THE 2018 QUEENSLAND BUSHFIRES REVIEW - FEBRUARY 2019 AGFORCE SUBMISSION 1 - AGFORCE QUEENSLAND

 
THE 2018 QUEENSLAND BUSHFIRES REVIEW - FEBRUARY 2019 AGFORCE SUBMISSION 1 - AGFORCE QUEENSLAND
February 2019

AgForce Submission

The 2018 Queensland Bushfires Review.

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THE 2018 QUEENSLAND BUSHFIRES REVIEW - FEBRUARY 2019 AGFORCE SUBMISSION 1 - AGFORCE QUEENSLAND
Contents
 Executive Summary ....................................................................................................................................... 3
 1.     Introduction ........................................................................................................................................... 7
 2. The impact of severe fires on the agricultural landscape, agricultural production and industry in
 regional, rural and remote areas .................................................................................................................. 9
 3. Past and current practices of land and vegetation management by the agricultural sector and
 regional industries.......................................................................................................................................13
 4.     The science behind activities such as back burning, clearing and rehabilitation .............................19
 5.     The economic impact of vegetation and land management policies, regulations and restrictions 23
 6.     Factors that contribute to fire risk in regional, rural and remote areas ...........................................27
 7. The role the agricultural sector has in working with emergency services and forestry management
 officials in managing fire risk. .....................................................................................................................32
 8.     Appendices ..........................................................................................................................................35
 Appendix 1: Queensland Bushfires 25 Nov 2018 to 4 Dec 2018 - AgForce GIS Support Overview ..........35
 Appendix 2: Queensland Legislative Principles and Regulatory Impact Statements ...............................48
 References                                                                                                                                                  49

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Executive Summary

AgForce Queensland Farmers (AgForce) is the peak rural group representing beef, sheep & wool and grain
producers in Queensland. AgForce thanks the Office of the Inspector-General Emergency Management
with the Queensland Government for the opportunity to provide input into this important review. Meeting
with the Inspector-General Iain McKenzie and Karla Hartnett was well received, as has further planning and
conduct of on-site consultative meetings with AgForce members affected by wildfires in proximity of
Calliope, Blackdown Tablelands, Taroom and Prosperpine.

Lifting productivity whilst concurrently strengthening environmental and biodiversity outcomes driven by
good science and on-farm practice change is, in the view of AgForce, critical to the future of the industry,
the Australian landscape and regional and rural communities. One major concern with this review is that
focusing on the emergency response to the 2018 fires in Central Queensland is addressing a symptom of
the wildfires that occurred rather than the causal factors. Sustainable broadacre agriculture requires land
manager confidence in the effective use of fire within property management practices, as well as the
prevention of uncontrollable bushfires that threaten life, assets and severely hamper production security.

Governments have created a complex web of volatile regulation of fire and vegetation management with
many unintended consequences, including a move away from use of fire in proactive land management
and risk minimisation, as well as use of local knowledge and experience. The significant reduction of
Indigenous low-intensity fire regimes has created environmental conditions favourable to tree growth, with
the result over two centuries being considerable thickening of previously open woodlands and grasslands.

Proactive fire management will reduce the need for emergency response. Ultimately, to reduce fire risks
stakeholders need to examine and agree on what baseline ecological and biodiversity balances are sought
and the desired and sustainable balance of landscape, production and socio-economic outcomes. From this
the necessary voluntary land, vegetation and fire management actions and required regulations to achieve
them can be derived. This should be based on objective science and include additional research as needed

AgForce maintains that the cumulative effect of land and vegetation regulations have increased fire risks as
well as depressing the productive potential of rural properties. Dysfunctional fire management and
emergency response is a systemic issue within many bioregions and rural districts in Queensland.
Marginalisation of broadacre agriculture and property viability has resulted in lower numbers of people on
the land and less capacity to proactively minimise fuel loads and prevent the build-up of fire risks. Causal
factors are altered tree/grass balance, diminished rights of land managers, free-market conditions without
subsidy support and incrementally expropriated property value and income without compensation.

Through AgForce mapping analysis, Queensland’s protected areas were over-represented in recent wildfire
damage in late 2018, as were regulated remnant vegetation areas. This is thought to be due to inadequate
State Government investment in land maintenance and management, including fuel-reduction burning,
and the impacts of current vegetation management regulations and enforcement on the ability to manage
fuel loads and the landscape to a healthy balance. As a result, governments need to reassess land
management policies and review and reform land and vegetation management legislation and regulation.

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The Queensland government pointed to climate change as a contributing factor for the ferocity of the fires
and if this is the case, then there is an even stronger argument for governments to urgently review and
reform land and vegetation management regulation, to enable any increased risk of wildfires to be
managed effectively by landowners. Examining the functioning of volunteer Rural Fire Brigades and their
interface with State Land Managers and paid fire services is important, however AgForce recommends that
improved understanding of the causal factors leading up to catastrophic fire conditions is critical.

Collaboration and education are key tools to improve landscape and property level outcomes, including in
peri-urban areas where fire risk-averse management is increasing.

Note: The content of this review is similar to that submitted to Australian Government’s Parliamentary
Inquiry into the impact on the agricultural sector of vegetation and land management policies, regulations
and restrictions in January 2019. AgForce is eager to assist in the progression of a broader review process
for vegetation management in Queensland (and Australia) and proposes 32 recommendations aligning to
the “effectiveness of preparedness activity and response” mentioned in Terms of Reference of this
Queensland Review:

     The impact of severe fires on the agricultural landscape, agricultural production and
     industry in regional, rural and remote areas
1.      A commissioned review of the wildfire events in central Queensland in November and
        December 2018 is required to systematically investigate and assess the broader impacts of the
        wildfires that goes further than this current short-term review process (which also includes a separate
        Australian Government inquiry). As part of this review, focus needs to be placed on investigating:
          a. The management of privately owned and state-managed lands affected by fires in the lead up
                to November/December 2018.
          b. The ways in which understanding(s) of existing legislation influenced the actions (and/or
                inaction) of people involved in controlling fires.
          c. The damage resulting from fires, including financial, ecological and social metrics.
          d. The costs of effective repair and rehabilitation of fire affected lands.
          e. The losses in primary production as a result of these fires.
          f. The impacts on rural industries and communities as a result of fires, and finally.
          g. The effectiveness of Emergency Response and the Rural Fire Brigades involved.
2.      Improvements in legislation and regulation are needed to facilitate rapid and effective
        decision-making within rural communities (i.e. volunteer fire fighters) at times of wildfire occurrence.
3.      Investment in education and awareness building of the impacts severe fires have on landscapes and
        healthy ecosystems to stress the importance of wildfire risk mitigation.

