KANGAROO VALLEY COMMUNITY BUSHFIRE COMMITTEE - 20 May, 2020 Submissions to the Senate
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KANGAROO VALLEY
COMMUNITY BUSHFIRE
Submissions to the Senate COMMITTEE
Inquiry into lessons to be
learned in relation to the
Australian bushfire season
2019-20
20 May, 2020
Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Kangaroo Valley Community Bushfire Committee
Capt. Matthew Gray, MAv, Chair
Prof Paul Cooper, PhD
Mike Gorman, BEng (Elec)
Gary Matthews, BSc (Hons)
Prof Gary Moore, PhD
Kate Rutherford, MNurs
Sarah Waddell, PhD
Kate Watson, LLM
Written by Mike Gorman, BEng (Elec)
Edited by Sarah Waddell, PhD
20 May, 2020
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Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Contents
EXECUTIVE SUMMARY ............................................................................................................................ 3
PART A - RESPECTIVE ROLES AND RESPONSIBILITIES OF DIFFERENT LEVELS OF GOVERNMENT, AND
AGENCIES WITHIN GOVERNMENT RELATING TO BUSHFIRE PREPAREDNESS – PLANNING AND
MITIGATION ............................................................................................................................................ 6
Nationally consistent bushfire risk management planning ................................................................ 6
Community-based bushfire planning.................................................................................................. 7
Nationally consistent Community Protection Plans ......................................................................... 10
Planning for the protection of critical infrastructure ....................................................................... 11
Critical infrastructure – NSW as an example ................................................................................ 11
Backup power supply .................................................................................................................... 12
Water supply ................................................................................................................................. 12
Planning for the protection of road infrastructure ........................................................................... 13
Planning for the protection of Primary Industry............................................................................... 14
Bushfire survival – tourism, outdoor education, and camping and picnic sites ............................... 15
Planning for Neighbourhood Safer Places ........................................................................................ 16
PART B - REDUCING FUTURE BUSHFIRE RISK - ADEQUACY OF FEDERAL GOVERNMENT’S EXISTING
MEASURES AND POLICIES ..................................................................................................................... 17
Transparency and accountability in national strategy implementation ........................................... 19
Transparency and accountability in implementation of bushfire inquiry recommendations .......... 20
Implementation of national guidelines on prescribed burning ........................................................ 20
Adequate guidelines – lack of implementation ............................................................................ 21
Proactive incentives from the Commonwealth to the States and Territories for prescribed
burning .......................................................................................................................................... 22
Hazard reduction programming & outcomes – transparency and accountability ....................... 22
National approach to bushfire shelter options................................................................................. 23
Other Safer Locations.................................................................................................................... 24
Construction of community refuges ............................................................................................. 24
Private shelters ............................................................................................................................. 25
Household bushfire sheltering ...................................................................................................... 25
National approach to mitigating impact on buildings and structures .............................................. 27
Landscaping................................................................................................................................... 27
Retrofitting .................................................................................................................................... 27
Last minute retrofitting ................................................................................................................. 27
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Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
EXECUTIVE SUMMARY
The Kangaroo Valley Community Bushfire Committee (KVCBC) is a local organisation of Kangaroo
Valley residents who are actively engaged in community-based bushfire planning and preparation.
KVCBC formed in September 2018 following a large public meeting called by the then Kangaroo
Valley Volunteer Fire Brigade captain and the local police officer to discuss perceived risks and
potential impact of bushfire due to the ongoing drought. KVCBC members include those with
relevant expertise as well as lived experience of the 2019-2020 Currowan fire.
These submissions regarding lessons to be learned in relation to preparation and planning for the
2019-2020 bushfire season address Terms of Reference Item (b) and Item (d) and are in two parts
with a total of 13 recommendations.
Part A Respective roles and responsibilities of different levels of government, and agencies
within government, in relation to bushfire planning and mitigation
Part B The adequacy of the Federal Government’s existing measures and policies to reduce
future bushfire risk.
A recurring theme in our observations regarding lessons to be learned from the 2019-2020 bushfires
is that there have been major weaknesses in bushfire planning and mitigation at the State level in
NSW and that these weaknesses point to the need for a stronger role and greater responsibility by
Federal government.
The severity of the 2019-2020 bushfires, which had a national impact, both socially and
economically, calls into question current State jurisdiction and the need for a devolved hierarchy of
control from the Commonwealth level to ensure a consistent policy & legislative framework to
enabling greater planning and preparedness across Australia.
Part A - Respective roles and responsibilities of different levels of government, and agencies –
planning and mitigation
KVCBC has identified major deficiencies within NSW bushfire risk management planning where plans
lack location-specific detail or defined actions to be carried out. Other planning shortcomings are
found in protection of critical infrastructure including backup power supply, Static Water Supply,
telecommunications and risk assessment for roads and bridges. In Kangaroo Valley, there is an
absence of bushfire planning for predominant sectors such as the dairy industry, outdoor education,
tourism, and camping and picnic grounds. Furthermore, as in most areas of regional NSW, there is a
lack of planning regarding the defence of Neighbourhood Safer Places.
Our initial research has found that similar shortcomings may not be found in all States and
Territories but it is conceivable that each has its own strengths and weaknesses in bushfire risk
management planning leading to inconsistent results in building resilience across the country.
