MFPE 2014 CHAPTER 6 BUSHFIRE MANAGEMENT ON THE DEFENCE ESTATE Scope 6.1. The provisions of this chapter apply to all properties owned or leased by the Department of Defence and are to be considered a “Legal and Other Requirement” under the Defence Environmental Management System (EMS). 6.2. Each property that is owned or leased by Defence is to be assessed to determine if it is bushfire prone in accordance with paragraph 6.21. If found to be bushfire prone a Bushfire Management Plan (BMP) must be prepared using the templates and guidance in the National Guidelines for Bushfire Management and Mitigation on the Defence Estate (‘the Guidelines’) available from the Directorate of Heritage and Biodiversity Conservation, or on the Defence Estate Quality Management System Bushfire Management Page http://intranet.defence.gov.au/estatemanagement/environment/Programs/Bushfire/main.htm. Aim 6.3. The aim of this chapter is to define the requirements for bushfire management for all Defence owned and leased properties. References 6.4. Reference is necessary to the following documents: a. Relevant and applicable State and Territory legislation, codes of practice and guidance pertaining to bushfire management; b. Commonwealth Workplace Health and Safety Act 2011 and regulations; c. Environment Protection and Biodiversity Conservation (EPBC) Act 1999; d. Codes of Practice: How to Manage Work Health and Safety Risks, Managing the Work Environment and Facilities and Work Health and Safety Consultation, Cooperation and Coordination; e. AS 3959-2009 Construction of buildings in bushfire-prone areas; f. DI(G) Operations 05-1, Defence Assistance to the Civil Community - Policy and Procedures; g. DI(G) ADMIN 40-3 Assessment and approval of Defence activities under the Environment Protection and Biodiversity Conservation Act 1999; and h. DI(G) ADMIN 59-1 Management of Defence Training Areas and the Defence Training Area Management Manual (DTAMM). Background 6.5. The Department of Defence (Defence) manages approximately 800 sites around Australia, covering more than 2.7 million hectares and containing more than 25,000 assets. One hundred and fifty seven of these sites are currently classified as bushfire prone. Defence processes and procedures must ensure these areas are managed to minimise or prevent detrimental impacts of bushfire while recognising the fundamental role bushfire plays in the Australian environment. MFPE 2014 6-2 6.6. The Australian Government has a National Bushfire Policy Statement for Forests and Rangelands (2012) which set out principles and strategic objectives for bushfire management and national goals. The principles establish protection of human life as the highest consideration, and emphasise the importance of bushfire risk awareness, preparedness, and proactive planning for bushfire survival. The notion of ‘shared responsibility’ is emphasised, whereby fire and emergency services, bushfire-prone land/property owners, and individuals living, working or visiting bushfire-prone areas all have important parts to play in managing bushfire risk. The need to actively and adaptively manage the land with fire is highlighted to maximise environmental benefits and ecosystem resilience, and reduce the adverse impact of severe fires. 6.7. Australia’s land and fire management agencies operate to a national bushfire awareness, warnings and safety framework titled “Prepare, Act, Survive”. A critical element of the Prepare, Act, Survive framework is that communities (Defence and civilian) understand local bushfire risks and know how to: mitigate bushfire risks, prepare for bushfire season, and respond to bushfire incidents in accordance with pre-planned bushfire survival plans. 6.8. The Workplace Health and Safety Act 2011 requires that hazards are identified and that the ALARP (As Low As Reasonably Possible) principle is applied to reduce risks to ensure a safe and healthy work environment. This bushfire policy establishes a framework for assessing and managing risks arising from bushfire hazards. Implementation of appropriate mitigation activities must be based on the National Codes of Practice; How to Manage Work Health and Safety Risks, Managing the Work Environment and Facilities and Work Health and Safety Consultation, Cooperation and Coordination (http://www.comlaw.gov.au/details/F2011L02804). 6.9. Defence’s approach to bushfire management is consistent with the above national frameworks. However, Australian States do not have a consistent approach to bushfire planning in bushfire prone areas. This policy establishes national standards for bushfire planning and management on the Defence estate based largely on the New South Wales model. 