     Past and current practices of land and vegetation management by the agricultural sector
     and regional industries

4.      The over-governance of landholders by three levels of government needs to be comprehensively
        reviewed, harmonised and made simpler and more consistent for all landholders. Policy instruments
        need to achieve mutually desired outcomes that support the health of rural economy and landscapes.

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5.      The agricultural sector, associated regional industries, governments, academia and all Queenslanders
        need to be aware of, learn from, understand and respect Indigenous fire management knowledge
        and practices.
6.      Fire as a landscape management tool for endemic native landscapes, public safety and reduced risk to
        infrastructure and biodiversity needs to be reinvigorated within federal, state and local government
        legislation and regulation.
7.      Education throughout the Australian community, agricultural sector and regional industries for
        increasing understanding of the benefits of fuel reduction burning and wildfire mitigation strategies.
8.      Education on content and how to implement the Queensland Government Regional Ecosystem Fire
        Guidelines and review their effectiveness.
9.      Education for the successful use of fire to minimise human and infrastructure risks as well as manage
        environmental outcomes, particularly sustainable vegetation management.
10.     Education for balancing agricultural land use with peri-urban landholders.
11.     Scheduling burns on state-controlled land using a ‘9am-5pm Monday to Friday’ calendar needs to
        cease to improve coordination with neighbours and minimise risk of ‘out-of-hours’ flareups and
        ensure necessary and adequate government staff involvement.

     The science behind activities such as back burning, clearing and rehabilitation
12.     A scientific forum needs to be assembled that objectively examines the evidence from Indigenous fire
        practice and its role in determining the previously balanced ecology and assess this against existing
        landscape, vegetation and fire management regimes across Queensland.
13.     Landholder (European) practices, experience and knowledge with land, vegetation and fire
        management needs to be incorporated in the above forum and the full range of desired outcomes for
        the landscape.
14.     A large-scale science summit is required, following the above science forum to progress a National
        Declaration on Natural Capital (e.g. Uluru Declaration1) through addressing the following scientific
        and policy dialogues:
           a. Natural Capital Resilience – preserving the value of our landscapes and vegetation
           b. Regenerative Agriculture – restoring topsoil, increasing biodiversity and building profits
           c. Drawing on Indigenous Knowledge – Long-term experience in managing landscapes
           d. Adapting to Climate Change – Making sense of fire and vegetation through variability
           e. Transition to Lower Energy Ag – Reduced emissions and increased sequestration
           f. Rural Economy – Budgets that support rural, regional and remote industries and people
           g. Regional Land Use Planning – Drawing above together in regional plans that work.
           h. How reduction in savannah burning is impacting on long term health and tree grass balance.
15.     Research needs to progress in the testing of improved vegetation management and fire guidelines for
        different bioregions in Queensland and across the nation in line with the synthesis of Indigenous and
        European vegetation and fire management knowledge.
16.     Research needs to be funded and conducted in the carbon flows and cycling within all bioregions, to
        gain an improved understanding of the true state of sequestration and emission balances.
17.     Action is needed in building Natural Capital and enabling Ecosystem Services Payments for
        broadening the income streams of landholders and incentivising management of healthy landscapes.

     The economic impact of vegetation and land management policies, regulations and
     restrictions

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18.   All levels of government should consider and properly address the financial impact of legislation and
      regulation of vegetation management on property value and primary production potential.
19.   Queensland needs a comprehensive review of Land Management legislation, which would include the
      management of fire on the land and incorporate consideration of primary production and income
      generation with ecosystem health and preservation and attention to the building and maintenance of
      Natural Capital.
20.   Abolish dollar or hectare-based protection area targets where they are not accompanied by increased
      budgets for maintenance of these values for a minimum of 50 years.
21.   Increase the current budget for State-Managed Public Lands to ensure adequate amounts for fire,
      pest and weed control.
22.   The Queensland government must protect fire-sensitive ecosystems and species in protected areas
      by allowing grazing in protected areas where the requisite values cannot be protected easily in
      another manner.
23.   The Queensland Government needs to repeal the VMA as a tree clearing Act, which penalises for
      minimum level bad practice rather than supporting landholders to implement best-practice.
24.   With HVA and IHVA provisions recently removed from the VMA, vegetation management legislation
      needs to allow landholders the continued affordable and practical possibility of developing regulated
      land for production of fodder and/or grain to mitigate against drought, incorporate fuel-reduction
      burning on rotational basis, reduce travel miles for fodder and finish stock for market.

  Factors that contribute to fire risk in regional, rural and remote areas
25.   Vegetation thinning regulations should accept the consequences of hot fires from thickened
      vegetation and allow acceptable rates of thinning as a fuel reduction action.
26.   Consistent and ongoing fuel reduction is needed within State and Forest Leases to reduce risks of
      uncontrolled wildfire (e.g. grazing in combination with fuel reduction burning).
27.   Improvements in legislation and regulation are needed to facilitate increased fuel-reduction burning
      suitable for all bio-regions in Queensland to mitigate against the risks of wildfire occurrence,
      particularly under changing climatic conditions.
28.   Increased investment by the Queensland Government in the management and preventative
      fuel-reduction burning of state lands.
29.   Investment in education and awareness building of the necessary role and function of fuel-reduction
      burning in the landscape for healthy ecosystems and wildfire risk mitigation.
30.   Special focus on the needs of peri-urban landholders in building their capacity to use fire and work
      with local Rural Fire Brigades to reduce fuel and improve the health of their native environment.

