Where did the policy of burning [at least] five per cent of public land every year come from? The material below is taken from the submission by the Victorian National Parks Association to the current enquiry. As readers will remember, the enquiry is being held to decide whether a blanket five per cent policy, or a policy based more precisely on risks and benefits should be implemented.
The full text of the VNPA’s submission can be found here. A submission more locally focused on box ironbark woodlands can be found on the Living with ecology and fire website, together with much other useful information on fire in our environments.
The VNPA’s background to the policy runs as follows:
A brief history of the 5% burn target
The 5% annual burn target has been recommended by two fire inquiries in Victoria: a 2008 Parliamentary inquiry, and the 2010 Bushfires Royal Commission. However, perhaps because of the often contradictory advice those inquiries received, and the lack of clear evidence that the target would work in a Victorian context, both inquiries recommended monitoring and reporting on a hectare-based target’s effectiveness and impacts. Both inquiries effectively asked for this current review.
1/ The Victorian Parliamentary Environment and Natural Resources C’ttee (ENRC) 2008 inquiry
A 5% state-wide annual burn target (c.390,000 ha) of public land was first formally recommended in the ENRC inquiry into The Impact of Public Land Management Practices on Bushfires in Victoria. However that recommendation (Rec 2.2) was largely based on flawed evidence supplied to the inquiry:
–The evidence misquoted a reference for burning in some forests in the USA, which actually recommended an annual strategically applied burn target of 1-2% of the landscape if strategically applied, or 2-5% if burns are random. (In any case, applying any target from a totally different forest type on the other side of the world has questionable value.)
–It quoted a Tasmanian paper that recommended burning Button Grass plains at the rate of 3% per annum for fuel reduction, but these plains actually occupied less than a quarter of the landscape concerned. In other words, the Tasmanian paper only recommended roughly 1% of that landscape area to be burned, and in a quite specific habitat type.
–It referred to the burning of Western Australia’s Jarrah, Karri and Tingle forests, where the target was a nominal 8% annually, but that target has never been applied to ‘all public land’ in WA. And those low elevation WA forests are not comparable to most of Victoria’s forest types, such as the steep-sloped ash forests, the Mallee, or central Victoria’s Box-Ironbark woodlands..
Recommendation 2.3 of the ENRC inquiry recognised the uncertainty of its target recommendation, saying:
“A comprehensive review of the effectiveness of the increased prescribed burning target in meeting ecological and bushfire suppression needs should be conducted every three years.”
2/ The Victorian Bushfires Royal Commission (VBRC) 2010 final recommendations
The VBRC held an extensive session on the fuel reduction question, bringing in experienced fire manages from Victoria, WA and also from the USA. The VBRC heard the advice of its appointed Expert Panel on fuel reduction over a period of two days.
While expert advice to the VBRC varied considerably, it did not in most cases recommend a single state-wide burn target.
The United States Forest Service’s National Director of Fire and Aviation, Jerry Williams, advised the Commission that a single hectare target could encourage managers to opt for the easier, larger burns in remote areas:
“We have a lot of examples in the US where targets have become an opportunity to pick off the low-hanging fruit, so to speak. I believe … targeting the foothills, eucalypt and high-risk fire regimes at larger sizes, strategically placed across the landscape and treated at adequate intervals across both public and private lands … were important places to start.” VBRC transcript: T15198:16 Williams
Australian fire behaviour specialists and fire ecologists on the VBRC’s Expert Panel were more-or-less unanimous in recommending a hectare-based target for the ‘foothill forests’ only, and that it should be performed as an experiment:
(Reference numbers refer to the VBRC’s transcript.)
- Mr Tolhurst, for example, said (15246/7-15):
“My understanding of what we were talking about is, if you like, almost a trial sort of use of prescribed burning and we were talking about particularly of progressing this in the foothill forest areas where there would be less contention in terms of the impact of the fire and we knew it was an area of high priority in terms of protection of life and property. So our discussion there was revolving around the first implementation, if you like, of a trial.”
Dr Bradstock added (15247/11-20):
“I think what we said was if you went for something around 5 per cent in foothill forests that it was our consensus that at least that would be okay in terms of vegetation responses, though we noted that there is very little information about animals. So that was part of the deal. We reckoned that the vegetation could cope with that; plenty of evidence to suggest that it could. We don’t know much about animals. We need to monitor it if you are going to do it. But that’s not a reason not to do it.”
