To:Victorian Inspector General for Emergency Management

Review of performance targets for the future bushfire fuel management program on public land

Date : 17 March 2015

General comments

The EFN has a direct interest in bushfire management. We include people whose properties have a common boundary with public land. We recognise that our farms are a part of wider environments and affected by activities throughout those environments. Our interests in fire management include human safety, property loss and environmental management and we support efforts to manage and reduce impacts of fire (whatever the methodology).

Members observations of current control practices

Our members observations, (while not scientifically assessed but experientially based) are as follows:

  • uncontrolled “controlled” burns have caused major environmental damage to fern gullies in the Mt Cole Range near Beaufort and impacted on private landholders,
  • high value habitat trees with hollows have been lost in many areas where the fuel loads were already low (so why burn?) and
  • large increases in fuel loads have occurred with change in vegetation components (more Acacia spp) following burns.
  • many burns have been conducted in remote drier areas where there are no obvious assets to protect and where wild fires mostly from lightning strikes have already had a major impact over thousands of hectares. We believe the frequency of burning in drier and heathland areas is already too high and impacts on birds and small mammal species will cause local extinctions.
  • research and monitoring of the impacts of fire and fire management practices is essential but appears to be under resourced. We believe it should be carried out by Parks Vic

Policy options

  1. EFN does not support hectare-based targets. We believe they are potentially
  • perverse incentives and likely to result in burning for the sake of burning
  • environmentally damaging if the emphasis on area burnt overrides other considerations. Our observations that current burning practices can threaten ecosystems and that the timing of burning operations is critical for habitat retention/restoration is supported by documented research (eg Lindenmayer et al. 2012- see footnote)
  1. In principle the EFN supports risk based targets, but notes that the term avoids addressing the question of what risks are considered and to whom, or what, any hazards apply. ‘Control’ burns are themselves a hazard and not infrequently cause loss of property. The term also avoids the issue of acceptable risk.



  1. Concurs with the principles and approaches provided in Section 1.4 of the 2013 State of the Environment  report of the Office of the Commissioner for Environmental Sustainability.
  2. Supports greater emphasis on environmental sustainability in the making of decisions about burning
  3. Supports (as an aid to understanding and decision making) a much more intense research and monitoring program to evaluate the effects of fires of all types. This information should be published in readily accessible sources.
  4. Suggests some of the workload of monitoring might be achieved by using ‘citizen scientists’ in projects

Footnote: Lindenmayer et al. (2012). Interacting Factors Driving a Major Loss of Large Trees with Cavities in a Forest Ecosystem. Plos One, Volume 7, Issue 10, e41864.

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