6.10. The implementation of this policy is described in the National Guidelines for Bushfire Management on the Defence Estate (‘the Guidelines’). These are available on the Defence intranet http://intranet.defence.gov.au/estatemanagement/environment/Programs/Bushfire/main.htm and contain technical information and templates to facilitate the development of nationally consistent, policy compliant BMPs. Objectives 6.11. In order of priority, the objectives of bushfire management and mitigation are to: a. protect human life; b. protection of assets to maintain Defence capability; c. protect civilian assets; d. minimise the physical and environmental impact of bushfires; e. provide for bushfire protection work to be undertaken in an environmentally sustainable and cost effective manner; and f. maintain fire regimes that are appropriate and necessary to conserve the environmental values. Definitions 6.12. Asset Protection Zone: an area between an asset and a bushfire hazard where bushfire fuel has been reduced significantly to protect the asset. 6.13. Bushfire: An uncontrolled fire burning in forest scrub or grassland vegetation, also referred to as a wildfire. MFPE 2014 6-3 6.14. Bushfire-prone Area: An area that can support a bushfire or is likely to be subject to bushfire attack. For Defence purposes, a Bushfire prone area includes both the area of vegetation that has been identified as having potential to support a bushfire; as well as a 100m strip adjoining or, surrounding each area of such vegetation. 6.15. Bushfire Attack: Attack by burning debris, radiant heat or flame generated by a bushfire which might result in ignition and subsequent destruction of a building. 6.16. Bushfire management: All activities directed to prevention, detection, damage mitigation, and suppression of bushfires and recovery after bushfire events. Includes bushfire policy, administration, law enforcement, community education, training of fire fighters, planning, communications systems, equipment, research, and the multitude of field operations undertaken by land managers and emergency services personnel relating to bushfire control and the use of fire to meet land management goals and objectives. 6.17. Bushfire Hazard: A fuel complex, defined by volume, type condition, arrangement, and location, that determines the degree of ease of ignition and of resistance to control. Bushfire hazards are variable in their severity, with severity levels usually measured in terms of the fire intensity (kW/m) arising from the hazard. 6.18. 6.19. Environment: The term environment includes: a. ecosystems and their constituent parts, including people and communities; b. natural and physical resources; c. the qualities and characteristics of locations , places and areas; d. heritage values of places; and e. the social, economic and cultural aspects of a thing mentioned in paragraph (a), (b) or (c). Fire regime: the inter-fire interval and intensity of fires occurring at a place. 6.20. Non-suppression activities: Activities taken to reduce bushfire risk which do not involve response action to control a fire. They include such things as mitigation awareness program activities and actions to warn, evacuate, shelter in response to a fire. Determining if a Property is Bushfire Prone 6.21. For the purpose of this chapter, a Defence property is designated as “bushfire-prone” if it: a. abuts non-Defence land designated as bushfire prone through a State/Territory or Local government process; b. abuts non-Defence land not designated as bushfire prone through a State/Territory or Local government process, but which represents a potential bushfire risk 1; or c. contains areas of vegetation that could support a bushfire2. 6.22. All properties owned or leased by Defence and designated bushfire-prone, shall be subject to an ‘Overall Site Bushfire Risk Assessment’ undertaken to determine the appropriate category of Defence Bushfire Management Plan to be prepared for the site. The ‘Overall Site Bushfire Risk Assessment’ methodology described in the Guidelines is to be used. 6.23. If a property owned or leased by Defence is designated as bushfire prone a Bushfire Management Plan (BMP) must be prepared in accordance with this chapter. 