1. Location
Location is a permanent, proven and increasingly dangerous Extreme Bushfire Zone, with the Shire of Mundaring rated Australia’s 5th highest-at-risk-of-bushfire Shire. (CSIRO and Australian Bureau of Meteorology’s State of the Climate Report 2018)

2. Bushfire evacuation
This Bushfire Evacuation Plan relies 100% on the unplanned, non-existent, un-committed-to, East Link highway. The developer holds an unsubstantiated assumption that this Highway will be financially committed to by Federal and State Governments - and their taxpayers, and that it will be completed by ‘2038’. A non-existent highway that ‘might’ - or might not - be finished in 2038, or even started at all, cannot be upheld by the WAPC as ‘orderly and proper planning’ - when lives depend on the outcome - and SPP 3.7’s primary objective is the ‘primacy of life.’

3. East Link dependency
Further, East Link cannot be considered because the State Government has committed to undertaking strategic planning for Westport (Kwinana), as recommended by Infrastructure WA. Westport which has a reliance on rail, not road, as the preferred freight option. No such strategic planning is underway, being recommended or planned for East Link which also requires an 80% Federal funding commitment and Infrastructure Australia approval. The Govt intends Westport to become the State’s future freight network - rendering the notion of East Link superfluous and outdated to the State’s needs.

4. Omission of important simulation data
Satterley’s Bushfire Simulations omit the most dangerous and prevalent bushfire wind directions and highest fire danger from the west and from the east. The 2014 Stoneville-Parkerville-Mt Helena Bushfire started on a westerly wind with 57 homes destroyed. The 2021 Wooroloo Bushfire started with howling easterlies and destroyed 87 homes.

5. Unrealistic ember attack risk
Ember attacks can result in spot fires 3.5 kms or more ahead of the main bushfire front as was experienced and recorded during the 2021 Wooroloo bushfire. In the Satterley bushfire simulation modelling spotting of only 500 m was used. This severely limits the predicted speed of advance of the bushfires simulated in the modelling and creates the illusion that there is more time to evacuate an area.

6. Unrealistic bushfire speeds used
Satterley’s Bushfire Simulations feature an unrealistic travelling speed (60kph) during a bushfire emergency and ignore ALL bushfire evacuation impacts such as tight, winding rural roads with loose-gravel sidings, bushfire smoke, road reserves on fire, burning embers reigning down, panicked drivers, accidents, fallen trees and powerlines blocking roads, slow moving vehicles towing horse floats, trailers and caravans, loose livestock / horses on roads, emergency vehicles accessing / leaving under emergency conditions

7. Unrealistic evacuation speeds assumed
Satterley’s Bushfire Simulations are based on a completely unrealistic and dangerous expectation of a 60-kph travelling speed for rural Stoneville Rd and Roland Rd, (and in the absence of any noted constraints in Point 5), while ‘NO EFFECT’ is noted for potential traffic speeds on Great Eastern Highway (GEH) or Toodyay Rd - meaning - zero expectations for road diversions, detours, closures, blockages, slow moving traffic, accidents, traffic congestion, traffic gridlock or bushfire conditions of any description.

8. Simulations exclude trucks, horse floats, caravans
There is no evacuation simulation for either all, or parts, of Stoneville and / or Roland Roads - the two main internal rural roads leading to GEH or Toodyay Rd, (or the non-existent East Link), being closed, deviated, detoured, congested, gridlocked, or inaccessible because of dangerous bushfire conditions. Only cars (travelling 60 kph) are in the evacuation simulations - no trucks, trailers, caravans or vehicles towing horse floats, despite representing a large local traffic proportion in this region.

9. Massive underestimation of emergency vehicle access
Major under-estimations of emergency vehicles: Satterley’s Bushfire Management Plan (Traffic Modelling) allows for only TWO emergency vehicles to be included for each of their traffic modelling zones (13 zones). In contrast: 500 firefighters and 95 emergency vehicles attended Wooroloo Bushfire in the first three hours- AFAC Independent Operation Review. That bushfire burnt 11,000 hectares. On March 21, 2023 - 11 firefighting crews were required to battle a 6-hectare blaze in Star Swamp North Beach.

