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1 Integrated Municipal Fire Management Planning Project: Literature Review. February 2005 INTEGRATED MUNICIPAL FIRE MANAGEMENT PLANNING PROJECT Leading to an Enhanced Emergency Management Planning Framework for Victoria Literature Review January 2005

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Page 1: INTEGRATED MUNICIPAL FIRE MANAGEMENT PLANNING PROJECT

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Integrated Municipal Fire Management Planning Project: Literature Review. February 2005

INTEGRATED MUNICIPAL FIRE MANAGEMENT PLANNING PROJECT

Leading to an Enhanced Emergency Management Planning Framework for Victoria

Literature Review

January 2005

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Integrated Municipal Fire Management Planning Project: Literature Review. February 2005

Table of Contents

How and why was the need for this ‘Integrated Fire Management Planning Process’ project identified? ......................................................................................4 How has ‘Integrated Fire Management Planning Process’ been defined? ...........5 Specific issues relating to the current Municipal Fire Prevention Planning arrangements ...........................................................................................................11

Lack of integration across land tenure....................................................................12 Agency specific planning and a lack of stakeholder participation...........................15 Lack of ‘ownership’ of the planning process at the municipal level ........................17 Implementation failure ............................................................................................19 Legislative complexities..........................................................................................21 Links to Emergency Management ..........................................................................22

Conclusion................................................................................................................23 References................................................................................................................24

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Integrated Municipal Fire Management Planning Project: Literature Review. February 2005

INTEGRATED MUNICIPAL FIRE MANAGEMENT PLANNING PROJECT Leading to an Enhanced Emergency Management Planning Framework

for Victoria

Literature Review

Fire does not respect boundaries, nor does it respect organisational arrangements. There is no logic, therefore, in planning separately across different tenure arrangements.1

In the last four years, a combination of investigations has brought particular attention to the issue of fire prevention planning at the municipal level. These investigations include the Country Fire Authority’s (CFA) Municipal Fire Prevention: Best Practice Review Discussion Paper (2001); the Auditor-General’s Report on Fire Prevention and Preparedness (2003); and Emergency Service Commissioner, Bruce Esplin’s Report of the Inquiry into the 2002-2003 Victorian Bushfires (2003). Currently, each municipality within the country area of Victoria has a statutory responsibility under the CFA Act 1958 to prepare and maintain a Municipal Fire Prevention Plan (MFPP), with the advice of Municipal Fire Prevention Committees (MFPC) and the assistance of the CFA’s Municipal Fire Prevention Planning Guidelines. As outlined in those Guidelines, each plan must:

• Identify areas, buildings and land use in the municipal district which are at particular risk in case of fire;

• Specify how each risk is going to be treated; and • Specify who is responsible for treating those risks.

It should also ‘encourage partnerships between local government, other government and non-government agencies, the private sector and community groups.’ 2 The accumulation of information relating to the MFPP has raised questions about the efficiency and effectiveness of this system and culminated in a suite of recommendations, supported by the State Government of Victoria, which identified the need ‘to reform the planning framework for fire.’3 As a consequence, the ‘Integrated Municipal Fire Management Planning Project’ has been instigated. This paper seeks to examine how and why the need for this project arose; how the ‘Integrated Fire Management Planning Process’ (either as a whole or in parts) is defined within the existing literature; and the issues that informed its instigation (i.e. the identified problems with current arrangements). The focus of the discussion will revolve around the core documents identified in this introductory section, but there are a number of other pertinent materials which bear some relevance to the issues.

1 Bruce Esplin, Report of the Inquiry into the 2002-3 Victorian Bushfires, 2003, p. 139. 2 Country Fire Authority (CFA), Municipal Fire Prevention Planning Guidelines, 2003, p. 4. 3 CFA, Integrated Municipal Fire Management Planning Project: Project Management Plan, 2004, p. 6.

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Integrated Municipal Fire Management Planning Project: Literature Review. February 2005

How and why was the need for this ‘Integrated Fire Management Planning Process’ project identified? Running parallel to the organisation’s 2001 audit of existing municipal planning arrangements, CFA’s Best Practice Review, sought to examine the processes and structures used to ‘develop, manage and implement’ Municipal Fire Prevention Plans (MFPP). This review occurred four years after amendments to the CFA Act 1958 formalised the requirement for each municipality to prepare and maintain such plans. Among the thirteen recommendations presented in the Review, Recommendation 8 stated:

The Community Safety Directorate (CFA) should seek to address the integration of fire prevention planning according to the following principles:

• Strategic support is required to obtain the commitment of agencies to fire prevention planning;

• All levels of government and stakeholders need to be involved; and

• Municipal fire prevention planning is relevant and beneficial to each stakeholder.4

The Victorian Auditor-General’s Report on Fire Prevention and Preparedness, released in 2003, supported the recommendations presented by the CFA’s Review and reinforced the concept of a multi-stakeholder commitment to fire prevention, stating that:

an important prerequisite [to agency response] is effective arrangements for consolidating fire prevention activities and coordination with key players such as local government, rail authorities, electricity distribution companies, and various landowners and tenants.5

In its examination of existing arrangements, the Auditor-General analysed not just the activities of the CFA and the Department of Sustainability and Environment (DSE), but also the adequacy of fire prevention activities undertaken by local government and key industry stakeholders.6 His conclusions made specific reference to a cooperative approach, as exemplified in Recommendation 3.59:

We recommend that key stakeholders in fire prevention, including DSE, the CFA, local government and the OESC work to develop mechanisms that support broader cooperation in fire prevention and preparedness.7

Following the 2002-3 Victorian Bushfires and the resultant inquiry, the Victorian State government confirmed its support for a number of recommendations to develop more consistency in planning and cooperation between fire and other emergency agencies, local government and communities. Recommendation 14.92, specifically states:

4 Best Practice Review, p. 74 5 Auditor-General Victoria, Fire Prevention and Preparedness, May 2003, p. vii 6 ibid, p. 30 7 ibid, p. 42

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That the CFA Act be amended to:

• Replace the current Municipal Fire Prevention Plan and the requirements for a Municipal Fire Prevention Committee with a Municipal Fire Management Plan and Municipal Fire Management Committee.

