Client: Coast to Country Planning Project: Bushfire Management … · 2020-03-26 · Group for a development proposal at Lot 2 Blackers Road Narrawong, Victoria. The planning permit

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QUOTATION: Landtech Consulting - Bushfire Management Statement; Quote; Lot 2 Blackers Road Narrawong Vic. Version: 16 March 2020

Client: Coast to Country Planning

Project: Bushfire Management Statement for

Lot 2 Blackers Road Narrawong, Victoria.

Date: March 16, 2020

Contact: C/- Fiona Castley [email protected]

Landtech: Peter Austin [email protected]

161 Skene St, Warrnambool.Vic.3280. Ph.0408-615677.

Figures 1 & 2 - Lot proposed for 5-bedroom dwelling to the west of Blackers Road, Narrawong (Source: Coast to Country 2020).

Prepared by: Peter Austin trading as Landtech Consulting ABN: 4531 2192 419

BSc (Env.Sc), Grad Dip Env Heath, Dip Horticulture, Dip VET, Cert IV TAE.

www.landtechconsulting.com.au

mailto:[email protected]

mailto:[email protected]

http://www.landtechconsulting.com.au/

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Document control

Assessment Bushfire Management Statement; 5-bedroom dwelling (150m²) development.

Address Lot 2 Blackers Road Narrawong Vic

Project number 461

Project manager Peter Austin (Landtech Consulting)

Mapping Peter Austin (Landtech Consulting)

Client Coast to Country Planning

CFA Fire Region Barwon South West – Casterton – CFA District 04

CMA Glenelg-Hopkins CMA

Council Glenelg Shire Council

Acknowledgements

Copyright © Landtech Consulting

This document is subject to copyright and may only be used for the purposes for which it was commissioned. The use or

copying of this document in whole or part without the permission of Landtech Consulting is an infringement of copyright.

Disclaimer

Although Landtech Consulting have taken all the necessary steps to ensure that an accurate document has been prepared,

the company accepts no liability for any damages or loss incurred as a result of reliance placed upon the report and its

contents.

Figure 3 – Forms of Bushfire Attack and management assessment related to this report.1

1 DELWP BMO Technical Guide 2017; Clause 44.06 Vic Planning Provisions, Accessed from:

https://www.planning.vic.gov.au/__data/assets/pdf_file/0029/107669/Technical-Guide-Planning-Permit-Applications-Bushfire-Management-Overlay.pdf


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Summary

This report is prepared in support of a planning permit application to be lodged by Coast to Country Planning

Group for a development proposal at Lot 2 Blackers Road Narrawong, Victoria. The planning permit application

seeks approval for a proposed 611m² (5-bedroom) dwelling and shed footprint, proximal to modified remnant

vegetation.

The site is entirely within the Bushfire Management Overlay and is within a highly bushfire-prone area.

Therefore, the nature of this development requires effective bushfire safety management measures to best

protect property and life.

A Bushfire Management Statement has been sought by the applicant to demonstrate how relevant bushfire

matters have been considered in the location and design of the proposal.

This Bushfire Management Statement (BMS) has been prepared by Landtech Consulting (see Figures 1 & 2)

and should be read in conjunction with the accompanying planning permit application. The BMS will

accompany a planning permit application involving the development of the proposed dwelling and shed,

including the use of building envelopes.

In addition to informing the siting and design of the proposed dwelling and location, this report will assist in an

assessment of the proposal by the Country Fire Authority (CFA), and a decision on the permit application by the

responsible authority (Glenelg Shire Council).

Further details on the design of the proposed buildings are located in the Town Planning Report and

Architectural Drawings enclosed with this planning permit application.”

The proposed development takes into account defendable space requirements from 22m to 50m which occurs

within the study area land parcel.

A BAL 12.5 construction standard is possible with managed defendable space within lot boundaries without

reliance on offsite management. Options for reduced defendable space will require increased building

construction standards and a change to BAL assessment.

Figure 4 – Proximal and linked remnant vegetation providing a landscape fire risk due to constraints beyond the lot (Source: Google 2020).

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The site is within a declared Bushfire Prone Area however and within the Bushfire Management Overlay (BMO)

under the Glenelg Shire Planning Scheme. This statement outlines how the proposed development responds to

the purpose and objectives of Clause 53.02-3 Bushfire Protection Objective:

Clause 53.02-3 applies to an application to construct a single dwelling or construct or carry out works

associated with a single dwelling if all of the following requirements are met: The land is zoned Neighbourhood

Residential Zone, General Residential Zone, Residential Growth Zone, Urban Growth Zone, Low Density

Residential Zone, Township Zone or Rural Living Zone. There is only one dwelling on the lot. The application

meets all of the approved measures contained in Clause 53.02-3,2 including the decision guidelines of the

Clause 44.06 Bushfire Management Overlay.3

The Bushfire Management Statement (BMS) has been prepared in response to the requirements of Clause 44.06 –

Bushfire Management Overlay, and in accordance with the application requirements of Clause 52.47-1 Dwellings in

existing settlements. This requires that approved measures AM 1.1, AM 1.2 and AM 1.3 be included in an application

The statement contains three components:

1. 1. A Bushfire Hazard Landscape Assessment including a plan that describes the bushfire hazard of the

general locality more than 150m from the site. Images or other techniques may be used to assist in describing

the bushfire hazard.

2. A Bushfire Hazard Site Assessment including a plan that describes the bushfire hazard within 150m of the

proposed development. The description of the hazard must be prepared in accordance with Section 2.2.5 of

AS3959:2018 Construction of Buildings in Bushfire Prone Areas (Standards Australia) excluding paragraph (a)

of Section 2.2.3.2. Images or other techniques may be used to assist in describing the bushfire hazard.

3. A Bushfire Management Statement describing how the proposed development responds to the requirements

of Cause 44.06, 53.02 and 53.02-3.

This report has been prepared in accordance with guidance provided in the Planning Permit Applications

Bushfire Management Overlay Technical Guide (DELWP, 2017).

Figure 5 – Site location with proximity to Mt.Clay SP with a history of broad-scale bushfires (Source: Google 2020).

2 https://planning-schemes.delwp.vic.gov.au/schemes/vpps/53_02.pdf 3 DPCD 2020; Advisory Note 46; Bushfire Management Overlay Mapping Methodology and Criteria. Accessed from:

https://www.planning.vic.gov.au/__data/assets/word_doc/0030/97572/AN46-Bushfire-Management-Overlay-Mapping-Methodology-and-Criteria.doc

https://planning-schemes.delwp.vic.gov.au/schemes/vpps/53_02.pdf

https://www.planning.vic.gov.au/__data/assets/word_doc/0030/97572/AN46-Bushfire-Management-Overlay-Mapping-Methodology-and-Criteria.doc

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CONTENTS

1. APPLICATION DETAILS………………………………………………………………………………………………………………………… 6

1.1 Site Description

1.2 Subject Site, Interfaces, Land Uses

1.3 Adjoining Land Uses

2. PLANNING CONTROLS……………………………………………………………………………………………………………………….. 8

3. BUSHFIRE HAZARD LANDSCAPE ASSESSMENT (hazard >150m)………………………………………………………………… 11

3.1 Bushfire Landscape Assessment

3.3 Description of surrounding area

3.3 Landscape risk

3.4 Bushfire Landscape Assessment Plan

4. BUSHFIRE HAZARD SITE ASSESSMENT (hazard <150m)…………………………………………………………………………….. 22

4.1 Vegetation

4.2 Topography

4.3 Defendable Space and Bushfire Attack Level (BAL)

4.4 Defendable Space Plan

4.5 Bushfire Site Assessment Plan

5. BUSHFIRE MANAGEMENT STATEMENT………………………………………………………………………………………………………. 33

5.1 Bushfire protection objectives

5.2 Landscape, siting and design

5.3 Defendable space and construction

5.3 Water supply and access objectives

6. CONCLUSION…………………………………………………………………………………………………………………………………….. 38

7. BUSHFIRE MANAGEMENT PLAN…………………………………………………………………………………………………………. 39

8. OWNERS OBLIGATIONS…………………………………………………………………………………………………………………………… 42

APPENDIX 1 – SITE DEVELOPMENT FEATURE SURVEY……………………………………………….................................. 43

APPENDIX 3 – LANDSCAPE SCENARIOS – LANDSCAPE ASSESSMENT……………………………………………………... 44

APPENDIX 4 – BUSHFIRE ATTACK LEVELS………………………………………………………………..................................... 44

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1. APPLICATION DETAILS

Table 1 – Application and lot details.

