to mr m keelty sa fire & emergency services commission ... · kangaroo island plantation...

Aurora House Suite 816, 147 Pirie Street, Adelaide SA 5000 T (08) 8227 2482 F (08) 8312 2020

kipt.com.au ACN 091 247 166

21 March 2020

To Mr M Keelty SA Fire & Emergency Services Commission South Australian 2019-2020 Bushfire Review GPO Box 2706 Adelaide SA 5001

[email protected]

Dear Mr Keelty,

Submission to the South Australian 2019-2020 Bushfire Review

Kangaroo Island Plantation Timbers Limited (KIPT) welcomes the opportunity to make a submission to the 2019/2020 Bushfire Review. We focus on the Duncan and Ravine complex fires on Kangaroo Island, which occurred between 20 December 2019 and 21 January 2020, but our comments may apply to fire management more generally in South Australia.

KIPT Standing

KIPT is a publicly listed forestry company, registered in South Australia, which owns and operates 14,369 hectares of timber plantations on Kangaroo Island, on a land base of approximately 25,000 ha (including 7,000 ha of native vegetation). Kangaroo Island also has an additional 3,256 ha of plantations, owned by 12 independent grower/investors, who are not formally represented in this submission.

Before the 2019-20 fires, plans to start harvesting the plantations were well advanced, pending government approval for KIPT to build a Seaport at Smith Bay on the north coast of Kangaroo Island. As a result of the fires, 95% of the KIPT plantations, and all the plantations owned by private growers, have been adversely affected.

The total area of KIPT and privately-owned plantations represent about 8% of the 211,000 ha affected by fire on Kangaroo Island. The remaining area comprises family farms, dwellings and tourism infrastructure, and an extensive area native vegetation on private land, crown land and national park. While the 2019-20 fire season was devastating for many communities and individuals across Australia, the impact is probably greater for a small island community like Kangaroo Island, with limited resources and transport constraints which create logistical challenges to fire response and recovery.

KIPT staff and contract fire fighters participated in the fire-fighting campaign between 20 December 2019 and 21 January 2020. As Managing Director of KIPT, I was present during most of the period, and on the fire-line at West End Highway on 3 January with the KIPT team (11 in total), when the fire escaped from Flinders Chase National Park under Catastrophic Fire Danger conditions and burned more than 100,000 ha in several hours.

As a large land manager on Kangaroo Island, KIPT had in the preceding years taken its fire management responsibility seriously, adopting industry standards for plantation maintenance, securing off-island resources and expertise to supplement its local capacity, actively engaging with CFS as an industry brigade, and coordinating with DEW in planning for native vegetation management.



As a professional forester I bring to this submission more than 30 years’ experience in wildfire suppression and management, in both a professional and volunteer capacity. KIPT has commissioned an independent forensic analysis of the fire events between 20 December 2019 and 21 January 2020 by consultants well known in the Australian forest industry and SA fire-fighting sector. This submission draws from first-hand experience of the events of the fire, prior professional knowledge and experience, and the independent forensic analysis.

Impact on our business

Before the fires, KIPT shareholders owned and operated a high-value timberland asset which was soon to be brought into production. KIPT took the precaution to insure the timber crop against fire and is now well placed to continue operating under the changed conditions.

The fires have impaired the value of the current crop of wood products, and capacity of the forests to continue to grow. Nevertheless, salvage of the wood products is still possible if the trees are not subject to further fire damage and harvested in a timely manner. Left unharvested, the fire-affected trees will deteriorate to the point that they are incapable of salvage.

KIPT, along with several mainland companies and government agencies affected by the 2019-20 fire season, is preparing a strategy to recover the fire-affected wood. Unlike our mainland colleagues, KIPT is prevented from sending its product to market until the proposed Seaport at Smith Bay is constructed. This creates additional risk to the KIPT shareholders and independent growers, not shared by the rest of the sector.

The salvage task can only proceed once a port is constructed, and land may only be brought back into full production once the fire-affected trees are removed. In making its investment decisions for the future, KIPT - like its neighbours and the wider community on Kangaroo Island - does not want to see the events of the 2019-20 fire season repeated.