1 A potential bushfire risk is considered to exist on sites where Defence assets are within 100 metres of a forest (other than rainforest), woodland or heath/shrubland, 1 or more hectares in extent, on the adjacent land. 2 Vegetation that could support a bushfire is considered to be forest (other than rainforest), woodland, or heath/shrubland, 1 or more hectares in extent, or grasslands which carry more than 2 tonnes per hectare of grass cover in the bushfire season MFPE 2014 6-4 Bushfire Prone Area Maps 6.24. A property that has been designated as Bushfire prone may have one or more distinct Bushfire Prone Areas. It could also be the case, as in 6.21(a) and 6.21(b), that the area of vegetation that might support a bushfire is outside a Defence boundary but the area that might be subject to bushfire attack includes areas within the Defence property. a. Properties that have been designated as “Bushfire Prone” are to have a map prepared that identifies the Bushfire Prone Area(s). The map is to delineate: (1) the vegetation that could support a Bushfire3; and (2) a 100m strip adjoining or surrounding each area of vegetation delineated in 6.23(a)(1). b. An electronic version of a map developed in 6.24(a) shall be maintained in the Defence Estate Management System (DEMS) Estate Register (see Estate Register User guide). c. A DSRG Spatial Data Management Plan compliant version of the map shall be submitted via National Spatial Information Management System for use in the Defence GIS. Bushfire Management Plans 6.25. Bushfire Management Plans (BMPs) are developed to protect a range of values, in accordance with the objectives set out in paragraph 6.11. These include protection of life and assets, but also environmental values. Fires spreading from or through Defence properties also pose risks to these values on adjacent land and BMPs must also take those risks into account. In addition to bushfire mitigation works, sites that contain native ecosystems may require the application of prescribed fire for ecological purposes. The BMP must detail the role and need for ecological burning, and risk mitigation strategies to ensure such works are conducted safely. 6.26. BMPs must be prepared in accordance with the BMP templates contained in the Guidelines. 6.27. Three BMP templates have been developed with content and format appropriate to the assessed Overall Site Bushfire Risk Assessment level for the site. Lower Risk sites: Level 1 BMP template A single sheet plan (A3 or larger) map-based plan (incorporating a map showing site layout and features, site access, bushfire prone areas/assets, asset protection zones, emergency assembly areas, and other information of use to fire and emergency services which may attend the site) and also incorporating mitigations works requirements, preparedness and response requirements, and relevant emergency contact details. Moderate Risk sites: Level 2 BMP template A single sheet plan (A1 or larger) showing information similar to that for a Level 1 BMP, with linkages to a regional or sub-regional BMP (document type) which contains more detailed bushfire resource information, risk assessments, procedural details and standards and information covering each of the BMP section requirements. Higher Risk sites: 3 Level 3 BMP template A BMP (document type) specific to the site which contains more detailed bushfire resource information, risk assessments, procedural details and standards and information covering each of the BMP section requirements, and incorporating map-based plans providing appropriate spatial specifications for mitigation, preparedness and response requirements. The perimeter is to encompass all of the Bushfire prone vegetation types. MFPE 2014 6-5 6.28. The development of a site BMP shall include consultation with all relevant stakeholders including the local fire authority responsible for the region in which the Defence property is located. 6.29. The Base Security and Emergency Management Committee (BSEMC) and Environmental Management Committees (or equivalent) must be made aware of the development of draft BMPs by the person preparing the plan. The BSEMC must be satisfied that any conflicts identified between BMP recommendations and existing site emergency response plans are resolved prior to finalisation of the BMP. 6.30. Defence environmental staff must review the BMP to ensure proposed fire mitigation measures are consistent with Defence’s obligations to protect the environment (see section 6.38). 6.31. Noting that bushfire management has been undertaken on Defence properties for many years, any new works proposed in a BMP must be explicitly demonstrated to be fit-for-purpose and necessary for bushfire management. They must be cost-effective and environmentally responsible. 