The transport sector will soon be Australia’s largest source of greenhouse gases. Whilst EV vehicle sales are growing, renewable liquid fuels have a key role in achieving net zero in this sector by 2050.  The past 12 months has seen an increase in project activity, and general government support, for renewable liquid fuels projects in Australia.  There is no one-size-fits all net-zero transport solution in Australia and it is pleasing to see growing recognition of this at various levels of government. 

This Industry Note provides a brief overview of TFA’s own 20 year involvement in renewable fuels projects in Australia and provides some commentary as to whether we are getting closer to some form of tipping point in project viability in the renewable fuel industry.

Three Decades in the Making

TfA Project Group is a design / engineering consultancy that developed out of the downstream oil industry in the mid-90s.

Developing specialist skills in this industry requires an acute appreciation for safety in design, and hazardous area layout considerations of numerous flammable and chemical products. For nearly 30 years, TfA have been trusted designers to all major Oil companies in Australia for the safe design of fuel storage and distribution facilities ranging from oil terminals, fuel depots, airport fuel farms, mining and commercial fuel facilities to service stations and truck stops. A highly capable team of design and engineering professionals is required to service such an industry and it is the complexities and challenges of this industry that have historically attracted such professionals.

These same specialist skills also apply to our many and varied renewable fuels projects.

TfA has been actively involved in renewable fuels projects since the early 2000’s.  In the current era where net zero commitments are being announced on a regular basis, it is often overlooked that the renewable fuels industry in some shape or form is already 20 plus years in the making in Australia.

TfA designed Australia’s first grain-to-ethanol plant at Dalby which became operational in 2009. Renewable fuel development is not simple and the journey from concept, feasibility, FEED and ultimately detailed design and construction took seven years. The fact that this is the only biorefinery to be built in Australia over the last 25 years makes the knowledge earned during this project invaluable. Many renewable fuels biorefinery projects have been through concept and feasibility stages in these intervening years, however none have been completed. In 2024, the Dalby plant is no longer operational and sustainable aviation fuel (SAF) plants are now starting the journey in the feasibility stage of the design process (with the aid of growing government support).

The Renewable Fuels Opportunity 

Our recent White Paper on renewable fuels ( discussed the manner in which Australia could viably support its own renewable fuels industry.  This comes at a time when various levels of government are also actively promoting and incentivising the electric vehicles industry, primarily for light / passenger vehicles.

Whilst electric vehicles will progressively reduce petrol consumption, many transport sectors such as aviation and shipping cannot be readily electrified and there will be a long term need for liquid fuels. Renewable liquid fuels have a critical long-term role if we are to achieve Net Zero.

There is clearly no one size fits all in a country with the population and distance dynamics of Australia.  A large proportion of the nation’s driving population seem to favour SUVs and utility vehicles which, in time, may well be more suited to renewable diesel than EV models.

Sales of EVs in Australia have grown significantly over the last couple of years reaching 7.5% of total new vehicle sales in 2023. In other parts of the world (US, Europe etc) that have adopted EV uptake earlier than Australia, EV sales have plateaued somewhat over the last year or two. Interestingly in the last two quarters of 2023, hybrids also outsold EV’s in Australia.

The conversion of leaded fuel to unleaded was a process in itself that took well over 10 years during the 1980s and 90s. The current transition to a mix of battery, hydrogen and renewable fuel sources for vehicles is bigger than that historic transition.  Such transitions take time.  The first ethanol conference TfA attended was in 2001 and our first world hydrogen conference was in 2008.

From an Australian point of view, and in an era of fuel security concerns where the majority of our fuel is imported, we could have benefited more by developing a sustainable, home-grown renewable fuels industry earlier in this century than where we find ourselves at present.

Current Initiatives 

The Queensland Government is currently preparing a Sustainable Liquid Fuels Strategy. TfA has been invited to a workshop at Parliament House to assist in finalising this policy.

The NSW Government has just announced a contribution of $100m to help stimulate SAF projects.

