ABOUT two months ago I received a “heads-up” from a mate who works in Canberra that Environment Minister Peter Garratt was considering listing prescribed burning as a threatening process under the Environmental Protection and Biodiversity Act. At first I thought this was nonsense, but then I reflected on the attitudes towards prescribed burning that we hear constantly from some well-known academics and environmental groups, and it suddenly seemed highly likely. So I wrote a letter to Prime Minister Kevin Rudd, seeking clarification. All of this was going at about the time of the catastrophic bushfires in Victoria.
I have now received a reply to my letter. It was written by Ms Kerry Smith, an Assistant Secretary with the Department of Environment, Water, Heritage and Arts. Mr Rudd had forwarded my letter to the Minister for the Environment, who in turn forwarded it to his Department, where it eventually filtered down through the Department’s Approvals and Wildlife Division to its Wildlife Branch and thence to the Species Listing Section.
I now realise that the situation is complex and has many ramifications, as demonstrated by the following advice from the Department:
1. In 2007 the Environment Department received a nomination (they cannot identify from whom) requesting that the Minister list as a threatening process under the Environmental Protection and Biodiversity Act: Contemporary fire regimes resulting in loss of vegetation heterogeneity and biodiversity in Northern Australia. The basis of the nomination was concern about widespread late-season fires in the seasonally dry tropics. The nomination did not raise prescribed burning as a threatening process. In fact, according to the Department, it took the position that prescribed burning at the right time of the year was appropriate as a measure to minimise the problem of wide-spread late-season fires.
2. The nomination was referred to the Minister’s Threatened Species Scientific Committee (TSSC), whose job is to review these proposals and make recommendations to the Minister. However, the Committee decided off its own bat that this nomination was relevant to the whole of Australia. So they then broadened the nomination, thus setting themselves the task of reviewing the impacts of contemporary fire regimes (obviously including prescribed burning) on vegetation heterogeneity and biodiversity for all ecosystems across the whole of Australia.
3. The TSS Committee has advised the Department that they propose to undertake a “transparent, rigorous, science-based assessment with full consultation with stakeholders and the public”. There will be a consultation period and public input will be sought. The Committee will identify independent scientists and consult with them. The final nomination will be released for public review and comments on the draft paper will be sought. The whole process is expected to take about a year. No start time and no budget were mentioned in the Department’s letter.
4. The TSSC has been given a deadline to provide its recommendation to the Minister by 30 September 2010. Minister Garrett will make the final decision, perhaps in early 2011
The Department’s letter concluded by referring me to Mr Peacock, Director of the Species Listing Section who would answer any further questions.
In the light of this letter, I have looked up the TSSC. It’s members are listed on the Department’s website. The Chairman is a Professor at the University of Qld and the other members are well-qualified academics and scientists. There is a marine biologist, a freshwater biologist, a river ecologist, a fisheries expert, a plant ecologist, a botanist, and an authority on fauna.
As far as I could see, there is no mention of bushfire management, fire science or fire ecology research in the resume of any of the members of the Committee. I assume that they will hire consultants to assist them as special advisers, as is normal practice with Committees like this.
I have also looked up a couple of the TSSC’s previous recommendations and it seems clear from this sample that they are wedded to the Precautionary Principle. This suggests a bias against action in favour of research, perhaps reflecting the weight of academics and scientists on the panel, as opposed to land managers with responsibility for fire outcomes.
The Department also advised in the same letter that even if this process results in contemporary fire regimes (which include prescribed burning in forests) being listed as a threatening process under the Act, “it would not result in the Australian government enforcing additional regulations on prescribed burning practices.” If something is listed as a threat the Minister “might decide to have a threat abatement plan” prepared, that “might consist of guidelines” regarding fire management practices.
I agree fully with the initial nomination. There is a serious problem with wide-scale late-season bushfires in northern tropical savannahs and woodlands. However, this has been known for at least 30 years or more, as has the solution, which is early-season prescribed burning to create a mosaic of fuel-reduced areas; these prevent late-season fires from burning too intensely (as the Aborigines knew maybe 30,000 yrs ago). We do not need a federal agency to research this any further. What is needed is for the governments of WA, NT and Qld to develop the appropriate land management plans for these areas, and to allocate the resources to get the plans implemented. Both the WA and NT governments, to my certain knowledge, are already active in this work, and there are a number of Aboriginal communities which are privately funded to carry out early-season burning.
It is interesting to note, and maybe the Committee will note it, that probably the most progressive and intelligent fire management practices in northern Australia at the moment are actually being carried out by corporate conservationists. I have reviewed the fire management policies and practices of the Australian Wildlife Conservancy for their large conservation estates in the Kimberley and north Qld, and I find that they are implementing exactly the sort of bushfire management that will optimise biodiversity and minimise carbon emissions, while also ensuring sensible fuels management. This is an instance of private land management setting first class standards, based on indigenous knowledge and excellent research from scientists, including Jeremy Russell-Smith and David Bowman.
The task which the TSSC has set itself cannot be accomplished in anything but a superficial way. How many contemporary fire regimes are there? Two hundred? A thousand? How many ecosystems across the whole of the country are being impacted by fire regimes? How is vegetation heterogeneity and biodiversity determined for each different ecotype?
It will be possible for the Committee to spell out some principles, but these are already well known to practicing fire ecologists.
