The Victorian Environment Department says a long-running underground fire at the Hazelwood coal mine has “created a choking reminder of the real price of relying on coal for electricity”.

The long-running coal mine fire was “an accident waiting for a time to happen”, according to a hard-hitting submission from Environment Victoria to the Hazelwood Mine Fire Inquiry.

Environment Victoria investigators have criticised the level of rehabilitation works at the mine, saying mine operator GDF SUEZ has failed to set out clear standards and timelines for the progressive rebuild.

The department has recommended that the Energy Minister have a second look the $15 million mine rehabilitation bond, saying it should be larger.

Environment Victoria described the fire as “one of the worst environmental disasters in Victorian history”.

“Brown coal is a known fire risk,” the department’s submission reads.

“The best approach to fire prevention in a coalmine is to properly rehabilitate areas of the mine that are not being used. As the Hazelwood mine fire exposed, there are significant problems with the standard and extent of rehabilitation at the mine site.”

“Firstly, this submission outlines that rehabilitation requirements imposed on GDF Suez by the Victorian government are currently too vague and lacking in detail to be effectively enforced. Secondly, there has been an absence of communication between the government and GDF Suez about the status of rehabilitation work,” Environment Victoria said.

The department has called for the government to set up a better “emergency response plan” for communities near coal mines.

It says there should be pollution trigger points for evacuation, and strongly criticised the government's health response to the fire, saying it served only to create “significant confusion” among residents.

“I think it's inappropriate to be commenting on submissions that have been put to the inquiry before the inquiry actually begins, and we will certainly be responding to issues that are raised by the panel during the inquiry,” a spokesperson for GDF SUEZ told Fairfax media outlet The Age.

Luc Dietvorst, an executive at GDF SUEZ Australian Energy, has previously said he is comfortable with any upcoming investigations into the fire.