Dr Clarke agreed (15247/27-15248/4):
“Absolutely. I endorse Dr Bradstock’s comment, particularly in relation to fauna and our ignorance of the impact on fauna. But the evidence to date suggests that that doesn’t look like a dangerous level in that habitat. I guess the other thing we were emphasizing in 20(b) was we think this is a habitat that’s important for human life and values and assets, and one in which a trial could take place without major risk to ecological values, but that we would want to monitor that.”
Asked to clarify his position, he added (15248/21-25):
“..I think the panel was of the opinion in this particular habitat type of foothill forest the risk was worth taking, provided there is a commitment to learning as we do it, and that couldn’t be said for other habitats about which we know less.”
And Mr Cheney (though asking for 8 per cent rather than Bradstock and Clarke’s 5 per cent), also agreed that the target applies to the foothill forests. (15250/10-16):
“I would also like to say that the panel agreed that this should be a program, not a trial. The word “trial” has come up, which is tending to say we should confine this to a relatively small area. No, the panel said that we should apply this as a program across the dry foothill forests of Victoria as an area basis, not in one specific area.”
And Mr Adams added (15250/31-15251/5):
“But I also think we were quite clear that, as a program, we say that it would take at least 10 years to implement it and that it should be monitored, but it is a program of the five to 10 per cent in the foothill forests, yes, but in the sense of a “trial” we end up on a semantic point.”
It is clear that the panel, when clarification was sought by Counsel for the State, was largely in agreement that the proposed target of at least 5 per cent was intended to apply to the foothill forests, and that there was a degree of uncertainty even there which could only be clarified through long-term monitoring.
Dr Clarke submitted a ‘clarification of expert opinion’ to the Commission shortly after the expert panel hearings. In that statement he makes it very clear that in his opinion:
“The available scientific evidence suggests that annual prescribed burning of 5% may be justifiable in dry eucalypt forest, if the primary goal is appreciable (perhaps 50%) reduction of risk to life and economic assets… on days of severe fire weather. There is also some evidence to suggest that in this particular habitat the ecological consequences of this level of prescribed burning are unlikely to result in irreversible or undesirable change. Since this habitat type is also the one encompassing or abutting the majority of economic assets at most risk from unplanned fire in this state, it would appear to be the habitat type in which the greatest reductions in risk to life and property might be obtained.
“However scientific evidence of the appropriate level of prescribed burning (percentage of the landscape or habitat type) needed to achieve desirable reductions in risk, while avoiding ecological harm, is not available for most other habitat types in the state. Consequently, in my opinion it is inappropriate to apply a target of 5-10% across the public estate of Victoria. Similar risk and ecological analyses to those conducted in foothill forests need to be conducted in other habitats with the goal of setting appropriately tailored targets for these habitats. In the absence of such evidence and analyses upon which to base targets for these other habitat types, there is a need in the interim, for careful and transparent setting of local/regional objectives to justify all prescribed burning activity in those habitats.”
The above statement demonstrated that the Commission had reason to be wary of recommending a target applicable to all public land or treatable public land.
Importantly, while the VBRC’s final Recommendation 56 did ask for an annual state-wide fuel reduction target of 5% of public land, the following VBRC recommendations (57 & 58) asked for the capacity to monitor and review the effectiveness and impacts of the target. Clearly, the Commission was allowing a future review of the target should evidence suggest it was not the most effective fuel management goal:
RECOMMENDATION 57 The Department of Sustainability and Environment report annually on prescribed burning outcomes in a manner that meets public accountability objectives, including publishing details of targets, area burnt, funds expended on the program, and impacts on biodiversity.
RECOMMENDATION 58 The Department of Sustainability and Environment significantly upgrade its program of long-term data collection to monitor and model the effects of its prescribed burning programs and of bushfires on biodiversity in Victoria.
The VNPA’s policy on the question under review is succinct and clear:
‘The VNPA supports a planned burn program in Victoria, for both fuel reduction and ecological purposes.
‘However we believe a hectare-based target has not produced, and cannot produce, the best outcomes for:
‘– public safety
‘– protection of infrastructure and built assets
‘–catchment protection or
‘–management of Victoria’s natural heritage.
‘We strongly support a risk reduction approach to planning and assessing fuel management across Victoria.
‘We also believe the planning of management burns should be focussed at a local level, and take into account all other available tools for the reduction of risk to life, property and the environment.’