The Victorian National Parks Association has made its submission to the current draft Fire Operations Plan. Since the VNPA covers statewide fire protection problems much better than we could do, we print its ‘general overview’ of its submission below:
The VNPA has long held concerns about the level of planned burning in Victoria, and the justifications given for the Fire Operations Plans.
In short, the level of burning is dictated by the 5% annual burn target recommended by the Victoria Bushfires Royal Commission (VBRC). However we note that in the last three reports from the VBRC’s Implementation Monitor, Neil Comrie has strongly advised that the target be reconsidered, because it is unachievable and counterproductive. He says in his last (and final) report that it “will not necessarily reduce the bushfire risk to life and property, and may have adverse environmental outcomes”.
Further, Mr Comrie also pointed out that the VBRC’s recommendations were not to be taken in isolation from each other. That means that Recommendation 56, to burn 5% of public land annually, should be considered in the context of other recommendations that are also designed to save lives, such as:
• Recommendation 57, which asks for an annual report on “prescribed burning outcomes in a manner that meets public accountability objectives”. Although not specifically mentioned in Rec 57, “public accountability” would clearly include the effectiveness of the burn program, especially the cost-effectiveness of the program in reaching the prime objective of the program: saving lives. There has never been a public assessment of the actual effectiveness of the program, despite outcries from the scientific community.
We believe it is high time for an independent assessment of the cost-effectiveness of the burn program as a tool to save lives, and an independent assessment of its impacts on biodiversity.
• Recommendation 4, which asks for the “encouragement of personal shelters around homes”. This recommendation emerged after the urgent call by the VBRC, in its earlier interim report, for the development of an Australian Standard for home bushfire shelters/bunkers. As far as we can see, there is no material widely distributed by DEPI that advises householders to install bunkers, even though well-designed bunkers clearly save lives and avoid the high risk of trying to flee a fire.
• Recommendation 20, which stresses the importance of rapid despatch of aircraft. While aspects of this recommendation have been adopted, and in many instances DEPI’s capability for rapid attack has been demonstrated very successfully, there have been other instances when aircraft have not been available, rendering the call for staff to be ‘on standby’ somewhat purposeless. FOPs should include the need for a rapid attack capability appropriate to the area concerned.
• Recommendation 1, which asks that “local solutions are tailored to and known to local communities through local bushfire planning”.
In other words, fire operations planning should happen at a local level, and should consider ALL of the available tools to best achieve public safety and biodiversity protection. That is, the FOPs should consider all of the relevant VBRC’s recommendations and also any further knowledge that has emerged since that time.
FOPs for the Warrandyte area, for example, might identify that an improved rapid attack capability and a plan to encourage/subsidise at-home bushfire bunkers are the best ways to save lives in that location and that relying largely on fuel reduction (other than very local burns or slashing) would not be the most useful way to allocate budgets. Importantly, in the case of a place like Warrandyte (and in the spirit of VBRC Rec 1), people in such an area should be made very aware that any fuel reduction that is able to be performed will not guarantee anyone’s safety in severe fire weather. (Note: on p. 5 of the VBRC’s Final Report Summary, “It is essential that there be a continued focus on providing frank and meaningful advice about the risks, and what is required to adequately prepare for and survive a bushfire”.)
Many important studies and reports have emerged since the VBRC’s recommendations in 2010, and they should be clearly informing any FOPs in the state.
For example, five leading fire behaviour scientists in Australia, Canada and the USA have demonstrated that managing the ignition point of a fire is more effective in reducing the extent of fire than fuel reduction. Managing the ignition point can happen through a combination of means, such as increased capacity for rapid attack at the source of a fire, by closing public access to remote areas during high fire danger days, and also through public education.
And other published papers from leading Australian fire scientists and ecologists convincingly show that fuel reduction burns are most effective when performed close to the assets they are meant to protect. This is the sort of strategic effort – small, difficult and expensive local burns – that Neil Comrie says is less likely to happen when managers are struggling to sign off on a large area target.
Other studies are showing us that we now have very little long-unburnt bush left in Victoria, and that the impacts on native wildlife are serious and growing:
• A series of recent studies by La Trobe and Deakin universities in the Murray Mallee region of Victoria, NSW and South Australia, involving more than 20 biologists and ecologists as researchers and collaborators, produced some alarming results. It seems that frequent burns in the Mallee will harm wildlife, and the now rare long-unburnt Mallee country is quite crucial for many species.
• Victoria’s 2013 State of the Environment Report raised concerns about the level of burning across the State, saying that “40% of native vegetation [was] estimated to be below minimum tolerable fire intervals” already, that there is only around 3% of very long-unburnt bush left, and that many species were at risk.
And further, in regard to the environmental impacts of planned burning, we note the statement in the last line of p. 15 of the VBRC’s Final Report Summary, which calls for “… more informed and scientifically-based decision making [for] prescribed burning regimes that meet conservation objectives as well as accommodating bushfire safety considerations”. In other words, while public safety is the prime objective of fire management, the protection of biodiversity is also an objective that should also be achieved.
Information provided to the public in relation to the FOPs submission process is currently inadequate in relation to ecological impacts. Most particularly, there is no information presented on whether a proposed burn is below the minimum TFI for a given burn area (usually a complex of EVCs), let alone whether it allows the long-term maintenance of an ecologically appropriate range of age classes for those EVCs. There is generally little, and in too many most cases no, apparent consideration of fauna in the justifications for ecological burns.
In short, we believe that the current FOPs process:
• Puts far too much emphasis on reaching, or even exceeding, the current 5% target;
• Does not adequately engage, or ask the public to consider, means other than planned burns that can also (and often more effectively) reduce the occurrence, or the impact, of bushfires;
• Operates largely within an information vacuum in regards to the important issue of the long-term survival of Victoria’s biodiversity.