Inquiry Search
Rec-ID | Code | Recommendation |
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REC321-4201 | 10 - Infrastructure | We recommend that DELWP improves the Powerline Bushfire Safety Program's transparency by publicly reporting on activities, costs and risk-reduction outcomes. |
REC321-4202 | 10 - Infrastructure | We recommend that DELWP investigates incentives and advises government on options to accelerate burying and insulating the remaining high-voltage bare-wire powerlines in the 33 highest risk areas. |
Rec-ID | Code | Recommendation |
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REC317-4083 | 10 - Infrastructure | The Australian Government should work with state and territory governments and critical infrastructure operators to improve information flows during and in response to natural disasters: |
REC317-4082 | 10 - Infrastructure | The Australian Government, working with state and territory governments and critical infrastructure operators, should lead a process to: |
REC317-4070 | 10 - Infrastructure | Australian, state and territory governments should expedite the delivery of a Public Safety Mobile Broadband capability. |
REC317-4086 | 22 - Role of local Gvt | State and territory governments should review their arrangements for sharing resources between their local governments during natural disasters, including whether those arrangements: |
REC317-4121 | 41 - Emergency Management exercises | Australian, state and territory governments should work together to develop a program for national level recovery exercises, building on the work currently underway through the Community Outcomes and Recovery Subcommittee of the Australia-New Zealand Emergency Management Committee. |
REC317-4085 | 22 - Role of local Gvt | State and territory governments should take responsibility for the capability and capacity of local governments to which they have delegated their responsibilities in preparing for, responding to, and recovering from natural disasters, to ensure local governments are able to effectively discharge the responsibilities devolved to them. |
REC317-4071 | 41 - Emergency Management exercises | Australian, state and territory governments should conduct multi-agency, national-level exercises, not limited to cross-border jurisdictions. These exercises should, at a minimum: |
Rec-ID | Code | Recommendation |
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REC264-1085 | 10 - Infrastructure | GDF Suez establish enhanced back-up power supply arrangements that do not depend wholly on mains power, to: • ensure that the Emergency Command Centre can continue to operate if mains power is lost; and • ensure that the reticulated fre services water system can operate with minimal disruption if mains power is lost. |
Rec-ID | Code | Recommendation |
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REC263-1092 | 29 - Operational Health and Safety | CFA and VICSES should: implement risk management processes within regions, districts, brigades and units to understand and manage the local risks associated with their volunteer workforces |
Rec-ID | Code | Recommendation |
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REC262-1490 | 10 - Infrastructure | That the Emergency Services Telecommunications Authority critically reviews: |
REC262-1489 | 10 - Infrastructure | That the Emergency Services Telecommunications Authority reclassifies its State Emergency Communications Centres as critical national infrastructure. |
Rec-ID | Code | Recommendation |
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REC258-2560 | 29 - Operational Health and Safety | The Civil Aviation Safety Authority devolve to Designated Aviation Medical Examiners the ability to renew aviation medical certificates (for Classes 1, 2, and 3) where the applicant meets the required standard at the time of the medical examination. |
Rec-ID | Code | Recommendation |
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REC250-0791 | 22 - Role of local Gvt | Local Government Victoria should lead the design and implementation of strategies to support councils to further develop social capital needed for recovery. |
Rec-ID | Code | Recommendation |
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REC232-2824 | 41 - Emergency Management exercises | The Australian Department of Health and Ageing consult with members of the general public or representatives of health consumers in the pandemic planning process, including in pandemic exercises designed to test the ability of government to respond to a pandemic event. Consumer involvement should include testing the ability of any communication strategy designed to inform and engage consumers about a pandemic event. |
REC232-2822 | 41 - Emergency Management exercises | The Australian Government test Australia’s ability to respond to a widespread outbreak of infectious disease other than influenza, by undertaking a pandemic exercise across the relevant Commonwealth, state and territory government agencies. |
Rec-ID | Code | Recommendation |
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REC230-2833 | 10 - Infrastructure | If recommendation 1 is not supported by the Australian Government, the committee recommends that the Minister for Broadband, Communications and the Digital Economy issue a Ministerial Direction to the Australian Communications and Media Authority to allocate as a minimum requirement, 20 MHz in the 800 MHz band for the purposes of a public safety mobile broadband network. |
