Inquiry Search
Rec-ID | Code | Recommendation |
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REC321-4203 | 9 - Community education | We recommend that DELWP provides advice to government, in consultation with Country Fire Authority, Fire Rescue Victoria and councils, on options to improve owner and occupier awareness of and accountability for bushfire management overlay planning controls (see Section 4.3). |
REC321-4204 | 4 - Fire season preparation | We recommend that DEWLP and CFA (in consultation with FRV) in partnership with councils, provide advice to government in line with the Safer Together: A new approach to reducing the risk of bushfire in Victoria policy on options to better resource the assessment of risk on private land, its treatment and activities to enforce compliance of land owners with risk-reduction treatments. |
Rec-ID | Code | Recommendation |
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REC319-4193 | 9 - Community education | Public communications: The Inspector-General for Emergency Management recommends that Emergency Management Victoria and the entity referred to in Recommendation 13, or otherwise responsible government department, coordinate ongoing education campaigns to increase public awareness of community roles and responsibilities during periods of emergency relief and recovery. |
Rec-ID | Code | Recommendation |
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REC318-4186 | 9 - Community education | The Inspector-General for Emergency Management recommends that Emergency Management Victoria – in collaboration with the emergency management sector – develops and implements processes to ensure greater dissemination and improved understanding of information for all Victorians, and visitors to Victoria in an emergency event. This should consider but not be exclusive to individuals who: |
REC318-4170 | 4 - Fire season preparation | The Inspector-General for Emergency Management recommends that responder agencies and Emergency Management Victoria review preparedness arrangements to ensure procedural documentation (including plans), recruitment, briefings and training are completed before significant seasonal events are likely to occur. Seasonal preparedness should culminate in attestations of assurance to confirm that: |
REC318-4185 | 15 - Inter-service cooperation | The Inspector-General for Emergency Management recommends that Emergency Management Victoria works with the emergency management sector and relevant emergency management entities in New South Wales and South Australia to identify and address key cross border operational and resource management issues. This engagement should aim to enhance interoperability and maximise the capability and capacity of agencies to work together during emergencies along Victoria’s borders. |
REC318-4184 | 15 - Inter-service cooperation | The Inspector-General for Emergency Management recommends that Emergency Management Victoria collaborate with the emergency management sector to develop a capacity model that considers current and future: |
REC318-4179 | 15 - Inter-service cooperation | The Inspector-General for Emergency Management recommends that Emergency Management Victoria – in accepting that emergency management is a ‘shared responsibility’ - collaborate with the emergency management sector and community to: |
REC318-4175 | 4 - Fire season preparation | The Inspector-General for Emergency Management recommends that the Department of Environment, Land, Water and Planning (or the single entity referenced in Recommendation 4) – supported by other organisations with a legislated responsibility for fuel management – plan for and increase the application of non-burning fuel management treatments including mechanical means. The annual fuel management report should include the non-burn component of fuel management treatment, track annual change, and provide a comparison to the previous three years. |
REC318-4174 | 9 - Community education | The Inspector-General for Emergency Management recommends that the Department of Environment, Land, Water and Planning (or the single entity referenced in Recommendation 4) – with support from all legislated fuel management organisations for public and private land – lead a community engagement process to improve the Victorian community’s understanding of: |
Rec-ID | Code | Recommendation |
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REC301-2383 | 15 - Inter-service cooperation | Tasmanian Fire Service (TFS), Tasmanian Parks and Wildlife Service (PWS) and Sustainable Timber Tasmania (STT) initiate a discussion among their Australasian peers about good practice around managing new fire starts in remote terrain, to include issues around identification, predictive analysis, risk management and suppression activities. The outcome should be a document which allows for benchmarking to accepted good practice across Australasia, from which Tasmanian fire agencies can develop protocols against which the management of future events can be tested. |
REC301-2388 | 15 - Inter-service cooperation | TFS, PWS and STT should establish a State Air Desk, to be staffed by specialist staff year-round, with responsibility for managing both preparatory and contractual issues out of season as well as aircraft management when fires or other emergency events are occurring. |
REC301-2386 | 15 - Inter-service cooperation | TFS, PWS and STT should work with government and each other to continue to pursue a whole-of-state fuel management and burning program that encompasses all land tenures, meets the range of outcomes required by the state (township protection, risk reduction and landscape-scale burns) and is inclusive of private landholders and local communities as well as all fire agencies. |
