28 May 2014 Mr Regan Travers Shire of Serpentine Jarrahdale 6

OCM003.1/07/14
Our Ref P13011-DN14193
Contact: Dylan Niblett
28 May 2014
Cardno (WA) Pty Ltd
ABN 77 009 119 000
Mr Regan Travers
Shire of Serpentine Jarrahdale
6 Paterson Street
Mundijong, WA, 6123
Dear Regan
SCHEME AMENDMENT 189 – LOT 304 HARDEY ROAD - CLARIFICATION REGARDING
PROPOSED VEGETATION RETENTION MEASURES
Following our telephone conversation on Tuesday 29 April 2014, this letter is provided to clarify
the proposed measures to retain remnant indigenous vegetation on Lot 304 Hardey Road,
Serpentine, (herein referred to as ‘the site’) as contained within the Scheme Amendment Report
and the accompanying Subdivision Guide Plan (SGP).
Scheme Amendment 189 proposes to rezone the site from ‘Rural’ to ‘Rural Living A’ under the
Shire of Serpentine Jarrahdale Town Planning Scheme No. 2 (TPS 2) and identify the site as
‘RLA 29’ on the appropriate Scheme Map. A SGP was provided as Appendix A in the Scheme
Amendment Report (‘the report’). The SGP proposes the creation of seven rural residential lots,
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each 4000m or greater. The SGP is consistent with the pattern of existing development within
the locality and will preserve the rural character and amenity of the area.
Existing vegetation
A flora survey was undertaken by a qualified botanist and confirmed the vegetation condition on
site as being ‘Completely Degraded (Category 6)’ as per the Keighery (1994) Vegetation
Condition Scale. The ‘Completely Degraded (Category 6)’ condition can be described as:
‘Structure of the vegetation is no longer intact. Often described as Parkland cleared, with flora
comprising weed or crop species with isolated native trees or shrubs.’
The flora survey also included a significant tree survey which identified the location of trees that
may be used for breeding, foraging or roosting by Black Cockatoo species, as classified by the
Referral Guidelines for ‘Three Threatened Black Cockatoo Species’ (SEWPaC, 2012c). The
location of these trees, proposed lots and indicative building envelopes were mapped accordingly
and included as Figure 7 in the Scheme Amendment Report (Attachment 1). The indicative
building envelope locations in this attachment are as per the submitted SGP. The findings of the
significant tree survey are detailed in Section 5.4.4 of the report.
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OCM003.1/07/14
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The significant tree survey identified the following number of species present on site:
> She-oak (x95);
> Jarrah (x7); and
> Marri (x10).
Proposed measures to retain identified significant trees and revegetate within lots
Taking into account the findings of the flora survey and the significant tree survey, the proposed lot
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configurations and the indicative building envelopes (each 1000m ) as shown on the SGP, seek to
optimise the retention of significant trees within each lot. Furthermore, the report includes scheme
provisions for the site which are proposed to be included within TPS 2. A number of these provisions
serve to preserve, manage and introduce vegetation over the site at various stages of the development
process. Attachment 2 provides an overview of the measures proposed to preserve remnant indigenous
vegetation on site, and also revegetate within individual lots.
Control over the retention of existing indigenous vegetation throughout the development process
The following provides a discussion of the proposed Scheme provisions identified in Attachment 2.
Proposed Scheme Provision 3:
This provision is applicable to the site throughout the development process and will remain in effect after
the transfer of ownership of the proposed lots to new land owners. This provision is considered to be a
robust mechanism which prevents the unnecessary loss and/or destruction of remnant indigenous
vegetation and trees, and will apply to ‘RLA 29’ until such time as the Scheme is amended accordingly or
revoked.
Proposed Scheme Provision 4:
The provision will require the location of the building envelopes to be confirmed prior to the clearance of
subdivision conditions and the construction of dwellings within individual lots. The ultimate location of the
building envelopes will take into account the indicative locations identified by the SGP and will have due
regard to the location of identified significant trees throughout the site. The envelopes will be
appropriately sited to optimise the retention of significant trees as far as practicable. The final building
envelope locations will also take into account geotechnical information relating to the site.
