.

cabins are within 50 metres of a refuge building and are clearly signposted.

the paths from cabins to the refuge area are safe, with management of surface fuels to ≤ 4 tonnes/ha.

the overall accommodation for tourists does not exceed 12 persons.



Further legal investigations have determined that Sussex Street will no longer be available to the development site, apart from a central crossover driveway/access roadway, as such the proposed FRA area has been slightly reduced. It should be noted that major IPA has been designed on a stand-alone basis as a bushfire protection measure. It assumes all other areas, within and adjacent to the subject site, contain persistent forest vegetation. As such the FRA is merely an additional bushfire protection measure, whose overall effects are not meant to be quantifiable, rather than add to the overall raft of protection measures. The reduction in the area of the FRA will not affect the extent or location of the IPA, which is already specifically designed to reduce radiant heat levels to 29kW/m2 at the refuge building, and will have no detrimental effects on the development overall. Note: All of the proposed accommodation (6 x tent sites, Caretakers Accommodation) is proposed to be located within 50m of the ‘Local Refuge Building’ - within the subject site.

The ‘Local Refuge Building’ will have an APZ area complying with Table A2.4 (maintained as an IPA) and will be constructed to an enhanced minimum bushfire construction level of BAL FZ and as the combined Caretaker’s Accommodation / Office / Reception is proposed to be located above the refuge, a fire rated roof/floor element (FRL 60/60/60 – as per AS 1530.4) will separate the two parts of the structure. The exit travel paths, from the camp sites and residence, will be wholly contained within the Asset Protection Zone (maintained as an IPA and FRA) of the ‘Refuge Building’ and as such will be maintained in an area where the management of surface fuels will not exceed 4 tonnes/ha, and given it will be within an APZ/IPA area, canopy and mid level fuels will also be greatly reduced to install a compliant IPA.

The refuge building is proposed to be approximately 89m3. Utilising the details within ‘Performance Standards for private bushfire shelters (ABCB 2010) - Table 3.4.3 Theoretical Duration of Occupancy’ as a comparative guideline only - a sealed structure of 45m3 will supply sufficient oxygen for approximately 10 persons for a duration of 14.9 hours. Whilst it is not proposed to build a structure to these guidelines, the table shows that the proposed structure will have a capacity to support up to 22 people (12 guests and up to 5 staff and a resident caretakers’ family of 5) for a considerable amount of time (even if applying a significant safety margin of 1:5), a one-hour window is still achievable and would be considered appropriate. The refuge may be required to hold up to 22 persons (12 guests and up to 5 staff and a resident caretakers’ family of 5) for a short period of time (possibly up to 1 hour). Available floor space within the refuge building for evacuees will be approximately 31m2, or approximately 1.4m2 per person. This also leaves a separate garage area of approximately 51m2 for evacuation vehicles.



This also exceeds the minimal requirements of ‘Performance Standards for private bushfire shelters (ABCB 2010) which recommends a minimum floor space in refuges of 0.75m2 per person.

Based on the analysis of slope and vegetation extent likely to persist adjacent to the

subject property, the subject development (Bundeena Coast Eco Lodge) can facilitate

the intent of the ‘Performance Criteria’ and achieve the ‘Acceptable Solutions’ for

‘Emergency and Evacuation Planning’ in relation to eco-tourist accommodation.

See survey/site plans and arborist reports detailing APZ canopy coverage and travel

distances.

PBP 2006 acceptable solutions for APZ (SFPP) compliance states that;

an APZ is provided in accordance with the relevant tables / figures [within PBP

2006],

exits are located away from the hazard side of the building,

the APZ is wholly within the boundaries of the development site (exceptional

circumstances* otherwise permitting),

mechanisms are in place to provide for the maintenance of the APZ over the life

of the development,

the APZ is not located on lands with a slope exceeding 18 degrees, &

the APZ is managed and maintained in accordance with the requirements of

‘Standards for Asset Protection Zones (RFS 2005).

Table 1.0 below outlines APZ compliance or non-compliance where applicable.

Table 1.0 – Subject Building Development

APZ Compliance

Eco-Tourism Development

an APZ is provided in accordance with the

relevant tables / figures

An APZ will be provided. It will relate

directly to the ‘Refuge Building’. It

will facilitate safe evacuation and

provides for acceptable travel

distances.

exits are located away from the hazard side

of the building

The subject development consists of

6 small camp sites, caretaker’s

accommodation / office / reception

above a refuge building with a



separate kitchen / dining facility,

within a bush land setting. Egress

arrangements will satisfy the

requirements for Eco-tourism

developments. Egress paths are

within the IPA and direct the

occupant away from the hazard.

the APZ is wholly within the boundaries of

the development site (exceptional

circumstances otherwise permitting)

Yes, the ‘Inner Protection Area’ will

be located wholly within the

boundaries of the development site.

mechanisms are in place to provide for the

maintenance of the APZ over the life of the

development

Recommended

the APZ is not located on lands with a slope

exceeding 18 degrees

Limited areas within the Northern

extent of the APZ marginally exceed

18 degrees down slope, over short

distances. Natural groundcovers will

be retained and/or regenerated

within this area to provide for better

soil stability. In addition, vegetation

maintenance procedures will be

carried out using a series of hand

held tools (manual or powered).

the APZ is managed and maintained in

accordance with the requirements of

‘Standards for Asset Protection Zones

Recommended

8.1 Bushfire vegetation management regimes (Current and Proposed)

Current Bushfire Management Regime Bushfire risk pertaining to the subject site, the land previously owned by Council to the South, and the Royal National Park to the East and further afield is currently managed by the National Parks & Wildlife Service under the ‘Royal & Heathcote National Parks & Garawarra SCA Fire Management Strategy 2009’. This Fire Management Strategy is considered to provide a suitable level of bushfire protection to the south eastern areas of the village of Bundeena, from a potential bushfire event either from within the Spring Gully area and/or from within the greater Royal National Park.



