Bush Fire Front

Submission:EPA Review of CALM Fire Mgt

Review of CALM’s bushfire management by the EPA - a submission from the Bushfire Front of WA

1. The Bushfire Front: our aims in this submission

We are volunteers, and are not affiliated with any government agency or organisation. We are not stirrers or fanatics, but members of the community genuinely anxious about the bushfire situation, and wishing to prevent bushfire damage. Our membership is set out in the attachment.

Our bushfire management experience ranges across the whole of Australia and many overseas countries, so that we are able to appreciate the WA situation and challenges in the widest context. We have read the Terms of Reference given to the EPA for this study by the Minister, and we have attended one public meeting conducted by the EPA at which issues were raised. Over the last 12 months we have had a number of meetings with CALM’s senior staff and with the specialist fire management officers, and we have inspected the outcomes of fire policy in the field.

We are familiar with the arguments put forward by the main opponents to CALM’s fire management approach. Mostly we regard these as unscientific, based on ideology rather than actual experience, and coming from a political agenda rather than from the aim of improving the overall system of forest and land management. We also deplore the personal attacks made on CALM staff by some of the more vocal of the “save the forest” brigade.

Our objective in this submission is to draw to the attention of the EPA a range of key issues with respect to bushfire management, to provide our perspective on them and to suggest ways in which the EPA can influence future management in the direction of World’s Best Practice. At the same time, we take the opportunity to debunk some of the myths which are commonly raised by CALM’s critics, in the expectation that all of these myths will be put forward to the EPA once again as part of this study.

2. Our position with respect to CALM and CALM’s fire management

There are many difficulties for CALM. Part of the problem is that CALM is a controversial agency, often caught in the middle between competing political agendas, and always in the sights of the environmental activists. It is also evolving quite rapidly in terms of its philosophy, structure and culture, and in many ways is an agency in transition. One serious issue is that recent appointments and structural changes have resulted in a paucity of bushfire experience in the Department’s upper echelons. This has led to the adoption of some retrogressive policies, such as the closure of southwest districts which once provided the staff and expertise to conduct fire management programs in forest areas, and a massive scaling-back of fire research programs in favour of more politically correct research in other fields.

Difficulties for CALM are exacerbated by the fact that the management plans which CALM must implement are prepared to the requirements ofthe WA Conservation Commission, an organisation with no bushfire managementexpertise, and which is not accountable for fire management on the ground.

CALM also has a serious problem with the media in WA, especially the ABC and The West Australian newspaper, both of which tend to look for opportunities to criticise the Department, rather than support it. The combined attention of critical environmentalists and critical media mean that bushfire management is always in the spotlight, and no mistakes are tolerated. This has resulted in a high level of risk-aversion in some sections of the Department, and an understandable timidity in relation to the prescribed burning program which in turn has contributed tothe burning program now being years behind schedule.

The accumulative effects of all these factors have had a profound influence on the way CALM has gone about its bushfire management on the ground in recent years and help to explain the widening gap between current management and Best Practice bushfire management on CALM land.

At the same time, we recognise that within CALM’s specialist fire branch, and at regional level, there remains a cadre of professional and expert officers who have a lifetime of fire management experience. These people are doing a magnificent but largely thankless task. They have responded professionally to the demands of the new culture in the Department, and have modified systems accordingly. They are also in a transitional phase. But at the same time they are the butt of never-ending and often personal attacks from “save the forest” activists, and are subjected to clever hindsight wisdom in the wake of every fire.  Even within CALM, fire control officers in the field are sneered at by some of the Headquarters and Woodvale officers who themselves are never required to take responsibility when fires occur.

We are also aware, from our own experience, that to CALM’s specialist, regional and district staff, bushfire management is a 12 months of the year, 24 hour a day preoccupation. If they are not dealing with a fire, they are preparing for one, or defending themselves against critics and the media. Many CALM field staff who spend a lifetime in fire control work end up with stress-related illnesses.

It is not widely understood that bushfire management is difficult not just in a technical sense, but because it must be practiced within a community with widely different political perspectives and social interests and an unforgiving attitude to mistakes. It is also an inexact science, since bushfires occur largely at random, and all fires burn at the whim of variables which humans cannot completely control or accurately predict. The men and women who do this work should be supported by the community, not sneered at, especially not by people who are not accountable for outcomes.

The Bushfire Front urges the EPA to consider the human elements of bushfire management, and to understand the many social and political complexities within which CALM is attempting to do this work.