The Federal Department of Climate Change, Energy, the Environment and Water is developing an Electricity and Energy Sector Plan addressing five key considerations:

  1. Mobilising investment
  2. Enabling electrification
  3. Growing alternative low carbon fuels
  4. Building Australia’s clean energy workforce
  5. Maximising outcomes for people and businesses

TfA are meeting with the Department as part of this consultation.

With many of the recent government policies focussed on EV uptake, it is pleasing to now see the growing recognition of renewable fuels in the energy mix.  It will play a critical role in the aviation and shipping industries achieving their environmental goals and more than likely with heavy vehicles and those suburban and recreational vehicles that Australia seems to prefer.

If this topic is of interest to you, keep an eye out for our forthcoming TfA industry event in the middle of 2024 and register your interest here.

The New South Wales, Department of Planning and Environment (DPE) brought the State Environmental Planning Policy (Sustainable Buildings) 2022 (Sustainable Buildings SEPP) into effect on 1 October 2023 for the purpose of implementing greater sustainability measures in new and substantially altered Residential and Non-Residential buildings.

Who Does this Policy Affect?

This policy affects both residential and non-residential development applications lodged across the State of New South Wales. For non-residential development in particular, the policy affects developments comprising:

  • the erection of a new building, if the development has a capital investment value of $5 million or more, or
  • alterations, enlargement, or extension of an existing building, if the development has a capital investment value of $10 million or more.

The only exceptions to these triggers are where any of the following items are satisfied:

  • Development that is permitted with or without consent or is exempt or complying development under the following policies:
    • State Environmental Planning Policy (Exempt and Complying Development Codes) 2008, or
    • State Environmental Planning Policy (Resources and Energy) 2021, Chapter 2, or
    • State Environmental Planning Policy (Transport and Infrastructure) 2021, Chapter 5,
      • For context, Chapter 5 of the Transport and Infrastructure SEPP refers to the now superseded Three Ports SEPP, which covers land within the application areas of Port Botany, Port Kembla and Port of Newcastle.
    • Development undertaken wholly in any of the following zones
      • Rural Urban Zones (RU1, RU2 or RU3)
      • Heavy Industry Zones (E5 or IN3)
      • Conservation Zones (C1, C2 or C3)
      • Waterway Zones (W1, W2, W3 or W4)
    • Development for the purpose of a residential care facility
What are the Assessment Requirements of this SEPP?

For non-residential developments that trigger assessment against this policy, councils will need to consider certain sustainable design measures prior to giving development consent, including:

  • the minimisation of waste from associated demolition and construction, including by the choice and reuse of building materials,
  • a reduction in peak demand for electricity, including through the use of energy efficient technology,
  • a reduction in the reliance on artificial lighting and mechanical heating and cooling through passive design,
  • the generation and storage of renewable energy,
  • the metering and monitoring of energy consumption,
  • the minimisation of the consumption of potable water.

Additionally, council will not be able to grant development consent unless the embodied emissions attributable to the proposed development have been quantified.

Referring to a recent DPE Technical Note on Embodied Emissions, the methodology for calculating the embodied emissions for projects that trigger assessment against this policy is through the use of the following:

  • NABERS Embodied Emissions Materials Form – Up until Mid-2024; and
  • NABERS Embodied Emissions Tool – From Mid-2024 onwards.

The content of the NABERS Embodied Emissions Materials Form requires determination of the quantity and type of materials required for a project at development application stage (where these specific details would have otherwise unlikely been determined as part of a project). It will be required that all new non-residential development applications submit a completed copy of the Embodied Emissions Materials Form, as councils will not be able to issue consent without this. Please refer to Embodies Emissions Material Form for further information:

Additional Considerations for Large Commercial Development

Under the Sustainable Buildings SEPP a Large Commercial Development is defined as follows:

large commercial development means non-residential development that involves—

  • the erection of new prescribed office premises, prescribed hotel or motel accommodation or prescribed serviced apartments, or
  • alterations, enlargement or extension of prescribed office premises, prescribed hotel or motel accommodation or prescribed serviced apartments, if the development has a capital investment value of $10 million or more.