It is important to note that buildings will not occupy the entire building envelope. As such, appropriately
siting buildings within the building envelopes can minimise disturbance to existing vegetation.
Proposed Scheme Provisions 5 and 6:
Provision 5 requires a Vegetation Master Plan to be prepared and implemented at the subdivision stage.
A Vegetation Master Plan has been prepared for the site (Appendix D of the report) and identifies a
location within each proposed lot for the purposes of revegetation. A 3m wide revegetation strip is
proposed to be planted at the rear of each lot. These areas will be planted with indigenous tree and
shrub species, such as Allocasuarina fraseriana (She-oak), Corymbia Calophylla (Marri) and Eucalyptus
marginata (Jarrah), which already exist on site. The revegetation will assist in offsetting any potential
disturbance to significant trees, given the replanting will utilise the same species as those which may be
affected. This is important in ensuring that there is an ongoing habitat for local fauna, such as Black
Cockatoo species.
As per Provision 6, the subdivider will be required to maintain the revegetation in accordance with the
Vegetation Master Plan until the land is sold, or is to plant a sufficient number of plants to allow for a
OCM003.1/07/14
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natural loss. After the time of sale, the new owners are responsible for managing the revegetation within their
lots. It is considered that the proposed development of the site may inspire positive impacts such as the
revegetation of previously neglected areas, with the aspiration that landowners will seek to maintain the
vegetation within their lot.
Proposed Scheme Provision 7:
The provision requires a Fire Management Plan to be prepared and implemented at the subdivision stage, to
the specification and satisfaction of Council and the Department of Fire and Emergency Services. The FMP
will identify appropriate fire management requirements for each of the lots, including the treatment of land
within a Building Protection Zone (BPZ).
It is acknowledged that a 20m wide BPZ (as measured from the external wall of a building) is an accepted
standard under the Planning for Bush Fire Protection Guidelines (Edition 2, 2010). However, it is important to
note that the BPZ does not require all trees within it to be cleared. Attachment 3 is an extract from the DFES
Prepare, Act, Survive publication which illustrates recommended precautions within a BPZ. The BPZs will be
a controlled environment with low ground fuel loads and manicured landscaped areas, to reduce the fire risk
of the lot. A BPZ is typically installed on an individual lot prior to any new dwelling/building being constructed
and forms part of the Building License approval.
While trees are not permitted to overhang or be within 2m of a building, existing tees may be preserved
within the BPZ so long as they are pruned to at least a height of 2m above ground level. Given this, it is
highly likely that existing significant trees will be able to be retained within a lot’s BPZ. Contrary to the EPA
submission on the proposed amendment, the BPZ is not simply a 20m cleared area around all buildings.
Proposed Scheme Provision 8:
The provision requires a site plan for each lot to be submitted with an application for a building licence, prior
to the construction of any buildings. The site plan is to be to the specification and satisfaction of the Council
and is to show the topography of the lot, the proposed location of the building pad, approved revegetation
areas, existing trees and stands of vegetation, trees and vegetation to be removed and retained and
proposals for tree planting and maintenance.
The Building Envelopes and Effluent Disposal Envelopes Plan required by proposed Scheme Provision 4,
will inform the preparation of the site plan.
The site plan will control the clearing and retention of trees and remnant vegetation by the purchaser of the
lot.
The management of remnant vegetation within lots at the building approval stage is considered to be the
‘final step’ in the development process and is important in ensuring that the proposed development is
consistent with the instruments in place to retain vegetation (i.e. Vegetation Master Plan and Building
Envelopes and Effluent Disposal Envelopes Plan). The site plan is an important tool in achieving a desirable
outcome in terms of maximising the retention of significant trees and indigenous vegetation within lots.