I assume that the TSS Committee is competent and is honourably driven by a desire to protect Australian ecosystems from threats. But I question whether they can tackle this project in isolation from other considerations. For example for most settled areas, it is not possible to separate the threat of fire to flora, fauna and ecological communities from the threat to human lives, communities and social and economic assets. Humans are also a threatened species in some bushfire situations. I also question whether the TSS Committee has the expertise in bushfire science to enable them to make an informed assessment of all the many elements that will need to be taken into account in each different situation.
The inevitable appointment of consultants to assist the Committee presents serious dangers. The Committee will be tempted to select academics, who are always available for this sort of work, are inexpensive compared to professional consultants (the academics are already being paid by their institution) and are keen to influence decision-making about the environment. Unfortunately bushfire scientists are very thin on the ground in Australian academic circles, and their ranks include several who are already saluting the anti-prescribed burning and pro-wildfire flag. It is a sad commentary on the state of intellectual leadership in bushfire science at the moment that I can think of only one Australian academic who would not be considered (by people involved in bushfire management) as a complete disaster if selected by the TSSC as their scientific adviser.
The Federal government does not need to get involved in this issue. There are already existing agencies in each State who have this role. For example in WA we have the EPA, the Conservation Commission, the Department of Environment and Conservation, and a Threatened Species and Communities Unit. The specific job of the Unit is to identify, review and deal with threats to species and ecological communities. In a former life I chaired this body, and I know that they work professionally, taking into account the latest information from competent and experienced scientists and land managers.
The Environment Department’s assurance that no new regulation will arise, even if a listing is made ….. but the Minister “might decide to abate” a threat….. strikes me as threatening in itself. If the Committee was persuaded by, say, the views of the Wilderness Society that prescribed burning in the jarrah forest must be listed as a threatening process, and if Minister Garratt then decided that this threat must be abated …. how would he succeed without imposing some form of Federal regulation on fire management operations by the responsible WA agency? A State-Federal stand-off on the issue would be inevitable, and would provide environmentalists with a heaven- sent opportunity to ridicule the State’s land managers, and to take legal action against them.
The TSSC’s review and report will overlap the Royal Commission into the Bushfires in Victoria, who will be covering many of the same issues. This makes for some interesting possibilities. For example, the Royal Commission could decide that in order to mitigate future bushfire disasters in Victoria, there needs to be a larger annual program of fuel reduction burning under mild conditions. Simultaneously the Threatened Species Scientific Committee, having conducted its own independent assessment, could decide that prescribed burning is a threat to Victoria’s forest ecosystems. Where will this take us?
I consider this project and its lengthy and costly processes to be a waste of time and money. The project is too large and complex. No Committee, and especially one proposing to involve the public in its deliberations can possibly achieve an outcome within the proposed time frame that will have any scientific credibility. Moreover, I oppose the Federal government entering an arena in which there are already existing State and Territory agencies set up to do the job. I would prefer to see Federal money going to independent audits of State agency performance – have they set, and are they meeting appropriate standards, targets and objectives – and then publicly reporting the results. This would overcome the problem that most Australian park and forest management agencies are not subjected to any independent and professional performance audits against performance standards.
My concerns, of course, count for nothing. People in the fire management community already know that they will have to take this new review seriously. It has taken on a life of its own, expanding from a small and appropriate study of fire impacts on northern savannahs to a continent-wide review of everything to do with fire, ranging from fire exclusion to high intensity wildfires and every combination and permutation in between. This means that we will need to prepare submissions, attend hearings, comment on draft papers, meet with consultants, defend our positions against 19th century northern hemisphere ecological concepts, and computer models put up as a substitute for field research. In other words, hours, days, probably weeks of work, and because most of us are volunteers, it is work for nothing. We have to do this because we know that if we don’t, and our voice is not heard, the TSSC will be swamped by fire mythology, by un-researched ‘science’ and by laughable but plausible-sounding assertions from the anti-prescribed burning brigade.
I know in saying all this I will be pounced upon by the usual voices of green outrage, and be accused of trying to undermine the most important scientific review since European settlement. And perhaps I am being too pessimistic. I have participated in dozens of bushfire reviews over the years, and invariably they come out in favour of prescribed burning (with the usual qualifications and provisos, with which I invariably agree). Maybe there is a chance that this committee, coming to bushfire management and fire science with fresh eyes, might see through the nonsense which will come at them from retrogressive institutions like the Fenner School of Environmental Studies at ANU. Perhaps they will visit the fire areas in Victoria and see for themselves the vegetation homogenizing and destruction of biodiversity associated with large high intensity bushfires. They might even compare this with the diverse and heterogeneous outcomes from patchy frequent mild fire. We might even be able to demonstrate to the Committee that there is another way of looking at the Precautionary Principle, one which applies specifically to bushfires and their impacts on lives, ecosystems and the environment.
If not, we just have to keep on doing what we are doing already, and never give up: trying to teach politicians and senior bureaucrats the two fundamental truths about fire management in Australia: (i) bushfires are inevitable; but (ii) we can chose between controlled fires burning under mild conditions, or massive wildfires that take all before them.
Roger Underwood is Chairman of The Bushfire Front Inc, an organisation devoted to improving the standards of bushfire management in Australia.