B172905 - No. 105 Cudgegong Road, Rouse Hill · BUSHFIRE PROTECTION ASSESSMENT FOR THE PROPOSED...

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BUSHFIRE PROTECTION ASSESSMENT FOR THE PROPOSED RESIDENTIAL FLAT COMPLEX ON LOT 80 in DP 208203, No. 105 CUDGEGONG ROAD, ROUSE HILL Australian Bushfire Protection Planners Pty Limited Bushfire Mitigation Consultants ACN 083 085 474 32 Old Dog Trap Road SOMERSBY 2250 NSW Phone: (02) 43622112 Fax: (02) 43622204 Email: [email protected]

Transcript of B172905 - No. 105 Cudgegong Road, Rouse Hill · BUSHFIRE PROTECTION ASSESSMENT FOR THE PROPOSED...

Page 1: B172905 - No. 105 Cudgegong Road, Rouse Hill · BUSHFIRE PROTECTION ASSESSMENT FOR THE PROPOSED RESIDENTIAL FLAT COMPLEX ON LOT 80 in DP 208203, No. 105 CUDGEGONG ROAD, ROUSE HILL

BUSHFIRE PROTECTION ASSESSMENT FOR THE PROPOSED RESIDENTIAL FLAT COMPLEX ON LOT 80 in DP 208203, No. 105 CUDGEGONG ROAD, ROUSE HILL

Australian Bushfire Protection Planners Pty Limited

Bushfire Mitigation Consultants ACN 083 085 474 32 Old Dog Trap Road SOMERSBY 2250 NSW Phone: (02) 43622112 Fax: (02) 43622204 Email: [email protected]

Page 2: B172905 - No. 105 Cudgegong Road, Rouse Hill · BUSHFIRE PROTECTION ASSESSMENT FOR THE PROPOSED RESIDENTIAL FLAT COMPLEX ON LOT 80 in DP 208203, No. 105 CUDGEGONG ROAD, ROUSE HILL

_______________________________________________________________________ © Australian Bushfire Protection Planners Pty Limited

Tel. 612 43622112 / 612 43621184 Email. [email protected]

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BUSHFIRE PROTECTION ASSESSMENT

FOR THE

PROPOSED RESIDENTIAL FLAT COMPLEX

ON

LOT 80 in DP 208203,

No. 105

CUDGEGONG ROAD,

ROUSE HILL

Report Document Preparation Issue Directors Approval Number Date Date B172905 Final 25.05.2017 26.05.2017 G.L.Swain

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EXECUTIVE SUMMARY Australian Bushfire Protection Planners Pty Limited has been commissioned by Weyand Pty Ltd to prepare a Bushfire Protection Assessment for a Development Application to Blacktown City Council for the proposed Residential Flat Complex on Lot 80 in DP 208203, No. 105 Cudgegong Road, Rouse Hill. The development site is zoned R3 Medium Density Residential Development and forms part of the Cudgegong Road Structure Plan, part of the North West Growth Centre and is located on the south-western side of Cudgegong Road and contains existing rural residential development including a dwelling which will be demolished as part of the subdivision work. The development site is adjoined to the northwest, southwest and southeast by R3 Medium Density Residential zoned land that contains existing rural residential development. The land to the northeast of the development, beyond Cudgegong Road, is also zoned R3 Medium Density Residential and has been approved for the construction of a multi storey medium density residential development. The Blacktown Bushfire Prone Land Map records that the development site and the adjoining land contains Category 1 Bushfire Prone Vegetation. As the development site is shown to contain bushfire prone vegetation the development, being the construction of a multi-unit medium density residential flat building within a bushfire prone area, is required to comply with the provisions of Section 79BA of the Environmental Planning & Assessment Act 1979. In addition, the building will be subdivided into Strata Title Units once completed and for the purpose of this report is deemed to be Integrated Development as defined by Section 91 of the Environmental Planning & Assessment Act 1979. The provisions of Section 100B of the Rural Fires Act 1997 apply to Integrated Development and the development is required to comply with the deemed-to-satisfy provisions of Planning for Bushfire Protection 2006. This report therefore examines the proposed development against these requirements and provides advice on the suitability of the development in addressing the availability of complying Asset Protection Zones/Defendable Spaces, access and water supplies for fire-fighting operations and the requisite level of construction to the building in order to address the potential levels of radiant heat exposure on the building.

