Submission on the Independent Review of the 2021 Wooroloo Bushfire

By Steve Gates

The Nature Reserves Preservation Group (NRPG) Inc. welcomes the opportunity to comment on this Inquiry, which we hope will build the case for changes to prescribed burning practices, based on scientific evidence, to minimise damage to our incredibly unique biodiverse ecosystems and wildlife, while addressing the fire risk and mitigation needs to protect our communities.

The NRPG references the Fire and Biodiversity Forum in June 2021 where respected and experienced Scientists presented their findings of the effects of fire on our biodiversity and options to reduce fuel load. The conclusions from the forum (see attached also) are as follows:

A. Abandon the target of prescribed burning 200,000 ha per year of DBCA managed south west forests and bush-lands as this target has no scientific basis, is contrary to indigenous practices, and destroys biodiversity.
B. Fire is the second most threatening process in the south west for threatened species.
C. Focus slow, cool, patchy prescribed burns in winter in understorey only in areas around infrastructure. Indigenous burning does not burn the tree canopy.
D. Never burn in spring, early summer or autumn.
E. Abandon aerial ignition of prescribed burns.
F. Retain long unburnt areas, as they are best for biodiversity protection and wildfire mitigation and are critical for many plant and animal species.
G. After 12 years of no fire, flammability of undergrowth declines.
H. Abandon the target of prescribed burning areas every 6 – 10 years. This frequency impacts on the known breeding cycles of forest dependent animals and plants.
I. Provide significantly increased capacity for rapid detection and at-source suppression of ignitions before they become wildfires.
J. Ensure critical habitats are protected from fire. For example peat lands, wetlands, and granite outcrops must never be burnt.
K. Protect long unburnt habitats with no prescribed burning. E.g. for Numbats and Honey Possums.
L. Long unburnt areas are needed for Honey Possums.

We make comment on the following Terms of Reference:

  1. Evaluate the first stage of the review of the Wooroloo Bushfire and undertake independent analysis across the range of focus areas examined, including response to the Wooroloo Bushfire, fuel management and processes for access into the fire affected areas.

    In regard to the response to the fire, we draw attention to conclusion I above, of the importance of Rapid detection and at-source suppression as a method to potentially reduce the need for prescribed burns and simultaneously reduce damage to the environment. (Ref 1 and 3 attached). With technologies such as real-time satellite monitoring or aerial drones, rapid detection is possible, and at relatively low cost. Investment in more water bombing or other technologies should be considered to address the rapid response options suggested.

    Regarding ‘fuel management’, we draw attention to conclusions F and G above, which pertain to the reduction of flammability. Frequent burns (less than 8-10 yrs) encourage tree and other regrowth of small diameters which burns rapidly and easily.

    Furthermore, Prof Kingsley Dixon confirms that the loss of leaf and other forest litter from frequent burns allows soil to dry more which increases flammability, and also encourages weed growth, (Ref attachment 2 & 3) often referred to as the ‘fire-weed cycle’ which also increases fire risk relative to healthy bushland.
  2. Examine the effectiveness of the use of heavy earthmoving equipment in the fire suppression effort including the systems, processes and capability that supports this.

    The “effectiveness” of such use should not be limited solely to its ability to control the fire. Whilst the use of such heavy earthmoving equipment is vital for effective suppression, the manner of its use is open to question. Frequently, post-fire examination reveals towering trees, decades, or even centuries old, lying on the fireground, having been pushed over by the machinery. In many instances, these habitat trees are toppled well away from the outer limits of the fire.

    Whilst the difficulties of operating such machinery in the face of a wildfire, often at night, are appreciated, more consideration should be given to the loss of the environmental and biodiversity values of such trees, once pushed over. Observers may sense that machinery operators, given free rein to carry out less-than-specific tasks, see such ‘felling’ as their most effective option. Detailed briefing of machinery operators by Incident Controller staff, may reduce the loss of such important trees.
  3. Examine the effectiveness of interagency coordination during the response and initial recovery phases of the incident.

    Coordination and communications between agencies at all phases of a fire can always be improved. A thorough examination of such elements is always warranted. Without such examination, improvements will not be made. Invariably, post-fire analyses reveal problems with coordination and communications between agencies and, whilst improvements have been made as a result of such analyses, more can be done.
  4. Consider the effectiveness of the impact assessment processes employed in informing early and timely recovery efforts and consider the effectiveness of the recovery function post response phase.

    This is a vital part of any fire scenario.
  5. Consider the extent, geographic range, method, effectiveness and duration of public warnings.

    No comment.
  6. Examine the effectiveness of the ‘Animal Welfare in Emergencies’ program as implemented by the Department of Primary Industries and Regional Development.

    Animal welfare should also address the massive killing of native animals which results from frequent prescribed burns (Ref 1 and 3 attached), and further increases the flammability of natural areas because of the loss of turnover of soil and leaf matter that native animals perform in their activities.
  7. Consider the meteorological aspects of the fire as examined by the Bureau of Meteorology.

    No comment.
  8. Provide a means for members of the public and other interested parties to make submissions to the Review and give these due regard in compiling its report.

    Provided herein.
  9. Consider any other matter that the Review Team identifies in its course of activities.

    No comment.

We urge the Independent Review to take on board the scientific expertise and knowledge of the references presented with this submission, and look forward to the outcome of the Review.


Steve Gates
President, Nature Reserves Preservation Group Inc.
[email protected]


  1. “What was said at the Fire and Biodiversity Forum?” The Urban Bushland Telegraph” Winter 2021, (Urban Bushland Council of WA)
  2. “Understanding the long-term impact of prescribed burning in mediterranean-climate biodiversity hotspots, with a focus on south-western Australia”, International Journal of Wildland Fire 2018, 27, 643–657
  3. “Future fire and a future for our biodiversity”, Kingsley Dixon, Curtin University and The University of Western Australia (Adapted from: Bradshaw et al. (2018) J of WildandsFire.


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