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Most of Australia’s ecosystems, especially forest ecosystems, have evolved with a regime of occasional large-scale intense fire. Since European occupation fire frequencies have increased dramatically, as shown by the paleobotanical record, threatening many floral and faunal species and communities. The giant forest trees that existed at the start of European settlement had not seen fire for centuries.

European occupiers used fire to clear land for settlement and agriculture and to provide ‘green-pick’ for stock. The northern hemisphere practice of regular burning became entrenched and was reinforced when the concept of prescribed burning in forests was introduced from North America by the Victorian Forest Commission in the early twentieth century.

As can be seen from the rapid regeneration of areas burnt in the 2002-2003 Alpine Fires and the Grampians and Brisbane Ranges Fires, our indigenous vegetation is resilient to occasional large-scale relatively intense fire, as it has evolved with such a fire regime. However, our indigenous vegetation is not resilient to high frequency fire, which it has NOT evolved with.

The FFG Act lists two Threatening Processes concerning prescribed burning:
1) “High frequency fire resulting in disruption of life cycle processes in plants and animals and loss of vegetation structure and composition

2) “Inappropriate fire regimes causing disruption to sustainable ecosystem processes and resultant loss of biodiversity

Frequent and/or regular burning has degraded or altered many areas of indigenous vegetation, reducing biodiversity, creating a more fire prone vegetation and allowing pest plant and animal invasion. Although invasive species can also invade areas burnt by unplanned fires (bushfires), there is greater likelihood of invasion from prescribed burning. Many serious weed species (such as boneseed) benefit and easily dominate an area under a regime of regular frequent burning.

Prescribed burning is designed to temporarily or permanently remove the shrub layer and understorey vegetation, which exposes native small mammals to predation from pest animals which can easily move through the denuded or sparser vegetation of the prescribed burnt areas. Native animal populations have been shown to recover from occasional large bushfires. However, regular burning prevents the understorey from attaining the density required for full protection from predatory pest animals.

Have proper scientific flora and fauna surveys been carried out for each burn?

There should be no burning within the Great Otway National Park until the park Management Plan is completed.

It is disappointing that the log and burn policy of the old Forests Commission is still entrenched in the DSE bureaucracy.

At least the DSE now admits that prescribed burning does not stop fires, but it still claims that fire hazard can be reduced by burning, despite little or no scientific evidence to support this claim this. The fact that prescribed burning actually makes certain vegetation types more fire prone demonstrates the opposite, that in fact prescribed burning INCREASES fire hazard.

Prescribed burning contributes considerably to global warming by sending copious amounts of a range of serious greenhouse gases into the atmosphere.

Otways Fire Operations Plan 08/09, 10/11

(Tall) Wet Forest
There should be absolutely NO deliberate burning within areas containing (Tall) Wet Forest.

(Tall) Wet forest is naturally resistant to fire due to its dampness, even in the middle of a 40o plus heatwave in the middle of summer. Burning the understorey will only dry out wet forest and make it more fire prone. Wet Forest also often surrounds or is adjacent to Cool Temperate Rainforest and provides wind, light and moisture buffering for the CT Rainforest. Within the (Tall) Wet Forest EVC there is also often the floristic community of Mixed Wet Forest/CT Rainforest, which is a transitional rainforest.

The massive burns OS2, 3, 4, 5 and 6 all contain significant areas of Wet Forest and pockets of Cool Temperate Rainforest and should be abandoned.

The under the previous Otway Forest Management Plan fire was excluded from Wet Forest.

Shrubby Wet Forest

There should also be NO deliberate burning within areas containing Shrubby Wet Forest, which is a type of Wet Forest.

The massive burns OS2, 3, 4, 5 and 6 all contain significant areas of Shrubby Wet Forest and should be abandoned.

Shrubby Wet Forest also often surrounds or is adjacent to Cool Temperate Rainforest.

Wet Heathland and Damp Heath Scrub

There should be NO deliberate burning within Wet Heathland and Damp Heath Scrub because of the impact on flora species. Damp Scrub Heath is a relatively uncommon EVC in the Otway region. Burns G03, 236/06 and P08-05.06 should abandoned.

Heathy Woodland

196/02 to 196/07 should be abandoned as these areas have been heavily burnt in recent years and cannot tolerate any further burning. 196/03 was burnt only two years ago ! !

If burnt in Autumn as normal, Silver Banksia flowering will be interrupted and genetic diversity of the species in the area will be affected.

Previous burning in this area has contributed to local loss of the New Holland Mouse.

196/05-07 are incorrectly listed as freehold and no tree cover. They are Heathy Woodland and part of the Anglesea Heath National Estate. Anglesea River is incorrectly labeled as “Marshall Creek”.