3. The Bushfire Cycle and its implications

A fundamental position taken by the Bushfire Front is that the right time for an inquiry into bushfire management is before, not after a bushfire disaster. We are acutely aware of the well-known phenomenon known to foresters and land managers as “the bushfire cycle”, which turns in the following way:

The Bushfire Cycle

First comes the bushfire disaster. Lives are lost, towns and farms and forests are blackened. Then there is a flurry of inquiries, political angst, Coroner’s reports and litigation. Heads roll, new appointments are made, young Turks move into positions of influence. The whole system is energised. Agencies redouble their efforts to design and implement a more effective bushfire system, always incorporating mitigation and prevention as well as suppression. Funds become available for new staff, equipment, radios, roads, fuel-reduction burning, training and research. Bushfire law is revised and strictly enforced. The success of all this is striking: disastrous bushfires do not occur.However, a successful bushfire system is always self-defeating. It’s very success leads to community apathy, political complacency, agency overconfidence, foolish planning decisions, budgetary re-arrangements and a softer approach to law enforcement. In these conditions, weirdo pressure groups flourish, promoting impractical (but attractively cheap) bushfire solutions. Year-by-year there are more and deeper cut-backs to bushfire mitigation and prevention budgets. Firefighter numbers decline, equipment is dispersed, fuels accumulate. After about 10-15 years, the first unstoppable fires start to occur, and before the system can be put back on the rails, there is another terrible disaster. The cycle then begins again.

It is our view that WA is currently nearing the end of the complacency phase of this cycle. There is less focus on bushfire mitigation and prevention, suppression resources have melted away, the first large, intense and unstoppable bushfires occurred in southwest forests last summer after a period of several decades mostly free from such fires, and government policy on forest management is increasingly influenced by pressure groups with a narrow political agenda, no professional competence in the area and no interest in a holistic approach to bushfire management. Unless the cycle is broken, a disaster is inevitable.

The review of CALM’s bushfire management by the EPA provides an opportunity for the EPA to make a positive contribution in this field (hopefully) before there is a disaster, i.e. to break the bushfire cycle.

4. Opportunity and risks for the EPA

The EPA is presented with an excellent opportunity when it comes to this inquiry: there are a number of other inquires underway at present, and several recent reviews have been undertaken and either published or are soon to be published, e.g.

* The very professional internal report prepared by CALM’s Chris Muller;

* It is likely that the Coroner’s Report into the Canberra bushfires will also be released in time for the EPA to review its findings.

The EPA is also able to draw upon expert input from organisations such as CSIRO’s bushfire unit in Canberra and personnel with extensive bushfire expertise and practical experience but who are not part of CALM, such as the Bushfire Front. These sources can provide information and input on which the EPA can build, without having to go over the same ground or reinvent the same wheels.

At the same time, there is a risk to the EPA associated with this inquiry and report. This arises from the EPA’s lack of internal bushfire management expertise and experience, and because an EPA inquiry inevitably triggers CALM’s main critics, i.e., environmental “save the forest” pressure groups. These groups are politically effective and media-savvy, but have abandoned science and lack practical fire management experience. They will exert a lot of pressure on the EPA to attack CALM and denigrate its staff. Such an approach can only make it harder for CALM to protect the State’s assets from bushfire damage.

It is a fundamental point that a “no fire” or a “let burn” approach to bushfires are not viable approaches to the bushfire issue. Some system of active bushfire management must exist. Nor is radical overnight change possible, mostly for reasons of cost, but also because of the heavy risks of introducing an untried system. Change will occur, as it has in the past, but must be developed over time, making the best use of current knowledge and skills, with the support of those who have to implement the changes and with a positive end in sight. The Bushfire Front believes that endpoint should be for WA to lead the world in Best Practice bushfire management, a system which takes into account all values, not just biodiversity or the environment.

5. The key questions

In commencing this review, the EPA needs to develop its position on some key questions:

* What is the historical context in which current bushfire management is conducted by CALM?

It is essential to that the EPA understands, and helps the community to understand, how we got to where we are, the key social and political influences, and the steady advance of scientific and technical knowledge associated with bushfire management in Western Australia. Without this perspective, it is easy to fall into the trap of seeing the current system of bushfire management as something which sprang fully grown from the current agency, rather than being the product of long experience and a variety of influences over a very long time. Bushfire management in WA has always evolved and is still evolving. A brief historical review since the early 1920s by land management agencies such as the Forests Department, the National Parks Authority and CALM will demonstrate the way policy, practice, philosophy, technology and science has evolved, and the professional way in which the staff have responded and adapted to different influences. This evolution, and the capacity to evolve is never acknowledged by CALM’s critics, but it is a proud story, and crucial as context to any review of the current situation.

* What are the outcomes the EPA and the community expects of CALM’s fire management?

The great mistake made by the critics of current bushfire management is to focus on processes rather than outcomes. This is partly because the outcomes have not been properly defined or agreed upon and we do not have effective ways of measuring progress towards them. But there is also the problem that different people are looking for different outcomes, or have different priorities.

This is an area in which the EPA can make a very positive contribution, because clearly CALM is finding it hard to respond to the different pressures upon it. Furthermore, the EPA cannot make any judgements about the processes of CALM’s fire management until it understands, and hopefully supports the outcomes which these processes are being (or should be) directed to achieve.

