1.1 ADMINISTRATION OF THE ESL

DFES is currently responsible for ESL administration under pt 6A of the Fire and Emergency Services Act. Recommendation 48 of the A Shared Responsibility: The Report of the Perth Hills Bushfire February 2011 Review (Report on the Perth Hills Bushfire) [1] was that the responsibility for the management and distribution of the ESL be moved to the Department of Finance.

DFES PREFERRED OPTION

1.1.1 Responsibility for administration of the ESL to remain with DFES

AVBFB PREFERRED OPTION

1.1.3 Responsibility for administration of the ESL to be handed over to an independent third party

AVBFB comments:

The inevitable perception that a conflict of interest exists when a decision maker is also a potential beneficiary of the decisions being made is, at least, extremely unhelpful in creating an outcomes-based, open culture among the various stakeholders in WA’s emergency services.

While the AVBFB accepts that there may be some inefficiencies in an independent third party administering the ESL, it contends that the benefits of eliminating any potential of DFES being seen as having either a perceived or actual conflict of interest would far outweigh the cost of doing so.

OTHER OPTIONS NOT SUPPORTED

1.1.2 Responsibility for administration of the ESL to be handed over to another government agency

 


 

1.2 ESL FUNDING MODEL AND REVENUE STREAMS

A key part of the ESL methodology outlined above is the division of land into different ESL category areas based on the services available in that area.

Currently there are two types of boundaries in the emergency services legislation 1) ESL category areas; and 2) Fire Districts.  The potential abolition of Fire Districts is discussed in Chapter 2 Administration and Miscellaneous Provisions.  This section deals with ESL category areas.

DFES PREFERRED OPTION; AVBFB PREFERRED OPTION

1.2.1 Retain the current ESL funding model

AVBFB comments:

While the AVBFB believes the current ESL funding model is not perfect, it is of the view that none of the alternative options proposed would be a universal improvement. It is important to note that that fires on Unallocated Crown Land (UCL) are a significant drain on resources and therefore options with the theme apparent in 1.2.4 should not be entirely dismissed.

OTHER OPTIONS NOT SUPPORTED

1.2.2 Abolish ESL category areas

1.2.3 Abolish ESL category areas and create ’emergency service areas’ in line with CDJSC inquiry recommendations 68, 69 and 70

1.2.4 An additional ESL category to cover Unallocated Crown Land

1.2.5 Higher ESL rates for high-risk areas

 


 

1.3 ADDITIONAL LEVIES

The ESL is property based and as a result only landowners are required to pay the levy. Some stakeholders raised the possibility of charging additional levies, not tied to property ownership, to ensure more users of emergency services contribute to funding services. In addition these levies should increase the overall available revenue pool.

AVBFB PREFERRED OPTION

None of the options presented can be supported at this time

AVBFB comments:

Generally the AVBFB is not opposed to a “user-pays” funding model of government services, however it urges the government to undertake a thorough and transparent review of the current and historical use of the ESL before considering any increase to the rate or scope of application of the levy.

A secondary, more specific issue relates to the impact any increase to the ESL would have on both the number and morale of the state’s 26,000 individual Volunteer Bush Fire Brigade members. The Association is of the view that every increase in cost-of-living expenses (including the ESL) reduces the ability of many individuals to sacrifice paid employment opportunities for voluntary work. Any trend in that regard is likely to significantly impact on general morale and ultimately may deter others from volunteering.

The AVBFB therefore strongly recommends detailed research and analysis of these two points before any progressing with any proposal to alter the scope or magnitude of the existing ESL arrangements. Without more detail in this regard, the Association is unable to support either option presented.

OTHER OPTIONS NOT SUPPORTED

1.3.1 Collect an emergency services levy from vessel owners

1.3.2 Collect an emergency services levy from motor vehicle owners

 


 

1.4 ESL ADJUSTMENTS

DFES PREFERRED OPTION

1.4.1 Provide clarification that adjustments will only be permitted in the current financial year

AVBFB PREFERRED OPTION

1.4.2 Allow adjustments to be made in the current year and a set number of previous years

AVBFB comments:

The AVBFB asserts that as a result of often under-resourced/over-stretched administration personnel, there is often important and legitimate need for adjustments to be made up to 2 years prior to the current financial year.

 


 

NON-LEGISLATIVE ISSUES

Some issues identified in relation to the Response, Command and Control are non-legislative in nature and therefore are not in the scope of this Review. An undertaking was given to all stakeholders that the Review would pass on information on non-legislative issues raised to the relevant DFES business area or other government agency responsible.

AVBFB comments:

The AVBFB commends the author of the concept paper for observing non-legislative issues raised by stakeholders during consultation and notes that all such issues fall outside the scope of the “Concept Paper: Review of Emergency Services Acts”.

The Association considers some of these items to be extremely important and therefore wishes to put on the record that the lack of comment in this submission does not imply support or otherwise for any of the issues published under the heading of “non-legislative issues” in this or other chapters.

Further, the AVBFB respectfully but strongly urges the government to explicitly seek comment from the Association and other stakeholders before seeking to address any of the issues identified as not within the scope of this paper.

 


 

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