Rec-ID | Code | Recommendation |
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REC299-1348 | 4 - Fire season preparation | In keeping with the Victorian Bushfires Royal Commission’s findings and recommendations, human life has primacy in bushfire‑related regulations and it is important that this is maintained in the implementation of bushfire management overlays and relevant vegetation removal exemptions should reflect the primacy of human life. |
Rec-ID | Code | Recommendation |
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REC297-1256 | 9 - Community education | That SES and Tasmania Fire Service share resources and align their community education programs and adopt an all-hazards approach to awareness. |
REC297-1251 | 9 - Community education | That all councils include an easily identifiable website link for the public to locate their Municipal Emergency Management Plan and community safety information. |
Rec-ID | Code | Recommendation |
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REC288-1197 | 9 - Community education | The Committee finds that on the evidence presented, the State Fire Commission introduces key performance indicators reporting in relation to its work in community engagement to measure its success in program delivery and community engagement. |
REC288-1196 | 9 - Community education | The Committee finds that on the evidence presented, that the State Fire Commission should assess whether community engagement programs of the State Fire Services and State Emergency should be centralised. |
REC288-1198 | 17 - Assets and technology | The Committee finds that on the evidence presented, that the Government should undertake a review of how firefighting equipment and gear in Tasmania can be better standardised with interstate equipment and gear to improve cross-jurisdiction resource utilisation. |
Rec-ID | Code | Recommendation |
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REC287-1186 | 9 - Community education | The Tasmanian fire agencies review: • their pre-season engagement with groups such as (but not limited to) environmental groups who might beneft from a greater understanding of fire management tactics, in order to inform them of and receive feedback on intended approaches to firefghting and fire management the work of the Public Information Section at incident management, regional and State level, to develop an increased appreciation of what information management might be most appropriate to serve the public interest in understanding the progress of the incident and to identify ways of providing surge capacity to resource effective information management in protracted and signifcant incidents. |
REC287-1180 | 15 - Inter-service cooperation | The Tasmanian fire agencies consider the development of fire operational guidelines to avoid long-term environmental impacts such as: • • • strategies and tactics that will minimise the impact of fire management activities conditions under which earthmoving equipment and fire chemicals may be used information on seasonal conditions and the times of year when various strategies and tactics should be applied, and fuel management strategies. |
REC287-1179 | 15 - Inter-service cooperation | The Tasmanian fire agencies develop a joint multi-agency Fire Preparedness Matrix to guide decision-making in response to severe fire weather conditions or capacity issues. |
Rec-ID | Code | Recommendation |
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REC264-1083 | 9 - Community education | The State, led by Emergency Management Victoria, develop a community engagement model for emergency management to ensure all State agencies and local governments engage with communities and already identifed trusted networks as an integral component of emergency management planning. |
REC264-1073 | 15 - Inter-service cooperation | The State establish, for any future incident, integrated incident management teams with GDF Suez and other Victorian essential industry providers, to: • essential industry providers; and require that emergency services personnel work with GDF Suez and other appropriate • implement the Australasian Inter-service Incident Management System. |
Rec-ID | Code | Recommendation |
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REC247-0935 | 4 - Fire season preparation | That the State Emergency Management Committee includes in its planning, the development of contingency emergency management plans for areas of high risk due to local conditions. |
REC247-0857 | 2 - Emergency powers | That the Tasmania Emergency Management Plan enable, and all organisations with a role in emergency management activate, emergency plans at lower threshold events to practice their arrangements and achieve a ‘hot start’ in escalating events. |
REC247-0892 | 17 - Assets and technology | That a review be conducted of the resource capacity and capability to provide effective and efficient emergency operations, including approved improvements. |
REC247-0934 | 4 - Fire season preparation | That the State Fire Management Committee considers developing a structured, systemic and proactive bushfire hazard reduction program with municipal councils and Tasmania Fire Service; and advises the Government on any legislative or other changes required to implement such a program. |