  The role the agricultural sector has in working with emergency services and forestry
  management officials in managing fire risk
31.   The Queensland Government need to review the VMA, Nature Conservation Act 1992 (NCA) and
      Environmental Protection Act 1994 (EPA) as a matter of urgency, including improving relations
      amongst stakeholders that manage Queensland landscapes and for dealing with an environment that
      is fire adapted and needs burning for its very health and succession.
32.   Agriculture seeks a partnership approach to meeting all recommendations listed.

For questions on this submission or for further contact in the review process, please feel free to contact Dr
Greg Leach on 0428 720 651 or email leachg@agforceqld.org.au.

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1. Introduction

AgForce thanks the Office of the Inspector-General Emergency Management with the Queensland
Government for the opportunity to provide input into this important review. We understand that the
Office of the Inspector-General Emergency Management seeks to assess the effectiveness of preparedness
activity and response to the major bushfires that occurred from late November to early December in 2018,
and to the associated heatwave by entities responsible for disaster management in Queensland.

The office meeting and further contact with the Inspector General Iain McKenzie and Kayla Hartnett have
been very well received by members involved in the large wildfires in central Queensland, as well as policy
and representative staff. Investigations into effectiveness of preparedness activity and response to these
major bushfires are timely and profoundly important for the future of Queensland landscapes, agriculture,
our social and cultural links with the land and our confidence in being able to keep members safe while
dealing with the impacts of climate change. The terms of reference and depth of this review necessarily
need to encompass the wider context of fire management and its longer-term realities.

AgForce has had high levels of active engagement with vegetation and land management policies,
regulations and restrictions that have been developed at federal, state and local government levels for
almost two decades. Our Vegetation Management Committee (VMC) is a highly engaged group of
landholders who are located across Queensland and are the main representatives for members in the
thirteen different bioregions. AgForce, in line with our overall recommendation, is eager to assist in the
progression of a broader review process for vegetation management in Queensland and Australia.

Broadacre agriculture in Queensland is affected by over 75 Acts and regulations, covering over 17,500
pages at a state level alone. This cumulative burden is exacerbated by the fact that overlapping regulations
usually occur at the federal, state and local government levels, usually with little direction or interaction of
each other. This adds to the overall drag on small business productivity and profitability and impinges on
proactive land management practices. The Productivity Commission in its review of the Regulation of
Australian Agriculture 1 recommended fundamental change in native vegetation and biodiversity
conservation regulation, including considering economic and social factors. The Commission’s 2004 report
into Native Vegetation 2 (written when there was a comparably small degree of vegetation regulation)
contained a detailed list of impacts to landholders of the regulation to native vegetation, including flow on
effects to regional communities.

These included:
   • Negative impacts on farm practices and returns
   • Restricting available land
   • Cost of management of vegetation
   • Impacts on property values
   • Changed investment patterns and financier attitudes
   • Compliance costs
   • Breakdown in landholders’ trust in dealing with government.

This need for streamlining and reducing the burden of regulation is a key reason for the strong AgForce
support for this review and our expectation is that significant reform will result.

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Lifting productivity whilst concurrently strengthening environmental and biodiversity
      outcomes driven by good science and on farm practice change is, in the view of
      AgForce, critical to the industry, Australian landscape and regional and rural
      communities.

The complex and regularly changing legislation controlling land and vegetation management in Queensland
has contributed to landholder frustration in not being able to effectively manage agricultural production
systems and balance income streams. In addition, ongoing thickening and increases in the extent of
vegetation across bioregions decreases available livestock feed resources. The effective integration of fire
as a management tool to assist with maintaining effective tree-grass balance has become more challenging
with the increases in regulatory control of vegetation as well as the changing nature of managing volunteer
Rural Fire Brigades and the higher levels of scrutiny and community expectations placed on land managers.

There are voluntary tools aside from further regulation that will help deliver policy outcomes for land and
vegetation management, and these should be prioritised.

The following sections expand on the general terms of reference for the Review.

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2. The impact of severe fires on the agricultural landscape, agricultural production and industry
   in regional, rural and remote areas

2.1. Were we Prepared for Severe Fires on Queensland Agriculture, Landscapes and Industry?

In short, No. AgForce argues that Government lands in Central Queensland were not in a prepared state
with inadequate fuel reduction burning, disrepair of access infrastructure and inadequate communication
and planning with neighbours and volunteers in local Rural Fire Brigades. Many AgForce members report
that the fires were only controllable and contained on private properties, on Category X land not regulated
by the Vegetation Management Act.

Fire conditions and behaviours somewhat similar to what has been experienced in southern Australia in
wildfire tragedies for decades are evidently possible also in Queensland. Is this due to climate change as
some promptly argued in Queensland Government, or is it a manifestation of a mixture of compounding
issues? One AgForce member asks whether, ‘There could be a certain amount of laissez–fare attitude in
Queensland compared to Victoria regarding forest fires?’ Landholders from central Queensland argue that
the impacts of wildfires in central Queensland in late November and early December 2018 were much
worse than they would ordinarily have been due to the inadequate management of state lands, which
includes limited management of the landscape with weed control and hazard reduction burning, poor
access track maintenance and the build-up of fuel-loads to extreme levels.

The VMA introduced 20 years ago has fundamentally changed the way in which farmers and the
government itself have approached the management of native trees across Queensland. Landholders have
had controls placed on their long-held rights to manage vegetation, enable better balance between grass
and trees and mitigate against the threat of wildfires, similar to what Indigenous Australians did just over
two centuries ago.

