170634 – Lot 101 Balcatta Road BERP ©2017 BPP Group Pty Ltd Page | 24

Appendix 5

Information – Bushfire Warning System -Situational Awareness

Further details on the DFES Bushfire Warning System Alert Levels are presented on the followingpage.

Where possible, continually monitor the DFES website for emergency alerts, warnings and updates.

The link is https://www.emergency.wa.gov.au/

DFES Information Line 1300 657 209

DFES Alerts on ABC local radio

DFES Emergency Telephone Alerts: All landline and mobile telephone numbers (including silentnumbers) are automatically registered to receive warning messages based on their billing address.

170634 – Lot 101 Balcatta Road BERP ©2017 BPP Group Pty Ltd Page | 25

ERINDALE

RD

ERINDALE

RD

CRES

SALL

RD

BALCATTA RD

CORB

USIER

PL

MACA

DAM

PL

BALCATTA RD

BALCATTA RD

MUMFORD PL

BALCATTA RD

REID HWY

BALCATTA RD

MUMFORDPL

1 0 11 0 1

____________ LEGEND ____________

Lot 101Buildings

Proposed Expansion Area®v Hydrant

0 10 20 30 40 50

Metres

____________ SCALE (A3) ____________

Disclaimer and Limitation: This map has been prepared for bushfire management planning purposes only. All depicted areas, contours and any dimensions shown are subject to survey. Bushfire Prone Planning does not guarantee that this map is without flaw of any kind and disclaims all liability for any errors, loss or other consequence which may arise from relying on any information depicted.

Map created on: 5/12/2017

B A L G AB A L G AC A R I N EC A R I N E

W A N G A R AW A N G A R A

PERTHROADBOARD

NORTH BEACH

SORRENTO

KARRINYUP

MARMION

TRIGG

WHITFORD

WATERMANHAMERSLEY

__________ LOCALITY __________

p

Lot 101 Balcatta Road, BalcattaBunnings Warehouse

Aerial Image: Landgate 2017

Coordinate System: GDA 1994 MGA Zone 50Projection: Universal Transverse Mercator

Map compiled by: Mick Whitelaw

Option 2 - Southern EvacuationLeisure Park Scarborougha

Option 1 - Eastern EvacuationLeisure Park Balga a

Appendix 6Site Response Map

Contact Phone #Emergency 000

DFES 13 33 37City of Stirling 9205 8555City of Stirling 9205 8555City of Stirling 1300 365 356

Nearest Evacaution CentreLeisure Park Balga

Princess Road, Balga b

MITCHELL FWY

MITCHELL FWY

MITC

HELL

FWY

REID HWYREID HWY MI

TCHE

LLFW

Y

WANNEROO RD

MITCHELL FWY

MITCHELL FWY

MITC

HELL

FWY

M ITC

HELL

FWY

NORT

H BE

ACH

RD

NORTHBEACH

RD

ERINDALE RD

ERIN

DALE

RD

AMELIA ST

BALCATTA RD

BEACH RDBEACH RD

ARKAN

ARD

BALGAAV

ERIN

DALE

RD

AMELIA ST

GIRR

AWHE

ENAV

PRIN

CESS

RD

BEACH RDBEACH RD

AMELIA ST

PRIN

CESS

RD

NORTH BEACHRD

BEACH RD

BEACH RD

AMELIA ST

ERINDALE RD

MAIN

ST

BALCATTA RD

ERIN

DALE

RDER

INDA

LE R

D

PRINCESSRD

ODIN

DR

CEDR

ICST

CEDR

ICST

1 0 11 0 1

____________ LEGEND ____________

Lot 101Evacuation Readiness Zone (1km)Bushfire Awareness Zone (2km)

0 250 500 750 1,000

Metres

____________ SCALE (A3) ____________

Disclaimer and Limitation: This map has been prepared for bushfire management planning purposes only. All depicted areas, contours and any dimensions shown are subject to survey. Bushfire Prone Planning does not guarantee that this map is without flaw of any kind and disclaims all liability for any errors, loss or other consequence which may arise from relying on any information depicted.