REC247-0856 | 2 - Emergency powers | That the Government reconsider the current position on emergency declarations in the Emergency Management Act 2006 and the Act is amended to provide: • a graduated scale of emergency declarations; • the ability to make a declaration when an emergency has occurred, is occurring or is about to occur; • the ability for the State Controller (or whatever the person in overall control of response and recovery operations is called) to make one or more declarations; • a declaration to enable access to all emergency powers. |
REC247-0891 | 9 - Community education | That emergency management plans specifically include processes for effectively engaging with local communities and using community resources, including volunteers. |
REC247-0933 | 4 - Fire season preparation | That the Government considers whether a peak body should be established, with authority to effectively implement a bushfire mitigation plan. |
REC247-0855 | 17 - Assets and technology | That a structure and facilities be established for the State Controller or other person managing multi-agency response and recovery operations. |
REC247-0948 | 15 - Inter-service cooperation | That the Department of Justice conduct an independent review to develop a suitable model for integrated and interoperable emergency management arrangements in Tasmania. |
REC247-0880 | 17 - Assets and technology | That bushfire agencies develop, implement and maintain air operations procedures. |
REC247-0931 | 4 - Fire season preparation | That a specific risk prevention and mitigation advisory body be established for the State Emergency Management Committee. |
REC247-0854 | 15 - Inter-service cooperation | That in multi-agency response and recovery operations, arrangements be made so it is unambiguous who is in charge of these operations. |
REC247-0944 | 9 - Community education | That the State Emergency Management Committee develops and coordinates a whole-of-government community resilience strategy for emergencies in a form that can be practically implemented, as a priority. |
REC247-0879 | 17 - Assets and technology | That bushfire agencies develop procedures for the automatic activation of aircraft to fires at pre-determined trigger points on high fire risk days. |
REC247-0894 | 17 - Assets and technology | That the police and other emergency service organisations discuss their resource issues for emergency operations with the Government. |
REC247-0943 | 9 - Community education | That a bushfire community education and information strategy be professionally developed and coordinated across the fire authorities by Tasmania Fire Service. |
REC247-0878 | 17 - Assets and technology | That bushfire agencies evaluate the use and effectiveness of fixed wing water bombing aircraft. |
REC247-0893 | 17 - Assets and technology | That further options to appropriately supplement the resources available for emergency management operations be examined. |
Rec-ID | Code | Recommendation |
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REC246-0784 | 17 - Assets and technology | Recommendation 9 TFS should review the capacity of its Fire Information Line to handle very large scale events, and explore additional options for a surge capability for the Fire Information Line. |
REC246-0787 | 9 - Community education | TFS make their community education and safety material available to the culturally and linguistically diverse (CALD) communities in Tasmania. |
Rec-ID | Code | Recommendation |
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REC216-2865 | 9 - Community education | Management of community expectations: further development of tools that would allow the community to more easily |
REC216-2864 | 9 - Community education | Management of community expectations: continued community education. |
REC216-2863 | 9 - Community education | Management of community expectations: better understanding of what different groups within a community expect. |
Rec-ID | Code | Recommendation |
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REC199-0444 | 2 - Emergency powers | the state, as a matter of urgency, develop a multi-agency Incident Control Team capability to be readily available for statewide deployment to establish incident control or to relieve functioning control structures. |
REC199-0441 | 4 - Fire season preparation | the state undertake further trials to explore the opportunity for greater use of social media as a credible source of information to and from the public during an emergency |
REC199-0431 | 9 - Community education | the state allocate core funding for the ongoing delivery of the ‘FloodSafe’ program to flood prone communities across Victoria. |
REC199-0483 | 9 - Community education | the state ensure: • where external assistance is provided to Victoria during emergencies, communities are advised of the specific purpose of that assistance, through media and other information channels; and • all agencies provide incident management personnel with information regarding the arrangements for tasking Australian Defence Force resources and that this advice is reinforced during emergencies where Australian Defence Force support is provided. |
REC199-0430 | 9 - Community education | the state undertake a community education program to inform households of their respective flood risk. This may include information on rate notices of heights of houses above flood level and educating people about flash flooding. |
REC199-0452 | 17 - Assets and technology | the state ensure that any new systems and equipment purchased by state emergency management agencies are interoperable with other relevant agencies to the fullest extent possible. This should involve the state establishing a procurement gateway process with input from the Emergency Services Commissioner. |