Calliope grazier, AgForce member and President of the Queensland Cattle Board, was heavily involved in
the control of wildfires on properties he owns and is totally frustrated with the wildfire outcomes. He said:

        “The fires ran uncontrolled within three State Forests in the valley and the Rural Fire Brigade
        volunteers and local producers were appalled that the lack of controlled burning over recent years
        had led to the landscape being a fire-bomb just waiting to be let off. The fire was uncontrollable in
        land regulated by the VMA, but when it reached Category X country on properties of landholders
        neighbouring the Park, we were able to stop it. In 1983 when we had similar fire conditions, we
        were able to access the State Forest lands on trafficable roads and the landscape and timber was
        managed – Now the access tracks are overgrown, we are not able to back-burn in the park and the
        weed load with lantana creates more fuel and severely limits our ability to fight the fire.”

As expanded below, the AgForce policy has always been that the ‘landscape needs to be managed.’
Landholders understand that the uncontrolled regrowth and restricted access for weed control brought
about by the VMA creates ‘feral landscapes’ that are a harbour for pest animals and invasive plants and can
become severe fire risks. The AgForce VMC, made up of members located across Queensland’s bioregions

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are adamant that the management of trees is a long-term process that requires a balanced approach to
maintaining a healthy landscape.

Northern Australian woodlands are adapted to frequent, low-intensity fires however very intense wildfires
can cause tree mortality (Grice and Slatter 1996 3). Members are deeply concerned that the recent wildfires
and loss of over 580,000ha is a tragic outcome that has decimated valuable timber resources and killed
millions of animals in doing so. Forty percent of the wildfires (234,300ha) affected Queensland Protected
Areas including national parks, forest reserves, state forests and conservation parks (Table 1). Within this
protected area estate wildfire area, 60 per cent was across the timber resources held within state forests
and timber reserves (140,000ha). Appendix 1 provides a detailed description of AgForce’s calculation of
areas affected by recent fires, which was communicated with members.

Table 1: Fire scar area across Queensland protected areas and extent of fires across regulated, remnant
and regrowth vegetation areas (Category B, C, R and A) compared to non-remnant, agricultural properties
(Category X). More details of fire scar area calculations in Appendix 1.
 Extent of Queensland bushfires from 25 November to 4 December 2018
 Total area of fire scarring                           584, 476ha          Per cent (%) of
                                                                           fire scar area
 34 Queensland protected areas affected                234, 300ha                  40
 (includes national parks, state forests, etc)
                             Regulated vegetation areas affected
 Category B remnant vegetation affected across 527,436ha                           90
 all land uses
 Regulated regrowth areas (Category C, R and A)         11,578ha                    2
 Category X non-remnant vegetation                      45,131ha                    8
 (mainly on agricultural properties)

The Queensland Government needs to consider that the VMA has fundamentally changed landholders’
ability to manage vegetation for reducing wildfire risk, removing weeds and achieving productive use of the
land and sustainable outcomes. AgForce believes that effective management of the landscape requires a
collaborative approach, with farmers, graziers, peri-urban landholders working alongside conservationists
and Government staff to preserve the Natural Capital that we all need. As this AgForce member says:

        “We need to be able to do this together – the landscape needs to be managed and the VMA is
        currently stopping us from jointly controlling wildfire risks and preventing the outbreak of weeds
        that create fire-storm conditions. The State lands need to be managed and the landholders need
        access to Category B and Category C High-Value Regrowth areas that the VMA keeps them out of.”

In addition to the vegetation issues, landholders have been deeply concerned about the impact on native
wildlife. This AgForce member mentioned, “When we were protecting buildings on the State lands we had a
closer look around, saw scorched animals and a nest of dead chicks fell out of a nearby tree. Lots of wildlife
perished in these hot fires.”

A grazing family near Eungella National Park near Nebo in central Queensland fought the wildfire for six
days and expressed distress in the loss of baby calves, burnt koalas in addition to extensive damage to

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40km of fencing. “We only gained some control when the fire approached the Peak Downs Highway and
wider fire breaks were constructed” 4.

For nine days in early November 2018, a Cape York grazier and her family fought a wildfire originating from
the neighbouring Springvale and Kings Plain Stations. Springvale was acquired by the Queensland
Government for conservation during 2016. “Insufficient fire management lines and no back-burn plans
resulted in Springvale being burnt out along with dead quolls, lizards and ground dwelling native animals” 5.
The grazing property lost 2,000ha of grazing land. Nearby Kings Plains Station, owned by a nature
conservation trust, lost $150,000 of carbon credits to 70,000ha lost due to wildfires.

Landholders and authorities alike have not had time to systematically investigate and assess the broader
impacts of the wildfires in central Queensland. This Queensland Government commissioned review of
these wildfire events should incorporate all impacts.

2.2. AgForce Member Concerns of Increasing WildFire Threat

     “Excessive fuel loads, that are left unburnt for 7 to 15 years (some of the regrowth in a National Park
     neighbour has not been burnt for over 30 years!) are a fire-bomb waiting to be let off – When these
     areas burn on a high-fire-risk day, they incinerate everything and the ecosystems are damaged
     immeasurably - animals, plants and soil organic matter are cooked and are very slow to rebuild.”

A recent fire at Wyaralong in southeast Queensland from an unknown source, created significant risk for
planted areas, so fire crews were called to assist. Even with 20 fire trucks in the district, crews from Victoria
and Tasmania were engaged, however these firefighters, with experience of wildfires in southern Australia,
were reluctant to venture into the high fuel loads. “There is no way we will go in there, we can only manage
it from the road. The fires that did take place in the surrounding lands were very hot with significant
regrowth.”

Example of grassed area that has not been managed for over 10 years, with no cattle grazing and no fuel
reduction burning. Before and after photographs – total annihilation. This is the result of Qld Government
policies and regulations locking up land.