Per above, the development types outlined under item (a) are defined as follows:

  • Prescribed Office Premises – Office Premises with a Net Lettable area of at least 1,000m2;
  • Prescribed Hotel or Motel Accommodation – Hotel or Motel Accommodation with at least 100 rooms;
  • Prescribed Service Apartments – Building comprising at least 100 Serviced Apartments.

For development assessed as a Large Commercial Development, the consent standards include demonstrating reduced reliance on fossil fuels in alignment with the NSW 2050 Net Zero Strategy. It is additionally noted that the development would need to achieve the minimum efficiency standards outlined below:

  • Energy use
    • The standard for energy use for development for the purposes of prescribed office premises is a 5.5 star NABERS energy rating.
    • The standard for energy use for development for the purposes of prescribed hotel or motel accommodation is a 4 star NABERS energy rating.
    • The standard for energy use for development for the purposes of prescribed serviced apartments is a 4 star NABERS energy rating.
  • Water use
    • The standard for water use for large commercial development is a 3 star NABERS water rating.

Additional Considerations for State Significant Development

Similar to Large Commercial Development, the requirement where assessing state significant development is to outline measures for the reduction of use of fossil fuels, in alignment with the NSW 2050 Net Zero strategy.

However, this does not apply to all state significant development applications, only those identified under schedule 1, items 13-15 of the Planning Systems SEPP, as outlined below for reference:

  • 13 Cultural, recreation and tourist facilities
  • 14 Hospitals, medical centres and health research facilities
  • 15 Educational establishments
Industry Example

Service Stations with CIV Exceeding $5 Million

The DPE’s arbitrary capital investment value (CIV) threshold of $5m would, in today’s era of escalated construction costs, apply to many new-to-industry and knockdown/rebuild commercial service station projects in NSW.  The minimal zoning exemptions under the policy would also leave limited exemption where the project exceeds the capital investment value threshold.

When assessing service station developments, the assessment benchmarks would be confined to the minimum standards under the policy. When reviewing these benchmarks against recent service station designs completed, the following is noted:

  • Construction and demolition waste minimisation is generally conditioned for contractors to implement when commencing construction. This may require the preparation of more detailed construction and demolition waste management plans, providing clear strategies for waste reduction;
  • Service station buildings, like many commercial buildings, are designed and built with limited natural ventilation, which may result in councils starting to request how this provision is achieved in the design.
  • In order to maximise surveillance of the forecourt, the retail buildings are generally designed with a high level of glazing along the front façade, achieving natural lighting to the front of house areas; limited change is anticipated here, maintaining that the back of house areas are not required to be provided with natural lighting;
  • Generation and storage of renewable energy is expected to see councils requesting the implementation of on-site batteries and solar panels. While achievable by way of implementing battery storage within the service yard and establishing solar on the roof, this will add additional build cost to projects;
  • While reduced water and energy consumption is expected to be capable of being addressed by confirming the implementation of high efficiency fixtures and appliances, this is anticipated to add additional build cost to projects.

Further, the preparation of the NABERS Embodied Emissions Form / Tool will comprise a new minimum lodgement benchmark for all developments triggering this SEPP. Given the level of detail required under this form, it is considered that in order to determine the material types and quantity, a certain portion of detailed design may need to commence prior to lodgement of the development application.

However, one benefit for the majority of service station developments is that the building design is generally standardised, so the material types and quantity may be able to be quantified based on historic projects for similar builds or company design standards, particularly for the purpose of a development application. This could be developed into a standardised form / template which could be applied to the bulk of new projects.

TfA’s Response – Key Issues

The key issues that we see with this policy in principle are as follows:

  • There is limited actual direction within the policy, implementing generalised standards that are to be enforced to the ‘satisfaction of the consent authority’.
    • Ultimately this could see increased difficultly in the approval process and provides too much leverage for councils to interpret the policy as they see fit;
  • Some level of detailed design consideration may be required at Development Application stage to demonstrate compliance with the NABERS Embodied Emissions Materials Form / Tool;
  • With development applications in NSW currently taking significantly longer than other states and territories in Australia, it is foreseen that additional benchmarks will provide councils with grounds to further delay the processing of applications;
  • The requirements for solar panels and batteries as well as higher efficiency appliances and fixtures will add to already elevated project construction costs.