REC230-2832 | 10 - Infrastructure | The committee recommends that the Minister for Broadband, Communications and the Digital Economy take appropriate measures to secure, for public service agencies, priority access to an additional 10 MHz of spectrum in the 700 MHz band for public safety purposes. |
REC230-2831 | 10 - Infrastructure | The committee recommends that the Minister for Broadband, Communications and the Digital Economy issue a Ministerial Direction to the Australian Communications and Media Authority to allocate 20 MHz of contiguous spectrum in the 700 MHz band for the purposes of a public safety mobile broadband network. |
Rec-ID | Code | Recommendation |
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REC217-1825 | 22 - Role of local Gvt | When developing flood mitigation options in lowland areas, local governments should give consideration to the use of temporary levees as an alternative or addition to permanent structures. To maximise the use of these structures and limit flood damage, and aid affordability, consideration should be given by local governments to the sharing of temporary levees among different townships and different council areas. |
REC217-1819 | 22 - Role of local Gvt | In consultation with local communities, local councils will develop flood response plans as subplans to their current Municipal Emergency Management Plans. As part of the flood risk assessment process, these plans will be informed by the best available flood mapping and modelling, and will identify agreed activities to be undertaken during floods including, where appropriate, the construction of temporary levees. The condition of levees will be incorporated into such plans to enable improved emergency response. |
Rec-ID | Code | Recommendation |
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REC216-2871 | 22 - Role of local Gvt | Efficient and effective supporting tools and processes: high-quality local/municipal planning. |
Rec-ID | Code | Recommendation |
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REC199-0486 | 22 - Role of local Gvt | the state, following the completion of the Municipal Association of Victoria Improving Emergency Management in Local Government program, work with municipalities to revise the role and responsibilities of local government in emergency management. The issue of capability and capacity of each local government should be addressed in all related emergency management arrangements. |
REC199-0468 | 22 - Role of local Gvt | municipal councils undertake a risk assessment of caravan parks and decide if any should be included in the list of facilities where vulnerable people may be located. |
Rec-ID | Code | Recommendation |
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REC195-0335 | 10 - Infrastructure | Energy Safe Victoria ensures that the standards for vegetation clearance around power lines consider the impact of fire on electrical infrastructure and the risk of loss of electricity supply to the community. |
Rec-ID | Code | Recommendation |
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REC189-2911 | 29 - Operational Health and Safety | The review team recommend that: |
REC189-2907 | 29 - Operational Health and Safety | a) For the purposes of designing and implementing its regulatory activities, National Offshore Petroleum Safety Authority (NOPSA) should continue to identify priority hazards and risks and their underlying causes, in consultation with the NOPSA Advisory Board and stakeholders (see Theme 9, Stakeholder engagement). |
REC189-2912 | 29 - Operational Health and Safety | The review team recommend that the safety case system be strengthened by including provisions for a design notification scheme along the lines of that under the British Offshore Safety Case Regulations. |
Rec-ID | Code | Recommendation |
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REC181-0181 | 22 - Role of local Gvt | Municipal councils include in their municipal fire prevention plans for areas of high bushfire risk provision for the identification of hazard trees and for notifying the responsible entities with a view to having the situation redressed. |
REC181-0182 | 10 - Infrastructure | The State (through Energy Safe Victoria) require distribution businesses to do the following: ■ disable the reclose function on the automatic circuit reclosers on all SWER lines for the six weeks of greatest risk in every fire season; ■ adjust the reclose function on the automatic circuit reclosers on all 22-kilovolt feeders on all total fire ban days to permit only one reclose attempt before lockout. |
REC181-0180 | 10 - Infrastructure | The State amend the regulatory framework for electricity safety to require that distribution businesses adopt, as part of their management plans, measures to reduce the risks posed by hazard trees—that is, trees that are outside the clearance zone but that could come into contact with an electric power line having regard to foreseeable local conditions. |
REC181-0184 | 10 - Infrastructure | The State amend the regulatory framework for electricity safety to strengthen Energy Safe Victoria’s mandate in relation to the prevention and mitigation of electricity-caused bushfires and to require it to fulfil that mandate. |
REC181-0179 | 10 - Infrastructure | The State (through Energy Safe Victoria) require distribution businesses to review and modify their current practices, standards and procedures for the training and auditing of asset inspectors to ensure that registered training organisations provide adequate theoretical and practical training for asset inspectors. |
