Resource Guide to the Bushfire Royal Commission Submissions 2020

All of Mike Gorman’s research into the Royal Commission submissions has now been consolidated into a single paper.

Mike Gorman takes up the story:

These submission tables have been created to make it a little easier for those interested in the 2019/2020 bushfire story to gain a better understanding of what has been publicly said in relation to the published submissions. The tables are a guide only and I would recommend that the submissions are read to gain a better understanding of the issues being raised. The submissions are biased towards NSW due to time constraints and my personal interests. At this stage I have not included items associated with recovery due to the size of the task and that it is still ongoing.


  • The submissions are a valuable resource for the following reasons:
    • Most, if not all, interested parties have had a chance to have their say resulting in a large amount of information being made available on all aspects of bushfire management
    • In Australia, it is rare for the general public to be invited to have a say and describe their own experience
  • The community input into the submissions has been limited by the short time frame available to make submissions and the fact that many people from bushfire effected communities are still facing significant trauma and were not in a position to make a documented contribution
  • It is inevitable that there will be omissions and minor mistakes in this guide due to the sheer size of the task and the way in which the material has been published
  • These comments would also apply to the NSW bushfire inquiry

The submissions have been broken into the following categories:

  • Planning
  • Land management
  • Cultural burning
  • NSW response
  • Built environment
  • Evacuation

Comments in relation to bushfire planning

  • There are a number of submissions that relate to bushfire research including the need for independent research. This suggests a possible issue concerning ‘agency controlled’ research
  • The willingness to seriously embrace risk management is questioned by a number of submissions. This is demonstrated by all government’s inability or unwillingness to shift funding from response & recovery to preparation & prevention
  • While the importance of the national strategy for disaster resilience has not been questioned, it is seen as a philosophy that has not yet been actioned
  • A number of submissions question the usefulness of the NSW Bush Fire Risk Management Plans and whether they work for communities
  • There are a lot of submissions making reference to the poor bushfire planning and protection of critical infrastructure particularly in relation to telecommunications
  • A large number of submissions question the resolve of all governments to implement the recommendations of previous bushfire inquires, hinting at a serious issue of accountability and transparency with bushfire management
  • A lot of submissions highlight the over reliance on volunteers. This is particularly relevant for NSW where Government decisions have reduced the capability of NPWS, FCNSW and WaterNSW to manage fires. A number of foresters have questioned the suitability of the NSW RFS for forest fires
  • A large number of submissions highlight the need for early detection and suppression of remote fires. Based on the submissions the real issue may lie with a lack of resolve to suppress the fires as opposed to early detection
  • There is likely to be a large resistance to change based on the submissions from existing organisations associated with fire management as their submissions rarely identified any problems and often made few if any recommendations

Comments on fuel management

  • Fuel loads, the cause and the best way to address the issue is very contentious
  • While the focus on fuel loads is normally directed at national parks and forestry a number of submissions point out that that the fuel loads on privately owned land is potentially a bigger issue particularly given its proximity to assets.
  • A number of submissions have also pointed out that the current processes for managing fuel loads on private land is cumbersome and has resulted in the fuel loads increasing
  • A number of submissions also point out, in relation to fuel loads, that the last 500m is the most critical land management zone with respect to the protection of assets

Comments in relation to cultural burning

  • A very large number of submissions like the idea of cultural/indigenous/fire stick burning
  • A few submissions have made references to possible limitations in southern Australia
  • A few submissions make reference to it not being a ‘quick fix’

Comments in relation to the NSW bushfire response

  • The failure to use local knowledge is the most common issue identified followed by poor communications and slow or inadequate initial response to fires
  • The aviation industry has commented on the inadequate initial response in NSW
  • NSW Government cutbacks in staff in NPWS, FCNSW and WaterNSW made a significant difference in the ability of land managers to response to the fires
  • The NSW RFS decision to restructure and not to fill vacant positions lead to a reduced capability in IMTs. This almost certainly lead to the decision to run with mega IMTs which in turn reduced local knowledge and impacted on the quality of the response
  • The RFS bushfire, and in particular forest fire, capability has been significantly reduced due to a number of reasons. This meant that the RFS could not make up for the loss of capability within the land manager organisations.
  • A combination of the reluctance to use local knowledge and to delegate along with the loss of bushfire skills within the RFS has led to significant failures with respect to backburning
  • The poor quality of blacking out was most probably caused by a combination of reduced skills, volunteer fatigue and dryness of the fuel. At times an impossible amount of water was required to blacken out completely
  • There was a surprising amount of input from heavy plant operators and contractors in general. There was comment that the community should not have to put fuel in fire trucks because the RFS has not paid its bills!
  • The poor working relationship that the RFS & FRNSW persists
  • The poor working relationship the RFS has with private firefighting resources, as in the farm ute, has not been resolved
  • Poorly managed road blocks are a significant issue for rural property owners

Comments in relation to built environment

  • There were a limited number of submissions looking at how best to mitigate the impact of bushfires on the built environment and almost all of these identified the need for further work

Comments in relation to evacuation

  • I cannot recall any submission that indicated that the management of evacuations went well other than when local communities stepped in and organised themselves
  • A number of submissions highlighted that the ‘leave early’ message is somewhat stymied by the late opening of evacuation centres

Mike Gorman, Kangaroo Valley, 15th of August 2020

Content Sharing

Related Posts

  • The VFFA submission to the Royal Commission and VFFA Vice President Brian WIlliams' submission are both published in this story.

  • Mike Gorman from the very effective team in Kangaroo Valley has compiled this index of all the submissions to the Royal Commission that relate to the firefighting response in NSW.

  • The Royal Commission is up and running and you can find a link to the Opening and the complete transcrpt in this post. We also review an excellent Sydney Mormning Herald article which quotes VFFA President Mick Holton.

  • Craig Lapsley succeeded in getting formal safety standards for fire bunkers implemented in Victoria over a decade ago. In NSW the RFS remain 'dead against them' according to this informative Sydney Morning Herald article.

2 Replies to “Resource Guide to the Bushfire Royal Commission Submissions 2020”

  1. One has to. be allowed to mitigate the actual or potential fire threat by being permitted to conduct our own hazard reduction in clearing our private land around our homes and farming infrastructure buildings to minimise the risk factor without fear of prosecution.

    Yes, our rural blocks of heavily timbered land with a massive load of fuel litter on the floor are waiting to explode into a fireball, 10 minutes from Campbelltown..
    Last burnt in 1994, 26 years ago. Section 44.
    House caught alight, but thankfully saved by dedicated and selfless volunteers.

    The area was earmarked for a hazard reduction and was plastic tapped out by the authorising management many years ago and all us landowners never heard another word about it. Kept in the dark. We were all Ignored when we attempted to follow up due to the non event of fire onto the ground.

    To this day, the landscape remain untouched and the tapping system has perished over the long years and one may see the last remaining remnants of red and white tape if they have a strong magnifying glass.

    The 10/50 rule, if one has the ability to analyse its content is probably non existent in this environment due to environmental protection issues associated around the 10/50 rule, an example being the Koala population protection policy and together with any other Acts that may relate to this specific environment ie Vegetation Act.

    Interesting to note that the public document of the Bush Fire Risk Management Plan was signed off by the Commissioner in 2012 and is in urgent need of a critical response update.

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