The Nature Conservation Council and their bush fire policy

I put myself to sleep last night reading the NCC bush fire policy from 2002. This policy is still current, and I presume something similar holds sway in Victoria.

Before I start, make sure you understand this:

Since the passing of the Rural Fires Act 1997 and the Fire Brigades Act 1989, the NCC has had responsibilities under these pieces of legislation to appoint conservation representatives to the Bushfire Coordinating Committee (BFCC) and Rural Fire Service Advisory Committee (RFSAC) as well as to the Bushfire Management Committees (BFMCs) around NSW. This provides NCC with the opportunity to promote environmental considerations and outcomes in bushfire management practices and policy.

Having served on many committees in my lifetime, I know how easy it is for a committee to become sidetracked and bogged down by one or more lunatic members. I'm not saying that the NCC are appointing loonies to all committees, but given the number of BFMCs around NSW, they must have appointed at least one Mad Hatter. You can write off the work of any BFMC with a Mad Hatter on board. It only takes one person to chuck a handful of sand into the gearbox, and the whole thing grinds to a halt.

I may be taking chunks of the policy out of context, but let's start at the beginning:

1.3 "Broad area burning" - prescribed burning, for the purpose of reducing fuel levels, of "extensive" areas of land in relation to the total size of the affected natural area in any one year. For example:

• for SEPP 19 urban bushland areas and similar remnant bushland areas protected under the Crown Lands Act, the Local Government Act and the Environment Protection & Assessment Act - no more than 10% of a given natural area, with a maximum area of 100 ha. should be burned;
• for the larger areas of "managed lands" such as national parks, state forests, and for private rural lands - a maximum area of 1,000 ha. should be burned.

Note: This definition does not apply to lands which may be burnt for ecological purposes following an appropriate professional assessment.

Right, there is the policy in black and white. If fuel loads are a problem, there are strict limits on how many hectares you can burn.

Let's look at the limit of 1000 hectares per year in a national park.

I also read the Tarawi Nature Reserve fire management strategy, and discovered whilst reading it that the Tarawi reserve has over 33,000 hectares. The interesting thing about this 38 page document, which is very extensive and well put together, is that it says nothing about how many hectares they are going to burn each year. There is only one clue in the document, and it is buried in this graphic on the last page:


This shows the planned and actual burns between 1997 and 2005 - nothing appears to have been burned at all in 2002, 2003 and 2004. See those tiny strips of colour? They are the planned and actual burns, and it doesn't explain whether the red strips are burns planned for 2006 and beyond, or whether they were planned burns that were not carried out in the 1997-2005 period. It would be a shocker if they were "planned, but not carried out", since I would estimate that they're about 40% of the total burning.

The question here is whether even the planned burning over that period was sufficient, and I do not have the knowledge or experience to answer that, but at first glimpse, they appear to be carrying out a minuscule amount of burning. And it's not like the smoke is going to annoy urban greenies living nearby - this reserve is in the middle of nowhere on the SA border. It really is the back of beyond in a big way.

Let's go back to that "1000 hectares per year" limit in a national park. It looks to me like between 1997 and 2005, they didn't burn 1000 hectares in total, let alone per year. But even if they stuck to the 1000 hectares per year limit, they would only burn each patch of park once every 33 years. At the rate they are going, it looks like each bit of park will get a managed burn once every century or two.

Is that enough?

And what happens when we don't burn often enough and widely enough to reduce fuel loads to a reasonable level?

1972 - 14 December
A fire at Mount Buffalo burnt for 12 days, covering an area of approximately 12,140 hectares. This area included 7,400 hectares of State forest and 4,520 hectares of National Park.

1977 - 12 February
Widespread fires occurred across the Western District of Victoria, mostly in grasslands. The fires caused the deaths of four people and burnt approximately 103,000 hectares. More than 198,500 stock, 116 houses and 340 buildings were lost.

1980 - 28 December – 6 January 1981
A fire started from a lightning strike on December 28, 1980 and continued to burn through until 6 January 1981. The fire burnt 119,000 hectares in the Sunset Country and the Big Desert.

1983 - 31 January
Fires in the Cann River forest district burnt more than 250,000 hectares including large areas of State forest.

1983 - 1 February
A fire at Mt Macedon burnt 6,100 hectares including 1,864 hectares of State forest. Fifty houses were destroyed.

1983 - 16 February 'Ash Wednesday'
Australia’s most well-known bushfire event. Over 100 fires in Victoria burnt 210,000 hectares and caused forty seven fatalities. More than 27,000 stock and 2,000 houses were lost. Areas severely affected included Monivae, Branxholme, East Trentham, Mt Macedon, the Otway Ranges, Warburton, Belgrave Heights, Cockatoo, Beaconsfield Upper and Framlingham (see also Ash Wednesday pages).

That adds up to just under 700,000 hectares of totally destroyed land between 1972 and 1983 - you can average that out to 58,000 hectares of utter destruction per year.

Are we currently burning 58,000 hectares per year in a managed way? Me, I'd prefer to burn those 58,000 hectares per year in a controlled fashion, rather than watching the whole lot go up like an atomic bomb. But each to their own.

