Bega Valley Independent Review (Keelty Inquiry 2018)

Tathra during the recovery phase
Tathra during the recovery phase

In the interest of promoting an open and honest debate, the VFFA has decided to publish our submission. We hope that other groups will do the same.

The VFFA is somewhat disappointed in the way that this inquiry has been handled as follows:

  1. The timeframes for groups to make submissions was very short and rushed
  2. The information regarding the review was not actively promoted by the NSW State Government, and
  3. What is happening with the referral of this fire to the Coroner?

One could be excused for thinking that the NSW State Government just wants these problems to go away, particularly with an election just around the corner.

The VFFA is promoting open debate from all persons involved. This includes the NSW Rural Fire Service (RFS), Fire and Rescue NSW (FRNSW), NSW National Parks and Wildlife Service (NPWS), Forestry Corporation of NSW, the Rural Fire Service Association (RFSA), the Volunteer Fire Fighters Association (VFFA), the Fire Brigades Employees Union (FBEU), the insurance companies and most importantly, the firefighters (from all fire services) and the public of NSW.

The VFFA Submission

April 14, 2018

Bega Valley Independent Review
GPO Box 5434
Sydney NSW 2001
Emailed to:

VFFA Submission – Keelty Inquiry 2018

As President of the Volunteer Fire Fighters Association (VFFA), I visited the township of Tathra on the 3rd, 4th and 5th of April 2018. I used the opportunity to speak with volunteer firefighters, local residents and workers engaged in the recovery process.

The VFFA would firstly like to acknowledge the incredible work conducted by all firefighters, support personnel, the residents of Tathra and surrounding areas during the firefighting operations. We also would like to thank the volunteers, residents, business owners, community groups, local and state government agencies for their hard work during the recovery phase.

1. Review and report on the adequacy of the fire services response to the Reedy Swamp fire Bega that occurred on 18 March 2018, and subsequently impacted on the township of Tathra.

As the lead agency, the Rural Fire Service (RFS) had significant input both prior and during the Reedy Swamp fire.

(a) Bush Fire Risk Management Planning

Prior to the fire, the RFS was responsible for the planning and implementation of the Bush Fire Risk Management Plan to protect Tathra.

Scrutiny of this plan is crucial in determining how 69 homes and 35 outbuildings came to be lost on the afternoon of 18th March 2018 in Tathra.

Until 5 years ago, risk management plans were audited by the Independent Audit and Investigations Unit. The NSW RFS Commissioner put an end to this and Bush Fire Management Committees (BFMCs) were allowed to conduct their own audits.

Whilst this might sound good in principle, BFMCs report that hazard reduction activities have taken place. The reporting does not always identify if a reasonable quota was reached or if the desired quality of the hazard reduction was obtained.

The results (performance audits) of the BFMC should be reported in the Annual Report of the NSW RFS. It appears that the NSW RFS annual reports fail to properly identify the performance of bush fire management activities, as required under Section 62 of the Rural Fires Act.

An independent, external audit of Bush Fire Risk Management Plans is the only accurate way to determine the successful implementation of the plans.

It is recommended that the NSW Government establishes an independent auditing process (external to the NSW RFS) to report on the quality of bush fire risk management planning and hazard reduction outcomes.

(b) Fuel Reduction.

Every Federal, State and Coronial inquiry since the 1939 Stretton Inquiry, has recognised that the lack of hazard reduction was a major contributing factor to the intensity, spread and damage caused by wildfire.

The 2003 inquiry into Australian bushfires, titled “A Nation Charred” was the largest national bushfire inquiry conducted.

On page 49, 3.9 the Inquiry stated:

“The purpose of fuel reduction, then, is not to prevent wildfires but rather to mitigate the potential of their threat to life, property and the environment. The restriction of available fuel, decreases the:

  • intensity at which the fire burns
  • flame height and depths, and
  • rate of spread of the fire

from what they would otherwise be in the same conditions”.

Using figures supplied by the NSW RFS, the following graph illustrates this point.

Fuel builds up in the Australian bush at an average of 2 tonnes per hectare, per year.

7.5 tonnes per hectare (just under 4 years) is very easily managed as it produces 300kW per metre of fire front.

Note: 1 kW = the power of a single bar radiator.

Increase the fuel to 30 tonnes per hectare (15 years) and the intensity increases by 17 times to 5,200kW per metre of fire front.

At 5,200kW the fire is an uncontrollable wildfire.

Fuel loads have become so bad that the CSIRO have reported some wildfires are producing fire intensities of 100,000kW per metre of fire front.

Uncontrollable wildfires destroy everything – lives, property, infrastructure, livestock and the environment.

The Victorian Royal Commission went one step further recommending fuel reduction targets. They recommended that a minimum of 5% of all fire prone lands be treated annually.

In NSW over the last 20 years, we have averaged less than 1% fuel reduction annually through prescribed burning. At 1% it would take 100 years to treat fire prone lands once.

Once Brigades were given the freedom to work directly with their local communities to achieve hazard reduction. Achievable goals can be reached when our 2,000+ RFS brigades are managing their own patch. History has proven that the NSW RFS cannot successfully manage the entire state from Sydney. The NSW RFS only needs to provide support and assistance to the local brigades if required.

2. Review the call taking and despatch arrangements of both Fire and Rescue NSW and NSW Rural Fire Service across the State, and make any recommendations to ensure they are best practice, addressing emerging technology, and provide the best possible service delivery to the community of NSW.

