The little communities of Mt Tomah and Berambing were never warned in December 2019 that a bushfire was heading their way.
The fire in question had been deliberately lit at Mt Wilson by the RFS in an ultimately unsuccessful attempt to quell the monstrous Gospers Mountains fire which was bearing down on the area.
The backburn eventually claimed homes at Mt Tomah, Mt Wilson and Berambing and dozens of residents were trapped in a burnover, forced to seek shelter where they stood and unable to flee.
They are now questioning the RFS strategy to light the backburn in severely challenging conditions on December 14, 2019.
The survivors group has made a 129-page submission to the coronial inquiry into the Black Summer bushfires, which sits at Katoomba courthouse for three days of hearings starting on Wednesday.
The report was written by locals Jochen Spencer and Kooryn Sheaves from the Mt Wilson RFS Backburn Survivors Group.
It begins with Mr Spencer describing how it felt to be caught in a burnover, as he was on December 15.
"A burnover is where you are surrounded by fire and can't escape. To survive you much find shelter where you are. The burning heat on your skin is so painful and you can't see or breathe because the smoke makes you cry and chokes your lungs...
"All you want in these moments is water. Water to drink, water to wet your skin and clothes and water to put out the fire raging around you."
They contend the NSW RFS did not act reasonably when it changed its strategy for managing the Gospers Mountain fire by lighting the Mt Wilson backburn and that it breached its statutory requirements under the Rural Fire Act 1997 when it failed to issue public warnings when the backburn escaped containment lines.
They submit that the RFS had implemented a containment strategy for the Gospers Mountains fire on December 13 which would ultimately be successful in both containing then extinguishing the fire so they question why the strategy was changed a day later.
The group also said in their submission that the failure of the RFS to explain the reasons behind the change of plan was causing "ongoing pain and distress" in their communities.
They believe the RFS response to the recommendations of the 2020 NSW bushfire inquiry has been insufficient to prevent them being burnt out again without warning.
The hearing at Katoomba from June 15-17 has no room for the public but proceedings will be live streamed. See https://www.coroners.nsw.gov.au/coroners-court/upcoming-inquests/nsw-bushfires.html.