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“Hot severe fires burn my high-quality timber trees – so I always try to reduce fuel load so severe
        fires will not carry when the conditions arise. I would recommend that we have the ability to easily
        conduct these fuel reduction burns. I am currently permitted to do this under the existing fire
        legislation and I hope this continues, but I would like to see others in the district having the
        confidence to do this. My neighbours are not game to burn.”

In 2017, Queensland Government imposed a $1Million fine on a landholder from Eidsvold in the North
Burnett region for clearing firebreaks ‘too wide’ at 40 metres 6. A previous wildfire in 2011 had burnt out
the property and caused $300,000 in damages. The landholder had requested clarification of firebreak
width from the government and only received advice two years after commencing the firebreaks.

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2.3. Recommendations

1. A commissioned review of the wildfire events in central Queensland in November and
   December 2018 is required to systematically investigate and assess the broader impacts of the
   wildfires that goes further than this current short-term review process (which also includes a
   separate Australian Government inquiry). As part of this review, focus needs to be placed on
   investigating:
       a. The management of privately owned and state-managed lands affected by fires in the lead
            up to November/December 2018.
       b. The ways in which understanding(s) of existing legislation influenced the actions (and/or
            inaction) of people involved in controlling fires.
       c. The damage resulting from fires, including financial, ecological and social metrics.
       d. The costs of effective repair and rehabilitation of fire affected lands.
       e. The losses in primary production as a result of these fires.
       f. The impacts on rural industries and communities as a result of fires, and finally.
       g. The effectiveness of Emergency Response and the Rural Fire Brigades involved.
2. Improvements in legislation and regulation are needed to facilitate rapid and effective
   decision-making within rural communities (i.e. volunteer fire fighters) at times of wildfire
   occurrence.
3. Investment in education and awareness building of the impacts severe fires have on landscapes and
   healthy ecosystems to stress the importance of wildfire risk mitigation.

3. Past and current practices of land and vegetation management by the agricultural sector and
   regional industries

3.1. AgForce Policy Context on Vegetation Management

AgForce has considered at depth the complex and vexed issues faced by land managers, administrators,
scientists, conservationists and other stakeholders within the broader community in managing vegetation
in Queensland. AgForce members are primary producers and while their interests are in the development
and profitability of a thriving broadacre agricultural industry in Queensland. They are mindful of the need
to balance agricultural production with the needs of the environment and society in order to achieve a
sustainable future for themselves, their local communities and all Australians.

In developing policies representing member interests, AgForce has conducted detailed engagements for
almost two decades with vast stakeholder networks who are also concerned about the management of
land and vegetation in Queensland. A re-emerging issue through the development of policy and the
ongoing changes of legislation and regulation has been a lack of clarity on the history of vegetation
management in Queensland and Australia and the agreed aims on what Australians want vegetation
management to deliver in the future.

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What are the agreed future roles and management approaches for land and vegetation, of all Australians?

The importance of this review is its potential to open up these important questions that AgForce and many
other stakeholders have been asking. Moreover, the open terms of reference of the inquiry provide the
chance to address some of the deeper questions of how agriculture has evolved in Queensland and across
Australia. This includes the impact that this has had on the landscapes across bioregions and what the
current agricultural industry can do to resolve issues such as wildfires, emissions, climate change, the need
to restore and maintain Natural Capital (with the commensurate concept of ecosystem services payments)
and providing food for larger human populations?

AgForce members understand and advocate that vegetation needs to be managed and have developed
clear policies on this. Primary producers know this through their direct experience of the impacts of what
happens if land is left unmanaged - “It becomes feral!” They know that the vegetation and ecosystems
spoken about by older landholders have changed and thickened under more recent management practices,
but they seek deeper answers and reasons for this. They know fire, grazing pressure and seasonal
variations influence regrowth habits. They also know that vegetation systems can take many years,
decades and centuries to respond to management actions that are implemented on the ground. Making
poor decisions now can take centuries to unwind.

AgForce seeks to openly examine the longer history of vegetation management in Queensland in order to
improve understandings of how ecosystems, trees, grasses, animals and humans have evolved through
pre-Indigenous, Indigenous and now European times and learn from this to inform decisions about how
vegetation needs to be managed and enjoyed. Critical to this is the role of policy instruments in achieving
mutually desired outcomes, such as incentives to support good land management, the investments in
education in improving practices and the role of regulation in preventing avoidable, undesirable outcomes.

3.2. Critical Transitions from Indigenous to European Agricultural and Vegetation Management Practices

Before examining past and current European land and vegetation management practices by agricultural
and regional industries in Queensland (and across Australia), we must first understand the ways in which
landscapes, vegetation and ecosystem communities have responded to climatic and human disturbance.
Australia’s prehistory (before humans) and history (including humans) indicate that Indigenous Australians
disrupted the previous balances of nature and extinguished many species, including megafauna (Flannery
2002) 7. Over a few millennia after the arrival of Indigenous communities to Australia, a new balance which
included human-induced fire was established. Indigenous Australians introduced the firestick, which
replaced a regime of infrequent high-intensity lightning fires, or megafires. They rearranged the vegetation
composition at a landscape level and terminated succession of many plants along with their associated
megafauna herbivores. Indigenous Australians maintained a newly established balance for more than
40,000 years, which included large environmental and climatic fluctuations (Jurskis 2016) 8.

The distribution, extent and condition of regional ecosystems that exist in Australia today are
fundamentally changed from vegetation communities that were found by European settlers when they
explored and ‘began’ agricultural production just over two centuries ago. Unbeknown to most European
settlers, Indigenous Australians had developed intricate systems of agriculture over tens of thousands of
years, including firestick farming of grasslands and open woodlands supporting grazing livestock as well as
harvesting of yams and grass seed for milling and baking and indeed storage of grains and produce (Pascoe
2018) 9. Indigenous Australians used firestick farming to disrupt and reorganise nature before making
burning the mainstay of their economy and the land management practices they employed.

