Manager of Natural Environment Services
RFS Headquarters
Locked Bag 17
GRANVILLE NSW 2142
Dear Sir/Madam,
Coastwatchers has many concerns about the introduction of this code and its practical application into the community in general. The Rural Fire Service (RFS) is anticipating a level of expertise existing in the rural landholder community that does not exist at the moment for many reasons. Also this lack of expertise may lead to an increase in uncontrolled burn offs that have the potential to cause more environmental, social and property damage than is desirable.
Although this draft code does offer protection for some ecosystems on the whole it will lead to the loss of vegetation and further pressure on threatened or vulnerable species. The code relies on outdated vegetation mapping that is too general in nature and does not take into account regional factors. To this date mapping of threatened ecosystems is still evolving on the South Coast and Coastwatchers are not confident that this will be completed in the foreseeable future due to the inertia of government and budgetary constraints. We would therefore insist that the Precautionary Principle be applied to the introduction of this Code and that the Code be rolled out in parallel with other agencies involved in natural resource management. This approach would be consistent with Section 1.4 (a) & (b) of the code that states that the Code must consider Ecological Sustainable Development and Section 111 of the EP&A Act, Duty to Consider Environmental Impacts.
It appears that the RFS is the compliance and consent authority but the entire onus to safely and competently undertake the works in a timely fashion is the responsibility of the land manager. This puts undue pressure and responsibility onto land holders who for various may not be able to undertake the proposed works. This may lead to hardship and/or burning of vegetation at inappropriate times. As the threatened ecosystems of the South Coast has not been spatially quantified we must question the ability of the RFS to administer the Code so as to ensure the important issue of the protection of the environment is not compromised by an over zealous approach to the application of this Code.
In summary of the above Coastwatchers are generally concerned with the;
Furthermore, specific comments are outlined below;
Section 1.13 Enforcement
This section needs to be written in plain English so that the average man on the street can understand the intent of the document.
2.3 Land excluded from the Code
There is private land on the South Coast that is not adequately mapped but never the less has vegetation listed under the Threatened Species Act contained within its boundaries. These lands may fall within part 2.3(c) of this section of the Code.
2.4 Work that may be carried out in specific areas
The removal of weeds in sensitive areas by fire is totally unacceptable in rainforests and wetlands and should not be encouraged in place of manual removal techniques.
3.3 Land Management Zones (LMZ)
The fire management of private properties that contain many different forest types is complex and landholders will need expert advice when deciding the fire regimes for different mosaic patterns across the landscape. Properties are traded and there is no guarantee that the new owners will understand the importance of appropriate burning patterns or will even care and take a scorched earth policy to fire management. As this Code is rolled out the ability of the RFS to administer it will be tested and appropriate funds will need to be assured by the NSW Government in order to maintain the integrity of the environment.
4.3 Standards for the protection of riparian buffers
The buffers for the Asset Protection Zones (APZ) and Strategic Fire Advantage Zones (SFAZ) are inappropriate in the case of Wetlands, Lakes and Lagoons. These should be consistent with NSW Government Policy and the universally accepted standards and be 30 meters in width.
Other considerations are that, 1st and 2nd order streams occur higher in the landscape and on greater slopes, therefore buffers need to be wider in order to ensure that they are not unintentionally burnt as fire tends to behave more aggressively the steeper the slope.
Appendix A- Fire frequency table for SFAZs and LMZs
This table is too simplistic and does not take into account bioregional differences and issues of aspect and practical implications of the fire frequency. If this was strictly applied on the South Coast it would lead to massive air pollution events for many months of the year. The economic and environmental implications would be detrimental to the general community and industries that rely on the image of the area being marketed as the Nature Coast. When private property burn offs are combined with the hazard reduction works carried out by Forests NSW and the Department of Environment and Conservation this will lead to air quality and medical issues being raised by the community.
Finally, for this Code to succeed there needs to be a change in culture at the brigade level and elsewhere in the RFS. The RFS needs to be aware of the different attitudes to the environment and fire in the various communities of the South Coast. As outlined above the officers involved with the application of this Code will also be required to be up to date with the latest natural resource work being undertaken in the region.
The community was recently polled by the Eurobodalla Shire Council in order to ascertain their values. The IRIS Research Group findings have clearly identified that the natural environment is cherished by the residents of the Shire with the opening statement "By far the most prominent theme was for the natural environment to be preserved and valued". It continued,"Beaches and waterways remain pristinely clean and are complimented by an abundance of untouched bush areas".
Throughout the findings of this survey the community reinforced the message of the importance of the environment to the general prosperity of the Shire. The RFS will need to be sensitive to the communities' values and plan future interactions with them accordingly; these may require a different approach to those used in other parts of the State.
Yours Sincerely
Mark Fleming (Vice President)