Our submission

KIPT has addressed the terms of reference for the review in Appendix A and a synopsis of the fire events for the period 20 Dec-21 Jan is provided below. In addition, I take the opportunity to reinforce the submission with a statement addressing several recurring themes that have emerged in the public domain, since the fires started on 20th December:

• Timber plantations represent a capital-intensive high-value form of agriculture, because many years of biological growth is accumulated in the forest until the trees reach maturity. Plantation health and the products produced from the trees are sensitive to fire. Owners and managers of timber plantations are motivated to establish risk management strategies including in-house fire-fighting capacity and engagement with neighbours and government agencies on fire surveillance and suppression. It is common for plantation companies to hold some form of insurance against wildfire.

• The science of fire behaviour and the principles of fire management and suppression are well understood. There should be no doubt that the fires on Kangaroo Island before the conflagration on 3 January were containable. A strategy which emphasised suppression through direct attack between 20 December and 2 January, would have likely mitigated or avoided the damages incurred on 3 January. Climate change may exacerbate fire risk, reinforcing the need to modify native vegetation management policies and emphasise direct attack strategies to avoid a repeat of the 2019-20 Kangaroo Island fires.



• Fire behaviour in native vegetation reflects accumulated fuel load and can be mitigated through cool burning for hazard reduction and ecological purposes. Unmanaged native vegetation allows fuels to accumulate and presents a high risk for fire occurrence, and increased difficulty of suppression. Management of native vegetation in proximity to human habitation and enterprises should prioritise community protection, through regular cool burning and direct-attack methodologies.

• Well-managed timber plantations do not present a higher risk of fire compared to other rural land activities. Plantations present a lower risk than unmanaged native vegetation due to the plantation structure and fuel arrangement, and design features such as compartmentalisation with mineral earth fire breaks, and water access points. Direct fire attack in plantations is well accepted to be safe and achievable due to the localised climate effects of the trees and the arrangements of fuel. Back-burning should not be undertaken in plantations unless absolutely necessary.

• Direct attack should be the primary tactic for fire suppression in native vegetation, plantations and farmland. In our view, there is a tendency in recent years for fire-fighting agencies towards risk averse strategies aimed at containment and fallback. This has increased risk of wildfires burning longer and larger during cooler periods in which suppression could have been achieved through direct attack. Larger fire fronts create the conditions in which high-intensity conflagration can occur on Catastrophic Fire Danger days, such as experienced 3 January 2020 on Kangaroo Island. Wildfire burning under Catastrophic conditions cannot be stopped and will consume all flammable materials until a weather change or some geographic obstacle allows for containment.

• Existing powers are already held by local government in South Australia to manage fire risk through establishment of policies and procedures for rural lands. Country Fire Service has the authority to mobilise resources to attack and contain wildfire. In our view, improvements to the application of existing powers should be considered before new powers or laws proposed.

This submission is made on the basis that the South Australia state government, together with the wider community, will support wise and well-reasoned approaches to landscape management and wildfire suppression. The objective should be to reduce the risk as much as possible of uncontrolled wildfires occurring under Catastrophic Fire Danger conditions, as occurred on the 3rd and 9th of January 2020, which in our view could have been largely avoided.

Keith Lamb MFor, GrDip(REM), BForSc, MIFA, GAIDC Managing Director, Kangaroo Island Plantation Timbers Ltd



Situation Response

1 20 – 29 December

Duncan Fire

Lightning strikes cause several fires to emerge on private land.

KIPT was on elevated surveillance 16-20 Dec due to high fire danger, and responded with CFS and farm units when lightning ignited fires emerged 20 Dec. Losses from wildfire to community minimised however concern raised about backburning unnecessarily under plantations and outside Incident Action Plans.

2 30 Dec - 2nd Jan

Ravine 1 Fire

Lighting strikes cause two new fires in national park. High fuel loads contributed to fire behaviour.

Suppression response was hampered by Wilderness regulations and lack of access to national park.

3 Escape of fire north across Cape Borda Rd into plantation and other land.

Failure to suppress fire in national park, and failure to attack spot-overs on Cape Borda Road leads to avoidable losses for plantation owners and local community. Ravine 1 fire continues to burn while Ravine 2 grows in area.

4 3 January

Ravine 2

Escape of fire east across West End Hwy into plantation and other land under Catastrophic Fire Danger Conditions. Parndana is evacuated

Catastrophic FDI due 3 Jan was predicted days in advance. Failure to suppress fire through direct attack in national park prior to 3 January leads to large scale losses to community and plantation owners.