We note that whilst the triggers for the Large Commercial Development and State Significant Development are currently limited with respect to potential for considerations for our clients, DPE have confirmed that they intend on reviewing this policy in 2025 and every 3 years following. TfA Project Group (TfA) are committed to reviewing the potential policy updates proposed by DPE during this period and will report back with amendments that directly impact our clients.

How TfA can Assist?

Given TfA’s expansive background across a broad range of development types from approvals to delivery, we have an expansive catalogue of projects and a wealth of technical experience that makes us equipped to assist in navigating this policy.

TfA are able to assist in the following in responding to the requirements of this policy for any new non-residential development applications with a capital investment value exceeding $5 Million:

  • Preparing the Embodied Emissions Materials Forms as part of the DA lodgement package;
    • This can be prepared as a standardised or project specific basis, depending on the specific project needs.
    • This will involve quantifying the anticipated materials to be utilised for a proposed development.
  • Assisting in the development of sustainability / net zero statements;
  • Assisting in the development of new and amended design standards that provide options to respond sustainability considerations anticipated to be requested by councils.

Any queries in relation to this matter, please contact the TfA Town Planning Team who would be happy to discuss further, phone 1300 794 300 or email

This month, in July 2020, TfA Project Group proudly celebrates 25 years in operation! From humble beginnings out of a Brisbane suburban garage to a national, multi-disciplinary consultancy, we look forward to another successful 25 years ahead.

Although challenging times this year, we value our long term relationships with clients, high ratio of long term employees and also the many young graduates we have mentored along the way, many of whom now hold senior positions within our diverse group of clients.

We are as passionate as ever about the projects we deliver with quality and value at the forefront of our culture.

A foundation of TfA since its inception has been in servicing the downstream oil industry. This has included bulk petrochemical facilities (fuel depots and terminals, bitumen import and process facilities and lubricant blending plants), aviation, marina and mining fuel facilities, retail and commercial facilities including the development of well over 1,000 service stations, truck-stops and travel centre developments. We remain leading consultants in this industry to this day.

bulk fuel storage

Over the years, we have broadened our industry expertise and specialise in a range of other industries including renewable energy / biofuels, hazardous industry / dangerous goods and broader commercial / industrial forms of development.

Service Station Development

Our goal to provide a one-stop-shop to service the full life cycle of a project has seen our original project management, engineering and design drafting service now expanded to include full town planning, architectural, engineering (all major disciplines) and project management. Particularly over the last 10 years, this goal has been realised and has also allowed us to expand our national reach from our head office in Brisbane to our other offices in Sydney, Melbourne and Perth.

Service Station Town Planning

Some of our major achievements over the last 25 years include:
• Establishing national service agreements with downstream oil industry clients to deliver our full suite of professional services
• Thriving in a dynamic retail fuel industry that has evolved significantly over the last 25 years
• Being at the forefront of the bio-energy industry (particularly in the development of biofuels and hydrogen) both of which we have been active in since the early 2000s
• Maintaining an excellent staff retention record with many long-term valued staff with 10 years plus service at TfA
• Successfully transitioning our management structure in 2016 to lay the foundations for another successful 25 years ahead

TfA Group engineers

Thank you to all our valued staff and clients for allowing us to maintain a successful operation for the last 25 years and well into the future!

TfA Group Sponsorship

Dangerous goods are found in virtually every home and business in Australia. They can be anything from the flammable aerosols used as deodorants, to aggressive industrial acids. Despite being common, dangerous goods pose major safety risks to people and the environment if they are mismanaged.

