Submission:EPA Review of CALM Fire Mgt

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

December 2003

1. The Bushfire Front: our aims in this submission

This submission to the EPA is made by the Bushfire Front (Western Australia). We are a group of West Australians concerned about the risks of bushfire damage to people, lives and forests. We have accumulated nearly 400 years of personal experience in bushfire prevention, firefighting, bushfire science, fire planning, administration, legislation and agency operations.

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

We wish to make our position clear from the outset. We support the present system of bushfire management carried out by CALM. We understand the risk of bushfires in southwest regions, the values threatened by large, high intensity bushfires, and the legal and moral position in which any agency with land management responsibilities is placed. We are familiar with the research into fire effects, and with the practical application of fire ecology in the Australian environment. We believe that CALM has no option but to take positive bushfire prevention and mitigation measures (which include a prescribed burning program for fuel reduction) as well as to be effectivefirefighters.
At the same time, we believe that  every system can be further refined and improved. Furthermore we are concerned that CALM’s current bushfire management is not producing satisfactory outcomes with respect to minimising the risks of damaging wildfire.

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;

* The 2002 Ascot conference where credible fire scientists reviewed current ecological and environmental issues relating to fire and a book of refereed papers published;
* Federal-level reviews undertaken by the House of Representatives (completed) and COAG (to be released in March 2004); and
* A recent seminar organised at Curtin University by the Academy of Technological Science and Engineering from which strong recommendations emerged.

* 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?

There is an old saying that “if you don’t know where you are going, any road will take you there”. It is also a lesson of history that objectives which are clear, and are widely shared in the community, are easier to achieve.

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.

CALM’s critics do not recognise this situation. As soon as there is a fire, or if a burn goes slightly wrong, they leap into attacking mode, and the implication is always that CALM officers are incompetent.  But when wildfires burn farms, homes, towns and forests, and the Coronial Inquiries and litigation commence, it is the CALM officer in the field who is called to account and who is judged.

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.

* What about the wider picture?

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.

6. The issue of the pre-European situation
Fundamental to the debate about the use of fire in WA forests is the debate about pre-European fire occurrence. However unprofessional this debate has become, the EPA will be obliged to review and to adopt a position on it.

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.

If the concept that fire is a natural part of the ecosystem in Australia then it is the withdrawal of fire and the setting aside of long unburnt areas which must be considered as the departure from the norm, not the insertion of fire by prescribed burning.

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;

* Whether a patch of bush is burnt by headfire, flank fire or tail fire;
* Large differences in fuel moisture between fuels on ridges, gullies, wetlands, southern aspects, northern aspects;
* Diurnal variations in temperature and relative humidity for fires burning over 24 hours;
* Past fire history and fuel levels;
* Forest type;

* 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.

8. The fire control rationale for a prescribed burning program
The relationship between fire intensity and fuel levels, and the relationship between fire intensity and fire damage are two issues which are not in dispute anywhere in the world. Fire damage is directly related to the intensity of the fire (i.e. the rate at which energy is released, usually expressed in terms of kilowatts per metre), and to the size of the fire. A mild trickling forest fire of low intensity has no killing power and is easily suppressed. But the range of possible intensities is almost infinite. As conditions escalate, so does intensity, and at the extreme end of the scale, the intensity of a bushfire is immense, i.e. capable of generating cyclonic winds, uprooting huge forest trees and carrying spot fires for many kilometres. The following table demonstrates the range of bushfire intensities, with comments on the impact and difficulty of suppression:

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.

The weather cannot be controlled by forest managers, but fuel levels can. This is the rationale for the use of “prescribed” fire (i.e. fires lit deliberately under carefully prescribed conditions) to reduce the level of fuels in the forest, and thus reduce the intensity of a subsequent fire and, as a feed back mechanism, further reduce the fuel consumed.
The attention of the EPA is also drawn to the extensive series of experimental forest fires (Project Vesta) conducted over the past 5 years by scientists from CALM and CSIRO to examine the question of how fire behaviour is affected by the age of the fuel.
These experiments clearly demonstrated that all of the major fire behaviour variables that contribute to the difficulty of suppression (i.e. rate of spread, flame dimensions, spotting) increase as the  amount? of the fuel increases over time?.
In many forests the accumulation of shrub and bark fuels (that add to flame heights and spotting potential) continue to increase after the surface fuels have stabilised or reached equilibrium. Nevertheless, in older and heavier fuels, fires are always harder to control and do more damage.