5 9 January

Ravine Complex

Ongoing and uncontrolled large fire area burning under Catastrophic Fire Danger Conditions. Parndana and Vivonne Bay are evacuated.

6 10 Jan-21 Jan Containment and mop-up period. Ongoing containment strategy included backburning under plantations, increased area of plantation affected by fire. Incident of arson reported on or near to KIPT estate.



Appendix A: KIPT’s response to relevant parts of the terms of reference

PREVENTION

1. Reducing Bushfire ignitions

• Electricity Infrastructure;

• Arson and Operation Nomad;

• Machinery and power tools;

• Lightning strikes and detection; and

• Hazard Reduction

In relation to Arson, KIPT makes the following comments.

KIPT plantations were subjected to an alleged arson attack during the fire suppression efforts. The

community of Kangaroo Island should reject this behaviour as unacceptable and not in the best

interests of its safety and wellbeing. Police investigated the incident but no formal report was made.

A community-based campaign which discourages arsonists must be considered for the 2020/21 and

later fire seasons. A strong working relationship with local police is required to ensure an integrated

effort to prevent arson.

Further, it was observed that unauthorised backburns were conducted within plantations and outside

of the approved CFS Incident Action Plans. These activities had the effect of increasing the fire

area, resulting in significant and unnecessary loss of plantation assets, increasing the area required

to be patrolled by the fire crews and in one case cutting off the planned escape routes for

firefighters.

Unauthorised burns of any sort must be investigated by the police to ensure that this behaviour is

not repeated and those involved brought to justice.

In relation to lightning strikes and detection reduction, KIPT makes the following comments.

Our KIPT staff and indeed many farmers and CFS volunteers are well aware of the risks of dry lightning strikes on Kangaroo Island and monitor the lightning trackers which indicate the locations and strikes on Kangaroo Island. During lightning events, the community is actively engaged in surveillance that will identify fire starts at an early stage. Some of the lightning tracking applications provide quite reasonable detail but come at a cost. It would be appropriate that these applications and websites be provided free to the community. This will increase the interest in this monitoring activity and improve the appropriate emergency response to lightning fire starts on the island.

In relation to hazard reduction, KIPT makes the following comments.

Hazard reduction burns in Kangaroo Island in the Wilderness Protection Areas (WPA) are ineffective.

The Wilderness code of management must be reviewed because it fails to recognise that under a

changed climate more fires in the wilderness protection areas are now presenting a real risk to

human life. Fires starting in the WPA have killed 3 people in 12 years.



With climate change, it can no longer be argued that fire is simply a natural part of the environment,

such that conservation values are best served by not fighting naturally-ignited fires. On the contrary,

more frequent and/or more severe fires due to climate change have now become a threat to

conservation values.

The destruction of large areas of wildlife habitat in an extreme fire has seriously compromised the

conservation value of the protected area. The fire history suggests that this may be the new normal,

with higher impact fires and more Catastrophic fire weather days. A strategy to reduce impacts with

ecological burning is now worthy of implementation.

The appropriateness of a fire-prone WPA so close to settled areas also needs to be reviewed. If the

protected area was rezoned as part of the Flinders Chase National Park greater consideration of fire

impacts would be possible.

At the very least, prescribed hazard reduction burns should be undertaken where national park and

WPA borders private land, to reduce the likelihood of uncontrolled intense fire escaping from native

vegetation onto farms, plantations and tourism assets.

Since 2001, only 3,470 hectares of land has been prescribed burnt; at 193 hectares per year this area will have negligible impact on lowering the fuel hazard. An increased and focused strategy to lower the risk is required and has been shown to be effective.

2. Community Preparation and resilience

• Community Education and engagement;

• Home and contents insurance’

• Volunteer training, development, coordination, support and welfare; and

• Farm firefighting units.

In relation to Community Education and engagement, KIPT makes the following comments.

Community concerns that the plantations elevated the fire hazard in the landscape are unfounded in

science and experience. The CFS ‘Plantation Firefighting’ training package recognises this and

demonstrates that fire behaviour is modified when fires approach and enter plantations. The recent

experience on Kangaroo Island shows that fires entering plantations were partly arrested by the fuel

arrangement and the modifications to airflow within the plantations. In some places, the fires did not

pass through the plantations and the farmland downwind was protected. This was also the case in

2007 on Kangaroo Island, where, across a wide front, juvenile plantations completely arrested what

had been a fast-moving wildfire.