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When explorers and settlers ‘discovered’ grazing and farming lands, they frequently mentioned ‘park-like’
landscapes (Gammage 2012) 10 and even Captain Cook in 1770 noticed that along Australia’s coastline the
trees had no ‘underwood’. Cook also reported smoke and numerous fires all up the Queensland coast
(Australian Government 2004) 11. Over the succeeding decades explorers frequently recorded more open
landscapes than we have today. For instance, in 1827, Peter Cunningham described landscapes of
Parramatta and Liverpool as lightly timbered and so clear of undergrowth that you could ride a gig in any
direction without hindrance. Thomas Mitchell also reported that people travelled freely across the
landscape and were able to see far ahead. He also recorded the interdependence of fire, grass, grazing
animals and man, with fire-adapted species being sustained by moderate to low intensity fires which
maintained nutrient cycling, healthy ancient trees and shrubs, herbs and grasses, bare patches and animals
with the ‘natural landscape’ having low levels of discontinuous fuels and no megafires (Jurskis 2016).

3.3. Management by Modern Agriculture Thickens Fire Adapted Ecosystems

Understanding the transition from Indigenous to European management of vegetation and regional
ecosystems and the immense impact that this has had is critical to advancing recommendations on
enduring practices for managing native vegetation under current and future agriculture in Australia. The
characteristics exhibited in 2019 by vegetation communities across different bioregions and regional
ecosystems were profoundly influenced by the management practices used for many tens of thousands of
years by Indigenous Australians.

The term ‘fire-stick’ was introduced by Edward Curr in the 1880s in his observations of Indigenous
Australians managing pastures through controlled burning. The slow expansion of the agricultural sector
and its associated regional industries following discovery of grazing and farming lands by commissioned
explorers such as Sturt, Mitchell, Flinders, Cunningham, Kennedy, Gregory, Leichhardt and many others,
ultimately saw Indigenous firestick farming cease (Jurskis 2016).

The conversion to European agricultural management systems has included some continuation of
low-intensity burning of some pastures and landscapes, but a widespread cumulative aversion to fire
prevails over much of the Australian landscape. Pascoe argues that horrific fire events such as Ash
Wednesday(s) in 1980 and 1983, and Black Saturday in Victoria in 2009 have shaped perceptions of the role
of fire within the Australian psyche to one of terror, rather than fire as a management tool.

Progression of a risk-based view of fire over recent decades has further exacerbated earlier perceptions of
settlers which had influenced them to reduce low intensity small-scale burning. So even from the beginning
of European settlement in Australia, reduced burning was changing the landscape. Thomas Mitchell
noticed changes to vegetation due to reduced burning in 1848:

        Where a man might gallop whole miles without impediment and see whole miles before him … the
        omission of the annual periodic burn by natives of the grass and young saplings has already
        produced in the open forest lands nearest to Sydney thick forests of young trees … Kangaroos are
        no longer to be seen there, the grass is choked by underwood; neither are there natives to burn the
        grass, nor is fire longer desirable among the fences of the settlers (Gott 2005) 12.

More than 170 years ago explorers and early settlers were evidencing impacts of settlers’ ‘risk-averse’
approach to fire, with the risks largely based on loss of infrastructure, feed reserves, stock and ultimately
human life. The breakup of land ownership and provision of surveyed land grants, with landholders

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separated by fences as well as differing management imperatives created significant barriers to
coordinated management of fire that were not present under Indigenous burning regimes.

The significant reduction of Indigenous low-intensity fires created environmental conditions favourable to
tree growth, with the result over two centuries being considerable thickening of previously open
woodlands and grasslands. The variation in timing and intensity of fires when compared with Indigenous
practices radically changed the nature of the country, so that what had been productive agricultural land
became scrub within decades (Pascoe 2018). Soil carbon isotype studies of trees versus grasses from the
Burdekin catchment in North Queensland demonstrated 64 per cent of sampled sites had thickened over
100 years 13. Central Queensland has also changed from grass to woody vegetation dominance over the last
100 years, since the introduction of European farming practices 14.

3.4. Agricultural Fire Management in Queensland

Historic fire management by European farmers across Queensland bioregions, including intergenerational
properties of many AgForce members, involved frequent targeted burning of pasture and woodlands. As
one member reflects:

        “When we started farming with dairying, clearing land and growing pasture grass and crops, we
        used to drop a match off a horse when we saw a bit of dry that would burn. The result of this low
        impact approach to fire management were cool to medium fires in a mosaic pattern. We tended to
        burn at the end of winter, so we have feed through the cold part of the year. Would burn after first
        good rain around August (Exhibition time) to remove rank grass and encourage green pick. Wiry old
        forest grass needs the rank material removed for cattle to get access to green pick and adequate
        nutrition.”
        “Landholders have learnt that effective burning needs to be coordinated with the most conducive
        conditions, when they arise – balance of soil moisture, temperature wind speed and direction,
        humidity and existing topography and fire infrastructure. Historic [European agricultural] burning
        was done with none of the existing fire services equipment, people or machinery - trucks,
        helicopters, dozers, etc. Agriculture in the past century has had more breakup of the landscape with
        small crops that served as firebreaks. Today, particularly in more populated areas, the changed land
        use from dairying and other agriculture and moves toward peri-urban land users who do not like
        fire and do not know how to manage it, creates a much different fire scenario with significantly
        reduced fuel reduction burning.”

The introduction of the Vegetation Management Act (VMA) in 1999 created a large barrier for people being
able to manage vegetation as they had previously, with greatly increased concern about fines and
compliance action. This concern is reflected in a member response:

    “We did not need to worry so much about the law – We could do what was needed. Now we cannot
    even control weeds without letting DNRME know when, where and how we are going to conduct the
    activities. If we need to spray crops for weeds we do not need to notify, but when we need to manage
    weeds in remnant vegetation with fire or other measures, we need to inform the Government of every
    step.”

