Dialogues of the deaf 1: two arguments that never meet

Does fuel reduction burning work to reduce fire risk? For fire managers there is no debate. Their practice is governed by assessments of fuel load, and computer modelling of fire behaviour.

Managers concede one thing: that some burns are too hot, and may cause undue vegetation growth—that is, to increase fuel loads. They attribute these malfunctions to the difficulty of getting the right conditions for burning: and things do have to be right: temperature, wind, soil moisture… Factor in political pressure, especially from those who fervently believe that the only way we can be safe is to burn the bush black as often as possible, and the managers are in a challenging situation.

In the Fryers Nature Conservation Reserve: this area is slated for a fuel reduction burn. How will it look in a couple of years?

How can we make an informed judgment on the managers’ success? It’s hard, if not impossible, to get the managers’ internal post burn assessments—ie, their judgments on how much fuel had been reduced. Instead, we have assertions as to how this or that bushfire was brought under control after it had been impeded by a fuel reduced area. There were a lot of these at the Black Saturday Royal Commission.

But what about systematic assessments of the effects of fuel reduction? A rare example appeared on The Conversation website last week. Among other things, its authors claimed that in the NSW Black Summer fires, ‘Where prescribed burns had very recently been carried out, the bushfires were marginally less severe, about half of the time’. This is despite the fact that in the previous ten years the amount of forest ‘fuel reduced’ was the largest in the state’s history.

Further, the authors examine fire history in WA, and conclude that ‘Bushfires were three times less likely in old (ie, unburned) forests than they were in recent prescribed burns’. They argue that this is because forests left to themselves tend to thin out the flammable shrub layer; burning actually promotes growth of this layer.

So there are broadly two sides to the fire argument:

  1. Left to themselves, forests build up fuel to a dangerous extent.
  2. Left to themselves, forests tend to reduce dangerous fuels.

This is the nightmare world of ‘alternative facts.’ Only one side of the argument can be substantially true. But how do we sort out which one?

The problem is that these two sides of the argument never seem to communicate. We offer an example below.

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Dialogues of the deaf 2: an example

Tarilta resident Rob Simons sent The Conversation article to local fire managers asking they consider it before undertaking the upcoming Helge Track burn. The reply he got is remarkable, in that it completely ignores the argument of the article:

‘Thanks for sending the below link to the article.

‘While there are differing views on planned burning, fire is a natural part of Victoria’s environment.

‘Victorian government legislation requires the Department of Environment, Land, Water and Planning (DELWP) to reduce the risk of damaging bushfires and to protect human life.

‘As described in the Forest Act 1958, The Chief Fire Officer, on behalf of the Secretary to DELWP, is required to carry out proper and sufficient work in State forests, national parks and on protected public land for the immediate prevention and suppression of fire and the planned prevention of fire.

‘Bushfire risk is linked to the distribution and accumulation of fuels if left untreated. DELWP, the Country Fire Authority (CFA) and stakeholders have developed strategic bushfire management plans using science, simulation tools, and local knowledge to manage this risk. These plans inform bushfire risk reduction targets and locations in the landscape where planned burns are conducted. (Bushfire Management Strategies for each region can be found on the DELWP website)

‘Through the Loddon Mallee Region Strategic Bushfire Management Plan, the Helge Track planned burn unit has been identified as an important location for burning to be applied to reduce the impact of bushfire on the community.

‘To meet its statutory requirements, DELWP intends to complete this planned burn when weather and fuel conditions are suitable.

‘While DELWP planned burns do not totally eliminate the risk and potential impacts of bushfires, they are a key part of an integrated bushfire risk management strategy to protect life, property and the environment including community education and awareness, ensuring access for firefighters and equipment and fast response to bushfires.

‘I hope the information is of assistance.’

No, the information is not of assistance. Everything in it is already well known to anyone who’s taken an interest in fire management. Worse, the letter makes no effort to deal with the matters in the Conversation article.

For the purposes of this discussion, FOBIF is not interested in taking sides in the argument. Up to now we have concentrated on trying to ensure that DELWP does what it says it will: observe the controls in its protocols, keep fires cool, look after old growth trees.

But what we’d like to see is a genuine engagement of the fire managers with the other side of that argument. That argument has been carefully put together by reputable scientists on the basis of detailed research.

Doesn’t it deserve a consideration?

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Dialogues of the deaf 3: what’s in a phrase?

The two arguments above have a rough parallel in ecology:

  1. Leaf litter is dangerous fuel which builds up and needs to be destroyed by burning.
  2. Leaf litter is important insect habitat, which reduces itself via invertebrate activity and natural decomposition. Burning destroys invertebrates and inhibits the process whereby litter turns into soil.

