Submission to Draft Code of Practice for Fire Management on Public Land
Goongerah Environment Centre
RSD Bonang Rd Goongerah 3888
Ph: 0351540156
Fax: 0351540157
geco@green.net.au
www.geco.org.au
Fire Code Review
PO Box 500
East Melbourne
Victoria 3002
2 September 2 005
RE: Draft Code of Practice for Fire Management on Public Land
Introduction
The Goongerah Environment Centre is situated in Far East Gippsland. We have had a long history of being involved in various "public consultations" regarding fire management, including attending public meetings and making submissions. This submission to the Draft Code of Practice for Fire Management will be brief and highlight some of the concerns we have raised on previous occasions regarding fire management on public land. See http://www.geco.org.au/2004/firesub04.htm for an example.
Fuel Reduction Burning
It is of concern to us that the Draft Code seems to be placing such an emphasis on the use of fuel reduction burns to control potential wild fire. It is well recognised that fuel reduction burning does not stop fires and there is evidence to suggest that such burning does not always reduce the fuel load. In fact, it could be argued that fuel reduction burning in fact creates a greater fire risk in that it dries out wet forest.
It should be noted that, although there is a legal requirement for fire prevention and suppression, there is no statutory requirement for fuel reduction burning to be carried out.
The long term ecological effects of fuel reduction burning are unknown. However it is likely to have an impact on soils, water and biodiversity. Considering that fuel reduction burns are by no means a proven of effective strategy in reducing the intensity and risk of wild fire, we urge you to take the precautionary principle in scheduling such burns in the name of fire management.
Fire Control
Fires are notoriously difficult to control. There has been a long history of fuel reduction burns and ecological burns jumping containment lines and becoming out of control. This is not only a threat to private property but to the surrounding forest. Given the difficulty in controlling fire, we are concerned about the effect of fuel reduction burns on wet gullies, wet forest and rainforest in East Gippsland. We are also concerned about the effect on water courses of these fires, which despite best intentions, often burn areas that were not intended to be burnt.
Ecological Burning
There is a lack of knowledge about the effect of burning on ecosystems in Victoria. Therefore to advocate ecological burning is in contradiction to the precautionary principle advocated in the Flora and Fauna Guarantee Act.
Carbon emissions
The release of carbon in the yearly government-sponsered bonfire that happens every autumn in the name of fire management cannot be underestimated. The effects of climate change are being felt around the globe, and there has been scant attention paid the the effect of carbon emissions from fuel reduction burns on human health.
Accountability and Monitoring
We are concerned about a historical lack of monitoring of compliance with the current Code of Practice and the lack of meaningful recourse for breaches of the Code that may occur. The Draft Code does nothing to ameliorate these concerns.
The Draft Code does not enshrine adequate resources or processes for compliance. Therefore the public will have no recourse for future compliance issues.
We hope that the final Code of Practice for Fire Management on Public Land addresses some of our concerns.
Yours sincerely,
Fiona York, Andrew Newnham and Rena Gabarov
Goongerah Environment Centre