Municipality Glenelg Shire Council

Address Lot 2 Blackers Road NARRAWONG 3285

Council Property Number 90035000.09

Zoning RURAL LIVING ZONE (RLZ)

SCHEDULE TO THE RURAL LIVING ZONE (RLZ)

Overlays BUSHFIRE MANAGEMENT OVERLAY (BMO)

ENVIRONMENTAL SIGNIFICANCE OVERLAY (ESO)

Figure 6 – Image depicts largely cleared landscape surrounding Mt.Clay State Park and location of study area north of Narrawong

(Source: Google 2020).

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1.1 Site Description

Table 2 – Site description parameters.

Site shape The site is broadly rectangular in shape and aligned approximately north-south (east – road frontage, west –

pasture to remnant bushland).

Site dimensions Site length – 235m

Site width – 140m - 202m

Site area 4Ha

Existing use and

siting of buildings

and works on and

near the land

The site is generally cleared of vegetation and built infrastructure existing as a vacant lot. The lot has a small

ephemeral dam in the east-north-east of the site which is proximal to the proposed built footprint.

This lot is wire fenced within surrounding rural and residential similar land-use lots. Proposed infrastructure

includes a 5-bedroom dwelling and shed.

Existing vehicle

arrangements

There is a single gravel cross-over into the property directly accessing Blackers Road to the north-east of the

lot.

Location of nearest

fire hydrant A fire hydrant does not exist within or proximal to the subject site.

Any other features

of the site relevant

to bushfire

considerations

The entire land parcel is essentially clear of vegetation apart from limited remnant single and grouped trees

proximal to the proposed dwelling to the east of the lot.

Within the lot the main significant areas of remnant vegetation exist sparsely across the site which is

dominated by pasture grasses. In addition to grass fire risk on all sides of the property, to the west includes a

strip of vegetation along a proximal watercourse which eventually leads north to Mt Clay National Park.

Roadside linear strips of vegetation lead to, and past the site to the east along Blackers Road.

Figure 7 – Site descriptive feature map showing localised vegetation connections relating to landscape fire risk (Source: Google 2020).

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1.2 Subject Site, Interface, Land Uses

The subject site is recognised as Lot 2 Blackers Road Narrawong and located within the Rural Living Zone (RLZ), and

the subject to an Environmental Significance (ESO) and Bushfire Management Overlay (BMO).

The site has an area of approximately 4 hectares (deduced from title), with direct access to Blackers Road to the east,

with the land parcel sharing all other boundaries with adjoining freehold lots, with a maximum parcel depth of

235 metres.

Figure 8 – Sparse site remnant vegetation persists to the east of the lot with single specimens within pasture-dominated areas elsewhere

(Source: Google 2020).

Site features include an approximately 100m² dam, located in the east-north-east portion of the lot, and proximal to the

proposed dwelling and shed development. Site infrastructure includes the dam and essentially cleared pasture.

In addition to part-wire boundary fencing (east and north boundaries), and power infrastructure are contained within

areas proximal to the dwelling. The site contains single specimen trees and few clumps of remnant vegetation.

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1.3 Adjoining Land Uses

The surrounding coastal and hinterland landscapes contain a number of small townships/settlements. These

settlements include clusters of rural-residential lots within larger agriculturally-based lots, proximal large

protected areas with a history of significant bushfire hazard.

The RBPA (Barwon South West)4 suggests the study area continues to experience development pressure east of the

Narrawong settlement in proximity to a bushfire hazard area. Clusters of small lots at Narrawong exist in close

proximity to bushfire hazard areas associated with scattered remnant vegetation.5

Section 5.2 of RBPA (Barwon South West) suggests that the south-east of this CFA management district which

includes the assessed lot, is within forest, heathland, and grassland environments. Several watercourses

descend through the area containing linear and connecting corridors of riparian vegetation such as that

adjoining the west of the site.

The coastal hinterland areas provide a bushfire hazard for surrounding settlements which contain small and

rural/residential lots in or in proximity to bushfire hazard areas. The aesthetic and natural values of these areas

attract development pressure for rural-residential settlement.

Land adjoining the subject site has been previously used for grazing and general agricultural activity, with rural-lifestyle

subdivisions to the east of the site.

Land to the north of the study area is linked via riparian remnant vegetation leading to large protected areas as part of

Mt.Clay State Forest and a major bushfire hazard proximal to the site.

Land to the south and east includes a dominance of managed (grazed) grassland, with the site linked to partly-

contiguous road and fence-line vegetation.

Figure 9 – Identified bushfire hazard areas due to incremental lifestyle development within largely rural landscapes.

To the west the lot (study area), an adjoining large hectare lot abuts the Mt.Clay SF and Narrawong Flora reserve, a

large core of classifiable vegetation with a varied planned burn and wildfire history.

Land to the east includes newly subdivided but generally wooded lots that require fire management practices to reduce

ongoing fire-risk.

4 Victorian Government 2018 Barwon South-west Region Fire Management Plan; Accessed from:

https://www.planning.vic.gov.au/__data/assets/pdf_file/0018/102294/Barwon-South-West-Region-Part-1.pdf 5 RBPA CFA Barwon South West; Glenelg-Shire; Accessed from: https://www.vfrr.vic.gov.au/

https://www.planning.vic.gov.au/__data/assets/pdf_file/0018/102294/Barwon-South-West-Region-Part-1.pdf

https://www.vfrr.vic.gov.au/

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2. PLANNING CONTROLS

a. Planning Policy Framework

The Planning Policy Framework (PPF) seeks to ensure the objectives of planning in Victoria (as set out in

Section 4 of the Planning and Environment Act 1987) are fostered through appropriate land use, development

policies, and practices.

The PPF informs the preparation and implementation of local planning policy objectives and the introduction of

zone and overlay controls. It seeks to integrate relevant environmental, social and economic factors in the

interest of net community benefit and sustainable development.

The objective of Clause 13.02-1S Bushfire Planning is ‘to strengthen the resilience of settlements and

communities to bushfire through risk-based planning that prioritises the protection of human life.’

Strategies to achieve the objective include identifying and assessing bushfire hazards, appropriate settlement

planning, consideration to areas of high biodiversity conservation value, and use and development controls in

a Bushfire Prone Area.

Hazards identified and risks assessed in Clause 13.02-1S by:

- Prioritising the protection of human life over all other policy considerations.

- Directing population growth and development to low risk locations and ensuring the availability of, and

safe access to, areas where human life can be better protected from the effects of bushfire.

- Reducing the vulnerability of communities to bushfire through the consideration of bushfire risk in

decision-making at all stages of the planning process.

- Not approving development where a landowner or proponent has not satisfactorily demonstrated that the

relevant policies have been addressed, performance measures satisfied, or bushfire protection measures

can be adequately implemented.

b. Bushfire Management Overlay (BMO)

The purposes of the Bushfire Management Overly include:

• To ensure that the development of land prioritises the protection of human life and strengthens

community resilience to bushfire.

• To identify areas where the bushfire hazard warrants bushfire protection measures to be

implemented.

• To ensure development is only permitted where the risk to life and property from bushfire can be

reduced to an acceptable level.

Planning Advisory Note 46 Bushfire Management Overlay Mapping Methodology and Criteria outlines that the

Bushfire Management Overlay generally applies to areas of significant bushfire hazard where head fire

intensity is modelled to be 30,000 kW/m or more.

Under the Bushfire Management Overlay, a planning permit is required to construct a dwelling.

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An application must meet the requirements contained in Clause 53.02 Bushfire Planning of the Glenelg

Planning Scheme. The provisions of Clause 53.02 contain:6

- Objectives. An objective describes the outcome that must be achieved in a completed

development.

- Approved measures (AM) - An approved measure meets the objective.

- Alternative measures (AltM) - An alternative measure may be considered where the responsible

authority is satisfied that the objective can be met. The responsible authority may consider other

unspecified alternative measures.

- Decision guidelines. The decision guidelines set out the matters that the responsible authority

must consider before deciding on an application, including whether any proposed alternative

measure is appropriate.

Section 5 of this report outlines how the proposed development responds to the requirements of Clause 53.02

& 53.02-3.

Clause 53.02-1 (2018) applies to an application (under Clause 44.06 - Bushfire Management Overlay), unless

the application meets all of the requirements specified in a schedule to Clause 44.06.


associated with a single dwelling if all of the following requirements are met:

• The land is zoned Neighbourhood Residential Zone, General Residential Zone, Residential Growth

Zone, Urban Growth Zone, Low Density Residential Zone, Township Zone or Rural Living Zone.