One of the key recommendations from the 2009 Victorian Bushfires Royal Commission was to
support liaison with local communities in bushfire planning and preparation and to adopt
community-based plans as part of the planning and preparation process. This approach was
endorsed in the National Strategy for Disaster Resilience and, more recently, in the March 2020
National Disaster Risk Reduction Framework. However, KVCBC has encountered resistance from
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Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
government agencies in seeking to initiate community input into bushfire planning and preparation.
For this reason, we believe that more is required from the Commonwealth to enshrine the practice
of community-based bushfire preparedness in all States and Territories.
Community Protection Plans are an example of other instruments that have not been fully
developed in NSW and there is likely to be inconsistency across States and Territories in this regard.
Risk management planning for the protection of critical infrastructure appears to be haphazard in
NSW including in relation to backup power supply, water supply and roads. Whilst these areas of
responsibility often fall to State and Territory governments, national policy and guidance would help
ensure targets are reached consistently and with transparency and accountability. Nationally
important primary industries would also benefit from a national approach to bushfire protection as
would bushfire survival measures for the tourism sector, outdoor education, and camping and picnic
sites. In addition, Neighbourhood Safer Places across the nation would benefit from consistent
measures relating to bushfire protection.
Part B - Reducing future bushfire risk - the adequacy of the Federal Government’s existing
measures and policies
Where KVCBC has recommended in Part A that the Commonwealth should take on a stronger role or
responsibility, it is implied that existing national measures are inadequate. At the moment, the
Commonwealth either provides broad aspirational leadership in the form of strategies or
frameworks or detailed technical guidance in the form of guidelines but without any legislative
measures to provide the bridge between the two. We believe that it is time for a national approach
established within a legislative foundation setting out objectives, roles, functions, duties, obligations,
measures for accountability and transparency as well as new arrangements to allow for funding
incentives provided by the Commonwealth to State and Territory governments.
Current instruments created at the national level take the form of strategies and frameworks:
• National Strategy for Disaster Resilience
• Australian Disaster Preparedness Framework
• National Disaster Risk Reduction Framework
• Crisis Management Framework.
Key words that describe the current approach are ‘coordinated and cooperative effort’, ‘principle of
shared responsibility between all levels of government, business, industry and communities’. The
National Disaster Risk Reduction Framework establishes a vision combined with goals and priorities.
Whilst detail is provided in national guidelines on some aspects of bushfire mitigation, such as
prescribed burning, there is no national legislation on reducing future bushfire risk – planning,
mitigation, response and recovery.
A strong reason for recommending a legislated national approach relates to the need to build
accountability and transparency. In NSW, lack of accountability and transparency abounds in regard
to bushfire planning and preparation, starting from implementation of the National Strategy for
Disaster Resilience, the NSW Critical Infrastructure Resilience Strategy and Emergency Management
Arrangement for NSW down to the local level of implementation of Bush Fire Risk Management
Plans. Notably, many of the findings of the 2009 Victorian Bushfires Royal Commission fires have not
been actioned in NSW.
KVCBC believes that that to ensure accountability and transparency there should be a national public
register of responses to all actions that form part of national strategies and frameworks and another
register to record the implementation of recommendations that arise after a public bushfire inquiry.
Where the Commonwealth has provided detailed guidelines such as in relation to prescribed
burning, there are similar issues with implementation. Whilst the content of the range of documents
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Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
on prescribed burning are comprehensive, it would appear that they are not implemented by all
relevant parties in NSW. Prescribed burning is a key disaster risk reduction measure and yet there is
no national measure to oversee and guide prescribed burning. KVCBC is not critical of the adequacy
of existing national guidelines but has recommended that incentives be introduced by the
Commonwealth that tie financial support for the bushfire response effort with effective
implementation of national guidelines on prescribed burning including reporting and data-sharing.
Areas in which KVCBC sees a need for national standards, codes and specifications for bushfire
mitigation include bushfire shelter options (identification and assessment of Other Safer Locations,
community refuges, private bushfire shelters, household sheltering) and standards for buildings and
structures (retrofitting, improvements for bushfire resilience, landscaping).
Figure 1 The sky above Tallowa Dam road just before the Currowan fire impacts 4th Jan 2020
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Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
PART A - RESPECTIVE ROLES AND RESPONSIBILITIES OF DIFFERENT LEVELS OF
GOVERNMENT, AND AGENCIES WITHIN GOVERNMENT RELATING TO BUSHFIRE
PREPAREDNESS – PLANNING AND MITIGATION
The following submissions are related to Item (b) in the Terms of reference for the Senate Inquiry as
they concern lessons to be learned in relation to preparation and planning for the 2019-2020
bushfire season, with particular reference to the respective roles and responsibilities of different
levels of government, and agencies within government.
The background to our submissions is dissatisfaction by KVCBC with the role played by NSW state
agencies in preparing for the 2019-2020 bushfires, particularly the NSW RFS, which has led us to
conclude that greater leadership is required from the Commonwealth to ensure that deficiencies
experienced in the last fire season are not repeated.
We have benefited from reviewing the National Disaster Risk Reduction Framework, March 2020
(‘the Framework’). Our submissions will refer to the guiding principles as well as the priorities and
strategies for action identified in the Framework. Given that KVCBC is a community-based
organisation, we see two of the five-year Governance, Ownership and Responsibility outcomes as
being particularly important (emphasis added):
All sectors and communities understand the extent to which they have a responsibility to reduce disaster
risk
All sectors and communities are engaged in a national mechanism to connect and guide efforts to reduce
disaster risk.
We also note that the framework states that ‘to be effective, action to reduce disaster risk must be
transparent, sustainable, accountable and undertaken in partnership’ (emphasis added).