Understanding and properly managing the dangerous goods in your facility has never been more important. Following several major incidents, dangerous goods have recently been receiving increased attention and increased penalties for non-compliances. This article has been written by TfA Project Group, leading Dangerous Goods Consultants, to address the following questions:

1. What are dangerous goods?

2. What are your obligations for dangerous goods management

3. Where should you start if you want to improve your dangerous goods management

What are Dangerous Goods?

Dangerous goods generally fall under 9 possible classes, as defined in the Australian Dangerous Goods Code, with each class having its own storage and handling requirements. The classes are as follows:

  • Class 1 – Explosives
  • Class 2 – Gases
  • Class 3 – Flammable Liquids
  • Class 4 – Flammable Solids
  • Class 5 – Oxidising Substances and Organic Peroxides
  • Class 6 – Toxic and Infectious Substances
  • Class 7 – Radioactive Substances
  • Class 8 – Corrosive Substances
  • Class 9 – Miscellaneous Substances

Some goods may not fulfill the criteria of any of the classes but are still considered dangerous goods under the relevant legislation (e.g. diesel).

The prevalence of dangerous goods today cannot be understated. The table below provides some examples of commonly used dangerous goods for various applications.

dangerous good table and classes

Table 1: Common dangerous goods in select applications [1]

Dangerous goods storage and handling can take many forms, and the selected approach can be as important as the species of dangerous goods being stored. Figure 1 provides an example facility that show many of the common means of storing dangerous goods.

dangerous goods storage

Figure 1: Dangerous Goods Storage in Example Facility

What are Your Obligations?

The importance of managing dangerous goods is recognised by legislation across Australia. In October of 2019, new Victorian penalties were introduced for the mismanagement of dangerous good. Under new legislation, illegal storage and handling of dangerous goods could result in a 10-year jail term for individuals, and a $6.4 million fee for body corporates.

The overarching structure of the legislation is identical across the country, as summarised in the figure below.

Hierarchy of Dangerous Goods Requirements

Figure 2: Hierarchy of Dangerous Goods Requirements and Guidance

Australian Dangerous Goods Legislation

It is the responsibility of all person’s conducting a business or undertaking to comply with the relevant legislative requirements for dangerous goods management. These requirements will vary depending on the specifics of your facility. For example, in Victoria small quantities of many dangerous goods are not subject to the regulation if they are for residential use. On the opposite end of the spectrum, sites storing massive quantities of dangerous goods may need to register as a major hazard facility and would receive additional oversight.

The laws regarding dangerous goods vary amongst states and territories, although there are some commonly adopted national guidelines (e.g. The Australian Dangerous Goods Code). The law is stipulated at the highest level through the acts relevant to each state and territory (e.g. The Dangerous Goods Act 1985 in Victoria). Regulations applicable to each state and territory are made under the acts (e.g. Dangerous Goods (Storage and Handling) Regulations 2012 in Victoria). To complicate matters, dangerous goods which travel across state borders must meet the requirements of all relevant jurisdictions.

The table below provides an overview of the most prevalent legislation applicable to each state and territory for the management of dangerous goods. In some cases, additional requirements will apply for particular dangerous goods (e.g. specific legislation for explosives or radioactive substances), specific modes of transport (e.g. transport over air or sea) or other legislation (e.g. workplace health and safety regulations).

Examples of dangerous goods applicable regulation across Australia

Table 2: Examples of applicable regulation across Australia

Standards and Codes of Practice

The legislation often refers to codes of practice and standards for guidance on the management of dangerous goods. Compliance with standards and codes of practice is generally not required by law. However, they are valuable as practical advice for meeting your legal requirements. They represent the baseline level of acceptable practice and should followed unless there is an equal or better protection in place. If a standard is not followed without properly assessing and controlling the resulting risks, then the non-compliance can be used as evidence of dangerous goods mismanagement.

There are many standards applicable to the management of dangerous goods. Depending on the specifics of your facility, assessing and achieving compliance with all the relevant standards can be a complex undertaking. Some standards cover entire classes, whereas others cover only specific chemical species (e.g. ammonia) or dangerous goods held in specific conditions (e.g. cryogenic storage).

