Leeuwin-Naturaliste National Park

In early 2011 the Conservation Commission, the DEC governing body, called for public comment on the draft management plan for the Leeuwin-Naturaliste national parks and reserves. As the BFF had made a close inspection of fire management issues in the region in October 2010, the following submission was forwarded to the DEC planning staff.


The Planning Officer

Department of Environment and Conservation

What is the Bushfire Front

The Bushfire Front (BFF) is a Western Australian voluntary organisation dedicated to protecting householders, farmers and forests from the ravages of bushfires. Our main focus is the southwest corner of WA, where hundreds of thousands of people, valuable property, public assets and priceless forests are threatened by wildfire.

We are practical bushfire specialists, with hundreds of years’ accumulated experience in preventing bushfire damage to people, property and forests. We are a group of West Australians deeply concerned to prevent bushfire damage to people, lives and forests. Each of us has worked in bushfire prevention, bushfire science, fire planning, administration or operations for over 35 years.

In this submission we comment only on the fire management aspects of the draft plan, whilst at the same time recognising the unique and beautiful biodiversity, and the need to protect it in the subject area. We would be happy to meet with either DEC or the Conservation Commission to discuss our concerns.

Overall Comments

As the draft plan is very detailed and rather large, it would have assisted review if there had been an Executive Summary that was a summary of the provisions of the plan, rather than an account of the policy and legal background..

Taking the fire management section as a whole, the BFF believes there is far too much emphasis on conservation of biodiversity in the region. DEC has not given enough weight to the fact that during the main fire season, i.e., January, there could be up to 20,000 people scattered across the Leeuwin-Naturaliste Ridge. Most of these people will be visitors who have no understanding at all of bushfires and will have no idea what to do in case they encounter one. The difficulties associated with locating them, warning them and managing such a large number are daunting indeed.

The Draft Plan also makes quite inadequate provision for protection from bushfire of the main town in the region, Margaret River. It recognises that the town, as well as other centres, faces an extreme bushfire threat, but makes only vague references to what will be done to mitigate the threat. The Plan needs to make much more specific provisions for crucial issues such as this.

We believe the fire management section of the Draft Plan needs extensive revision, to address the points made below.

Specific Points in the Draft Plan

Plan Section: Managing Fire to Protect Life and Community Assets

Issue: Threat to Human Life

Following Table 6, the draft quotes:

Other high risk areas include bushland in the vicinity of Margaret River, Prevelly, Yallingup, Dunsborough, Gracetown and Augusta. The townsites of Yallingup, Gracetown and Prevelly are surrounded by particularly heavy fuel loading and have limited access. However, the location of adequate refuge areas (i.e. the beach and reticulated ovals) and the presence of reticulated water in some of these areas indicate that bushfire poses a significant threat to infrastructure, but a limited threat to human life.

This statement is highly disputable. We are not aware of any rapid advice system to warn both residents and visitors that evacuation is immediately necessary. Any incoming fire maybe moving at >2 km per hour, leaving almost no time for people to react and seek shelter. Narrow and congested roads will further exacerbate the situation, for both fleeing motorists and incoming emergency services. It is likely that incoming emergency services will not be able to penetrate into certain areas because of fire activity or fallen trees.

The time delay because of notifications and distance to travel will be a major factor also.  Short, medium and long distance ember attack will add to spot fire development, further threatening access and lives. Older houses in particular, with outdated construction standards and materials, aggravated by dense dry flammable vegetation, will be highly vulnerable to ember attack. Aircraft suppression support is not available during darkness, further affecting control or containment. Steep slopes, with highly flammable vegetation, driven by strong winds, will increase rates of fire spread to very significant levels. GIVEN THIS, IT IS HIGHLY LIKELY THAT DEATHS AND SERIOUS INJURY TO PEOPLE WILL OCCUR.

Issue: Asset Protection

The Draft Plan states:

Asset protection areas are strategically located along the Leeuwin-Naturaliste Ridge immediately around key community assets (Map 4), and will be managed with a priority for the protection of life and the particular asset. The full range of options for bushfire mitigation described above may be employed in these areas. A key component of management will be prescribed burning and the use of mechanical fuel management techniques (see below). The management objectives for these areas are to maintain a reduced fuel level and a fire response capacity appropriate to protect the asset.