Whilst our experience is in attempting to build local-level bushfire preparedness, we are very aware
of the need for strong governance at the national level to provide a link between local and national
efforts and note that the Framework states at page 18 as follows (emphasis added):
To improve disaster risk reduction outcomes, there is significant potential for a nationally-owned and
multi-stakeholder led coordination mechanism. Such a mechanism could bring together relevant
cross-sectoral expertise to support effective implementation and monitoring of disaster risk reduction
efforts across the country. It would provide an important link between local and national efforts.
Recommendation 1
Nationally consistent bushfire risk management planning
The Commonwealth to ensure a nationally consistent approach to policy and legislation on bushfire
risk management planning by State and Territory governments that
• significantly improves the quality of bushfire risk management planning undertaken at the
level of State and Local government taking into account the experience of State and Territory
governments that have adopted best practice bushfire risk management planning
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Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
• provides accountability in planning through requirements for making information on the
implementation and performance of bushfire risk management plans publicly available.
The disparity between States and Territories regarding the adequacy of bushfire risk management
planning became apparent to the KVCBC prior to the 2019-2020 bushfires. It points to the need for a
nationally consistent approach to improving resilience and providing for accountability in natural
disaster risk management and preparation.
In NSW the bushfire risk management plans are developed by the NSW RFS while in Victoria,
Tasmania, South Australia and Western Australia the bushfire risk management plans are developed
by the Council/Shire/Municipality with input from the combat agency.
In preparing for the bushfire season, the KVCBC reviewed the Shoalhaven Bush Fire Risk
Management Plan (SBFRMP) prepared by the Shoalhaven Bush Fire Management Committee in
accordance with Part 3 Division 4 of the Rural Fires Act, 1997 and approved by the Bush Fire Co-
ordinating Committee of NSW. It was clear that the bulk of the main text of the SBFRMP is largely a
cut and paste of the same information used across NSW; it contains very little information specific to
the Shoalhaven, let alone Kangaroo Valley, for example, the current 2018 version leaves out half of
Kangaroo Valley’s critical infrastructure.
The current NSW approach to bush fire risk management planning creates an illusion that effective
bushfire risk management planning has been carried out when, in fact, the reality for communities
such as Kangaroo Valley, is that there has been no systematic planning or significant engagement
with the community. Importantly, there has been no methodology for recording or monitoring the
performance of bush fire risk management plans and there has been no attempt to evaluate
specified treatments. This lack of accountability is something that could be addressed at the national
level.
Recommendation 2
Community-based bushfire planning
The Commonwealth to ensure that a nationally consistent approach to policy and legislation on bush
fire risk management planning by State and Territory governments endorses community-based risk
management planning as a national objective to be implemented in all States and Territories.
The National Strategy for Disaster Resilience (the Strategy) is guided by the principle of shared
responsibility between all levels of government, business, industry and communities. As KVCBC is a
community-based organisation, we are particularly aware of the need to better involve local
communities in building disaster resilience.
We note that Priority 1 in the Framework – Understand Disaster Risk states that Strategy A is to
‘improve public awareness of, and engagement on, disaster risks and impacts.’ In relation to Priority
4 - Governance, ownership and responsibility, Strategy C is to ‘Support and enable locally-led and
owned place-based disaster risk reduction efforts’ (emphasis added).
We would like to point out that in our experience a community-based approach to bushfire
preparation has not been adopted in NSW, unlike in some other States. Ultimately, due to the finite
resources of governments and their agencies, it is only communities that can deliver the changes
required to build bushfire resilient communities. In the same way that our society relies on
volunteers for the bushfire response, it also makes sense to use the community’s own resources for
planning and preparation.
7Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Currently, in NSW, the Rural Fire Service (RFS) provides a broad brush, high level Local Government
Area (LGA) Bush Fire Risk Management Plan (BFRMP) which does not identify local community
needs. The NSW RFS bushfire planning processes for a community such as Kangaroo Valley leaves a
very large gap between the LGA BFRMP level and the household level Bushfire Survival Plan.
Figure 2 Duffys Lane the morning after 5th Jan 2020
The KVCBC has filled the planning gap between the LGA BRRMP and household level by developing a
Kangaroo Valley Bushfire Plan and many areas have developed Locality/Neighbourhood Bushfire
Plans. The Kangaroo Valley Bushfire Plan looks at the big picture issues that affect the broader
community while the Locality/Neighbourhood Bushfire Plans deal with the details of protection and
mitigation of a relatively small group of properties. The Kangaroo Valley experience has shown that
for local community planning to be truly effective, it needs to be undertaken below the ‘big picture’
level, down to, effectively, the street level, often referred to as the ‘neighbourhood’ level.
The Kangaroo Valley neighbourhood groups have proven to be extremely effective at:
• improving communications
• facilitating the dissemination of critical emergency information
• helping everyone who participates to prepare a household Bushfire Survival Plan
• assisting vulnerable people
• providing an access point for RFS community engagement and bushfire advice
• having frank and meaningful conversations as identified by the 2009 Victorian Bushfires
Royal Commission
8Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
• helping people to make sound decisions with respect to staying and defending
• helping with the immediate bushfire response by the provision of detailed neighbourhood
maps to firefighters
• helping with the practical side of the recovery process
• helping with the emotional side of the recovery process by developing a sense of
community and the support that comes with it.
