MAINTAINING THE EFFECTIVENSS OF BUSHFIRE PLANNING AND BUILDING REQUIREMENTS THROUGHOUT THE LIFE OF A DEVELOPMENT. Debbie Pinfold 1

MAINTAINING THE EFFECTIVENSS OF BUSHFIRE PLANNING AND BUILDING REQUIREMENTS THROUGHOUT THE LIFE OF A DEVELOPMENT Debbie Pinfold 1 1 Sutherland Shire Council, NSW, Australia DPinfold@ssc.nsw.gov.au Paper Presented at the Planning Institute of Australia 2012 National Congress / 29 April 2 May 2012 / Adelaide, South Australia 1

Planning and building regimes in many Australian jurisdictions now routinely require development in bushfire prone areas to incorporate a range of bushfire protection measures, namely defendable space largely cleared of combustible vegetation, access, water supply, and bushfire construction standards. While it has been widely accepted that ongoing maintenance is essential to ensure that these bushfire protection measures remain effective for the life of the development, little practical consideration has yet been given as to how this can be achieved. The 2009 Victorian Bushfires Royal Commission, arguably the first inquiry to look more closely at the issue of ongoing maintenance, concluded that: It is imperative that the conditions that exist at the time of a planning or building approval, such as the required defendable space or the bushfire attack level of the site, are maintained to provide for continued bushfire risk management. Ensuring that this occurs is, however a challenge in both the planning and building regimes (Section 6.13 in volume 2 of the 2009 Victorian Bushfires Royal Commission findings). This paper examines the key practical challenges in ongoing maintenance of bushfire protection measures and examines the role of the planning and building process in meeting these challenges: 1. Allocating responsibility and resources for enforcing ongoing maintenance. 2. Recording of ongoing maintenance requirements in a way that is understandable and readily accessible. 3. Giving adequate consideration to the feasibility of ongoing maintenance in both strategic planning and the development/building process. 4. Integration of ongoing maintenance into the broader risk management framework. INTRODUCTION The benefits of designing residential developments in areas of high bushfire risk to provide in built protection from bushfires have been recognised for a number of decades now. For example, in NSW planning policy documents have advocated that the design of new subdivisions incorporate a setback between dwellings and the bushfire hazard (now called a defendable space or an asset protection zone) since the late 1960s. Numerous studies and inquiries following major fires have subsequently expanded the range of in built bush fire protection measures to include bush fire construction standards for residential developments, water supply and access requirements; and also lead to the introduction of schemes to formally identify bushfire prone lands to which such requirements apply. We are now at the stage where most planning and building regimes across Australia routinely require developments in designated bush fire prone areas to incorporate a range of in- built bush fire protection measures, and at a more strategic scale, also 2

require the bush fire risk to be taken into account when determining the suitability of a locality when rezoning for residential development. For almost as long as the value of in-built bush fire protection has been recognised, the need for ongoing maintenance of these bushfire protection measures has also been acknowledged. Such ongoing maintenance has largely been left in the hands of the owners or occupiers of affected properties. The principle that owners and occupiers are responsible for bushfire maintenance is no different to the principles applying to other forms of property maintenance. If you own a property, or occupy it, you usually have responsibility for ensuring that the development remains habitable and safe. Our planning and building approval systems, which deal primarily with the initial construction of a development to the required standards, are based on this very assumption. Where it is possible to apply conditions relating to ongoing maintenance of a development, it is generally assumed that these conditions will be complied with, (as for other conditions of consent), and as such any enforcement regimes are generally reactive and complaints driven. However, in the case of the ongoing maintenance of bushfire protection measures, we are expecting the owners and occupiers of a property to conduct a level of maintenance which in many circumstances is significantly greater than that which would be necessary for the general upkeep of a property located outside of a bushfire prone area. For example, in Sutherland Shire, the minimum lot depth required for a standard residential lot is normally 27 metres. This lot depth generally provides for a separation of less than 10 metres between the dwelling and the front and rear boundaries. However, on the urban bushland interface of Sutherland Shire, our combination of ridge top development and forest vegetation means that a new subdivision would generally require an asset protection zone (or defendable space) between the dwelling and the hazard extending for some 60 metres. While the road reserve may account for some 18 metres of Asset protection zone, this still often leaves 42 metres depth to be managed to the standard necessary for an asset protection zone within the property, which represents a significantly greater maintenance burden for the owner/occupier than normal. Further, it is not easy for owners or occupiers to understand the requirements which apply to their property. Planning/building regimes provide specific information about ongoing maintenance of a property which is often only at the time of initial construction of the development, or upon its sale. The information provided is usually not written with the end users in mind. Lastly it is important to remember that the owners and occupiers responsible for this ongoing maintenance are, by and large, ordinary householders, with varying levels of understanding and experience in bushfire situations, and varying capabilities (financial, physical, time etc) to maintain their dwelling and surrounds to the standard necessary to provide the intended level of bushfire protection. 3

