Introduction
The New South Wales Rural Fire Service (RFS) has introduced important update to the building and development guidelines for bushfire-prone areas in the Addendum to Planning for Bushfire Protection 2025 commencing on 4 April 2025. This change brings about changes to the construction requirements for new primary and secondary schools.
What are the changes?
Internal Tenability: For certain primary and/or secondary school buildings assessed as having a lower bushfire exposure, the requirements of Specification S43C9 (Internal Tenability) no longer apply.
The removal of the S43C9 requirements is not a blanket change for all new schools. It applies only when the school building is located in a lower risk setting, as defined by the following criteria:
- The school building is not on land, or within 100 meters of land, that is:
- Categorised as Vegetation Category 1; and
- Is greater than 5 hectares in size; or
- Is within 100 meters of another area of land that is also categorised as Vegetation Category 1 and is larger than 5 hectares.
In simpler terms, if a new school is not in close proximity to a large area of Vegetation Category 1 land, the specific internal tenability requirements of S43C9 are deemed unnecessary.
Vehicular Access: The addendum removes the requirement to comply with the Special Fire Protection Purpose (SFPP) access requirements in Table 3 of the 2022 Addendum for school buildings. This means new schools are no longer automatically subject to these more rigorous provisions.
The addendum also amends Specification S43C14 (Vehicular access) of the National Construction Code (NCC) 2022. It replaces the previous SFPP requirements with the applicable performance criteria and acceptable solutions found in Table 6.8b of the main Planning for Bush Fire Protection 2019 document.
To restate, by reverting to the standards in Table 6.8b of PBP 2019, the requirements for vehicle access for new schools become more aligned with those for other types of development, such as residential subdivisions. These standards still maintain adequate access for firefighting crews but offer more flexibility.
The acceptable solutions in Table 6.8b cover aspects such as:
- Public Road Widths: Two-way roads that are at least 8 metres wide (kerb to kerb) and one-way roads that are at least 4 metres wide.
- Property Access Roads: Requirements for road widths and passing bays to ensure fire trucks can access the property from the public road network.
- Turning Areas: Provision for fire trucks to turn around safely.
- Maximum Grades and Crossfalls: Limitations on the steepness of access roads.
- Bridge and Culvert Capacity: Ensuring these structures can support the weight of a fire truck.
In summary, the 2025 Addendum provides an adjustment to the internal tenability and vehicle access requirements for new school developments in NSW. It removes a layer of regulation requirements in lower-risk scenarios to streamline the building process, while maintaining stringent safety standards where the bushfire threat is more significant.
For more detailed information on the Addendum, you can visit the NSW Rural Fire Service website.
Planning for Bush Fire Protection - NSW Rural Fire Service
Bushfire Performance Solutions
It is considered that whilst the above allows for added concessions for Class 9b primary and secondary schools, other Class 9b tenancies such as childcare centres are still subject to the requirements of NCC Specification 43.
Lote has experience with two (2) different approaches to address NCC Specification 43 variations, in particular with respect to Specification S43C9 (Internal Tenability) and Specification S43C12 (Emergency Power Supply).
- Method A – Computational Fluid Dynamics (CFD) Modelling to BCA Deemed-to-Satisfy Provisions.
Method A involves the incorporation of CFD fire and smoke Modelling to design a Mechanical System to adequately comply with the prescriptive requirements of Specification S43C9 (Internal Tenability) and Specification S43C12 (Emergency Power Supply).
- Method B – Undertake a Bushfire Performance Solution to remove Specification S43C9 (Internal Tenability) and Specification S43C12 (Emergency Power Supply) Requirements
Method B involves the development of a Performance Solution to remove the Specification S43C9 (Internal Tenability) and Specification S43C12 (Emergency Power Supply) Requirements for the building.
Please contact us for more detailed information on Method A and Method B.
References
New South Wales Rural Fire Service. (2022). Development and construction of Class 9 buildings that are special fire protection purpose development on bush fire prone land. https://www.rfs.nsw.gov.au/__data/assets/pdf_file/0018/250110/Guidance-document-Development-and-construction-of-Class-9-SFPP.pdf
New South Wales Rural Fire Service. (2025, January). Planning for bush fire protection: A guide for councils, planners, fire authorities and developers: Addendum January 2025. https://www.rfs.nsw.gov.au/__data/assets/pdf_file/0004/282199/Addendum-to-PBP-2019_January-2025.pdf
New South Wales Rural Fire Service. (n.d.). Planning for bush fire protection. https://www.rfs.nsw.gov.au/plan-and-prepare/building-on-bush-fire-prone-land/planning-for-bush-fire-protection