The KVCBC believes the number and quality of written household bushfire survival plans in the
community has increased significantly with the introduction of the neighbourhood groups. This has
occurred largely due to the sharing of written household plans and the discussions held about
locality specific information during the neighbourhood group meetings. The Kangaroo Valley
experience has shown that community-level bushfire planning can be effective when it is conducted
by trusted people within the local community.
This factor was also identified in the detailed findings of the 2009 Victorian Bushfires Royal
Commission. The 2009 Victorian Bushfires Royal Commission stated as part of Recommendation 1:
Ensure that local solutions are tailored and known to communities through local bushfire planning.
Further on, in the detailed Royal Commission Report under Section 1.6.3: Advice and Local Planning
are Crucial, it is stated that:
A continued focus on providing frank and meaningful advice on the risks and what is required to
adequately prepare for and survive a bushfire is essential. Local planning and emergency
management processes are also essential if this advice is to have a sound basis.
In 2012, the Victorian CFA introduced a trial program called Community Led Planning in response to
the 2009 Victorian Bushfires Royal Commission. The CFA website states:
The trial found that communities, when supported, are in the best position to lead activities that
result in a stronger, more connected and prepared community.
The CFA now provides assistance to those communities that want to be better prepared for
bushfires to develop a Community Led Action Plan.
The South Australia Country Fire Service has implemented Community Fire Safe groups supporting
neighbours to prepare for bushfire. The CFS website states:
By working together with your neighbours or group you will be in a better position to prepare for
fires, thereby increasing your chances of survival.
The Tasmanian Fire Service has also implemented a Bushfire Ready Neighbourhood Groups. The TAS
website states:
BRN Groups are formed when small groups of people living in high risk bushfire areas take
responsibility for their own safety and work together to devise plans and actions to suit their lifestyle,
environment and community.
The Western Australian Department of Fire and Emergency Services has implemented Bushfire
Ready Groups. The DFES website states:
Bushfire Ready is a local community action program aimed at encouraging local residents to work
together in preparing and protecting their families and properties against bushfires. Bushfire Ready
aims to build the community resilience by providing an opportunity for neighbours to network, share
ideas and information and develop and implement strategies to reduce their bushfire risk.
9Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
The Kangaroo Valley experience has been that NSW Government agencies, including the RFS, have
been unsupportive of community bushfire planning. This lack of support is contrary to the National
Strategy for Disaster Resilience, the NSW Critical Infrastructure Resilience Strategy, and Emergency
Management Arrangements for NSW.
Recommendation 3
Nationally consistent Community Protection Plans
The Commonwealth to prepare policy and guidance for State and Territory governments in order to
provide a consistent approach regarding preparation of Community Protection Plans - community
information guides, map displays and quality of information on bushfire risk in bushfire prone areas.
Community Protection Plans are made at the State and Territory level within the overall national
arrangements for disaster management. In NSW, the RFS currently provides locality- or village-based
Community Protection Plans (CPP) as a means of offering further protection in addition to hazard
reduction and community engagement. The RFS website indicates that 117 communities across NSW
have a CPP.
Kangaroo Valley, in spite of its Very High bushfire risk rating, is not included nor listed to have a CPP
in the future. Based on the format of existing CPPs in NSW, even if a plan were to be provided, most
likely it would only address the immediate village area with no protection to the localities and
neighbourhoods that comprise most of Kangaroo Valley.
In comparison, the Victorian Country Fire Authority (CFA) changed its Township Protection Plans to
Community Information Guides – Bushfire. These guides currently have been rolled out to 278
communities. The Victorian approach provides very easy to understand local information that can be
viewed on a smart phone. In comparison, the NSW approach provides difficult to understand maps
that need a tablet or bigger sized screen. The Victorian maps, by virtue of their design, are accessible
to both locals and tourists, while the NSW maps would only be accessible with significant local
knowledge or a tourist with a high degree of map reading skills.
The KVCBC believes that the current CPP program in NSW is totally inadequate for the following
reasons:
• no accountability or transparency as to which communities are selected
• the maps are difficult for the general public to understand
• lack of quality local information
• maps are not useable on a smart phone screen
• roll out of the program is such that large sections of the NSW will never be protected
• lack of independent evidence that the CPP has been successful at providing protection
to communities.
In our view, there would be huge benefits in terms of national consistency for there to be a national
approach to the preparation of all aspects of CCPs.
10Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Recommendation 4
Planning for the protection of critical infrastructure
The Commonwealth to prepare policy and guidance for the revision by State and Territory
governments of legislation in relation to bushfire protection of critical infrastructure (CI). The policy
should encourage the following:
• audit of current CI lists and their backup power supply
• audit of static water supply (SWS) and reticulated water supply as part of CI
• provision of Bushfire Risk Assessments, Bushfire Mitigation Plans, Bushfire Management
Plans and Bushfire Pre-Incident Plans for all CI
• accountability in bushfire planning outcomes for CI.
This recommendation relates to the respective roles and responsibilities of different levels of
government in relation to assessing and reducing disaster risk for infrastructure. As stated at page 12
of the Framework, ‘[s]ome states have developed state-wide infrastructure strategies and critical
infrastructure resilience strategies informed by a comprehensive understanding of natural hazards,
exposure and resilience.’ However, in the view of the KVCBC, it is highly likely that the level of
preparedness is inconsistent between States and Territories.
In the Framework, a five-year outcome for National Priority 2 on Responsible Decisions is stated to
be ‘[i]ntegrated and robust frameworks are used to assess and reduce disaster risk in all
environments, but particularly infrastructure, land use and development planning’. Strategy C is to
‘[b]uild the capability and capacity of decision-makers to actively address disaster risk in policy,
program and investment decisions’. In the view of KVCBC, the Commonwealth has an important
leadership role to play in building this capability and capacity.
