NPA Parks Management Committee
The following regional planning issues are included in this edition of the journal because they raise issues that have potential state-wide implications for NPA and the protected area network.
Sydney Harbour NP amendment
The NPWS exhibited an amendment to the Plan of Management (POM) for Sydney Harbour National Park (SHNP) in late 2020. The amendment proposed a significant shift in how ‘Special Events’ are managed on the islands of SHNP. The current plan sets a maximum number of visitors per event to each of the harbour islands. The rationale is to avoid the adverse impacts of visitation by regulating the maximum number of people who would be permitted on the islands. Adverse impacts in this context range from trampling native vegetation or rock platforms to generating excessive noise for the adjacent residential suburbs. In addition to complying with the maximum carrying capacity, event organisers were required to complete an application that included some form of Environmental Impact Assessment (EIA).
The inclusion of carrying capacities under the POM ensured that the harbour islands did not suffer long term deterioration of environmental condition, whereas the EIA for specific events regulated the potential of individual events to cause undue damage.
The amendment that is being proposed by NPWS seeks to remove the island carrying capacities, instead relying entirely upon compliance with event guidelines and completion of an application form to avoid inappropriate environmental impacts.
NPA’s submission opposed the removal of the carrying capacity caps. It argued
NPA is extremely concerned about the shift in thinking about the role of POMs that is betrayed by this amendment. The amendment effectively replaces policies that reflect the values, characteristics and sensitivities of individual sites or precincts within SHNP with reliance upon a state-wide event management policy and EIA. In NPA’s view this amounts to a serious diminishing of the role of POMs, which is to set overall policy after detailed evaluation and consideration of the long-term needs of a reserve. EIA may be used to assess whether an individual event will have an adverse impact, but it is wholly inappropriate for determining whether the repeated use of a location for events will have a damaging effect. Assessment of cumulative impacts is a well-documented shortfall in all EIA processes. Accordingly, neither the Event Guideline or EIA provide an appropriate basis for determining long term sustainability. That is, and must remain, the central role of the POM.
NPA’s Park Management Committee (PMC), which has an overarching role in reviewing POMs and other on-park planning matters, is concerned about the increasing tendency to subvert the primacy of POMs through the adoption of guidelines, masterplans, EIA and other regional planning assessments. None of these have the same statutory force as POMs and don’t require the same level of community consultation and review. For this reason, PMC has recommended that NPA oppose any attempts to subvert the role of POMs through non-statutory mechanisms such as those proposed in the SHNP POM.
Snowy 2.0 Transmission Connection Project
NPA has campaigned against the major infrastructure construction project, Snowy 2.0, in Kosciuszko National Park. Despite our representations at all levels of government, and through each stage of the formal planning process, environmental approval has been granted by the NSW and Commonwealth Governments.
The final stage of Snowy 2.0, requiring approval, is the transmission connection between the new power station and the national electricity grid. The initial component of that 400km connection traverses eight kilometres of Kosciuszko National Park and one kilometre into the adjacent Bago State Forest. The transmission project is being managed by TransGrid on behalf of Snowy Hydro. In late 2020 we finally received a briefing from TransGrid disclosing that they are proposing two sets of 330kV overhead transmission lines, requiring towers up to 70m high and a cleared easement up to 200 metres wide. One square kilometre of National Park is to be cleared, permanently.
NPA asked for TransGrid’s assessment of alternatives, specifically laying underground cables in trenches, tunnels or using directional drill techniques. To our shock the response was that no such assessment had been conducted, as the cost of undergrounding was considered prohibitive by Snowy Hydro.
NPA rallied an expert group to assess the viability of underground transmission. NPA’s objective is very straightforward, namely to reduce the damage inflicted on Kosciuszko to the maximum possible extent. Our experts quickly established that undergrounding was indeed a far superior option than overhead transmission towers. An Open Letter, signed by two dozen environmental organisations and 50 expert engineers, scientists, economists and environmentalists, and a Background Paper outlining the case for underground cables, was released on 20 Jan 2021 (LINK) and received strong media interest, including a major article in the Sydney Morning Herald. The experts have continued analysing alternatives and have now identified a route though the existing Lower Tumut Switching Station that offers significant savings for the $2+ billion transmission augmentation project known as HumeLink. This alternative also has significant benefits for the National Electricity Market and substantially reduces the impact of new 500kV transmission lines on local communities and landholders.
All of this analysis and campaigning, including many briefings to parliamentarians, has taken place before the formal release of the Environmental Impact Statement (EIS). The reason for pushing the issue prior to the EIS is the sad history of environmental planning in NSW – which is basically that once an EIS is released, there is little interest from the regulators in requiring proponents to assess alternatives with less environmental impact. Our planning system is focused on whether developments are ‘approvable’ (the answer is almost always yes when government is driven by job creation and development), not whether the selected option is the best one possible. That philosophy is simply unacceptable, especially in this case, when what is at stake is another massive impact on our precious Kosciuszko National Park.
As a postscript, NPWS has just issued a Draft Amendment to the Kosciuszko National Park Plan of Management, to ensure that Snowy 2.0 operations are consistent with the plan of management (POM). One proposed amendment is to add the words in bold “Require all additional telecommunication and transmission lines to be located underground, except those constructed as part of the Snowy 2.0 project”. It is outrageous that the existing POM, prohibiting overhead transmission and telecommunication lines, is to be swept away just for Snowy 2.0. If enacted, this sets the precedent that every other National Park POM will potentially be ’amended’ to permit overhead lines. Something that is unheard of in other parts of the world.