REC181-0178 | 10 - Infrastructure | The State (through Energy Safe Victoria) require distribution businesses to change their asset inspection standards and procedures to require that all SWER lines and all 22-kilovolt feeders in areas of high bushfire risk are inspected at least every three years. |
REC181-0176 | 29 - Operational Health and Safety | The Country Fire Authority and the Department of Sustainability and Environment adopt the title ‘safety officer’ (as opposed to ‘safety adviser’) and require without exception that a safety officer be appointed to every level 3 incident management team. |
REC181-0202 | 22 - Role of local Gvt | The State develop and implement, in consultation with local government, a mechanism for sign-off by municipal councils of any permit conditions imposed under the Bushfire-prone Overlay and the regular assessment of landowners’ compliance with conditions. |
REC181-0183 | 10 - Infrastructure | The State (through Energy Safe Victoria) require distribution businesses to do the following: ■ fit spreaders to any lines with a history of clashing or the potential to do so; ■ fit or retrofit all spans that are more than 300 metres long with vibration dampers as soon as is reasonably practicable. |
REC181-0153 | 22 - Role of local Gvt | The State establish mechanisms for helping municipal councils to undertake local planning that tailors bushfire safety options to the needs of individual communities. In doing this planning, councils should: ■ urgently develop for communities at risk of bushfire local plans that contain contingency options such as evacuation and shelter; ■ document in municipal emergency management plans and other relevant plans facilities where vulnerable people are likely to be situated—for example, aged care facilities, hospitals, schools and child care centres; ■ compile and maintain a list of vulnerable residents who need tailored advice of a recommendation to evacuate and provide this list to local police and anyone else with pre-arranged responsibility for helping vulnerable residents evacuate. |
REC181-0177 | 10 - Infrastructure | The State amend the Regulations under Victoria’s Electricity Safety Act 1998 and otherwise take such steps as may be required to give effect to the following: ■ the progressive replacement of all SWER (single-wire earth return) power lines in Victoria with aerial bundled cable, underground cabling or other technology that delivers greatly reduced bushfire risk. The replacement program should be completed in the areas of highest bushfire risk within 10 years and should continue in areas of lower bushfire risk as the lines reach the end of their engineering lives; ■ the progressive replacement of all 22-kilovolt distribution feeders with aerial bundled cable, underground cabling or other technology that delivers greatly reduced bushfire risk as the feeders reach the end of their engineering lives. Priority should be given to distribution feeders in the areas of highest bushfire risk. |
REC181-0174 | 29 - Operational Health and Safety | The Country Fire Authority and the Department of Sustainability and Environment amend their procedures for investigating safety incidents and ‘near-misses’ to ensure that all dangerous incidents, including back-burns, are fully investigated and that all relevant people are consulted and informed of the results. |
REC181-0195 | 22 - Role of local Gvt | The State press municipal councils—in particular, Murrindindi Shire Council—to urgently adopt a bushfire policy in their Local Planning Policy Framework and incorporate bushfire risk management in their planning policies and strategies for rebuilding communities such as Marysville, Kinglake and others affected by the January–February 2009 fires. |
Rec-ID | Code | Recommendation |
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REC180-2973 | 22 - Role of local Gvt | Local Government Victoria should, further to its work on strengthening the oversight role of audit committees, assist councils to develop good practice approaches to implementing, overseeing and continuously improving business continuity management. |
REC180-2972 | 22 - Role of local Gvt | Councils should strengthen their continuous improvement frameworks by: |
REC180-2971 | 22 - Role of local Gvt | Councils should improve the structure, format and content of their business continuity plans to provide greater clarity on roles and responsibilities for emergencies, more specificity on continuity and recovery responses, and better integration with other council disaster recovery and emergency plans. |
REC180-2970 | 22 - Role of local Gvt | Councils should improve assessments of business continuity risks by: |
REC180-2969 | 22 - Role of local Gvt | Councils should strengthen governance arrangements for business continuity by: |
Rec-ID | Code | Recommendation |
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REC179-2976 | 41 - Emergency Management exercises | The Department of Human Services should regularly test recovery plans with partner agencies. |
Rec-ID | Code | Recommendation |
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REC177-3321 | 29 - Operational Health and Safety | Careful consideration must be given to equipment compatibility as part of well construction design. |