• Bring together all stakeholders with an involvement in fire management for both private and public land within the municipality.8

Victorian Premier Bracks also made a commitment that the CFA, DSE, and the Department of Victorian Communities would work with municipal councils, and the Victorian Emergency Management Council sub-committee (established to ‘ensure an all-agency and appropriate industries’ policy framework is developed’) and other stakeholders to ‘ensure that there is a consistent approach to planning for fire prevention and planning across municipalities.’9 How has ‘Integrated Fire Management Planning Process’ been defined? In the evolution of debate resulting in the establishment of the Integrated Municipal Fire Management Planning (MFMP) Project, while a clear definition which clarifies its distinction from Municipal Fire Prevention Planning (MFPP) is not apparent, a range of terminology has been used to explore the parameters of its meaning, with much of the terminology being interchangeable. While many of the differences in terminology are only subtle, clarity of definition would certainly assist in the communication of the project objectives in the consultation process, and ensure that the move from Municipal Fire Prevention Planning (defined as integrating and coordinating government and non-government services in fire prevention10) to Municipal Fire Management Planning is clear. Integrated Although not specifically related to the project in question, in the context of broad emergency management arrangements, the Report of the Inquiry into the 2002-2003 Victorian Bushfires (VBI) makes reference to the accepted ‘all hazards, comprehensive and integrated’ model, and defines integrated as meaning that ‘all agencies make their specialist contributions,’ whether through combining activities or plans.11 This interpretation is reinforced throughout the report (although often in reference specifically to the ‘integration’ of activities between the CFA and DSE. For example, in reference to the Integrated Multi-agency Co-ordination Centres established by DSE and CFA to co-ordinate the work of Incident Management Teams and the deployment of resources across them.) In the broader context, ‘integration’ is used in discussions about training, such as the management experience gained through united involvement in fuel reduction activities of DSE ‘Project Firefighters’, local landowners and CFA staff and volunteers; also in the ‘Integration of Agencies’, which draws in agencies beyond CFA and DSE, to include those responsible for road

8 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 149. 9 State Government of Victoria, Victorian Government Response to the Report of the Inquiry into the 2002-2003 Victorian Bushfires, 2003, p. 6. 10 Best Practice Review, p. 6 11 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 164.

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closures and communications (the media). 12 At one stage, however, the report does use ‘integration’ in a more limited sense, in reference to the belief that ‘recovery is not a post-event process….response and recovery can, and should, be integrated.’13 The Victorian Emergency Management Manual defines integrated quite simply as that which should ‘involve all people and relevant agencies’, and refers to the emergency response role of emergency services, government departments, councils, voluntary organisations and the private sector.14 The CFA Best Practice Review also uses the term ‘integration’ in reference to the alignment of plans (e.g. CFA business plans and Municipal Fire Prevention Plans), as well as in the sense of shared stakeholder arrangements that would ‘promote the management of fire safety in a holistic, cooperative and coordinated manner.’ 15 Furthermore, the Review also refers to the ‘integration’ of fire prevention planning ‘both at the management and implementation levels.’16 The DSE Code of Practice for Fire Management on Public Land, according to their response to the Victorian Bushfire Inquiry, ‘provides an integrated, coherent, and transparent policy statement for Fire Management (of which fire protection is a major component) on Public Land’, thus defining ‘integrated’ in a land tenure specific context.17 However, the use of ‘integration’ within the broader emergency context is applied in a number of documents. In a paper published the year before the VBI Report, for example, Neil Britton referred to the ‘Integrated Emergency Management System’, a model that would:

help form partnerships between the different levels of resource owner, both vertically (between levels of government) and horizontally (between the different agencies and the public-private sector).18

Of the many ‘drivers’ for this ‘new’ emergency management, he wrote, are ‘holistic, integrated management [and]…partnerships…..both central and local governments as well as the private and non-governmental sectors have roles to play – but they need to be coordinated.’19 The terms ‘coordination’ and ‘cooperation’ are interchanged in the Auditor-General’s discussion of ‘arrangements’, in the context of relationships between all key stakeholders.20

12 ibid, p. 144, and Fire Prevention and Preparedness, p. 49 and p. 55. 13 Report of the Inquiry into the 2002-3 Victorian Bushfires, p.216 14 Office of the Emergency Services Commissioner (OESC), Emergency Management Manual, 2004 p.4 15 Best Practice Review, p.3 16 ibid, p. 75 17 Department of Conservation and Natural Resources, Code of Practice for Fire Management on Public Land, December 1995, p. 8 18 N. R. Britton, ‘A new emergency management for the new millennium?’ Australian Journal of Emergency Management, Volume 16, Edition 4, Summer 2001/02, p. 45 19 ibid, p. 47 20 See for example, ‘effective arrangements for coordinating fire prevention activities and coordination with key stakeholders…’, ‘challenge of coordination is not simply restricted to the DSE and the CFA…..to become more proactively involved in fire prevention and preparedness’, and ‘cooperative arrangements between all our fire agencies need to be developed in a number of areas’, Auditor-General Victoria, Fire Prevention and Preparedness, May 2003, p. vii and p. 45

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Writing from within the OESC, Paul Gabriel also used the terms ‘integrated’ and ‘holistic’ to describe the office’s proposed model for local government community safety planning and practice, which emphasised the ‘local process….where people are provoked and empowered to identify and address their local safety issues.’21 In this context, ‘integrated’ is used in terms of assisting municipalities to connect their management planning processes with other similar community safety activities, such as crime and injury prevention. When speaking specifically of the proposed ‘way forward’ in terms of municipal planning, the VBI Report speaks of a ‘consolidated planning process – the Municipal Fire Management Plan’.22 ‘Consolidation’, is used to define the alignment of existing Municipal Fire Prevention Plans (MFPP), with the Strategic Fire Protection Plans for Public Land and the planning undertaken by utilities and other government departments.23 In this context, the CFA, the Auditor-General and the VBI reports refer to the significance of developing a statewide fire safety strategy (the Office of the Emergency Services Commissioner’s (OESC) the Model of Fire Cover), which ‘will be applied across the whole of the State, including public land, to provide both valid and consistent quantitative measures of risk,’ and will be critical to the development of the MFMPs.24 Both the VBI Report and the Auditor-General’s report also use the term ‘integration’ in reference to ensuring complementary prevention activities on both public and private land,25 an association also apparent in the CFA’s submission to the inquiry in reference to some of the perceived problems raised by the public, in particular ‘that fire prevention and suppression plans for public and private land were not developed, integrated, practiced.’26 In this same submission, the CFA recommended the ‘evolution of emergency management for Victoria to move to a more integrated planning structure’. This structure is explained within a series of dotpoints which can be used to summarise all the various elements of ‘integration’ referred to in the literature:

• remedy the separation that currently exists between prevention and emergency management planning;

• encompass the full range of risks that exist in both public and private land; • engage the community in the planning process; • integrate and coordinate planning at municipal and state level within a new

community safety planning and coordination framework, supported by relevant legislation;

• encompass the prevention, preparedness, response and recovery (PPRR) aspects of the emergency management continuum into single end-to-end functional plans that form part of an overarching municipal and State community safety plan;

21 P. Gabriel, ‘The development of municipal emergency management planning in Victoria, Australia’, The Australian Journal of Emergency Management, Volume 18, No. 2, May 2003, pp. 74-79 22 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 139. 23 ibid, p.144 and Figure 14.1 on p.145. 24 Best Practice Review, p. 25, Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 144 and Fire Prevention and Preparedness, p. 37 25 Fire Prevention and Preparedness, p. 66 and Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 144. 26 CFA’s Submission to the Victorian Bushfire Inquiry, Integrated fire suppression outside the Metropolitan Fire District: From the Foothills to the Alpine Heights, June 2003, p. 55.