Graham Swain Managing Director Australian Bushfire Protection Planners Pty Limited

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................ 3  TABLE OF CONTENTS .................................................................................................. 4  SECTION 1 ...................................................................................................................... 5 

INTRODUCTION .......................................................................................................................5 1.1  Aim of this Assessment. ....................................................................................................5 1.2  Development Proposal. .....................................................................................................5 1.3   Statutory Requirements. .................................................................................................10 1.3.1   Legislation. .................................................................................................................10 1.3.2   Planning Policies. .......................................................................................................11 1.4  Documentation reviewed in this Assessment. ................................................................12 1.5   Site Inspection. ................................................................................................................12 

SECTION 2 .................................................................................................................... 13 DESCRIPTION OF DEVELOPMENT SITE ............................................................................13 2.1  Location & Description. ...................................................................................................13 2.2  Adjoining Land Use. ........................................................................................................14 2.3  Topography. ....................................................................................................................14 2.4  Vegetation. .....................................................................................................................15 2.4.1   Vegetation within the Development Site. ...................................................................16 2.4.2   Vegetation within 140 metres of the Development Site. ............................................16 2.5  Site Photographs. ............................................................................................................17 2.6   Significant Environmental Features within the Development Site. .................................18 2.7   Known Threatened Species, population or ecological community within the

Development Site. ...........................................................................................................18 2.8   Details and location of Aboriginal relics or Aboriginal place. ..........................................19 

SECTION 3 .................................................................................................................... 20 PRECINCT LEVEL ASSESSMENT ........................................................................................20 3.1   Introduction. .....................................................................................................................20 

SECTION 4 .................................................................................................................... 21 BUSH FIRE PROTECTION ASSESSMENT ...........................................................................21 4.1  Introduction. .....................................................................................................................21 4.2   Determination of Asset Protection Zones – Proposed Medium Density Residential Flat

Building. ...........................................................................................................................22 4.3  Assessment of Bushfire Attack (Construction Standards). .............................................23 4.4  Access Standards for Firefighting Operations. ...............................................................25 4.4.1   Adequacy of Public Roads. ........................................................................................25 4.4.2   Fire Trail Access to two-way Public Roads. ...............................................................25 4.4.3   Emergency Response Access / Egress. ....................................................................25 4.5  Water Supplies for Firefighting Operations. ....................................................................25 4.6  Emergency Management for Fire Protection. .................................................................25 4.7   Adequacy of Sprinkler Systems & other Fire Protection Measures. ...............................25 4.8   Evacuation. ......................................................................................................................25 

SECTION 5 .................................................................................................................... 26 BUSHFIRE MANAGEMENT STRATEGIES ...........................................................................26 Strategy 1 – Water Supplies for Firefighting Operations: ........................................................26 Strategy 2 – Bushfire Construction Standards to the proposed Building: ...............................26 Strategy 3 – Public Roads: ......................................................................................................26 

SECTION 6 .................................................................................................................... 27 CONCLUSION .........................................................................................................................27 

REFERENCES: ............................................................................................................. 28 

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SECTION 1 INTRODUCTION

1.1 Aim of this Assessment. The aim of this Bushfire Protection Assessment is to review the proposed Development Application to determine compliance with the intent of Planning for Bushfire Protection 2006 and in particular: • Determine the formation of the vegetation on and adjoining the development

site; • Undertake an assessment to determine the effective slope of the land which

will cause the most insignificant fire behaviour on the facility; • Determine the Fire Danger Index [FDI] for the site; • Undertake an assessment to determine the adequacy of the bushfire

protection measures, including the following matters:

(i) The provision of setbacks from vegetated areas; (ii) Fire fighting water supplies; (iii) Access requirements for emergency service vehicles; (iv) Land management responsibilities; and (v) Evacuation management.