In fire management, as in any form of management when there are multiple outcomes, it is also essential to rank policy goals. This is because there is a range of options which fire managers can adopt, and different approaches can be selected to optimise different outcomes. A “Save the Quokka Association” for example, is likely to criticise CALM for not having a fire management system which is specifically targeted to protect quokkas. But CALM could easily design it’s whole bushfire management system around the need to optimise quokka populations. The trouble is, they would immediately then ask themselves the next question - if we do this, what else will suffer? Single-interest groups are never faced with having to make the sort of trade-off decisions which policy-makers and land managers must face every day.

The EPA can assist CALM and the community as a whole by taking a broad view of bushfire management, making its desired outcomes explicit and ranking them so that managers clearly know what is expected of them, rather than zeroing-in on narrow aspects of the management process. An effective way to do this is to participate in the development of CALM’s new fire policy, which we understand is to be released during the EPA review.

* Who is ultimately accountable for outcomes, and responsible for actions?

The EPA has to remind itself and its audience that bushfire management is not a theoretical exercise or simply a matter for debate between learned academics - it involves hard-decision making by policy-makers and managers in the field. There are many choices between doing one thing or another, or not doing something in order to do something else. Decision-making in a wildfire situation is usually required “on the run” and under conditions of great stress, especially where lives are at risk, and there are high levels of uncertainty about issues like wind strength and direction.

Similarly, running a large prescribed burn, especially in southern forests, contains risks and uncertainties. Every effort is made to minimise these, but some burns are too hot, some too cool and some escape their boundaries. This is not the fault of the concept, or of the system, or of the people involved. It is simply an expression of what happens in every field of human endeavor - we try our best to get the best results, but unexpected things happen. It also emphasises the need for CALM to rebuild its fire research program, to supply field officers with continuously updated technologies and information.

There is also the question of lead-time. Bushfire mitigation and fire prevention programs cannot be achieved overnight. Years of planning and preparation on the ground are needed. Take the example, common these days, where CALM is forced to cancel a prescribed burn because of complaints from environmental activists. This has a double impact: (i) the accumulation of another year’s fuel, making an unstoppable wildfire more likely; and (ii) the loss of up to three year’s lead time in planning the burn and carrying out the preparatory work on the ground and with neighbours and the community.

It is critical that the EPA acknowledges issues relating to responsibility and accountability.

* What are the options available to CALM and what are the likely consequences (in terms of bushfire outcomes as well as ecological impacts) of these options?

The principles of bushfire management are well understood and enough is known about the science and technology to set out a range of different approaches. The question is not what to do, but what will be the consequences of following one approach or another?  Examples of some common suggestions to CALM include:

(i) Fuel reduction burning should be confined only to areas around towns. [The consequence of this policy would be massive unstoppable bushfires in the remaining forest, as seen last summer in Victoria and ACT.](ii) People should be told that if they live in or near the forest, they should expect to get burnt out, it’s their own fault for choosing to live in a fire prone area. [The consequence of this approach would be massive damages litigation against the agency under common law, especially from people who already live in these areas and have an expectation that the government will mitigate bushfire risks in the neighborhood on crown lands.](iii) CALM should employ thousands of firefighters and station them permanently all over the forest, so that any fire which starts can be instantly suppressed. [Anyone who has ever fought a bushfire on a hot windy day in long-unburnt jarrah forest will recognise that this concept is laughably impractical. The first consequence would be a financial cost of millions of dollars for the thousands of men and machines needed, the second would be massive bushfires and probably the loss of many firefighter lives.](iv) CALM should let bushfires burn and not attempt suppression, except at the edges of towns. [Again the consequence would be unstoppable fires burning out of the forest under the worst conditions, as happened at Canberra, plus major damages litigation under common law].(v) CALM should install a massive irrigation system with sprinklers all over the forest. [Presumably the water would come from the Ord River pipeline].

Most suggestions for alternative fire management systems are clearly based on the philosophy that “fire is bad” and seek a situation where either the world must be manipulated to permanently exclude fire, or to one where we avert our eyes and pretend fires don’t exist. Both approaches ignore history, science and the law.

Any new and different fire management strategy, must pass tests relating to practicality, legality, cost-effectiveness and community acceptability in the long-term. By itself, “saving the quokka” is not enough.

It is claimed by some that prescribed burning is responsible for the release of large quantities of carbon dioxide, and thus contributes to increased greenhouse effects. Prescribed burns do cause emissions of carbon dioxide, but far less than the emissions that would be produced by the wildfires that would otherwise inevitably cover the same area. Furthermore, the emissions are cancelled out in a few years as the burst of regrowth after a burn sequestrates the same amount of carbon that was previously released. It is really a cyclic process that has been occurring for millennia, unlike industrial and vehicle emissions.

There are also objections to the smoke produced by prescribed burns. Although procedures are in place to minimise the risk of smoke drifting over urban areas, this does sometimes happen, for short periods. Opposition to the smoke is based on a distaste for air pollution and putative adverse effect son human health, especially for asthma sufferers. The fact is, as is well known to the EPA through its own air quality monitoring studies, smoke from prescribed burning is a minor component of metropolitan air pollution. We submit that it is far better to endure a few hours of smoke from prescribed burning than days of intense smoke pollution from wildfires, as well as the damage caused by the fires. Moreover, if given adequate warning of smoke events, those at risk can take measures to  minimize the impact. Compliance with air pollution regulations is currently a major constraint on prescribed burning programs near Perth. Temporary seasonal relaxation of these regulations would allow far greater degree of safety from bushfires to be achieved near the metropolitan area.