Where Do I Start?

The first step to best practice dangerous goods management is to understand your facility and its contents. The following 3 questions provides you with a strong start to understanding your dangerous goods requirements:

1. What dangerous goods you are storing?
2. How much are you storing of each of your dangerous goods?
3. How you are storing/handling your dangerous goods?

Many facilities will have a site manifest that clearly identifies the answers to all three of these questions.

What are you storing?

Each dangerous good stored on your site must have an SDS (Safety Data Sheet) that details it’s physical and chemical information. If this information is not available, then it is recommended that a dangerous goods audit be conducted immediately.

Whilst not always feasible, if a dangerous good pose a significant risk, it is worth considering either:

  1. Eliminating the storage of dangerous goods where possible; or alternatively
  2. Substituting dangerous goods for a less harmful substance.
How much are you storing?

Dangerous goods inventories should be kept to a minimum. That said, thousands of facilities around Australia require storage of large amounts of dangerous goods for regular use. Dangerous goods quantity will have a major impact on the requirements for compliance with legislation and in some cases will dictate your options for storage and handling.

How are you storing/handling your dangerous goods?

The standards clearly delineate between various dangerous goods storage methods. Requirements for compliance will vary depending on factors such as:

  • Are the dangerous goods in packages or in tanks?
  • Are the dangerous goods stored above ground or below ground?
  • Is the dangerous goods storage permanent or temporary?

Whilst no two facilities are identical, some of the most common non-compliances include:

  • Storing incompatible chemicals together
  • Not having the right electrical equipment for your zone
  • Out of date Safety Data Sheets
  • Not having an up to date manifest plan when required
  • Excessive quantities of chemicals stored for a storage method
  • Problems with storage area (e.g. ventilation)
  • Fire protection
  • Inadequate labelling of storage containers
Next Steps

Identifying your facilities dangerous goods storage and handling requirements requires a detailed understanding of the legislation, codes of practice, and relevant standards. It strongly recommended that expert advice is sought if there is any uncertainty on whether you are correctly managing your dangerous goods. A dangerous goods expert will be able to identify non-compliances and work with you to manage the risks in your facility.

TfA is a member of the Australasian Institute of Dangerous Goods Consultants and actively apply our expertise to projects where dangerous goods are involved.

We can help you identify and classify dangerous goods within your facility, conduct audits, undertake assessments and reports for authoritative bodies and incorporate changes into your existing designs.

Any queries in relation to this matter, please contact Ben Phillips, Director who would be happy to discuss further.

Telephone – 1300 794 300
Email –
Website –


WorkSafe Victoria, “Commonly used dangerous goods,” 2019. [Online]. Available:

Minister for Workplace Safety, “Media Release (New Dangerous Goods Laws Pass Parliament),” 2019. [Online]. Available:

National Transport Commission, “Australian Code for the Transport of Dangerous Goods by Road & Rail – Version 7.6,” 2018

Legislation as described in Table 1.

The Department of Transport and Main Roads (TMR) has prepared a draft Roadside Fuel Facilities Policy (draft RFF policy) to achieve a consistent standard of facility providing fuel and associated services, and to ensure that such facilities are meeting TMR’s objectives around road safety and driver rest areas.

The draft policy is intended to replace the existing Service Centre Policy (2013) and the associated Access Policy for Roadside Service Centre Facilities on Limited Access Roads.

The draft policy sets the parameters within which TMR will support Roadside Fuel Facilities (RFFs) on the State Controlled Road (SCR) network. TMR’s intention is to offer design guidance for RFF development, which has previously been left to the market and/or development assessment process.

It has implications for the future approval of white on blue advance warning signage and direct access onto defined limited access roads.  TfA Project Group was invited by TMR to provide formal comment on the draft RFF policy.  A summary is outlined below.

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What is an RFF?