1.2 Development Proposal. A Development Application is to be lodged with Blacktown Council for the construction of a proposed multi-storey medium density Residential Flat complex on the R3 – Medium Density Residential zoned portion of Lot 80 in DP 208203, No. 105 Cudgegong Road, Rouse Hill. The complex consists of four [4] multi storey residential buildings containing a total of 201 units located to the southwest of the existing Transmission Easement. The land located to the northeast of the Transmission Easement forms a residual lot that is zoned RE1 – Park, under the Blacktown Local Environment Plan. The Blacktown Development Control Plan identifies that access to the buildings is from a new road located adjacent to the north-western boundary of the development site - refer to Figure 1 – Land Zoning Map on Page 6; Figure 2 – DCP on Page 6 & Figure 3 – Site Plan of the proposed development on Page 7. Figures 4 & 5 on Pages 8 & 9 provide a copy of the Ground Floor Plans.

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Figure 1 – Blacktown Land Zoning Map

Figure 2 – Blacktown DCP

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Figure 3 – Site Plan of the proposed Medium Density Flat Complex.

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Figure 4 – Ground Floor Plan – Lot A of the proposed Medium Density Flat Complex.

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Figure 5 – Ground Floor Plan – Lot B of the proposed Medium Density Flat Complex.

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1.3 Statutory Requirements. This report has been prepared having regard to the following legislative and planning requirements: 1.3.1 Legislation. (a) Environmental Planning and Assessment Act (EPA Act) Planning and development within NSW is regulated by the Environmental Planning & Assessment Act, 1979 (EPA Act). This Act was amended in August 2002 by the Rural Fires & Environmental Assessment Legislation Amendment Act, 2002. In relation to bushfire planning for new residential, rural residential and special fire protection developments in bushfire prone areas in NSW, the following sections of the Act apply: (i) Section 79BA: Section 79BA requires a consent authority to determine if a proposed development that is located within a designated Bushfire Prone Area, or the buffer zone to the Bushfire Prone Land, complies with Planning for Bushfire Protection 2006. (ii) Section 79C(1) states: “In determining a development application, a consent authority is to take into consideration such of the following matters as are of relevance to the development the subject of the development application:

The likely impacts of the development (e.g. natural hazards such as bushfire threat);

The suitability of a site for development (e.g. bushfires)

(ii) Section 91(1):

Defines the subdivision of bushfire prone land, for residential rural; residential subdivision and the construction of special protection purpose development, as integrated development which requires authorization under Section 100B of the Rural Fires Act 1997.

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(b) Rural Fires Act 1997 The objectives of the Rural Fires Act are to provide: • The prevention, mitigation and suppression of fires; • Coordination of bushfire fighting and prevention • Protection of people and property from fires; and • Protection of the environment.

In relation to bushfire planning for residential and rural residential subdivision and special fire protection purpose developments in bushfire prone areas in NSW, Section 100B of the Act applies. Section 100B provides for the issue, by the Commissioner of the NSW Rural Fire Service, of a Bushfire Safety Authority for development which creates the subdivision of bushfire prone land for residential and rural residential development and construction of special fire protection purpose developments located within a Bushfire Prone Area. An application for a Bushfire Safety Authority must be lodged as part of the development application process and must demonstrate compliance with Planning for Bushfire Protection 2006 and other matters which are considered necessary, by the Commissioner, to protect persons, property and the environment from the impact of bushfire. In relation to the management of bushfire fuels on public and private lands within NSW, Sections 63(1) and 63(2) require public authorities and owners / occupiers of land to take all practicable steps to prevent the occurrence of bushfires on, and to minimize the danger of, the spread of bushfires. (c) Rural Fires Regulation 2013. Section 44 of the Rural Fires Regulation 2013 relates to planning for new residential, rural residential and special fire protection purpose developments in bushfire prone areas in NSW and provides details of the matters that are required to be addressed for the issue of a Bushfire Safety Authority under Section 100B of the Rural Fires Act. 1.3.2 Planning Policies. Planning for Bushfire Protection – 2006 (Rural Fire Service). This document provides guidance on the planning and development control processes in relation to bushfire protection measures for development in bushfire prone areas.