When the above factors are taken into account, it is evident that owners or occupiers will be unlikely to maintain the bushfire protection measures incorporated into their property without significant outside intervention. The question which arises is what form this outside intervention should take, and what role planning and building approvals regimes should play in facilitating ongoing maintenance. FACILITATING ONGOING MAINTENANCE The Victorian Bushfires Royal Commission was arguably the first inquiry to take a more detailed look at the difficulties involved in ongoing management of bushfire protection measures applied through the planning and building regime. The Royal Commission concluded that: It is imperative that the conditions that exist at the time of a planning or building approval, such as the required defendable space or the bushfire attack level of the site, are maintained to provide for continued bushfire risk management. Ensuring that this occurs is, however a challenge in both the planning and building regimes 1. The Royal Commission findings recommended a number of initiatives to meet this challenge, including: Point of sale bushfire checks in relation to the bushfire safety of the site and building they propose to purchase, using market forces to encourage maintenance and increase awareness (Recommendation 53). Development of mechanisms for checking and facilitating compliance with planning permit conditions for defendable space, access and water supply both initially and over the life of the development; (Recommendations 52 and 54). Ensuring through the planning assessment process that the ongoing maintenance of the required bushfire protection measures is feasible (Recommendation 40) Introduction of controls to allow for and guide removal of native vegetation to mitigate bushfire risk (Recommendation 41). The recommendations were based on the specific circumstances arising through the Victorian planning system, but can be used to identify a broad conceptual framework for consideration of ongoing maintenance programs not only in Victoria, but across the country, as follows: 1. Targeted Education - Targeted education about the bushfire safety and maintenance requirements specific to individual sites and buildings, at appropriate intervals. 2. Monitoring and Enforcement - Development of mechanisms for checking and facilitating compliance with planning approval conditions for defendable space, access and water supply both initially and over the life of the development. 3. Design for Sustainable Maintenance Giving adequate consideration to the feasibility of ongoing maintenance in the planning assessment process. 4

4. Removing legislative barriers to ongoing maintenance particularly ongoing maintenance of native vegetation. KEY PRACTICAL CHALLENGES FOR ONGOING MAINTENANCE In using these principles to design and implement a practical system for ongoing maintenance, some key, and interrelated issues need to be addressed. These are: 1. Allocating responsibility and resources for enforcing ongoing maintenance. 2. Recording of ongoing maintenance requirements in a way that is understandable to the end users and readily accessible to those responsible for conducting, encouraging and enforcing ongoing maintenance requirements. 3. Giving adequate consideration to the feasibility of ongoing maintenance in both strategic planning and development/building assessment processes. 4. Integration of ongoing maintenance into the broader risk management framework. My experiences in implementing bushfire planning controls within Sutherland Shire Council, a bushfire prone local government area on the southern outskirts of Sydney, are used to illustrate the discussion of the above mentioned points. Appendix A provides a brief overview of Sutherland Shire and its bushfire planning requirements. Allocating Responsibility And Resources for Enforcing Ongoing Maintenance. Central to the above mentioned findings of the Royal Commission was the acknowledgement that, while owners/occupiers might have the ultimate responsibility for ongoing maintenance of bushfire protection measures imposed through planning and building regimes, this is unlikely to occur to the required levels without external intervention. It is therefore necessary to identify who will be responsible for undertaking enforcement action and how such action will be resourced. There are a number of possible approaches, depending on factors such as whether ongoing maintenance of bushfire protection measures is seen primarily as a matter for enforcement as part of the planning/building approvals regime, or whether a broader risk management approach is adopted. The underpinning fire agency legislation, and its allocation of hazard management responsibilities on private land is likely to be another factor in determining the approach taken within a jurisdiction. Such differences are evident between the approach being implemented in Victoria following the Royal Commission, and that in New South Wales. In implementing the findings of the Royal Commission in relation to the enforcement of planning permit conditions relating to defendable space, access and water supply, Victoria have produced a planning policy allocating roles and responsibilities 5