The bushfire protection measures, implemented by the said strategy, include the installation/maintenance of 2 separate management ‘Zones’. The first measure is a large ‘Asset Protection Zone’ (APZ) which encompasses a large area within the eastern section of the subject site, extending to the adjacent residential development along Beachcomber Avenue to the North, and into the Royal National Park lands to the East, terminating at the proposed access road to the subject site. The second measure is a large ‘Strategic Fire Advantage Zone’ (SFAZ) which covers the remainder of the general Spring Gully area, including the remainder of the subject site (western section). These areas are primarily managed to achieve bushfire safety outcomes, with some consideration of the environmental impacts where appropriate. The NPWS objective for an APZ is ‘the protection of human life and property. This will have precedence over guidelines for the management of biodiversity. Maintain Overall Fuel Hazard at Moderate or below’. This is normally achieved utilizing manual techniques such as ‘slashing’. The NPWS objective for an SFAZ is to ‘reduce fire intensities over larger areas. Maintain Overall Fuel Hazard at High or below, however adherence to guidelines for biodiversity will take precedence where practical’. This is normally achieved using periodic hazard reduction burns, conducted within environmental thresholds (or timeframes) specifically based on the vegetation species within the area. It should be noted that the current Spring Gully APZ has traditionally been managed only as a SFAZ, and treated with periodic hazard reduction burns only, in conjunction with the greater Spring Gully SFAZ. It should also be noted that the prescribed burns were conducted only in 2002/2003 and more recently in 2015, at an interval of approximately 12 years. Ideally, this vegetation should be subject to burns at 7 year intervals. As Council and private lands were party to the subject management strategy, Council is required to review the environmental impacts of any proposed bushfire hazard reduction program. Council conducted a review of the recent Hazard Reduction Burn (reviewed 15 July 2014 and conducted in mid-2015) and approved the proposed actions, concluding that the burn would not have an adverse effect on the area, including the erosion effects on steep slopes within the burn area. Proposed Bushfire Management Regime

The vegetation within the subject site is proposed to be managed under the Vegetation Management section of the Management Plan (Bundeena Coast Eco Lodge, RVA Australia Pty Ltd (Revision A, February 2016), which forms part of the development application documentation.



This vegetation management regime has been designed to offer an equivalent level of bushfire protection to the adjacent residential areas within Bundeena Village, and in line with the current vegetation management regime in place for the RNP and surrounding areas.

The bushfire protection measures, proposed to be implemented by the said plan, include the installation/maintenance of 3 separate management ‘Zones’.

The first measure is an ‘Inner Protection Area’ (IPA) which forms a complying ‘Asset Protection Zone’, based on the relevant ‘eco-tourism’ bushfire planning provisions within PBP 2006 (i.e. maximum RHF or 29 kW/m2 at the ‘refuge’ building entrance). The IPA is located within the Southern section of the subject site and contains the proposed main building structures.

The area identified as IPA is proposed to be managed in terms of PBP A2.2 (vi) which states: The IPA is critical to providing a defendable space and managing heat intensities at the building surface. The IPA should provide a tree canopy cover of less than 15% and should be located greater than 2 m from any part of the roofline of a dwelling. Garden beds of flammable shrubs are not to be located under trees and should be no closer than 10 m from an exposed window or door. Trees should have lower limbs removed up to a height of 2 m above the ground.

The second measure is a ‘Fuel Reduced Area’ (FRA) which covers the area North, East and West of the IPA, and is also bounded by the two Riparian Zones (which are excluded as they are also to be excluded from the NPWS SFAZ hazard reduction works).

The area identified as FRA is should be regularly maintained through manual means, to ensure that the natural buildup of dead leaves and branches is restricted. Any exotic vegetation should be removed.

This is to ensure that the fuel loadings are maintained at an overall fuel Hazard of ‘High’ or below (as per the Overall Fuel Hazard Guide - Department of Sustainability and Environment 3rd Edition 1999) which is in line with specific SFAZ parameters utilised by the NPWS within the current management regime, thus giving at least an equivalent level of protection to the residential areas as is currently in place.

In actual fact, given the length of time between prescribed hazard reduction burns (i.e. generally at least 7 years, but up to 12 years as per recent works), a regular manual management regime, as proposed, which continually manages fuel levels equivalent to a SFAZ level, will provide a ‘better’ level of protection overall to the adjacent residential area.

The environmental benefits within the site will also be enhanced by the exclusion of the ‘Riparian Zones’ from the fire management regimes, and the introduction of a new ‘Conservation Area’ within residual lands in the western section of the subject site. These areas will be managed to achieve environmental outcomes only, including the management of weeds and maintenance of native vegetation.

The environmental impact of the bushfire protection measures stated above have been assessed by the consulting arborists and confirmed within the Ecological Impact Assessment.



The Arboricultural Assessment, by Peter Richards - Tree and Landscape Consultants, Padstow (dated 21 October 2015), has confirmed that the works associated with the pruning of trees as recommended by the Bushfire Assessment ‘is not considered to be detrimental to the health and condition of trees’ providing the recommendations of the assessment are suitably implemented.

This was also confirmed within the Ecological Impact Assessment by Cumberland Ecology, Carlingford Court (February 2016) which, in part, states:

‘Impact of proposed IPA/FRA vs NPWS SFAZ The subject site currently forms part of the Spring Gully SFAZ which covers a total area of 165.85 ha. The proposed IPA/FRA for the proposed development will alter the bushfire regime of a total area of 3.15 ha.

The regime for the FRA does not entail removal of vegetation but is limited to removal of litter build up to reduce fuel loads. From an ecological perspective, this does not differ significantly from the NPWS regime and therefore will not significantly alter the current biodiversity values within the proposed FRA.

The proposed IPA regime will entail removal of understorey vegetation and reduction of canopy cover. However, the retention of trees will still provide connectivity with bushland in the adjacent Royal National Park and limited groundcover habitat will still be available for native fauna and flora.