Prior to the new draft policy there were no benchmarks on minimum requirements for service stations and service centres. The intent of the new draft policy is to facilitate the safe, integrated and efficient use of highways and motorways on the SCR network by ensuring commercial fuel operators deliver services and facilities to benefit road users across Queensland. The policy sets minimum requirements for RFFs and outlines the parameters under which TMR will consider support for RFFs on the SCR network. The RFFs are divided into four categories as follows:

  1. Category 1: RFF Service Centre
  2. Category 2: RFF Remote Service Centre
  3. Category 3: RFF Service Station
  4. Category 4: RFF Unattended Facility

TMR’s intention is to create a network of defined ‘RFFs’ across Queensland’s major highways.  They will do this through their own EOI / ITO process or via a proponent led process.  To assist this process, they intend to create ‘RFF Plans’ which will identify specific sites and/or particular regions where they would like to see RFFs develop.

Why Apply to Become an RFF?

Under the draft policy, TMR indicate that sites that are formally classified by TMR as RFFs will benefit from the following:

  1. provided access to the SCR traffic stream
  2. included in TMR publications
  3. eligible to apply for White on Blue signage

The RFF classification will be used as a way to control which sites can apply for White on Blue signage and also, we believe, as a further means to restrict direct access onto ‘Limited Access Roads’ as defined under the Transport Infrastructure Act 1994.

TfA’s Response – Key Issues

Whilst we support the rationale behind creating categories of development to give greater clarity and certainty around TMR’s approval of white on blue signage and direct highway access, there needs to be greater flexibility and a more ‘merits based’ assessment than what they are currently proposing under the draft policy.

Some key points we have highlighted to TMR in our submission are summarised below.

White on Blue Signage

One frustration for the industry over recent years has been TMR’s inconsistent interpretation of their own signage guidelines and as a result, some TMR regions are more flexible to approving white on blue signage than others.

TMR’s current draft RFF policy is calling for industry comment on whether the use of company logos should be included on the white on blue signage.

Our view, which is shared by many in the industry, is that the use of the company logos aids in alerting the travelling public to the specific type of uses / facilities within the site.  This is of benefit in reducing the need to check these facilities against a vehicle’s sat nav system or mobile phone.  Where the logos are placed on the sign in accordance with the dimensions specified within TMR’s Queensland Manual of Uniform Traffic Control Devices 2017 (MUTCD), they are not considered to cause visual clutter.

In our opinion, the benefit of having the logos to promote awareness to the travelling public outweighs any concern TMR may have on visual clutter.  Any issue / concern around visual clutter is more pronounced when the service centre operator needs to apply separately for a road corridor permit to erect a separate billboard sign.

TMR’s current draft RFF policy signage

Queensland Department of Transport and Main Roads Signage

Limited Access Roads

Under the Transport Infrastructure Act 1994, a state-controlled road may be declared a ‘limited access road’ in order to regulate access and egress points with the idea of improving traffic flow and safety.

Where there may be merit in limiting direct access to category 1 and 2 RFFs to limited access roads which are the major highways such as the Bruce Highway and Pacific Highway etc, TMR’s policy here overlooks the fact many limited access roads are also in suburban areas – some examples around Brisbane include stretches of Gympie Road, Beaudesert Road, Mount-Gravatt Capalaba Road and Old Cleveland Road.

The policy therefore needs to allow for more flexibility in its approach to access onto limited access roads.

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RFF Categories

The draft policy outlines minimum design / layout requirements for each category.  As currently drafted, these are overly prescriptive in our view and we have provided examples to TMR where amendments should be considered.  Examples include an unrealistic interpretation of what minimum requirements are to be provided for category 3 (service station) such as heavy vehicle parking, and the effective ‘prohibiting’ of the sale of petroleum at a category 4 (unattended facility).

RFF Plans

The draft policy indicates TMR intend to develop RFF Plans for specific sites and/or particular regions.  We have asked TMR for more detail on the nature of these plans, the timing around their release and the extent to which industry may be consulted.

Relation with Development Approval Process

It is unclear whether TMR plans to incorporate the draft RFF policy and guideline into the development approval process under the Planning Act, 2016.  There are already separate State codes an application is required to address when the State / TMR is involved as a referral agency.

