Fire Operations Plan: a detailed response

FOBIF’s detailed response to the draft Fire Operations Plan for our district is published below. We will know the effect of this and other responses to the draft plan when we attend a meeting with DSE in Bendigo in mid September.

As we have previously made clear, our major worry is the signals we have been receiving from DSE workers that there is little intention of following the directions of the Code of Practice in Zone 3 burn operations.

 

 

 

 

 

 

 

 

 

 

 

Other serious concerns include the allocation of a huge area of Mount Tarrengower to be 90% burned, and a section of the Diggings Park south of Guildford to be 80% burned. The full submission follows:

FIRE OPERATIONS PLAN 2012: FOBIF SUBMISSION:

We will make our submission according to zones, and starting with Zone 3. We believe that the politically imposed burn targets, many of which have little or nothing to do with human safety or environmental health, make it urgent that DSE and Parks take special care with each operation: and it is in Zone 3 that success or failure is most obvious. In view of the collapse of bird numbers measured by Castlemaine Field Naturalists, and severe insect infestations in Eucalypts south of Vaughan, ‘ecological resilience’ becomes a major priority.

ZONE 3: GENERAL CONSIDERATIONS

At the July consultation meeting in Bendigo [DSE fire manager] Simon Brown described Zone 3 operations as aiming at a burn coverage of a ‘minimum of 20%’. During the following discussion the figure of 30% was mentioned. However we have been recently informed by DSE operatives that the actual aim is 50%.

• We consider a 50% aim to be incompatible with the stated ecological objectives of the burn, and ask for assurances that the 20-30% aim be strictly observed.

Further, though the FOP and the Code [of Practice]  refer to ‘ecological resilience’ and ‘forest regeneration’ as objectives we have again been informed by DSE workers that fuel reduction is the sole consideration of burn managers. We also notice that all Zone 3 burns have been tagged in the FOP as ‘FRB’.

• We ask for reassurance that the ecological aims of each burn will be clearly and publicly stated and carefully targeted.
• For each of the burns named below we would like to know what specific scientific information and monitoring data are guiding the exercises, and what species in particular are in need of ‘regeneration’.
• It would be helpful to the public and would help fulfil the Code of Practice objective of transparency if burn plans were made available to the public before operations took place.

Given that ‘ecological resilience’ and ‘forest regeneration’ are objectives of these exercises, it seems illogical to be burning in Spring, when plants are setting seed and animals are breeding.

• We request that no Zone 3 burns take place in Spring.

In our submission to DSE on fire zones in August 2011 we wrote that Kevin Tolhurst had argued that management burns might work ecologically if they were of ‘low intensity’, and we offered a warning about the proposed Limestone Tk [CAS 51] burn. We added:

‘..Our experience with last year’s Wewak track burn makes us very apprehensive about both the fuel load and ecological outcomes. The rampant destruction of mature trees and resultant explosive [stringybark] regeneration, together with much bare earth, is a great cause for worry when considering the Tarilta creek, a much steeper and therefore erosion prone topography. We believe that detailed planning of this burn, and tight supervision, will be necessary to avoid last year’s problems [or worse, given the steeper slopes]. We have these concerns about all proposed EMZ burns.’

This precautionary advice seems to have been completely disregarded, and the resultant disaster is in the Tarilta creek for all to see. [see https://www.fobif.org.au/2012/03/tarilta-gorge-burned-off-washed-away/  and following posts]

• We request that all Zone 3 burns be of low intensity, and that careful attention be made to topography and catchment protection.

PARTICULAR ZONE 3 PROPOSALS + THE ZONE 2 RUSCONI’S RD PROPOSAL AND ZONE 1 TARRENGOWER PROPOSAL

1 Muckleford/Maldon: Dunn’s Reef [CAS 11], A Frame Tk[CAS 12] Donkey Farm tk [CAS 10]

See our general observations above about Zone 3 burns.

When these three parcels are added to last year’s severe and destructive Demo Tk burn, a very large proportion of this forest block will have been covered in a short time. If this pattern continues, the whole of the Maldon/Muckleford block will have been burned inside ten years—disastrously inside the Tolerable Fire Interval for this type of bushland. This would seem to work clearly against ‘ecological resilience’ and ‘forest regeneration’.

• For this reason we ask for assurance that the 20-30% burn coverage be strictly adhered to, and that the precise nature of the ‘ecological resilience’ and ‘regeneration’ aimed at be clearly stated in the burn plans.
• We ask that DSE biodiversity mapping for this area, upgraded and supplemented with local knowledge, be incorporated in the burn plan to reinforce the above.
• Further, we ask that these burn plans be made public in advance of the operation.

2 Maldon: Nuggettys – [CAS 5] Perkins Reef [CAS 2] Tarrengower [CAS 1]

 See our general observations above about Zone 3 burns.

Nuggetys CAS 5

• In our opinion fire operations in this parcel should be targeted to clearance of flammable weeds like gorse. It’s hard to see that any fire is necessary ecologically in this parcel; we believe that burn coverage should be limited and low intensity.

Tarrengower CAS 1

This is a very large parcel for a Zone 1 burn—as far as we can see, more than double the area of any other Zone 1 in our district. It’s very hard to see why it has been zoned in this way. While it is clear that bushland abutting the town needs careful fuel management, it’s by no means clear why the south side of the Mount needs high intensive fuel reduction, especially since the area around the Tower was burned in 2009.

• We believe that this parcel should be broken up, and the southern half [possibly the area bordered by Anzac Hill Rd] be amalgamated with CAS 2 as a Zone 3. Fire in this southern half should be directed at protecting properties along Parkins Reef Rd.
  

