RE: Draft Flinders Chase Fire Management Plan, January 2003

The Conservation Council recognises the importance of fire management both as an ecological and political issue. We have been alarmed at the populist and knee-jerk responses in much of the public debate on bushfires over a number of years, and we are concerned to see that fire management is based on sound ecological principles. After much research and discussion among our member groups, the Conservation Council has developed a general policy on prescribed burning of native vegetation which represents the agreed position of a range of conservation groups in South Australia. The policy is attached for your information.

Our general policy position is that Conservation Council of South Australia (CCSA) will support the use of fire as an ecosystem management tool for parks in South Australia subject to a number of criteria and considerations being addressed in all fire planning processes. We have considered the proposals in the draft Flinders Chase Fire Management Plan for prescribed burning against our policy, and against our understandings of good ecological management, and we are opposed to proposals outlined in the Plan. Our opposition is focussed on the intention to deliberately burn in all eleven defined conservation zones for either the “maintenance of biodiversity” or hazard reduction. The reasons for opposing the Plan are as follows

Prescribed burning for hazard reduction:

The detrimental impacts of prescribed burning for hazard reduction are well known and are outlined in the National Parks and Wildlife submission to the Select Committee on Bushfire Protection and Suppression Measures (1992). Furthermore, the considerations on whether prescribed burning is appropriate or not are outlined in the final Report of the Select Committee on Bushfire Protection and Suppression Measures (1993). In both of these documents a precautionary approach to prescribed burning is encouraged and “must be considered in conjunction with other fire suppression and prevention activities” (Select Committee Recommendation 14). We do not believe that the proposals to prescribe burn within Flinders Chase and Ravine des Casoars reflect a precautionary approach, nor are the proposals considered in conjunction with the various other options that are available.

More specifically, the Plan does not provide detail of, nor delineate, the actual areas where burning is intended and it is difficult to determine what many of these burns are designed to protect. In one instance, where more precise detail is provided, it is stated that the intent is to burn native vegetation surrounding the new staff facilities at Rocky River. While this might reduce fire hazard around these buildings, the question has to be asked why these structures were built adjacent to native vegetation in the first place, especially when there are appropriate building sites on cleared land nearby. This is a stark example of the department’s failure to plan fire hazard reduction in conjunction with other fire prevention activities.

Outside the reserves, grazing farmland, blue gum/pine plantations, and tourist infrastructure are cited as areas requiring protection from wildfire. It is stated that “NPWSA have an obligation to undertake fire management works and activities to protect built assets, both private and public, buildings, agro forestry and farmlands” This point is not contested by CCSA but we do not accept that this ‘protection’ should be provided by ”patch burning” within the reserve system and it is difficult to understand how patch-burning hundreds to thousands of metres away from these assets can achieve any level of fire protection. CCSA also asks why no detail is provided on the efforts being made by neighbors to assist in the protection of their assets? Again, this is failing in the Draft Flinders Chase Fire Management Plan. It needs to account for other fire prevention activities. This is a critical omission because over the period 1976 to 2002, two fires escaped from the reserve into private land, whereas six fires entered the reserve system from outside (NPWS Fire Statistics).

In summary, on the basis of the information provided to CCSA, the proposal to burn for the protection of human life and built assets, is considered unacceptable. Experience suggests that the prescribed burns, especially those well away from the assets they intend to protect, are unlikely to achieve their intended aim of asset protection, or reduce the size of wildfires. Spotting will still occur and it is well known that these imposed burns will have undesirable impacts on the native vegetation and associated fauna. CCSA is also concerned that the proposed burns may escape to become wildfires. NPWSA has a poor record here eg. Gosse Lands, Rocky River, Mount Scott, Marble Hill, Messent etc. It would be much simpler and environmentally acceptable, to place hazard reduction emphasis at the boundary between the reserve/s and adjoining land, where the opportunity exists to limit the number of fires entering the reserve and where shared responsibilities can be better met.

Prescribed Burning for habitat management:

On page 33 it is stated “A range of post-fire ages…should be present in the study area. Where wildfires are not meeting this requirement, pro-active management of large even aged stands through the prescribed use of fire will be undertaken.” In Tables 1 to 5 (pp. 21 to 24) areas burnt within each age class are provided with a comment on whether that age class is “under represented”, “adequately represented” or “over represented”. If the area within each age class is less than 10% of the total then it is called “under represented” whereas areas greater than 30% are considered “over represented”. “Adequate” lies somewhere in between. The age classes themselves are divided up into 0 to 5 yrs., >5 – 15 yrs., >15 – 25 yrs., 25 – 40 yrs. >40 – 75 yrs, in what is called “generalised post-fire recovery stages for communities”. There are numerous problems with this concept.

Firstly, CCSA can see no ecological justification for dividing up age classes into so called “post-fire recovery stages.” It is common knowledge that each species of plant or animal has its own somewhat unique life cycle. Some plant species move into a post-fire system quite early, whereas others are not apparent for years. Some plants produce seed in the first few years after emerging, whereas others do not for up to a decade (see S.A. Fire Plant Response Register). Fecundity and survivability also varies tremendously between species of plant and animal, whereby some species can reach viable populations within months and others not for decades. There is simply no evidence to support the idea that the life cycles of both plant and animal species can be grouped into common post-fire time capsules.

Secondly, the age classes are also statistically misleading because the time interval within each class is different. While the 0 to 5 year class has a 5 year post-fire period, subsequent age classes have post-fire periods of 10, 15 and 35 years respectively. By designing age classes this way, the magnitude of younger age classes are understated whereas older age classes are overstated.

