Royal National Park, Heathcote National Park and Garawarra State Conservation Area Draft Plan of Management and Draft Mountain Biking Plan

Southern Sydney Branch has made a comprehensive submission objecting to both these planning documents. The proposed changes amount to a major shift in the balance between conservation, recreation, and commercial operations. You can read more in the submission.

The NPA submission followed months of deliberations by a dedicated team of members who undertook field surveys, met frequently, and reviewed published papers.

The primary concern was that minimal information of new visitor facility proposals was provided and no detail was given to their likely heritage impacts. The reserves are within easy access of millions of greater Sydney residents yet no attempt at determining sustainable carrying capacities was undertaken. Instead more visitor facilities are proposed including ‘serviced’ camping with car-based sites allowing for campervans in expanded recreation zones.  

Of concern was that the draft plans state that proposed new visitor facilities will be subject to future NPWS environmental assessments for which the NPWS has a policy of not making publicly available. Related to this is that comprehensive flora and fauna surveys of the reserves are decades old.

NPA had to seek additional mapping from the NPWS to show that the proposed mountain biking networks crossed over areas of mapped endangered ecological communities, while statements in the plans said that such outcomes would not be allowed.

According to the draft plans, a 2002 trial that allowed mountain biking to occur on 6km of track in addition to the 150km of allowed management trails, has resulted in at least 104km of additional illegal tracks, half of which NPWS now propose to formalise. Recent work by NPA has shown that in some proposed mountain bike areas, the actual length of existing illegal tracks is 50% greater than that listed in the draft plans. This brings into question the ability of the NPWS to apply legislation that clearly make such actions an offence.

NPA proposed that mountain biking in the reserves be restricted to the existing management trail network, and that Government look for opportunities on other lands to meet demand. A number of mountain bike discussion papers have been produced by the NPWS which when accessed show that mountain bike riders represent less that 0.8% of all visitors, however large parts of the reserves are to be zoned for mountain biking, incorporating the grading of tracks to meet international standards and allowance for national, regional and club events.

The NSW Government recently announced a major $80 million funding boost for a visitor facility expansion in the reserves. Therefore there are proposals in the draft plans for new facilities that have no assessment of impacts, the NPWS has not yet considered community input on those draft plans, the Minister has not signed off on a new plan of management, and yet proposed new facilities are already funded.

Full submission is available here

Book Review: Dead in the Water – Richard Beasley

Dead in The Water: A Very Angry Book About Our Greatest Environmental Catastrophe … The Death of The Murray-Darling Basin, Richard Beasley

Reviewed by David Stead, NPA Book Club

This is the story of the demise of Australia’s largest water catchment system, the Murray Darling-Basin. It covers one seventh of Australia’s landmass, Australia’s two largest rivers and is about three times the size of Germany. At the heart of the story is the need to return to the water system, environmentally sustainable water levels, by clawing back over-allocation of water for agricultural and commercial uses.

The how and why will shock readers.  The current government catch cry of ‘making decisions based on the best scientific advice’ has no place in Murray Darling decision-making as described by Richard Beasley, particularly with respect to the volume of water required to comply with legislation and enable to environmentally sustainable water levels.

Richard is a former Senior Counsel Assisting at the Murray-Darling Royal Commission. He relies on Royal Commission submissions, evidence and proceedings to support many of his statements. Richard provides a quick sketch of the Basin’s history, since colonisation and current uses, before getting into the detail on implementation of the Water Act (2007) and various failed government approaches to preserve the environmental integrity of the Basin. The story is well laid out and written for the average person (not in legalese) although some found there was a bit of repetition and a few too many references to what happens later (or earlier) in the book.

Some will find the message is delivered with a sense of humour that will have you laughing, not about the topic but by the way Richard draws the reader into the story. One example; ‘my publisher has put every competent defamation barrister on retainer … anyone who feels aggrieved … [is] left with the morons’. Richard then goes on to bluntly call out what he terms fact-based negligence, illegality or maladministration by the Murray Darling Basin Authority, governments, some politicians and others.

Conservation leaders urge Premier to protect Kosciuszko Nation Park from commercial over-development

Some of the state’s leading conservationists, ecologists and former national parks managers are “imploring” Premier Gladys Berejiklian to “set aside disastrous plans” to significantly increase commercial development of Kosciuszko National Park.

Kosciuszko National Park must be protected

An open letter to the NSW Premier – 20 August 2021

Dear Premier Berejiklian,

We, the undersigned, are dismayed by the unprecedented plans your Government has announced for Kosciuszko National Park.  

More than seventy-five years ago your parliamentary forebears legislated to protect the mountain landscapes, alpine habitats and headwaters of the Murray, Murrumbidgee and Snowy rivers as Kosciuszko National Park.  It was a truly precious gift to future generations.  

Reckless plans for Kosciuszko National Park must be stopped

The National Parks Association of NSW and the Nature Conservation Council have launched a campaign to stop a massive intensification of commercial development within Kosciuszko National Park. 

The NSW Government is proposing to increase the cap on resort beds by more than 40% (up from 10,915 to 15,360), build new and expanded carparks, allow helicopter flights onto the ski fields, and open walking tracks to four-wheel drive vehicles.   

