On 14 January 2020 the Andrews government announced an independent inquiry into the 2019-2020 Victorian fire season would be conducted by the Inspector-General for Emergency Management (IGEM).

Through this Inquiry, IGEM will ‘examine Victoria’s preparedness for the fire season, response to fires in large parts of Victoria’s North East, Gippsland, and Alpine regions, and will review relief and recovery efforts’.

There is still time to make a submission to this process.

How to make a submission

Submissions need to be sent by the end of April.

There are two phases. The current phase covers ‘Community and sector preparedness for and response to the 2019-20 summer season’.

It has a series of ‘Terms of Reference’, or TORs. You can respond to which of the TORs that are relevant to you.

Individuals and organisations are invited to provide submissions, addressing the Inquiry’s Terms of Reference, through:

Inspector-General for Emergency Management
GPO Box 4356
Melbourne VIC 3000


Ideas on what to include in your submission

There is a submission guide from the Victorian National Parks Association here, and their main points are also provided below. You can cut and paste which of these you agree with and send to the contact details above.


Friends of the Earth also has some suggested points to make in a submission:

  • We urge the state government to increase funding for FFMV firefighters, including remote area firefighters (rappel crews) and air capacity for fighting fires
  • The government should provide annual funding to purchase firefighting aircraft to increase our fire fighting capacity and reduce the need to contract aircraft from interstate or overseas.
  • In addition to funding additional FFMV remote area teams we propose a new volunteer remote area fire force be established, similar to the Remote Area Fire Teams (RAFT) model in NSW, which could be structured to offer opportunities for younger and urban based people to join fire fighting efforts
  • ‘Salvage logging’ compounds the impacts of both fire and logging, and subjects fire-affected forests to mechanical disturbance during the critical recovery stage of the vegetation and should not be allowed in fire impacted regions
  • We urge this investigation to listen to the science relating to the relative values of fuel reduction burning and resist simplistic ‘more burning will solve the fire problem’ analysis which is being promoted in many mainstream and social media outlets
  • We oppose a return to a hectare target for fuel reduction burning and support the retention of the “targeted risk reduction” approach. Hectare targets will only cover public land. A considerable portion of fire risk in Victoria comes from the remaining two thirds of the land mass, which is held privately. Focusing on hectare targets on public land ignores the real fire risk that is associated with private land
  • Where fuel reduction treatments are used, we would recommend that smaller areas are burnt. We also suggest that the IGEM consider the proposal to establish local volunteer GreenFire groups to work with land managers on fuel reduction and fuel load management, which might also involve the use of non fire techniques
  • We encourage continued state government support for Cultural burning programs
  • In considering future fire threat, the IGEM must consider the contribution of native forest logging to forest flammability
  • It should specifically rule out salvage logging of burnt areas because of the ecological impacts of such activity
  • There are specific ecological values in snow gum and alpine ash forests that need to be considered before any fuel reduction burning is introduced into these forest communities. Some vegetation communities, such as rainforest should not be burnt, and buffer and ecotone areas should also be protected from burning
  • The Office of the Conservation Regulator has been undertaking an investigation into claims about excessive road clearing in East Gippsland after last summer’s fires. We urge the IGEM to consider any recommendations that come from the OCR report when it is completed
  • The state government should take a leadership role to educate the Victorian community about the fact that climate change will make fire seasons longer and more destructive
  • To help reduce the problem of climate change making fire seasons longer and more intense, the Victorian government must to continue to reduce carbon emissions in line with the recommendations of mainstream climate science


VNPA form submission

Climate change and fire

Long-term climate changes combined with short term weather changes are critical drivers of fire. As the climate warms, the frequency of severe fire danger days increases. A warming climate exacerbates the wildfire risks already posed by legacy issues such as inappropriate planned burning regimes, logging and arson.

To address IGEM terms of reference: ‘Consider all challenges and implications for bushfire preparedness arising from increasingly longer and more severe bushfire seasons as a result of climate change’ and ‘State evacuation planning and preparedness processes/practices and their effectiveness with an emphasis on remote/isolated communities and Victorian peak holiday season locations’ you may like to include, in your own words, something like:

  • We need to continue to reduce carbon emissions the cause of climate change. But also under increasingly longer and more severe bushfire seasons there is an urgent need for comprehensive, strategic emergency evacuation plans and stronger wildfire preparedness, including support for private bushfire shelters, better planning regulations and other means of protection for citizens living in high bushfire risk areas.

Protecting key ecological assets and unburnt refuges

After a wildfire there will often be patches of unburnt vegetation within the burn area that are of critical importance for the recovery of flora and fauna. Unfortunately there are threats to this recovery process from ‘burning out’, ‘salvage logging’ and introduced weeds and predators.

To address ‘In considering effectiveness of Victoria’s operational response to the 2019-20 fire season, IGEM should particularly consider: planning and response mechanisms to protect biodiversity threatened by bushfire’ you may like to include something like:

  • Islands of unburnt vegetation within burn areas must be protected from ‘burning out’ by fire crews, whenever possible. The burning of these natural refuge areas increases the ecological impacts of wildfire and inhibits the recovery of plants and wildlife.
  • ‘Salvage logging’ compounds the impacts of both fire and logging, and subjects fire-affected forests to mechanical disturbance during the critical recovery stage of the vegetation and should not be allowed in fire impacted regions. In addition, there needs to be much clearer regulation and assessment of hazardous tree removal to avoid the wholesale roadside clearing that happened in this fire season.

Rapid response and aerial firefighting

The capacity for aircraft to get quickly to the point of ignition of a wildfire is paramount for the protection of both the community and of our natural heritage. Victoria currently has a fleet of 50 aircraft – but it should be expanded and strategically employed across the state. Federal and state funding should be significantly increased, allowing effective aerial control of ignition points in remote areas of the state.

To address IGEM terms of reference ‘Consideration of the adequacy of existing administrative and funding mechanisms in place at a state level to support the operational response efforts’ and ‘In considering the timeliness and effectiveness of activation of Commonwealth assistance, and Commonwealth resource availability’  you may like to include something like:

  • There is an urgent need for increased capacity for control of fire at the point of ignition. We need a radical increase of secure state and federal funding to support the operational costs of fighting wildfires before they become uncontrollable in both remote and populated areas.

Strategic approach to fuel reduction and planned burning

Between 2003-04 and 2016-17 the Snowy district in East Gippsland has had more planned burning than any other district in Victoria. Planned burns can be ineffective in reducing wildfire risk when they fail to reduce risk on days of severe fire danger. Planned burns can be counterproductive at reducing risk whenever young post-fire regrowth is more flammable than long-unburnt forests – a situation that can last for decades. 

To address IGEM terms reference ‘Review of all opportunities and approaches to bushfire preparedness, including different methods of fuel and land management (for example ‘cool burning’, mechanical slashing, integrated forest management, traditional fire approaches) to protect life and property as well as ecological and cultural values’ you may like to include something like:

  • Planned burns and other fuel reduction processes (such as slashing) should be directed to where they are most effective: close to assets such as towns in need of protection.
  • To reduce the flammability of the landscape, Victoria needs to set targets to protect and promote the growth of older vegetation in those forest types where older growth is historically less flammable than younger post-fire growth.
  • Broadscale planned burning can reduce the abundance of critical wildlife habitat features, such as tree hollows and hollows in logs. A strategically planned burning program that minimizes ineffective and counterproductive burns is also critical for biodiversity protection.
  • Victoria needs to improve pre and post-fire monitoring of flora and fauna, and pre and post-fire monitoring of fuel loads. Favourable ecological and flammability outcomes should be incorporated into risk management.