Addressing stakeholder feedback

All formal submissions were acknowledged in writing by the Chair of the Panel upon receipt. The Panel have addressed stakeholder feedback below.

Legislative remit

The Panel understands that fire agencies provide many services beyond fire, however its legislative remit is focused on the review of fire risk across Victoria, and the provision of fire services by fire agencies.

Section 4 of the Act is specific to the Panel’s limited remit:

  • Section 4F(b) – change in fire risk
  • Section 4H(a) and (b) – change in fire risk
  • Section 4J(1) – provision of fire services by fire service agencies
  • Section 4J(2) – change in fire risk
  • Section 4J(4) – change in fire risk, and
  • Section 4K – change in fire risk.

Further, section 32A of the Act references ‘alarm of fire’ which covers assistance related to a:

  • fire
  • accident
  • explosion, or
  • other emergency.

Fire, explosions and accidents where fire is a risk will be incorporated into the Panel’s methodology.

Although non-fire considerations are outside the Panel’s formal recommendations, its final report will comment qualitatively on broader responsibilities that are beyond a ‘change in fire risk’. These responsibilities include Emergency Medical Response (EMR) and other fire agency services, which the Minister may need to consider.

In making a determination on the Panel’s review, section 4M(2) of the Act requires the Minister having regard to the following before instigating any legislated changes to the FRV fire district:

  • the capacity of the fire services agencies to perform its statutory functions and duties
  • the implications for the budget and resources of the fire services agencies
  • the implications for the budget and resources of the emergency management sector, and
  • other implications for the emergency management sector.


By examining historic fire incidents, existing resources and whether the relevant Service Delivery Standards (SDS) are being met, the Panel will ascertain the areas around Victoria that are experiencing an unacceptably high level of fire risk. The inaugural review undertaken by the Panel will establish a fire risk baseline for Victorian communities.

Where boundaries are changed, fire agencies remain responsible for determining appropriate fire station capacity and capability responses (such as personnel training or adjustments to fire-fighting equipment). Planning for the viability of new stations falls within the remit of the Department of Justice and Community Safety.


Feedback from stakeholders regarding data was varied, ranging from suggestions of what to include, who to consult, how to calibrate and manage the data. Fire and explosion data is being used by the Panel to undertake the assessment of risk. A complete description of fire and explosion and an outline of all incidents encompassed will be available in the final recommendation report.

The Panel has access to all fire service incident data, including EMR, high angle rescue, urban search and rescue and trench rescue. Broader consideration of these incidents and the risk they pose may be commented on in the Panel’s final recommendation for further consideration by the Minister.

Similarly, false alarms and hoax calls are being considered by the Panel but will not be used to calculate risk. The Panel are investigating this data to understand the overall workload of each fire agency and their subsequent ability to respond to risk.

The outcome of each fire incident (or impact) will be explored in terms of casualties (injury plus fatalities) of fire brigade personnel and members of the public. Only casualties recorded at the time of the fire [1] will be examined, due to difficulties in obtaining coronial data. Property losses and/or economic losses as a result of fire will not be considered by the Panel.

Australian Bureau of Statistics (ABS) datasets have been used to explore fire risk patterns in communities. These include 2016 Census data relating to population and households and derived indices, such as Index of Relative Socio-economic Advantage and Disadvantage (IRSAD). Relevant data from the 2021 Census isn’t currently available for use in this analysis.

Population projection data is also being used in the analysis. Planned future residential, commercial and industrial precinct spatial data have also been incorporated into the methodology.

Consideration of climate change is limited to bushfire risk. The Panel relies on risk outputs from the Department of Environment, Land, Water and Planning’s (DELWP) Forest, Fire and Regions group, which considers fuel reduction activities and encompasses both public and private land. Bushfire risk will be integrated into the Panel’s methodology. Other bushfire related datasets being considered, include the Bushfire Risk Register, bushfire management overlay and bushfire prone areas. Additional climate change data such as changes in building construction are not considered due to the difficulty in obtaining the related datasets.

With respect to qualitative data, the Panel is considering its integration into the methodology. A range of qualitative data was suggested, with reference to prevention, preparedness and recovery information.

Any perceived shortcomings in data availability, consistency or quality will be noted by the Panel in the final report for fire agency and Minister consideration.

Capacity and capability

The Panel recognises that standards of fire cover [2], represented by capacity and capability data vary between organisations. These differences in standards of cover are not examined to determine if they manifest risk, rather, the Panel seeks to gain an overall view of state wide risk with the current settings in place.

The Panel understands that fire incident response times are calculated differently by the fire agencies. Suggestions to use Emergency Services Telecommunications Authority (ESTA) data to calibrate the response time were considered. However, the Panel is assessing risk based on the individual agencies’ ability to service the risk. The Panel is not normalising the calculation of response time in order to do this.

Surge capacity during bushfires is the responsibility of the fire agencies. In particular this will be a consideration for the Country Fire Authority (CFA) to advise the Panel further over the course of the review.

Guidelines and standards

The National Emergency Risk Assessment Guidelines (NERAG) are focussed primarily on emergency risks and provide general guidance on management frameworks and approaches.

These guidelines have been adapted from the Australian risk management standard AS ISO 31000:2018 Risk management - Guidelines (ISO 31000:2018).

The Panel have developed a risk assessment methodology that aligns with these guidelines and is considered a ‘best practice’ approach. ISO:31000 and NERAG define risk as “the effect of uncertainty on objectives”.

Our risk nomenclature, outlined in Appendix A: Theoretical risk overview, may vary from the guidelines, but it has been adopted to align datasets and make the quantitative process more understandable across a broader range of stakeholders.


[1] Fire incident data includes attribute information such as:

  • location of fire incident
  • response time
  • standard response time
  • casualty, and
  • property loss.

This information is recorded at the time of the incident.

[2] Response capability in terms of time and on-scene performance for personnel and equipment