Mr Wayne Gregson
Department of Fire and Emergency Services


Dear Commissioner,

Re: Review of the Emergency Services Acts (“Concept Paper”)

Please find attached the Association of Volunteer Bush Fire Brigades’ (AVBFB) formal submission to the department’s concept paper.

Document structure

The physical layout of the document follows that of the original paper and includes every chapter and option as well as much (but not all) of the preamble provided by DFES in order to provide context to the AVBFB comments. The AVBFB preferred option and explanatory notes/observations are all contained within green boxes – in an effort to enable the reader to easily differentiate between the DFES and Association content.

Key themes

Since the review began in mid-April the AVBFB has, to the best of its ability, consistently encouraged its member brigades and volunteers to submit individual comments and feedback to DFES. As a result, a number of our constituents have informed the Association that they felt they did not have the capacity to make a full, independent submission.

Indeed, the Association was asked a number of times to provide a “template” submission that members could duplicate and submit as their own. However, the AVBFB took the view that the consultation process would deliver better outcomes for the wider community if submissions from our volunteer members reflected their genuine, independent views rather than far less valuable copy-and-paste “template” comments.

I’m proud to note that the AVBFB made this decision in the full knowledge that not only would this reduce the raw numbers of submissions from volunteers seemingly in support of the Association’s views, it would also most likely increase the number that presented views to the contrary. While some might consider this an unusual point for a peak body to celebrate, I have chosen to do so because it highlights the AVBFB’s commitment to one of the most important themes underlying the majority of the views expressed in the attached submission: the need for legislation to provide for greater recognition of the diverse circumstances and requirements of the state’s various emergency services.

As the peak body for the volunteer bush fire community, the AVBFB takes its independence and role of representation very seriously and endorses the attached submission on behalf of its constituents based on a combination of feedback from individuals and elected representatives of prescribed zones. However, we also concede that as fellow volunteers doing our best with the very limited resources, time and infrastructure we have, the Association has simply not yet been able to consult with every interested individual member within the allocated time.

It is important to note that this challenge would unlikely be overcome with an extension to the DFES consultation period. The fact is that the WA Volunteer Bush Fire Brigades are the largest and most diverse emergency service in Australia’s largest and most diverse jurisdiction. The AVBFB believes that the time and resources allocated to the consultation period was more than adequate to properly engage and consult the career and other DFES managed volunteer services and understands the compromise made in terms of the VBFB service was pragmatic in order to allow DFES to progress its agenda without undue delay.

The goodwill we have demonstrated in providing that concession leads me to introduce the other important theme evident in many of the comments we have provided in the attached submission: the need for greater sensitivity and goodwill when addressing issues of significance to volunteers. In good faith and without intending to labour the point, more than 90% of Western Australia’s emergency service personnel provide their time to deliver an essential service at no cost to the tax-payer.

I have no doubt that fact is widely appreciated within DFES and the broader government. However, I would be remiss in not addressing the numerous examples of insensitive choices of language and failure to better explain the underlying motives of DFES-preferred options in the Concept Paper. While there is broad acceptance within the volunteer community that there is a legitimate need for strong command and control protocols in any emergency service, a great deal of angst and mistrust could be avoided if more DFES communication demonstrated a better understanding of the unique needs of Western Australia’s proud emergency service volunteers.

With no desire to dwell on historical challenges, I offer the above in the context of the AVBFB being committed to providing honest, robust feedback on behalf of our constituents without fear or favour.

In closing, the AVBFB is appreciative of the opportunity to provide feedback at the conceptual stage of the review of current legislation and looks forward to working with DFES and the State Government to ensure the next stage of the process is open, inclusive and resourced in such a way that enables direct consultation with a larger proportion of Volunteer Bush Fire Brigade members.

Yours sincerely,

Terry Hunter

31 July 2014


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