Critical infrastructure – NSW as an example
As defined in the 2018 NSW Critical Infrastructure Resilience Strategy, critical infrastructure (CI) is
‘the assets, systems and networks required to maintain the security, health and safety, and social
and economic prosperity of NSW’. This strategy has identified bush fire as a hazard for CI and
emphasises that we must prepare for all threats.
However, in October 2018, the KVCBC realised that much of Kangaroo Valley’s CI is missing from
Local Government emergency planning and bushfire planning including a major dam (Tallowa Dam),
the power station, the electrical substation, the only bridge across the river dividing Kangaroo Valley
(Hampden Bridge) and major roads, as well as telecommunications infrastructure such as the
telephone exchange upon which many of our community depend given unreliable mobile phone
coverage.
As a result, these sites have no, or inadequate, asset protection zones or bushfire defence systems.
Importantly, none of these sites have a bushfire pre-incident plan detailing how the RFS or Fire &
Rescue NSW would defend them during a bushfire. Most of these sites have little or no adequate
Static Water Supply (SWS) to assist fire fighters in defending them.
The KVCBC is of the view that the lack of planning and preparation of CI greatly increases risks to
firefighters being tasked to defend these assets and that this is an inappropriate and unsustainable
situation. The apparent failure to properly plan and mitigate for bushfires with respect to CI in NSW
represents a failure by NSW Government departments and agencies as well as asset owners to
comply with well documented policy and strategies. There also exists a failure by these bodies to be
transparent with respect to their disaster planning.
11Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Figure 3 Kangaroo Valley’s famous Hampden Bridge without a bushfire mitigation plan 9th Jan 2020
Backup power supply
During the recent Currowan fire, there were many stories of the chaos that ensued when the
electricity network failed - fire trucks were unable to operate due to a lack of fuel as the local service
station had no power, communications systems failed, water supply failed and evacuation centres or
neighbourhood safer places were unable to function optimally. The KVCBC considers that to help
improve the disaster resilience of communities across NSW all CI in a bushfire prone area should
have either a backup generator or a connection point with a changeover switch so that a generator
can be easily connected.
Water supply
Static Water Supplies (SWS) are rarely associated with critical infrastructure. In addition, villages and
urban interface areas often do not have easily accessible SWS.
The KVCBC understands that rural village reticulated water supplies may not have built-in disaster
resilience features to make them a reliable source of water during bushfires. This can be for a range
of reasons including: power failure, damaged infrastructure from the fire, and extreme demand due
to the fire. Firefighters, including our own local brigade, often report on the lack of reliable water
supply when bushfires impact on villages and urban areas.
Some water supply authorities actively acknowledge this unreliability. This is an example of a
message from the WA Water Corporation:
12Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Residents living in or near bushland are reminded not to rely on public water supplies if they plan to
stay and defend their homes during a bushfire.
We really want to get the message out to everyone who may be affected by bushfires that their usual
public water supply may not be available. Residents need to have an independent water supply, such
as a concrete or steel tank with a minimum 20,000 litre capacity.
The KVCBC believes that the NSW Government, water supply authorities, and combat agencies in
NSW are currently either unaware of, or have no consistent approach to, addressing these
deficiencies and that the Commonwealth needs to take the lead in ensuring that action be taken and
accountability is provided in this regard.
Recommendation 5
Planning for the protection of road infrastructure
The Commonwealth to prepare policy and guidance for the State and Territory governments in
relation to the protection of road infrastructure with the following measures:
• systematic state-wide bushfire risk assessment of all roads and bridges as CI
• roadside bushfire planning guidelines for use by local government.
Road infrastructure is another example of critical infrastructure but is also related to transport and
so may not be identified as CI. The Currowan fire demonstrated that prolonged closure of roads can
have a major effect on business and tourism in particular. Significant damage was done to both the
Princes Highway and the Kings Highway due to fire which resulted in significant delays in reopening
both roads. Responsibility for roads may fall to Local, State or Federal government and, in the view
of KVCBC, is likely to suffer from inconsistency in approach regarding bushfire preparedness.
Recommendation 62 from the 2009 Victorian Bushfires Royal Commission identified the need for a
‘systematic state wide program of bushfire risk assessment for all roads …’. In response to the
recommendation, VicRoads developed the Road Bushfire Risk Assessment Guideline and Risk
Mapping Methodology. The CFA has also developed Roadside Fire Management Guidelines. Neither
the NSW RFS nor NSW RMS have developed any bushfire management or risk assessment plans for
NSW roads equivalent to the work undertaken in Victoria.
In 2018, the KVCBC brought their concern about lack of bushfire planning for road infrastructure in
Kangaroo Valley to the notice of NSW RFS and NSW Roads and Maritime Services (RMS). Both the
NSW RFS and NSW RMS failed to take any steps to address this lack of planning. The Shoalhaven
Bush Fire Risk Management Plan fails to even identify as an asset major roads or major bridges, such
as the Hampden Bridge in Kangaroo Valley.
Prior to the Currowan fire, the RMS appeared to have no awareness that the Hampden Bridge
needed a bushfire risk management plan, mitigation plan or a pre-incident plan. This is in spite of the
fact that the Hampden Bridge is made largely of timber and steel, is the only link between the north
and south parts of the village, carries the village’s reticulated water supply, has a historic character
and is listed on the NSW Government heritage register, and is surrounded by bush with no asset
protection zone.
13Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Figure 4 Last minute protection of critical road infrastructure by the NSW RMS. A good example of when planning has been
neglected 9th Jan 2020
Recommendation 6
Planning for the protection of Primary Industry
The Commonwealth to prepare policy and guidance for State and Territory governments in relation
to bushfire protection of primary industry with the following measures:
• bushfire planning guidelines for primary industry in general
• pre-incident plans to ensure the supply of critical goods and services to primary
producers
• specific bushfire planning material on the basis that the only viable option may be to stay
and defend.
The KVCBC is of the view that, as an important sector within the national economy, primary industry
requires particular protection at the national level.
We are aware of the plight of dairy farmers during the 2019-2020 fires given their inability to
evacuate a large dairy herd. In 2018, the KVCBC identified that Kangaroo Valley dairy farms should
be included in a community bushfire plan. This decision was, in part, based upon stories from the
August 2018 Kingiman Road fire where dairy farms around Milton were severely affected by a lack of
planning.
14Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
The KVCBC approached our Local Land Services (LLS) office and asked for assistance with the
development of a bushfire plan for the local dairy farms. The LLS office declined the request on the
basis that it thought it would not be supported by the local RFS District Office.
When the Currowan Fire approached Kangaroo Valley, the KVCBC approached our local Member of
State Parliament to request assistance for Kangaroo Valley dairy farms. The drought and the effect it
was having on the profitability of the dairy farms was discussed in addition to the vulnerability of
dairy farmers to the Currowan fire. By way of example, conversations with the Chittick’s dairy farm
revealed that not only would they be affected by the inability of the milk trucks to access the farm if
roads were closed due to fire, but the greater financial impact would come from the failure of grain
and hay deliveries.
Recommendation 7
Bushfire survival – tourism, outdoor education, and camping and picnic sites
The Commonwealth to prepare policy and guidance on bushfire planning for the State and Territory
governments including bushfire management plans, bushfire survival, village-level information and
signage in relation to
• the tourism sector
• outdoor education
• camping and picnic areas
The tourism and outdoor education and activities sector currently has no national or state-based
industry association bushfire planning policies or guidelines.
In relation to the tourism, in NSW, some Local Government Areas (LGAs) have developed an
Emergency Management Fact Sheet for Tourism Operators, with important information for visitors
that the tourism operator can offer as part of an information pack. However, because these fact
sheets are developed at the LGA level, they are still quite general in nature and do not provide local
village or community information that someone caught in a bushfire would need. Additionally, these
fact sheets often rely on references to websites for more detailed information which will not work in
many localities due to a lack of Internet or mobile reception. As the Currowan fire has shown, during
a major fire the communications network may be compromised.
Tourists within a fire prone area are likely to come from a major city or overseas and lack bushfire
knowledge. Most likely, they will lack a good understanding of the local area in which they are
staying. This creates a particular set of problems not addressed by standard bushfire educational
material such as household Bushfire Survival Plans. Whilst Victoria has developed locality- or village-
level bushfire information for visitors in the form of Victorian Survival Guides, NSW has not done so.
Highly relevant, locality-specific information on sheltering, Neighbourhood Safer Places, Other Safer
Places and other data is not provided in NSW.
In relation to outdoor education, some individual operators do have their own plans to varying levels
of detail. It would appear that the NSW RFS and NSW Department of Education currently provides
no information on bushfire planning for the outdoor education industry. Only limited information is
available on how to shelter if caught in a bushfire while bushwalking or undertaking any outdoor
activity.
15Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Kangaroo Valley currently has a Sydney secondary school with a permanent outdoor education
campus and another permanent outdoor education facility located on the edge of the valley at
Fitzroy Falls. A number of outdoor education companies also use Kangaroo Valley on a regular basis
for bushwalking, canoeing, and mountain bike trips for city-based schools.
The remote nature of these outdoor activities means there is little likelihood of emergency warning
messages being received or mobile reception being available for communication. The KVCBC is
aware of school groups lighting camp fires when total fire bans have been declared, due to a lack of
awareness that a ban had been imposed. As the fire season has grown in length, there are now
occasions when dangerous fire conditions occur outside the official bushfire season. This
lengthening of the fire season and the associated increased risk for those undertaking outdoor
education activities means there is an even greater need for bushfire policies and guidelines in the
industry.
Camping and picnic areas will often be located in bushfire prone areas which may be managed by a
range of landholders. Most of these sites have little or no mobile reception so public communication
and advice systems will not be effective and cannot be relied upon. The sites managed by NSW
National Parks and WaterNSW are well controlled during major fires and on days with a catastrophic
forecast. However, unofficial sites may be unmanaged by their respective local governments.
The KVCBC has noted the following deficiencies in relation to camping and picnic areas:
• lack of physical signage close to main roads to reduce the number of visitors actually
reaching these locations during periods of dangerous conditions
• inadequate information on NSW Government websites about the closure of these sites
• lack of information through social media on the status of these areas
• lack of bushfire management plans with trigger points for the closure of these sites and
other useful information.
Recommendation 8
Planning for Neighbourhood Safer Places
The Commonwealth to prepare policy and guidance for State and Territory government specific to
Neighbourhood Safer Places (NSP) to ensure that
• NSPs have a Bushfire Mitigation Plan, Bushfire Management Plan and Bushfire Pre-
Incident Plan and
• NSP plans are available to the public to provide accountability and transparency.