• There is only one dwelling on the lot.

• The application meets all of the approved measures contained in Clause 53.02-3. Clause 53.02-4

applies to all other applications.

APPROVAL PATHWAY7

PATHWAY 1 – CLAUSE 52.47-1 DWELLINGS IN EXISTING SETTLEMENTS

Clause 52.47-1 provides a streamlined process for preparing and assessing a planning application.


associated with a single dwelling where the following apply:

• The land is zoned Neighbourhood Residential Zone, General Residential Zone, Residential Growth Zone,

Urban Growth Zone, Low Density Residential Zone, Township Zone or Rural Living Zone.

• There is only one dwelling on the lot. Clause 52.47-7 operates as follows:

• The application must meet all the approved measures in Clause 52.47-1.

• Where an application meets the applicable approved measures the corresponding objective is also met.

• All approved measures must be met.

• No alternative measures can be included in an application.

If an applicant chooses to include alternative measures, the application will be assessed under Pathway Two

and all relevant approved or alternate measures of Clause 52.47-2 must be met.

6 DELWP; Victorian Planning Schemes; Accessed from: https://planning-schemes.delwp.vic.gov.au/schemes/glenelg 7 Technical-Guide-Planning-Permit-Applications-Bushfire-Management-Overlay; Accessed from:


https://planning-schemes.delwp.vic.gov.au/schemes/glenelg


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c. Other development controls - Zoning

The subject site is zoned Rural Living Zone (RLZ).

d. Other development controls - Overlays

The subject land is affected by a Bushfire Management Overlay.8 This overlay has a focus on:

• Implement the Municipal Planning Strategy and the Planning Policy Framework.

• To ensure that the development of land prioritises the protection of human life and strengthens

community resilience to bushfire.

• To identify areas where the bushfire hazard warrants bushfire protection measures to be

implemented. To ensure development is only permitted where the risk to life and property from

bushfire can be reduced to an acceptable level.

The subject land is also subject to an Environmental Significance Overlay (ESO).9 This overlay has a focus on

• To implement the Municipal Planning Strategy and the Planning Policy Framework.

• To identify areas where the development of land may be affected by environmental constraints.

• To ensure that development is compatible with identified environmental values.

8 Technical-Guide-Planning-Permit-Applications-Bushfire-Management-Overlay; Accessed from:

https://www.planning.vic.gov.au/__data/assets/pdf_file/0029/107669/Technical-Guide-Planning-Permit-Applications-Bushfire-Management-Overlay.pdf 9 Technical-Guide-Planning-Permit-Applications-Environmental Significance Overlay; Accessed from:

https://www.planning.vic.gov.au/__data/assets/pdf_file/0029/107669/Technical-Guide-Planning-Permit-Applications-Environmental-Significance-Overlay.pdf


https://www.planning.vic.gov.au/__data/assets/pdf_file/0029/107669/Technical-Guide-Planning-Permit-Applications-Environmental-Significance-Overlay.pdf

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3. BUSHFIRE HAZARD – LANDSCAPE ASSESSMENT

The bushfire hazard landscape assessment provides information on the bushfire hazard more than 150 metres from a

development site. Considering bushfire from this broader landscape perspective is important as it affects the level of

bushfire risk a development and its future occupants may be exposed to.10

Considering the bushfire risk arising from the broader landscape

Bushfire is a dynamic hazard and can be highly unpredictable with factors contributing to the bushfire risk diverse.

The purpose of the landscape assessment is not to predict the outcome of a bushfire event, but to provide information

that builds a better understanding of the bushfire risk in a location, and to inform decision-making.

These seek to support more consistent decision-making, based on the risk from the landscape beyond the site.

The broader landscape and the potential size or scale of a bushfire is an important consideration in the assessment of

a planning application. The likelihood of a bushfire, its severity and intensity, and the potential impact on life and

property varies, depending on where a site is located in the surrounding landscape.

The defendable space and construction requirements in the BMO and Clause 53.02 Bushfire Planning are based on standard requirements. To determine these requirements, models are used to predict radiant heat from a

fire-front based on specific inputs and assumptions. Considering the surrounding landscape in bushfire decisions is

important because the accuracy of the models in reflecting bushfire exposure on a particular site varies in different

landscapes.

This is because the scale of a bushfire and its potential destructive power is driven by the characteristics and previous

management of the broader landscape, rather than those characteristics within 150 metres of the site.

How is the landscape assessment used in preparing and assessing a planning application?

The landscape assessment presents contextual information on a site and informs the following-stage Bushfire Hazard

Site Assessment. It provides information critical to potential bushfire behaviour, and how the approved and alternative

measures adequately mitigate the risk.

The landscape assessment is used where Clause 53.02 Bushfire Planning requires consideration of the bushfire

risk from the landscape beyond the site. This requires that approved measures AM 1.1, AM 1.2 and AM 1.3 be

included in an application and associated decision guidelines.

The assessment provides information that allows these provisions to be responded to as part of the bushfire

management statement submitted with an application.

Figure 10 – 100m² ephemeral dam exists within the north-east part of the lot and proximal to where a dwelling is proposed.

10 DELWP Planning Permit Applications Bushfire Management Overlay Technical Guide; Accessed from:



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3.1 Bushfire Landscape Assessment Hazard

The bushfire hazard landscape assessment provides information on the bushfire hazard more than 150 metres away

from a development site and includes:

▪ Factual information on the bushfire hazard (vegetation extent and slope);

▪ Information on key features of the general locality relevant to better understanding the protection provided by

the location; and

▪ Provides contextual information on a site.

The landscape assessment does not assess a specific development proposal and is only required where Clause

53.02 Bushfire Planning requires consideration of the bushfire risk from the landscape beyond the site.

3.2 Description Of Surrounding Area

The surrounding landscape has a mixed fire history based on the broadscale 1939 fires, followed by various

fires within the Mt.Clay protected area including in 2016, in addition to planned management burns.

The immediate area consists of large rural and agricultural-sized lots with recent rural living development

providing the locality a mixed forest and open space and rural character (see Figures 1-12).

Topography within the surrounding area is variable and includes foothill gullies and ridges of the southern

flanks of Mt.Clay State Park/Forest), in addition to sloping sites to the south toward the more level farmland

adjacent to the coast.

The study site slopes from the north-west to the south and adjoins a local watercourse to the west of the site

buffered by an additional land parcel in between.

Classifiable vegetation within rural properties to the east of the site include elements of remnant Lowland Forest

and more distant riparian vegetation (see Figure 12) which has been variably cleared, including specifically much

understorey potentially reducing fire risk. The rest of the localised landscape is dominated by exotic pasture and

native grassland species as part of ongoing agricultural properties.

In addition, site linkage vegetation includes isolated riparian vegetation to the west of the site (adjoining the

bare lot directly to the west) and variably contiguous vegetation to the east from roadside remnant vegetation

along Blackers Road (Narrawong).

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3.3 Landscape Risk

The former Planning Practice Note 65 provides useful guidance on describing landscape typology.

The landscape typologies outlined in Practice Note 65 range from low risk landscapes where there is little

vegetation beyond 150 metres of the site and extreme bushfire behaviour is not possible, to extreme risk

landscapes with limited or no evacuation options.

Figure 11 – Site immediately south and within the foothills of Mt.Clay State Park (Source: Google 2020).

Figure 12 – Site of increased landscape-based hazard due to complex terrain within and beyond the site (Source: Google 2020).

Once a bushfire is large, the weather and the interaction of the fire with itself becomes the dominant driver of

fire behaviour. Variation in fuel and topography become less relevant as large bushfires tend to ‘smooth’ these

out.

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This should be remembered when classifying vegetation and determining slope in landscape types Three or

Four and the assessment of these factors should be made with due caution. This will include:11

• Considering the influence of slope on fire behaviour beyond the 150m assessment area as well as

within.

• Determining effective slope on worst case rather than an average.

• Choosing the more conservative fuel type in situations where the classifiable vegetation does not fit

neatly into a specific vegetation class.

• For ‘modified’ vegetation to be considered a valid classification, the level of modification and the

distance the fire has to travel through these modified fuels must be significant.

• In most instances it will not be appropriate to classify fuels as modified in landscape types Three or

Four.

• Similarly, fuels must be significantly managed and clearly meet defendable space prescriptions before

they can be classified as ‘low threat’.

Landscape Scenario

It is considered that Landscape Scenario Three best represents the area surrounding the subject site, although

not specifically applying to this area.

• The type and extent of vegetation located more than 150 metres from the site may result in neighbourhood-

scale destruction as it interacts with the bushfire hazard on and close to a site.