for compliance with bushfire planning permit conditions 2. This policy appears to view ongoing maintenance as an extension of Victoria s planning system and places the primary responsibility for promoting compliance with permit conditions on the Councils. Suggested mechanisms include raising awareness of the need for ongoing compliance, an active system of compliance checking and enforcement using Victoria s Planning system. While the issue of a fire prevention notice under the Country Fire Authority Act is also mentioned, the guidelines state that the use of a fire prevention notice is not a substitute for enforcement actions under the Planning and Environment Act. Instead, municipal fire prevention officers are encouraged to notify their planning enforcement unit if they believe planning requirements are not being complied with. In New South Wales, no formal policy position has been confirmed in recent years. However, a review of historical documents indicates that the planning system was intended to facilitate the initial establishment of bushfire protection measures, with ongoing maintenance (of vegetation in defendable space at least) achieved by other means. For example Circular 74 Planning in Bushfire Prone Areas published by the NSW State Government in 1982 acknowledged that while the imposition of planning controls is covered by the Environmental Planning and Assessment Act, 1979, the effective maintenance of these controls will depend on a variety of legislative powers contained in other Acts, among them the Bush Fires Act, the Local Government Act and the NSW Fire Brigades Act. Sutherland Shire Council has always relied upon this approach for the ongoing management of defendable space on private lands, which has been in our experience, the most frequently occurring ongoing maintenance issue. Council uses the hazard management provisions for private property contained with the Rural Fires Act, 1997 and its predecessor, the Bushfires Act, 1939 for the enforcement of vegetation management within asset protection zones (defendable space). Currently, the provisions of Section 66 of the Rural Fires Act, 1997, where bushfire hazards are identified on private lands, allow for the issue of a bushfire hazard reduction notice by the local authority requiring the owner or occupier of that private land to carry out bushfire hazard reduction work. Section 70 of the Rural Fires Act permits the necessary bush fire hazard reduction work to be carried out if the owner or occupier fails to comply with the notice in the specified time frame, and recover the cost as a debt from the owner or occupier. This legislation applies regardless of whether or not the hazard results from the failure of the responsible land owner to maintain an asset protection zone formally established under planning legislation. Given the existence of hazard management provisions in the Rural Fires Act, 1997, any failure to maintain the APZ over the long term, would not be followed up using the enforcement provisions of the Environmental Planning and Assessment Act, 1979. The pathway to achieving the removal of the hazard (which is the ultimate aim of enforcement action) is far more direct and less litigious under the Rural Fires Act, 1979, than using the compliance provisions available in the Environmental Planning and Assessment Act, 1979. 6

Similarly any ongoing education on maintenance of properties has occurred through the educational programs of the Rural Fire Service, through the Bushfire Risk Management Plan. NSW has yet to formally address ongoing compliance with requirements other than bushfire hazard reduction, and the legislative provisions in NSW complicate such considerations. For example, the consideration of bushfire matters and imposition of requirements for residential subdivisions is generated by the need to obtain a Bushfire Safety Authority from the Commissioner of the Rural Fire Service, is a requirement under the Rural Fires Act, 1997. Whether responsibility for enforcement of ongoing maintenance rests with Councils, the fire authorities, or a combination of both, the issue of how to resource ongoing maintenance exists. Both fire agencies and councils have a wide range of inspection and enforcement responsibilities, and limited resources, which have to be prioritised between various competing interests. Just as with the owners and occupiers themselves, the amount of time and money spent on educating, inspecting and enforcing the ongoing maintenance of bushfire protection measures will be subject to perception of the risk and competing priorities. It is therefore important to prioritise education, inspection and enforcement programs to ensure the available resources are targeted to areas of highest risk and compliment other bushfire risk management strategies being undertaken by fire and land management agencies. An approach which considers ongoing maintenance as part of the overall bushfire risk management strategy for an area is discussed later in this paper. Perhaps as part of such an overall bushfire risk management plan, agencies need to look at which parts of the bushfire risk management process they can best contribute to. It may be that hazard accumulation within defendable space is best managed under fire service legislation, as any other bushfire hazard would be, but planning or building legislation be used to enforce compliance with conditions relating to built form which cannot be enforced by other means. The Royal Commission also recommended an approach using point of sale bushfire checks to provide follow up for bushfire requirements contained within building permits; illustrating the range of strategies and responsibilities necessary to achieve ongoing maintenance. The importance of minimising the need for extensive enforcement activity through good up-front design is also highlighted when resourcing implications are taken into account. Good up front design which makes it more likely that the owners and occupiers will carry out the necessary work with minimal intervention, as discussed later in this paper. Recording Of Ongoing Maintenance Requirements In A Way That Is Understandable And Readily Accessible 7