The document makes no mention of how quickly fuel loads build up, which is a crucial question. If 6 tonnes to the hectare is where things start to get nasty, how long does it take to reach that point? If bush in an area is adding 1 tonne per hectare per year, then I guess you'd want to burn it every 6 years. If it is adding 0.1 tonnes per hectare per year, we hardly need to bother burning it in our lifetime.

But I have googled this and that, and I can't find anything anywhere that documents either how much leaf litter and so on exists in certain areas (like our National Parks), and how quickly it's growing. If 6 tonnes, or 10 tonnes, or 20 tonnes - or whatever - is determined to be the critical level, then I would have thought the bushfire program for the next few years would consist of t his statement:

• Burn everything over 6 tonnes per hectare (or whatever limit you choose)
• Burn different patches per year so that not everything burns at once
• Ensure that in (say) 5 years time, nothing is over the limit

Now that of course is a bit simplistic and unrealistic, but if you start at a point like that, you can generate some idea of the acreage that you need to burn per year. I'm sure it will be about 10 times higher than what the NCC wants, if not more. Whether we have the capacity and capability to do that is another matter.

I can't find anything that comes even close to that. Instead, we get 38 page reports that say nothing. Nothing. They are beautifully prepared arse covering documents. However, a good looking strategy paper should never be confused with action, and the delivery of actual results. If they put as much effort into burning as they did into generating reports, we'd probably never have another wildfire in this country again.

How much can we safely burn each year?

From the CSIRO:

Frequent fire is a natural and important part of the tropical savanna environment in northern Australia.

Every Dry Season, from May to October, up to 50 per cent of the landscape is burnt, and most fires are deliberately lit.

Fire is the most important land management tool for biodiversity conservation however; there is widespread confusion and concern over why so much burning takes place.

Yes, the Top End is different to down here, but in certain areas, we should not be concerned by massive burn offs.

This is from a paper presented in 1969:

Mr. A. G. McArthur of the Commonwealth forestry and Timber Bureau has perfected a method of measuring the inflammability of the fuel on the forest floor at any particular time. This enables the forester to gauge the speed and intensity of fire which might occur in that type of fuel. Other fire researchers have demonstrated that the heat intensity of a forest fire is directly proportional to the square of the inflammable fuel on the forest floor. This accumulation commonly varies between 4 and 20 tons per acre. Any accumulation in excess of 6 tons per acre is regarded as dangerous. Research personnel have demonstrated that it is possible, both economically and safely, to reduce that accumulation by cool, slow, low-flame fires.

The NCC has come out staunchly against this in a 2003 submission to a parliamentary committee on bushfires:

The simplistic argument that the answer to severe fire events is widespread, untargeted controlled burning needs to be dismissed. Effectively what is being advocated is the removal of the understorey and leaf litter layers of bushland, especially our least disturbed bushland - National Parks. This would mean the removal of the most critical food and habitat for most of our species as well as leading to massive soil and nutrient loss with resultant loss of water quality.

I read that to mean that it is ok to do small controlled burns around certain assets, like the cafe and kiosk in the middle of the park where the visitors can get an ice cream, but the rest of the park is off limits to controlled burning.

The thing is, the build up of leaf litter and such on the forest floor just isn't going to magically go away. My reading of the NCC website and their policies is that they have adopted a head in the sand approach - just ignore the whole question of fuel load, and blame someone else when the whole lot goes up.

Let me finish with this gem, from the Protection of the Environment Act 1991, which is part of the legislation governing what you can and can't burn:

(2) For the purposes of subsection (1) (a), ecologically sustainable development requires the effective integration of economic and environmental considerations in decision-making processes. Ecologically sustainable development can be achieved through the implementation of the following principles and programs:

(a) the precautionary principle-namely, that if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.
In the application of the precautionary principle, public and private decisions should be guided by:

(i) careful evaluation to avoid, wherever practicable, serious or irreversible damage to the environment, and

(ii) an assessment of the risk-weighted consequences of various options,

(b) inter-generational equity-namely, that the present generation should ensure that the health, diversity and productivity of the environment are maintained or enhanced for the benefit of future generations,

(c) conservation of biological diversity and ecological integrity-namely, that conservation of biological diversity and ecological integrity should be a fundamental consideration,

(d) improved valuation, pricing and incentive mechanisms-namely, that environmental factors should be included in the valuation of assets and services, such as:

(i) polluter pays-that is, those who generate pollution and waste should bear the cost of containment, avoidance or abatement,

(ii) the users of goods and services should pay prices based on the full life cycle of costs of providing goods and services, including the use of natural resources and assets and the ultimate disposal of any waste,

(iii) environmental goals, having been established, should be pursued in the most cost effective way, by establishing incentive structures, including market mechanisms, that enable those best placed to maximise benefits or minimise costs to develop their own solutions and responses to environmental problems.

I can't understand a word of it. How then are our "unlettered, hick, redneck" cousins in the bush supposed to make head or tail of it?

No wonder the world is going to hell in a hand basket.