It is recognised that, on Catastrophic Fire Danger days, the fires largely burn in a manner controlled

by the wind and atmospheric conditions and are largely independent of the fuel condition. However,

on less severe days, fires are easier to manage in plantations as compared to the native vegetation

due to fuel arrangement and type, access and maintenance of the estates.

There would be great benefit in educating the community in the differences of fire behaviour and

therefore management in plantations as compared to the native vegetation. This may dispel the

fears and rumours that plantations increase risks when it is recognised in firefighting services that

they do not.



In relation to the training and development of firefighters KIPT makes the following comments.

Timber plantation assets require a significant investment over many years before the plantation is harvested and the assets realised. This is very different to a seasonal crop where its loss in one season might allow for a recovery in the following season, subject to infrastructure losses. However, for a plantation asset, the destruction of a 15-year-old plantation will require at least 15 more years of management, care and investment to achieve the recovery of that asset.

There are a number of aspects to consider here and these are summarised below.

Some of the firefighters responding from Kangaroo Island and the mainland were trained in Plantation Firefighting and this training course will assist those responding to fires in and adjacent to the plantations. This course is not mandatory and the competencies are not assessed under a maintenance regime. Without the training, firefighters are not aware of the:

• Value of plantations as an asset in the landscape;

• The reduced fire activity afforded by plantations; and

• The methods of direct attack to fires adjacent to and within plantations.

As we understand it, backburns were carried out through the plantations in the 2019-2020 fires, some of which were not authorised in Incident Action Plans (developed by the Kangaroo Island IMT), and many of which were not effective. This increased the losses of plantation assets unnecessarily and also the loss of other private assets adjacent to the plantations.

Firefighters may not be aware that any fire in a blue gum plantation, even a benign fire, can render it unmerchantable for the markets for which it was grown (i.e. paper making).

More training and awareness of Plantation Firefighting is required across the state.

PREPARATION

3. State Bushfire Plan and State Bushfire Coordinating Committee

• Developing a new state bushfire plan;

• The role of the state bushfire committee; and

• Developing policies and standards to reduce bushfire risk.

In relation to the development of policies and standards to reduce bushfire risk, KIPT makes the following comments

Policies on prescribed burning

We are experiencing a new era of more significant fires in our landscape across Australia. In addition to the changes in climate-induced fire behaviour and frequency, we are expanding our populated areas, which encroach on the rural lands. We must respond to this change and adapt the way we manage land that contains native vegetation. Providing wilderness protection areas is important to the community, but if not managed, it produces an unacceptable risk to life and property.

KIPT considers that there should be more prescribed burning in relevant areas adjoining the occupied and productive lands.



KIPT understands that effective mosaic burns have reduced the intensity of fires on lands adjacent to reservoirs, which had a positive outcome in the 2015 Sampson Flat fires.

Located south of Playford Highway east of West End Highway, there is a block of land containing native vegetation which was subject to a prescribed burn, which demonstrates the positive effects of a hazard reduction burn. The following photo on the left shows the vegetation is largely unimpacted by the Ravine Fire and yet at the perimeter of that prescribed burn the vegetation has been ravaged by the intensity of the Ravine Fire. The area subjected to the prescribed burn shows that it would have provided a safe haven for wildlife to survive and proof that prescribed burning is effective in fire management.

Source: KIPT staff and contractors. These photographs were taken from the same location. Left photo looking south east, right photo looking south west.

Policies on direct attack

KIPT submits that there should be more direct attack in firefighting efforts.

In respect to the native vegetation, early and rapid response to fires with heavy machinery and direct attack fire appliances can keep the size of the fire manageable and reduce perimeter size, enabling the fire to be contained by the resources available. Delays in responding with heavy machinery to secure the edge and create access to the fire perimeter decreases the effectiveness of the limited resources on the island.

It is important to establish a policy within the state plans that allows for this direct attack to happen immediately, as part of the initial response. This should be in all landscapes including Wilderness Protection Areas to protect life and property, and to protect the remainder of the Wilderness Protection Area itself.

The use of aerial attack was limited at the early stages of these fires, the time when it could have been most effective. The use of aerial firefighting on Kangaroo Island is not limited by the access issues experienced by ground resources.