Therefore, from an ecological perspective, the alterations to the bushfire regime are not considered to significantly alter the current biodiversity values within the IPA.

The IPA will collectively alter the bushfire regime of a total area of 0.50 ha which constitutes less than 1% of the total Spring Gully SFAZ. The impact of the Spring Gully SFAZ regime was assessed by Council and was determined to have no significant ecological impacts. Therefore, an alteration to the fire regime of less than 1% is unlikely to significantly alter biodiversity values beyond current conditions’.

9.0 Siting & adequacy of water (in relation to reticulation rates or where

dedicated water storage will be required)

Considering the proposed use for the subject development (eco-tourist resort), the

access, services and emergency planning provisions determined for bushfire safety

compliance is derived on the basis of the NSW Rural Fire Service Fast Fact 10/7

Version 3 March 2012 (Ecotourism).

With regard to the proposed development NSW Rural Fire Service Fast Fact 10/7

Version 3 March 2012 (Ecotourism) states, ‘Access, services, emergency and

evacuation planning for ecotourism developments must adhere to Special Fire

Protection Purpose Development requirements in accordance with Section 4.2.7 of

PBP 2006.’



The subject development site is not connected to any reticulated town water supply.

PBP ‘Performance Criteria’ for fire fighting water supply state that:

a water supply reserve dedicated to firefighting purposes is installed and

maintained. The supply of water can be an amalgam of minimum quantities for

each lot in the development and be reticulated within dedicated firefighting

lines,

PBP ‘Acceptable Solutions’ for fire fighting water supply state that:

10 000 litres is the minimum dedicated water supply required for firefighting

purposes for each occupied building, excluding drenching systems,

The provision for suitable connection for RFS and/or NSW Fire Brigades purposes

in section 4.1.3 in relation to water supplies is made available (see section 16.0

below for specific provisions).

The proposed development will incorporate a static water supply, which is able to

suitably address the requirements of PBP 2006.

This will consist of a series of 3 attached water tanks, located to the East of the sites

access driveway / turning bay. They will contain a minimum amalgam of

approximately 50 000 litres, meeting the minimal volume requirements (for up to 5

habitable buildings).

A good level of fire fighting equipment and infrastructure will also be installed on

site.

Each building (excluding the camp sites which will have portable extinguishers) will

be fitted with a fire hose reel, a fire fighting pump and portable extinguishers.

Stortz fittings will also be connected to all water tanks located within the

recommended APZ.



The proponent however, is planning to construct a new short access roadway, within

a limited central section of the private unmade road (Sussex Street) which is

approximately 20m in length and 6.5m wide - along the central Southern boundary.

This roadway will provide direct access to all critical parts of the development site

(including the water supplies, refuge building and caretaker’s accommodation).

The access roadway will be constructed and maintained to the ‘Performance Criteria’

of PBP 2006 Section 4.1.3 Access (1) Public Roads.

The remaining access roadway, through the Royal National Park, currently presents

as a well maintained sealed road, with cleared verge areas and constructed drainage.

It is currently approximately 4.0m – 5.5m wide .

It will be a recommendation of this report that a formal access provision is sought

from the NPWS. A formal access easement or ‘right of way’ must be established to

secure access to the development site (from both a practical and emergency

viewpoint). It will also be a recommendation that this access road must be

maintained to a high standard (i.e. equivalent to the provisions of PBP 2006 s4.1.3 –

Access: Public Roads).

This will include the need to provide a minimum width for this roadway of 6.5m – 8m

overall to satisfy the Acceptable Solutions of PBP 2006 s4.1.3 – dependent on

relevant Curve Radius / Swept Path (as per PBP 2006 s4.1.3 - Table 4.1 page 20).

The Traffic Engineering Report by McLaren Traffic Engineering, Sutherland

(Reference No. 15445.01FC - Preliminary Traffic Advice for Conciliation Discussions -

18th January 2016) provides confirmation of current and proposed road widths,

based on relevant swept paths, and notes the extent of the works required to the

current vegetation along the edges of the roadway, to facilitate these minimum

widths.

Subsequently, the Arboricultural Assessment, by Peter Richards - Tree and Landscape

Consultants, Padstow (dated 21 October 2015), has confirmed that the action

recommended by the said traffic engineering report ‘is not considered to be

detrimental to the health and condition of trees’ providing the recommendations of

the assessment are suitably implemented.

This was also confirmed within the Ecological Impact Assessment by Cumberland Ecology, Carlingford Court (February 2016) which, in part, states:



‘The ecological site assessment determined that vegetation to be trimmed along the shared access path does not constitute an EEC and is a community that is well represented within Royal National Park. The vegetation to be trimmed is located along the edge of an existing path and is currently subject to impacts such as edge effects.

The trimming of vegetation will not significantly alter the current habitat values of the vegetation for native flora and fauna and will not exacerbate any existing indirect impacts such as edge effects. Therefore, there will be no significant impacts to native vegetation communities, native flora or native fauna as a result of tree trimming within the shared access track.’

This access road will connect to the public road system to the NE of the

development. Beachcomber Avenue is a sealed, all weather urban road

approximately 9m in width within a 20m road reserve area. It provides direct access

through residential areas to the village of Bundeena.

All public roadway areas noted on approach to, and departure from, the subject

property are well formed and sealed two way public roadways (with cleared verge

areas, constructed drainage and ample room for passing or parked traffic) which also

service the surrounding residential area of Bundeena.

All public roadway areas (within the study area) servicing the subject development

site do not exceed 15 degrees’ slope.

All public roads servicing the subject property would currently and easily have the

capacity to handle an increase in traffic associated with a potential bushfire

emergency affecting the area. The above assuming that normal emergency services

and traffic supervision is being conducted during an emergency bushfire event.