While the priority of asset protection areas and strategic protection areas is for the protection of life and community assets, the department will continue wherever possible, to apply fire in a way that does not compromise biodiversity values. For example, prescribed burns to protect life and community assets may be manipulated using smaller burn cells (and hence the potential for greater intervals between fire) to achieve biodiversity outcomes. However, where life and community asset protection coincides with high biodiversity values, and it is not possible to achieve multiple objectives, priority will be given to the protection of life and community assets.”

Apart from Map 4, no detail is available, or justification as to the size of the Asset Protection Areas, to justify the size of these areas and to afford any reasonable degree of protection to the coastal townships. Not stated either is whether these areas will be burn as a single unit, or in smaller units, which will diminish their effectiveness against incoming fires. 

Any township buffer less than 1 kilometre wide, or more than 8 years old, will afford little protection from incoming fires. The frequency of these burns or maximum fuel loadings acceptable is not specified either. Without this trigger, these burns may not be given the appropriate priority in the burn programme, and undertaken to meet protection needs of these townships on time.  

Why is there no Asset Protection zone west of Augusta, given that strong afternoon south westerly sea breezes are a feature of the climate there? The Asset Protection zone around Hamelin Bay is too small to be effective, as are the two small zones shown on Map 4 north west of Augusta.

The draft plan correctly states that the main town on the region, Margaret River, faces an extreme bushfire threat. It is reasonable to expect, therefore, that the fuel reduction burning activities will be designed to be effective in mitigating that risk. The Plan should state that this entire Asset Protection zone will be maintained with fuel load less than 8 tonnes/ha, or under perhaps 7 years old (in heath and scrub country) and that the burns in the zone will be relatively large to ensure that they are effective. In a zone of this nature, it is futile to use small burning cells, as they will not achieve the objective of the Asset Protection zone. Small burn cells will simply be bypassed by any bushfire.

We acknowledge that it is more difficult to do this around Yallingup, Gracetown and Prevelly as the vegetation type does not lend itself to fuel reduction burning as readily as the forest around Margaret River. Nevertheless, the mechanically slashed firebreaks around these centres are unlikely to be effective in stopping a bushfire, although they will provide an effective boundary for a fuel reduction burn. The plan needs to state explicitly that the native vegetation around those centres will be burnt to a depth of at least 1 kilometre, otherwise the fire threat to them will remain extreme.

The current level of THREATS to the coastal townships listed above are SO GRAVE  that IMMEDIATE action MUST be undertaken to reduce these threats. We suggest that the MINISTER for the ENVIRONMENT should make himself fully aware of this serious situation and respond accordingly.

Issue: Fire Exclusion Areas

The Draft Plan states that significant areas of vegetation will remain unburnt as scientific reference areas. No real justification is given for this. It is quite inappropriate to provide any such area at all in a region of such high fire risk as this, where the main priority should be protection of life and property. Complete protection from fire is widely acknowledged as entirely unnatural in this part of the State, so why impose a management regime so divorced from reality?

We are particularly concerned at the large fire exclusion area to the west of the Boranup karri forest. Such a large area poses a major threat to this unique outlier of karri. A fire starting on the coast there would sweep very rapidly into the karri and cause major damage. We find it difficult to reconcile DEC’s professed concern about conservation of biodiversity with this obvious threat.

Assuming that significant areas of coastal vegetation will remain unburnt for biodiversity purposes for extended periods of time, rates of spread and fire behaviour in these areas will be significant, and promote long distance spotting.

Issue: Need for a Regional Approach

The plan does not give sufficient weight to the need to manage the fuels outside crown land. There are very heavy fuels on much of the forested private land in the region. Heavy fuels on other land could well nullify any fuel management activities by DEC. It is totally inadequate to state that DEC will continue to liaise with local government, FESA, etc, for bushfire mitigation. The plan should clearly state that DEC will work with those bodies to develop a regional fire management plan that will integrate fuel management on public and private land.

It would greatly assist DEC and FESA to make residents of the region aware of the level of fire risk if maps showing fuel loads across the whole Leeuwin-Naturaliste Ridge were made public in spring each year.

Issue: Accountability

It should be noted that whilst DEC manages the land allocated to its care, it is the Conservation Commission that determines and sets the policy by which DEC must operate. The  Conservation Commission must therefore be FULLY ACCOUNTABLE for any policy which puts life and property at risk, and when it ultimately FAILS, be FULLY responsible for the outcome of any tragedy which occurs.

 The Bushfire Front 18 February 2011