Concerns about new policy directions by CFA
We all understand the CFA has a duty to take all steps “for the protection of life and property in case of fire” (Section 20, CFA Act) but we at Red Eagle are very concerned about some of their reported actions and policies as explained in the 2013/2014 annual report.
Their headline messages seem to be: CFA declares properties near forests as high bushfire risk / CFA targets high risk areas with information and advice / CFA opposes development in high risk areas
Here are some troubling references from the CFA 2013/2014 annual report:
CFA relies on the Victorian Fire Risk Register and proximity to the bush to identify properties at high bushfire risk.
Our first concern is that the VFRR is an unsuitable risk management system. The CFA copied it from NSW Rural Fire Service, apparently without too much due diligence. VFRR claims to be based on ISO 31,000, but ISO 31,000 is not designed for or relevant to broad area bushfire risk assessment or management. Instead ISO 31,000 is designed for risk management within an organisation. Furthermore, the VFRR risk ratings have no correlation to ISO 31000, and are in effect, a confusing and distorted replica of it. In addition, ISO 31,000 specifically says that “ISO 31,000 cannot be used for certification purposes”. Refer Solution Paper 8B Paper 8B Misuse of ISO 31000 for bushfire risk.
Our second concern is that proximity to the bush is not the cause of bushfire damage. It is coincidental, but gets the blame. Refer to Solution Paper 3B. Paper 3B What is not to blame for house loss Demonising the forest penalises property owners near the forest irrationally and unfairly. It suggests an innate fear of forests within CFA culture. On the contrary, Red Eagle has found that forests with mitigated fuel are as good or a better an ally to the fire fighter and resident than mitigated grass fuel is. Demonising the forest diverts CFA attention from dealing with the real causes of bushfire damage – Refer Solution Paper 3A. Paper 3A House Loss – causes and influences
CFA aims to develop community resilience, ie, community’s ability to respond after adversity.
• CFA advises people about risk and encourages people to undertake protection.
• The CFA does annual research including monitoring risk perception in high risk areas
• Research helps discover people’s information needs
Our concern: We would prefer to see a policy of self reliance – use community resources and teamwork to prevent damage from the real causes before it happens. A policy of developing community resilience suggests that damage is regarded as inevitable, or that government lacks will or knowledge to prevent damage.
CFA targets people living within 150m of forest because research says 87% of bushfire deaths occur there.
There are 100,000 properties close to the bush and therefore deemed to be at high risk. CFA advises these people about risk and encourages them to leave early.
CFA also sent 100,000 personal messages to new residents in high risk areas to register for CFA information.
CFA regions monitor and develop preparedness levels in at-risk communities
Community Information Guides target at-risk communities.
Our concern is that CFA policy is confused by statistics and is targeting the wrong areas with the wrong messages. CFA seems to have a strong belief that proximity to forest is the cause of risk, house loss and deaths, and this has become the basis of policies which encourage residents near the bush to evacuate on bad weather days even before fires occur and policies which prevent new house construction near the bush.
We do not know which paper the CFA quotes from, but we are concerned that it is presented as a cut and dried fact because it is regarded by CFA as such. We are aware of a 2013 paper by CSIRO people in which they analysed bushfire death data back to 1901. They were looking for correlations not causes. They found 50% of deaths occurred inside a structure within 9m of forest, 78% within 30 m of the forest edge and 95% within 50 m, and 100% within 130m. Wow. Would a confused CFA boffin blame the structure and the forest, or just the forest? Come on CFA boffins. Listen up. When CFA policy people read references that say, for example, 80% of house loss occurs within 100m of forest, they use this as evidence to condemn the forest. It is like discovering that all people who lived in the 18th century are now dead, and then blaming the 18th century as a killer century. They do not understand that if 80% of all houses occur within 100m of houses, the presence of forest is a coincidence and therefore is not a cause of house loss. When they read a reference that 80% of house loss occurs within 100m of forest, they would also read that 10% of house loss occurs within 10m of the forest. They do not understand that these references are about cumulative house loss. If they apply their same misguided logic, they would promote that houses are safer near the bush because house loss is lower, wouldn’t they? See Solution Paper 6B. Paper 6B House loss rate in severe bushfires Part 2
While promoting evacuations, the boffins seem to selectively ignore the messages in other well known statistics, eg, (1) the loss rate in vacant houses in severe bushfire attack is 77% (this means if evacuation policy is successful, house losses are very high), and (2) the survey of residents during 2009 Victorian bushfires that found 77% of houses that were defended by one or more people survived the fires (this means self defence was a successful strategy during the Black Saturday fires).