Map created on: 5/12/2017

L E X I AL E X I A

PERTHROADBOARDNORTH BEACH

SORRENTO

KARRINYUP

MARMION

TRIGG

WHITFORD

WATERMANHAMERSLEY

PERTH

BAYSWATER

__________ LOCALITY __________

p

Lot 101 Balcatta Road, BalcattaBunnings Warehouse

Aerial Image: Landgate 2017

Coordinate System: GDA 1994 MGA Zone 50Projection: Universal Transverse Mercator

Map compiled by: Mick Whitelaw

Bunnings WarehouseBalcatta a

Option 1 - Eastern EvacuationLeisure Park Balga a

Bushfire Response Zones MapAppendix 7

Contact Phone #Emergency 000

DFES 13 33 37City of Stirling 9205 8555City of Stirling 9205 8555City of Stirling 1300 365 356

Nearest Evacaution CentreLeisure Park Balga

Princess Road, Balga

Level 1, 50 Subiaco Square Road, Subiaco, WA 6008 P.O. Box 243, Subiaco, WA 6904 Phone: (08) 9380 3100 Fax: (08) 9380 4606

177 Spencer Street, Bunbury, WA 6230 P.O. Box 287, Bunbury, WA 6231 Phone: (08) 9792 4797 Fax: (08) 9792 4708

Email: info@strategen.com.au Web: www.strategen.com.au ABN: 32 056 190 419

Giselle Alliex Senior Planning Officer City of Stirling 25 Cedric Street STIRLING WA 6021 Our reference: CST18014.01

Dear Giselle,

REVIEW OF “BUSHFIRE MANAGEMENT PLAN (DEVELOPMENT APPLICATION – BUILDING ADDITION): LOT 101 BALCATTA ROAD, BALCATTA (BUNNINGS)” AND ASSOCIATED “BUSHFIRE EVACUATION (RESPONSE) PLAN”

Please find below results of Strategen’s review of the abovementioned reports as requested. The Bushfire Management Plan (BMP) and associated Bushfire Evacuation (Response) Plan (BERP) were lodged to accompany a Development Application (DA) relating to a proposed building addition to the existing Bunnings Warehouse situated at Lot 101 Balcatta Road, Balcatta in the City of Stirling.

Strategen’s comments and recommendations are based on a desktop review. Should site inspection be required to further validate on-ground conditions, Strategen can undertake this task at the City’s request.

Overview of the planning proposal

The DA aims to facilitate extension of the existing Bunnings Warehouse located at Lot 101 Balcatta Road, Balcatta in the City of Stirling. The DA represents proposed development intensification in a designated bushfire prone area and a BAL-FZ rating was confirmed through site assessment. This triggers the following bushfire planning requirements under State Planning Policy 3.7 Planning in Bushfire Prone Areas (SPP 3.7). 1. Policy Measure 6.7 of SPP 3.7 in relation to DAs proposed in areas of BAL-40 or BAL-FZ.

• planning approval can only be granted when the proposal constitutes minor or unavoidable development and the BMP adequately justifies a deviation from standard compliance with the bushfire protection criteria in accordance with requirements under Policy Measures 6.7.1 (for minor development) or 6.7.2 (for unavoidable development).

2. Policy Measure 6.6.2 of SPP 3.7 in relation to vulnerable or high-risk land uses proposed in areas of BAL-40 or BAL-FZ. • proposals must comply with Policy Measures 6.6.1 and 6.7.2 • Policy Measure 6.6.1 requires the following:

if the proposal is classified as a vulnerable land use, a bushfire emergency evacuation plan must be prepared for proposed occupants

if the proposal is classified as a high-risk land use, a bushfire risk management plan must be prepared for any flammable on-site hazards.

It is Strategen’s opinion that application of these policy measures has not been adequately conveyed in the BMP.

Page 2

General comments – Bushfire Management Plan

1. Strategen considers the site assessment outlined in Section 5 of the BMP, as well as the subsequent maps depicting classified vegetation, effective slope and BAL contours, are acceptable and meet relevant requirements under Guidelines for Planning in Bushfire Prone Areas (the Guidelines).