Submission Guide for the Snowy Mountains Special Activation Precinct and the amendment to the Kosciuszko National Park Plan Of Management.

What is happening in Kosciuszko National Park?

The National Parks Association of NSW (NPA) is calling on members and supporters to oppose NSW Government’s proposals for a massive expansion of commercial activities in Kosciuszko National Park (KNP).  

These proposals would see the construction of accommodation and visitor facilities in highly fire prone areas, a whopping 40% increase in overnight accommodation , new carparks, helicopter transport into the resorts and, in a shocking rejection of sustainability principles, heating the waters of Yarrangobilly in a gas-powered parody of a Japanese Onsen.  

The NSW Government’s message is that KNP is in pristine condition and that none of their proposals would damage the park.  

They are wrong.  These reckless proposals overturn more than forty years of careful planning and management in KNP.  The balance between the protection of the environment and recreational activities is being discarded by plans that treat KNP as little more than a commercial commodity.  

The disturbing signal is that the future of KNP is moving from Environment Minister Kean and the National Parks and Wildlife Service into the hands of the deputy Premier and his Department for Regional NSW.  

This submission guide will assist NPA members and supporters to respond to the two documents outlining the NSW Government’s plans for KNP.

Where can I see the proposals?

The first of the documents on public exhibition is the Snowy Mountains Special Activation Precinct Masterplan (the Masterplan).  The Masterplan outlines the NSW Government’s vision for the development of the Snowy Mountains region.  

The link to the Master Plan.  

The second document is an amendment to the Kosciuszko National Park Plan of Management (POM).  POMs are statutory plans prepared under the National Parks and Wildlife Act.  They describe the physical attributes and conservation values of a park, identify threats to those values and provide a scheme of management priorities.  Most importantly, the policies in POMs determine what activities, including development and commercial activities, are permissible and under what conditions.  

The intent of this particular POM amendment is to make the developments proposed in the Masterplan legally permissible.  

The link to the POM amendment is Draft Plan of Management.  

Development proposals for two specific precincts in KNP, Yarrangobilly and Currango, are further detailed in precinct plans.

Where do I lodge my submission?

Submissions on the Masterplan should be lodged at Master Plan by 23rd August 2021.

Submissions on the POM should be lodged at Draft Plan of Management by 23rd August 2021.

Please remember that you don’t need to be a subject expert to make a submission.  As someone who cares about KNP your views matter.  We recommend using your own words when making a submission. 

If you don’t have time to look at both documents NPA recommends concentrating on the POM.  The reason is that the developments proposed in Masterplan would only be legally permissible if the POM is amended.

Submission points 

Kosciuszko National Park, a precious and vulnerable national park

The NSW Government’s video introducing the masterplan claims that Kosciuszko is ‘pristine’ and ‘environmentally resilient’.  

This claim is either stunningly ill-informed or deliberately misleading.  KNP has suffered, and continues to suffer, more environmental damage than any national park in Australia.  The sources of that damage include: 

  • historic clearing, grazing and mining; 
  • the escalating impacts of climate change, which recently caused the most intense wildfires in recorded history; 
  • destruction of alpine habitats as a direct result of the deputy Premier’s legislation protecting  feral horses; 
  • un-rehabilitated scars of Snowy Hydro’s former construction sites; 
  • historic and continuing environmental impacts from the resorts;
  • massive scale clearance and construction works by the Snowy 2 project; and 
  • unnecessary proposals for new overhead transmission lines across the park.  

KNP is also under extreme environmental stress from the existing level of development and use.  KNP is amongst the most heavily visited national parks in NSW and contains far more accommodation than any other national park in Australia, with 10,000 overnight beds.  All visitors need basic services such as sewerage treatment, waste collection, road maintenance, power and water.  These services are difficult to deliver in the alpine setting, and some, notably sewerage treatment, have a history of causing significant environmental damage.  

KNP cannot sustain any further assaults.  It needs better protection, not further damage through the inappropriate developments described in the Masterplan and POM.  

National Parks are for conservation and low-impact recreation

The Masterplan and POM treat the National Park as land awaiting a higher economic and commercial purpose.  National Parks are gazetted for the protection of natural landscapes, ecosystems and their natural and cultural values.  Recreational and commercial activities may be appropriate in national parks, but only where they are consistent with the core conservation objectives of reservation.  

The Masterplan and POM would intensify the stresses already confronting KNP, putting the future of the park at serious risk.  Doing so fails our legal, national and international obligations to protect national parks.  Australia is already an international pariah on so many environmental issues, let’s not add over development of KNP those failures.  

A National Park, not an urban development site

The exhibited documents overturn the planning hierarchy for national parks.  Instead of the POM defining the limits of future development and activities after careful analysis of the values and threats of a specific park, the current process is unashamedly designed to increase commercial access to, and returns from activities within KNP. 

The POM has been relegated to an enabling document for the Masterplan.  It proposes that the environmental values of KNP would be protected by future assessments under the Environmental Assessment and Planning Act (EP&A Act).  

