Submission to the Integrated
Municipal Fire Management
Planning
Discussion Paper
Municipal Association of Victoria
February 2006
This submission has been prepared by the Municipal Association of Victoria (MAV) in
response to the release of the Integrated Municipal Fire Management Planning project
discussion paper.
The MAV is the statutory peak body for local government in Victoria, representing all 79
municipal councils within the state. This submission has been prepared by MAV staff
following consultation with councils from metropolitan, regional and rural areas.
Whilst this submission aims to broadly reflect the views of local government in Victoria, it does
not purport to reflect the exact views of individual councils, who have also been encouraged
to make submissions directly to the IMFMP Project Team.
For further information about this submission contact:
Eleanor Jacobs
Policy Adviser
Municipal Association of Victoria
Tel 9667 5533
Email: ejacobs@mav.asn.au
February 2006
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1. Introduction
The Municipal Association of Victoria (MAV) welcomes the opportunity to contribute
to the direction of integrated fire management planning in Victoria. Local government
has a significant role in ensuring the safety of Victorian communities and, as part of
this, all municipalities have an involvement in managing local fire risks. Local
government is therefore a significant stakeholder in the Integrated Municipal Fire
Management Planning (IMFMP) project as acknowledged by the presence of Norm
Free as Local Government Consultation and Communications Manager on the
IMFMP Project Team.
It is important to note, however, that local government does not necessarily support
the title of this project which should be Integrated Fire Management Planning to
recognise that integration will occur at all levels: state; regional; and municipal. In
particular, many councils see great value in strengthening fire management planning
at the regional level to provide strategic direction for fire management at the local
level.
This submission only considers in detail those issues and options raised in the
IMFMP Discussion Paper that are likely to have a significant impact on the local
government sector.
One issue of great importance to the local government sector is that of leadership of
the fire management planning process at the municipal level. A range of opinions on
which organisation or appointment would be most appropriate to lead this process
have been expressed by councils across Victoria including significant support for
municipal councils leading the planning process. The MAV recommends that fire
management planning be led by the MFESB in the three metropolitan regions and
CFA in the five rural and regional areas. This would ensure that a coordinated
planning process could be implemented state-wide and would ensure that agencies
with expertise in fire issues attest to the integrity of the municipal plans.
1.1 Key Recommendations
The MAV position on the propose options appear in boxes throughout this
submission. The key recommendations that are highlighted in this submission are:
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That a State Fire Management Policy Committee is established. The terms of
reference for this committee should include providing policy direction;
developing the integration of fire services; strategic planning; monitoring of
relevant research and development in fire management; considering broader
issues such as climate change; and assessing fire risk at the state level.
That new arrangements for fire management at the regional level is
developed that integrate fire management planning with regional emergency
management arrangements.
That a standard format for Municipal Fire Management Plans is developed in
a way that encourages better planning rather than a template format.
A self-audit process for Municipal Fire Management Plans is established at
the municipal level incorporating a clear reporting structure to ensure that
appropriate standards are maintained.
That a Code of Practice for Fire Management is developed for Victoria.
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2. Project Assumptions
The local government sector generally accepts the project assumptions made in the
discussion paper, however there are three assumptions that require further attention:
the assumed risk management standard; the inclusion of ‘preparedness’; and the
assumed funding arrangements.
2.1 Risk Management Standard
In paragraph 24 it states that ‘This project assumes that fire management planning
will be aligned to the Australia/new Zealand 4360 Risk Management Standard’.
While there is some support from local government for the use of this standard for
the purpose of consistency of approach to risk management, concerns have been
raised about its applicability for fire management in practice as it is time consuming
and resource intensive to implement.
This standard was introduced to Victorian emergency management arrangements a
number of years ago but has not been evaluated since its introduction. In order to
justify its continued usage, this standard should be tested for outcomes and whether
these outcomes justify the resources required to utilise it. It is important to explore
other options for risk management before assuming that the Australia/New Zealand
standard 4360 is the most appropriate.
MAV Position – Project Assumptions, paragraph 24: It must be
recognised that the Australia/New Zealand Standard 4360 is resource
intensive. If this standard were to be introduced for integrated fire
management, there would need to be additional resources provided and
time allowed to phase in its usage.
2.2 Inclusion of Preparedness
It is important that fire management planning is aligned with emergency management
arrangements more broadly to ensure an integrated approach. The Emergency
Management Manual Victoria (EMMV) states that the three major functional areas
recognised as necessary components for a comprehensive approach to emergency
management are “Prevention, Response and Recovery”. While preparedness is
recognised as a key responsibility of agencies in the EMMV, it should be removed
from the project assumptions for the IMFMP project to align with the broader
emergency management arrangements.