Policies on fire extinguishment ahead of catastrophic fire days

We have experienced the aftermath of a fire being allowed to continue into a Catastrophic day. The Wangary fire of 2005 resulted in the loss of nine lives following a fire that was not extinguished



ahead of Catastrophic fire weather conditions. The Ravine Fire on Kangaroo Island started on 30 December and was not extinguished ahead of the Catastrophic weather conditions of 3 January. Fortunately, there were significant warning messages to the community well ahead of the catastrophic weather presented on the morning of 3 January, but still two lives were lost.

It is incumbent on the community to resource firefighting efforts on going fires ahead of Catastrophic days to make every attempt to extinguish those fires before the weather presents uncontrollable fire conditions. Philosophical debates about the purpose and value of WPAs and the role of fire within them should occur and be resolved now, not while a fire is actually burning, so that decisive action can be taken in real time. That is one of the key benefits of holding an inquiry.

4. State Emergency Management Plan including Extreme Heat Planning

• Review of emergency planning arrangements

No Comments are provided on these issues.

5. State Development and Control planning

• Bush fire zoning; and

• Local government planning, roles in emergency management.

In relation to the bushfire zoning and planning, KIPT makes the following comments

KIPT considers that the planning outcomes have not considered the danger of a large Wilderness Protection Area on the west end of Kangaroo Island and the risks that this creates for the people, assets and businesses that occupy the land to the east and north of the national parks. If the park is to remain relatively unmanaged as compared to farms and other occupied lands, then there is the strong potential for more catastrophic fires. Under a climate change scenario, the intensity and frequency of catastrophic fires will continue to increase. The problem arises where lightning strikes (recorded as more frequent in the Wilderness Protection Areas of Kangaroo Island compared to other areas due to an ironstone ridge) start fires and are followed by a lack of direct attack due to an inability to use heavy machinery to respond to the fires and access the perimeters before the fire can escape.

Fires that escape the western wilderness areas will always have an impact on life and property to the east as the weather changes to a south westerly following a high fire danger day with winds from the north or northwest.

RESPONSE

6. Call taking and dispatch

• 000 and dispatch of resources;

• Preplanning of strike teams; and

• Links to public information and warnings.

In relation to the despatching of resources, KIPT makes the following comments



The remoteness of Kangaroo Island makes all resourcing a challenge. While the current number of fire appliances on the island may be theoretically appropriate for the area of land covered and the assets contained within it, the resourcing is presented with significant challenges related to the ability to scale up resources due to transport and accommodation of crews.

The despatch of additional crews and appliances from the mainland was achieved over time, and it is recognised that the fires that started on Kangaroo Island on 20 December 2019 occurred on a day of significant fire activity in Region One of the CFS, and across the entire state. CFS resourcing was stretched, which delayed the response of adequate resources to the Island.

Further, resources despatched did not include those with adequate Plantation Firefighting skills. Deliberate and value-destructive backburning of plantations occurred where direct attack would have rewarded firefighting operations and outcomes with a smaller perimeter and potentially an easier firefighting activity augmented through the protection of the plantations.

KIPT suggests that the opportunity exists to develop new strategies for managing firefighting resources on the Island, and to include a resourcing doctrine and preplanning policies that allows for rapid increases in resourcing on the island with appropriately aged appliances and with appropriately installed halo/curtains and other crew protection systems.

Further, the resourcing of appropriately trained plantation skilled firefighters will help with plantation assets across the state including the Kuitpo, Peterborough, Mt Gambier, Second Valley and Kangaroo Island plantation areas.

7. Equipment and resources

• CFS/MFS appliances, communications and safety systems;

• Technology such as Automatic Vehicle Location (AVL), mapping, line scanning;

• Aviation resources including Large Aerial Tankers; and

• Logistics arrangements such as Humanihuts and retardant.

In respect to CFS Appliances, KIPT makes the following comments.

KIPT considers that availability of CFS appliances was a limiting factor in the response to the Ravine Fire, particularly due to the significant number of fires that started on 20 December and 30 December. This is included in the submission in section 6 above.

The use of the Kangaroo Island spare ‘34’ appliances that are positioned on the island is a good strategy in theory but they are relatively old and out of date with current fire safety requirements. This is particularly important when they are crewed by mainland firefighters who are unfamiliar with the older appliances and have expectations about industry standard crew safety systems.