The starting point for any education/enforcement/ risk management regime is the availability of an understandable, easily accessible and consolidated record of the bushfire protection requirements that apply to each property. However, the planning and building system tends to provide information about ongoing maintenance to owners and occupiers at the time at which the proposed development is being designed and approved. Further, the information is usually stored in a way which is not easily retrieved in later years when ongoing maintenance becomes necessary, and is often written in a legalistic way which is difficult for owners or occupiers to interpret. For example (in NSW at least): 1. All formal information about ongoing maintenance of the bushfire protection measures applying to a specific property are provided at the time of the initial development/building proposal: General Guidelines for subdivision or building in Bushfire Prone Areas are usually only referenced at the design stage, and often only by the designers and not the ultimate occupants. Planning/building approval conditions may also require for ongoing maintenance of the bushfire protection measures required under that approval, but particularly for dwelling houses, these too, are usually only looked at during the actual construction phase. The purchaser of an already constructed property may never see these conditions, neither may a tenant of a property. Similarly information contained on the title of the property, is in my experience, associated by most land owners as a source of information identifying building restrictions which apply to a site. As such they are likely to be acknowledged only at the time of property purchase or dwelling construction, and are unlikely to be used by the land owner as a source of information about ongoing maintenance. Further, tenants would most likely never have access to this information. Planning certificates obtained at the time of sale of a property only advise whether the land is bushfire prone or not. Such information is relevant to most people only when they lodge an application for planning or building approval. Even if a planning certificate triggered someone to inquire about the steps necessary to make their property safe from bush fire, they would normally turn to the general bushfire safety education material provided by the fire agency. Such information usually only provides generic and simplified guidance on property and bushfire maintenance, and the specific bushfire protection requirements imposed on a particular property through the planning and building process are often far more onerous than those indicated in this material. 2. In addition, planning and building approval regimes are unlikely to provide a consolidated record of all ongoing maintenance requirements applying to a property. For example, bushfire conditions are often spread over multiple 8

approvals and time periods - such as approvals for subdivision, initial dwelling construction, and later additions, issued by Councils and private certifiers. It is also often difficult and time consuming to retrieve historical files and compile a comprehensive list of the bushfire protection measures required on the property, when the development history stretches back over 20 years or so. Even within the one development approval, the applicable bushfire management requirements may be spread over multiple documents such as the written conditions, the approved plans, and a plan of management dealing with environmental and bushfire management. In my experience, it is difficult for the average planner to make sense of these requirements a few years down the track, let alone a resident. 3. Further, approval conditions and information on title are often written in a way which is not easily interpreted by land owner/occupiers. For example, a condition which requires an asset protection zone to be maintained in accordance with the specifications contained in Planning for Bushfire Protection, 2006, means little to a resident and requires additional research to determine what this actually means. 4. Information sharing between fire and planning agencies is often limited. Yet it is the fire agencies who are usually approached when land owners/occupiers need information about how to protect their properties from bushfire and are often in the best position to provide such ongoing education. For example in NSW, Councils are required to send copies of approvals for subdivisions or other specified forms of vulnerable development to the head office of the Rural Fire Service; however, this information is not passed on to the local district offices involved in education, enforcement and fire suppression planning. Further, for single dwellings or alterations and additions, there is no legislative requirement to send copies of approved plans and conditions to the Rural Fire Service. Councils and Fire agencies should examine ways of storing and sharing records of approval conditions relating to bushfire protection measures for individual properties, to aid the easy retrieval of this information in 50 or so years time. Ideally, an information register recording in plain language, the bushfire requirements applying to each property, needs to be established. Conditions of approval and provisions for inclusion on the property title also need to be written with the future in mind. Will they be easily understood by planners, fire 9