• Bushfire can approach from more than one aspect.

• The site is located in an area that is not managed in a minimum fuel condition.

• Access to an appropriate place that provides shelter from bushfire is not certain.

Bushfire can approach at the site from more than one aspect (N, NW, S, SE – coastal influence). While the site

is located in an area which includes mainly pasture and is generally managed in a minimum fuel condition

utilising cattle grazing, this is not always the case as observed.

Fire Authorities have assessed Narrawong as having a VERY HIGH bushfire risk, suggesting local residents and

visitors should be prepared for fire and have a plan for when the Fire Danger Rating is SEVERE, EXTREME or

CODE RED.

The Regional Bushfire Planning Assessment - Barwon South West Region (DPCD 2012) identifies scattered

remnant vegetation and vast tracts of unmanaged grassland as a known fire risk within the region however the

area does not have a Community Information Guide – Bushfire (Township Protection Plan) in place with

evacuation focused southwards to the coast.

An NSP-BPLR may be an open space at a local sports field, foreshore or park, or they may be located within a

community building such as a hall or sports pavilion. Narrawong or Tyrendarra does not have a designated

Neighbourhood Safer Place12 with Portland the suggested closest site (15km to the south-west of study site).

11 CFA Applying the Bushfire Hazard Landscape Assessment in a Bushfire Management; Accessed from:

https://www.cfa.vic.gov.au/documents/20143/69511/guidence-applying-the-landscape-assessment_V3.pdf/27fc4afb-2dee-32ff-67db-e584efade2c0 12 CFA Safer Places Database (Victoria), Accessed from: http://www.saferplaces.cfa.vic.gov.au/cfa/search/default.htm

https://www.cfa.vic.gov.au/documents/20143/69511/guidence-applying-the-landscape-assessment_V3.pdf/27fc4afb-2dee-32ff-67db-e584efade2c0

http://www.saferplaces.cfa.vic.gov.au/cfa/search/default.htm

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Table 3 – Landscape risk threats within the landscape beyond a 150m buffer area.

Parameter Detail

Overview

The subject site is located within a rural conservation setting to the north-east of Portland (14km), surrounded by rural

and agriculture-based landscapes on three sides, and Blackers road to the east.

Land to the north, south, and east across Blackers Road contains moderately-sized 2-6ha lots with patches of planted

and indigenous vegetation, typically lacking understorey, and dominated across the landscape of seasonally-cured

exotic pasture grasses.

Apart from the potential risk of grassland fire from all directions (principally from the west and south, mostly contiguous

riparian and roadside vegetation provides potential landscape-scale fire linkage to the study site. Riparian and lowland

forest vegetation types presents a hazardous fire risk within such areas.

The likely bushfire would originate from the Mount Clay State Forest to the north and west.13 This forest

vegetation is on a downslope with low managed grassland/pasture buffer in between.

This forest has bushfire fuel and risk management control by DELWP. The approach of fire from the south is

less likely due to lack of high-risk fuel sources, low threat managed vegetation, and the predominant wind

direction being from the west-north-west, however localised downslope south present a fire risk if exotic

pasture fuels are not managed.

Protection can be provided in the nearby township of Narrawong. This is a short distance of 3km to the south

which can be done by exiting the property away from the likely bushfire approach direction.

North: Rural properties to the north of the site consist of generally managed grassland-dominated vegetation cover,

however with partly contiguous fence-line and riparian-fringing remnant vegetation.

These lots could be considered managed spaces however the linkage to the vegetation toward a northern gully

increases potential landscape risk.

East: Rural acreage properties (approx. 4ha) to the east and south-east contain contiguous elements of lowland forest

within such lots lacking middle and understorey elements. Grassland persists within the understorey contain exotic and

native grass species in an unmanaged state.

The upslope then downslope nature of the topography to the east presents a bushfire risk due to such landscape

features and relatively complex terrain. The contiguous nature of the vegetation to provide fire linkage in times of high

fire danger also presents a risk from this direction.

13 EMV Victoria 2018, BSW Regional Strategy Fire Management Plan; Accessed from: https://files-em.em.vic.gov.au/public/EMV-web/Barwon-South-West-

Regional-Strategic-Fire-Management-Plan.pdf

https://files-em.em.vic.gov.au/public/EMV-web/Barwon-South-West-Regional-Strategic-Fire-Management-Plan.pdf

https://files-em.em.vic.gov.au/public/EMV-web/Barwon-South-West-Regional-Strategic-Fire-Management-Plan.pdf

18


West: There are two land parcels to the west preceding the Mt.Clay State Forest, a large remnant forest with Heathy

Woodland and Lowland Forest vegetation types. Notwithstanding a 200m buffer past the adjoining western lot, riparian

vegetation linked to the broader Mt.Clay remnant vegetation may increase fire risk. Ember attack could be significant

subsequent to a wind change from the west.

South: Bushfire risk from the south consists of exotic pasture grass dominated land cover types, generally grazed and

therefore considered a managed vegetation type. However, this cannot be guaranteed, and the threat must be

accounted for within this assessment due to wind change fire scenario’s.

Sparsely contiguous vegetation persists to the south-east lacking middle and understorey vegetation structural

elements. Reduced patches of roadside vegetation persist to the south along Blackers Road.

Subject site

information

Landscape Assessment Plan (see Figure 13 & Section 3.4):

• subject site

• scale and distance bar

• vegetation extent in the broader locality (0-100km)

• road networks

• fire run(s) into the site

• a bushfire direction of travel diagram

• history of bushfire in the area

• any significant landscape features that are relevant to the considerations set out in Clause 53.02; and

• information from the relevant Regional Bushfire Planning Assessments.

Landscape Scale Map with measured distances indicate the following:

-20km, 50km, 100km (where relevant) landscape buffers;

-proximity of the site to nearby urban, township or other areas where fuel is managed in a minimum fuel

condition.

19


Parameter Detail

Localised fire

history

1939 – in January (“Black Friday”) when 2 million hectares of Victoria burnt including most of the

now Glenelg Shire, and including Portland, Heywood, Bridgewater, Tyrendarra, Condah, Lyons,

Dartmoor, Rennick, Strathdownie and Tullich.

2006 - a fire at Tyrendarra was ignited by lightning in farmland east of Heywood and spread for

several days across farmland, rough lava flow areas along the Fitzroy River. The fire threatened

communities in the Tyrendarra and Narrawong areas before eventually being controlled near the

coast.

2014 – a fire started in the Mount Clay/Narrawong state forest burning an area of approximately

1300 hectares.

Figure 13 – Broad-scale landscape assessment map.

20


Parameter Detail

Provide further

information for

more complex

locations

The surrounding landscape has been assessed as having VERY HIGH bushfire risk.14

The most likely bushfire scenarios are those typically associated with the direction of wind on severe,

extreme or code red days (in other words, extremely hot, dry, northerly wind conditions).

The site has potential to be impacted by a large landscape-scale fire approaching from the north and

north-west from Mt.Clay State Park/Forest which could include ember attack under strong north and

north-west winds. The reserve is used heavily by campers and 4WD enthusiasts adding risk to the

potential for weather driven dry lightning strikes accompanied by extreme fire weather (low FDI etc).

The additional most likely bushfire scenarios are those typically associated with a wind change from the

west-south-west post-northerly winds based on a potential grass fire.

While areas of grassland within southern and the surrounding area may moderate the speed and

intensity of the fire before it impacts the subject site, under conditions typical of severe, extreme or

code red days, the subject site is likely to be impacted upon by grassland ember attack. This is

especially the case due to sloping upslope sites dominating the lot.

Roadside tree-planting and lots further east which include potential upslope sites outside the 150m

landscape scenario also present a risk when winds become variable in localised fire weather.

This directional should not be discounted even where a catastrophic northerly fire approach is most

likely.

Exotic grassland dominating surrounding properties within and outside 150m of the site are currently in a

managed state, which would reduce fire risk if such conditions prevailed long-term. This cannot be considered

secure and as such grassland fire linked by contiguous roadside vegetation linking many of the local properties

is a possibility.

The Regional Bushfire Planning Assessment - Barwon South West Region (DPCD 2012) identifies

scattered remnant vegetation and vast tracts of unmanaged grassland as a known fire risk within the

region however the area does not have a Community Information Guide – Bushfire (Township

Protection Plan) in place with evacuation focused southwards to the coast at Narrawong (Princes

Highway).