6.32. If a change in the level of works performed by Base Service contractors will be required to deliver works prescribed in the BMP, the Garrison, Estate and Business Support Branch in Defence Support Operations, DSRG, should be engaged to provide an assessment of the feasibility of the proposed services and works prior to finalisation of the BMP. 6.33. The roles and responsibilities for the development of the BMP are listed in table 6-1. Person/s Responsible Role Regional Director (RD) Responsible for the assessment and management of bushfire risk on the properties for which they are responsible. The RD must approve all Bushfire Management Plans (BMPs) prepared for those properties. Persons delegated by the RD Any person directed by the RD to perform a task in order to manage bushfire risks must do as instructed to fulfil their obligations. This includes specialist contractors responsible for land management on, e.g. designated Explosive Ordnance sites. Typically the Senior Environment Manager will be responsible for initially reviewing the quality of the BMP and the Base Support Manager will be responsible for ensuring works are implemented. However, Range Control Officers or other groups and service personnel may fill these roles for certain properties. These roles must be defined in the BMP. Base Service Contractors4 Have primary responsibility for performing works required by the BMP. All works and associated planning of works, must be jointly conducted with relevant Defence personnel to ensure Bushfire risks are mitigated. National Program Manager responsible for Bushfire Policy in Environment and Engineering Branch, Defence Support and Reform Group Responsible for ensuring The Defence Bushfire policy is up to date and that appropriate guidance is available to persons responsible for implementing the policy, including development of BMPs Directorate of Environmental Protection and Assessments in Environment and Engineering Branch, Defence Support and Reform Group (DEPA) If required, provide technical assessment of environmental impact assessments associated with BMPs. DEPA are the Defence lead and point of contact if a referral to the Minister for Environment under the EPBC Act is required. Table 6–1: Roles and responsibilities for BMP 4 Includes GSS, CMS and Base Service contractors MFPE 2014 6-6 Implementation of Bushfire Management Plans 6.34. The implementation of this policy and any plans and works arising from it must be in accordance with the Commonwealth Workplace Health and Safety Act 2011. 6.35. Works included in an approved BMP will be implemented based on an annual assessment of the feasibility of works against environmental and budgetary constraints. When assessing the feasibility of works a risk assessment must be conducted that takes account of Defence risk dimensions. Where a direct threat to personal safety is likely if works are not conducted, the risk mitigation requirements of the Code of Practice How to Manage Work Health and Safety Risks must be taken into account. 6.36. Pre-season checklists (appendix H of the Guidelines) of mitigation and preparation works must be completed and logged in the relevant Estate Maintenance System. 6.37. Fire protection requirements are to be maintained on properties that have been identified for disposal as outlined in chapter 17 and in addition this includes implementation of the BMP. Environmental Impact of Bushfire Management Activities 6.38. Under the provisions of the Environment Protection and Biodiversity Conservation (EPBC) Act (1999), Defence has a responsibility not to take an action that has, will have, or is likely to have, a significant impact on the environment without approval of the Commonwealth Environment Minister. All BMPs are to be developed and implemented in such a way that there will be no significant impact on the environment unless absolutely necessary. 6.39. Defence has a further obligation under Commonwealth Biodiversity Policy to first avoid any clearing of native habitats, then, if clearing is necessary, to mitigate any such impacts, and then to potentially offset any residual impacts of clearing. 6.40. BMPs should carefully consider the need for new trails, firebreaks or hazard reduction works in light of these obligations, balanced against the priority requirements to protect life and capability. Impact assessments for proposed new works will follow the process set out in the Guidelines and will be included as an appendix in the BMP. Further advice on Defence’s obligations under the EPBC Act are available in DI(G) ADMIN 40-3. Bushfire Management Plan Monitoring, Reporting and Review Cycle 6.41. In addition to the annual completion of pre-season checklists outlined in paragraph 6.35 there is an annual requirement to provide digital mapping of fire events and to report fire-related matters as detailed in the Guidelines. 6.42. Every fire event affecting the Defence estate, including planned and uncontrolled burns, must be reported to the RD or delegate using the bushfire reporting form included in the Guidelines. Full reporting should occur within seven days of the fire being extinguished, and no more than 14 days afterwards. 