The development approval process in Queensland is inherently a merit / performance-based system (as opposed to, for example, the more rigid planning system in NSW).  We have asked TMR for further clarity here and this reinforces the need for the draft policy to serve more as a supporting design guideline with sufficient flexibility.

Request a Copy & Comment Period

For further information, feel free to request a copy of both the draft RFF policy and our formal submission via

TMR had an initial comment period until 24 June 2020 but they have informed us they are still taking submissions into July as this is not a statutory comment period.

Any queries in relation to this matter, please contact John Rowell (Director – Town Planning) or Brendan Easton (Town Planner), who would be happy to discuss further.

Telephone – 1300 794 300
Email –
Website –

Brisbane City Council is currently undertaking public consultation until 9 September 2019 for proposed amendments to its Service Station code within the Brisbane City Plan. The changes will provide increased controls to manage the interface between service stations and ‘sensitive uses’, most notably around air emissions and stormwater management.

A link to the proposed amendments can be found here:

In addition to the Service Station code, the changes to council’s air quality and stormwater management policy will also relate more broadly to wider forms of industrial development, including the storage of hazardous materials.

Summary of Proposed Changes

The proposed amendments are more a tightening of certain policy elements as opposed to any sweeping / wholesale changes in policy direction. From a Queensland perspective, other councils often follow the policy directions that Brisbane City Council undertake. It is therefore important to fully understand the proposed changes with potential wider adoption down the track.

Council’s own summary of the proposed amendments is as follows:

  • clarify the existing requirement for service station development to avoid or minimise fuel vapour emissions, in addition to ensuring air quality criteria are met
  • refine assessment criteria for visual amenity, noise, health and wellbeing to enable improved outcomes for service station development, particularly in Centre zones and near residential uses
  • enable service stations and industrial development to use new technologies for stormwater quality protection.

These are discussed in further detail in the sections below.

Visual Amenity

The proposed changes now provide more specific commentary around the screening of mechanical plant and equipment from both any public space or adjoining residential use.
In our experience, the majority of new suburban service stations are generally designed to provide some form of screening to plant and equipment, particularly from public vantage points. However, additional requirements around screening from residential areas may result in more challenging screening requirements where for example a constrained site may require equipment to be located on top of the roof of the building.

Stormwater Treatment

There is an additional policy provision in the code which now deals specifically with spill management and stormwater treatment systems over ‘uncovered forecourt areas’ with a new table of stormwater criteria provided.
The outcome of this new table of criteria is that the first flush of the uncovered forecourt area will be required to satisfy the same treatment criteria of the fuel dispensing areas, namely:

  • <5ppm (mg/L) total petroleum hydrocarbons (TPH)
  • ≥80% reduction in total suspended solids (TSS)
  • ≥90% reduction in gross pollutants (GP)

For new applications, were these changes to be adopted, many current treatment systems over uncovered forecourt areas would fail to meet the above criteria. Noting for new applications only and not applied retrospectively.

Air Quality

The section of the code around air quality is proposed to be updated to include more direct reference to the provision of Stage 2 Vapour Recovery. Currently, the relevant performance criteria has a fairly broad interpretation that amenity to sensitive uses is ‘maintained’ through (in part) the installation of ‘vapour recovery systems’. This wording is proposed to be updated with more direct wording around ‘avoids or minimises air emissions through the installation of Stage 1 and Stage 2 vapour recovery systems’.

In our opinion, it would therefore be more difficult to argue against the provision of Stage 1 and 2 vapour recovery where in close proximity to sensitive uses.

The policy also provides clearer reference not just to the protection of sensitive zones, but also sensitive uses within the rural zone. This would give more weight to residential premises within rural zones that previously may have been afforded a lesser degree of amenity protection where located along a busy road or in close proximity to uses of a non-rural nature.

The opportunity for public comment closes at 5pm – 9 September 2019. For queries in relation to the above proposed amendments, please contact John Rowell who would be happy to discuss further.

Telephone – 1300 794 300
Email –
Website –

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