Which one of these is true? That’s a discussion we’d like to see.

Notification of the Glenluce-Helge Track burn, due any day now. The fuel reduction aim of the exercise is open to debate. In our view, the objective ‘to maintain or improve the resilience of natural ecosystems’ is no more than a gesture.

In the mean time, one thing we can be sure of is that ecological concerns are not central to the practice of fuel reduction. Although managers have tried to be consultative on ecological effects in their burns, the fact that they are obliged to burn large areas prevents them from really engaging with ecological values. The Conversation article makes a point made many times before:

‘Early Australian colonists recorded many Australian forests as park-like with open understoreys.

‘This reflected First Nations’ care for country. In southwest Australia, as in many parts of the continent, Indigenous fire use was precise and focused. Unlike prescribed burns, Indigenous practitioners did not attempt to burn vast areas at once.’ (Fobif emphasis)

The upcoming Helge Track fire is 344 hectares. The adjacent Wewak Track block, due for burning next year, is 470 hectares. Together, that is a vast area of land in our region, probably the biggest area ever burnt in this way. We believe it’s impossible to look after ecological values in such an area.

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Fun reading: is this a flashback, or a flash forward?

Given the spate of gold exploration licences being sought, and granted, in this region, we’d like to remind readers of a fun document which appeared as the pandemic was gathering pace, and may not have gotten the attention it deserved.

It’s the Victorian Auditor General’s report on mine and quarry rehabilitation, tabled in August 2020. You can find it here. Like all such reports, it’s not easy reading, but it’s worth a crack, and the one page summary at the start won’t stretch your brain.

All prospective miners are required to pay the state upfront an amount of money adequate for restoring the land after the mine or quarry has been exhausted.

A common sight in our region. The Castlemaine Diggings Heritage Action Plan (2005) put it nicely: this landscape ‘demonstrates the severe environmental impact that can result from inadequate environmental constraint.’ Are we facing a repeat performance?

Are they doing this? The report’s conclusions are succinct:

‘The Department of Jobs Precincts and Regions (DJPR) is not effectively regulating operators’ compliance with their rehabilitation responsibilities. This exposes the state to significant financial risk because some sites have been poorly rehabilitated or not treated at all. If not addressed, these sites also present risks to Victorians and the environment.[FOBIF emphasis]

‘Systemic regulatory failures encompass:

  • using outdated cost estimates
  • not periodically reviewing bonds for their sufficiency—including a four-year bond review ‘moratorium’ for which there is no documentary evidence that it was duly authorised
  • failure to assure that site rehabilitation had actually occurred before returning bonds
  • approving inadequately specified rehabilitation plans
  • lack of enforcement activities.

‘Further, while some changes to address conflicts of interest were made following Parliament’s Independent Inquiry into the EPA in 2016, Earth Resources Regulation (ERR)—the primary mining regulator—still resides within DJPR, which seeks to foster and develop the mining industry.’ (FOBIF emphases).

The disturbing part of this is the revelation that the regulator and the promoter of mining are in the same department. This kind of compromise, where the regulator is too close to the industry it’s regulating, is all too common. Does the casino industry come to mind?

The upshot of this is that extensive areas of Victoria are being degraded by mining with little prospect of rehabilitation—unless the tax payer stumps up millions for the work ($361 million and counting, so far).

The DJPR, in its acknowledgement of the Auditor General’s report, accepted that change is necessary, recognising that

‘transformational improvement in site rehabilitation is required to protect public safety, land, infrastructure and the environment, in order to avoid any repeat of past problems associated with abandoned and legacy sites.’

We’re not sure how the transformational improvement is going. Watch this space.

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The middle of nowhere, on the outskirts of town

A strong group gathered yesterday in fine weather for FOBIF’s first walk of 2022. Mike Reeves had devised an ingenious route on the outskirts of Elphinstone: confined to a relatively small area, the walk wound through bushland gullies which could have been miles from anywhere, and provided enough ups and downs to generate a moderate amount of sweat. The walk ventured into areas set for a DELWP burn this season, and participants were interested in imagining what would be the outcome of the operation. Watch this space.

The middle of nowhere?FOBIF walkers wind through bushland near Elphinstone.

Our thanks to Mike for a brisk start to our walking year; and to Frances Cincotta for illuminating insights into the vegetation along the way.

Our April walk will be led by Jeremy Holland on Mount Alexander. Check this website for details.