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• produce community safety plans that are living documents–that are developed, audited, understood and (more importantly) utilised before, during and after an event; and

• be recognised as best practice.27 Municipal The responsibilities of councils are clearly enunciated in the CFA Act 1958 and apparent in the planning and implementation controls of a number of other Acts.28 According to CFA Best Practice Review, those responsibilities in relation to fire prevention planning have increased ‘over the past 50 years’29, and, argues Paul Gabriel, the days when the local council were responsible for only ‘roads, rates and rubbish’ are gone.30 As far back as 1939, the expectations of municipalities were implicit in the Stretton report which stated:

For any practical purpose, no duty of prevention of the outbreak of fires, other than the rather negative duty created by the law as it exists, is cast upon any private person or local government body, although it would appear that permissive powers in this behalf are conferred upon municipalities under the Local Government Act 1928.31

The Department of Justice Victoria stated in 2001 that councils are uniquely placed to work with their own communities and make decisions at the local level, reflecting those communities’ needs and wishes.32 In the context of the Integrated Municipal Fire Management Planning project, as outlined in the project plan, however, the word municipal is used in contrast to state or regional i.e. that it is a level of planning, rather than being used to describe a function assigned to municipal councils as bodies to carry out largely in their own right.’33 Fire Management The investment in the Municipal Fire Prevention Planning process, established under the CFA Act 1958, and the shift to a Municipal Fire Management Planning process (which will deliver a ‘Prevention, Preparedness, Response and Recovery (PPRR) output framework’) reflect the strategic evolution in fire service direction over the last decade. A more ‘proactive’ risk management model, an area which has been discussed in a vast array of documentation, has surpassed the traditional focus of response and suppression. The adoption of this approach provided a more holistic methodology for reducing the risk of fire, and ‘promoted greater efficiency in the delivery of services to the community’34. According to the literature, it demands a diversification within the fire services, recognising that response is only a small part of managing the risk of 27 ibid, p. 57 28 These include the Planning and Environment Act 1987, Building Act 1993, Building Regulations Act 1994, among others. 29 Best Practice Review, p. 8 30 Gabriel, p. 74 31 Stretton Royal Commission, Report to Inquire into the causes of and measures taken to prevent the bushfires of January 1939, and to protect life and property, 1939, p.14. 32 Best Practice Review, p. 6. 33 Integrated Municipal Fire Management Planning Project: Project Management Plan, p. 6. 34 P. Smith, J. Nicholson and L. Collett, (1996) Risk Management in the Fire and Emergency Services. Australian Emergency Management Journal. Vol 11 No.2 Winter, p.6.

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fire and includes an understanding of what risks face the community, what strategies are needed in the event of a disaster and how such disasters can be minimised.35 The risk management approach was endorsed by the 1994 Senate Standing Committee Report which stated that disaster management systems in Australia were ‘too response focussed and identified a need….to focus on areas of prevention, preparedness planning, training and recovery.’36 This report was followed shortly in 1995 by the release of the Australian/New Zealand Standard on Risk Management and by the 1998 EMA ‘Guidelines for Emergency Risk Management’. In 1999 the EMA defined emergency risk management as:

a systematic process that produces a range of measures which contribute to the well-being of communities and the environment’.37

Linked to this risk management approach has been the increased focus on community participation and the expansion of the previous response focused emergency management approach to include enhanced preventative, mitigatory and recovery oriented strategies, the comprehensive approach.38 The VBI Report refers to the range of plans in Victoria which cover prevention and mitigation of fire and states that the MFMP would bring effective and concurrent implementation of response and recovery activities.39 While the Integrated Municipal Fire Management Planning project is focused on fire, as its title indicates, within the scope of the project is a plan to develop a process ‘to extend its approach to the municipal management of other emergency risks, thus contributing to an improved municipal emergency management framework for Victoria.’40 In his preface to the 2001 Model of Fire Cover Discussion Paper, the Emergency Services Commissioner, Bruce Esplin outlined some of the concepts that were broadening traditional approaches to fire cover (i.e. beyond response times and weight of attack), stating that:

emphasis in the fire services has shifted in recent times to include prevention as well as suppression, the term fire cover is also becoming more broadly defined to address the causes of risk from fires, in addition to the emergencies that may result.41

In its Fire Management Glossary of Fire Terminology the DSE specifically defines the distinction between fire prevention and fire management, thus drawing in the risk management methodology. ‘Fire Prevention’ is defined as ‘all activities associated with minimising the incidence and severity of wildfire, particularly those of human origin’; and ‘Fire Management’ as ‘all activities associated with the management of

35 A. Rhodes & S. Reinholtd, ‘Partnerships for Community Safety: A Model for reducing residential fire fatalities.’ Paper presented at the AFAC Conference: Forging Partnerships, October 1998. 36 D. Angus, ‘Recent Developments in Emergency Management”. Presented at the Emergency Services Forum, Brisbane, October 1997, p. 35 37 Emergency Management Australia (EMA), Australian Emergency Manuals Series: Emergency Risk Management - Applications guide, 1999. 38 I. D. Manock, ‘Sustainability: The Emergency Risk Management Approach’. Paper presented to the 2003 Australian Disaster Conference, Canberra, September 2003, p. 2 39 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 139. 40 CFA, Integrated Municipal Fire Management Planning Project: Project Management Plan, p. 6. 41 OESC, A Model of Fire Cover: Discussion Paper, 2001, p. 6.

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land, including the use and exclusion of fire to meet resource management goals and objectives.’ 42 A significant element highlighted with the literature surrounding risk management methodology, is the recognised need of fire services to influence the external environment in their capacity as responsible parties in the mitigation of risk. The ‘community’ has been encouraged to become more self-reliant and more involved in dealing with risk. A shift to a more proactive approach, argues Michael Hill, rather than the reactive, has already had a huge impact on the numbers of fires, and consequently on the burden on resources.43 Ideally, wrote Alan Hodges, communities would be ‘locally organised and resourced, well-informed about local risks, proactive in prevention, risk-averse, motivated and able to manage…effective planning and action.’44 In order to achieve such goals, wrote Alan Rhodes of the CFA, the fire services have sought to discard their role as ‘authorities’ and present themselves to the community as facilitators or specialist supporters with a desire to build partnerships. 45 According to documentation, Victoria has led the way in developing the community safety model with the implementation of such programs as the Metropolitan Fire Brigade’s Juvenile Fire Awareness and Intervention Program, and the Country Fire Authority’s Community Fireguard and Bushfire Blitz programs. The involvement of people in the community, however, argues Michael Hill, is only one element of the partnerships that have been created to implement the community safety model – partnership with local government is another. Collaboration at the municipal level is a ‘vital component of local responsibilities in emergency management and the creation of a safer community’.46 More recent literature has reinforced this ‘collaborative’ significance. In the summer of 2001/02, Neil Britton published a paper on emergency management for the ‘new millennium’, which referred to the ‘Integrated Emergency Management System’, a model which ‘places emergency management in the overall context of a community’s economic and social activities.’47 Echoing this statement within the Victorian context, the VBI Report stated that the most significant change has been:

the move from a reactive focus on the event, to an emphasis on the situation or consequences of the event for the affected community (or communities). As a result, Victoria has moved to a whole-of-government approach that recognises that extreme events, or multiple concurrent events, require coordinated management by more than just the State’s emergency services.48

Published just prior to the release of the report, Paul Gabriel’s article, ‘The development of municipal emergency management planning in Victoria’, reinforced

42 www.dpi.vic.gov.au 43 Hill, M. ‘Fire Service Management – The need for change’, Fire Australia, February, 1997, p. 7 44 A. Hodges, ‘Towards Community Safety’. Paper presented at the AFAC Conference: Priority Community Safety, October 1999. 45 A. Rhodes & L. Foster, ‘Reducing Fire Risk: Civil Society as a Partner for Prevention’. Paper presented at Fire, Rescue and Safety Conference, Singapore, November 2001. 46 Hill, p. 7 47 Britton, p. 45 48 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 228.