It is noted that there is no practical ‘alternative access’ provisions / roads for this

development site. The development will primarily rely upon its emergency

procedures to ensure an ‘early evacuation’ of the site in case of a bushfire event,

with an onsite ‘refuge building’ providing a redundancy arrangement in need.

10.2 Internal roads

The proposed internal road system, servicing the subject development is limited in nature. It comprises of only a single short driveway, accessing the proposed refuge building, approximately 20m in length. As such, it will not fully comply with the ‘Acceptable Solutions’ within PBP 2006 s4.2.7 Access - Internal Roads, however, as a considered opinion, has been designed and will be constructed to specifically comply with the corresponding ‘Performance Criteria’.



The only Acceptable Solutions that this driveway would not comply with, are limited to:

The driveway is not proposed to be ‘sealed’

The driveway, being a dead end, does not incorporate a 12m radius ‘turning circle’

To ensure the ‘Performance Criteria’ are met, which is merely to ‘provide safe access for emergency services and allow crews to work with equipment about the vehicle’, a large ‘turning bay’ is proposed, which will also provide direct access to the proposed water tanks. The turning bay has been specifically designed by the consulting traffic engineers to support the loadings and movements of a Category 1 Tanker (fire appliance). The proposed internal road system will be designed to comply with all load ratings, widths, slopes and grades will be within complying tolerances. In addition, Council has requested that 4 car spaces are to be provided within the site, these have been located to the West of the turning bay and have direct access to the driveway and access road.

11.0 Public roads link to fire trails and have two-way access

The subject development site does not propose nor require any fire trail access to

service the subject development site.

12.0 Adequacy of access and egress for emergency response

The proposed overnight tent sites are located within 50m of the refuge building. The

refuge building is located within 20m of the modified roadway access point, and

within the APZ area, maintained as an IPA. PBP states (as the performance criteria

for Access – Internal Roads);

internal road widths and design enable safe access for emergency services and allow crews to work with equipment about the vehicle.

The IPA area, surrounding the refuge building, along with the new roadway (crossing

Sussex Street) and the associated turning bay (as described above) would reasonably

support the operational use of emergency firefighting vehicles. The connection point

to the static water supply will be located within this area.

Provided that the APZ areas and roadways are maintained as per the

recommendations stated by this report, it is a considered opinion that access or

egress for the subject development site would be adequate for the purposes of

bushfire safety compliance and emergency response.



13.0 Adequacy of maintenance plans and emergency procedures

13.1 Bushfire maintenance plan

Considering the extent of land within the subject development site that will require

ongoing management / maintenance to facilitate APZ compliance (as identified and

recommended by this report), it is recommended that a ‘simple’ landscape

vegetation and bushfire management (property maintenance) plan be prepared for

the subject development site. The plan should at least address;

A proposed schedule of landscape maintenance and activities which ensure the provisions of proposed fire / asset protection management zones, &

A proposed schedule of building maintenance and activities which ensure the correct installation or function of building design / materials incorporated for bushfire protection.

PBP Appendix 5 (Bushfire Provisions – Landscaping and Property Maintenance)

should be considered when preparing a bushfire maintenance plan for the subject

development site and surrounds.

It is noted that a bushfire maintenance plan as section Vegetation Management of

the Plan of Management, Bundeena Coast Eco Lodge, RVA Australia Pty Ltd

(February 2016) has been submitted as part of the supporting documentation for the

development application.

In addition, it is a recommendation of this assessment that an ‘Annual Audit’ process

is adopted to suitably certify compliance with the conditions of consent, related to

all bushfire protection measures.

This would require the owner / operator of the development to prepare an annual

compliance audit and submit a report on the said audit to the Council and RFS. The

audit and report must be conducted by a suitably qualified and experienced

independent bushfire consultant, and include management of the APZ / FRA in

accordance with the consent conditions, implementation and review of the

management protocols and the Bushfire Evacuation Plan, confirmation that the

associated utilities (power/gas/water supply) meet the consent requirements and

that the buildings and access roads are maintained in accordance with the bushfire

construction requirements and DA conditions.

Further, the development would not be used unless current certification was

available.



13.2 Fire emergency procedures

PBP acceptable solutions for emergency and evacuation planning requirements (relevant to the subject development) include;

An emergency/evacuation plan is prepared consistent with the RFS guidelines for the Preparation of Emergency/Evacuation Plan.

Compliance with Compliance with AS 3745-2010 ‘Planning for Emergencies in Facilities’.

An Emergency Planning Committee is established to consult with residents (and their families in the case of aged care accommodation and schools) and staff in developing and implementing an Emergency Procedure Manual.

Detailed plans of all Emergency Assembly Areas including “onsite” and “offsite” arrangements as stated in AS 3745- 2010 are clearly displayed, and an annual (as a minimum) trial emergency evacuation is conducted.

It is noted that a bushfire specific ‘Evacuation Plan’ has been developed. This plan has been submitted as part of this development application process. This plan is consistent with the RFS guidelines for the ‘Preparation of Emergency/Evacuation Plan’.

14.0 Construction standards to be used

It is a recommendation of this assessment that the proposed ‘Refuge Building’ will be

located in a complying APZ area (i.e. compliant with Table A2.4 PBP 2006) which

would support a refuge building constructed to withstand 29 kW/m2.

However, it is also a recommendation of this report that the ‘Refuge Building’ be

upgraded to comply with Section 9 - AS3959:2009 Bushfire Attack Level Flame Zone

(BAL FZ) as an added level of protection, and as the combined Caretaker’s

Accommodation / Office / Reception will now be located above the refuge, a fire

rated roof/floor element (FRL 60/60/60 – as per AS 1530.4) will separate the two

parts of the structure.

It is also a recommendation of this report that the ‘Caretakers Accommodation’ (now

located above the refuge) be constructed to comply with Section 9 - AS3959:2009

Bushfire Attack Level Flame Zone (BAL FZ). The caretaker’s accommodation is not to

be utilized as a refuge building.