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In addition to the provisions of the Planning for Bushfire Protection 2006 document, the Commissioner may determine, under Section 100B of the Rural Fires Act, additional measures for rural residential and residential subdivisions and ‘Special Fire Protection Purpose’ development that are considered necessary to protect the development against the impact of bushfire. 1.4 Documentation reviewed in this Assessment. The following documents were reviewed in the preparation of this report: • Architectural Plans and Elevations of the proposed medium density residential

flat building prepared by Dreamscape Architects; • Aerial Photograph of the development site and adjoining land; • Planning for Bushfire Protection 2006 prepared by the NSW Rural Fire

Service; • Australian Standard AS3959 – 2009 - “Construction of Buildings in Bushfire

Prone Areas”; • Rural Fires Act 1997; • Rural Fires Regulation 2013; • Blacktown Council Certified Bushfire Prone Land Map; • Blacktown LEP; • Cudgegong Road Structure Plan. 1.5 Site Inspection. Graham Swain of Australian Bushfire Protection Planners Pty Limited inspected the site on the 28th April 2017 to assess the topography, slopes and vegetation classification within and adjoining the development site. The inspection also examined the management of the vegetation on the adjoining properties to determine the actual extent of any vegetation within 100 metres of the development site which could lawfully be mapped as being bushfire prone vegetation.

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SECTION 2 DESCRIPTION OF DEVELOPMENT SITE

2.1 Location & Description. The land within the development site consists of Lot 80 in DP 208203, No. 105 Cudgegong Road, Rouse Hill. The development site is rectangular in shape and is located to the southwest of Cudgegong Road, one lot to the southeast of Macquarie Road. Figure 6 – Location of the development site.

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Figure 7 – Aerial Photograph showing location of Development Site.

2.2 Adjoining Land Use. The landuse to the northwest of the development site is zoned R3 and contains an existing dwelling on rural residential land. The land to the northeast of the development site, beyond Cudgegong Road, contains a Sporting Field and R3 zoned land which has an approval for the construction of a medium density residential unit complex. The land to the southeast and southwest of the development site contains existing rural residential development and is zoned R3. [Refer to Figure 7 – Aerial Photograph above]. 2.3 Topography. Appendix 2 of Planning for Bushfire Protection 2006 states that slopes should be assessed, over a distance of at least 100m from a development site and that the gradient of the land should be determined which will most significantly influence the fire behaviour to the site. a) Within the Development Site. The land within the development site is level in a northeast/southwest direction and slopes to the southeast at less than 5 degrees.

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b) Within 100 metres of the Development Site. The land to the northwest of the development site rises at less than 5 degrees to the northwest. The land to the southwest falls to the southwest at less than 5 degrees and the land to the northeast of the development site, beyond Cudgegong Road, falls to the east at less than 5 degrees. The land to the southeast of the development site is level. Figure 8 – Topographic Map

2.4 Vegetation. Appendix A2.3 of Planning for Bushfire Protection 2006 provides a methodology for determining the predominant bushfire prone vegetation for at least 140 metres in all directions from the future development on the site. Vegetation is classified using Table A2.1 of Planning for Bushfire Protection 2006, which classifies vegetation types into the following groups: (a) Forests [wet & dry sclerophyll forests]; (b) Woodlands; (c) Plantations – being pine plantations not native plantations; (d) Forested Wetlands; (e) Tall Heaths; (f) Freshwater Heaths;

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(g) Short Heaths; (h) Alpine Complex; (i) Semi – arid Woodlands; (j) Arid Woodlands; and (k) Rainforests. 2.4.1 Vegetation within the Development Site. The development site contains scattered shade trees and managed grass. This vegetation has been mapped in the Cudgegong Road Structure Plan [2013] identifies this vegetation community as Shale Plains Woodland. 2.4.2 Vegetation within 140 metres of the Development Site. The surrounding land contains similar vegetation as found on the development site with the Cudgegong Road Structure Plan [2013] recording the vegetation community as Shale Plains Woodland – refer to Figure 9 - Cudgegong Road Structure Plan [2013] Vegetation Map, below Figure 9 - Cudgegong Road Structure Plan [2013] Vegetation Map.

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2.5 Site Photographs.

Site Photograph No. 1 – Taken from Macquarie Road looking across the managed vegetation on the land to the northwest of the development site

Site Photograph No. 2 – Taken from Cudgegong Road looking across the managed vegetation on the development site and land to the southeast.