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3.5. Changing Face of Rural Fire Brigades and Confidence in Using Fire as a Management Tool

Governments have unintentionally responded to fire disasters in perverse ways, with increased funding for
firefighting equipment and command and control communications systems, but at the expense of
education in the use of fire in sensible, preventative land management and the incorporation of local
knowledge and experience. Changes in the Rural Fire Brigade network and funding as well as legislative
control of fire 15 in Queensland has also caused varied outcomes in different districts. For instance, an
AgForce member and Fire Warden near Boonah suggests:

       “In 25 years, there has been a large change in fire services and equipment in south east
       Queensland. In 1994, Mt French had the only fire truck in the district (highly subsidised at $6,000)
       and other local rural fire brigades used private farmer/landholder equipment. From this period on
       however, there has been a steady increase in fire trucks and equipment due the increased concern
       of people coming into the district without prior experience of farmers burning and understanding
       that fuel loads need to be managed. What will happen in 20 years time? How much more
       equipment do we need? – We already have 11 fire stations and 20 trucks now in Boonah region
       alone, but is this solving the problem? The authorities need to talk to the landholders – After all. ‘He
       who owns the risk owns the fire’ It is the landholder’s responsibility – Authorities need to be
       educating the landholders and community people rather than just thinking that a fire truck will
       solve the issue.”

       “The culture that we have in Boonah now has changed where peri-urban landholders will have a
       small number of animals or none at all and they do not want to burn or slash to prevent wildfire.
       We are losing the plot as a rural community, with Fire Wardens and other fire staff required to
       handle an increasing number of calls, events and enquiries from people who have little
       understanding of rural land and risks associated with burning and not burning. In the past,
       neighbours used to burn together in many cases. Particularly where properties neighboured a
       National Park, there was not the difficulties that are being encountered today. In south east
       Queensland, the transition to peri-urban landholders is creating large issues with the poor
       coordination of burning practices and ideologies.”

Presently, only North Queensland uses fire consistently across wider landscapes as a regular management
tool. AgForce members within different regions report that the coordination of fire management amongst
and between neighbours has become less effective over recent years, with many citing issues such as:
    1. Decreased willingness of landholders to volunteer within Rural Fire Brigades.
    2. Reduced confidence in Rural Fire Brigades to provide support for managing and controlling fires.
    3. Increased centralisation of control of fire management volunteers from remote locations, at times
        by people without adequate context of local conditions and fire characteristics.
    4. Increased complexity of legislative controls linked with fire management, including multiple
        Queensland Acts (Vegetation Management Act 1999 (VMA), Nature Conservation Act 1992 (NCA),
        Fire and Emergency Services Act 1990 (FES)) leading to increased apprehension in using fire as a
        management tool.
    5. Limited awareness and understanding of recommended fire regimes, such as the Queensland
        Government Regional Ecosystem Fire Management Guidelines 16.
    6. The transition of land to the public estate (and subsequent removal of grazing from private land,
        leases including Forest Leases) has caused a large understory of combustible fuel to build up.

3.6. Three Levels of Government Over-Governing Vegetation Management

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Landholders in Queensland are in many cases subject to vegetation regulations administered by three
levels of government, each with their own peculiarities and questionable linkages between regulatory
instruments. In a recent review of the Environment Protection and Biodiversity Conservation Act 1999
(EPBC Act) AgForce members conveyed issues of poor landholder awareness of the Act and their
obligations as well as the complex interrelationship between federal, state and local government
legislation. Generally, AgForce members related their confusion about EPBC Act referral requirements and
the indecisive responses and recommendations they have encountered when engaging with Department of
Environment’s (DoE) staff about the EPBC Act. Several members were concerned about heavy handed
conduct in compliance actions that took place in 2016. Generally, the EPBC Act has been of limited concern
for landholders in Queensland and seen as too hard to understand, however there are large concerns
about the Australian Labor Party’s intention to include an agricultural trigger within the Act.

The Queensland Government administers two Acts that have major consequence for native vegetation
management, as well as other mechanisms controlling development projects. The VMA, despite its title,
was introduced to Queensland to stop broad scale tree clearing. The VMA has not been well received by
primary producers, nor has it been a useful tool to assist landholders to manage vegetation with the flow
on effects of managing soil, land and production. The VMA has been amended 38 times since introduction.
The lack of a bipartisan political approach to vegetation management has confused and frustrated
landholders and regional departmental staff to the marked detriment of good long-term land
management, biodiversity stability, trust and proactive relationships between landholders and the State,
political cohesion, and ultimately, sustainable primary production with environmental outcomes.

The Nature Conservation Act 1992 (NCA) has been less of a concern for landholders until 2014, when the
Queensland Government activated a Protected Plants mapping layer and regulatory provisions 17. The
Protected Plants mapping layer identified blue circular areas two kilometres in diameter around records in
the WildNet Database, a long-term dataset which amassed voluntary and Government recordings of ‘rare’
plants. Rare plants are “Endangered, Vulnerable or Near-Threatened” (EVNT) native species. The accuracy
of this dataset was highly questionable by landholders, but more so was the move by Queensland
Government to have landholders ‘prove’ that a protected plant was not within the blue circular area
through a prescribed ecological survey method, if new clearing to manage vegetation was proposed. The
confounding issue with these two Acts is that neither has precedence and while a landholder can sign up
protections under one Act, it does not mitigate against enforcement of the other Act.

The third layer of government controlling landholder’s management of vegetation are Local Government
Areas, largely aligned with the highly populated areas of the state. For landholders in the vicinity of South
East Queensland or along the coastal strip there are a range of differing, but complex and detailed
restrictions that have been enacted through the planning schemes and vegetation management codes of
most Local Governments. These codes protect biodiversity and landscape values of regional council areas.
For instance, an AgForce member close to Wivenhoe Dam, north west of Brisbane, claimed that:

    “I am now controlled by three levels of Government when I want to touch any tree on my freehold
    property. If I need to clear even a small area I have to apply to Somerset Regional Council and pay a
    sum of money, I have to consult with the State vegetation legislation and I also have to comply with the
    Federal EPBC Act. Is this over-governance?”