* What are the gaps in knowledge, or the areas where technical improvements are needed?

We never know enough, improvements are always possible, change stemming from research and experience is inevitable. This is why in the past WA had the finest bushfire research unit in Australia and as good as any in the world. This research effort was the engine room for all the technical changes which have occurred, and which has allowed new approaches to be tried. That this has been let slip in recent years is a serious issue, and this should be one of the EPA’s main interests and concerns. WA should again have an active well-funded bushfire research team, stationed in the forest, and charged with providing both the intellectual and technical leadership for the Department.

There is another factor. The main research emphasis in Australia in recent years has been on research into fire ecology and environmental impacts, rather than fire operations. This was a response to the ideology that “fire is bad, and damages the environment.” This has led to a situation where little research has been done on fire technology and control.

The EPA should be careful to highlight the narrowness of its own terms of reference in this review. There is an important issue of overall fire management in WA including non-CALM land, and issues such as legislation, ministerial arrangements and accountability, monitoring and reporting and so on, i.e. Best Practice.

The EPA must draw to the attention of the Minister that there is a need for a major overhaul of the whole bushfire management system in WA, and that this extends way beyond CALM.

The basic position taken by opponents of prescribed burning is that, from an environmental or ecological perspective, “fire is bad”. Fire is regarded as an agency which damages and destroys ecosystems. When taken to its logical conclusion, the default situation, against which any burning program must be assessed, is one in which fire does not occur. If fire is bad, then no-fire is good. This kindergarten-level approach to ecology and the Australian environment has had a number of consequences:

* The denial of Aboriginal burning and the rejection of David Ward’s grass tree research; fire in the forest is seen as a product of European invasion, or of commercial interests.* The need for CALM to constantly justify insertion of fire into the landscape, while no-one seems to have to justify withdrawal of fire and the on-going focus of research into the so-called deleterious impacts of prescribed burning.* The view of some wildlife researchers that long-unburnt areas are “the control” against which burnt areas must be assessed, with any differences between them being judged as unfavorable towards burnt areas.* The view of some soil scientists that fire causes “loss” of nutrients and destruction of soil microbes, rather than “maintenance” of an environment to which the Australian native flora and fauna is thoroughly adapted; and* The deeply held view in the community that fire is “un-natural” and the repeated statements by journalists it “destroys” the forest.

There is a quite different way in which this issue can be approached. This is to accept that fire is a natural element of the Australian ecosystem and always has been. The bush burnt, often. Fire disturbs, but does not destroy. Australian plants and animals have evolved in the presence of fire. Even if burning by Aboriginals is denied (as many environmentalists, but no aboriginal people do) the very simplest understanding of climate, fuel accumulation and flammability, lightning strikes and fire behaviour demonstrates that fires occurred regularly and were widespread in pre-European times.

Furthermore, pre-European times reach back for hundreds of thousands of years. The number of different fire regimes which might have applied from time to time in any patch of bush is no doubt astronomical , but you can be sure that whatever it was, the species present in the forest today survived them. This compares with CALM’s prescribed burning program which reaches back to the mid-1950s and which itself has been simultaneously overlaid by a regime of summer wildfires. The idea that in this brief time agency policies have damaged and destroyed ecosystems is so absurd that it can only be based on the most rigid and blinkered of ideologies.

The ultimate weakness of the position of the anti-burning environmental activists is this: to “save” forests from logging, they are described as pristine, virginal, precious, fragile ecosystems. Strangely in another forum, the same forests are described by the same people as having been ruined, simplified, eroded and corrupted, by CALM’s prescribed burning programs.

7. The natural variability within a large prescribed burn

The EPA will no doubt receive many submissions which say “we are not opposed to prescribed burning, we just wish CALM would do it in such a way that conserves the biodiversity, not destroys it”. This view is supported by drawing attention to a regime where burns are generally lit under mild rather than hot conditions, are done in the spring and at about a 7-8 year interval. It is claimed that this “rigid routine” leads to uniformity, and thus to loss of biodiversity.

Setting aside the fact that no loss of biodiversity as a result of this sort of burning has ever been actually demonstrated, there is another important issue: this is the natural diversity in any fire or any prescribed burn.

Few people who have not themselves carried out a CALM prescribed burn, or made a detailed study of burn outcomes over many hectares and successive burns, realise the wide range of diversity which occurs within prescribed burns, especially mild spring burns. This results from the wide variations in fire intensity occurring within a burn or between burns. Variability is associated with

* Topography - fires burn more rapidly up slope than on the flat or downslope;

* Presence of swamps, rock outcrops, roads and other barriers which slow or disrupt the run of a fire, or cause it to pick up.