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Site Photograph No. 3 – Taken from Cudgegong Road looking across the land, to the northeast of the development site, which is approved for medium density residential development. 2.6 Significant Environmental Features within the Development Site. The land within the development site does not contain significant environmental features such as SEPP 14 Wetlands, SEPP 44 Koala Habitat, SEPP 26 Littoral Rainforests; land slip areas or National Parks Estate; areas of geological interest; steep lands [>18 degrees] or riparian corridors. 2.7 Known Threatened Species, population or ecological community

within the Development Site. Cudgegong Road Structure Plan [2013] identifies that the development site and adjoining properties contain Shale Plains Woodland which, along with Shale Hills Woodland, makes up the Cumberland Plain Woodland vegetation community with the Shale Plains Woodland being the common of the two forms. It is listed as a critically endangered ecological community under the NSW Threatened Species Conservation Act 1995.

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Figure 10 - Cudgegong Road Structure Plan [2013] – Combined Constraints Plan.

Whilst the Cudgegong Road Structure Plan [2013] identifies that the development site and adjoining properties contain Shale Plains Woodland it is noted that the ‘Zoning Controls’ plan in the document identifies the development site as being rezoned to support R2 – Low Density Residential Development with the land tot e southwest remaining as RU4 – Rural Small Holdings. The Blacktown LEP zones the land surrounding the development site as R3 – Medium Density Residential Development. 2.8 Details and location of Aboriginal relics or Aboriginal place. There are no known sites of Aboriginal heritage significance within the development site.

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SECTION 3 PRECINCT LEVEL ASSESSMENT

3.1 Introduction. The Blacktown Council Bushfire Prone Land Map records that the development site contains Category 1 Bushfire Prone Vegetation. Figure 11 below is an extract from the Bushfire Prone Land Map showing the Category 1 Bushfire Prone Vegetation and Buffer Zone. Figure 11 – Extract of the Blacktown Bushfire Prone Land Map.

Legend: Red Hatch – Category 1 Bushfire Prone Vegetation; Yellow Hatch – Buffer Zone Red – 100m wide Buffer Zone to the Category 1 Bushfire Prone Vegetation The inspection of the development site and adjoining lands confirmed that the mapped Category 1 Bushfire Prone Vegetation on the development site and adjoining land consists of a tree canopy with managed understorey. This vegetation is therefore incorrectly mapped as bushfire prone vegetation.

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SECTION 4 BUSH FIRE PROTECTION ASSESSMENT

4.1 Introduction. Section 44 of the Rural Fires Regulation 2013 requires that an application for a Bushfire Safety Authority must include a bushfire assessment for the proposed development (including the methodology used in the assessment) that addresses the extent to which the development provides: • asset protection zones;

• the siting and adequacy of water supplies for firefighting operations; • capacity of public roads to handle increased volumes of traffic during a

bushfire emergency; • whether or not public roads link with the fire trail network and have two way

access; • the adequacy of access and egress for the purposes of emergency response; • the adequacy of bushfire maintenance plans and fire emergency procedures

and; • the construction standards to be used for building elements. Planning for Bushfire Protection 2006 provides a methodology to determine the Asset Protection Zones and Bushfire Attack / Construction Standards required for habitable buildings in development for residential purposes that are designated as bushfire prone. Sections 4.2 and 4.3 of this report use the methodology provided by Planning for Bushfire Protection 2006 to determine the Asset Protection Zones and construction standards required for the proposed medium density units. The remaining items identified by Section 44 of the Rural Fires Regulation 2013 are examined in Sections 4.4 – 4.8 of this report.

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4.2 Determination of Asset Protection Zones – Proposed Medium Density Residential Flat Building.

Appendix 2 of Planning for Bushfire Protection 2006 provides the following procedure for determining setback distances (Asset Protection Zones): (a) Determine vegetation formations as follows:

• Identify all vegetation in all directions from the site for a distance of 140 metres;

• Consult Table A2.1 to determine the predominant vegetation type; and

• Select the predominant vegetation formation as described in Table A2.1.

(b) Determine the effective slope of the land under the predominant

vegetation Class. (c) Determine the appropriate fire [weather] area in Table A2.2. (d) Consult Table A2.4 and determine the appropriate setback [Asset

Protection Zone] for the assessed land use, vegetation formation and slope range.