REC177-3288 | 29 - Operational Health and Safety | As soon as a risk of barrier failure arises, no other activities should take place in the well other than those directed to removal of the risk. |
REC177-3303 | 29 - Operational Health and Safety | Tracking and analysis of cementing problems/failures should occur to assess industry trends, principal causes, remedial techniques and so on. |
REC177-3282 | 29 - Operational Health and Safety | If a risk assessment or compliance review is triggered by the happening of a predetermined event, specific consideration should be given to whether a ‘hold point’ should be introduced such that work must cease until the problem is resolved (and the subject of appropriate certification). |
REC177-3299 | 29 - Operational Health and Safety | Regulatory approval to rely on only one barrier should not be given unless (i) a proper risk assessment is carried out; (ii) exceptional circumstances exist; and (iii) risks involved are reduced to ‘as low as reasonably practicable’. The default position must be that well integrity must be assured. |
REC177-3281 | 29 - Operational Health and Safety | Wellbore gas bubbling should be regarded as a trigger for independent review of well integrity. Industry and regulators should identify and document other triggers. |
REC177-3295 | 29 - Operational Health and Safety | Wells drilled into hydrocarbon zones should be treated as live wells, with the potential to blowout unless a documented risk assessment establishes otherwise. |
REC177-3279 | 29 - Operational Health and Safety | Well construction and management plans, and drilling programs, should include provision for testing and verifying the integrity of all barriers as soon as practicable after installation. |
REC177-3294 | 29 - Operational Health and Safety | Perceived time and cost savings relating to any matters impacting upon well control should be subjected to rigorous safety assessment. |
REC177-3278 | 29 - Operational Health and Safety | Well construction and management plans should include provision(s) for reviewing the integrity of barriers at safety‐critical times or milestones, such as (i) prior to suspension involving departure of the rig from the platform; (ii) prior to re‐entry of a well after suspension; (iii) prior to removal of any barrier. |
REC177-3293 | 29 - Operational Health and Safety | If a dispute arises between a licensee and a rig operator in relation to a well control issue, and is not resolved between them, the matter must be raised with the relevant regulator before discretionary operations proceed. |
Rec-ID | Code | Recommendation |
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REC176-0138 | 10 - Infrastructure | The Productivity Commission undertake an examination of bushfire risk from ageing power infrastructure, including an assessment of replacement costs and likely suppression costs from bushfires caused by defective infrastructure. |
REC176-0139 | 10 - Infrastructure | Subject to the findings of the Productivity Commission, the Commonwealth examine options for the funding of replacement of power infrastructure that presents an unacceptable bushfire risk. |
Rec-ID | Code | Recommendation |
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REC156-3487 | 10 - Infrastructure | Electricity distribution businesses develop and implement alternative arrangements for monitoring fallen powerlines. |
REC156-3500 | 10 - Infrastructure | The Emergency Services Telecommunications Authority, in partnership with Telstra, consider technological solutions to streamline the handover process for Triple Zero calls. |
REC156-3492 | 22 - Role of local Gvt | The review of the municipal emergency management planning guidelines being led by the Office of the Emergency Services Commissioner clarify local governments’ role in community information about emergencies. |
REC156-3494 | 10 - Infrastructure | Energy Safe Victoria finalise the development of the passport system to improve interstate mutual aid arrangements allowing operator access to qualified interstate power restoration personnel. |
Rec-ID | Code | Recommendation |
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REC154-3459 | 41 - Emergency Management exercises | To improve response preparedness, DPI should clearly link the selection of simulation exercises to the risk management framework to target coverage of high risks. |
REC154-3462 | 41 - Emergency Management exercises | DPI should formalise the approach and framework for evaluating simulation exercises and response to Emergency Animal Disease incidents with guidelines to define the nature of the review process. This should include: |
Rec-ID | Code | Recommendation |
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REC149-3147 | 29 - Operational Health and Safety | As all stakeholders have responsibility for safe outcomes, decisions regarding target subjects for safety promotion need to have the support of all stakeholders including NOPSA and the workforce. Industry, which ultimately has the responsibility for managing risk as well as funding the promotion, should take a leadership role in implementation. |
REC149-3144 | 29 - Operational Health and Safety | The Safety Case proponent should be allowed some flexibility to involve appropriate experience matched with the proposed workforce competencies to enable the Safety Case to be developed with value adding processes. Subsequent to the hiring of the workforce Final Government Response Offshore Petroleum Safety Regulation Inquiry and 2008 Review of NOPSA Operational Activities and preferably before the commencement of operations a review of the Safety Case should take place with the new workforce to ensure they understand the accepted Safety Case, its risks and Safety Management Plan. |
