06/10/2026
A Risk Management Plan that only addresses on-site consequences is not meeting the requirements of any of Australia's current BESS fire safety guidance documents.
CFA's June 2025 guideline is explicit that consequence analysis must identify and assess both on-site and off-site receptors. Off-site receptors that must be considered include dwellings, schools, hospitals, child care and aged care facilities, community hubs, emergency services, environmental receptors such as soil, flora and fauna, and waterways.
The consequence analysis must model and map the potential extent of exposures to those off-site receptors — including radiant heat flux, plume spread of gases and smoke in both typical seasonal conditions and fire weather conditions, and potential explosion overpressures — across scenarios where in-built safety systems both succeed and fail.
FRV's GL-55 similarly requires consequence modelling that considers off-site impacts, particularly where a BESS is located within 200 metres of a habitable structure. At the pre-construction phase, this modelling is a required input to the fire safety documentation regardless of the scale of the project.
The Risk Management Plan uses this analysis to justify the separation distances, fire breaks, water management systems, and detection and protection measures specified for the facility. Without robust off-site consequence analysis, those justifications have no foundation.
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