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the view that conceptual shifts in emergency management in Australia had included a move away from an ‘emergency-centric’ view of emergency management towards a ‘community-centric’ view, which has added to the increased responsibilities of local government in supporting emergency services and the community.49 In its current explanation of emergency management, EMA notes the growing sophistication in mitigation strategies and acknowledges the significance of the ‘recognition that local level planning, integrated with the agendas of all stakeholders was the context whereby emergency management could be most effective and efficient.’50 Specific issues relating to the current Municipal Fire Prevention Planning arrangements One of the conclusions of the Auditor-General’s report was that the existing municipal fire prevention planning ‘does not work well’ and that a number of weaknesses had been identified in the existing arrangements.51 This sentiment was supported in the DSE’s submission and response to the Bushfire Inquiry:

The development and implementation of ‘Municipal Fire Prevention Plans’ has, in Victoria to date, and with a few exceptions, been a less than satisfying process. Where they exist beyond a rudimentary form, they tend to lack a strategic approach.52

And the VBI Report itself concluded that despite the number of different plans covering the prevention and mitigation of fire in Victoria, there were concerns about the existing arrangements.53

The problems associated with the MFPPs, as identified within the core literature, are examined individually under these central elements:

• Lack of integration across land tenure • Agency specific planning and a lack of stakeholder participation • Lack of ‘ownership’ of the planning process at the municipal level • Implementation failure • Legislative complexities • Links to Emergency Management

49 Gabriel, pp. 74-75. 50 www.ema.gov.au ‘What is Emergency Management?’ 51 Fire Prevention and Preparedness, p. 40 and p.64. 52 Response to Questions for the Department of Sustainability and Environment Arising from Public Submissions, Public Consultations and Research, July 2003, p.47. 53 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 139

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Lack of integration across land tenure The conflict between public and private land tenure has a long history having been identified as an issue as early as 1939 in the Stretton Report on the Victorian Bushfires of that year:

Both [the Board of Works and the Forests Commission] have ignored the advice and supplications, however well informed, of the private landholder whose interests have for long years past been placed in jeopardy by the refusal of these bodies to protect him against the danger which they have brought to his door. Both have, in turn, been exposed to the danger which the landholder has caused by illegal measures of self-help which have been forced upon him by the inflexibility of the law.54

One of the main concerns relating to existing planning processes raised by the VBI Report was that:

Planning treats public and private land separately and does not adequately address the planning needs of the interface between them. Even though consultation with interested parties is envisaged and encouraged, there is insufficient integration between the different plans, and consultation and input from other stakeholders is inadequate.55

The interface between public and private lands, it continued, is no longer just an issue for farmers, but impacts on an increasing population of people in both permanent and weekend residences in areas that interface with public land.56 Many submissions, according to the Report, revealed a perception that land management at the interface was inadequate and that appropriate land clearance regimes were needed for both private and public lands.57 Many respondents believed that ‘recovery was more difficult due to public land managers not being ‘good neighbours’ as they had not prepared their boundaries to contain possible fires.’58 The DSE, however, refuted this and other claims ‘that fire was “allowed to escape” public land to the detriment of private landholders,’ 59 stating that fires were fought aggressively in accordance with the Code of Practice for Fire Management on Public Land (1995) statement:

Upon detection of a wildfire, control action will be fast, determined, safe and thorough with the primary objective of controlling the fire in the shortest possible time with due regard to management objectives, environmental objectives and economy.60

The problem of fighting fires across private and public land had also been raised by the Victorian Coroner in 200261 and in response the CFA and the DNRE (later the

54 Stretton Report, p. 10 55 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 144 56 ibid, p. 19. 57 ibid, p. 50 58 ibid, p. 59 59 DSE Response to Questions p. 19 60 Code of Practice for Fire Management on Public Land. 61 Victorian State Coroner, Report of the Investigation and Inquest into a Wildfire and the Deaths of Five Firefighters at Linton on 2 December 1998, 2002 p. 575

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DSE) reiterated the need to develop a ‘seamless’ relationship in the management of fires, a concept suggested on a number of occasions.62 However, in its submission to the VBI in 2003, the CFA stated:

there have continually been many cracks in this seamless relationship over time and it is a recurrent theme of operational debriefs and reports that CFA and DSE have not worked as well together as they should – or as they themselves would have hoped. The current arrangements are built more on relationships than structures, which is not conducive to ongoing best practice fire management.63

While it believed that ‘integration at all levels between CFA and DSE was generally the best that has been seen to date….[and had been] very much facilitated by integrated, cooperative pre-season preparedness arrangements’ across land tenure, the DSE also noted in its own submission to the Inquiry, that ‘some integration issues (or perceptions of issues) continue to arise from a lack of understanding, in some quarters, of DSE’s role as a control agency.’64 The Auditor-General’s Report noted that in the past, DSE (and its predecessors) had regarded community preparedness education as outside the scope of its business as manager of fire on public land. However, the increasing spread of residences and holiday homes into areas adjoining DSE managed lands, ‘has made the distinction between public and private land fires less clear-cut.’65 While it acknowledged that ‘the strategic links across the public/private land interface have generally been difficult to foster’, the DSE expressed its belief that the development of such plans as the Public Land Fire Protection Plans had been made with the general input of MFPCs.66 Within its 1995 Code of Practice for Fire Management, the first of its kind in Australia, the DSE sought to develop a ‘framework for the integrated management of the fire and fire related activities on public land in Victoria’,67 and recognised the need to educate the community, specifically those whose homes abutted public land, through public awareness programs.68 The VBI Report, however, stated that even though the DSE is a participant in the MFPP process, ‘there is limited scope to resolve concerns relating to the interface between public and private lands,’69 and that one of the strategies identified by a number of the 273 written submissions to the Inquiry was the need for ‘greater consistency from all levels of government on key policy issues such as fuel reduction burning, and private/public and urban/rural land interface.’70 The Auditor-General’s report argued that the Wildfire Management Overlays, which could be used to guide development in fireprone areas so that home owners could have the best chance of withstanding a fire, through design and landscaping, are ‘not being fully utilised.’71 The information flow from some municipal councils to new 62 CFA/DNRE Position Paper, Safe Forest Firefighting, 2000 63 From the Foothills, p. 53 64 DSE Response to Questions, p. 35. 65 Fire Prevention and Preparedness, p. 72. 66 DSE Response to Questions, p.47 67 A Code of Practice for Fire Management, p. 3. 68 ibid, p. 14 69 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 139. 70 ibid, p. 44 71 Fire Prevention and Preparedness, p. 66