An NSP-BPLR may be an open space at a local sports field, foreshore or park, or they may be located

within a community building such as a hall or sports pavilion. Narrawong or Tyrendarra does not have

a designated Neighbourhood Safer Place15 with Portland the suggested closest site (15km to the south-

west of study site).

The Bushfire Risk Management Register (Glenelg VFRR 2017)16 suggests Narrawong has the

potential for a high-risk fire based on development and settlement patterns.

Apply landscape

typology and

provide conclusions

It is deemed the subject site and broader landscape type can be described as Broader Landscape Type 3, (see

Table 4 of this report) as referred to within Practice Note 65:

The type and extent of vegetation located more than 150 metres from the site may result in neighbourhood-

scale destruction as it interacts with the bushfire hazard on and close to a site.

• Bushfire can approach from more than one aspect.

• The site is located in an area that is technically not managed in a minimum fuel condition (although in reality

from site observation in peak fire season actually is managed).

• Access to an appropriate place that provides shelter from bushfire is certain including defendable areas within

the west of the site, although sheltering would not be advisable and where protection within the Narrawong

township 3km south is the less hazardous option.

The study site has the potential to be also impacted by exotic-species grass fire hazard to the west and south.

Retained roadside vegetation on Blackers Road on a north-south axis adjacent to the east of the site also

provides potential connection of highly flammable grass and crown fire.

14 Glenelg Shire (2019); Site and Context Description and Design Response; Accessed from:

https://www.glenelg.vic.gov.au/files/Planning/P19122_Advertising_for_web.pdf 15 http://www.saferplaces.cfa.vic.gov.au/cfa/search/default.htm 16 EMV Victoria, Bushfire Risk Management Register - Glenelg VFRR (2017); Accessed from: https://www.vfrr.vic.gov.au/

https://www.glenelg.vic.gov.au/files/Planning/P19122_Advertising_for_web.pdf

http://www.saferplaces.cfa.vic.gov.au/cfa/search/default.htm

https://www.vfrr.vic.gov.au/

21


3.4 Bushfire Landscape Assessment Plan

Figure 14 – Overarching landscape factors before management is considered within the broader landscape >150m beyond the site.

22


4. BUSHFIRE HAZARD – SITE ASSESSMENT

The Bushfire Hazard Site Assessment describes the subject site and bushfire hazard within 150m of the proposed

development.

Pursuant to Clause 53.02 Bushfire Planning, “the description of the hazard must be prepared in accordance with

Sections 2.2.3 to 2.2.5 of AS3959:2018 Construction of buildings in bushfire prone areas (Standards Australia)

excluding paragraph (a) of section 2.2.3.2”.17

This Bushfire Hazard Assessment:

Provides factual information on the bushfire hazard (vegetation type and slope);

Informs defendable space and building construction requirements; and

Utilises the methodology contained in Australian Standard AS3959:2018 Construction of buildings in bushfire prone

areas (AS3959) to provide contextual information on a site.

Figure 15 – Dam to the north of the proposed house site with treed cover and generally sparse or grassland understorey.

Figure 16 – >150m landscape assessment zone includes classified woodland to the east.

17 SAI 2018, Australian/New Zealand Standards; AS3959:2018 Construction of buildings in bushfire-prone areas; Accessed from:

https://www.saiglobal.com/PDFTemp/Previews/OSH/as/as3000/3900/3959-2018.pdf

https://www.saiglobal.com/PDFTemp/Previews/OSH/as/as3000/3900/3959-2018.pdf

23


4.1 Vegetation

Vegetation within 150 metres of the site has been classified in accordance with the descriptions contained in

Section 2.2.3 in AS3959:2018 (Standards Australia: Construction of buildings in bushfire-prone areas) and the

CFA’s Vegetation Classes guide.18

Figure 17 – View looking north-east over proposed part of dwelling site with dam in background adjoining Blackers Road.

1. Classified Vegetation - Woodland

Patches of contiguous remnant vegetation located within the 150m buffer zone from north-east to south-east

match the AS3959 Woodland vegetation group, broadly defined as:

‘Woodlands or (rarely) forests that lack an abundance of hard-leaved (sclerophyllous) shrubs in the

understorey. Perennial grasses interspersed with perennial herbs are prominent in the understorey and may

be continuous, with shrubs being clumped or sparse in more open woodlands, typically 5–20 metres high’.19

In addition, areas of non-contiguous roadside vegetation within the same buffer persists along Blackers Road

to the north and south, and are variably managed, with increased flammability due to exotic grass dominance

within the understorey.

Figure 18 – Commencement of Woodland vegetation type with linkage from site to roadside to unmanaged lots to the north-east and

beyond and where vegetation management regimes could be variable.

18 CFA; Vegetation Classes – Bushfire Management Overlay 2018; Accessed from: https://www.cfa.vic.gov.au/documents/20143/69511/Vegetation-Classes-

Victorian-Bushfire-Management-Overlay-v0-3.pdf/f29e4450-a4ea-bfcb-ffe5-13cbbf01c746 19 CFA 2014; Vegetation Classes for BMO; Accessed from: https://www.cfa.vic.gov.au/documents/20143/69511/Vegetation-Classes-Victorian-Bushfire-

Management-Overlay-v0-3.pdf/f29e4450-a4ea-bfcb-ffe5-13cbbf01c746

https://www.cfa.vic.gov.au/documents/20143/69511/Vegetation-Classes-Victorian-Bushfire-Management-Overlay-v0-3.pdf/f29e4450-a4ea-bfcb-ffe5-13cbbf01c746




24


2. Classified Vegetation - Grassland (managed/unmanaged exotic pasture grass)

Remaining areas have been classified as Grassland (AS3959); defined as all forms of grassy vegetation

(including cropping and pasture) and including areas with shrubs and trees, if overstorey foliage is less than

10% canopy cover. Areas shown as Grassland appear to be regularly maintained / grazed.

For the purposes of this assessment however a precautionary approach has been adopted, and all areas

shown as grassland are assumed unmanaged, and therefore potentially classifiable vegetation.

The degree of slope southwards, notwithstanding the major fire risk from the north and north-west must form

part of fire risk mitigation.

Figure 19– Example of exotic grassland species required to be assessed due to the fire-producing nature of species if left unmanaged.

Figure 20 – Southern down-sloping flanks of lot and roadside edge to the right.

Figure 21 – Western view across currently managed vegetation cover to adjoining site and ephemeral riparian area.

25


3. Low-threat vegetation and non-vegetated areas

Areas of low threat vegetation and non-vegetated areas have been excluded under the following AS3959

criteria:

a) Vegetation of any type that is more than 100m from the site;

d) Strips of vegetation less than 20m in width regardless of length and not within 20m of the site, or each other:

e) Non-vegetated areas, including driveways, roads, footpaths, buildings and rocky outcrops; and

f) Low threat vegetation, including managed grassland, maintained lawns, golf courses, maintained public reserves and

parklands, botanical gardens, vineyards, orchards, cultivated ornamental gardens, commercial nurseries, nature strips and

wind breaks.

Areas of low threat vegetation and non-vegetated areas are located as single specimen trees within the western

and southern part of the site, roads, driveways, lawns within the 150m lot buffer. Defendable space

requirements proximal to the proposed dwelling will be managed landscapes and included as low threat

vegetation.

Figure 22 – Single specimen remnant trees exist well-spaced within the site.

Figure 23 – Part of suggested defendable space with enhanced vegetation management risk reduction measures required.

26


4.2 Topography

The slope of the land under the vegetation influences likely fire behaviour. As the slope increases so does the

intensity and rate of spread of bushfire.

The assessment requires the slope under classifiable vegetation to be identified according to the following

classifications:

• All upslopes and flat land (0 degrees)

• Downslope >0 to 5 degrees




• Downslope greater than 20 degrees.

Topography within the site falls from 91m elevation (north-east of lot) to the southern boundary on a

downslope of >5 to 10 degrees.

Topography to the south of the lot and within the 150m buffer includes downslope of >5 to 10 degrees.

Topography to the north of the site (within 150m of the development) consists of upslopes and flat land (0

degrees).

Topography to the east of the lot and within the 150m buffer includes upslopes and flat land (0 degrees).

Topography to the west of the site and within the 150m buffer includes >0 to 5 degrees downslope.

The proposed development is exposed to vegetation classified as:

- Low threat (managed) vegetation to the north upslopes and flat land (0 degrees).

- Woodland to the east within upslopes and flat land (0 degrees).

- Grassland to the south includes downslope of >5 to 10 degrees.

- Grassland to the west includes >0 to 5 degrees downslope

Figure 24 - Slope map in degrees showing extent of site slope within and beyond the study area.