REC199-0410 | 17 - Assets and technology | the state take the necessary measures to upgrade existing manual stream and rain gauges and ensure that all future gauges provide a seamless transfer of data from the gauges to the Bureau of Meteorology. |
REC199-0451 | 15 - Inter-service cooperation | the state ensure, as a matter of priority, that the State Control Centre is able to function as a fit for purpose, multi-agency emergency management centre. Necessary works to achieve this outcome should have an overarching focus on the implementation of common agency systems and processes to the fullest extent possible. |
Rec-ID | Code | Recommendation |
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REC196-0230 | 9 - Community education | Explain the meaning of ‘timely, relevant and tailored’ community bushfire warnings through training and meetings particularly of Information Section staff and Incident Controllers. |
Rec-ID | Code | Recommendation |
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REC195-0318 | 15 - Inter-service cooperation | The Fire Services develop a joint protocol for each Fire Service to notify the other of fires reported from fire towers |
REC195-0337 | 9 - Community education | DSE enhance community engagement programs in East Gippsland to ensure that local communities are more informed about the complexities and interdependencies of prescribed burning and encourage local input. |
REC195-0309 | 15 - Inter-service cooperation | The Fire Services, and other emergency management agencies, use the Tostaree fire as a scenario exercise to improve understanding of fast-running fires and enhance interoperability and control strategies |
REC195-0334 | 4 - Fire season preparation | The Fire Services Commissioner leads a task force to: a. identify legislation, policies and guidelines that impact on vegetation management and recommend necessary changes b. develop a set of risk-based standards for vegetation management with respect to strategic firebreaks and the assets being protected c. integrate maintenance standards across all areas of responsibility and tenure. |
REC195-0333 | 9 - Community education | The Fire Services identify opportunities for the community to learn about, engage with and influence local emergency management planning. |
REC195-0332 | 9 - Community education | The Fire Services, in consultation with the community, develop a methodology for measuring community preparedness. They should also develop tailored education and information sharing opportunities to improve community understanding of bushfire risk, mitigation and preparedness. |
REC195-0327 | 15 - Inter-service cooperation | The Fire Services Commissioner ensures that the inter-relationship between Information Sections at all levels is understood. |
Rec-ID | Code | Recommendation |
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REC181-0204 | 2 - Emergency powers | The State amend the Country Fire Authority Act 1958 to enable the Chief Officer to delegate the power to issue fire prevention notices. |
REC181-0157 | 9 - Community education | The Commonwealth lead an initiative through the Ministerial Council for Police and Emergency Management, facilitated by Emergency Management Australia, to develop a national bushfire awareness campaign. |
REC181-0201 | 9 - Community education | The Victorian Building Commission, in conjunction with the Country Fire Authority, develop, publish and provide to the community and industry information about ways in which existing buildings in bushfire-prone areas can be modified to incorporate bushfire safety measures. |
REC181-0172 | 15 - Inter-service cooperation | The Country Fire Authority and the Department of Sustainability and Environment standardise their operating systems and information and communications technologies with the aim of achieving greater efficiency and interoperability between agencies. |
REC181-0156 | 9 - Community education | Victoria lead an initiative of the Ministerial Council for Education, Early Childhood Development and Youth Affairs to ensure that the national curriculum incorporates the history of bushfire in Australia and that existing curriculum areas such as geography, science and environmental studies include elements of bushfire education. |
REC181-0194 | 9 - Community education | The Country Fire Authority produce for community guidance material on fire-resistant landscape and garden design, including a list of fire-resistant species. |
REC181-0212 | 4 - Fire season preparation | VicRoads implement a systematic statewide program of bushfire risk assessment for all roads for which it is responsible, to ensure conformity with the obligations in s. 43 of the Country Fire Authority Act 1958 and with the objectives expressed in the VicRoads 1985 Code of Practice. |
REC181-0171 | 17 - Assets and technology | The State, in conjunction with Emergency Management Australia and the Department of Defence, develop an agreement that allows Commonwealth aerial resources that are suitable for firefighting and support activities to be incorporated in preparedness plans and used on days of high fire risk. |
REC181-0152 | 9 - Community education | The State revise the approach to community bushfire safety education in order to: ■ ensure that its publications and educational materials reflect the revised bushfire safety policy; ■ equip all fire agency personnel with the information needed to effectively communicate the policy to the public as required; ■ ensure that in content and delivery the program is flexible enough to engage individuals, households and communities and to accommodate their needs and circumstances; ■ regularly evaluate the effectiveness of community education programs and amend them as necessary. |