2.3 Recurrent Funding
While it is stated in the assumptions that recurrent annual funding of $1.43m will be
provided by the State Government, it is not clear how this is to be spent or whether it
will be adequate to implement the project outcomes. Sufficient funding should be
provided to achieve the objectives of the project, the project should not be adapted to
the funding being offered.
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3. Structural Arrangements and Role Definition
3.1 Memorandum of Understanding at State Level
Section 1.2.1 Structure at the State Level, paragraph 47 – Proposes that a
Memorandum of Understanding is established at the state level between
stakeholders with fire management responsibilities to ensure a coordinated planning
approach and appropriate interface between participants.
A Memorandum of Understanding may be pre-emptive if established before
clarification of roles and responsibilities at state, regional and municipal level. These
roles must be established and implemented before a Memorandum of Understanding
can be meaningful.
Metropolitan councils have questioned whether they should be included as a
stakeholder with fire management responsibilities as they currently have a limited
role in fire management. The Metropolitan Fire Brigades Act 1958 states that “Each
municipal council, the municipal district or part of the municipal district of which is in
the metropolitan area of Victoria must appoint a person to be the fire prevention
officer for that council for the purposes of this Act”, In addition metropolitan councils,
as with rural and regional councils, have a role in land management and enforcement
through fire prevention notices. The level of involvement for metropolitan councils
needs to be considered in situations where there is not a significant fire risk within the
municipal boundary.
MAV Position – Section 1.2.1, paragraph 47: A Memorandum of
Understanding between stakeholders with fire management responsibilities
should be developed after roles and responsibilities at the state, regional
and municipal levels have been established and implemented to reflect the
new arrangements.
3.2 State Fire Management Policy Committee
There was strong support from the local government sector for the establishment of a
State Fire Management Policy Committee. Councils indicated that a State Fire
Management Policy Committee could provide the following support that would be of
value to the local government sector and all agencies involved in fire management in
Victoria:
- Policy direction;
- Integration of services;
- Strategic planning;
- Monitoring of relevant research and development in fire management;
- A consideration of broader issues such as climate change;
- An assessment of risk at the state level; and
- A keystone for integrated fire planning.
MAV Position – Proposal 1.2.1a, paragraph 48: Local government
supports the formation of a State Fire Management Policy Committee. It
is suggested that clear terms of reference should be developed for this
committee.
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3.3 Regional Coordination of Fire Management Planning
Councils indicated support for Option 1.3.1b which proposes that new arrangements
for emergency management planning at the regional level, which integrate fire
management planning with the regional emergency management arrangements.
Some concern was raised that of the agencies involved in fire management, some
currently work on a regional basis while others are divisional. However, there is
strong support for more planning and coordination to occur at the regional level to
ensure consistency across municipalities.
MAV Position – Section 1.3.1, paragraph 57: Local government
supports Option 1.3.1b that proposes that new arrangements for
emergency management planning at the regional level that integrates fire
management planning with the regional emergency management
arrangements.
3.4 Leadership at the Regional Level
There was little consensus from the local government sector about who should lead
the fire management planning process at the regional level, however it seems
reasonable that it should be appointed by the State Fire Management Policy
Committee. This committee would then have the ability to align the leadership of fire
management planning process at the state, regional and municipal levels to ensure
an appropriately integrated system.
Some support has been expressed by local government for a neutral appointment to
lead fire management at the regional level. Cultural issues amongst fire agencies at
local level, and therefore collectively at the regional level, are of concern and
increase the appeal of a neutral option. An important aspect of the workability of a
neutral appointment would be the establishment of clear reporting requirements back
to state level arrangements. It would also be important to define which organisation
or person would be eligible to be a neutral appointment before this proposal could be
fully supported by the local government sector.
Option 1.3.2a is supported by some councils and certainly it seems that an agency
with a strong involvement with fire management would be a logical choice. However,
it has also been raised that it would be problematic for any land manager (i.e. the
Department of Sustainability and Environment (DSE) or municipal councils) to lead
fire management at either the regional or municipal level. This means that Option
1.3.2a may not be supported on the basis that the DSE may be the organisation
deemed responsible for managing the most significant level of risk in some regions.
It is not clear from this discussion paper how the greatest level of risk would be
ascertained.
Urban interface councils would be concerned if grouped with metropolitan councils as
the appropriate leadership may not be the same for inner metropolitan and interface
councils with significant wildfire risk.