27


Table 4 - Characteristics present within the site and surrounding environs.

Assessment area and

analysis of the site

The broadly rectangular north-south aligned lot occupies an area of 4 Hectares and contains

predominantly low-threat exotic grassland pasture species. It also has trees remaining from remnant

vegetation that were left around a small dam as part of former farming activities that are proximal to

the proposed dwelling.

The study site (lot) is located within the Rural Living Zone (and Schedule’s) and is also affected by

the following overlay:

Bushfire Management Overlay (BMO)

The subject site is set amongst an established rural 2-40ha lots on generally rectangular land

configurations running north-south. The vegetation within the immediate and wider areas is

dominated by remaining Lowland Forest vegetation and modified roadside vegetation with grassy

understorey.

Vegetation classification

This is Section 2.2.3 in

AS3959

Vegetation within the assessable area (150m radius) is either low-threat managed land excludable

pursuant to AS3959-2018 2.2.3.2 (f); or, ‘woodland’ generally dominated by Manna Gum, Swamp

Gum, Messmate and grassy understorey; or

1. Patches of remnant vegetation located within the 150m zone from north-east to

south-east match the AS3959 Woodland vegetation group.

2. Remaining areas have been classified as Grassland (AS3959); defined as all forms

of grassy vegetation (including cropping and pasture) including areas with shrubs

and trees if overstorey foliage is less than 10% canopy cover.

Exclusions – low-threat

vegetation and non-

vegetated areas

This is Sect ion 2.2.3.2 (f) in

AS3959

Vegetation exclusions within the assessable area includes single specimen trees within the

western and southern part of the site, roads, driveways, lawns within the 150m lot buffer,

managed defendable space areas proximal to the proposed dwelling (managed to a state of

‘low threat’ and is therefore excludable pursuant to AS3959-2018 2.2.3.2 (f)).

Distance to classifiable

vegetation

This is Section 2.2.4

AS3959

The closest classifiable vegetation (woodland) is located:

• 48m to east (on an adjoining property)

The closest classifiable vegetation (grassland) is located:

• 78m to the north

These vegetation patches do not meet the exemption detailed in AS395-2018 2.2.3.2 (d) as they

are connected to larger areas of classifiable vegetation (with road break to the east).

Slope under the classifiable

vegetation

This is Section 2.2.5 in

AS3959

The effective slope under the classified vegetation is as follows: North (and north-east): Upslope/Flat

East: Upslope/Flat

South: Downslope

West: Downslope

Note: where the vegetation classification is “Low Threat”; the prevailing slope has no bearing on the BAL rating.

Reticulated Water Supply,

Fire Hydrant

The closest fire hydrant is located > 3km to the south within Narrawong coastal township (based

on information from the CFA 2020).

28


4.3 Bushfire Site Assessment Plan

Figure 25 – Bushfire Risk Site Assessment Map.

29


4.4 Defendable Space Bushfire Attack Levels (BALs)

Figure 26 – Part of defendable space required proximal to the proposed dwelling site shown above.

Defendable space is an area of land around a building where vegetation is modified and managed to reduce the effects

of flame contact, radiant heat, and embers associated with bushfire. Flame contact, radiant heat, and embers are the

way a bushfire attacks a building.

It is in the Client’s interest to be setback as far as reasonably possible from this risk; accordingly building envelopes are

setback from each site boundary and other dwellings as far as reasonably possible.

CFA referral regarding defendable space and construction requirements is suggested to support that building

envelope layout has satisfactorily responded to Clause 53.02 Bushfire Planning.

As the application proposed is a single dwelling PATHWAY 1 – CLAUSE 52.47-1 DWELLINGS IN EXISTING

SETTLEMENTS applies.

30


Clause 52.47-1 Dwellings in existing settlements A streamlined process for preparing an application can be used.

This requires that approved measures AM 1.1, AM 1.2 and AM 1.3 be included in an application and that land is

zoned Neighbourhood Residential Zone, General Residential Zone, Residential Growth Zone, Urban Growth

Zone, Low Density Residential Zone, Township Zone or Rural Living Zone.

• There is only one dwelling on the lot. Clause 52.47-7 operates as follows:

• The application must meet all the approved measures in Clause 52.47-1.

• Where an application meets the applicable approved measures the corresponding objective is also met.

• All approved measures must be met.

• No alternative measures can be included in an application.

Clause 52.47-1 Dwellings in existing settlements A streamlined process for preparing an application can be used.

This requires that approved measures AM 1.1, AM 1.2 and AM 1.3 be included in an application

Approved measure AM 1.1: Siting

Approved measure AM 1.2: Defendable space and construction

Approved measure AM 1.2 (continued): Defendable space on adjoining land

Approved measure AM 1.3: Water supply and access

Permit exemption to create defendable space Clause 52.48-5 sets out a planning permit exemption to create

defendable space for a single dwelling or an alteration or extension to a dwelling.

Where a planning permit has been issued under the Bushfire Management Overlay, the removal, destruction or

lopping of vegetation to create a defendable space cannot be prevented by:

• any requirement of a planning permit, including any condition, or

• any requirement or provision of the planning scheme.

This exemption only applies where land is in the General Residential Zone, Residential Growth Zone, Neighbourhood

Residential Zone, Urban Growth Zone, Low Density Residential Zone, Township Zone, Rural Living Zone, Farming Zone

or Rural Activity Zone.

31


Bushfire Attack Level (BAL) Construction standards are referred to within AS3959:2018.

The defendable space required is determined by the vegetation type, slope and the preferred BAL construction

standard. Clause 52.47-1 suggests single dwellings must be constructed to BAL12.5.

The defendable space requirements for BAL-12.5 are detailed within the following table. Defendable space for this

development is within property boundaries (see Figure 27 & Table 5).

Please note: For this proposal within lot boundaries all vegetation must be managed (grazed) on an ongoing basis,

and treed area immediately north of built infrastructure requires vegetation management by the owner to support on-

site defendable space and chosen BAL construction requirements.

Table 5 – Defendable space and required construction standards as per AS3959:2018.

Parameter North South East West

FDI 100 100 100 100

Classified vegetation type Low threat#

(and managed) Grassland Woodland Grassland

Effective slope

(degrees)

Upslope/Flat

0 deg

Downslope

<5 to 10 deg

Upslope/Flat

0 deg

Downslope

>0 to 5 deg

Distance to classified

vegetation (metres) 78 115 48 100

Defendable Space

Requirements (metres) (need) 50m

25m (BAL 12.5)

33m (BAL 12.5) (including road interception)

22m (BAL 12.5)

Construction to BAL LOW 12.5 12.5 12.5

#Low Threat vegetation - Defendable space is to be provided for a distance of 50 metres, or the property boundary whichever is the lesser, for buildings

constructed to all bushfire attack levels. The minimum construction standard is BAL 12.5.

Topography to the north of the site (within 150m of the development) consists of upslopes and flat land (0 degrees).

Topography to the south of the lot and within the 150m buffer includes downslope of >5 to 10 degrees.

Topography to the east of the lot and within the 150m buffer includes upslopes and flat land (0 degrees).

Topography to the west of the site and within the 150m buffer includes >0 to 5 degrees downslope.

Vegetation

- Low threat (managed) vegetation to the north upslopes and flat land (0 degrees).

- Woodland to the east within upslopes and flat land (0 degrees).

- Grassland to the south includes downslope of >5 to 10 degrees.

- Grassland to the west includes >0 to 5 degrees downslope

Table 720 – Outbuilding construction requirement

Building construction condition

The proposed outbuilding is separated from the adjacent building by a wall that extends to the underside of a non-combustible

roof covering and has a FRL of not less than 60/60/60 for load-bearing walls and -/60/60 for non-load-bearing walls when

tested from the attached structure side, or is of masonry, earth wall or masonry-veneer construction with the masonry leaf of not

less than 90mm in thickness. Any openings in the wall shall be protected in accordance with the following: i. Doorways – by FLR -/60/30 self-closing fire doors

ii. ii. Windows – by FRL -/60/- fire windows permanently fixed in the closed position

iii. iii. Other openings – by construction with a FRL of not less than -/60/Note: Control and construction joints, subfloor vents, weep-holes and

penetrations for pipes and conduits need not comply with Item iii.

20 Victorian Government; Victorian Planning Provisions;

32


4.5 Defendable Space Plan

Figure 27 - Defendable Space Map.

33


5.BUSHFIRE HAZARD – SITE ASSESSMENT

This section of the report describes how the proposal responds to requirements of Clause 44.06 (Bushfire

Management Overlay) and Clause 53.02 (Bushfire Planning).