As previously discussed, to smooth out the supposed peaks in age classes, patch burning is proposed throughout the National Park and Wilderness Area, but, as with the proposed hazard reduction burns, there are no specific areas delineated. It is claimed that these burns will “create a mosaic of burnt areas and age classes”, provide “refuge areas” and overall “reduce fire frequency”. To support this action, the Plan cites the work of Keith et. al. (2002) but does not provide any more information on the source. It is therefore not possible to check the relevance of this reference, the interpretation of it, nor how it relates to the actions proposed. If it is valid to consider patchiness as important within this system then one needs to begin with an understanding of the extent of existing patchiness and determine whether this in itself is sufficient. As can be seen, the extent of patchiness is already quite significant (see wildfires in 1986, 1990,1991. Map 7).

CCSA is concerned the draft plan has only cited one scientific study on an incredibly complex issue. We believe a greater justification for patchiness must be presented before we can accept its validity.

It is evident from the fire history records that there have been numerous wildfires covering extensive areas in both reserves and that any attempt to deliberately increase this frequency with burns of lower intensity, especially in the spring, will lead to a decline, not a maintenance or increase in biodiversity. It is well known that frequent, low intensity burns in winter or spring, cannot sustain biodiversity (see Choate 1999). The plan states “prescribed fires should aim to reflect the seasonality, intensity and variety found in wildfires”. The department needs to demonstrate scientifically that such a condition can be met, especially without burning during hot periods (summer). In addition if the deliberately burnt areas don’t get out of control and become wildfires, then they will be comparatively small and therefore prone to excessive grazing (Choate op. cit.).

Costs associated with prescribed burning:

It is unclear what costs are expected and whether a cost benefit analysis has been undertaken. To do prescribed burning safely and effectively, a considerable commitment of time and resources are required. In Victoria, for example, all prescribed burns are treated as wildfire situations and funds allocated accordingly. Will the same level of resources be allocated to the Flinders Chase and Ravine des Casoars Fire Management Plan? If extra resources are available then it may be worth considering whether this money will be better spent on goat, pig and koala control in these reserves.

We know this will have a positive impact on the natural ecology of Flinders Chase and Ravine des Casoars. The Biodiversity Plan, 2001, sets goat, pig and Koala control along with rehabilitation and revegetation works as priorities, not burning, for the protection of biodiversity.

It is acknowledged that the draft document briefly mentions post-fire grazing, but there are no guarantees provided within the Plan that pre and post fire monitoring will occur, nor whether any action will be taken when grazing becomes excessive.

Compliance with Flinders Chase and Ravine des Casoars Management Plan:

The current Management Plan for Flinders Chase N.P., Kelly Hill C.P., Ravine des Casoars Wilderness Protection Area and Cape Bouguer Wilderness protection Area states:

“The plan does not prescribe the use of fire as a tool for the management of ecosystems in the park, unless research indicates that there will be substantial benefits to ecosystems.” (page 67).

No research to date indicates that any substantial benefit will be gained from the prescribed burning proposed. CCSA strongly believes there is inadequate research to indicate that any substantial benefit in ecosystem management will be gained from the proposed burning regime.

The proposals to burn are also at variance with the Wilderness Code of Management. As this issue is discussed in some detail in a submission from the Wilderness Society, CCSA will add its support for the concerns expressed.

Summary and Recommendations:

If the proposal to prescribe burn within Flinders Chase and Ravine des Casoars goes ahead then there will be serious repercussions. Not only will this be a sorry day for the conservation of biodiversity within both a National Park and Wilderness Protection area, but a precedent will be set which will make it easier to burn other reserved areas for inappropriate reasons. The CCSA will support prescribed burning when it can be demonstrated that there are sound reasons for doing so. However, it does not support prescribed burning that will clearly have a negative impact on natural values and achieve little, if anything in the reduction of fire hazard. Overall, CCSA recommends that:

· no deliberate burning is carried out within Flinders Chase National Park or Ravine des Casoars Wilderness Protection Area until it can be clearly and objectively demonstrated that the proposed burns will achieve acceptable outcomes.

· the Department for Environment and Heritage establishes an expert fire ecology group, made up of scientists from within and outside of DEH, that is required to look at and advise on all burning proposals before they are submitted to the Native Vegetation Council for approval.

· this group, as its first task, be required to develop a scientifically acceptable and transparent system for assessing prescribed burning applications, that gives fair recognition to environmental values.

· CCSA is given the opportunity to comment on all proposals to carry out prescribed burning, and that this occurs before applications are submitted to the Native Vegetation Council.

Please find attached a copy of the CCSA Policy on prescribed burning. . We lookforward to working with your Department to protecting the unique biodiversity of Flinders Chase.

Yours sincerely

Jasemin Rose

President

Conservation Council of South Australia

120 Wakefield St.

ADELAIDE 5000

References:

Best L & Choate J eds. (1992) A Submission to the Select Committee on Bushfire Protection and Suppression Measures. Parliament of South Australia, House of Assembly. Submitted by Biological Conservation Branch, National Parks and Wildlife Service.

Choate J. (1999) Planned Burning and the Management of Biodiversity: A decision support system. Unpublished

Report of the Select Committee on Bushfire Protection and Suppression Measures (1993) House of Assembly, Parliament of South Australia.

Cc Minister John Hill MP

Mr Greg Leahman

Mr Allan Holmes