The NZPFU has withdrawn from the Technical Competency Framework (TCF) working group as FENZ has no intention to have tangible and transparent assessed pre-requisites and qualifications for the appointment to the ranks of Fire Commander and Assistant Fire Commander.

The NZPFU has repeatedly documented its concerns that FENZ will appoint personnel to the rank of Commander without having achieved transparent and accountable training and qualification programmes necessary to ensure safe and effective command and incident control.  In February we recorded again our concerns and we saw no merit in continuing with the TCF group. That position was provided to members here.  We sought a meeting with FENZ in a final attempt to get a training and qualification framework for Commanders that meets the standards of safe systems of work.  

On the 9^th March 2021 the National Council and the NZPFU representative on the Working Party Graeme Gilroy met with the National Commander Kerry Gregory, the Deputy Chief Executive People Brendan Nally and the TCF business owner David Guard to again raise our concerns and seek clear answers on what the TCF would include.  There was a refusal by the National Commander to commit to including the current career rank system as the pre-requisite for the appointment of Commanders and Assistant Commanders who will be commanding career firefighters and on the roster across all incident types.  There will be no protections in place to ensure only Commanders with the appropriate qualifications, training and experience are deployed to command an incident, or to prevent Commanders deploying to incidents they are not qualified, trained or experienced to command.  The responses we received only confirmed our concerns that there is no intention to have assessable pre-requisites and qualifications for the rank of Commander that have the lives and safety of firefighters and the public in their hands at a range of incident types and significance.

The TCF has been fundamentally flawed from the start as the intention is to avoid current rank and command requirements to enable FENZ to appoint non-qualified or sufficiently experienced personnel to the operational roles of Commander and Assistant Commander.  FENZ’s perspective that integration changing current qualifications, training and experience standards in the rank system to level the playing field to appoint those that cannot meet those standards as Commanders with ACL3 is wrong and dangerous.  Integration does not require sacrificing the necessary foundations of qualifications and experience to be able to appoint those that cannot meet those standards.  On the one hand FENZ is trying to develop generic standards to obtain ACL3/be appointed to Commander/Assistant Commander roles yet insists the Commander will only be deployed or have command and control authority for the type of incident they are qualified and experienced to attend.  If there is no intention to deploy rural personnel to command incidents other than wildfire, then there is no need for a generic technical competency framework. The correct approach would be to assess the current training, qualification and experience requirements for Commander ranks to determine any gap that should be addressed.

For the past 3-5 years there has been a stream of groups and committees with work relevant to command and rank structures to ensure effective and safe incident management.  The NZPFU has had representatives and subject matter experts actively participate providing evidence in support of the proposals and positions put forward.   History repeats with these groups reaching an impasse when FENZ does not accept the evidence but attempts to bypass the work to force an ideology that those with limited qualifications and experience in one type of response are to be considered equally trained, qualified and experienced incident controllers.  In each group there has come a time when it is clear that FENZ is just ticking boxes of consultation, that co-design is a misnomer as it is only cooperative when the design fits FENZ’s undeclared by obvious desired outcomes.  At that point, when the NZPFU has been unable to influence decision-making on sound evidence, we have no option but to walk away.

• 2015:  Command and Control manual rewrite where doctrine material was presented and discussed.  The manual was not completed or published.
• 2016:  Interim command and control policy workshops.
• 2017:  Target Operating Model where the NZPFU registered its concerns about the implications of proposals.
• 2018-2019:  Unified Service Delivery Group where FENZ pitched it as a “co-design" process.  We had to fight to have appropriate representatives on the group after you declared in February 2019 that rank/role would be the priority focus in preparation of tranche 2.  Through that group 8 general principles were agreed to be the basis for consultation but this never occurred and were not included in the Tranche 2 consultation.
• 2018-2021:  Tactical Command workshops which morphed into the Incident Leadership and Development course.  FENZ had a view that rural should be able to access the course without any pre-requisite qualifications or experience, or any process to determine equivalency or relevancy of appropriate qualifications and experience.  
• We have had union representatives on IMT Planning groups, the Training standards Committee, TAPs review group, Level 2 investigations and provide submissions to operational reviews where the training qualification framework with experience embedded are highly relevant to the issues discussed.   
• In addition there was also significant work undertaken by career firefighters seconded into the Integration department in 2018-2019 that was relevant to rank and command structures.  That work appears to have been shelved without explanation.

If FENZ continues on this path of removing the fundamental foundations of safe systems of work we see the following scenarios resulting – all with possible dire consequences for the health and safety of firefighters, and the community they are supposed to protect. 

1. A critical lack of experienced, trained and qualified Commanders available to deploy to all types of incidents.  
2. Commanders deploying to incidents that they are not trained, experienced or qualified to command.
3. Commanders being deployed to an incident they are trained, qualified and experienced to attend but the exposures and risks develop into an incident the Commander is not competent to command.
4. Commanders cognisant that they are limited in their training, qualifications and experience will just not deploy at all.  A repeat of the Christchurch earthquake scenario again where the Fire Service was heavily criticised for the absence of qualified and trained Commanders.

We have put FENZ on notice that we cannot condone or accept any roster or command system that gambles with the health and safety of career firefighters being under the command of non-qualified or experienced Commanders.

In unity,
Wattie Watson
National Secretary