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Strategic fuel breaks 1: the prospects for 2022

As we’ve reported (see our posts, with maps, here, here and here), DELWP is planning to create Strategic Fuel Breaks (SFB) in our region over the next two years. Castlemaine households have been recently letterboxed about this program. Note that the works as originally proposed have been held up by approvals problems. Initial works will be re-instating previous fire-breaks and concentrating on woody weeds: these are the works shown on the letter to households.

Grevillea dryophylla, Walmer forest. Enviro groups have been engaged in detailed conversations with DELWP in an effort to see that rare and vulnerable species are not damaged by the fuel breaks project.


Several local enviro groups have been in consultation with DELWP over the implementation of this program, with the focus being on protection of biodiversity values. Castlemaine Field naturalists, FOBIF, Castlemaine Landcare, Muckleford Landcare, Golden point Landcare,Friends of Kalimna Park and several individual community members have engaged in a detailed set of meetings on the project, including onsite meetings to look at the challenges involved.

The letter below to the SFB implementation team was drafted by Euan Moore, Castlemaine Field Naturalists Vice President, on behalf of the local groups involved.


First, I would like to thank you and your team for your patience and time working with our community group here in Castlemaine. We do appreciate your efforts.

So that we can avoid misunderstandings in future, this letter summarises what our community group believes is the way the Strategic Fuel Break (SFB) program will be implemented. Please let us know if we have misunderstood what your team said.

1 The SFBs to be implemented in the 2021/22 year are:

  1. Daltons Rd,
  2. Woodbrook Rd,
  3. Youngmans Track,
  4. Chewton-Fryerstown Rd & Wattle Gully,
  5. Around the Loddon Prison,
  6. Forest Creek / Leanganook Track,
  7. Kalimna Park adjacent to houses, etc.

2 The other SFBs (Fryers Ridge, Irishtown Track, Porcupine Ridge, Muckleford Forest, etc.) may be constructed in 2022/23 or later.

Continue reading

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Strategic Fuel Breaks 2: points of contention

Readers will remember that FOBIF’s major concern is that mulching of high value roadsides will be catastrophic both from a biodiversity and amenity point of view. Further, we are curious about the relationship between the SFB program and the Fire Operations plan which governs DELWP’s fuel reduction program.

In her response to Euan’s letter, Justine Leahy, senior leader of the SFB project team, has offered the following responses:

  1. On environmentalists’ concerns about mulching roadsides,

‘Areas proposed for mulching depend on the species present, and height and density of understory growth. As a general rule, mulching would not be required where shrubs are less than 1m tall or very sparse, however all woody weeds will be mulched and some native species such as Cassinia sifton are particularly flammable so may be mulched even if less than 1 m high.’

‘The depth of mulching from the road will be less than 20 m for Walmer SF, Fryers Range, Muckleford SF. Where mulching is proposed in areas of high biodiversity value, and where shrub height and density trigger the need for mulching, it will be less than 5 – 8 m from the road verge.’

  1. On the connection of the fuel breaks program with the fire operations plan:

‘Strategic Fuel Breaks are a key action of DELWP’s Advanced Forest and Fire Management strategy. The locations and treatment options for proposed SFBs were raised by the same operational staff who undertake planned burning and other nonburn fuel treatments as part of the Joint Fuel Management Program. Though they are presented separately on the Joint Fuel Management Plan SFBs will complement the burning and nonburn fuel treatments (as presented together here). Given the cyclic nature of the burning program, at some point SFBs will be utilised as pre-prepared burn boundaries that will not require any additional treatment. The ongoing management of SFBs will become the responsibility of the land manager, so the locations and treatments chosen are those with the greatest benefit for fire prevention and response.’

FOBIF accepts the clarification of the relation between the SFB and the control burn program at face value. On mulching, however, we are VERY concerned that Fryers Ridge road verges will be mulched for 5-8 metres on both sides. Consultations this year may –we hope–bring some improvements on this plan. In any case, we believe funding problems may cause delays in implementing the project.

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A great discovery

There’s not a great deal to be rejoicing about right now, but here’s one thing, a report by John Walter in the latest edition of Wombat Forestcare newsletter:

‘As a regular visitor to our forests, woodlands and grasslands, I can report that one of the great pleasures that one can receive is the finding of a new plant or fungus during your field trip.

‘Clusters of bright yellow flowers caught my eye and I quickly realised I was looking at an Acacia species that I had never seen before.’ Rare and endangered Acacia sporadica, Fryers Forest.

‘New does not have to be new to science to make it exciting, it could simply be a new species that you have not seen before or perhaps a species that you have not seen in a particular district. In my role with the Upper Campaspe Landcare Network, I have been spending a lot of my time chasing down as many of our insect pollinator species as I can. In September, I became the entire survey team for the project as Covid lockdowns prevented the core team from travelling interstate and up from Melbourne.

