Friends of Nillumbik Inc. (FoN) is a grassroots not-for-profit, community volunteer group. We have around 1000 supporters who live and work in the Shire of Nillumbik.  The purpose of our association is to support and promote the environmental and landscape values, neighbourhood character, orderly planning and good governance of the Shire of Nillumbik.

FoN supports the priority given to the protection of human life, in all Victorian planning schemes.

The four Strategic Priorities (page 12)

We agree with the four strategic priorities.

Operating Principles (page 13)

Principle 1:  Protection of human life. We agree.

Principle 2:  Balancing environmental protection with bushfire risk.  We partially agree – comments below.

Principle 3:  Shared responsibility.  We agree.

Principle 4: Reducing, managing and modifying fuels.  We partially agree – comments below.

Comment on Principle 2:  We question whether ‘balancing’ is appropriate in this context.  It suggests the environment and bushfire risk will always be in competition. The truth is, they must be made to work together.  Mitigation must operate to keep the environment both healthy and safer, rather than diminishing it. While much indigenous knowledge and practice has been lost, this dynamic appears to have operated for thousands of years in Australia.  Principle 2 should be re-phrased.  Maybe: “Integrating environment protection with bushfire mitigation”?

Comment on Principle 4:  We question what a “holistic approach” means when considering fuel reduction across a range of land-types with different characteristics. If environmental values are to be protected then land containing high value bushland habitat will be treated differently from grassland, for example.  What knowledge base will be used to identify sensitive land which should be managed differently in order that, “the shire’s unique flora and fauna are protected”?  Fuel reduction techniques must be tailored to suit the environmental sensitivity of the land.  A data base already exists in the ESO renewal completed by the previous council.  Principle 4 should include a reference to the need for well founded data identifying land of environmental significance.

  Objectives (page 14)

Comments:

Goal 1.3 and 1.4:  On roadsides and council reserves the fuel reduction technique chosen must be appropriate for the vegetation type.  Woody weeds and introduced grasses have a greater biomass than native grasses. Sensible fuel reduction treatment should work to favour native species.  Oversight by botanists will be needed.   We should encourage the planting of local grasses (e.g. themeda autralis, austrodanthonia linkii etc) which stay green through the Summer months and do not produce the fuel loads of the introduced species. This would contribute to longer term fire mitigation benefits and should be actioned, as a priority, on public land.

Goal 1.5:  Establishing an active indigenous burns program will be challenging due to the complete loss of local indigenous knowledge.  There will obviously need to be trial programs with the careful collection of observation data and assessment of results over the long term.

Private land burn-offs present enormous risk. Firestick and drip burning must be in the hands of the professionals. In addition to the risk of escaped and out of control burn-offs, haphazard burning can exacerbate soil erosion and decrease run-off water quality leading to more problems to be solved.  Haphazard and uninformed burning off can adversely affect both flora and fauna if performed incorrectly and at the wrong time of the year. Local expertise will best inform this strategy. For example, the data that the Bend of Isles Cooperative has accumulated over the 35 years of regular ecological burns is highly relevant.

Goal 1.7, 2.1, 2.2:  While exemptions 10/30 and 10/50 are state-legislated and unlikely to change, we question whether they’re evidence-based.  It seems that under extreme ‘Code Red’ conditions tree removal will make no difference, and with moderate conditions trees may help to keep the surrounds cool, catch embers and slowdown wind speed, apart from their amenity and habitat value.  The education suggested under 2.2 must include the significant environment data base mentioned in the Principle 4 comment above (see Goal 2.5)

Goal 2.5:  The extensive ESO review research undertaken under the previous council should be the basis of the education mentioned.

Goal 2.8:  The content framework and tools for households could include encouraging residents to adopt a safer property layout with well-placed firebreaks and dense wind shield plantings. Mitigation is not all about less. Driveways can be situated to contribute to an effective firebreak. Smooth barked eucalyptus trees can act as heat shields for a structure. Well-watered green zones can play a part.  Mineral earth abutting structures could be encouraged as a fire mitigation method.  Reliable water access and publication of this resource to local brigades should be encouraged.

The management of the different “zones” on a property for their potential to slow and diminish the impact of a fire is essential. Riparian zones will need different management to the ridge lines. Taking into account the challenging topography of our Shire is essential. A one size fits all is not a desirable approach and must be avoided. Fence to fence slashing or burning is not an appropriate plan.

Goal 4.1:  We suggest adding words to this goal. i.e. “Actively advocate to ensure legislation, policy and infrastructure investment meets the needs of the Nillumbik community, …..and biodiversity protection.”

Further comments on the draft:

In developing this Strategy, key directives and recommendations must be acceptable to the whole community. Council have an excellent opportunity to bring our community together during this period.

In a recent survey, an overwhelming majority of respondents stated that, “ the natural environment is a key reason that they chose to live here”.  Planning for Nillumbik’s bushfire preparedness can be achieved alongside the goal of caring for the land and its people with an eye to preserving what is desirable about the ‘Green Wedge Shire’, for future generations.