• Since in any case parts of this zone are very steep, we believe that managers of this burn should pay careful attention to possible erosion consequences, and pre-emptively implement mitigation measures.
  

Parkins Reef CAS 2

This area is a mixture of good quality bush with fine trees, and degraded, weed infested land.

• We urge that where possible fire be used precisely to protect assets like Carman’s Reef and North British mine.

The southern part of this zone is especially infested with oxalis and bridal creeper. Ill directed fire could enable these to outcompete native grasses.

• We urge that every effort be made to avoid spreading weeds in this operation.
• Given the aim of ‘ecological resilience’ and ‘forest regeneration’ we’d like to know what research information is being used to avoid weed spread in CAS 2.

3 Chewton: Railway Dam—[CAS 13]

See our general comments above about Zone 3 burns.

This parcel abuts the significant Asset Protection Zone running along the Pyrenees Highway. This Zone 1 strip has been severely burned in recent years, and if these burns have had any effect on fuel levels fire coverage in CAS 13 should not need to be either extensive or severe.

• The southern half of this parcel contains the south facing headwaters of Fryers Creek. This and other moist gullies and south facing slopes should be excluded from the burn.
  

4 Taradale: Plantation Tk – [CAS 17] Carnell Rd—[CAS 14]

See our general observations above about Zone 3 burns.

• We request that a 20% coverage be strictly adhered to, using pre existing tracks as borders. Inside the defined area a moderate burn only be aimed at.

5. Glenluce: Amanda’s Tk  [CAS 15] 6. Franklinford: Peppertree Tk [CAS 16] and 7. Guildford: Rusconi’s Rd [CAS 9]

See our general observations above about Zone 3 burns

These proposed burns are adjacent to or close to this year’s Limestone Tk CAS 51 [Tarilta] exercise.

• We would like to know how these proposed burns will ‘complement’ CAS 51. Further, we would like to know how they will ‘complement’ the 2010 Wewak/Loop tracks burn, which was so severe as to provoke massive Stringybark regeneration.

Please note that the forest in this area has been subject to a devastating attack by some kind of leaf miner, possibly cup moth. Local residents report that trees are looking worse than they have for many years.

• This is a good argument for postponing treatment of these parcels for as long as possible, till the bush is somewhat less vulnerable to impacts.
• A burn coverage of close to 20% should be strictly adhered to.

Amanda’s Tk CAS 15:

This is a very diverse area. There are large habitat trees along Middleton Ck, Brown’s Gully and other gully areas; poor quality dense eucalypts along Amanda’s track; very steep topography, especially along Middleton Creek; heavy gorse infestations along Middleton Creek, etc. Brown’s Gully, a key section of the Great Dividing Trail, has important heritage value, and on our observation seems to have very low fuel loads.

The fuel loads vary widely. We can’t see how this whole area can be considered as a single burn.

• We recommend that DSE consider confining the actual burn coverage to a carefully selected section of the treatment parcel.
• We ask that the burn plan clearly stating the science behind the ecological aims of the operation be made public before the burn takes place.

Please note that Guildford Landcare is conducting gorse clearance and revegetation work along the lower reaches of Middleton Creek. It would be ironic if the newly restored section was destroyed by silt deposition caused by DSE operations, in the manner of Tarilta. The cliff sections of the creek should definitely not be burned.

• In our opinion, fire protection and ecological resilience would be best achieved by removal of gorse from the creek, something which could probably not be achieved by fire without serious damage to the creek itself. If fire protection is the aim, this burn should be abandoned altogether and the money for it given to Guildford Landcare to continue their creek clearance works.
  

Peppertree Tk [CAS 16]

• As this is an important part of the Hunters Ck catchment, and is adjacent to the severely burned Limestone tk area, we submit that the burn area be strictly limited to 20%.

Guildford-Rusconi’s Rd [CAS 9]

We are completely mystified that this parcel is in Zone 2. Given its situation it should be in Zone 3, and our general observations for Zone 3 apply here.

• We request a rezoning of this area to Zone 3. In particular, a discrete section of this parcel should be targeted, possibly to the north of the parcel.
• Please note that this parcel is suffering from the same problems as bush on the other side of Tarilta Creek: severe attack by a leaf destroying creature, possibly cup moth. This would be a good reason for postponing this exercise.

We endorse the observations made by Rusconi’s Rd resident Rob Simons on this proposal, particularly on the subject of the spread of flammable plants via roadworks and fire operations.

PLEASE NOTE THAT IF THE RUSCONI’S RD  AND PEPPERTREE TK PROPOSALS GO AHEAD, 70- 80% OF THE TARILTA CATCHMENT WILL HAVE BEEN SEVERELY BURNED BY DSE IN FIVE YEARS. THIS, COMBINED WITH THE CURRENT INSECT ATTACK AND PREDICTED DRIER CONDITIONS IN THE COMING YEARS, COULD HAVE A DISASTROUS EFFECT ON THIS FOREST AREA. This alone is a very good reason for altering CAS 9 to a Zone 3 and confining the burn area to 20%.

ZONES 1 AND 2 PROPOSALS

Castlemaine Kalimna Park [CAS 3 and 7 (Golf Course)]

We endorse the submission of the Friends of Kalimna Park on these proposals.

We would like to emphasise that the CAS 3 parcel should not be treated as one, but for fully effective management of this valuable land, the exercise should be broken up and each section treated differently according to its different biodiversity and fuel load characteristics.

Castlemaine Poverty Gully and Arthur’s Tk [CAS 107 and CAS 8]

These areas contain important colonies of the Castlemaine Spider Orchid.

• We would like to be assured that this rare plant will be treated with an appropriate fire regime established by scientific research. We assume that the provisions of the Flora and Fauna Guarantee act will be followed.

29 August 2012