Water Catchments

The burns planned within Geelong’s water catchment will result in reduced water quality from ash and sediment entering the catchment dams and will dry out the catchment by removing the understorey allowing greatly increased soil evaporation. In subsequent years understorey regrowth will use up valuable water. The proposed burns are within wet (tall & shrubby) and damp forest that already has an inherent fire protection due to the moisture retentive understorey. A good quality catchment will be unnecessarily compromised. The massive burn OS609/10 must be abandoned.

Tourism Impacts

One of the huge burns (OS2) contains significant tourist facilities including walking tracks and Upper and Lower Kalimna falls. Such a burn will impact on tourism. Likewise burn 246/03 & 04 contain waterfalls including the Cora Lyn falls and will be affected.

Little Asset Protection despite claim

Despite the claim that the DSE is planning to burn for mainly built asset protection the Operations Plan shows that most of the burning is large-scale burning well away from built assets. The plan appears to still be using the old FMZ classifications inconsistent with the new Code of Practice. Burning in the listed FMZ 3 and FMZ2 areas should be abandoned as they are not for asset protection and are ecologically destructive.

Burn Aggregation

There appears to be a deliberate attempt to aggregate burn areas to create very large recently burnt areas. Burn 268/02 which is excessively large in itself, is adjacent to the ecologically destructive Coalmine Creek burn of about 2 years ago. The practice of burn area aggregation should not be allowed.

EVC assignments

The Plan should list all of the main EVC’s within the burn area, not just one.


We wish to meet with officers of your department to hear your response to our submission and to discuss the draft fire ops plan.

PO BOX 192, APOLLO BAY, 3233


  1.   Laurence Gaffney Says:

    Read your FOP Plan Submission with Interest.
    Many of your concerns are similar to those of the Friends of Hoddles Creek. Happy to send you a copy of our Submission.
    My reason for contacting you is discuss our concern about the lack of engagement @ accountability of the DSE in relation to the provision of the rationale/design of these prescribed burns particularly in Ecological Fire Management Zones. Basically the DSE are refusing to provide any detail. Hence it is very difficult to effect any change. I am thinking some sort of Alliance betwwen like minded groups may be the way forward. This may enable a high level meeting of some sort within the DSE or Govt. Any advice you can provide on ways to get traction on this issue would be appreciated.

    Laurence Gaffney
    FOHC,Prescribed Burning & Fire Ecology Spokesperson
    PH:- 9728 2992

  2.   Laurence Gaffney Says:

    A Case Study of the 2012 Planned Burn GB0003 in the Hansen Creek Road Area of Hoddles Creek has been undertaken and is now available at the Friends of Hoddles Creek Website.
    The case study revealed the following:-
    • That the Burn site was not selected in accordance with best practice for Zone 3 Ecological Burns.
    • That the Land Management Objective provided by the DSE for this Burn was technically/scientifically impossible. (i.e. to bring fire age class distribution closer to the idealised distribution identified through fire ecology study)
    • Routine Planning Assessments as is required by DSE Guidelines were not undertaken. (e.g. Life stage Assessment for Burn Planning)
    • That ecological assessments for the burn were based on Vegetative Growth Stage Data which the DSE knew to be incorrect.
    • That the relatively recent logging history of the Burn Area was ignored.
    • That the Annual Yarra Target for the burning of Shrubby Foothills Forest (EVC 45) is being exceeded by approximately three times.
    • That the DSE is burning Forest Habitat within a Conservation Reserve with age classes that are unrepresented elsewhere within the Reserve or the Yarra Land Management Unit. (i.e. A major Environmental Conservation Issue)
    • That significant environmental damage was caused by the bulldozing of a control line that was unnecessary in the circumstances.
    • That the Key Fire Response Species (KFRS)considered by the DSE for this burn were inappropriate for the Fire Cycle Stage of the Burn Area.
    • That an attempt to exclude the Riparian Area (EVC 17) from the Burn for ecological purposes was only partially successful.
    • That no Pre Burn Overall Fuel Hazard Assessments were made hence it will not be possible to accurately measure the outcome of the Burn in relation to reduction of Overall Fuel Hazard.
    • That pre burn clearing around the bases of older habitat tress with hollows, for protection from the planned burn, was very limited in scale and mostly unsuccessful, resulting in disproportionate numbers of these trees being destroyed by the Burn.
    • That Control Line Rehabilitation program comprised minor erosion control works only.
    • That the approved Burn Lighting Pattern could not by design produce a mosaic pattern. (Note:- This was an objective of the Burn).

    The unprofessionalism of the DSE uncovered by the FOHC Case Study for Burn GB0003 is of major concern as the protection of Life & Property, and Ecosystems are at stake. The Friends of Hoddles Creek expect a planned burn decision making process/framework that is transparent and based on the best science available.

    Laurence Gaffney
    Secretary, Friends of Hoddles Creek

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