Council had raised concerns related to the Outdoor Kitchen / Dining Tent in relation

to combustibility of tent material and LPG installations, given the location in relation

to the refuge building. The Kitchen facility has now been relocated, and is now

proposed to be remote from the refuge.



PBP 2006 and associated eco-tourism planning guidelines provide no specific

construction requirements for any buildings other than the refuge, as such the

kitchen tent has no specific bushfire construction requirements. However, this

structure is considered as minimal, in relation to construction elements. It is

effectively an open deck, with steel poles and insulated canvas coverings. The canvas

should be treated to ensure it has a low flammability index and fixtures and fitting

are minimal.

PBP 2006 does not exclude the use of domestic gas services (e.g. LPG cylinders) in

any scenario. PBP 2006 provides appropriate guidelines for the installation and

maintenance of gas cylinders, and as such the use of LPG within the site can be

supported, providing these specific guidelines are adhered to.

15.0 Adequacy of sprinkler systems

Sprinkler systems are neither recommended nor required for the subject

development site.

16.0 An assessment of how the development complies with the acceptable solutions, performance requirements and relevant specific objectives within Chapter 4 of PBP

16.1 Performance criteria / acceptable solution compliance

The following table outlines how the subject development complies (or otherwise)

with PBP provisions for a Special Fire Protection Purposes development. Compliance

is stated as;

YES – the subject development currently facilitates the acceptable solution for bushfire

safety,

REASONABLY ASSUMED – the subject development can reasonably facilitate the

acceptable solution for bushfire safety, predicated on assumptions of the existing and

future design, and activities that are recommended occur,

NOT APPLICABLE (N/A) – the acceptable solution is not applicable to the design or

construction of the subject development,

NOT CONSIDERED – the acceptable solution for bushfire safety is considered

unnecessary or otherwise overly exceeds the relative risk associated with a bushfire

event affecting the subject development. Bushfire safety compliance is based on

performance criteria,

NO – the subject development will not facilitate the acceptable solution for bushfire

safety compliance. Bushfire safety compliance is based on performance criteria or

alternate solution.



Table 4.0 Derived from PBP Chapter 4; 4.2.7 – Standards for Bush Fire Protection Measures for Special Fire Protection Purpose Development

Performance Criteria Acceptable Solution Compliance Assessment / Comment

radiant heat levels of greater than 10kW/m2 will not be experienced by occupants or emergency services workers entering or exiting a building

an APZ is provided in accordance with the relevant tables and figures in PBP

Yes

A defendable space is provided on site. The APZ aligns with Table A2.4 of PBP 2006 (Residential Subdivisions)

The APZ is aligned to the ‘Refuge Building’ entry point.

Travel paths and travel distances (i.e. <50m to a refuge) comply with the intent of PBP in relation to eco-tourism developments.

Recommendation No. 1 of this report.

exits are located away from the hazard side of the building

Yes

the APZ is wholly within the boundaries of the development site

Yes

applicants demonstrate that issues relating to slope are addressed: maintenance is practical, soil stability is not compromised and the potential for crown fires is negated

mechanisms are in place to provide for the maintenance of the APZ over the life of the development

Yes Recommendation No. 1 & 4 of this report. Limited areas of the IPA are located on slopes exceeding 18 degrees. Native groundcover vegetation will be retained/regenerated to stabilise soils and manual vegetation management techniques will be utilized to ensure maintenance is achievable.

the APZ is not located on lands with a slope exceeding 18 degrees

No

APZs are managed and maintained to prevent the spread of a fire towards the building

in accordance with the requirements of ‘Standards for Asset Protection Zones (RFS 2005)

(Note - a Monitoring and Fuel Management Program should be required as a condition of development consent)

Reasonably assumed

Recommendation No. 1 & 4 of this report.

vegetation is managed to prevent flame contact and reduce radiant heat to buildings, minimise the potential for wind driven embers to cause ignition and reduce the effect of smoke on residents and fire-fighters

Compliance with Appendix 5 (PBP) Reasonably assumed

Recommendation No. 1 & 4 of this report.

internal road widths and design enable safe access for emergency services and allow crews to work with equipment about the vehicle.

internal roads are two-wheel drive, sealed, all-weather roads

No

A short driveway, supported by a single turning bay will provide access that will allow firefighters to work around the vehicle. It is a recommendation of this

report that a formal access

provision is sought from the

NPWS . A formal access

easement or ‘right of way’ must

be established to secure access

to the development site (from

both a practical and emergency

viewpoint).

It will also be a recommendation

that this access road must be

maintained to a high standard

(i.e. equivalent to the provisions

of PBP 2006 s4.2.7 – Access:

internal perimeter roads are provided with at least two traffic lane widths (carriageway 8 metres minimum kerb to kerb) and shoulders on each side, allowing traffic to pass in opposite directions

Reasonably assumed

roads are through roads. Dead end roads are not more than 100 metres in length from a through road, incorporate a minimum 12 metres outer radius turning circle, and are clearly sign posted as a dead end

No

traffic management devices are constructed to facilitate access by emergency services vehicles.

Reasonably assumed




a minimum vertical clearance of four metres to any overhanging obstructions, including tree branches, is provided.

Reasonably assumed

Internal Roads).

It is noted that there is no

practical ‘alternative access’

provisions / roads for this

development site.

The development will primarily

rely upon its emergency

procedures to ensure an ‘early

evacuation’ of the site in case of

a bushfire event, with an onsite

‘refuge building’ providing a

redundancy arrangement in

need.

.

curves have a minimum inner radius of six metres and are minimal in number to allow for rapid access and egress

Reasonably assumed

the minimum distance between inner and outer curves is six metres

Reasonably assumed

maximum grades do not exceed 15 degrees and average grades are not more than 10 degrees

Reasonably assumed

cross-fall of the pavement is not more than 10 degrees

Reasonably assumed

roads do not traverse through a wetland or other land potentially subject to periodic inundation (other than flood or storm surge)

Reasonably assumed

roads are clearly sign-posted and bridges clearly indicate load ratings

Reasonably assumed

the internal road surfaces and bridges have a capacity to carry fully-loaded firefighting vehicles (15 tonnes)

Reasonably assumed

Non-reticulated water supply area.