6.43. BMPs are developed for an expected five-year life. Plans will be reviewed at periods not exceeding five5 years. Earlier revision may be deemed necessary as a result of the outcome of a bushfire-related incident, end-of-season review or a bushfire or other activity that substantially changes the risk profile of a property and required mitigation works. 5 five year BMP’s for sites north of the Tropic of Capricorn are not to incorporate prescribed burning works in the Bushfire Mitigation Works Schedule. For tropical zone sites the BMP is to identify a process for how Annual Burning Works Programs will be developed that takes account of areas burnt by planned and unplanned fires in the last and other recent seasons MFPE 2014 6-7 Bushfire Prone Asset – Specific Risk Assessment 6.44. All BMP’s shall contain a risk assessment for all Defence assets within bushfire prone parts of a site. The risk assessment procedure applied shall be in accordance the methodology specified in the Guidelines. 6.45. All BMP’s shall prescribe appropriate Asset Protection Zones (APZ) between bushfire prone assets and bushfire hazards. APZ dimensions shall be appropriate to the type of vegetation hazard, slope class of land on which the hazard and asset are situated, building construction level, and the Regional/Jurisdictional value for Fire Danger Index promulgated in AS 3959 Table 2.1 (or as otherwise refined and declared by the relevant State/Territory jurisdiction). Procedures for determining APZ dimensions and standards are contained in the Guidelines. 6.46. Bushfire fuel reduction strategies to reduce the intensity and rate of spread of bushfires shall be considered for all Level 2 and 3 risk properties. Any proposed fuel reduction activities require an explanation of how the activity will reduce risk and to what assets/values. If no fuel reduction strategies are proposed the reasons why not are to be documented. For all fuel reduction works proposed during the life of the BMP, the following information is to be provided: a. Location and management unit identification number/name; b. Size in hectares of unit to be treated; c. Vegetation types and proportions within the proposed treatment area; d. Expected hazard level or fuel load at nominated treatment year; e. Objectives of the fuel reduction treatment; f. Prescriptions to be applied during the fuel reduction treatment; g. Nominated treatment area boundaries; h. Nominated season for treatment; i. Proposed treatment method (eg. slashing, mechanical removal, grazing, ground or aerial burning or combination thereof); and j. Forecast cost of BMP requirements. Bushfire Prone Areas and Construction Standards 6.47. Chapter 7 details Defence requirements for all building proposals on sites that have been designated ‘Bushfire Prone’. Identification of Desirable Fire Regimes 6.48. All BMPs shall identify the fire regimes necessary to provide vegetation cover and structure characteristics appropriate and safe for Australian Defence Force (ADF) training requirements. Regimes should be ecologically appropriate for the vegetation types to which they are to be applied. 6.49. Where there is a conflict between the fire regimes necessary to promote vegetation cover attributes suitable for training activities and those required to maintain ecological health and diversity, the acceptance of the burn regime will be governed by the conservation status of the vegetation. Ecological requirements will take precedence in communities listed under the EPBC Act, and training requirements will take precedence in all other communities unless a fire-sensitive EPBC listed species is present that would not tolerate the prescribed regime. Decisions regarding appropriate burn regimes must be documented in the BMP. MFPE 2014 6-8 Prepare, Act, Survive Planning 6.50. Consistent with the nationally adopted ‘Prepare, Act, Survive’ bushfire survival planning framework, all BMPs shall contain bushfire preparedness (seasonal and event), pre-planned bushfire defensive response and survival action requirements for site users. Requirements shall be documented in a Prepare, Act, Survive plan6 specific to each individual property. 6.51. Adequate Prepare, Act, Survive planning is essential to meet the central Work Health and Safety planning requirement to Consult, Co-operate and Co-ordinate. Prepare, Act, Survive plans shall be prepared in accordance with the Guidelines. 