It was noted that a move towards regional emergency management would require
significant commitment from the State Government. There was strong support for
the integration of fire management into emergency management arrangements
recognising that fire is just one of the risks faced by Victorian communities.
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MAV Position – Option 1.3.2b, paragraph 62: Fire Management
Planning at the regional level should be led by an appointment made by
the State Fire Management Policy Committee.
3.5 Structure at the Municipal Level
It is important when examining the fire management planning arrangements, that fire
is treated in the same way as other risks identified through emergency management
planning. Clearly this is in line with the all-hazards approach that is central to
Victoria’s emergency management arrangements.
Local government has strongly argued that the current composition of Municipal Fire
Prevention Committees (MFPCs) needs to change if they are to become effective
structures. Currently MFPCs are often dominated by fire agencies and this does not
allow for adequate input from the other agencies and organisations involved in fire
management at the local level. There was also concern that current MFPCs do not
necessarily have expertise in risk management processes.
Despite some concern about the assumption of local government involvement in fire
planning, it is recognised that if community engagement is a key element of fire
management, local government will need to have a continued role in MFPCs even if
they do not lead these committees or the planning process.
Some councils have indicated support for Option 1.4.1b due to its flexibility and that it
allows for fire to come under the Municipal Emergency Management Planning
Committee. Others suggested that Option 1.4.1c would be more appropriate due to
its alignment with a risk management approach and its potential for better
engagement with private stakeholders and public authorities.
Many councils have indicated that in their experience Fire Prevention planning can
be more onerous that Emergency Management planning. On this basis it is of
concern that metropolitan councils may have additional planning responsibilities if the
recommendations contained in section 1.4.1 were adopted state-wide.
There is some support in the local government sector for Option 1.4.1b and 1.4.1c.
There is clear support for fire management planning to sit under emergency
management planning. However, there is not clear direction as to how the legislation
should support this either through mandated fire management planning arrangement
or under the existing Emergency Management Act 1986.
3.6 Leadership at the Municipal Level
There is no definitive local government position about who should lead fire
management planning at the municipal level. There is both strong support for and
opposition to the proposal that local government could provide this leadership role.
The MAV Position listed below was supported by the MAV Board of Management.
During MAV conversations with local government representatives, some level of
support has been expressed for all options - 1.4.2a, b, c, d and e.
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At the fundamental level, it has been questioned whether Municipal Fire Prevention
Committees would be necessary at all if appropriate regional arrangements were in
place. It could be that only an operational plan would be required at municipal level if
regional planning provided the strategic focus for fire management.
As with the regional level it seems somewhat logical that an agency with a strong
involvement in fire management would lead this process (Option 1.4.2a or 1.4.2b) but
there is also concern that a land manager should not have this responsibility.
Options 1.4.2a and 1.42c suited some municipal arrangements where the CFA, DSE
or MFESB are seen as best placed to lead the municipal level fire management
planning process. As indicated earlier, there is concern that DSE should not lead fire
management planning processes as they are a major land manager.
Of those that supported Option 1.4.2d, a neutral appointment, it was argued that
currently it is difficult to get all relevant agencies and organisations involved and that
this may assist in bringing everyone to the table. It was suggested that a neutral
appointment would avoid some of the current political and cultural problems faced in
the functioning of MFPCs. However, this option would be problematic to implement
in practice for two reasons: firstly, it may require a new structure to be created at the
municipal level; and secondly, it would be difficult to ensure that a neutral appointee
would have sufficient local knowledge and expertise to perform this role.
Of those councils who indicated supported for Option 1.4.2e, that municipal council
will be responsible for leading the fire management planning process at municipal
level, it was clearly stated that this role needs to be better resourced. Currently
councils have significant responsibility for fire management but are provided with little
power to assist in performing these roles. Concerns were expressed about the
liability issues of local government leading this planning process. If many agencies
have input into fire planning, should local government be held accountable on behalf
of all participants when plans are audited or tested? This raises questions about who
exactly is being audited if the plan is a group effort. If 1.4.2e was adopted, it was
suggested that power to delegate to another agency may be a useful inclusion.
It is important to note that some councils have indicated that they strongly oppose
Option 1.4.2e and indicated that local government should NOT lead fire management
planning at the municipal level. There were a number of reasons for this position
including the lack of expertise or involvement of fire management issues on a day to
day basis, the lack of resources available for these activities, and the fact that this is
the current arrangement and has not proved to be an entirely effective strategy.