A water supply reserve dedicated

to firefighting purposes is installed

and maintained. The supply of

water can be an amalgam of

minimum quantities for each lot in

the development and be

reticulated within dedicated

firefighting lines.

10 000 litres is the minimum dedicated water supply required for firefighting purposes for each occupied building, excluding drenching systems

Yes Recommendation No.2 of this report.

A static supply of 50 000 litres is proposed to be installed on site.

The provision for suitable connection for RFS and/or NSW Fire Brigades purposes in section 4.1.3 in relation to water supplies is made available

Reasonably assumed

the minimum dedicated water supply required for fire fighting purposes for each occupied building excluding drenching systems, is provided in accordance with PBP] Table 4.2

Reasonably assumed

a suitable connection for fire fighting purposes is made available and located within the IPA and away from the structure. A 65mm Storz outlet with a Gate or Ball valve is provided

Reasonably assumed

Gate or Ball valve and pipes are adequate for water flow and are metal rather than plastic

Reasonably assumed

underground tanks have an access hole of 200mm to allow tankers to refill direct from the tank. A hardened ground surface for truck access is supplied within 4 metres of the access hole

Reasonably assumed




above ground tanks are manufactured of concrete or metal and raised tanks have their stands protected. Plastic tanks are not used. Tanks on the hazard side of a building are provided with adequate shielding for the protection of fire fighters

Reasonably

assumed

all above ground water pipes external to the building are metal including and up to any taps. Pumps are shielded

Reasonably assumed

location of electricity services will not lead to ignition of surrounding bush land or the fabric of buildings or risk to life from damaged electrical infrastructure

Electrical transmission lines located underground; or

where overhead electrical transmission lines

are utilized, no part of a tree is closer to a

power line than the distance set out in

accordance with the specifications in

‘Vegetation Safety Clearances’ issued by

Energy Australia (NS179, April 2002).

Reasonably assumed


Any electrical transmission lines within the subject development, associated with its alternate power supply system, will be located underground.

location of gas services will not lead to ignition of surrounding bush land or the fabric of buildings

reticulated or bottled gas is installed and maintained in accordance with AS 1596 - 2002 and the requirements of relevant authorities. Metal piping is to be used.

Reasonably assumed

Gas cylinders are proposed to be located within the development.

These cylinders should be suitably shielded to prevent direct flame contact and radiant heat exposure.

all fixed LPG tanks are kept clear of all flammable materials and located on the non hazard side of the development

Reasonably assumed

If gas cylinders need to be kept close to the building, the release valves must be directed away from the building and away from any combustible material, so that they do not act as catalysts to combustion

Reasonably assumed

polymer sheathed flexible gas supply lines to gas meters adjacent to buildings are not to be used

Reasonably assumed

an Emergency and Evacuation Management Plan is approved by the relevant fire authority for the area

an emergency/evacuation plan is prepared consistent with the RFS guidelines for the Preparation of Emergency / Evacuation Plan

Reasonably assumed


compliance with AS 3745-2010 ‘Planning for Emergencies in Facilities’.

Reasonably assumed

compliance with AS 4083-1997 ‘Planning for emergencies - for health care facilities’

N/A

suitable management arrangements are established for consultation and implementation of the emergency and evacuation plan

an Emergency Planning Committee is established to consult with residents (and their families in the case of aged care accommodation and schools) and staff in developing and implementing an Emergency Procedures manual.

Reasonably assumed


detailed plans of all Emergency Assembly Areas including “onsite” and “offsite” arrangements as stated in AS 3745-2010 are clearly displayed, and an annual (as a minimum) trial emergency evacuation is conducted.

Reasonably assumed




In relation to eco-tourist accommodation: suitable refuge areas and evacuation / management arrangements are in place commensurate with the bush fire risk.

at least one building should be used as a local refuge area and comply with the APZ’s and construction requirements for residential buildings.

Yes Recommendation No. 5-7 of this report

A ‘Refuge’ building is recommended for this development.

The development and subsequent APZ areas are designed to facilitate safe egress directly to the refuge building and in need to the public road system.

Travel paths and travel distances comply with the intent of PBP in relation to eco-tourism developments.

cabins are within 50 metres of a refuge building and are clearly signposted.

Yes

the paths from cabins to the refuge area are safe, with management of surface fuels to ≤ 4 tonnes/ha.

Reasonably Assumed

the overall accommodation for tourists does not exceed 12 persons.

Reasonably Assumed

a mechanism for the relocation of occupants on days of a total fire ban or adverse fire activity is provided in the local area in which the development operates.

Reasonably Assumed

16.2 PBP 2006 specific objective assessment Table 16.2

PBP 2006 Specific Objective Assessment / Comment

(i) afford occupants of any building adequate protection from exposure to a bush fire

Where the recommendations stated by this report are reasonably and adequately incorporated (where practicable), staff and occupants within the subject development site during a significant bushfire event would be afforded the benefit bushfire protection ‘measures in combination’.

(ii) provide for a defendable space to be located around buildings

Where the recommendation relating to APZ management as stated by this report is reasonably and adequately incorporated (i.e. continued property and vegetation maintenance), building structures located within close proximity to the primary bushfire hazard would be afforded a level of defendable space. This requirement is satisfied by a recommended APZ area maintained as an IPA and travel exit paths maintained at 4t/ha close to the eco-tourism cabins.

(iii) provide appropriate separation between a hazard and buildings which, in combination with other measures, prevent direct flame contact and material ignition

The proposed development is for an eco-tourism resort. PBP gives dispensations for this type of development. APZ areas do not need to comply on each building within the development.

PBP provides an option for a single complying ‘Refuge’ building (with complying APZ arrangements) or safe egress arrangements within <50m of the development.