Currently, in NSW there is no requirement for an NSP to have a bushfire management plan. NSPs are
required to be inspected to ensure they are still suitable, but the KVCBC has been unable to find any
publicly available record of these inspections having taken place or the findings of the inspection.
In the same way that households are required to have a Bushfire Survival Plan, the KVCBC believes
there is an obvious need for a NSP to have a plan that will set out how the arrival of residents, and
possibly their animals, will be coped with. For example, one of the lessons learnt during the Victorian
fires was that cars in an NSP need to be spaced out to reduce the possibility of a ‘car park’ fire.
16Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Access to water and hoses as well as available facilities such as toilets and showers should be
discussed and planned for in advance.
Figure 5 Building to flame zone did not save this house 6th Jan 2020
17Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
PART B - REDUCING FUTURE BUSHFIRE RISK - ADEQUACY OF FEDERAL
GOVERNMENT’S EXISTING MEASURES AND POLICIES
The following submissions in Part B relate to Item (d) in the Terms of reference for the Senate
Inquiry as they concern lessons to be learned in relation to the adequacy of the Federal
Government’s existing measures and policies. There is an implicit assessment of the adequacy of the
Federal Government’s existing measures and policies to reduce future bushfire risk in Part A - where
KVCBC has recommended a role or responsibility for the Commonwealth, it is implied that existing
national measures and policies are inadequate.
Current instruments created at the national level take the form of strategies and frameworks:
• National Strategy for Disaster Resilience (NSDR)
• Australian Disaster Preparedness Framework
• National Disaster Risk Reduction Framework
• Crisis Management Framework.
The National Disaster Risk Reduction Framework establishes a vision combined with goals and
priorities. Key words that describe the current approach are ‘coordinated and cooperative effort’,
‘principle of shared responsibility between all levels of government, business, industry and
communities’.
In the lead up to the 2019-2020 bushfires, KVCBC was very aware of inadequacies in bushfire
preparedness across NSW. In our research, we were frequently dismayed that actions mentioned in
the NSDR and recommendations from the 2009 Victorian Bushfire Royal Commission had not been
adopted in NSW and there was no system for accountability in this regard. Apparently, the NSW RFS
did not consider itself bound by recommendations from another State even though bushfire
conditions in NSW and Victoria are often very similar. This attitude points to the need for stronger
measures and policies at the national level and, we recommend, that for greater certainty these
measures be given a legislative basis.
Whilst there are detailed Federal Government technical guidelines on aspects of bushfire mitigation,
such as prescribed burning, there is no overarching policy or national legislation on reducing future
bushfire risk, and neither is there any way of making the content of the technical guidelines
obligatory at the State and Territory level of government.
The following submissions are made in relation to measures that could be introduced by the
Commonwealth to ensure a more nationally consistent approach to reducing future bushfire risk,
starting with monitoring the implementation of national strategies and recommendations of
bushfire inquiries, to reporting requirements on implementing prescribed burning in combination
with an incentive-based approach to Commonwealth funding for bushfire response, to standards for
bushfire shelter options, and buildings and structures.
18Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Recommendation 9
Transparency and accountability in national strategy implementation
The Commonwealth to issue national reporting requirements and procedures to provide
transparency in the implementation of national strategies such as the National Strategy for Disaster
Resilience (NSDR) including a public register recording implementation of concepts and approaches.
Whilst the Commonwealth has produced a number of Strategies and Frameworks relevant to
reduction of bushfire risk, there is an absence of mechanisms to ensure that the principles and
strategies in these documents is actually carried out by State and Territory government and this
amounts to a major inadequacy in the overall arrangement.
Absence of community-based bushfire planning is an example of where implementation of the
National Strategy for Disaster Resilience (NSDR) has been lacking in NSW. The Office of Emergency
Management in the NSW Department of Justice has formally adopted concepts identified in the
NSDR as part of the Emergency Management Arrangements (EMA) for NSW 2016 and the NSW
Critical Infrastructure Resilience Strategy 2018. Both the NSDR and the EMA for NSW identify that a
key element for building disaster resilience is for government departments and agencies to work
with, and partner with, local communities. Both documents recognise that for disaster resilience to
be effective there needs to be a change in the mindset and thinking of the combat agencies.
However, the KVCBC experience has been that, at the local level, the mindset is still very much stuck
in the Response and Recovery phase of disaster management and that little effort has been made to
focus on the Prevention and Preparation phases as emphasised in the NSDR and EMA.
The KVCBC was formed as a local effort to implement the recommendations on community
involvement in building disaster resilience, as described in the above strategies. It has been working
to improve the disaster resilience of the Kangaroo Valley community for the last 18 months,
following increasing concern over the elevated fire risk in October 2018 due to the drought.
However, the KVCBC encountered resistance from the local RFS Shoalhaven District Office. The
committee originally prepared a Kangaroo Valley Bushfire Plan Brief which was totally rejected by
the RFS Shoalhaven District Office. The committee then decided to convert the brief into a Kangaroo
Valley Bushfire Plan Discussion Paper as it was felt that it would be harder for the district office to
object to a ‘discussion’.
The KVCBC experience has also been that at the local level there has been poor ability to engage and
partner with local communities. The Shoalhaven Bush Fire Risk Management Plan was last updated
by the Shoalhaven RFS District Office in 2018. The KVCBC understands that this review received no
feedback or submissions from across the Shoalhaven. The KVCBC believes that the local district
office does not value community input and, hence, makes no effort to seek it out and, in our own
experience, actively worked against community-based resilience building. The NSW RFS Corporate
Planning & Policy documents make no reference as to how the RFS intends to implement the NSDR
or even the NSW EMA.