Come on CFA boffins. For the sake of the people, seek help about your forest-a-phobia paranoia, and in the meantime look at facts and valid science for solutions.
The CFA has a new approach to discouraging new subdivision development at the planning stages, ie, to avoid “placing more people and new communities in high- or extreme-risk locations where the bushfire risk cannot be reduced to an acceptable level.”
They also say that works “such as the inclusion of a buffer, use of perimeter roads, etc can reduce the overall risk to an acceptable level”
Our concern is that the new CFA policy is now classifying areas near forest as high risk and is now determined not to allow any development. If so, this is against the spirit of the CFA Act. Remember the spirit of the CFA Act is to protect people and property where they are, eg, by enforcing removal of fuel hazards if a house is under threat and providing suppression services. It is also inimical to land values and the regional economy.
Is the change of policy an indication that the CFA now believes their risk-slaying tools do not reduce risk near forests to acceptable level? Since the WMO era began, the CFA has applied works such as buffers, roads and water supply to subdivisions, and then approved them. Since the WMO days, the CFA has required new owners to apply defendable space and BAL because they believed this reduced risk to acceptable level.
Maybe they now agree with our view that the whole WMO / AS3959 / BMO concept is flawed risk management because it is based on treating an artificial flame in an artificial forest that has no relation to causes of house loss. That would be the start of a breath of fresh air. They would have the support of the Royal Commission, which found no evidence that the WMO system or the AS3959 / BAL system reduced house loss on Black Saturday. See Solution Papers 7A, 7B, 7C and 7D. Paper 7A The BMO Experiment Paper 7B The WMO Experiment Paper 7C The AS3959 Experiment Paper 7D Can two wrongs make a right
But, alas the answer is no. Despite the non evidence, the CFA’s belief doctrine survives in the current BMO system, which also relies on these beliefs. Thus, CFA, fire agency and planning department policy protects us with the invisible but potent shield of beliefs. Unfortunately, beliefs might work well within the human mind, but are ineffective against the bushfire, which cannot think and simply obeys the laws of Nature.
We urgently ask that the CFA policy makers eschew fear of forests and entrenched beliefs to lead the revolution to base community protection policy on rational thinking that mitigates the real causes of bushfire damage.
CFA identifies 45,000 low risk allotments that do not need CFA referrals.
We support the idea of reducing red tape. We support the idea of declaring areas as bushfire-protected. We support the idea of freedom from the costly burden of ineffective statutory bushfire conditions on development. Our concern however, is that this risk category is based simply on them being far from a forest. If they are in grassland, the risk may be very high. Look at the grass fires of last year and the year before. They easily outran the high tech, post-Royal Commission fire agencies in relatively mild weather. The core issue is if they propose to protect their surrounding communities from bushfire attack? If the answer is yes, they can tell us how they will protect them. That would be a positive step for bushfire world in Victoria.
The brutal impact of the CFA’s new policy can be seen in the recent rejection of a planning permit. The planning permit meets all the government’s criteria for the Bushfire Management Overlay, but the CFA advises the Council of its opinion that the area is high bushfire risk and advises against a new house, despite being within a settled area. On the basis of this opinion, the Council rejects the application. Amazingly, Council does not seek documentary justification of the opinion nor seek an independent risk assessment. Thus, we are witnessing how CFA beliefs overrule the government’s planning policy.