‘While finding and photographing new and interesting insects is exciting enough for me, on September 7 I was looking for an ideal location in the Fryers Ranges to conduct the first of our early spring pollinator surveys. The flowers at my proposed site were plentiful but the day simply was not warm enough to make the insects active so I walked a little further into the woodland to see what else might be flowering.

‘Clusters of bright yellow flowers caught my eye and I quickly realised I was looking at an Acacia species that I had never seen before. I knew of Ern Perkins’ record for Acacia sporadica and had previously attempted to locate those plants without success, and as these plants were about 500 metres away from Ern’s record, I had my suspicions that the new plants would prove to be Acacia sporadica. The plants were growing in clusters ranging from 10 stems up to 150 stems in each cluster. I located 17 clusters plus a number of apparently single stemmed plants that might prove to be additional plants or perhaps an outlier from one of the main clusters. In all, I counted over 600 stems and virtually all of them carried the bright golden flowers making quite a sight against the glaucous foliage

‘I confirmed my suspicions regarding the identity of these plants once I returned home, and then discovered that A. sporadica is listed as critically endangered in the June 2021 threatened species listings.

‘Finding the location of such a large population was very exciting and this species is only found in two other locations, one near Howqua and the other near Myrtleford in north-east Victoria. It suckers, forming clumps or clusters of stems up to 9 metres in diameter and apparently only rarely sets seed. One clump in the new population had over 150 stems and was easily 4 or 5 metres in diameter.

‘This new population would make the Fryers Ranges population the second largest and greatly increases the known population of this beautiful but endangered species.’

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Fire’s On

Mount Alexander Shire residents may have received a couple of DELWP leaflets in their letter boxes last week, informing them of upcoming management burns. All are fuel reduction exercises—ecology is a secondary consideration, if it’s a consideration at all. For that reason FOBIF has been concerned to quiz the Department as to the actual fuel reduction achievements in its previous burns. On that score we’re very sceptical, but try as we may, we can’t get DELWP to tell us frankly what they think they’ve achieved.

This is the related map, showing where burns are proposed:

You can check FOBIF’s submissions on this program here.

FOBIF is concerned, as always, by the detail of implementation of these exercises. In particular, we believe that the larger area burns are far too big to manage in detail. The Helge Track burn is 344 hectares, and the one proposed for the following year along Wewak Track is 470 hectares! We are convinced that ‘reduction’ burns conducted in this area over the last 20 years have actually generated more fuel. Questioned about this, fire officers have been… non committal, though we were interested to get the following admission from DELWP last year:

‘We have also observed that lower intensity burns seem to not generate as much fuel and accumulate fuels slower than burns that are generally burnt hotter. In addition, lower intensity burns generally maintain the Overall Fuel Hazard (OFH) levels under triggers for more years than higher intensity burns.’

Let’s hope that means an improvement in methods over those of the (sometimes) disastrous past.

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The cliffs of lunacy

Decades ago Simone Weil predicted that ‘‘We will see throughout the country the most incredible absurdities—and they will appear natural.’ She was right on any number of fronts. One of the most incredible is car advertisements on TV and online. Readers will remember that in 2019 FOBIF launched a complaint to the Ad Standards Bureau over a Suzuki commercial promoting reckless  and destructive driving: the ad actually suggested that responsible driving is boring, and driving around in circles was great fun. Our complaint was found to be partly justified, and the advertiser agreed to modify the ad…though we couldn’t see it made any difference.

In any case, the lunatic promotion of very silly behaviour continues. An avalanche of commercials for SUVs urges TV audiences to plough through creeks, churn up sand dunes, kick up dirt and disfigure beaches. A lot of this behaviour is actually dangerous, but presumably it appeals to the fantasies of those drivers who see it as an enhancement of their self image.

Our nomination for the silliest current commercial goes to Mitsubishi Outlander, whose effort culminates in the following image of a family ‘enjoying’ the outdoors:


Have a close look at where the car is:

We’re not sure how the happy family is going to get their picnic out of the boot. Maybe that’ll be in the sequel?

Does all this matter? Is anyone going to be stupid enough to park inches from a cliff edge? Probably not. But a significant percentage of people subjected to this barrage of propaganda will engage in bad practices. Have a look at this:

Castlemaine Diggings NHP, February 2022: some drivers have been persuaded that the only way to have fun is to gouge a bit of the bush. Our photo doesn’t really capture the destructive results of this hooning.

FOBIF has tilted at this particular windmill before, with mixed results. Should we try again? Mmmm…

Next in this infinite series: Flying, gouging, churning and splashing with Nissan Navara.

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