6.52. The BMP shall specifically identify non-suppression related response requirements in the event of a bushfire on or threatening the site. Triggers and procedures for site evacuation shall be identified, procedures for personnel remaining on site shall be identified, including preparedness actions and decision triggers for any defensive actions while sheltering on site. 6.53. The BMP shall identify the locations and capacity of bushfire emergency refuges of last resort7 on site. These are only for use in the contingency that inadequate bushfire warning is received and safe evacuation of personnel from the site is not possible. Current Bushfire Attack Level of the refuge area as well as bushfire attack vulnerabilities and recommended upgrade works for refuge areas will be identified in the BMP. Response Capability Assessment for Defence Activities 6.54. All BMPs shall contain an assessment of what suppression resources should be at immediate readiness for Defence activities that have the potential to start bushfires for each Fire Danger Rating (FDR) category. Chapter 7 of the Defence Training Area Management Manual (DTAMM) outlines an incremental restriction of live firing activities at increasing fire danger. Under no circumstances should live firing be conducted during a catastrophic fire danger rating. Live firing activities should not occur on days of high or extreme fire danger, or days when a total fire ban has been declared. However, where there is an operational urgency to conduct an exercise during high or extreme fire danger, an approved waiver can be sought in accordance with the provisions of chapter 7 of the DTAMM. Clear prescription of what resources are required under these conditions is therefore vital to ensure safe conduct of training. Assessments shall be conducted in accordance with the Guidelines, and must determine; the level of first response available on the property, what is required to meet activity needs, and what the likely delay is until other fire-fighting services arrive on site. Consistency between Bushfire Management Plan and Base Emergency Incident Response Plans 6.55. The person preparing the BMP shall identify the relationship between the BMP and any relevant Emergency Management Plan (EMP) for the site. If there are necessary inconsistencies between the BMP and EMP these must be referred to the BSEMC or relevant body in charge of emergency management for the site, and approved prior to finalisation of the BMP. Relevant Qualifications and Experience for Bushfire Management Planning Contractors 6.56. There are no national qualifications frameworks for Bushfire Management Planning covering the range of bushfire management planning tasks required by Defence. Therefore to ensure that Defence BMPs are prepared or reviewed by appropriately skilled and experienced bushfire management planners, persons preparing or reviewing a plan must be able to demonstrate the following: a. 6 7 Understanding of fire behaviour in the region being assessed – demonstrated use of fire behaviour models for the prediction of bushfire spread and behaviour in forests, woodlands, heath, shrublands and grasslands (choose those vegetation groups applicable to the site). Demonstrated experience using fire behaviour potential predictions for determining what levels of suppression response capacity may be needed to contain bushfires at different Fire Danger Ratings (FDRs); Prepare, Act, Survive planning requirements are identified in the Guidelines Criteria for selecting bushfire emergency refuges of last resort are identified in the Guidelines MFPE 2014 6-9 b. Practical understanding and experience of how fires are suppressed – practical experience of bushfire suppression operations for the purpose of determining what levels of suppression response capacity may be needed to contain bushfires at different FDRs; c. Practical understanding of prescribed burn planning and implementation requirements – Practical experience planning and conducting prescribed burns for the purpose of ensuring that prescribed burning works proposed in Bushfire Mitigation Works Schedules are actionable, ecologically appropriate, cost-efficient, and able to be safely conducted; d. Understanding of the AIIMS Incident Control System for fire incident management – demonstrated experience working in Incident Management Teams using the AIIMS ICS system, for the purpose of identifying appropriate command and control arrangements, including partnership arrangements with emergency services, for inclusion in the Response section of the BMP; e. Practical land management experience – demonstrated practical understanding of land management activities, such as road and trail maintenance; weed management; safety and hazard management in bushland situations; soil and water considerations; for the purpose of devising actionable, effective and cost-efficient works requirements in Bushfire Mitigation Works Schedules and Recovery actions; and f. Experience preparing strategic and tactical fire management plans covering scales from landscape level to property level. Demonstrated experience preparing bushfire management plans at the scale relevant to the site, and experience relevant to local landscapes and ecosystem types.