“Character vegetation” in the Sunshine Coast Regional Planning Scheme 2014 prevented another AgForce
member from clearing non-native radiata pine trees along a fenceline.

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3.7. Recommendations

 4. The over-governance of landholders by three levels of government needs to be
     comprehensively reviewed, harmonised and made much simpler and consistent for all
     landholders. Policy instruments need to achieve mutually desired outcomes.
 5. The agricultural sector, associated regional industries, Governments, academia and all
     Australians need to become aware of, learn from, understand and respect Indigenous fire
     management knowledge and practices.
 6. Fire as a landscape management tool for endemic native landscapes, public safety and
     reduced risk to infrastructure and biodiversity needs to be reinvigorated within federal, state
     and local government legislation and regulations.
 7. Education throughout the Australian community, agricultural sector and regional industries
     for increasing understanding of the benefits of fuel reduction burning and wildfire mitigation
     strategies.
 8. Education on content and how to implement the Queensland Government Regional
     Ecosystem Fire Guidelines and review their effectiveness.
 9. Education for the successful use of fire to minimise human life and infrastructure risk as well
     as manage environmental outcomes, particularly sustainable vegetation management.
 10. Education for balancing agricultural land use with peri-urban landholders.
 11. Scheduling burns on state controlled land using a ‘9am-5pm Monday to Friday’ calendar
     needs to cease to improve coordination with neighbours and minimise risk of ‘out-of-hours’
     flareups and ensure necessary and adequate government staff involvement.

4. The science behind activities such as back burning, clearing and rehabilitation

4.1. Past Disaster Responses, Contested Science and Political Capture

It has been argued by several authors that fire scientists long ago identified the basic physical parameters
that should guide prescribed burning to protect the Australian environment, society and economy.
However, theoretical ecologists have introduced confounding theories over recent decades that has misled
effective fire management practice.

    “There is a dichotomy in Australia between a pragmatic, scientific and socially responsible
    approach to fire management based on history, experience and research of soundly based
    hypotheses on the one hand, and a theoretical, green, academic approach on the other.
    Despite overwhelming evidence that prescribed burning maintains ecosystem health,
    resilience and biodiversity, as well as fire safety, green academics and bureaucrats still don’t
    ‘get it’.” (Jurskis 2016)

Jurskis (2016) further argues that three decades of wasteful research and misleading science has been
based on false assumptions such as; prescribed fires reset vegetation to ground level; ecosystems relatively

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unaffected by post-European management are close to natural, and; maintaining these ‘natural
ecosystems’ maximises biodiversity. This research has been driven by politically-motivated, disaster
response funding which has led to some books on fire ecology recommending that broad scale hazard
reduction is threatening biodiversity conservation and must therefore be avoided by land managers and
resisted at a political level (Organ 2003) 18. These competing views on the use of fire for vegetation
management are seriously misleading, with contrasting recent international research by Bliege Bird et.al.
2008 19 concluding that fire-stick farming by Indigenous Australians (or anthropogenic burning) increases
biodiversity and prevents habitat loss at the local scale.

The issue of competing science has been further exacerbated by government’s need for green political
support. Advocacy for increased fuel-reduction burning intervals by academics aligned with green
conservationists has resulted in reduced funding for operational fire management programs. Furthermore,
experienced land and fire managers underpinned by practical fire ecology science, along with volunteers
are now controlled through green political influence. As a consequence of this misleading science, fire
hazards continue to increase and megafires are occurring more frequently.

4.2. 100,000 Years BC, 1788 or 1989 - What is the Ideal Landscape that We are Trying to Achieve?

A fundamental issue with vegetation management in Queensland that AgForce members have long
lamented is the complete lack of clarity on what the ‘desired’ landscape, vegetation and regional
ecosystems should look like? What is the configuration, density and extent of vegetation that landholders
on their respective properties should be managing towards? Without a simple agreed baseline outcome,
planning is made more difficult in trying to comply with complex and highly prescriptive legislative and
regulatory requirements towards achieving a narrow range of potential outcomes.

When there is no obvious and communicated vision of what success looks like, landholders are justifiably
frustrated. The focus of the VMA on preventing clearing almost completely ignores what the ‘conservation
target’ or ‘desired ecosystem mix’ is. No recognition is given to invasive native and naturalised species in
Queensland legislation such as currant bush (Carissa ovata and C. lanceolata), mimosa bush (Acacia
farnesiana), bread fruit (Gardenia vilhelmii), Gutta percha (Excoecaria parvifolia) and several wattle species
(Acacia spp.). Such species were controlled by fire, both natural and due to Indigenous Australians’ actions
before land management practices changed with European settlement.

Given the fact that Australia has undergone considerable environmental change following the arrival of
Indigenous Australians, with about 40,000 years of management to create fire adapted ecosystems, and
then with greatly reduced fire and vegetation thickening with the arrival of Europeans, the ideal ecological
baseline is highly unclear. If we are managing for 1788 conditions, we need to make a collective decision
about this. If we are managing for pre-Indigenous Australia, well let’s decide what that was. Or if we are
managing for the 1990’s to scientific benchmarks of regional ecosystems collected in Queensland in the
1990s, then let all stakeholders agree on what the baseline looks like.

The Regional Vegetation Management Planning (RVMP) process implemented by Queensland Government
in the early 2000’s was a highly inclusive attempt by Queensland Government to establish agreement on
what the ideal or target composition, extent and density of regional ecosystems were within each of
Queensland’s thirteen bioregions. Landholders and conservationists were enthusiastic about the
development of the 24 baseline plans and codes that identified the ‘ideal’ or optimum outcomes for
managing vegetation and ecosystems on their properties and within the subcatchments and districts they
live within. This Baseline Planning approach would be best used on an Area Management basis, to support

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