Table 1 provides a summary of this assessment and the resultant widths of the Asset Protection Zones for the construction of proposed medium density residential flat complex on the site. Table 1. Determination of Asset Protection Zones – Residential

Development. Fire Danger Index [FDI] for the site is 100

Aspect Vegetation within 140m of

development

Predominant Vegetation

Formation Class [Table A2.1 Planning for

Bushfire Protection 2006]

Effective Slope of

Land

Recommended width of Asset

Protection Zone [from Table A2.4 of Planning for

Bushfire Protection 2006

Compliance with Specifications of

Table A2.4 Planning for Bushfire

Protection 2006

All

aspects to the

proposed buildings

Managed Shale

Plains Woodland

Nil – vegetation

managed

N.A.

None required as the site is adjoined by managed vegetation

Yes – The proposed residential flat

complex is located more than 110 metres from unmanaged

Bushfire Prone Vegetation

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Assessment Results: The Development Application seeks approval to erect a medium density residential flat complex on an existing lot which forms part of the Cudgegong Road Structure Plan in the North West Growth Centre. The land is zoned R3 – Medium Density Residential with the same landuse zoning on adjoining properties to the northwest, northeast, southeast and southwest. It is therefore assumed that, for the purpose of determining Asset Protection Zones, the using land management techniques [slashing/grazing of the understorey grasses] will remain until development commences. The Blacktown LEP identifies that the residual land created in the subdivision of the development site, to the northeast of the Transmission Line Easement is zoned RE1 – Public Recreation and will therefore remain managed in perpetuity. 4.3 Assessment of Bushfire Attack (Construction Standards). The 2010 amendment of Appendix 3 of Planning for Bushfire Protection 2006 provides the following procedure for determining bushfire attack on a building within a designated bushfire prone area: (a) Determine vegetation formation types and sub-formations around the

building as follows; (i) Identify all vegetation types within 140 metres of the site using Keith

[2004]; (ii) Classify the vegetation formations as set out in Tables A2.1 in

Appendix 2; and (iii) Convert Keith to Specht classifications using Table A3.5 of

Appendix 3 [2010].

(b) Determine the separation distance between each vegetation formation and the structure;

(c) Determine the effective slope of the ground for each vegetation group; (d) Determine the relevant Fire Danger Index [FDI] for the Council area from

Table A2.3 in Appendix 2;

(e) Match the relevant FDI, appropriate vegetation, distance and effective slope to determine the bushfire attack levels using the relevant tables of A.S.3959 – 2009 as indicated below:

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(i) FDI 100 – Table A2.4.2; (ii) FDI 80 – Table A2.4.3; and (iii) FDI 50 – Table A2.4.4.

There are four levels of bushfire construction which are accepted by the NSW Rural Fire Service for the construction of residential buildings on existing lots which are identified as being bushfire prone. These are BAL 12.5; BAL 19; BAL 29 and BAL 40 as defined by A.S. 3959 – 2009. The NSW Rural Fire Service does not accept A.S. 3959 – 2009 BAL 40 & BAL FZ for buildings on bushfire prone land which is subject to a subdivision proposal. This also applies to strata title subdivision of medium density unit developments. Where more than one facade is exposed to a hazard, then the highest construction is required to that facade with the other facades being constructed to a level lower than the highest determined level of construction. All buildings located within 100 metres of bushfire prone vegetation must be constructed to a minimum standard of BAL 12.5. Table 2 provides a summary of Bushfire Attack and the resultant construction standards to the building. Table 2 Bushfire Attack Assessment – Determination of Construction

Standards to the proposed medium density flat development. Fire Danger Index [FDI] – 100

Aspect Predominant Vegetation

Class [Table A2.1 Pf BP 2006]

Effective Slope

of Land

Minimum width of Asset

Protection Zone

Provided

Level of Bushfire Attack

[Table A3.3 of PfBFP 2006]

Construction Standard in

accordance with A.S.3959

All

aspects to the

proposed buildings

Managed Shale

Plains Woodland

N.A.

None required as the site is adjoined by managed vegetation

Nil

Nil bushfire construction standards required.

Assessment Results: As a result of the land surrounding the development site being managed and therefore not bushfire prone with future residential development removing the current vegetation there is no requirement for the application of Bushfire Construction Standards to the proposed building – pursuant to A.S. 3959 – 2009 – ‘Construction of Building in Bushfire Prone Areas’.