agencies and residents (and lawyers and planning appeal commissions) in 50 years time? Giving Adequate Consideration To The Feasibility Of Ongoing Maintenance In Both Strategic Planning And Development/Building Assessment Processes. When the limited availability of monitoring and enforcement resources is taken into account, self regulating design becomes a critical component of any ongoing maintenance system. Having observed the level of maintenance of defendable space in Sutherland Shire over the last 15 or so years, it is evident that the most effective method for ensuring ongoing maintenance is to ensure that the design of bushfire protection measures makes it easy and achievable by the future occupants, with the resources available to them. This is best achieved by designing the defendable space for a dual purpose so that its maintenance facilitates everyday use of the space, rather than its sole provision for protection against a possible future bushfire event. Defendable space is unlikely to be maintained where the extent of work involved is significantly greater than that required for normal household maintenance. I have observed for example, that when part of the defendable space is bushland, and the sole purpose of management is for bushfire protection, it is unlikely that those responsible will conduct the necessary maintenance work unless compelled to do so. Steeper topography, which increases the difficulty of ongoing maintenance, also appears to be a significant disincentive. Planning proposals, whether at a strategic level, or for an individual development should be required to demonstrate that the proposed bushfire protection measures (particularly defendable) will be designed and sited so that the future occupants of the development who are responsible for their ongoing maintenance can readily conduct the maintenance with the tools and resources reasonably likely to be available to them. A more proactive approach should also be taken when fire agencies and other expert bodies recommend future amendments or additions to bushfire protection requirements, to ensure that the long term maintenance of new or modified bush fire protection initiatives recommended by these expert bodies will be feasible; and that our system is not relying upon flawed assumptions that ongoing maintenance will occur. For example, Australian Standard AS3959-2009 Construction in Bushfire Prone Areas, in its scheme for determining the bushfire construction standard that should apply to a dwelling, assumes that there will be virtually no vegetation between the development and the assessed vegetation. 3 This is a flawed assumption if, over the life of the development, vegetation is not managed in the defendable space and a bushfire hazard recurs, as the level of construction provided may no longer be adequate for the level of bush fire risk. Integration of ongoing maintenance into the broader risk management framework. 10

Planning and building approval regimes may effectively provide for the initial establishment of bushfire protection measures within a development; but are not well designed for the systematic long term monitoring and enforcement of their provisions. In my experience, there is a general assumption that approval conditions will be complied with and enforcement for non compliance with planning or building conditions is often complaints driven, reactive and resource intensive. Where ongoing public safety matters are recognised to arise from the approval of a particular form of development, ongoing monitoring and compliance with safety requirements is usually managed under separate legislation, outside of the planning and building approvals regime. Consider for example, matters such as building swimming pool fencing, food safety, building fire safety and pollution licensing. Similarly, ongoing maintenance of bushfire protection measures which contribute to increasing the resilience of communities to bushfires, could be viewed as part of a broader bushfire risk management strategy. Ten or twenty years or more after a development is first occupied, it will be necessary to educate land owners/occupiers about how to maintain their properties to minimize the bushfire risk, and to identify situations where the risk is not being properly managed and take steps to rectify the situation - whether or not their property has in-built bushfire protection measures. The ongoing maintenance of bushfire protection measures needs therefore to be considered as an integral part of an overall bushfire risk management planning scheme and recognised as a strategy that is distinct from their initial establishment under planning and building legislation. Such an approach does not excuse land owners/occupiers from their responsibility, but does allow a systematic approach to bush fire risk management across the community. The existence of in-built bushfire protection measures should however, mean that the level of bushfire risk can be more easily managed than on properties where no in built protection exists. For example there should be no legislative impediment to the ongoing management of vegetation as required by the initial planning approval; the creation of a defendable space of adequate size should be possible; and only minor maintenance rather than extensive retrofitting required to ensure the dwelling provides the necessary level of protection. With improved information management systems) it may be possible to feed into education campaigns run as part of an overall bushfire risk management plan, by providing specific advice on how individual properties need to be maintained, based on the previous planning and building approval conditions. CONCLUSION Planning and building approvals regimes have a significant role to play in the initial establishment of developments which incorporate in-built protection from bush fires. They can also have a significant role, in facilitating the ongoing maintenance of these in built protection measures by: 11