7. The consequences of letting the burning program slip

In recent years, there has been a significant reduction in the areas of the forest subject each year to fuel reduction prescribed burning by CALM. According to Muller, the forest now carries heavier fuels than at any time since the 1950s.
The reasons for this are many and varied, but include:
* Opposition to prescribed burning from environmentalists who are very clever at manipulating the media and the public, especially by exaggerating the problem of smoke pollution and raising mythological issues about environmental impacts;
* Risk aversion by CALM staff, who do not like being roundly criticised every time they do a burn and are fearful of the consequences of mistakes;
* Lack of resources, in particular manpower and funds;
* Lack of priorities for fire management at the level of CALM’s senior leadership, and an antipathetic inexperienced? approach to the issue from the Conservation Commission; and
* Expansion of areas with-held from burning, either as “no-planned burn” areas or young regrowth.

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

The EPA’s review of CALM’s bushfire management must include a clear statement on the impacts of large, intense bushfires. This is because these are the inevitable consequence of a management approach which does not incorporate effective broad-acre fuel reduction burning.
A large and intense bushfire has a range of consequences. The human impacts include:
* Loss of life and injury to people caught in the fire, or to firefighters or other emergency service workers.
* Loss of property and people’s assets, including houses, vehicles, fences, livestock, plantations, records, heritage.
* Psychological damage to people who are trapped, or who lose loved ones or property;
* Loss of public infrastructure, especially power lines, water pipes, roads, bridges, railways, community assets, businesses.
* Financial costs in terms of firefighting, rehabilitation, insurance burden, taxes, litigation, inquiries.

* 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

* Immediate destruction of wildlife, and wildlife habitat. The more intense the fire, the less fauna survives, or the less habitat survives into which survivors can move. Modern ecologists recognise that to minimise the impact of disturbance, and to ensure most rapid recovery, there needs to be some carry-through of propagules from the pre- to the post-disturbance phase. The higher the fire intensity, the smaller amount of carry-though occurs.
* Long term loss of topsoil through water and wind erosion. The hotter the fire, the greater loss of ground cover and soil. Soil erosion leads in turn to silting up of waterways, rivers and reservoirs.
* Destruction of conservation programs, for example years of fox baiting to enable woylies to recover in Dryandra forest would be wasted if the whole forest was consumed in one disastrous high intensity fire. The Nuyts Wilderness fire of two years ago destroyed many rare and threatened species of fauna, as the fire was too hot to allow them to escape.

* 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.

9. Wildfire damage to hydrological systems
This issue is so serious in the West Australian context that it must be considered separately. It is also a subject on which there is now a credible database of information resulting from catchment research going back many decades.

In summary:

(i) Periodic, low intensity prescribed burning has no deleterious impacts on water catchment areas and hydrological cycles. Provided burns are professionally managed, to ensure burn timing and location is staggered, and winds are selected to ensure ash does not fall into reservoirs, the general impact is actually positive. Temporary fuel and shrub reduction assists groundwater recharge and surface run-off to water courses, rivers, storage areas, and there is rapid post-fire recovery, thus minimising the risks of erosion.
(ii) Occasional high intensity fires have a disastrous wide-ranging impact on catchments and water production. The outcomes include:
* Serious soil erosion, as soon as rains hit bare slopes;
* Sedimentation of creeks, wetlands and waterways;
* Ash pollution of reservoirs;
* Massive even-aged regeneration of vegetation, leading over time to reduced catchment yield.
The attention of the EPA is drawn to catchment impact studies being undertaken in the ACT in the wake of their massive bushfires last summer. Two of Canberra’s three water supply reservoirs are still closed due to ash pollution, there has been massive sedimentation of creeks and waterways, and modelling has shown that future water supply yields are likely to decline in all areas where stand-replacement has occurred.