5.1 Bushfire protection objectives

The proposal is located within Pathway 1 in accordance with Clause 53.02-3 (2018) Dwellings in existing

settlements – Bushfire protection objective of the Glenelg Shire Planning Scheme, which specifies

requirements for bushfire design and construction measures to reduce the risk to life and property to an

acceptable level. This is in addition to Clause 52.47-1 objectives and approved measures.

Objective 52.47-1.1 Siting


Objective 52.47-1.2 Defendable Space and Construction



Objective 52.47-1.3 Water Supply and Access


34


5.2 Landscape, siting and design

Objective 52.47-1.1 Siting


Requirement

Bushfire protection can be enhanced by considering the separation of a dwelling from the bushfire

hazard, proximity to public roads and emergency service vehicle access on a site. Considering these

elements together supports the selection of an appropriate place to site a dwelling.

Each application can demonstrate that the best possible site for the dwelling is selected, even if there

are siting constraints, such as lot size. AM 1.1 can therefore be implemented on all sites.

AM 1.1 A building is sited to ensure the site best achieves the following:

• The maximum separation distance between the building and the bushfire hazard.

• The building is in close proximity to a public road.

• Access can be provided to the building for emergency service vehicles.

Response

• All siting options have been considered with potential for minor variation with advice from CFA and the

Responsible Authority.

• Existing cleared areas have been selected as site for proposed dwelling.

• The dwelling (footprint) has been sited to achieve BAL12.5 defendable space.

• The single dwelling will be provided with defendable space to property boundaries.

• The proposed development will immediate vehicle access to Blackers Road and escape pathways to

the south.

• Consult with property owners from the north through to the east to minimise exposure to the bushfire

hazard from neighbouring land

• The preferred siting options are detailed in the bushfire management statement.

• As the bushfire hazard is from three potential aspects, managed defendable space is maximised to

increase the separation distance on these sides of the building.

• Siting complies with neighbouring development and complies with local planning schemes and

building regulations.

Has Approved Measure AM 1.1 been fully met? Yes ✓ No ☐ Partially met ☐

35




The main feature is to consider defendable space around a structure that mitigates the effects of flame

contact, radiant heat and embers on buildings and to apply the corresponding construction standard

(referred to as a bushfire attack level).

Requirement

A building provides the defendable space in accordance with Column A, B, C, D or E of Table 1 to Clause 52.47-3.

Table 6 (BMO Technical Guide) sets out the vegetation management requirements within the defendable

space. Adjoining land may be included as defendable space where there is a reasonable assurance that the

land will remain or continue to be managed in that condition as part of the defendable space.

A building is constructed to the bushfire attack level:

• That corresponds to the defendable space provided in accordance with Table 1 to Clause 52.47-3, or

• The next lower bushfire attack level that corresponds to the defendable space provided in accordance with

Table 1 to Clause 52.47-3 where all of the following apply:

x A private bushfire shelter (a Class 10c building within the meaning of the Building Regulations 2006) is

constructed on the same land as the dwelling.

x A minimum bushfire attack level of BAL 12.5 is provided in all circumstances.

Response

• The building provides defendable space in a accordance with Column A, B, C, D or E of Table 1

to Clause 52.47-3.

• Adjoining land will not be relied upon as defendable space due to inability to guarantee

managed landscapes.

• AM 1.2 and Table 1 provided information for the choice of how much defendable space is

provided (the less defendable space provided the higher the construction standard and

associated cost).

• The applicable construction standard (bushfire attack level) has been applied.

• Table 1 (reading down the columns) was used to obtain the applicable bushfire attack level.

• Consideration was given to whether the next lower bushfire attack level is more appropriate

The bushfire attack level can never be lower than BAL 12.5 (basic ember protection).

Has Approved Measure AM 1.2(a) been fully met? Yes ✓ No ☐ Partially met ☐

36




Adjoining land can be ‘included’ as defendable space where it is managed in a condition that achieves

the same outcome as if it was managed and located on site.

A reasonable assurance however that the land will remain or continue to be managed in that condition as part

of the defendable space is required.

The bushfire hazard site assessment suggest reliance on adjoining land for defendable space requirements

cannot be guaranteed.

Requirement

The bushfire hazard site assessment should justify that any adjoining land meets the defendable space

requirements if this approved measure is included in an application.

Design suggestions include:

• Low-threat vegetation will often be suitable as off-site defendable space if it can be demonstrated that the

adjoining land will remain in that condition.

• If off-site defendable space can be justified the actual defendable space on that aspect is provided to the

property boundary of the site subject to the application.

• If adjoining land will be managed in future then a permit condition should require management to occur

before development commences.

• The bushfire management statement will need to provide evidence that the adjoining land will remain in that

condition.

Response

• Low-threat vegetation immediately surrounding the proposed house site will be included as

defendable space via owner ongoing and within-site landscape and vegetation management options.

• As off-site defendable space is not proposed to be utilised, defendable space to the property

boundaries to the north, west and south will not be part of defendable space calculations.

• If adjoining land will be managed in future, then a permit condition should require management to

occur before development commences. The bushfire management statement would need to be

modified and evidence provided that adjoining land will remain in that condition.

• Managed defendable space will only be on the land subject to the application.

Has Approved Measure AM 1.2(b) been fully met? Yes ✓ No ☐ Partially met ☐

37


Objective 52.47-1.3 Water Supply and Access


Once a site for a dwelling is selected the static water supply and vehicle access design and construction

standards can be applied.

A building is provided with water supply and access features such as:

• A static water supply for firefighting and property protection purposes specified in Table 4 to Clause

52.47-3. The water supply may be in the same tank as other water supplies provided that a separate

outlet is reserved for firefighting water supplies.

• Vehicle access that is designed and constructed as specified in Table 5 to Clause 52.47-3. Information

The bushfire hazard site assessment provides the information to respond to this approved measure.

Requirement

• Fire authority access and length of the access are the essential criteria to determine the applicable

requirements under AM 1.3. Table 4 and the Fire Authority Requirements set out the fittings and access

requirements. Further detail is provided in Section 7.6 of this report.

• Incorporating this approved measure simply involves:

-identifying the applicable requirements in the bushfire management statement

-showing the applicable requirements on the submitted plans.

Fire authority access to the water supply (if required) will be an important factor when considering where to site

the structure in AM 1.1.

• The water supply and vehicle access design and construction standards will be a condition on the planning

permit.

Response

• It is proposed that a minimum total capacity of 10,000L be provided as a dedicated static water

supply for firefighting and property protection purposes.

• Water tank(s) must be non-combustible and sited so that firefighting vehicles can get within 4m

of outlets.

• The water supply outlet must be located within close proximity of the dwelling. Fittings must be

in accordance with CFA requirements.

All internal roads must provide access in accordance with the following vehicle design and construction

requirements:

- All-weather construction and load limit of at least 15 tonnes.

- Provide a trafficable width of 3.5 metres and clear of encroachments for at least 0.5 metres on each side and at least 4 metres

vertically. Curves must have a minimum inner radius of 10 metres.

- The average grade must be no more than 1 in 7 (14.4%) (8.1°) with a maximum grade of no more than 1 in 5 (20%) (11.3°) for no

more than 50 metres. Dips must have no more than a 1 in 8 (12.5 per cent) (7.1 degrees) entry and exit angle.

- A turning area for fire fighting vehicles must be provided close to the building by one of the following: turning circle minimum radius

of eight metres.

Has Approved Measure AM 1.3 been fully met? Yes ✓ No ☐ Partially met ☐

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6. CONCLUSION

The single dwelling development proposal at Lot 2 Blackers Road Narrawong has been assessed against the

requirements of the Glenelg Shire Planning Scheme. The proposal typically requires the Clause 53.02-3

application Pathway One. The surrounding landscape has been assessed as having very high bushfire risk.

The site has potential to be impacted by a landscape scale fire approaching from the north, west or south and

east if topography and wind direction coincide to produce such a fire.

A fire from these directions would typically approach through grassland and patches of remnant vegetation,

driven by in the first instance hot, dry variable northerly winds which are then impacted typically by west south-

westerly wind change. The site is also in areas that incur coastal wind influence as can be seen from

assessment maps within this report.

While areas of grassland within the surrounding area may moderate the speed and intensity of the fire before it

impacts the subject site, under conditions typical of severe, extreme or code red days, the subject site is likely

to be impacted upon by ember attack.

Remnant core areas such as Mt.Clay State Park to the north and north-west are ever-present potential source

of high intensity fire approaching from this direction.