2. The resulting BAL-FZ determination triggers Policy Measure 6.7 of SPP 3.7. This requires that the proposal demonstrate compliance with either minor (Policy Measure 6.7.1) or unavoidable development (Policy Measure 6.7.2).

3. With regards to assessment against the bushfire protection criteria outlined in Section 7.1 of the BMP, Strategen considers that the proposed development does not comply or meet the intent of Element 1 (Location) and Element 2 (Siting and Design of Development), and their corresponding Acceptable Solutions, based on the assessed BAL-FZ rating and inability to achieve or create the necessary separation distance or Asset Protection Zone (APZ) required for the proposed building to comply with a BAL-29 rating or lower. The BMP acknowledges these non-compliances with the Acceptable Solutions, and this is stated several times in the BMP.

4. Strategen considers that where compliance with Acceptable Solutions of the Guidelines cannot be met, in addition to justifying either minor or unavoidable development, an appropriate performance-based Alternative Solution is required to demonstrate compliance with the performance principle and intent for each Element where deviation is proposed. Application of an appropriate Alternative Solution has not been adequately conveyed in the BMP to demonstrate how compliance will be achieved with the performance principle and intent for Elements 1 and 2.

5. Strategen acknowledges that building construction standards for the proposed building addition do not need to formally comply with AS 3959 under the National Construction Code due to the proposed building class being Class 4 – 9, and not Class 1, 2, 3 or associated 10a.

6. Strategen has interpreted from the BMP that irrespective of the above, the recommendation is for the proposed building extension to be constructed to a BAL-FZ standard in an attempt to mitigate the potential radiant heat flux. However, based on the information provided in the BMP, Strategen is not able to accurately assess this approach as there is insufficient justification provided for the Alternative Solution based on the following: (a) the BMP does not provide any detailed modelling (including Method 2 BAL calculation

if required) or discussion about the anticipated bushfire behaviour and scenarios (b) the BMP does not provide any justification as to why building to a BAL-FZ standard of

construction is appropriate in this instance including demonstration that the assessed radiant heat flux is manageable through the proposed BAL-FZ building construction response. It also is not clear whether the proposed building materials and landscape yard is to be constructed to BAL-FZ or not

(c) the BMP does not discuss any of the existing or proposed building systems or features that may complement the bushfire management measures such as on-site fire hydrant and sprinkler systems or occupant warning systems

(d) the BMP does not explore any viable options for modified building location, siting or design to restore compliance with acceptable solutions under Element 1 and Element 2. Strategen understands there may be valid reasons for the non-compliance, however these are not stated in the BMP

Page 3

(e) the BMP does not discuss any scope for vegetation clearing, firebreak construction, landowner management or fuel modification to achieve an appropriate level of separation/APZ and restore compliance with acceptable solutions under Element 1 and Element 2. Strategen understands this may not be possible given the tenure of the adjacent lot, but little discussion on this is provided.

7. Given development in BAL-FZ areas is typically not supported through the WA planning process, which is contrary to SPP 3.7 policy requirements and Guideline Acceptable Solutions, due to the increased level of risk associated with placing life and property in these areas. It is incumbent on the proponent to provide clear justification for the proposed Alternative Solutions, therefore in the absence of a clearly defined Alternative Solution, Strategen is unable to accurately assess whether the proposed development in BAL-FZ is a safe/appropriate response to the bushfire risk.

8. Strategen considers the proposal complies with acceptable solutions for Element 3 Vehicular Access and Element 4 Water, as discussed in Section 7.1 of the BMP.

9. The BMP references provision for an APZ in Section 7.3 and Section 10.1; however, the actual alignment and width of the APZ is not provided, nor is the APZ depicted on any figure. It is not clear whether the proposed building materials and landscape yard are within the APZ and whether they comply with APZ requirements. Strategen also notes that Section 7.3 includes old guidance no longer applicable with regards to hazard separation zones and minimum APZ widths of 20 m. This information should not be included in the BMP if it is not applicable to the proposal or bushfire management response, or is no longer in accordance with the Guidelines.