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.

Bushfire managers know that the suppression-alone approach will always ultimately fail. This is because there will never be enough resources to pounce on every new fire within seconds of its starting – and that is what is required when you are dealing with heavy eucalypt fuels which are drought-affected, under severe weather conditions. Under these conditions, firefighters are rapidly overwhelmed and the fires take on a life of their own, generating their own wind and throwing new fires way out ahead of themselves. The only chance the firefighter has in these situations is to wait until the headfire runs into an area where fuels are low, intensity drops, and effective suppression work can be done.

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.

11.     A prescribed burn is a process not an outcome
One of the greatest difficulties faced by land managers who practice prescribed burning is that so few people are properly educated about the Australian bush and fire’s place in it. Members of the Bushfire Front are accustomed to hearing journalists or distraught members of the public describing a recently burnt area as “destroyed”. This is often despite the case that (unknown to the journalist or community observer), the same area had been prescribed burned 5 or 6 years previously and had not been destroyed!

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:

* Kings Park is only 400 ha in size, and the bushland area is even smaller.
* The whole park is accessible on bitumen roads, none more than a few hundred metres away from any patch of bush, and is criss-crossed with sealed tracks which can be used by fire appliances;
* The park employs its own fire fighting staff, with equipment, and these are able to reach any point in the park within 10 minutes of a fire starting.
* Approximately 30 FESA fire brigade units are located within a 20 minute radius of the park;
* Bushland areas are interspersed with mown grassland which has a sprinkler system;
* The southern boundary of the park is the Swan River;
* The park is infested with an exotic weed (veldt grass), which is stimulated by fire and there are a number of exotic trees along avenues which will seed into the bushland following fire;
* The park is surrounded on three sides by suburbia, so smoke management to minimise impacts on people is impossible.
* The park is full of people most days of the year and there would be safety implications if burns were undertaken.
It is also worth noting that despite all its advantages, especially from a suppression point of view, the park has been devastated by high intensity wildfires three times in the last 20 years – hardly a good advertisement for the suppression-alone approach.

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.

12. Best Practice bushfire management – the wider picture in WA
As part of its review of CALM’s fire management, the EPA could take an important initiative, and draw the government’s attention to the generally parlous state of bushfire management in WA. We are a long way from having a Best Practice system.
The Bushfire Front defines a  “best practice” fire management system as being one with the following characteristics:
(i) It will deliver protection of community assets and human values from destructive bushfires;
(ii) It will avoid or minimise undesirable long-term environmental impacts;
(iii) It will take into account the need to ensure the safety of firefighters, especially volunteers;
(iv) Fire use and fire suppression will be based on credible science, and protocols and prescriptions will be continually updated in the light of research and field experience;
(v) There will be provision for independent monitoring of outcomes, and public reporting;

(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.

1. Overarching legislation. This is necessary to establish the authority of the government to dictate bushfire policy and to set overarching objectives and enable action on the ground, including enforcement. Good legislation will provide CALM with the authority to implement policy and will protect the Department from unreasonable litigation. It will establish the heirachy of policies (i.e. where bushfire management sits compared to other land management or planning objectives and responsibilities). An essential element of the legislation will require the government to create and implement a State Bushfire Policy, which can provide the basis for CALM’s fire policy.
Status: The State’s principal bushfire legislation (the Bush Fires Act) is outdated, and does not address current needs or establish accountability. The CALM Act does not directly deal with fire management at all and directs that CALM’s primary role is conservation. This leaves CALM in the situation where it has no legal backing for its fire management work, and where, consequently, fire is seen as a subset of conservation, not a primary program in its own light.

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.

Status: Western Australia does not have a State Bushfire Policy. Instead, there are a number of policies operating independently and without coordination within different agencies and Local Government Authorities. CALM has a Fire Policy, currently under review, but the Conservation Commission (in whichCALM land is vested) does not.

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.

Status: no such arrangement dealing with bushfires exists. Relations between the State and Federal government are unclear, with the general approach being for the latter to fund suppression work rather than prevention, and to provide some funding for research through CSIRO and the new Bushfire CRC.