The KVCBC is of the view that key elements in the NSDR have not been adopted, namely to:
• plan and prepare rather than simply respond and recover
• partner and work with communities
• partner and work with businesses
• partner and work with owners of critical infrastructure
• partner and work with other agenies.
19Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
Recommendation 10
Transparency and accountability in implementation of bushfire inquiry
recommendations
The Commonwealth to issue national reporting requirements and procedures to provide
transparency in the implementation of bushfire inquiry recommendations including a public register
of recommendations and their implementation by the Commonwealth, States, Territories and Local
Government.
As at 2013, there had been 51 inquiries across Australia since 1939 related to bushfires and bushfire
management with over 1700 recommendations.1 An introductory review of these inquiries by the
Australian National University and the Bushfire and Natural Hazards Cooperative Research Centre
has shown that there are multiple recurring themes that may show a problem with the lessons
management process.2 This review concluded as follows:3
It may be that the inquiries are identifying issues that cannot be solved, making recommendations
that cannot be implemented or that their recommendations are sound but ignored or not diligently
applied. Further, recommendations both over time and over inquiries, even those that are inquiries
into the same event, may produce inconsistent findings and suggestions.
In the view of the KVCBC, at least in NSW, there has been a cycle of inaction with respect to
recommendations of previous bushfire inquiries. In researching disaster resilience, the KVCBC
identified a number of recommendations of the 2009 Victorian Bushfires Royal Commission that
have not been actioned in NSW. Whilst this Royal Commission applied to Victoria, the
recommendations are very relevant for NSW and should have been implemented. Indeed,
throughout the NSW bushfire crisis, there were a number of media articles questioning why the
NSW Government should hold another inquiry when recommendations of previous inquiries have
not been actioned.
The need for consistent monitoring of the implementation of recent bushfire inquiries, including the
current Federal Royal Commission, would seem to be readily apparent. An official national process
needs to be established so that implementation is monitored as a matter of course and is publicly
available. Such a process will also help to identify reasons for any lack of implementation.
Recommendation 11
Implementation of national guidelines on prescribed burning
The Commonwealth introduce additional national measures to ensure implementation of guidelines
on prescribed burning such as the following:
(a) making financial support by the Commonwealth for the bushfire response effort
conditional on effective implementation of nationally agreed prescribed burning
measures;
1
Eburn M, Hudson D, Cha I and Dovers S, ‘What has 75 years of Bushfire Inquiries (1939-2013) Taught Us?’,
Proceedings of the Research Forum at the Bushfire and Natural Hazards CRC & AVAC Conference, Wellington, 2
September 2014, https://www.bnhcrc.com.au/publications/biblio/bnh-1558, 2.
2
Ibid, 6.
3
Ibid.
20Kangaroo Valley Community Bushfire Committee Submissions to 2020 Senate Inquiry
(b) rigorous national reporting and data-sharing arrangements on
• hazard reduction schedules
• performance monitoring of hazard reductions
• outcome of hazard reductions
• historical hazard reduction outcomes.
Adequate guidelines – lack of implementation
Prescribed burning is a key disaster risk reduction measure and yet there is no national basis on
which prescribed burning can be managed and monitored. KVCBC is not critical of the content of
existing Federal Government measures and policies on prescribed burning but seeks to make
recommendations as to how to ensure their implementation and achieve transparency and
accountability in this regard.
Our submissions on prescribed burning relate to the Framework Priority 4: Governance, Ownership
and Responsibility which recommends the establishment of a national mechanism to oversee and
guide disaster risk reduction efforts and cross-sector dependencies to:
• Establish a national implementation plan for this framework
• Support and enable locally-led and owned place-based disaster risk reduction efforts
• Incentivise improved transparency of disaster risk ownership through personal and business
transactions
• Consistently report on disaster risk reduction efforts and outcomes
• Create clear governance pathways for pursuing disaster risk reduction.
The KVCBC is aware of the excellent work being done by The National Burning Project jointly
commissioned by the Australasian Fire and Emergency Service Authorities Council (AFAC) and the
Forest Fire Management Group (FFMG). This project, carried out by the Australian Institute for
Disaster Resilience, has produced a range of comprehensive documents available on the Australian
Disaster Resilience Knowledge Hub https://knowledge.aidr.org.au/resources/national-prescribed-
burning-guidelines-and-frameworks/ .
As stated in the Best Practice Principles for Prescribed Burning,
The National Burning Project (NBP) has brought together inter-related aspects of prescribed burning
across Australasia to design guiding frameworks and principles for a more holistic and consistent
approach to prescribed burning. A number of detailed reports have been produced …, each of which
stands alone, yet with synergies across reports that have been drawn together into a number of easy
to use synopses:
• Process Map of Prescribed Burning
• Best Practice Principles for Prescribed Burning (this document)
• Risk Management Framework For Prescribed Burning
• Objectives, Monitoring and Evaluation Framework for Prescribed Burning
• Program Logic for Prescribed Burning.
The synopses are designed to facilitate greater utilisation of the prescribed burning principles by land
and fire professionals, to improve consistency nationally, and provide orientation to users about the
NBP products and how they fit together.
The frameworks produced by the NBP identify four phases of planning and implementation for
prescribed burning. Ready-to-utilise synopses are presented across the four phases of prescribed
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