In accordance with the requirements of the Bushfire Management Overlay, the following applies:

− A minimum of 48 metres defendable space for classified Woodland to the east of the proposed dwelling

in accordance with Table 1 under Clause 53.02-3.

− A minimum of 100 metres defendable space for classified Grassland to west and south of the proposed

development in accordance with Table 1 under Clause 53.02-3.

− The proposed single dwelling is to be appropriately sited on a generally cleared and proposed highly

managed site, with defendable space from the bushfire threat accommodated, and constructed to

BAL12.5.

− Blackers Road immediately to the east of the lot provides direct access and egress for emergency

vehicles.

− A total (minimum) of 10,000 litres of static water supply will be provided onsite in an easily accessible

location, dedicated for personal use during an emergency.

− Site access will be upgraded if required to accommodate emergency vehicles in accordance with

requirements set out in Table 6 under Clause 53.02-3.

In light of the above, the proposal is considered to appropriately adhere to the requirements of the Bushfire

Management Overlay (if it applied to the proposed development site), ensuring risk to life and property have

been reduced to an acceptable risk.

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7. BUSHFIRE MANAGEMENT PLAN

7.1 Maintenance Schedule

Before the occupation of the building defendable space must be implemented on the land and thereafter

maintained as specified below:

- Grass must be short cropped and maintained during the declared fire danger period.

- All leaves and vegetation debris must be removed at regular intervals during the declared fire danger

period.

- Shrubs must not be located under the canopy of trees.

- Individual and clumps of shrubs must not exceed 5m² in area and must be separated by at least

5 metres.

- The canopy of trees must be separated by at least 5 metres.

- There must be a clearance of at least 2 metres between the lowest tree branches and ground level.

7.2 Additional requirements within 10 metre management zone:

- Within 10 metres of a building, flammable objects must not be located close to the vulnerable parts of

the building.

- Plants greater than 10 centimetres in height must not be placed within 3 metres of a window or glass

feature of the building.

- Trees must be trimmed to provide a minimum 10 metre clearance from the building.

- Trees must not overhang or touch any elements of the building.

Outside of the Bushfire Management Overlay, areas that are subject or likely to be subject to bushfire are included in the

Bushfire Prone Area designated under the Building Regulations 2006 (regulation 810).

There are three forms of bushfire attack:

• ember attack which occurs when small burning twigs, leaves and bark are carried by the wind

• radiant heat which can ignite houses and other assets

• flame contact involving burning vegetation directly touching a house or other asset.

Passive risk mitigation through location, spacing and alignment of group accommodation and/or by establishing a buffer

between the bushfire hazard and the development. The use of internal and perimeter roads, water bodies, and open

spaces managed in a minimal fuel state, are examples of effective buffers.

Buffer distances may be determined using AS3959-2018 Building in bushfire prone areas (Standards Australia).

The Australian Standard uses vegetation type and the slope of the land to determine minimum distances between a

bushfire hazard and new development.

A buffer distance equivalent to a bushfire attack level of 12.5 for new development should be used. Note that for land

subject to the Bushfire Management Overlay different buffer distances apply. The following examples illustrate approaches

that can be taken.

Where such approaches are adopted the bushfire risk should usually be considered to have been reduced to an acceptable

level.

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7.3 Static Water Supply Requirements

The building must be provided with a static water supply (minimum 10,000 litres) for property protection

purposes.

The water supply may be in the same tank as other water supplies provided that a separate outlet is reserved

for firefighting water supplies.

The water supply must be an above ground water tank constructed of concrete or metal.

All fixed above ground water pipes and fittings required for firefighting purposes made of corrosive resistant

metal.

7.4 Water tank requirements

The water supply should be stored in an above ground water tank constructed of concrete, steel, or corrugated

iron. The water supply should be identified.

Shared water tank Water supply identification

Figures 28 & 29 – Water tank and supply identification panels required (Source: CFA 2020).

7.5 Water supply outlet, pipe work and valves

Figure 30 – Water supply outlet, pipework, and valves (Source: CFA 2020).

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7.6 Access Requirements

Where the length of access is greater than 200 metres the following design and construction requirements apply:

- All-weather construction.

- A load limit of at least 15 tonnes.

- Provide a trafficable width of 3.5 metres.

- Be clear of encroachments for at least 0.5 metres on each side and at least 4 metres vertically.

- Curves must have a minimum inner radius of 10 metres.

- The average grade must be no more than 1 in 7 (14.4%) (8.1°) with a maximum grade of no more than 1 in 5

(20%) (11.3°) for no more than 50 metres.

- Dips must have no more than a 1 in 8 (12.5 per cent) (7.1 degrees) entry and exit angle.

- A turning area for fire fighting vehicles must be provided close to the building by one of the following:

- A turning circle with a minimum radius of eight metres.

- A driveway encircling the group accommodation.

- The provision of other vehicle turning heads - such as a T or Y head - which meet the specification of

Austroad Design for an 8.8 metre Service Vehicle.

Width Dips and gradients Encroachments

Figures 31 & 32 – Access and encroachment dimensions (Source: CFA 2020).

42


8. OWNERS OBLIGATIONS

There are a range of obligations of the landowner. It is important that the landowner is aware of these obligations and

understand what is required to ensure ongoing compliance.

1. Bushfire Attack Level (BAL) Rating and Construction Requirements

Buildings and works to the land must be developed within building envelopes and constructed to a minimum BAL 12.5.

2. Vegetation Management and Defendable Space

The following management prescriptions must be applied and maintained in all areas nominated as ‘defendable

space’:

Within 10 metres of a building, flammable objects such as plants, mulches and fences must not be located close to

the vulnerable parts of the building such as windows, decks and eaves.

Trees must not overhang the roofline of the building, touch walls or other elements of a building.

Grass around properties should be kept short. Five centimeters or less is considered short. All leaves and vegetation

debris must be removed at regular intervals.

Shrubs should not be planted under trees.

Plants greater than 10 centimetres in height at maturity must not be placed directly in front of a window or other

glass feature.

Tree canopy separation of two metres and overall canopy cover of no more than 15 per cent at maturity.

3. Water supply construction and maintenance requirements

Onsite static water supply is required to be installed and must be designated solely for firefighting purposes (and may

incorporate use of the dam within the east and at the highest elevation within the site).

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APPENDIX 1 – SITE DEVELOPMENT FEATURE SURVEY

44


APPENDIX 2 – LANDSCAPE SCENARIOS – LANDSCAPE ASSESSMENT21

Broader Landscape Type

One


Two


Three


Four

- There is little vegetation

beyond 150 metres of

the site (except

grasslands and low-

threat vegetation).

- Extreme bushfire

behaviour is not

possible.

- The type and extent of

vegetation is unlikely to

result in neighbourhood-

scale destruction of

property.

- Immediate access is

available to a place that

provides shelter from

bushfire.


vegetation located more

than 150 metres from

the site may result in

neighbourhood-scale

destruction as it

interacts with the

bushfire hazard on and

close to a site.

- Bushfire can only

approach from one

aspect and the site is

located in a suburban,

township or urban area

managed in a minimum

fuel condition.

- Access is readily

available to a place that

provides shelter from

bushfire. This will often

be the surrounding

developed area.


vegetation located more

than 150 metres from

the site may result in

neighbourhood-scale

destruction as it

interacts with the

bushfire hazard on and

close to a site.

- Bushfire can approach

from more than one

aspect.

- The site is located in an

area that is not managed

in a minimum fuel

condition.

- Access to an appropriate

place that provides

shelter from bushfire is

not certain.

- The broader landscape

presents an extreme

risk.

- Evacuation options are

limited or not available.

INCREASING RISK

APPENDIX 3 – BUSHFIRE ATTACK LEVELS

BAL levels explained (Source: Victorian Building Commission 2019).22

21 Myers Planning 2020 from Former Planning Practice Note 65, DTPLI, 2014. 22 Victorian Building Authority 2019; Bushfire Assessment Levels Explained; Accessed from: https://www.vba.vic.gov.au/consumers/bushfire-protection

https://www.vba.vic.gov.au/consumers/bushfire-protection

45


Defendable Space Requirements (Source: Victorian Building Commission 2019).23

23 Victorian Building Authority 2019; Bushfire Assessment Levels Explained; Accessed from: https://www.vba.vic.gov.au/consumers/bushfire-protection

https://www.vba.vic.gov.au/consumers/bushfire-protection

46


Documents

Client: Coast to Country Planning Project: Bushfire Management … · 2020-03-26 · Group for a development proposal at Lot 2 Blackers Road Narrawong, Victoria. The planning permit