CALM’s critics are always quick to point to areas of scorched crowns, or places where burns became more intense than forecast. This is portrayed as a reason to not do prescribed burns.  The contribution of diversity in fire regime to biodiversity is ignored. So is the fact that often up to 30% of a burn area normally remains unburnt in various pockets.

There is a wide variation in the outcome of any prescribed burn, ranging from areas unburnt to areas burnt quite hot. This variation is carried through to the next burn, and so on, because areas left unburnt in one burn, will carry double the fuel the next time around and are thus more likely to carry a more intense fire. But from the viewpoint of biodiversity, this is good! And it is especially good compared with the loss of diversity associated with the two alternatives, i.e. the very large wildfire consuming everything in its path or the long unburnt area with heavy fuels, waiting to be consumed.

Fire (and thus prescribed burning) clearly has a vital role in the maintenance of the health and vitality of forests and woodlands. Fire stimulates regeneration of plant communities and associated fauna habitat.  Prescribed fire (at the lower levels of intensity) ensures mosaics and natural ecological boundaries within the landscape are maintained.  On the other hand, these subtle features are lost if the chosen fire regime is one of successive large-scale high intensity fires that leave no corner of the landscape unburnt.Even though most of WA’s forest is now managed primarily for nature conservation values there is still an essential need to manage fire regimes through the planned application of fire.  The EPA’s attention is drawn to a 2002 report prepared by the Fire Ecology Working Group of the Victorian Department of Natural Resources and Environment. This demonstrated that the majority of vegetation associations found on public land experienced fires less frequently than required to maintain a balanced distribution of age-classes.  Vegetation associations can in fact be threatened by under-exposure to fire, rather than by the commonly-perceived threat of too-frequent burning as claimed by CALM’s critics. Exactly the same situation applies in WA.We are well aware of the deliberate variation to burning regimes applied by CALM. This includes autumn burning and variation in rotation lengths. A theoretical approach already exists which incorporates a “regeneration phase”, and when the practicalities are solved, this can be applied. The idea that CALM applies a rigid prescription that results in ecological simplification is untrue, and cannot be demonstrated on the ground.

The intensity of a fire is influenced by three main variables: the heat of combustion of the fuel, the speed of the fire and the fuel consumed. For practical purposes the heat of combustion of natural fuels can be considered constant; the speed of the fire is determined by the weather and the fuel; the fuel consumed is determined by the total available fuel and the intensity of the fire.

7. The consequences of letting the burning program slip

The consequences are clear: as fuel levels  increase in the forest, so fires will become harder to control. Eventually will come a day when many fires start at the same time, probably as a result of lightning, under hot, dry and windy conditions. Large, intense, unstoppable killer fires will occur, and the damage will be immense. A side effect of these increased fuel levels and associated increased difficulty in fire control is greatly increased danger to firefighters. This is a very significant to which the EPA should give consideration.

8. The consequences of large intense wildfire

* Loss of well-loved landscapes in national parks and forest reserves.

Quite apart from the human, social and economic damage caused by high intensity fires, there are profound and long-term environmental impacts. These include

* Massive injections of smoke into the atmosphere, under uncontrolled conditions.

Recreational facilities in the forest such as picnic and camping areas, huts, signs and interpretive material are  all susceptible to high intensity fires. The severe Mt Cooke fire last summer destroyed a range of important facilities on the Bibbulmun Track, the replacement of which required the use of funds withdrawn from other recreational programs.

In summary:

Most of the forests of the southwest are also catchment areas for water supply. The value of these catchments is threatened by high intensity bushfires. It is thus obvious why historically, forest managers have given a high priority to protecting these values through a program of low intensity burning aimed at minimising the occurrence of high intensity fires.

10.   Is there an alternative strategy which works?

There are two broad approaches to bushfire management: (i) the suppression-alone approach and (ii) the mitigation/ suppression approach. Both have a number of elements in common (e.g., good detection systems, good access to the forest, a cadre of trained and well equipped personnel) but there is a significant difference.

Advocates of the suppression approach believe that any fire can be suppressed provided you can get sufficient fire-fighting resources onto the fire quickly enough. All of the eggs, as it were, are in one basket: find the fire and put it out before it gets too big.

Advocates of the mitigation/suppression approach accept that the suppression approach is generally adequate in some circumstances, e.g. in urban areas, or in some agricultural areas where the fuels are mostly grass, crop or pasture. It can also work during mild summers when few fires occur (which happens quite regularly, especially in southern forests). However, the suppression approach is clearly deficient in forests subjected to drought and severe fire weather, and when multiple fires occur simultaneously. To cover these situations, which also occur regularly in all Australian forests something extra is needed. In addition to having effective firefighting resources land managers must have taken measures in advance of the fire occurring to reduce fire intensity and improve the ease and safety of suppression work.

In fact, nowhere in the world has a bushfire management system based on suppressionalone ever been successful. Even the Americans with their enormous wealth and resources cannot suppress high intensity bushfires when they occur under bad conditions, in heavy fuel and in multiples. This has been demonstrated repeatedly in recent North American summers. The Australian experience is identical. CALM itself could not successfully suppress two forest fires occurring at the same time last summer before they got out of hand and caused serious damage.