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.

Status: There is no intra-State interagency agreement or MOU dealing with bushfire management. Agencies tend to compete, rather than work together. Within government there are at least six Ministers with bushfire responsibilities, but no coordinating body. CALM and FESA cooperate in some areas but operate at arm’s length in others, while CALM and Forest Products Commission do not even have an operating protocol spelt out to indicate fire responsibilities and arrangements. There are cooperative arrangements for actual fire suppression, specifying command arrangements, but these have never been tested in a major disaster situation.

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.

Status: In WA the ridiculous situation applies where, for State forests and national parks, a different organisation is responsible for planning (CCWA) and for implementing management plans (CALM). The Conservation Commission comprises members of the public, and has virtually zero bushfire expertise or experience. In its most recent forest management plan, the Commission has clearly set out to make fire management more complex and less likely to succeed, and there has been a redirection of approach from the strategic to the particular. In effect, this arrangement has taken bushfire management planning in State Forests and National Parks away from the professionals and handed it to amateurs.

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.

Status: CALM has a comprehensive fire management system on the ground, run by competent and experienced professionals, but nevertheless, no single document within CALM spells out the fire management objectives, priorities and strategies applying across all tenures managed nor the performance standards which are to be achieved. Fire management is dealt with in numerous district and regional operational documents and in specific management plans for individual parks or reserves (prepared by CALM and approved by the Conservation Commission).

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.

Status: Few LGA employ professionally trained and experienced bushfire experts to oversee bushfire management on private land. In many Shire Councils, fire has a lowly status and is the responsibility of the ranger. FESA has tended to take a softly-softly approach and is letting fire management at the LGA level slowly evolve, rather than getting in there and aggressively sorting out the mess. A serious issue is the decline in numbers of bushfire brigade members in most rural districts, due mostly to demographic changes, especially in the southwest where traditional farmers are steadily being replaced by hobby farmers or absentee landowners.

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”.

Status: CALM has this in hand, but no LGA does. Even so, critical aspects of CALM’s fire management on the ground have been allowed to decline in recent years. In particular they have not met their own fuel reduction target for at least a decade, are badly short of permanent trained staff, and no longer have ready access to heavy firefighting machinery.
Moreover, A very large new plantation estate (>120,000 ha) has sprung up on private land in the southwest and great southern regions during the last 10 years, but with little attention to bushfire aspects, and currently there is no coordinated leadership to get a proper system of fire detection, fuel management and fire attack in place. The government (through FESA) has not taken a leadership role in this issue, and the different forest owners see themselves as commercial competitors, and do not work cooperatively.

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.

Status: funding is generally available for fire suppression, but is hard to get for fire prevention work. For many years CALM has been unable to fund a permanent workforce of trained staff in the southwest and is reliant on volunteers and casuals, plus staff from FPC to assist when there is a fire. Inadequate resources are a constraint affecting the prescribed burning program.  There is no system of financial accountability at any level for bushfire work – i.e., a system in which an independent auditor can directly relate expenditure to outcomes and performance standards.

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.

Status: There is no independent monitoring of outcomes or public reporting on fire management on a State-wide basis in WA. CALM and FESA report on themselves, but not against any publicly stated performance standards. It is thus impossible for the public or the government to know how things are going, or to assess whether public funds are being responsibly spent.

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.

Status: WA was once a world leader in bushfire research, now it has virtually none.

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 a clear statement of objectives for bushfire management with targets and performance measures and priorities, so as to allow actual outcomes to be compared with proposed outcomes;
* CALM’s failure to achieve adequate levels of prescribed burning in forest areas, thus exposing the southwest to the risk of large, high intensity fires;
* The need to restructure and rebuild the fire research program, with attention to fire operations as well as ecology;
* The problem of CALM being required to implement management plans prepared to the requirements of the Conservation Commission, which has no bushfire management experience;  [Plans are prepared by CALM and approved by CCWA.]
* Lack of bushfire management expertise and experience in CALM’s senior management;

* 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.

The Bushfire Front is happy to further assist the EPA in any aspect of its review, in the hope that this unhappy situation can be avoided.