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4.4 Access Standards for Firefighting Operations. 4.4.1 Adequacy of Public Roads. The proposed development will have access to a new public road constructed along the north-western boundary of the site with a new road separating the development site to form a south-western lot [proposed Lot A] and a north-eastern lot [proposed Lot B]. These new roads shall be constructed to standards which comply with Section 4.1.3(1) of Planning for Bushfire Protection 2006 and provide adequate two-way access for fire-fighting appliances. Access to the residual lot [proposed Lot C] will be provided from Cudgegong Road. 4.4.2 Fire Trail Access to two-way Public Roads. The proposed development does not require the provision of a fire fighting access trail. 4.4.3 Emergency Response Access / Egress. Emergency access and egress to the proposed development is to be provided off the new road network as explained in Section 4.4.1 above. 4.5 Water Supplies for Firefighting Operations. A reticulated water supply is available to the site from a main located in Cudgegong Road and Macquarie Road. The proposed development provides for the extension of this service into the buildings to provide a fire-fighting water service to each floor to address the provisions of A.S 2419.1 – 2005. A hydrant booster assembly shall be provided for structural fire-fighting and no additional water supplies are required for bushfire fighting operations. 4.6 Emergency Management for Fire Protection. Due to the negligible level of bushfire risk on the proposed buildings, there is no requirement to implement emergency management systems to aid in the protection of the building/occupants against the exposure to bushfires. 4.7 Adequacy of Sprinkler Systems & other Fire Protection Measures. There are no sprinkler systems required or recommended. 4.8 Evacuation. Evacuation from the complex due to bushfire risk will not be required.

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SECTION 5 BUSHFIRE MANAGEMENT STRATEGIES

Strategies to address the aim and objectives of Planning for Bushfire Protection 2006 are as follows: Strategy 1 – Water Supplies for Firefighting Operations: The existing Sydney Water reticulated service shall be extended into the development site with hydrants installed in accordance with A.S. 2419.1 – 2005. Strategy 2 – Bushfire Construction Standards to the proposed Building: The landscaped gardens shall be maintained to the standard of an Inner Protection Area [IPA]. Strategy 3 – Public Roads: The new public roads shall be constructed to standards which comply with Section 4.1.3(1) of Planning for Bushfire Protection 2006 and provide adequate two-way access for fire-fighting appliances.

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SECTION 6 CONCLUSION

This report has been prepared for a Development Application seeking consent for the construction of a two hundred and one [201] unit residential flat complex on Lot 80 in DP 208203, No. 105 Cudgegong Road, Rouse Hill . The development site and adjoining lands is recorded on the Blacktown Bushfire Prone Land contain Category 1 Bushfire Prone Vegetation. However, the site inspection confirmed that the mapped Category 1 Bushfire Prone Vegetation is in fact Shale Plains Woodland with a managed [slashed/grazed] grassy understorey. This vegetation is therefore not deemed to be bushfire prone and does not present a hazard to the proposed buildings. The Blacktown Bushfire Prone Land Map is therefore not accurate. The development does not require the provision of Asset Protection Zones, pursuant to Panning for Bushfire Protection 2006, or bushfire construction standards pursuant to A.S. 3959 – 2009 – ‘Construction of Buildings in Bushfire Prone Areas’. I confirm that the proposed development complies with the deemed-to-satisfy provisions of Planning for Bushfire Protection 2006.

Graham Swain Managing Director, Australian Bushfire Protection Planners Pty Limited.

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REFERENCES: • N.S.W Rural Fire Service – Planning for Bushfire Protection 2006;

• N.S.W Rural Fire Service – Threatened Species Hazard Reduction List for the

Bushfire Environmental Code (2003); • Environmental Planning & Assessment Act – 1979; • Rural Fires Act – 1997; • Rural Fires and Environmental Assessment Legislation Amendment Act 2002; • Rural Fires Regulation 2013; • NSW Rural Fire Service – Guideline for Bushfire Prone Land Mapping 2015; • Threatened Species Conservation Act 1995; • Native Vegetation Act; • Bushfire Environmental Assessment Code 2006; • Building Code of Australia; • Australian Standard A.S. 3959-2009 “Construction of Buildings in Bushfire

Prone Areas”; • Blacktown Bushfire Prone Land Map;

• Blacktown LEP; • Cudgegong Road Structure Plan.