REC149-3135 | 29 - Operational Health and Safety | The initial acceptance of a new facility Safety Case should be in conjunction with inspection of a facility upon commencement of operations. |
REC149-3128 | 29 - Operational Health and Safety | National Offshore Petroleum Safety Authority (NOPSA) should develop guidelines in consultation with stakeholders to provide clarity and consistency to the process which ultimately will result in better safety outcomes. |
Rec-ID | Code | Recommendation |
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REC145-3231 | 22 - Role of local Gvt | The Committee recommends that the Australian Government request that the Centre for Excellence for Local Government ensure a particular focus on capacity building for coastal local councils. Capacity building should focus on addressing issues relating to: |
Rec-ID | Code | Recommendation |
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REC125-3901 | 22 - Role of local Gvt | That councils formulate, track and report on measures that show their performance in managing drainage assets. |
REC125-3899 | 22 - Role of local Gvt | That councils implement a condition assessment and monitoring program conforming to best practice principles. |
REC125-3896 | 22 - Role of local Gvt | That councils plan for, and implement, formal consultation arrangements with stakeholders to set drainage goals and objectives, and desired service levels. |
REC125-3894 | 22 - Role of local Gvt | That councils develop flood risk management practices consistent with best practice risk management, and that these incorporate: |
Rec-ID | Code | Recommendation |
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REC123-3882 | 41 - Emergency Management exercises | The Office of the Emergency Services Commissioner convene a working group of key emergency services and emergency management agencies to develop a flow chart based on scenario testing, to support decision making and the assessment of response requirements to medical, hazardous materials and CBR emergencies including their transition from one type to another. |
Rec-ID | Code | Recommendation |
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REC117-3639 | 41 - Emergency Management exercises | The ANAO recommends that the Attorney-General’s Department, in consultation with the National Counter-Terrorism Committee, strengthens the reporting on the National Capability Development Exercise Programme through: |
REC117-3638 | 41 - Emergency Management exercises | The ANAO recommends that the Attorney-General’s Department, in consultation with the Department of the Prime Minister and Cabinet and the National Counter-Terrorism Committee: |
REC117-3637 | 41 - Emergency Management exercises | The ANAO recommends that the Attorney-General’s Department, in consultation with the Department of the Prime Minister and Cabinet and the National Counter-Terrorism Committee, pursue a more strategic and systematic approach to the measurement of performance via the National Capability Development Exercise Programme by: |
REC117-3636 | 41 - Emergency Management exercises | The ANAO recommends that the Attorney-General’s Department, in conjunction with the National Counter-Terrorism Committee’s exercise management advisers, explore options for the incorporation of more contemporary and varied testing and training aids in the National Capability Development Exercise Programme. |
REC117-3634 | 41 - Emergency Management exercises | The ANAO recommends that the Attorney-General’s Department, in consultation with the Department of the Prime Minister and Cabinet and the National Counter- Terrorism Committee, pursue the adoption of a more strategic approach to determining the National Capability Development Exercise Programme so that: |
Rec-ID | Code | Recommendation |
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REC116-2129 | 41 - Emergency Management exercises | The Working Group recommends that Emergency Management Australia and the jurisdictions through the AEMC develop a three year rolling national exercise strategy aimed at testing the response and recovery aspects of large scale disasters. |
REC116-2115 | 41 - Emergency Management exercises | The Working Group recommends that the results of the scenario modeling be presented to the Australian Emergency Management Committee (AEMC) upon completion, and that AEMC form Sub Working Groups of State/Territory emergency management representatives as appropriate to be tasked with considering response and recovery capability (both state/territory and national) against the identified consequences. |
REC116-2107 | 10 - Infrastructure | The Working Group recommends that State/Territory emergency management plans should explicitly take the need for rapid assessment of damaged physical infrastructure into account. The importance of rapid physical infrastructure assessment in ensuring the supply of utilities including sewerage and drainage, electricity, water and gas to residential structures and other types should be recognised and considered. |
Rec-ID | Code | Recommendation |