10. Assumes everyone leaves in timely manner
The evacuation modelling assumes ‘all residents will evacuate in a timely manner’ and no one stays to defend their home. Evidence refutes that assumption showing approximately many residents up to 30-40% stay and defend their property. That could mean 1200 North Stoneville people remain on-site during a full-scale bushfire emergency.

11. Evidence shows evacuations aren't timely
The scientific evidence shows in reality evacuation often takes place at the last minute as the fire front arrives—forcing people out into the most intense part of the fire. In addition, some people refuse to go, others are simply missed by the evacuation order, while others will attempt to go back into the fire-affected area to save their pets, children and properties.

12. Aerial water-bombing is not a reliable defence option
Aerial water-bombing is not capable of successfully defending North Stoneville. Aerial water-bombing (including the Boeing 737 FW-LAT) has a 2000 kW m-1 threshold capacity. An Extreme or Catastrophic level bushfire in North Stoneville will generate above that threshold. For example - the intensity of the 2008 Stoneville Bushfire - which started on the actual site of this planned development - and is AGAIN omitted and ignored from Satterley's plans, was measured at 7000 kW m-1, which is 5000kW m-1 above the maximum 2000 kW m-1 aerial firefighting threshold. This bushfire trapped several people in a dam, burned 700 hectares and destroyed four homes. WA has no active night-time aerial water-bombing capability and, like the non-existent East Link, the ‘potential future prospect’ of it cannot be considered, given the risks to people’s lives MUST be balanced against fact - not fiction.

13. Water supply during a bushfire not guaranteed
WA’s Water Corporation stated December 22, 2022: “Mains water supply cannot be guaranteed during a bushfire” - placing the corralled 1001 homes of 2800+ people at great risk given water capacity and pressure to this location will be lower than ‘usual’ suburban subdivisions.

14. Area is close to bushfire volatile region
WA’s Water Corporation stated December 22, 2022: “Mains water supply cannot be guaranteed during a bushfire” - placing the corralled 1001 homes of 2800+ people at great risk given water capacity and pressure to this location will be lower than ‘usual’ suburban subdivisions.

15. Mobile phone communication
Mobile phone communication cannot be relied on during bushfires.

16. Increased bushfire risks
Climate Change is increasing bushfire risks: decreasing rainfall in Perth, increasing temperatures, more frequent Extreme and Catastrophic Fire rated days (Bureau of Meteorology).

17. Planned ethanol plant omitted
Omission of a planned adjacent and highly volatile ethanol plant - using flaring at Red Hill, bordering John Forrest National Park, 3 kms from site.

18. High cost to build not included
High costs of building to Bushfire Alert Level (BAL) levels and increasing insurance costs in bushfire risk zones are not included. Recent bushfire and flood disasters in Eastern Australia have rendered some regions un-rebuildable and uninsurable.

19. Schools add evacuation risk
Two planned schools on-site create a bushfire and evacuation risk for 1500 children, teachers, and staff. Hundreds of parents would race to the area causing traffic gridlock and potentially trapping residents trying to escape on just two external bushfire exits. One exit must always be expected to be compromised by the fire or as an emergency vehicle access road. (DFES)

20. Dam water should be a last resort
The plan cites dam water connected to the operation of the proposed WWTP as an available source for bushfire fighting. Hills’ Local Volunteer Bushfire Brigade members say using dam water as a backup in a bushfire emergency is THE LAST RESORT - and most often totally disregarded because dam water can contain rocks and other debris that clog fire-truck pumps and pipes and the content of the water is unknown (causing contamination of the firetruck / pipes, and potentially contamination of private property the water might be used on - even people).