The effectiveness of fuel reduction burning in assisting wildfire suppression is often queried by CALM’s critics. They claim that areas previously burnt will reburn,  that fuels reaccumulate, or that shrub density is greater after a burn, therefore making firefighting in these areas harder. The Bushfire Front has one question to people making these claims: how would you know?

To the best of our knowledge none of CALM’s critics have themselves ever been responsible for a major firefighting task under bad conditions, or have carried out experimental fires which test the effect of variations in fuel levels on fire behaviour. Claims that fuel reduction burning is a waste of time are based on an ideological opposition to prescribed burning, not on hard experience or science. It is a revealing fact that the contrary view is held by all people who have been responsible for firefighting in forests under severe conditions. There is a fundamental point at issue for the EPA here: is this review to accept the views of amateurs, or the advice of professionals who have actually been involved in bushfire management?

The EPA will be told that the town of Dwellingup burned in 1961 despite the fact that annual reports of the day indicate that prescribed burning had been carried out in the Dwellingup district in previous years. This is a false argument. Burning had been done in parts of the district following changes to the Department’s policy in the mid-1950s, but there were long unburnt areas adjacent to the town, and it was in these areas that the firestorm developed which had such tragic consequences. Post-fire surveys highlighted the value of prescribed burns in reducing fire damage to the forest and providing safe areas from which suppression work could be mounted. Furthermore, broad-acre prescribed burning was in its infancy in the 1950s, and burns tended to be light and small or in narrow strips. The intense wildfires which developed following a dry lightning storm were able to burn around, or spot over previous burns.

There are many documented cases in which bushfires have been controlled once the headfire ran into an area of light fuel where a prescribed burn had been done. Every bushfire manager has had this experience. To deny it is to deny reality.

It is true that the short-term visual effects of any fire in the bush are dramatic: shrubs and flowers are reduced to ash, kangaroos depart for greener pastures, tree trunks are blackened and their leaves scorched brown, and for a week or so after the fire, there is an unusual silence. But this is not the final product, it is not the outcome of a prescribed burn.

The powers of recovery of Australian native forests after fire are remarkable. Within days the first new green shoots appear, and within weeks, there is a sheen of green across the soil surface and in the shrub and tree canopy. Pioneer species such as kangaroo and cats paws flourish. In tough resilient ecosystems like the jarrah forest, the visual effects of mild fire can disappear within 18 months and it takes an experienced eye to see that the area had been burnt at all.

The more intense the fire, however, the more dramatic the visual effect, and the longer it takes for the landscape to recover. This is particularly true in the karri forest. Because of the height of the tree canopy above the flames, and the very rapid regrowth of understorey shrubs, the visual effect of a mild intensity prescribed burn disappears very rapidly. On the other hand, a high intensity wildfire will kill mature karri trees, or will kill the tree crowns, so that a landscape remains of large dead trees, or trees with dead crowns and bushy epicormic growth up the stem. These can persist for decades, as monuments of the fire. This happened in the Walpole Nornalup National Park, where hundreds of dead karri trees are still standing after being killed in the severe bushfires there over half a century ago.

Opposition to prescribed burning on the basis of its visual impact stems from regarding the burn as an outcome, not as a process. Prescribed burns are at the low end of fire intensity, and do cause a change to the appearance of the bush, but the effect is temporary. Spring burns have the disadvantage of occurring in “the wildflower season” but the advantage of the most rapid recovery because most native plants produce their new leaves over summer. Autumn burns  have little effect on blossom, but visual recovery is slower. Jarrah trees scorched brown in an autumn burn can take nearly ten months to regrow their crowns, whereas a tree scorched in spring is completely green again within a few weeks.

We are aware that CALM seeks to minimise the adverse visual effects of prescribed burns. Burns are lit under the coolest conditions which will still provide effective fuel reduction; tree canopy height is measured before a prescription is drawn up so as to reduce the risk of scorch; burns are confined to one side of a tourist road in the one season, or are set back from the road edge, so as to minimise the amount of burnt bush tourists observe as they drive through. In the karri forest, burn intensity is kept as low as possible to avoid damage to mature trees.

It is also possible to minimise the undesirable visual effects of wildfire. This is by ensuring the forest is buffered against the disturbance - i.e., has the capacity to absorb it, rather than magnify it. The best way to buffer a forest landscape against the visual impact of high intensity fire is to maintain low fuels so that when a fire occurs, its intensity is reduced. This is particularly true of the karri forest, whose visual beauty is held in high regard by West Australians and is an important resource for tourists. This prized landscape can only be preserved in the long term by buffering it against high intensity fire by regular fuel reduction prescribed burning. The alternative of letting fuels accumulate so that high intensity fires are inevitable, condemns the karri forest to true, long-term landscape degradation. Young karri trees (even those only 5 or 10 years old) can recover rapidly from defoliation by fire, but a mature karri tree which is defoliated and has its bark cooked off never recovers.