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REC104-2250 | 41 - Emergency Management exercises | That DSE and CFA work in cooperation with the Municipal Emergency Response Coordinators to develop and conduct joint exercises that practise the skills and test procedures for operations of the Municipal Emergency Coordination Centre, Municipal Recovery Centre and Incident Control Centres. |
REC104-2304 | 22 - Role of local Gvt | That Municipal Emergency Resource Officers develop registers of volunteers willing and available to provide assistance and support during the response to, and recovery from, emergency incidents. |
REC104-2222 | 22 - Role of local Gvt | That Municipal Councils: |
REC104-2270 | 29 - Operational Health and Safety | That DSE and CFA continue to stress firefighter safety as their highest priority for incident managers and fire ground supervisors |
REC104-2223 | 10 - Infrastructure | That Government review legislation for utilities operating within the State to ensure their involvement in regional fire preparedness and mitigation planning. |
REC104-2335 | 41 - Emergency Management exercises | That the fire agencies develop a program to significantly increase the amount of joint training and exercises undertaken. |
Rec-ID | Code | Recommendation |
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REC098-2167 | 10 - Infrastructure | The Committee recommends that Emergency Management Australia and the Australian Communications Authority, in conjunction with the respective state and territory governments, ensure the survivability of essential communication installations during fire incidents by strategic fuel management around the assets. |
REC098-2163 | 10 - Infrastructure | The Committee recommends that Emergency Management Australia and the Australian Communications Authority jointly with the Australasian Fire Authorities Council: |
REC098-2138 | 10 - Infrastructure | The Committee recommends that the Commonwealth seeks to ensure that the Council of Australian Governments resolve to increase water access points for bushfire fighting on public land to the minimum national standard. |
REC098-2151 | 29 - Operational Health and Safety | The Committee recommends that the Commonwealth Attorney-General engage the Commonwealth, states and territories in a review of occupational health and safety legislation as it affects the proper and effective functioning of bush fire services. |
Rec-ID | Code | Recommendation |
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REC037-4164 | 22 - Role of local Gvt | The role of local government in counter—disaster affairs be clearly defined and formalised by legislation. Local government authorities would then be fully aware of their responsibilities and of their entitlement to financial and other counter—disaster resources from State Government level. [Reference paragraphs: 232 to 233] |
Rec-ID | Code | Recommendation |
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REC016_3944 | 10 - Infrastructure | It is recommended that the water pressure be improved so that a greater volume and jet may be available for the suppression of fires on the faces and also for the purpose of wetting the berms more widely and thoroughly when necessary. It is suggested that there should be variable control of the pressure so that production need not be adversely affected in times of normal danger. |
REC016_3943 | 10 - Infrastructure | It is recommended that a more constant, running revision of the main and sprinkler system be maintained in future so that the service which it is intended to convey shall be closely and efficiently available to all parts of the berms and faces. It is emphasized that the reticulation system in the berms is fixed and stationary, whereas the faces are continually receding as their surfaces are scraped away by the dredges. |
REC016_3951 | 10 - Infrastructure | It is recommended that the State Electricity Commission adopt a policy of conciliation and good will towards its closer neighbours. It is not suggested that its policy has been essentially otherwise. In future that policy can best be assured of success by time conferring of material benefit upon its neighbours at some monetary cost to the Commission. It is suggested, with conviction, that it would prove to be of great advantage to time Commission if it were to take an active part in the clearing and bettering of its neighbours’ scrub and timber country at time cost of the Commission. The settler whose land is fully cleared and in production, or who knows that his land will be cleared for him, has no incentive to burn illegally or carelessly. If this suggestion should he adopted, it would be necessary that it should be carried out in all cases in accordance with the settler’s convenience, that he himself should take an active part in the operations, and that he should be left, not with a financial obligation, but with a definite material advantage. |
Rec-ID | Code | Recommendation |
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REC004-3999 | 10 - Infrastructure | That, in view of the fact that along many of the lines, between the road-bed and the fences, there are numbers of dry inflammable stumps, which, when they catch fire, are very difficult to extinguish, and that the surface of the ground surrounding these stumps is usually chipped by the permanent-way men every summer, thus causing considerable expense without removing the risk of fire, the Railway Department should remove this source of danger, by grabbing them out and burning them as early as may be found practicable. |