If Option 1.4.2d or e are to be effective there will need to be appropriate resources
and legislative power factored into the arrangements.
It was noted that it is difficult to comment on this issue before the state and regional
arrangements are established. Ultimately it is best if all arrangements are
appropriately aligned.
MAV Position, Section 1.4.2, paragraph 85: The MAV supports Option
1.4.2a, that fire management planning at the municipal level be led by
CFA within the five rural and regional areas and by MFESB within the
three metropolitan regional areas.
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4. Consistency in Fire Management Planning
4.1 Standard Format for Municipal Fire Management Plans
The proposal to develop a standard format for Municipal Fire Management Plans is
generally supported with many councils acknowledging it is important that there is
consistency in fire management planning across municipalities. However, it is
important that the standard format be provided as some form of guide only and not
as a template. Templates were viewed as “tick the box” exercises that have little
value in practise. The process of planning is seen as more important than the
product by the local government sector.
MAV Position, Proposal 2.1a, paragraph 103: The proposal to develop
a standard format for Municipal Fire Management Plans is supported.
However, this format needs to be provided in a way that encourages
better planning rather than a template which may lead councils to take a
less active approach to planning.
4.2 Strategic Municipal Plan
Councils indicate that the proposal 2.1.1a, that municipal fire planning should be
based on the direction contained within the strategic plan, would help them align fire
planning across municipal boundaries and would ensure a uniform approach.
MAV Position, Proposal 2.1.1a, paragraph 106: The proposal that
municipal fire planning is based on direction from a strategic plan is
supported.
4.3 Municipal Fire Management Planning Cycle
Some concern was expressed by councils about proposal 2.1.2a that operational
municipal fire planning be completed annually. It was suggested that potentially
there should be a 10 year strategic plan (forward-looking program) and that municipal
fire planning be completed every three years or more often if necessary, i.e. if
significant development has occurred in the municipality.
It was suggested that there may be value in aligning Operational Municipal Fire
Management Plans with other relevant planning processes. The planning process
could also be undertaken as a rolling plan which would allow for greater flexibility as
to how much planning is required to be undertaken.
MAV Position, Proposal 2.1.2a, paragraph 109: Operational Municipal
Fire Management planning does not necessarily need to be completed
annually. It would be appropriate to explore the timeframe for this process
further once the roles and responsibilities for municipal fire planning are
more clearly established.
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4.4 Consistency in Information Management and Data Systems
Access to common language and data, including mapping systems, would improve
coordination between agencies and across municipalities. Therefore, it seems a
logical step that Memoranda of Understanding (MoUs) are established between
agencies, municipalities and organisations with emergency management
responsibilities to facilitate information, data and equipment sharing.
While councils certainly agree with this proposal in principle, the cost associated with
this set of proposals, (2.6i, 2.6ii, 2.6a, 2.6b, and 2.6c) would prevent some
municipalities from implementing the recommended actions without significant
funding for infrastructure and resource requirements.
MAV Position, Proposal 2.6i, paragraph 123 : The proposal that
Memoranda of Understanding (MOUs) are established between agencies,
municipalities and organisations with emergency management
responsibilities to facilitate information, data and equipment sharing is
supported by the local government sector.
4.5 Training
Many councils have indicated that it is unrealistic to expect fire risk exercises to be
completed annually although a small number suggest this is feasible. Currently fire
related exercises are undertaken every couple of years amongst other exercises to
test preparedness, response and recovery for other identified risks. Councils
expressed it is important that this allows for a variety of incidents to be tested.
Annual exercises could be conducted on a regional basis allowing for many councils
to participate but resulting in less resource-intensive preparation work to be
undertaken by individual councils.
It is important that the frequency of exercises is related to the local risks and changes
to the local environment. In addition, if a municipality has a fire event or a number of
fire events, there should be arrangements in place to ensure they are not required to
undertake exercises in addition to the required fire management activities.
Another aspect of training that should be highlighted is the need to provide adequate
training opportunities for Municipal Fire Prevention Officers. This training should
incorporate strategic planning rather than prevention issues only.
MAV Position, Proposal 2.7i, paragraph 132: It should not be mandated
that local government participate in annual exercises to test preparedness,
response and recovery for fire risk. Either annual regional exercise should
be undertaken which all councils from the region may attend or councils
should continue to exercise preparedness, response and recovery for a
variety of risks on a regular basis.