REC181-0192 | 4 - Fire season preparation | The Department of Sustainability and Environment develop and administer a collective offset solution for individual landholders who are permitted to remove native vegetation for the purpose of fire protection. |
REC181-0211 | 4 - Fire season preparation | The State and Commonwealth provide for municipal councils adequate guidance on resolving the competing tensions arising from the legislation affecting roadside clearing and, where necessary, amend environment protection legislation to facilitate annual bushfire-prevention activities by the appropriate agencies. |
REC181-0170 | 17 - Assets and technology | The Country Fire Authority and the Department of Sustainability and Environment amend their policies on aerial preparedness and standby arrangements, their dispatch protocols and the management of aircraft in order to do the following: ■ require that at locations that attract the risk assessment or preparedness level A on code red days all personnel needed for air operations must be on standby by 10.00 am; ■ establish a system that enables the dispatch of aircraft to fires in high-risk areas without requiring a request from an Incident Controller or the State Duty Officer. |
REC181-0210 | 4 - Fire season preparation | The State amend the exemptions in clause 52.17-6 of the Victoria Planning Provisions to ensure that the provisions allow for a broad range of roadside works capable of reducing fire risk and provide specifically for a new exemption where the purpose of the works is to reduce bushfire risk. |
Rec-ID | Code | Recommendation |
---|---|---|
REC155-3483 | 9 - Community education | That the Department of Sustainability and Environment and its partner agencies continue to develop a proactive approach to engagement with the local and wider media to achieve continuous improvement in the standard of community information and education. |
REC155-3475 | 9 - Community education | That in relation to Fire Operations Plans, the Department Sustainability and Environment extends the number of community meetings during the public consultation period to a minimum of one meeting for each Fire District, with the possibility of repeat visits to particular areas. |
Rec-ID | Code | Recommendation |
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REC132-3597 | 15 - Inter-service cooperation | Investigate engaging with other agencies involved in emergency management including SES, VicRoads, VicPolice, OESC and DHS to establish a single united emergency information line for Victoria that can be used to provide information to the public from all agencies involved. |
Rec-ID | Code | Recommendation |
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REC125-3891 | 15 - Inter-service cooperation | That Melbourne Water and councils explore opportunities for working collaboratively to address the management of flooding risks with a view to optimising the efficient and effective use of their flood mitigation resources. |
REC125-3897 | 17 - Assets and technology | That agencies assess the cost-effectiveness of establishing a dedicated and proven asset management information system which is integrated with the other information systems used to manage drainage assets. |
Rec-ID | Code | Recommendation |
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REC124-3889 | 15 - Inter-service cooperation | Develop a component of the DSE Workforce Strategy to build organisational capacity and sustainability of the prescribed burning program across the networked emergency organisation: |
REC124-3883 | 15 - Inter-service cooperation | Integrate information management systems relating to the prescribed burning program to provide consistency across the networked emergency organisation: |
Rec-ID | Code | Recommendation |
---|---|---|
REC104-2205 | 9 - Community education | That CFA should remain the lead agency in delivering the community education and information program to rural Victoria. |
REC104-2286 | 17 - Assets and technology | That CFA, having regard to terrain, continue to review the mix of firefighting appliances currently in service. In particular, consideration should be given to the number and distribution of smaller ‘slip-on’ type equipment. |
REC104-2210 | 9 - Community education | That CFA reports to the Minister for Police and Emergency Services on recommended solutions and implementation strategies for isolated small communities by June 2004. |
REC104-2220 | 2 - Emergency powers | That CFA should not be given the power to direct Forest Industry Brigades to engage in fire prevention and suppression activities off their land and that decision should remain the responsibility of the plantation company. |
REC104-2204 | 9 - Community education | That the three fire agencies (CFA, DSE and MFESB) develop and implement a joint Statewide fire awareness education and information program aimed at encouraging a higher degree of personal and household self-reliance. |
REC104-2283 | 15 - Inter-service cooperation | That DSE, CFA, MFESB and VICSES work cooperatively to establish a common system for resource tracking during major fires and incidents. |
REC104-2209 | 9 - Community education | That CFA, in conjunction with isolated small communities, develop and promote a suite of appropriate fire readiness and fire management strategies to meet their needs. |