1. Ensuring through the assessment process that ongoing maintenance of the required bush fire protection measures will be possible by those responsible, with the equipment available to them. 2. Designing bushfire protection measures with ease of ongoing maintenance in mind. 3. Allowing ongoing management within defendable space without need for further approvals to remove vegetation. 4. Providing information on the bushfire protection measures required in a way which can be easily shared between fire and planning/building agencies both at the time of approval and over the life of the development; and in a form that is able to be understood by the owners/occupiers ultimately responsible for the ongoing maintenance. However, the ongoing maintenance of bushfire protection measures through the enforcement provisions of the planning/building approval regimes is unlikely to provide for the effective ongoing maintenance of the bushfire protection measures. Once the development has been established, ongoing maintenance needs to be considered as an integral part of an overall bushfire risk management planning scheme. 12

APPENDIX 1 OVERVIEW 0F SUTHERLAND SHIRE COUNCIL BUSHFIRE PLANNING REGIMES Sutherland Shire Council is located on the southern outskirts of Sydney. It is an urban area, characterised on its periphery by ridge top developments, interspersed with heavily forested valley systems. Sutherland Shire has a history of significant bushfires, with major fires having occurred throughout the Shire during: 1938/39, 1944, 1954, 1956/57, 1967/68, 1768/69, 1974/74, 1976/77, 1979/80, 1983, 1988, 1989, 1994, 1997, 2001 and 2002. 4 Significant house loss occurred in the 1994 fire season, where 103 dwellings were destroyed in the Shire. A further 10 dwellings were destroyed in both the 1997 and 2002 fire seasons 5. Since the early 1970s, Council has had a number of bushfire development policies and plans, which required new subdivisions on the bushland fringe to incorporate Asset Protection Zones, perimeter roads or fire trails and enhanced water supply. Since the 1994 bushfires, Council has also introduced bushfire construction standards, which were seen as particularly important in those suburbs developed prior to the introduction of bushfire subdivision controls. Initially, our subdivisions required defendable space consisting of a highly modified inner area incorporating larger front or rear yards and the adjacent road or fire trail reserve; with an outer area of modified bushland, situated on public land beyond. In recent years, increased litigation, and reduced public resources have driven a change in subdivision design, where the whole of the defendable space, and any associated fire trail are to be wholly within the subdivision and managed by the owners/occupiers of that subdivision. Ongoing maintenance of defendable space in public ownership occurs as part of the Bushfire Risk Management Plan, or its predecessors. As such its ongoing maintenance is planned, and its execution reported upon. Ongoing maintenance of defendable space in private ownership is managed through the Rural Fires Act, 1997. Where a hazard develops, and is identified on privately owned defendable space, its maintenance has been enforced using the private property hazard management provisions in the Rural Fires Act, and the Bushfires Act before it. In this, Council is assisted by the Rural Fire Service, who now have responsibility for issuing of hazard reduction notices and ensuring compliance with these notices. When it comes to building maintenance, there is also no formal ongoing maintenance regime. The normal building certification helps to ensure the building when first constructed incorporates the required bushfire protection measures. However, after this, it is expected that the building will be maintained in this condition by the owners or occupiers. Council s Compliance staff act on any complaints, and when illegal works are carried out in bushfire prone areas and are careful to check the bushfire implications of such works. But there is no formal inspection and maintenance regime and such a regime is considered beyond the resources of Council. 13

Disclaimer The views and opinions expressed in this paper are those of the author and do not belong to and do not necessarily reflect the views and policies of Sutherland Shire Council. 1 2 3 4 5 2009 Victorian Bushfires Royal Commission Findings - Section 6.13 in volume 2 Department of Planning and Community Development Roles and responsibilities for compliance, 02 February 2012 and Promoting compliance with permit conditions 01 February 2012 Page 5 Victoria Department of Planning and Community Development Advisory Note 44 Defendable space in the Bushfire Management Overlay, 2012. Sutherland Shire Bush Fire Risk Management Plan, 2009. Information provided by Sutherland Shire Rural Fire Service District Office This paper also builds upon the following unpublished papers previously presented by the author: 1. 2009 EPLA Conference: Bushfire Protection Measures Will They be There When Needed? 2. 2011 AFAC Conference: Ongoing Maintenance of Bushfire Planning and Building Requirements: Maintaining Awareness and Action in 10, 20, 50 Years Time? Ongoing Maintenance of Bushfire Planning and Building Requirements: Maintaining awareness and action in 10, 20, 50 years time? 14