Alternative indicative building envelopes
As per our telephone conversation on 29 April 2014, further consideration has been given to the location and
shape of the indicative building envelopes within the lots, in order to optimise the retention of significant trees
within the site. Two alternatives to the indicative building envelopes identified on the SGP (identified in
Attachment 1) are described below.
It is important to note that the indicative building envelopes shown on the SGP are generally in accordance
with the setback requirements of TPS 2, being 20m from the primary street boundary and 10m from adjoining
lot boundaries. The alternatives have been formed on the basis that the setback requirements of TPS 2 can
be relaxed in order to assist in retaining on-site vegetation.
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The alternatives demonstrate that the indicative building envelopes as per the SGP could be refined to
optimise the retention of trees on-site. Table 1 provides a comparative overview of the options in terms of
retaining She-oak, Marri and Jarrah tree species.
Table 1
Total number of species located within the building envelopes
Trees species
Subdivision Guide Plan
Alternative A
Alternative B
Allocasuarina fraseriana (Sheoak)
23
10
17
Corymbia Calophylla (Marri)
2
0
0
Eucalyptus marginata (Jarrah)
0
1
0
Note: The Significant Tree Survey identified 95 She-oak, 7 Jarrah and 10 Marri trees present on site.
Alternative A
Alternative A is provided as Attachment 4. This option modifies all of the indicative building envelopes shown
on the SGP. This option could retain the highest number of trees, although a Jarrah tree is located within the
building envelope of proposed Lot 130. It is noted that there are only seven Jarrah trees present on site. The
indicative envelopes shown on proposed Lots 127 and 129 have been modified to avoid potential
disturbance to the Marri trees which were previously located within these envelopes, as per the SGP.
Alternative B also adopts this approach to retain the Marri trees.
Alternative B
Alternative B is provided as Attachment 5. Alternative B modifies five out of the seven indicative building
envelopes. This option seeks to retain all the Jarrah trees on site. As shown on proposed Lot 130, the Jarrah
trees have been retained although this has influenced the shape of the building envelope, resulting in more
She-oak being located within the envelope relative to Alternative A.
Conclusion
The proposed Scheme provisions to be incorporated within TPS 2 (outlined in Attachment 2) will provide an
effective strategy to retain remnant vegetation within the proposed lots. The SGP identifies indicative building
envelopes which serve as a guide as to where the final building envelopes could be located.
As demonstrated by the two alternatives discussed, there is scope to refine the indicative building envelope
locations at the subdivision stage in order to optimise the retention of significant trees within the proposed
lots. The two alternatives provide an indication of how this could be achieved. As per proposed Scheme
Provision 4, a Building Envelopes and Effluent Disposal Envelopes Plan will confirm the location of the
building envelopes, prior to the clearance of subdivision and the construction of buildings within individual
lots.
Trees of importance to Black Cockatoo species can be retained by appropriately locating buildings within the
building envelopes. Significant trees may exist within a BPZ, given appropriate actions are undertaken to
reduce ground fuel loads and to reduce the risk of trees as a potential fire source. Therefore, the majority of
the identified significant trees may be retained on site as per the methods discussed herein, and will not
require a reconfiguration of and/or provision of fewer lots.
It is therefore respectfully requested that the Shire endorse the proposal to amend TPS 2 to rezone the site
from the ‘Rural’ zone to the ‘Rural Living A’ zone, without modification. It is also requested that the SGP for
the site be endorsed by the Shire as part of the Amendment process.
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Yours faithfully,
Dylan Niblett
Town Planner
for Cardno
Telephone: 9273 3888
Email: [email protected]
Att: 5 x Figures
OCM003.1/07/14
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Attachment 1: Indicative building envelope locations as per the submitted SGP.
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Attachment 2: Proposed measures to preserve and replace on-site vegetation.
OCM003.1/07/14
Attachment 3: Department of Fire and Emergency Services - Prepare, Act, Survive (Version 4, 2012, page 31).
OCM003.1/07/14
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Attachment 4: Alternative A
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Attachment 5: Alternative B

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