REC104-2336 | 15 - Inter-service cooperation | That OESC work with the fire agencies in developing implementation strategies for recommendations agreed by Government. |
REC104-2214 | 9 - Community education | That CFA, recognising the value of the Community Fireguard Group program, undertake a review by June 2004 to identify opportunities to further develop the program to ensure its continuing appropriateness in preparing communities for fire into the future. |
REC104-2268 | 9 - Community education | That CFA and DSE include agreed Fire Control Priorities in community awareness and education material provided to the community before each fire season. |
REC104-2208 | 9 - Community education | That CFA and MFESB encourage householders to review their fire safety plan annually. |
REC104-2323 | 15 - Inter-service cooperation | That CFA, DSE, MFESB, VICSES, Victoria Police and OESC, in consultation with the Municipal Association of Victoria, consult on the proposal to combine Municipal Councils’ current responsibilities for the development of an emergency management plan/committee, as required by the Emergency Management Act 1986 and a fire prevention plan/committee as required by the Country Fire Authority Act 1958. |
REC104-2213 | 9 - Community education | That CFA provides technical advice to Community Fireguard Groups in the selection and purchase of appropriate equipment and protective clothing for use on their own land. |
REC104-2266 | 15 - Inter-service cooperation | That DSE and CFA review their joint planning for Incident Control Centres to ensure that, wherever safe and practicable, those Centres are located close to the fire area. |
REC104-2207 | 9 - Community education | That the Coordinator-in-Chief of Emergency Management directs that all emergency management agencies review, by June 2004, terminology and language in current communication and public education material to ensure it is clear, easily understood and consistent, particularly with regard to fire. |
REC104-2322 | 15 - Inter-service cooperation | That DSE commits appropriate resources to work with OESC in developing the bushfire component of the model. |
REC104-2212 | 9 - Community education | That Community Fireguard Group co-ordinators’ names are supplied to their local municipality for the 2003-2004 fire season, and are updated annually for use in information exchange should a Municipal Emergency Co-ordination Centre or Incident Control Centre be established. |
REC104-2265 | 15 - Inter-service cooperation | That in the review of Incident Control Centre locations, DSE and CFA give due consideration to: |
REC104-2206 | 9 - Community education | That CFA and MFESB: |
REC104-2295 | 15 - Inter-service cooperation | That more emphasis should be given to communication and discussion in regard to State Aircraft Unit’s roles, responsibilities, practices and procedures. |
REC104-2211 | 9 - Community education | That CFA clarifies and restates the roles and function of existing Community Fireguard Groups (including their relationship to the Municipal Fire Prevention Plan) to members, co-ordinators, Incident Controllers and Municipal Emergency Resource Officers, prior to the 2003-2004 fire season. |
REC104-2238 | 15 - Inter-service cooperation | That the Victorian fire agencies negotiate with their counterparts in New South Wales and South Australia to put in place agreements for mutual aid and the development of cross border strategy for the management of fires burning in the vicinity of, or across, State borders, and these agreements are reviewed annually. |
Rec-ID | Code | Recommendation |
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REC016_3952 | 4 - Fire season preparation | It is recommended that the question of the future responsibility be made certain and that the body so made responsible keep the grounds of the hospital free from undergrowth and trees wherever their presence may be a possible source of future danger. |
REC016_3950 | 4 - Fire season preparation | It is recommended that on days of abnormal danger loads of briquettes be not kept in the station yard. The real danger, which transcends in gravity the danger of time destruction of loads of briquettes, is that the prevailing wind or a change of wind might carry showers of burning embers to the town, which is but the width of a road away, and thereby cause material damage in the town. It is further recommended that the yard and its surroundings be kept clear of scrub and growth; and that special provision be made for quelling fire which may break out in the deposits of inflammable dust which lie in time yard. |
REC016_3949 | 17 - Assets and technology | It is recommended that the A.R.P. dams or earth tanks be kept filled during possible danger periods. |
REC016_3947 | 15 - Inter-service cooperation | It is recommended that the services of this body [Air Raids Precautions Body] be used in future if to do so be thought desirable. |
REC016_3953 | 15 - Inter-service cooperation | It is therefore recommended that the State Electricity Commission should be advised by someone whose profession it is to consider and devise methods of forest fire protection and suppression; that he should collaborate with others to devise a general scheme of organized protection of the undertaking and township of Yallourn; and that above all, he should have direct access to the Commissioners themselves, lest his advice should lose something of its strength and reality in its journey through the “proper channels” of the Commission’s organization. |