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private landowners, it argued, worked ‘less well’ to the point that many owners were not apprised of their responsibilities for fire management on their own land and of the benefits of prevention and preparedness.72 However, argued the DSE, the CFA, DSE and councils do work together to prepare the overlay mapping and verify boundaries:

The overlay is being introduced on a progressive basis. Twenty-six councils are currently in the process of implementing the overlay. Progress relies on expert input from the CFA and can only proceed as fast as the CFA information is made available. DSE is facilitating the implementation of the Wildfire Management Overlay by providing mapping services, waiving the planning scheme amendment fee and coordinating panel hearings (if required) for each amendment.73

To overcome some of the identified problems of firefighting across different land tenure, the CFA recommended to the VBI that the CFA should become the only agency with fire suppression responsibilities outside of the metropolitan fire district.74 The VBI Report, however, did not support such a recommendation, arguing that this would create a risk of degrading the crucial forest firefighting knowledge and experience within DSE’s Fire Management Branch.75 The Metropolitan Fire and Emergency Services Board (MFESB) also submitted to the Inquiry their belief that a system of statewide fire coordination already exists in Victoria under the Emergency Management Act and in their view:

whilst it may be enhanced through a process of continuous improvement, it has worked effectively over time.76

Rather than changing arrangements through the CFA proposed amalgamation of services, the VBI report concluded, a more integrated planning approach should be applied, with the MFPP process having consistent application across Victoria including implementation in forest plantations,77 and Alpine Resort Management Boards.78 In response to the Victorian Bushfire Inquiry the DSE launched a new initiative in 2004 and produced its Strategy Development Plan: Enhancing DSE’s approach to community engagement in Fire on Public Land. The purpose of this project is to:

Build stronger, more resilient relationships between DSE (Government) and the communities, stakeholders and partners who are affected by and/or deliver fire management outcomes for the state of Victoria.79

The project seeks to engage all stakeholders in an ‘integrated and coordinated’ manner ‘across land tenures and agencies’, and the DSE noted that such an

72 ibid, p. 5 73 DSE Response to Questions, p. 50 74 From the Foothills, p. 49 75 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 242. 76 Metropolitan Fire and Emergency Services Board (MFESB) Submission to the Victorian Bushfire Inquiry, p, 10 77 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 142 and Fire Prevention and Preparedness, p. 12 78 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 144 79 DSE, Strategy Development Plan: Enhancing DSE’s approach to community engagement in Fire on Public Land, p. 4

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approach is a relatively new discipline with little precedence in Australia or internationally.

Agency specific planning and a lack of stakeholder participation As outlined in the Emergency Management Manual of Victoria, the management of emergencies ‘is a shared responsibility involving many people and organisations in the community….In addition to the emergency services, all government departments may have some role to play’, as well as voluntary organisations and the private sector.80 With these obligations, many of which are legislatively enforced, has come the development of a range of plans across many organisations, creating a complex structure of planning processes. The complexity of planning arrangements can be seen, for example, in the section on roles and responsibilities as outlined in the State Emergency Recovery Unit’s (Department of Human Services) Recovery from Emergencies Management Guidelines:

Agencies and municipalities should have their own plans for delivering services for which they are responsible…..municipal and regional emergency response and recovery plans are in place….It is also important to be aware of the considerable variation in the regional boundaries of government agencies and to be familiar with both State Emergency Response Plan and the State Emergency Recovery Plan…in addition to municipal, regional and statewide plans, many agencies have their own plans and operations manuals…81

When such arrangements are implemented within an emergency situation, such as the bushfires of 2002-03, the lack of clarity could result in what the Victorian State Emergency Services referred to as ‘significant inconsistencies in either the undertaking of various roles, responsibilities and functions within the emergency arrangements, or a lack of desire to practice them.’82 The National Association of Forest Industries concurred with this criticism in its submission to the Select Committee on the Recent Australian Bushfires, stating that:

It has been clear for many years that at the State and local level there are conflicting policies and practices between a range of authorities. In times of crisis, these conflicts can cripple effective responses and lead to increased fire scale and increased impact from fires……The range of policy platforms between public and private resource-using land managers, local governments, government conservation agencies, fire authorities, and volunteer organisations is simply too diverse and too contradictory.83

Given this complexity, integrated planning is not a simple process (this is also discussed in the section on implementation failure). Specific to the context of ‘fire’, in its submission to the Victorian Bushfire Inquiry, the CFA noted that the lack of integration between the fire prevention plans at municipal level and the fire prevention plans prepared by DSE ‘has been recognised as a problem for many

80 Emergency Management Manual, p. 4. 81 State Emergency Recovery Unit, Department of Human Services, Recovery from Emergencies Management Guidelines, 2000. 82 Victorian State Emergency Services (VICSES) submission to the Victorian Bushfire Inquiry, p. 4 83 A Submission by the National Association of Forest Industries (NAFI) to the House of Representatives Select Committee on the Recent Australian Bushfires, June 2003, p.6

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years’.84 Indeed, the CFA Audit even noted that there were ‘only limited relationships’ between the MFPPs and the CFA’s own business plans. The lack of a holistic planning process, according to the CFA, is not uncommon, as stated in the Best Practice Review:

Limited integration appears to be the result of a lack of focus on relationships between government and other service providers. Indeed there are few arrangements that promote the management of fire safety in a holistic, cooperative and coordinated manner.85

According to the literature, the lack of integration in planning goes beyond that within the CFA or between the CFA and the DSE. In its assessment of fire prevention planning arrangements for three key industry groups: electricity distribution; non-metropolitan rail; and private forests, the Auditor-General noted that while the regulatory framework that directed the electricity distribution companies was good, ‘the regulatory regime for railways is weaker’. The Report also noted that:

In addition to the difficulties some municipal fire prevention officers have in identifying who is responsible for addressing hazards on rail corridors, there is currently no process linking wildfire mitigation programs on rail corridors with municipal fire prevention plans.86

A perception of a number of submissions, according to the VBI Report, was that many stakeholders undertook their own planning processes without the appropriate consultation with relevant parties. For example, some complained that the DSE prescribed burning plans were near completed by the time that they were presented to the community and Municipal Councils for ‘consultation’.87 As a consequence, they ‘did not adequately account for the priorities of the community, particularly those adjacent to public lands.’88 On the other side of the coin, some submissions to the Inquiry gave the perception that local councils were guilty of not fully involving the appropriate stakeholders in developing Municipal Emergency Management Plans, Fire Prevention Plans and local area and land management plans, which was ‘seen to limit key firefighting agency and community input.’89 In discussions relating to ‘Integrated Emergency Management’ in 2004 in Britain, one commentator noted that:

Responding organisations are likely to be unwilling to modify their own existing plans for, what may be seen as, the benefit of other services and so will tend to pay, at best, what is effectively lip service to the spirit of integration.90

Such ‘lip service’ can certainly be demonstrated in some Victorian municipalities, which, according to the CFA Best Practice Review, sometimes assigned

84 From the Foothills, p. 56 85 Best Practice Review, p. 3 86 Fire Prevention and Preparedness, p. 97. 87 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 50 88 ibid, p. 50 89 ibid, p. 51 90 Milton Keynes Emergency Planning Unit, Integrated Emergency Management, 2004, p. 1

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stakeholders responsibilities within their MFPPs without informing the stakeholder themselves, a situation which rightly concerned some authorities.91 Both the Auditor-General and the VBI reports commented on the fact that some utility companies and other agencies with public land management responsibilities ‘do not actively participate in the planning process, nor can they be compelled to undertake works that would complement the proposed measures in the plan [MFPP]’.92 The CFA advised the inquiry that since privatisation, ‘water authorities across the State have been reluctant to take an active role in the MFPP process.’93 The VBI Report also noted that current Victorian legislation does not provide specific requirements for the participation of agencies such as VicRoads, Victrack etc.94, and, it believed that with regard to Road Authorities, ‘all three levels of government – even owners of private roads – should be required to provide input into the MFPP process’,95 as should the ‘Electricity and Rail transport bodies.’96 However, despite the absence of legislative responsibility (beyond the CFA and municipal representatives) to attend fire prevention committees (i.e. the Municipal Fire Prevention Committees (MFPC)) many organisations did show a willingness to participate in the consultative process. The CFA Best Practice Review noted that a number of groups, without legislative obligation, had attended MFPCs, including DSE, VicRoads, Water Authorities, Power Companies and Landcare, even though much of this interaction occurred only ‘sporadically’97. What is needed, according to the VBI Report Recommendation 24.48 is a system in which:

all departments, statutory authorities, utility provides and Local Governments be made aware of the need to develop contingency plans for recovery activities, and that such plans, and associated public education and information strategies, are included in the Municipal Emergency Management Plans.98

Lack of ‘ownership’ of the planning process at the municipal level In addition to the concerns raised about government and industry participation in the planning process, the core literature also highlighted the issue of a lack of ownership within the municipalities and their communities. According to the VBI Report, a number of submissions commented that the apparent failure to involve the community resulted in a lack of understanding and ownership and ‘in some cases, failure to implement the plans [both MFPP and MEMP].’99 The report also commented that Fire Control Priorities (firefighter safety; community and asset protection; aggressive first attack on new outbreaks to extinguish fires; ecological and environmental value protection; and fire containment and control)

91 Best Practice Review, p. 38 92 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 139 93 ibid, p. 141 94 ibid, p. 22 95 ibid, p. 141 96 ibid, p. 141 97 Best Practice Review, p. 37 98 Report of the Inquiry into the 2002-3 Victorian Bushfires, 2003, p. 220 99 ibid, p. 51

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were not communicated clearly to the public, which ‘may have caused concern and some confusion for communities when decisions regarding broader strategy were being made’.100 In its response to the Inquiry, DSE stated that it had ‘always acknowledged that for a range of reasons - strategic, tactical and logistical - local knowledge is important to successful and efficient firefighting,’ but it also acknowledged that ‘during January and February there were occasions where the degree of input from locals was less than optimum.’ However, it continued, ‘DSE will also work with the CFA to encourage personnel who are in a position to provide local knowledge to undertake relevant training in advance, such that they can be more easily integrated into incident management arrangements.’ 101 A number of respondents, according to the VBI report, also questioned some of the ‘deployment strategies and tactics, specifically the level and quality of consultations between DSE and CFA...[and] that decisions were not being made at the fire front, limiting the input of local knowledge.’102 In addition some felt that Incident Management Teams (IMTs) did not use local knowledge and field observations at critical times. The Timber Communities Australia, for example, questioned why local knowledge and people had not been utilised in the fighting of fires and stated that local communities needed to ‘have more say in their (National Parks) management.’103 Paul Gabriel commented that in rural areas, many councils have a close involvement with fire services through support of volunteer brigades, but that there is a trend toward:

Greater state responsibility for rural fire service resourcing and management as the needs of state fire services for homogenous force deployable over a wide area exceed the capacity of municipalities.104

The important part it should play in terms of community sustainability, he continued, is not always ‘taken up willingly, or competently by local government’, which is why they may often ‘encounter structural obstacles created by others, such as the state.’105 This apparent ‘structural obstacle’ is not unique to Victoria. In a recent discussion paper produced by the Local Government Association of NSW about the apparent devolution of control from local government into the hands of the commissioner, it was stated that among the issues most commonly raised by councils is the:

Widespread dissatisfaction with the other funding and operational relationships between councils and the RFS [NSW Rural Fire Service], particularly with the role of Local Government having been dramatically changed and significantly diminished in recent years…..Because of the withdrawal of authority from Local Government, and the increased centralisation of decision making to the head office of the RFS, there are important questions about the ongoing role of councils in supporting

100 ibid, p. 154 101 DSE Response, p.31 102 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 53 103 Timber Communities Australia Submission to the Victorian Bushfire Inquiry 2003, p. 1 104 Gabriel, p. 74 105 ibid, p. 77

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bushfire brigades…..Their concern is that local councils will simply be agents of the Rural Fire Service in a bureaucratic mire.106

The CFA submission to the Victorian Bushfire Inquiry also referred to the recent legislative changes in NSW which had ultimately overcome the problem of fire control officers ‘serving two master’ – the Rural Fire Service and their local municipality, and stated that Victoria would benefit from such consolidation.107 What the NSW situation raises is the tension between ‘ownership’ and statutory duty. As Paul Gabriel argued, in terms of integrated planning, what is needed, is a process that is manageable and managed by local government personnel, so that it is ‘owned and not simply run out of a sense of duty.’108 The process would also need to be statewide and strategic while still allowing flexibility to include local imperatives. As the CFA Best Practice Review stated:

it was acknowledged by the MCS that some could view a generic approach to Risk Environments as compromising individual initiatives and treatments required at the local level, although, it appears that this has not eventuated.’109

It was thus deemed possible for municipalities to provide specific local information within a consistent framework.