12.    The Kings Park furphy

A view often expressed by those opposed to CALM’s prescribed burning is that CALM should follow the lead of Kings Park, which is managed by ecologists and where prescribed burning is banned. The implication is that what is right for Kings Park should be right for the whole of the southwest forests.

In fact, Kings Park is not typical of southwest forests. Consider the following:

It is our view that the success of the Kings Park approach is doubtful and it cannot be held up as a model for southwest forests.

13.    The endangered species furphy

Opponents of CALM’s prescribed burning programs are fond of blaming burning for the endangerment of species and for the loss of species. The favourite example is the Noisy Scrub Bird, said to have survived only in long unburnt areas, and driven into these areas by CALM’s burning programs.

There are many endangered species in southwest forests - but this is not as a result of prescribed burning. The Noisy Scrub Bird for example disappeared from forest areas decades before the prescribed burning program commenced.

What we do know without any doubt is that the small mammals and ground-inhabiting birds which are now regarded as endangered or threatened all recover in forest areas as soon as fox predation is removed. This is independent of the prescribed burning program. We also know that in the absence of foxes, the Noisy Scrub bird moves readily into, and lives happily in recently burnt bush, and has in fact been reintroduced successfully to jarrah forests where prescribed burning occurs.

The statement that CALM’s burning is causing loss of species is the opposite of what is actually happening. The burning program is protecting habitat (and animals) from incineration in high intensity fires, and in conjunction with fox control is allowing their numbers to grow rapidly.

Opponents of prescribed burning also claim that burning cycles are too short to allow regeneration of some plant species and that consequently these species are becoming extinct. The species are not named. In fact, intensive research into this concern has revealed that there are no plant species in the forest regions which are incapable of surviving periodic low intensity fires.

It is essential that CALM’s prescribed burning program has input from ecologists, is monitored and is updated in the light of research and experience. On the other hand, the environmental impact of the alternative, i.e., large high intensity all-consuming wildfires, must also be considered. The most sensible approach is to optimise community safety and minimise environmental impacts, while intensely researching the whole issue. This is the essence of Best Practice bushfire management.

(vi) Bushfire management will have community and media support, stemming from strong political leadership and a high level of public understanding of the issues.

This definition can be elaborated into the key strategic elements which together can be taken as a template for best practice bushfire management in WA. There are eleven such key elements, and all must be in place for a fire management system to be classed as “best practice”. They are set out below together with a comment on the current status for each, and the approach which the EPA could take.

The EPA should recommend: a complete review of bushfire-related legislation, leading to a new Bush Fires Act and a revision of the CALM Act which lifts fire management to equal status with?  conservation, plus a clear statement of legislative hierachy.

2. A State Bushfire Policy. It is essential that there is a written policy, developed and signed-off at the highest level of government. This will set out clear objectives for  all agencies, fire services and local government authorities, establish priorities for protection and responsibility for bushfire management. It will be reviewed on a 5-yearly basis with opportunity for community input, and specify the legislative means by which it will be accomplished through each of the agencies involved in its application. Above all, the Policy will establish clear lines of accountability for outcomes, especially at Ministerial, agency and Local Government levels.

The EPA should recommend: that Cabinet prepare and implement a State Bushfire Policy, setting the policy framework, priorities and accountability right across government, and providing CALM and the Conservation Commission (CCWA) with clear policy guidelines within which to develop their own fire policy.

3. An intergovernmental arrangement (MOU) between the State and the Commonwealth. This is essential given that the State is fundamentally responsible for land management, but the Commonwealth is the principal source of funds. The MOU will set out respective responsibilities and arrangements for funding bushfire operations and fire research and for maintaining officer-level liaison in the areas of education, operations and research.

The EPA should recommend: that the WA government take the initiative, either on its own account or through COAG, to develop an intergovernmental agreement on bushfire issues with the Commonwealth.

4. A State level inter-agency agreement between the forest management agency and other key agencies. There are many State-level agencies with responsibilities which impinge on bushfire management. For the system to work properly it is essential that there is an effective mechanism for coordination and cooperation, plus a capacity for agreeing on priorities. An effective Bushfire Management Interagency Agreement will have been jointly prepared by CALM/CCWA, FESA, EPA, Health, Local Government, Planning and Police. It would cover agreed responsibilities and accountabilities for cross-agency issues, plus mechanisms for coordination and cooperation, conflict resolution, incident management and emergency decision-making.

The EPA should recommend: that arising out of the new State Bushfire Policy, a Bushfire Coordinating Group should be formed to oversee all aspects of policy implementation.

5. A single land management organisation responsible for forest planning and management. Inefficiencies, conflict and poor planning will always result when different bodies are responsible for planning and implementation of plans, as is the case in WA. The job of the land management agency should be to implement the State Bushfire Policy, not to implement a separate bushfire policy or management plans incorporating fire strategies drawn up by a different organisation. It is also essential that within the land management agency, bushfire management is treated as a core business and accountability for outcomes is very clearly understood.