Brutal? We think so. The property owners were burnt out in the 2009 Black Saturday fires, five years ago. He wanted to stay and defend, but the local CFA told him to get out quickly, leaving the house vacant and undefended. Now the same CFA has a policy that prevents rebuilding in the same area.
We wonder what has changed.
A bit of history: According to the CFA Act, the CFA is a suppression organisation, pure and simple. The suppression model relies on volunteer fire fighters attending reported fires. This is its Plan A protection strategy. It has long known that suppression capability is limited to a windy FDI 30, but the volunteers always do the best they can. What happens to the fires that escape fire fighter control? We can confidently say that the CFA leadership has never seriously considered this. Privately they must know they run as infernos towards communities and towns. But there is no Plan B, ie, no towns or communities are consciously protected from them using targeted, accountable strategies. Perhaps Plan A suppression leadership just does not do Plan B stuff.
Remember the night before Black Saturday, 2009. The Premier assures us we are the best prepared ever to deal with what is to come. Next day the CFA cannot stop some Black Saturday fires from causing death and damage on private property. Did CFA leadership mislead the Premier or were they conveying in hope their unshakeable beliefs? Later, the Royal Commission found fire command and organisation was a shambles, despite a decade of very high bushfire activity. It heard evidence that volunteer fire fighters were distraught because they were way out of their depth or because they experienced high danger situations, and heard evidence that towns were not protected from either flame or firebrands. We can reasonably conclude that the CFA’s Plan A protection strategy (the fire suppression model) was ineffective on this day (because the fires got away), and that the towns and settlements in the path of the runaway inferno had no Plan B protection strategy.
Returning to new houses … Before Black Saturday, CFA policy approves building in high bushfire risk rural fringe areas, applying AS3959 and the CFA-designed WMO protection strategies to new houses because it believes they reduce risk. In the event of a bushfire attack, Plan A is the CFA’s protection strategy, even though leadership knows it fails in severe bushfire attack. There is no Plan B.
The severe bushfire attack happens and houses are destroyed, both new and existing.
Fast forward five years and now the CFA does not want people to build in these areas. An application comes in to rebuild a house, and it meets similar protection strategies as before (WMO and AS3959 have since been morphed into the BMO). But new CFA policy overrules these and now prevents rebuilding in rural fringe, saying it is high bushfire risk. As before, in the event of a bushfire attack, Plan A is the CFA’s protection strategy, even though leadership knows it fails in severe bushfire attack. It now has a larger budget, so it is a stronger suppression organisation. In addition, the CFA has now declared such rural fringe areas are extreme risk. There are many existing houses within them, but it has no plan to protect them against flame and firebrands. Instead, it will do what all sensible suppression focused leadership does – evacuate the people.
Thus, the CFA’s apparent message is this – bushfire risk is high but we only deliver Plan A protection. Because Plan A will not protect you or your house, we don’t want you building there.
This logic is destroying people’s lives and asset values. It is in a time warp. Plan B is not contemplated by suppression focused leadership, even though it would make new and existing houses safe.
We call on the fire agencies to acknowledge Plan A’s maximum design capability and voluntarily initiate Plan B strategies to protect communities and houses from bushfire from higher danger levels. We help them with Solution Paper 9. Paper 9 Defensive suppression. We call it defensive suppression, so they should feel comfortable. It is based on the proven principles of dry fire fighting, but it has elements of wet fire fighting, which will make them feel good. When Plan B is done properly, new development and existing houses can coexist in safety within a bushfire-protected environment. See Solution Paper 1 and Solution Paper 10. Paper 1 Introduction to the bushfire solution papers, Paper 10 Bushfire Solution. Black Saturday tragedies are avoidable with the correct strategies.