Implementation failure In addition to the belief that a lack of consultation and ‘ownership’ resulted in a failure to implement the MFPPs, the CFA Best Practice Review identified other reasons for the inability to put theory into practice. Out of sixty-three municipalities, according to the CFA’s 2001 Audit, sixteen had not successfully implemented the planning approach outlined in the Municipal Fire Prevention Planning Guidelines (1997). This, it was stated, was partly due to an inability to comprehend the scope, aim and required outcomes of the Guidelines.110 But other, more serious concerns were also raised. A prevailing problem identified by the three significant investigations into Victorian arrangements was the apparent failure to appreciate the strategic important of the MFPP process and the supporting MFPCs. The CFA Best Practice Review noted that while some ‘clearly saw the current function and role of the MFPC as pivotal,’ many stakeholders ‘did not see the current prevention committees as being relevant to them’ and they were often chaired by ‘a lower-level employee,’111 a sentiment echoed by the Auditor General.112 The DSE also spoke of the failure of MFPCs to ‘move beyond day to day issues.’113 According to the CFA’s Review, the MFPCs were seen as lacking in objectives, not serving the requirements of government and non-government agencies and too large

106 Local Government Association of NSW and the Shires Association of NSW, A discussion paper on Local Government’s role in the provision of fire services in NSW, January 2003 107 From the Foothills, p. 48 108 Gabriel, p. 79 109 Best Practice Review, p. 43 110 ibid, p. 2. 111 ibid, p. 52 and p. 4. 112 Fire Prevention and Preparedness, p. 40 113 DSE Response, p. 47

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to be productive, and that such problems had existed since the inception of the new planning process in 1997.114 These concerns were also raised in both the VBI and the Auditor-General’s Reports which commented on the need for more strategic management training for Municipal Fire Prevention Officers (MFPO), noting that many Municipal Councils ‘have not given due weight’ to the obligations of planning for an emergency, evidenced by the appointment of low ranking officer to the role of MFPO.115 The CFA Review noted that MFPOs were found to have ‘vastly different backgrounds, levels of responsibility and skills sets’ and they were concerned that many ‘were not in a position of influence in council and not respected in the municipality.’116 This concern was reiterated in the CFA’s submission to the Victorian Bushfire Inquiry, which stated:

In its internal review into the 1983 Ash Wednesday bushfires, CFA….found that council employees with responsibility for fire prevention and planning had ‘no qualifications or training in fire prevention and fire behaviour’ and for them fire prevention was ‘a secondary duty which receives attention just prior to and during the annual fire danger period’. It is a sad reflection of how little we have progressed that these same comments can still be made about some municipalities today.117

The size of the MFPC’s, according to the Auditor-General (some with more than 40 members) resulted in them being ‘at best, community consultative forums rather than effective advisory bodies,’118 which focussed on works level plans without ‘strategic emphasis, which limits the interest of stakeholders.’119 Since the amalgamation of some councils in 1994, argued the CFA, there are some instances where more than 50 brigades (seeking representation) are located in one municipality.120 A further limiting factor was that existing planning demanded significant commitment of resources from all the agencies involved and result in a ‘duplication of effort and information.’121 One MFPO, in the CFA Best Practice Review, stated:

Community Safety needs to be seen as one big package rather than having a committee for each one. Otherwise there is duplication and the right hand doesn’t know what the left hand is doing.122

Paul Gabriel reiterated this criticism, noting that many risk management approaches were being undertaken in isolation, despite the fact that there was often much overlap in the programs.123 One of the issues identified as exacerbating the failure to fully develop and implement the MFPPs is that, with the exception of a round of regional seminars for MFPOs, ‘corporate support to help municipalities implement the Guidelines has been

114 Best Practice Review, p. 17 115 Report of the Inquiry into the 2002-3 Victorian Bushfires, 2003, p. 147 and Fire Prevention and Preparedness, May 2003, p. 65 116 Best Practice Review, p. 71 117 From the Foothills, p. 56. 118 Fire Prevention and Preparedness, May 2003, p. 65 119 ibid, p. 40 120 Best Practice Review, p. 63 121 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 144 122 ibid, p. 26 123 Gabriel, pp. 78

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limited,’ and that Area Risk Managers ‘might not have influenced many municipalities in broadening the municipal understanding of what the MFPP should accomplish.’124 The VBI Report stated that a number of municipalities had established Municipal Emergency Coordination Centres, but that their effectiveness was ‘reduced by the limited support provided by DSE and CFA’, and that the lack of effective liaison with the Incident Control Centres ‘restricted the flow of information between these facilities and their communities.’125 A confusion relating to the lack of clarity about responsibilities for different areas of fire prevention planning and activities was also highlighted.126 Privatisation of many government authorities has added to the confusion and many MFPOs were ‘unsure which agencies were responsible for particular risks or they were unsure whom to contact within a particular agency.’127 A lack of relevant qualitative and quantitative data, required for municipal fire prevention planning, was also a problem, according to the CFA Best Practice Review, with no coordinated approach for access across municipalities. One focus group involved in the review process argued that municipalities were well-placed to collect data and could become ‘a local version of the Australian Bureau of Statistics (ABS).’128

Legislative complexities A number of agencies across Victoria have responsibilities for emergency management: the CFA, DSE, MFESB, SES, and Victoria Police. Each agency, with the exception of Police, is established by State legislation and is bound by the Emergency Management Act 1986 in the coordination of services. A range of Acts impact upon the activities of these agencies and beyond those directly pertinent to the emergency services are a variety of Acts which contain some reference to fire prevention. Interactions between a diversity of stakeholders within the legislative framework are thus extremely convoluted. In the CFA Best Practice Review, the suggestion was made that the lack of clarity revolving around the MFPP process related to the fact that the ‘legislation fails to articulate what is desired,’ as one MCS stated:

I think a serious look at this planning framework and structure…and…a review of the legislation to actually reflect what we are trying to achieve [is required]. If the MFPP is to coordinate everybody’s activities, let’s give it some legal status to do that. If it is just a council’s work plan document then let’s stop kidding ourselves that there is anything else.129

The VBI report concluded that the fire and emergency services and the Local Government undertook ‘an appropriate risk assessment and adequately prepared for the 2002-3 fire season within the parameters of climatic conditions, current legislation, policies and procedures.’130 However, part of the weakness in the existing planning arrangements, it continued, lay in the legislation relating to fire prevention 124 Best Practice Review, p. 15 125 Report of the Inquiry into the 2002-3 Victorian Bushfires, 2003, p. 180 126 Best Practice Review, p. 37 127 ibid, p. 62 128 ibid, p. 22 129 ibid, p. 17 130 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 127

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and planning, which is ‘fragmented (in some cases supplicated by other legislation), diverse, incomplete and does not compel all responsible agencies to work cooperatively within the process.’131 For example, it was recognised that the CFA Act, (specifically section 93B, where it is not lawful for Forest Industry Brigades to act outside the country area of Victoria), would need to be amended as it ‘directly conflicts with the spirit of mutual assistance and cooperation that has built up over time.’132 The conflicts that arise because of the varied Acts that define the responsibilities of DSE were also a source of discussion within the core documentation. The legislative responsibility for fire prevention and suppression across private and public lands within country Victoria as stated in a number of Acts, falls to the DSE, CFA and municipal councils. DSE’s legislative responsibilities are captured in the Forest Act 1958, the Conservation, Forests and Lands Act 1987, the National Parks Act 1975, the Emergency Management Act 1986 and the Flora and Fauna Guarantee Act 1988. According to the VBI Report, a number of submissions contended that ‘the lack of a clear pathway through the various pieces of legislation and their ancillary policy frameworks result in confusion on the ground.’133 The CFA also highlighted this:

Dual accountability and perceived or actual conflict of interest between DSE’s land ownership and management responsibility and those of prevention and suppression roles.134

A recent report on the state of the Australian environment also noted that historically, much of the legislation concerning fire management in Australia has been aimed at minimisation of loss to property and life and that legislators respond to deaths in bushfires by attempting to impose control on fire. However, ‘in many cases, this legislation narrows the range of acceptable or achievable fire regimes, and in some cases outlaws regimes which are required for the conservation of some biota’.135 The conflict between private and public lands and fuel reduction and conservation are ever-present.