10. Current Guidelines dictate that commercial land uses and general places of assembly are no longer deemed to be vulnerable land uses. On this basis, Strategen would not classify this development to be a vulnerable land use, thus the BERP would not be required to accompany the DA. The BERP might still be relevant as part of justification for a performance-based Alternative Solution; however, the BMP is not clear as to whether this is the case.

11. Based on previous experience with other Bunnings Warehouses, Strategen considers the proposed development would likely be a high-risk land use due to the potential for on-site storage of flammable materials, such as timber, paint, oil, chemicals and other combustibles. If it were classified as high-risk, in accordance with Policy Measure 6.7.1 the BMP must be accompanied by a bushfire risk management plan outlining how flammable on-site hazards will be managed. A bushfire risk management plan has not been included with this BMP.

General comments - Bushfire Evacuation (Response) Plan

12. As mentioned above, Strategen does not consider the proposed development to constitute a vulnerable land use and therefore does not believe a BERP is required to satisfy Policy Measure 6.6.1. It may be required for an Alternative Solution; however, this is not clearly articulated.

13. The ‘Key Site Information’ provides occupant numbers; however, there is little further information defining the occupant characteristics (physical and mental ability, children, disabled occupants, staff numbers, etc), other than there will be no overnight occupancy. Reference should be made to the occupants’ ability to evacuate by their own transport. There is also no information on any relevant building features, such as warning systems. Additionally, this table indicates there are no hazards on site, which is not accurate given the presence of flammable materials at the site.

Page 4

14. Information provided on the roles and responsibilities of the facility personnel could be more well-defined, especially as it may be these personnel required to manage the emergency in the initial stages.

15. Regarding the on-site assembly point, it may be more appropriate to locate this assembly point outside of the BAL-12.5 contour to a location on site that is in BAL-Low. This is not always possible for all developments; however, in this case, there are locations to the south of the site that are outside BAL-12.5 that may be more appropriate.

16. The off-site evacuation centre at Stirling Leisure Centre for the southern evacuation route is 7-8 km from the site. If a southern evacuation route is required, closer sites exist that would be more suitable. Additionally, this evacuation centre is not depicted on Appendix 7.

17. Other than the above, Strategen considers the evacuation and response provisions documented in the Bushfire Evacuation Plan to be compliant with requirements of the Guidelines.

18. Strategen considers that provision of suitable emergency evacuation for future building occupants should be a key consideration of any performance-based Alternative Solution for this proposal; however, the BERP does not adequately justify the siting of future life and property within BAL-FZ areas without proper consideration of additional response mechanisms (as discussed under Item 6).

Recommendations

The DA proposal is contrary to the intent of SPP 3.7 and Guideline Acceptable Solutions in that development is proposed in areas of BAL-FZ. Strategen does not consider that the BMP justifies the development as either minor or unavoidable development, nor does it adequately address the non-compliances through Alternative Solutions that clearly demonstrate that measure proposed provide a safe bushfire management outcome for future life and property assets.

For the proposal to be progressed and potentially approved by the relevant authorities, one or a combination of the following would need to be further considered: 1. Strategen does not consider the proposal to be minor development on the basis that it is

not residential development; however, the proponent may wish to seek clarity from DoPLH and/or DFES as to whether flexibility could be granted in this instance to enable this proposal to be considered as minor development (suitable justification would need to be provided). There are no guarantees of a successful outcome with this approach; however, if resolved on this basis, the planning proposal may be progressed in accordance with Policy Measure 6.7.1.

2. Provide a comprehensive performance-based Alternative Solution that explores those options referenced under Item 6 to properly address non-compliances with Element 1 and Element 2. Any Alternative Solution would need to clearly demonstrate compliance with the performance principles and the intent of both Elements.

3. Clarify the intent of the BERP with respect to the Alternative Solutions and amend as required, including any relevant comments in Items 13 -16 above.

4. Prepare a bushfire risk management plan outlining how flammable on-site hazards will be managed in accordance with Policy Measure 6.7.1, should the development be deemed a high-risk land use.

Page 5

Please feel free to contact me on 9380 3100 or at l.wears@strategen.com.au should you have any queries on the information contained in this letter.

Yours sincerely

Linden Wears SENIOR CONSULTANT

1 February 2018

cc: Roger Banks, Zac Cockerill