In an emergency like the Tathra fire, all available fire vehicles (regardless of their agency of origin) should be responded. The reference to “all available fire vehicles” is linked to a strategy that does not deplete capability in other areas. Fire and Rescue NSW (FRNSW) refer to this strategy as “Move Ups” but either service could employ this strategy.

Rescue incident logs published by News Corp showed that FRNSW offered to send crews at 12:34pm and again at 12:58pm on Sunday. It was reported that both of those offers of help were rejected by NSW Rural Fire Service.

The response system and the principles of a coordinated firefighting effort are dysfunctional if it is proven that the offer of assistance was rejected by the NSW RFS, on a day that was clearly identified as being problematic.

It is important to note that the VFFA is not pointing the finger at the local firefighters or local staff members. We are promoting a move towards a coordinated response, complementary fire service relationships and engaging local knowledge.

(a) What is the best possible outcome for the community and the environment

The strict adherence to agency boundaries and protocols seems to have taken the focus away from the best possible outcome for the community and the environment.

A way towards solving this problem is to appoint an overseeing Fire Service Commissioner that the two agency Commissioners or department heads report to.

The overseeing Commissioner would need to be sourced externally (not from within the NSW RFS or FRNSW).

(b) The call out system

The NSW RFS introduced an independent centralised CAD call out system 5 years ago and due to its many failings, the system has not been well received.

A centralised call out system cannot take into account the many intricacies pertaining to each District and local knowledge is critical to the call out process.

In many cases (topography, tenure and other factors), it’s not the nearest brigade that needs to be despatched, but the one that can be on scene in the shortest period of time.

There have been numerous cases with the wrong brigade being despatched, causing critical time delays.

If secondary support is required, the local district duty officer is in the best position to decide where those resources will come from.

(c) Radio Communications

There are far too many districts operating on the same radio frequency, this is the systems most critical failure and will inevitably cost lives one day.

An effective communications network in a fire campaign is paramount. Crews, Sector Leaders, Incident Controllers and Fire Control all need to know what is happening on the fire ground.

The communication needs to be timely, concise and relevant to the incident you’re dealing with.

Currently brigades are having to contend with heavy radio traffic from all over the state that impedes efficient incident management.

One Captain reported being blocked by other radio traffic for 20mins before his call sign was acknowledged at a hazard reduction.

It is also worth noting that a move away from UHF fire ground communications excludes farmers from the communications network. Many brigades have resisted this move away from UHF CB radio use by retaining the UHF CB as well as the service supplied fireground radios.

It could be said that the UHF CB radio was the social media platform of the bush, used by many farmers. Facebook and other platform are now used by the NSW RFS but these methods of information sharing may not always work in rural areas.

Verbal Evidence

The VFFA would appreciate the opportunity to provide verbal evidence during this inquiry as our Executive Council has vast firefighting experience and has been engaged in numerous government inquiries.

Key Recommendations

1. Increase hazard reduction by prescribed burning in bush fire prone lands from 1% to 5%. This is more likely to be achieved if the ownership of such land management programs is driven by local brigades in conjunction with their communities.

This has an enormous cost benefit because prevention is around 100 times more cost effective than reactive firefighting measures.

The uncontrolled wildfire scenario is and will continue to destroy the environment in a way that is unsustainable (financially and ecologically).

2. It is recommended that the NSW Government establishes an independent (external to the NSW RFS) auditing process to report on the quality of bush fire risk management planning and hazard reduction outcomes.

3. It is recommended that the NSW Government appoints an overseeing Fire Service Commissioner that the other two department heads (or Commissioners) report to.

A suitable person needs to be sourced externally (not from within the NSWRFS or FRNSW). This strategy may lead to the development of a single fire service. The government could play it safe, with staged implementation.

Michael Holton
Volunteer Fire Fighters Association

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2 Replies to “Bega Valley Independent Review (Keelty Inquiry 2018)”

  1. Dear VFFA
    The report of Commissioner Keelty’s report does not appear to be online. I was interested in your comment regarding Bushfire Risk Management Plans. The Bega Valley Shire’s BFRMP is promulgated here . It covers Tathra. I am interested to see if the Commissioner investigated the Tathra aspects of the Eden document. The NSW Rural Fires Act 1997 (Part 3 Divisions 4, 5 and 6) Requires these plans to be updated every 5 years as I read the Act. And consultation with the public is mandated. I note that Eden’s BFRMP was released June 2010. And I would be interested to know if any consultation with the public and subsequent review has been conducted. Specific controls or risk mitigations are identified by the plan to be implemented in Tathra. Fire Management Plans covering Tathra should also be available to the public. Given the very high order of fire risk identified by Eden’s Bushfire Risk Management plan assessed for Tathra it seems to be most important for any follow up to the fire to establish if the identified controls were implemented, when and who by and how that affected the fire. I cannot determine if Commissioner Keelty looked into this. I would be grateful if you would advise me if VFFA has and if so the outcome determined.
    Cris George

  2. Cris
    The Bega Valley Fires Independent Review (Keelty Report) was first published at
    We have now published links that include the VFFA response to the Bega Valley Fires Independent Review, an attachment that include more detail relating to our response and the original Review (Keelty Report).
    The link to that post is
    You may also be interested in having a look at the following video at
    And you can listen to the RFS Commissioner at
    Mick Holton

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