Integrated fire management planning was an outcome of the Report of the Inquiry into the 2002–2003 Victorian Bushfires, chaired by the then Emergency Services Commissioner, Mr Bruce Esplin (Esplin, Gill & Enright, 2003). The 2009 Victorian Bushfires Royal Commission concluded that integrated fire management planning could improve planning for fire prevention (Teague, McLeod & Pascoe, 2010, Volume 2, pp. 37-41). Integrated fire management planning requires the involvement of the community, public and private land owners, utility providers, the State, councils, and industry. By involving these parties, the characteristics of a given community can be understood and the fire risks identified can then be managed (Esplin, Gill & Enright, 2003, Ch. 14).

Mr King gave evidence to the Board that integrated fire management planning involves ‘looking at more in-depth risks associated with fire on an all agencies approach including the owners of critical infrastructure.’40 The objective of integrated fire management planning is ‘to ensure a more strategic and integrated approach to fire management planning, reducing the impact of fire in Victoria and assisting in establishing a state-wide planning approach and developing processes for continuous improvement.’41

Section 20(1) of the Emergency Management Act 1986 (Vic) (Emergency Management Act) provides that a municipal council must prepare and maintain a ‘municipal emergency management plan’ for emergency prevention, response and recovery. Preparation of the plan is by committee. Guidelines for committees are found in Part 6A of the Emergency Management Manual Victoria.

Mr Craig Lapsley, Fire Services Commissioner, gave evidence that municipal and regional plans draw linkages to other specific plans ‘including agency and mine mitigation, response and recovery plans ranging from government agencies, catchment management authorities and major essential service providers/sites including the coal mines.’42 Integrated emergency management plans are being prepared in some areas of Victoria across public and private land; however as explained by Mr Lapsley, ‘this integrated approach has not addressed the interface and integration of major hazards or special hazards that would result in integrated emergency planning for facilities like the Hazelwood mine.’43


The Latrobe City Council’s Fire Management Committee has produced a Municipal Fire Management Plan (as a sub-plan of the Latrobe Municipal Emergency Management Plan).44

The Municipal Fire Management Plan includes fire history information, assets at risk and control measures. It addresses the Gippsland Regional Strategic Fire Management Plan and the Victorian Fire Risk Register by referencing areas and assets recognised as at risk. The Municipal Fire Management Plan treatments for protecting assets are more operational, whereas the treatments for risk protection at the regional level are more strategic.

For example, the treatments listed for managing fire risk at the Hazelwood mine in the Municipal Fire Management Plan are:

  • routine asset site maintenance
  • (GDF Suez/CFA) Emergency Management Plan
  • on site firefighting resources
  • land use planning considerations for surrounding land use.45

Mr King gave evidence to the Board of his concerns that there is no program in place to monitor the implementation of the Municipal Fire Management Plan and that it is unclear who is responsible for implementing the plan.46 He indicated that he has no authority to tell any other agency what they have to do to meet the requirements of the Municipal Fire Management Plan.47

Mr Pullman gave evidence to the Board that despite it being part of his role, he was unaware that land use planning was listed in the Municipal Fire Management Plan as one of the treatments for the identified risk of fire in the Hazelwood mine.48

Mr Incoll made several observations about the interaction between the municipal fire planning and the integrated fire management planning regimes, and suggested that there is an overlap between the framework for the fire management planning under the Emergency Management Act and the long-established municipal planning process, which leads to confusion.49 He gave the example that both legislative schemes appear to appoint the same municipal officer in two roles, which are for all intents and purposes, the same role.50 He stated that the overlap and confusion must be resolved to ensure that fire prevention planning can be implemented effectively.51

Another criticism expressed by Mr Incoll was that there is no interface between Emergency Management protocols and fire preparedness of the Hazelwood mine.52 Mr Incoll noted that whilst there were opportunities for communications between the Latrobe City Council and organisations affected by fire in the region, the Municipal Fire Management Plan did not influence or interface with the fire planning at the Hazelwood mine because the mine is outside the jurisdiction of s. 43 of the CFA Act.53

Mr Incoll stated that ‘the lack of regulatory emphasis of fire protection is remarkable, given the proximity of the residential area of Morwell, the flammable nature of brown coal and the extensive previous fire experience in this Mine and Yallourn Open Cut.’54

Mr Incoll was also concerned that there is no enabling legislation that compels implementation of fire management plans.55

Mr Lapsley acknowledged that there were frustrations at municipal level with respect to the planning, resourcing and implementation of Municipal Fire Management, and that the legislation needed to be modernised to give consequences to the planning and to provide a specific statutory requirement for municipal fire management planning across the State.56


The Gippsland Regional Strategic Fire Management Plan was prepared by the Regional Strategic Fire Management Planning Committee with input from multiple stakeholders, in accordance with the principles of the 2007 Integrated Fire Management Planning Framework.57 The Plan was created under s. 9 of the Emergency Management Act.58 It details a range of fire mitigation activities and bodies accountable for delivering those activities.

In the last 14 months, each of the eight government regions in Victoria have for the first time,
prepared a regional strategic plan.59

The Gippsland Regional Strategic Fire Management Plan identifies and prioritises assets and risk across the Gippsland region. It categorises ‘Power Generation Facilities – coal mines’ (which would include Hazelwood Power Station and mine) as an extreme risk.60 Attachment A of the Gippsland Regional Strategic Fire Management Plan identifies ‘Power general facilities – coal mines’ as an asset, and notes that fire from external fire events has the potential to disrupt power supplies to the national grid.

The treatments for the risk are identified in Attachment A of the Plan as:

  • legislative controls including MHF (major hazard facility)
  • emergency management plans
  • CFA pre-incident plans
  • on site firefighting resources
  • ‘DPI regulatory planning’.61

Land use planning considerations for surrounding land use is listed as a ‘treatment recommendation’.62

Some issues were raised with the Board concerning the suitability of the Gippsland Regional Strategic Fire Management Plan.

First, the reference to ‘MHF’ is a reference to a ‘major hazard facility’ within the meaning of Part 5.2 of the Occupational Health and Safety Regulations 2007 (Vic) (OHS Regulations). Mr Leonard Neist, Executive Director of the Health and Safety Division at Victorian WorkCover Authority (VWA), gave evidence that the Hazelwood mine is not a ‘MHF’.63 Mr Lapsley told the Board that the reference in the Gippsland Regional Strategic Fire Management Plan to ‘MHF’ is ‘incorrect for that site’.64

Second, the evidence before the Board was that several of the parties who are required to implement these controls or treatments are either incorrectly described or were not aware of the actions expected of them. For example, the treatment ‘DPI regulatory planning’ refers to the Department of Primary Industries, a past regulator of the mine. The current regulators of the mine, the Mining Regulator and VWA, told the Board that they were not aware that they had a responsibility to implement any action for the mitigation of fire risk at the Hazelwood mine as set out the Fire Management Plan.65 The role of these regulatory bodies in the mitigation of fire at the Hazelwood mine is discussed more generally in Chapter 3.2 Regulation of fire risk in the Hazelwood mine.

Third, as noted above, Mr Pullman was not even aware that ‘land use planning’ was listed as a treatment of the risk of fire to the Hazelwood mine.66

Mr Lapsley accepted that the existing treatments in the Gippsland Regional Strategic Fire Management Plan were ‘pretty thin’, and identified other problems with integrated fire management planning as it currently operates.67