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5. Continuous Improvement
5.1 Performance Measurement
While there is general support for the principle of continuous improvement contained
in Proposals 3.1a, 3.1b and 3.1c, the practical implementation of these measures
would determine local government’s support. It is not clear, for instance, what form
of timely performance monitoring is recommended.
5.2 Auditing
Auditing for both fire management and emergency management plans has long been
a problematic process for local government. As noted earlier, the arrangement
whereby a number of agencies and organisations contribute to the development of
the plan but only council is responsible for the plan when it is audited is
unsatisfactory. It is important to note that the current Municipal Emergency
Management Plan audit process administered by the Victorian State Emergency
Service is currently being reviewed.
The use of ISO 9000 [Quality Management] or ISO 14000 [Environmental
Management] for fire management planning auditing are both strongly opposed and
viewed as inappropriate for this purpose. If ISO accreditation were involved in this
process, it would ultimately be an added burden for those involved in fire
management planning. The benefit in adopting an ISO accredited standard is that it
would potentially achieve uniform standards across the state although this is not
seen to justify the additional cost.
It has been suggested by some councils that existing auditing processes are
ineffectual and should be removed. The current system encourages meeting
minimum standards and passing audits rather than best practice planning or a
continuous improvement approach. Audits currently do not look at the functionality of
a plan but whether it states the required information. A standard format for plans
may assist in improving the current situation.
There was concern, as highlighted earlier, that if many agencies contribute to the
plan, it should not be the coordinator, or leader, of the planning process that is
audited but rather the committee that contributed. This would ensure that no single
agency is responsible for the maintenance and improvement of the municipal plan,
rather it would be the responsibility of all who provide input to the plan.
General support was indicated for self-auditing (option 3.2.2d). It would seem logical
that this be undertaken by the organisation that leads the fire management planning
process. Questions remain about whether this would lead to a drop in standards or
whether current performances, good and bad, would remain unchanged. Some
support has also been expressed for Option 3.2.2c, that an independent audit team is
established to conduct audits.
MAV Position, section 3.2.2, paragraph 160: General support has been
shown for Option 3.2.2d whereby there would be a self-audit process at
municipal level. However, it is important that there remain some reporting
structure, potentially to the State Fire Management Policy Committee to
ensure that standards remain appropriate across the state.
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5.3 Recognising Good Practice
Section 3.3 Good Practice proposes a number of options for recognising good
practice in fire management planning. A number of councils have expressed support
for these proposals, however it should be noted that similar awards and recognition
are available through existing structures. Some councils have expressed concern
that state awards may only reward those councils that follow state policy rather than
innovative, best practice. It has also been suggested by a number of councils that
these awards are not highly valued and do not necessarily lead to better fire
management in practise.
Proposal 3.3d, that a Code of Practice could be developed by the State Fire
Management Policy committee, was strongly supported. It was felt that this is the key
starting point for integrated fire planning across Victoria. At the very least, it should
be a key activity of the State Fire Management Policy Committee if such a structure
is created.
MAV Position, Proposal 3.3d, paragraph 170: Local government
supports the development of a Code of Practice by the State Fire
Management Policy Committee as outlined in Proposal 3.3d. As there are
existing mechanisms to recognise good practice in fire planning,
Proposals 3.3a, b and c are not seen as useful measures in improving fire
management at regional or municipal levels.
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6. Conclusions
Local government has clear roles in fire management that are articulated through
legislation and state government policy and therefore welcomes the opportunity to
contribute to the development of a more integrated model of fire management
planning. Councils have generally indicated support for a strengthening of planning
at the state and regional levels to ensure consistency across municipal borders. This
holistic approach should be reflected in the project title as Integrated Fire
Management Planning rather than focussing solely on the municipal level.
Municipal councils clearly have a great interest in the fire management planning
arrangements at municipal level. As indicated in Section 3.6 of this submission,
Leadership at the Municipal Level, councils have a range of opinions about which
organisation is best suited to lead this planning process. Through a consideration of
the issues of consistency, expertise and capacity, the MAV has determined that this
process would be best led by the CFA and MFESB.
The five key recommendations made by the MAV in this submission relate to the
establishment of the following structural arrangements:
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A State Fire Management Policy Committee;
Regional level fire management planning integrated with regional emergency
management arrangements.
A standard format for Municipal Fire Management Plans that encourages
better planning rather than a template format.
A self-audit process for Municipal Fire Management Plans at the municipal
level incorporating a clear reporting structure to ensure that appropriate
standards are maintained.
A Victorian Code of Practice for Fire Management.
The MAV supports local government involvement in the ongoing development of
improved fire management planning arrangements in Victoria.
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