Links to Emergency Management The VBI Report stated that ‘investment in fire suppression does not appear to be matched by a similar level of, or priority for, investment in prevention/mitigation.’ Furthermore, a number of respondents to the Inquiry, according to the Report, expressed a view that rehabilitation activities were ‘too slow and inconsistent’.136 Others noted that recovery was ‘far less traumatic when people planned and prepared for a fire or other emergency event.’137 While there was some optimism expressed by those involved in the CFA Best Practice Review about the possibility of integrating Municipal Fire Prevention Plans with Municipal Emergency Management Planning processes, many were not so convinced. Even the linkages highlighted by those who believed in its ‘integration’

131 ibid, p. 144 132 ibid, p. 142 133 DSE Response 134 From the Foothills, p. 47 135 Dr Jann Williams, Australia State of the Environment Report, 2001 136 Report of the Inquiry into the 2002-3 Victorian Bushfires, p. 58 137 ibid, p. 59

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appeared tenuous and many suggested that ‘municipalities are feeling pressured by the number of community-safety-type processes, which are impacting on them.’138 Perhaps more seriously, there remains a lack of understanding of the practice of risk management. Paul Gabriel notes that despite the enthusiasm for risk management, ‘there has been some lack of clarity of thinking among some Australian emergency management practitioners as to how risk management relate to the PPRR formulation.’139 ‘Best Practice’ stated the CFA Best Practice Review, ‘should include the integration of at least the MFPP and the MEMP, and perhaps a rationalization of other community safety-related planning processes.’140 Conclusion The nature and range of the literature pertinent to this project highlight the relevance of the integration of services in planning at the municipal level, a relevance that has been analysed and reinforced since the 1939 bushfires. However, what the literature also clearly reveals is that there is no simple single definition of what that might mean. The complexities within the legislative system, aligned with the diversity of policies and practices within the agencies (whether in the public or private sector), as well as what often appears to be the ‘lip-service’ paid to integration, have resulted in difficulties in implementing the current arrangements and a problem in simplifying the process for the future.

138 Best Practice Review, p. 23 139 Gabriel, p. 76 140 Best Practice Review, p. 26

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References: A Submission by the National Association of Forest Industries (NAFI) to the House of Representatives Select Committee on the Recent Australian Bushfires, June 2003. Alpine Resorts (Management) Act 1997. Angus, D., ‘Recent Developments in Emergency Management”. Presented at the Emergency Services Forum, Brisbane, October 1997. Auditor-General Victoria, Fire Prevention and Preparedness, May 2003. Britton, N. R., ‘A new emergency management for the new millennium?’ Australian Journal of Emergency Management, Volume 16, Edition 4, Summer 2001/02. Building Act 1993. Building Regulations Act 1994. Catchment and Land Protection Act 1994. Country Fire Authority, Municipal Fire Prevention Planning Guidelines, 2003. Country Fire Authority, Integrated Municipal Fire Management Planning Project: Project Management Plan, 2004. Country Fire Authority’s Submission to the Victorian Bushfire Inquiry, Integrated fire suppression outside the Metropolitan Fire District: From the Foothills to the Alpine Heights, June 2003. Country Fire Authority and Department of Natural Resources and Environment Position Paper, Safe Forest Firefighting, 2000. CFA Act 1958. Department of Conservation and Natural Resources, Code of Practice for Fire Management on Public Land, December 1995 Department of Sustainability and Environment, Strategy Development Plan: Enhancing DSE’s approach to community engagement in Fire on Public Land, 2004. Electricity Act 1998. Emergency Management Australia, Australian Emergency Manuals Series: Emergency Risk Management - Applications guide, 1999. Emergency Management Act 1986. Environment Protection Act 1970. Esplin, B., Report of the Inquiry into the 2002-3 Victorian Bushfires, 2003. Flora and Fauna Guarantee Act 1988.

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Gabriel, P., ‘The development of municipal emergency management planning in Victoria, Australia’, The Australian Journal of Emergency Management, Volume 18, No. 2, May 2003, pp. 74-79. Hill, M. ‘Fire Service Management – The need for change’, Fire Australia, February, 1997. Hodges, A., ‘Towards Community Safety’. Paper presented at the AFAC Conference: Priority Community Safety, October 1999. Local Government Act, 1989. Local Government Association of NSW and the Shires Association of NSW, A discussion paper on Local Government’s role in the provision of fire services in NSW, January 2003. Manock, I. D., ‘Sustainability: The Emergency Risk Management Approach’. Paper presented to the 2003 Australian Disaster Conference, Canberra, September 2003. Metropolitan Fire and Emergency Services Board (MFESB) Submission to the Victorian Bushfire Inquiry, 2003. Metropolitan Fire Brigades Act 1958. Milton Keynes Emergency Planning Unit, Integrated Emergency Management, 2004. National Parks Act 1975. Office of the Emergency Services Commissioner, A Model of Fire Cover: Discussion Paper, 2001. Office of the Emergency Services Commissioner, Emergency Management Manual, 2004. Planning and Environment Act 1987. Response to Questions for the Department of Sustainability and Environment Arising from Public Submissions, Public Consultations and Research, July 2003. Rhodes A. and Foster, L., ‘Reducing Fire Risk: Civil Society as a Partner for Prevention’. Paper presented at Fire, Rescue and Safety Conference, Singapore, November 2001. Rhodes, A. and Reinholtd, S., ‘Partnerships for Community Safety: A Model for reducing residential fire fatalities.’ Paper presented at the AFAC Conference: Forging Partnerships, October 1998. Smith, P, Nicholson, J. and Collett, L., ’Risk Management in the Fire and Emergency Services’, Australian Emergency Management Journal. Vol 11 No.2 Winter, 1996. State Emergency Recovery Unit, Department of Human Services, Recovery from Emergencies Management Guidelines, 2000. State Government of Victoria, Victorian Government Response to the Report of the Inquiry into the 2002-2003 Victorian Bushfires, 2003.

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Stretton Royal Commission, Report to Inquire into the causes of and measures taken to prevent the bushfires of January 1939, and to protect life and property, 1939. Timber Communities Australia Submission to the Victorian Bushfire Inquiry 2003. Transport Act 1983. Victorian State Coroner, Report of the Investigation and Inquest into a Wildfire and the Deaths of Five Firefighters at Linton on 2 December 1998, 2002. Victorian State Emergency Services (VICSES) submission to the Victorian Bushfire Inquiry, 2003. Williams, Dr J., Australia State of the Environment Report, CSIRO 2001.