A large APZ has been recommended to facilitate a safe transition between the cabins and the refuge and then the public roads.

However, where the recommendations relating to construction standards & APZ area stated by this report are reasonably and adequately incorporated, the proposed building structures will be given a certain level of protection.



(iv) ensure that safe operational access and egress for emergency service personnel and residents is available

Where the recommendations relating to APZ areas as stated by this report are reasonably and adequately incorporated, both emergency services personnel and occupants should be afforded safe access / egress within the subject development site for firefighting or evacuation purposes.

(v) provide for ongoing management and maintenance of bush fire protection measures, including fuel loads in the asset protection zone (APZ)

Where the recommendations relating to construction standards and APZ area stated by this report are reasonably and adequately incorporated, it would be reasonable to assume that regular maintenance works within the subject development would ensure ongoing management and maintenance of bush fire protection measures.

Should the standard or upkeep of APZ areas, vegetation maintenance or vehicle access (required for bushfire safety compliance) become compromised during the life of the subject development site, it would also be reasonable to assume such matters would be addressed by the Council or local Fire Authorities through their standard policies and processes.

(vi) ensure that utility services are adequate to meet the needs of firefighters (and others assisting in bush fire fighting)

Where the recommendations stated by this report are reasonably and adequately incorporated, the potential water supply facilities servicing the subject development site should be adequate for the purposes of bushfire safety compliance.

Similarly, where the installation or connection to electrical and gas services incorporates the recommendations as stated by this report, both emergency services personnel or occupants assisting in bush fire fighting should safely be able to manage potential electrical and gas hazards associated during a bushfire event.

(vii) provide for the special characteristics and needs of occupants [SFPP Development]

Where all recommendations relating to emergency evacuation procedures (planning) as stated by this report are reasonably and adequately incorporated, staff and occupants located within the subject development site during or preceding a bushfire event should be reasonably aware of safe access / egress options and associated actives to be undertaken.

(viii) provide for safe emergency evacuation procedures [SFPP Development]

As above.

17.0 Bushfire Safety & Compliance Recommendations

The following recommendations (Table 17.1) are proposed for bushfire safety &

protection for the proposed Eco-tourism development, ‘Bundeena Coast Eco Lodge’

at 60 – 70 Bournemouth Street Bundeena.

These recommendations are based upon the relevant provisions (acceptable

solutions or performance criteria) for a Special Fire Protection Purpose development

in a bushfire prone area and the NSW Rural Fire Service guideline entitled Planning

for Bushfire Protection 2006 (with special consideration to relevant sections

regarding ‘Eco-Tourist Resorts’).



Table 17.1 – Bushfire Safety / Compliance Recommendations

No. PBP Standard Recommendation

1 Asset Protection Zone

Inner Protection Area

The area indicated (within Appendix 1 - Map 2) is to be maintained as an Asset Protection Zone (Inner Protection Area) for the life of the development.

The above recommendation should ensure that no easily combustible material, structures, available forest fuel/bushfire vegetation or other items be installed, stored or allowed to re-accumulate and become contiguous within the area. The IPA extent should not support or carry a running bushfire towards the subject development site and associated infrastructure. The area identified as Inner Protection Area (IPA) should be managed in terms of PBP A2.2 (vi) which states: The IPA is critical to providing a defendable space and managing heat intensities at the building surface. The IPA should provide a tree canopy cover of less than 15% and should be located greater than 2 m from any part of the roofline of a dwelling. Garden beds of flammable shrubs are not to be located under trees and should be no closer than 10 m from an exposed window or door. Trees should have lower limbs removed up to a height of 2 m above the ground.

Fuel Reduced Area The area indicated (within Appendix 1 - Map 2) is to be maintained as a Fuel Reduced Area (FRA) for the life of the development.

The area identified as an FRA should be regularly maintained through manual means, to ensure that the natural buildup of dead leaves and branches is restricted. Any exotic vegetation should be removed.

This is to ensure that the fuel loadings are maintained at an overall fuel Hazard of ‘High’ or below (as per the Overall Fuel Hazard Guide - Department of Sustainability and Environment 3rd Edition 1999) which is in line with specific SFAZ parameters utilised by the NPWS.

2 Annual Audit The owner / operator of the development is to facilitate/prepare

an annual compliance audit and submit a report on the said audit

to the Council and RFS.

The audit and report must be conducted by a suitably qualified and

experienced independent bushfire consultant, and include

management of the APZ / FRA in accordance with the consent

conditions, implementation and review of the management

protocols and the Bushfire Evacuation Plan, confirmation that the

associated utilities (power/gas/water supply) meet the consent

requirements and that the buildings and access roads are

maintained in accordance with the bushfire construction

requirements and DA conditions.




3 Fire Fighting Water

(Non-reticulated

Supply)

Minimum supplementary static water supply of 50 000L

a suitable connection for firefighting purposes is made available and located within the IPA and away from the structure. A 65mm Storz outlet with a gate or Ball valve is provided.

gate or ball valve and pipes are adequate for water flow and are metal rather than plastic.

any underground tanks have an access hole of 200mm to allow tankers to refill direct from the tank. A hardened ground surface for truck access is supplied within 4 metres of the access hole.

any above ground tanks are manufactured of concrete or metal and raised tanks have their stands protected. Plastic tanks are not used. Tanks on the hazard side of a building are provided with adequate shielding for the protection of fire fighters.

all above ground water pipes external to the building are metal including and up to any taps.

The subject development should maintain 4 portable powered pumps (preferably diesel powered) >3kW (5hp) with compatible fire fighting hoses and fittings for water storage tank/supply. Pumps are to be suitably shielded from radiant heat.

Fire fighting hoses should be of a length (e.g. 30m – 50m) so as to reach all areas immediately surrounding the subject development site/APZ area.