The slow response of additional resources from the mainland due to the other fires in the state may have resulted in a lower initial resourcing than otherwise intended as the state marshalled resources to significant fires in multiple locations.

In respect to Aviation resources including Large Aerial Tankers, KIPT makes the following comments.

Aerial attack resources are important in firefighting because of their ability to impact on inaccessible terrain and the potential speed of response.

KIPT considers that the aerial resources responding to Kangaroo Island on 20 December were inadequate for the risks presented and the aerial resources needed. It is understood that aerial



resources were being applied to the Cudlee Creek fire on 20 December (and potentially other fires in the state), but it was noted that aerial attack was not observed on Kangaroo Island until late in the afternoon of Friday 20 December, suggesting that there were insufficient resources available to perform the necessary response to all fires.

Aerial resources can make an initial attack which will slow the spread of fire before ground crews respond for direct ground attack, and heavy machinery makes supporting breaks. The use of large aerial tankers (LAT) incurs significant cost at the expense of a smaller more mobile fleet that can be shared across the state when multiple fire locations are presented.

It may be more appropriate to direct the LAT funding into more of the lighter aircraft to allow for a more expansive coverage of aerial attack across the state and therefore support more fires in more locations.

8. Incident management and emergency coordination

• Incident management teams and facilities;

• Operational alignment of control agency and the State Coordinator;

• Functions and coordination between the State Control Centre, State Emergency Centre, State Emergency Information Call Centre Capability (SEICCC) and the State Crisis Centre; and

• Reporting to government.

In relation to the matter of Incident Management Teams and facilities, KIPT makes the following comments

The initial Incident Management Team on the Duncan fire was staffed by volunteers, before being replaced by some Level III IMT Resources from Adelaide. The IMT set up for the Duncan and Ravine Fires was initially understaffed, creating an opportunity for the fire to potentially grow to a size larger than it might otherwise have been.

Whist the Level III IMT people were performing admirably, there was clearly a need to add additional resources to be able to maintain an appropriate IMT level that could manage the fires ahead of the Catastrophic fire day of 3 January.

It would appear that the CFS was challenged in being able to manage multiple Level III IMTs operating across the Region One area (including Cudlee Creek and Kangaroo Island), and the ability to manage multiple fires on Kangaroo Island including Duncan, Menzies and Ravine as well as other smaller fires on 20 December.

It is suggested that the CFS reviews strategies to be able to manage multiple incidents as the frequency of significant fires increases with the acknowledged changes in climate outcomes.

The use of a Forestry Liaison Officer role is not consistent across the state. It is used successfully in the Green Triangle region but is not embedded in CFS doctrine to ensure it is used wherever appropriate. KIPT directors and contractors were at the IMT headquarters trying to fulfil this role but were not always recognised by the Incident Controller, Operations and Planning Officers. At one stage our staff were asked to leave the IMT to make more space.

Sectors that contain plantations need special recognition in Incident Management Planning. CFS sector commanders on the ground in locations that include plantations should have experience in plantation fire-fighting or ready access to such expertise, on the fireground. Local knowledge about the location of firebreaks and water sources is more important due to the greater intensity of features in a plantation landscape.



9. Pubic Information and Warnings

• Alert SA;

• Information Management systems to support improved messaging; and

• Coordination across Government messaging.

In relation to the matter of Alert SA, KIPT makes the following comments

It is understood that AlertSA only provides push messages when warnings are issued, rather than all fires. It would be appropriate that occupants and land owners be able to receive a warning message on their AlertSA app for any bushfire in their user defined alert area. This would assist in early notice to the community, which can respond with farm firefighting units, other land owners to be alerted to bushfire emergencies and other interested parties (such as asset owners) who may be impacted. This would take place early and upon the initial response to a bushfire, before the time is taken to assess if a warning message is required.

10. Interstate Deployments

• Support to other states; and

• Coordination of resource sharing arrangements.

No Comments are provided on this issue.

RECOVERY

11. Rapid Damage Assessment,

• Aerial surveillance and remote pilot aircraft; and

• Messaging of damage impact.


12. Transitional arrangements to recovery

• Australian Defence Force Support;

• Commonwealth Assistance; and

• Leadership and Coordination.


to mr m keelty sa fire & emergency services commission ... · kangaroo island plantation...

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