The EPA should recommend: that the CALM Act be amended to ensure that the Conservation Commission cannot over-rule CALM on any matter relating to bushfire management.

6. The responsible agency must prepare a Fire Management Plan. This will be a comprehensive document, looking ahead 5 years, based on the objectives and priorities specified in the State Policy. It will specify the strategies to be adopted on the ground to ensure the policy is implemented. It will clearly establish the annual targets and  performance standards against which monitoring and reporting will occur and cover other essential aspects of the fire program, e.g., the incident management system, district, regional and specialist staff organisational structure, environmental aspects, research priorities, formula for manpower needs, training and equipment requirements, liaison arrangements etc. The Bushfire Management Plan will be internally reviewed and updated annually and signed off by the agency’s Corporate Directorate. It will be available as a public document with supporting documentation including fuel age and other critical plans.

The EPA should recommend: CALM must produce a fire management system which spells out objectives, strategies, targets, performance standards and monitoring and reporting arrangements. This should be a public document, revised at least on a three-yearly basis.

7. Professional bushfire management at the Local Government level.  Bushfire management on private land is the responsibility of Local Government, and is mostly implemented by volunteers (but with some oversight by FESA). In order for this to be done properly, LGA need strong support and professional input from government. The two most essential aspects are provision of trained staff who can set objectives, make plans, train volunteers, undertake fuel reduction programs and educate the community, as well as fight fires. Professional fire management at local government level is easily neglected, and historically this has been the case in many southwest shires, or it is undermined by elected councils who do not appreciate bushfire dangers.

The EPA should recommend: a complete reappraisal of bushfire management by local governments and control of fire management by LGA by FESA. This needs to concentrate on the system, not just on the technicalities of fire control.

8. On-ground fire management system. On the ground there needs to be a holistic and well-integrated system which is designed to prevent bushfires or minimise their damage, as well as being set up to tackle fires rapidly and effectively. Such a system requires above all, good leadership from people with bushfire expertise and experience, plus administrative skills and a support network. From this will follow all those familiar elements: fuel reduction programs, public education including understanding of fire in relation to the environment, law enforcement, a good fire detection system, communications, maps, access, training, an automatically-triggered command set-up in the event of a fire, good equipment, fit and experienced firefighters, protocols for cooperation and liaison, and above all, clear accountability for outcomes. The old fire management adage must apply:  ”if you own the fuel you own the fire”.

The EPA should recommend: as for point 7, a complete reappraisal of bushfire management by LGA, and its oversight by FESA, plus an independent review of CALM’s failure to meet its prescribed burning targets, and the growing problem of fire management in the plantation estate.

9. Funding. There must be an annual budget allocation to the land management agency and to local government directed to the implementation of approved Fire Management Plans. The opposite approach, i.e. governments supply emergency funding to fight fires or to clean up afterwards, amounts to rewarding failure. The mirror-image of funding is also required - financial accountability. Agencies and LGA spending public money on fire management must be monitored to ensure they are held accountable for focusing on achieving targets effectively and efficiently.

The EPA should recommend: that a new approach to funding bushfire management be developed, with the primary focus on fire prevention. Accountability audits should be instituted. These should be done by independent professional auditors, like the EPA, assisted by fire management experts.

10. Independent monitoring and reporting on outcomes. The government must establish a small independent organisation and charge it with monitoring fire management achievements by agencies and local government. Annual reviews will compare outcomes with objectives, priorities and targets. There will be an independent report on the findings to Cabinet and to the community.

The AG should recommend:  that the government establish a small independent body of experts who can monitor actual outcomes against stated performance standards, and report these annually to the government and the public.

11. Ongoing research and effective research-operations liaison. WA needs to have solid, ongoing research programs into all aspects of fire management, including fire behaviour, fire effects, prevention and suppression technology, building design and planning. The research is best placed within the land management agency, so that research findings can be quickly and effectively translated into practice.

The AG should recommend:  that CALM reinstitutes a dynamic research program into fire behaviour, fire operations and fire ecology.

13. Conclusions

The Bushfire Front strongly supports the bushfire management approach adopted by CALM, and reiterates that in our view, CALM is well served by experienced, capable and professional officers in the specialist branch and regions. However we wish to see further improvements made. Some of these are outside the control of CALM, for example leadership and policy making from the government and the need for independent monitoring and public reporting on bushfire outcomes.

Aspects which CALM should address and on which the EPA should focus include:

* The need for sufficient funds to provide a permanent workforce of trained officers and forest workers in southwest regions, rather than relying on volunteers and casuals.

Probably the most serious threat to CALM in the future is the strong pressure to change Departmental culture away from active land management towards a more defensive nature conservation culture. The end point of this change will inevitably be less focus on bushfire mitigation and prevention, which will result in extensive high intensity fires, which in turn will result in loss of nature conservation values. Understanding of “The Bushfire Cycle” suggests that this threat will never be appreciated until there is a bushfire disaster, and changes are then forced on the Department by an angry community, and politicians looking for scapegoats.