4 Building Construction

Standards

The proposed ‘Refuge Building’ will comply with the construction techniques and materials required by the Australian Standard: AS: 3959-2009 Construction of buildings in bushfire prone areas.

With regard to relevant construction levels as follows:

BAL FZ Construction on all building elevations

Additionally, as the ‘Caretakers Accommodation will now be located above the refuge, a fire rated roof/floor element (FRL 60/60/60 – as per AS 1530.4) will be required to separate the two parts of the structure.

The fabric used within the proposed camping structures (i.e. all tents) should have a ‘Flammability Index’ of no more than 6 (AS1530.2).

The proposed ‘Caretakers Accommodation’ will comply with the construction techniques and materials required by the Australian Standard: AS: 3959-2009 Construction of buildings in bushfire prone areas.

With regard to relevant construction levels as follows:

BAL FZ Construction on all building elevations




5 Maintenance plans and

emergency procedures

Emergency /

Evacuation Plan

Bushfire

Maintenance

(Landscaping &

Building)

A Bushfire Emergency and Evacuation Procedures Plan be

developed (in accordance with AS3745 & RFS guidelines for the

Preparation of Emergency/Evacuation Plan as applicable) by a

competent & recognised provider (in consultation with the local

fire authorities) for the subject development site which, at least,

clearly identifies;

Roles & responsibilities of on-site staff

Protocols for safety briefings (bushfire emergency ‘house keeping’ rules)

Safe assembly areas & site plans (including clear signage located throughout the subject development)

Evacuation ‘triggers’ and notification

Transportation & evacuation routes

Traffic management & supervision (egress to Beachcomber Avenue with further direction to safe egress paths)

Designated assembly points

Means to account for all persons within the site

Who to contact in the invent of a fire (including local contacts)

Security after evacuation

Safety, welfare and emergency accommodation for occupants potentially evacuated and restricted from returning to the subject development site

Return to site procedures and conditions after the passing of a bushfire event

Site rehabilitation (e.g. damaged power infrastructure, damaged LPG cylinders potentially exposed to radiant heat, damaged trees etc.).

In addition, a ‘satellite phone’ should be utilised on site that could assist in covering any shortfall in mobile communications coverage due to natural deficiencies or emergency situations.

A landscape vegetation and bushfire management (property maintenance) plan is prepared for the subject development site. This should be in line with industry standards and RFS requirements.

6 Gas As applicable, any future gas supply connections should be designed & located in accordance with PBP.

Gas should be installed and maintained in accordance with AS1596 - 2002 and the requirements of relevant authorities.

Metal piping is to be used.




Fixed LPG tanks should be kept clear of all flammable materials and preferably located on the non hazard side of the residential building and/or suitably shielded with non combustible materials.

If gas cylinders need to be kept close to the building, the release valves must be directed away from the building and away from any combustible material, so that they do not act as catalysts to combustion.

7 Electrical Connection As applicable, all proposed electrical supply connections associated with the alternate power supply system proposed for the development, should be designed & located in accordance with PBP i.e. any new or re-located power line connections to service the subject development site should be located underground.

8 Access Roads

It is a recommendation that a formal access provision is sought to use the existing access road from the NPWS . A formal access easement or ‘right of way’ must be established to secure access to the development site. The access road must be maintained to achieve compliance with the access provisions of PBP 2006 s4.1.3 – Access: Public Roads. It is noted that there is no practical ‘alternative access’ provisions / roads for this development site. The development will primarily rely upon its emergency procedures to ensure an ‘early evacuation’ of the site in case of a bushfire event, with an onsite ‘refuge building’ providing a redundancy arrangement in need. Internal roads are to comply with the ‘Acceptable Solutions’ and/or the ‘Performance Criteria’ of PBP 2006 s4.2.7 – Access Internal Roads.

18.0 Conclusion

Based on the above assessment and undertaking of recommendations as stated by

this report, the proposed development can reasonably comply with the relevant

requirements of PBP (alternate solutions, acceptable solutions or performance

criteria).

Bushfire safety compliance and mitigation, as purported by this report, for the

subject development site comprises a package of ‘measures in combination’

primarily including asset protection zoning, upgraded construction standards, non-

reticulated water supply, emergency management procedures and bushfire

maintenance planning.



19.0 References

Australian Standard 1596:2002, The storage and handling of LP Gas.

Australian Standard 2419:2005, Fire hydrant installations - System design, installation and commissioning.

Australian Standard 3959:2009 Construction of buildings in bushfire-prone areas.

Planning for Bushfire Protection. A guide for councils, planners, fire authorities & developers (2006) – NSW Rural Fire Service.

Addendum: Appendix 2 - Planning for Bushfire Protection. A guide for councils, planners, fire authorities and developers (2010) – NSW Rural Fire Service.

NSW Rural Fire Service Fast Fact 10/07 Version 3 March 2012 (Ecotourism)

Overall Fuel Hazard Guide - Department of Sustainability and Environment 3rd Edition 1999



Sheet 1 – Overview Subject Site and Current Vegetation Management Areas



Sheet 2 – Overview Subject Site and Proposed Vegetation Management Areas



Sheet 3 – Development Envelopes, IPA, Access Roads



Sheet 4 – Development Envelopes and IPA



Appendix 2 – Site Photos (4/9/2014)

NPWS Car Park at entrance to RNP

Entrance to RNP, off end of Beachcomber Avenue

Beachcomber Avenue, looking North West

NPWS / RNP Entrance Road, looking South East, from entrance

NPWS / RNP Entrance Road, looking North, from midpoint

Start / entrance to the ‘Coast Track’



Large cleared area within RNP, looking South from subject site

Large cleared area within RNP, looking West

Sandstone Woodland vegetation on upper slopes within subject site

Transitional Sandstone Forest vegetation on lower slopes

Sandstone Forest vegetation on lower slopes, looking South upslope

Looking North West towards Wetlands within Bundeena Creek catchment

bushfire assessment and recommendations · 2017-05-31 · under section 100b of the rural fires act...

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