Native forest in Flowerdale, to the northeast of Melbourne, on McMahons Rd, is set to be ignited today, Monday 22nd April. The forest to be burnt has been labelled HR-MUR-BRD-0092 Flowerdale - McMahons Rd burn.

"Our Fuel Hazard assessment shows that the fuel hazard rating now, before the burn, is predominately moderate. The fuel hazard in the adjacent area, which FFMV burnt in 2022, is predominately moderate. If they aren’t reducing fuel risk in this area by burning, it’s not a risk-reduction operation. Is FFMV burning this forest in Flowerdale to reach a quota?”

 – Sue McKinnon, President of Kinglake Friends of the Forest

The following information comes from Kinglake Friends of the Forest:

Reduction of fuel hazard is being used by FFMV to justify burning 280 Ha of forest in Flowerdale, yet fuel hazard ratings were determined by a consultant ecologist to be moderate and unlikely to be reduced by burning.

• When carrying out surveys for hollow bearing trees in the site, the KFF members noticed that this forest had a remarkably open understory. “Most of it just looked like it couldn’t possibly have a high fuel rating – we were walking through all areas easily, with little bracken and virtually no shrubs.”
  
• KFF contracted an independent Fuel Hazard Assessment, (FHA) to evaluate the fuel hazard rating for the forest FFMV plan to burn. The assessment was carried out by a consultant ecologist who specialises in bushfire ecology and has extensive experience conducting FHAs throughout a number of the state's bioregions. He assessed the forest in predetermined, evenly spaced locations on the 21^st of April, 2024.
  14 locations were assessed in the forest that FFMV plans to burn, and 7 locations were assessed in the adjacent forest area that FFMV burnt in 2022.
• The fuel hazard assessment criteria is set by DEECA and outlined in the Fuel Hazard Assessment Guide[1]
• The fuel hazard assessment report commissioned by KFF concluded that for the forest stand that FFMV plan to burn, "it is unlikely that conducting a prescribed burn would be effective in further reducing fuel hazard within the area.”
  
• Comparison was made between the Fuel Hazard assessments in the area planned to be burnt and the adjacent area which FFMV burnt in 2022. The report concluded that “there were only marginal differences in elements of the fuel profile, and thus overall fuel hazard rating, at sites within each survey zone; indicating that the recent prescribed burn conducted in 2022 – Diggers Gully was largely ineffective in reducing overall fuel hazard.”
  
• We need to invest in remote area firefighting, and tower mounted cameras for rapid detection and suppression of bushfires, not spend time and money lighting fires where they achieve nothing for public safety and cause damage to community health and to the environment” Sue McKinnon, KFF
  
• Research in Sydney has linked deaths and spikes in hospital admissions to planned burn smoke pollution[2].
  
• The FFMV Hume Region Bushfire Management Strategy uses software called the Phoenix RapidFire simulator to determine risk. This program is run using modelled fuel load inputs calculated theoretically by fuel accumulation curves. In 2020 the Victorian Auditor criticised DELWP for not considering current fuel loads[3]. VAGO referred to Melbourne University studies of fuel measurements collected in the field that found that “the data collected did not match the modelled fuel accumulation curves in Phoenix RapidFire”.[4]
  
• A second study by Melbourne University was referred to in the VAGO report. This was carried out in the Midlands district of Victoria. It compared the fire risk determined using actual fuel measures in the field to risk determined using the modelled fuel loads used in the Phoenix risk simulator program. It found that “the current approach to modelling fuel hazard levels in the Midlands fire district is likely to be overestimating the amount of fuel present (and the consequent fire risks) and overestimating the efficacy of burning to reduce fuels.”[5]
  
• “Our Fuel Hazard assessment showing that the fuel rating is moderate suggests that the modelled fuel load that FFMV assumed for this site was incorrect. Either FFMV haven’t verified fuel on site, or they are burning to reach a quota rather than to address risk.” Sue McKinnon KFF
  ● In 2018 a Spotted-tailed Quoll was detected[6] 7 km away. This is one of a series of detections in the Kinglake - Mt Disappointment area. The most recent detection was just last week in Kinglake[7]. causing excitement in a community that is proud to be living with such a rare and special species.
  There is continuous forest connectivity between the 2018 quoll detection and the area that FFMV plan to burn. Quolls are solitary animals with each male’s home range being 4500 Ha. Females have a slightly smaller home range. Given this, 7 km of connected forest is not far.
• DEECA’s response[8] to the Quoll detection in Kinglake was to confirm that they will burn as usual but guide their staff and machinery operators to avoid any damage to rocky outcrops and large hollow logs suitable for Quoll habitat. There is no other part of their supposed Quoll mitigation plan that differs from their business as usual.
• Community surveys have shown that in the forest that FFMV plans to burn in Flowerdale, there is a high density of hollow bearing trees. These trees are critical for the survival of both arboreal animals and quolls that prey on them. DEECA’s own research[9] shows that planned burns result in the collapse of 22% of hollow bearing trees within planned burn sites.
• FFMV can and does protect hollow bearing trees, but only on the edge of the burn for the safety of operators. As a minimum, in general, hollow bearing trees should be protected throughout every burn area, but areas with moderate fuel hazard like this area should not be burnt. 
• The findings of moderate and low fuel hazard in this forest shows that this forest area, which was disturbed in the 2009 fire has matured beyond its post disturbance stage of dense shrubby regrowth. The understory shrubs have died off and the eucalypt regrowth is now tall enough to act as wind shelter rather than fuel. The fuel hazard assessment results back up the ecological control mechanism described in research by Fire behavior and management scientist Adj. A/Prof Philip Zylstra (Curtin University)[10]

• Dr Zylstra’s research in forests in Western Australia shows that fire initially promotes a dense understory regeneration, but ecological controls transfer this biomass from fuel (likely to ignite) to overstorey shelter (unlikely to ignite, creating a less flammable microclimate). The effect of these changes was to alter modelled fire behaviour, such that flame dimensions in mature forest were half those in regrowth, canopy damage greatly reduced, and fire suppression opportunities maximised. The primary controls were self-thinning and self-pruning.

Approaches that cooperate with, rather than disrupt, these processes, therefore, provide a pathway to mitigate current climatic effects on fire.

• The moderate fuel hazard rating of this forest area gives us an opportunity to leave the forest intact to mature to its least flammable state. Allowing FFMV to burn it today will take that opportunity away for decades.