This approach subverts the statutory role of POMs.  The EP&A Act processes are designed for the assessment of individual developments, not for the strategic management of the ecosystem processes, conservation and heritage values of a national park.  The Masterplan and EP&Act are the wrong tools to protect KNP- that is the role of the POM.  

The exhibited POM amendment should include a detailed assessment of the capacity of KNP to sustain the proposed developments.  It doesn’t.  It should be withdrawn and these issues fully assessed in a revised POM.  

The two plans would effectively transfer much of the responsibility for development within KNP from the National Parks and Wildlife Service to the Department of Planning and the deputy Premier’s Department for Regional NSW. This is unacceptable in a highly sensitive, extremely significant protected area. 

The Resort Precincts

The current POM for KNP protects the values of the park by limiting commercial and recreational activities within environmentally sustainable limits.  This is achieved in large part by limiting the number of overnight beds in the KNP to 10,000. 

The Masterplan and POM would allow the number of overnight beds to increase by 60%.  All associated services, from the capacity of the sewerage treatment plants to provisions for overnight parking, would also need to be enlarged to support this increase.

There is no assessment of the environmental impacts of this massive increase in overnight beds. The only justification provided is that there is a demand for additional accommodation. 

The vast majority of the existing accommodation is vacant for most of the year.  There is a large surplus of accommodation in KNP for at least 9 months per year.  In other words, the only purpose of the proposed additional beds is to service the peak of the snow season.

The future of the snowfields is dire.  Rising temperatures are already pushing the natural snowline above the current resorts.  The escalating costs and excessive water and power consumption of making artificial snow are becoming increasingly uneconomic.  The most optimistic forecasts project the end of the snow sports era within two decades, however if current trends continue a single  decade is more likely.

The situation is that any additional overnight accommodation, along with all of the infrastructure and services to support those beds, would only be required for a maximum of two decades.  It would be truly abysmal to create such stranded assets and inflict so much damage on the national park for the sake of a doomed industry.  National Parks must be managed for the long term, not for the transitory benefit of a sector in terminal decline.  

The proposed resort precincts are distributed across a significant area of KNP and large areas of native vegetation will need to be cleared. A central objective of previous management plans has been to limit the loss of natural habitat by confining the resorts to existing development footprint. The proposed resorts are located in areas of high biodiversity value and require careful management to ensure protection of rare habitats, ecosystem and species.  

Unsustainable visitor experiences

The Masterplan and POM prioritise ‘high end’ customers over other visitors to KNP.  Examples include allowing commercial tour operators to drive their clients on the Summit Track and helicopter transport into the resorts precincts.  Both proposals  completely detract from the quiet amenity sought by many visitors to national parks.   

The plans propose major changes at the Yarrangobilly Caves precinct.  The karst system at Yarrangobilly is of National, and International significance.  Karst environments are highly sensitive to disturbance and need careful management to maintain their significant values. 

Several of the changes, including increasing tour numbers, show little or appreciation for the sensitivity of the karst environment.  

The most startling proposal is to construct a series of bath houses around the existing springs.  These would be in the form of Japanese Onsens, bath houses traditionally located around hot thermal springs.

It is self-evident that such structures are not part of the heritage of Yarrangobilly.  They represent at best a contrived attempt to create a new tradition, and at worst, shameless cultural appropriation. 

The waters at Yarrangobilly are far colder than needed for the Onsens.  The plans propose raising the water temperature using large-scale gas heaters.  National parks should model sustainability principles, and Installing a high emissions facility in a national park setting is entirely at odds with community expectations.  

Transport and parking

Both documents make provision for increases in car parking in the resort precincts.  Additional parking will join additional accommodation as an unnecessary ‘stranded asset’ as snow cover declines.  It also has a number of adverse impacts in the short term.  One is that the potential sites for expanded carparks have significant conservation values, particularly for threatened species and ecological communities.  

Whenever questioned about inappropriate development the he NSW Government responds that KNP is very large and their development proposals only impact on a small percentage of the park.  This argument is very misleading- many of the threatened ecological communities and species that are found in KNP have very restricted ranges, in some cases to only a few hundred hectares of the park.  The total size of KNP is irrelevant, the issue is the significance of impact in the particular areas proposed for development such as these carparks.

The other concern is that the focus on additional car parking spaces locks in a private transport model that Australians are rapidly abandoning for long distance travel.  National Parks should be promoting environmentally sustainable behaviours, which in the case of KNP demands better mass transport.  

A better future for Kosciuszko

The Commonwealth Government recently announced that Australia has joined the International alliance ‘the high ambition coalition’.  The centrepiece of the membership of the alliance is to halt the loss of biodiversity by protecting 30% of our land and sea in conservation reserves.  

The protected area network in NS W protects barely 9% of the state.  We have a long way to go to get anywhere near the 30% target.  That task will be fatally undermined if the existing conservation reserves, such as KNP, are not protected from land clearance, infrastructure development and other inappropriate uses. 

The Masterplan and POM do nothing to enhance the protection of KNP, and instead endanger the  conservation values of the park.  At a time when we should be stretching towards higher ambitions for our protected area network, the NSW Government wants to diminish one of the jewels in our reserve system, KNP. 

Thank you for making a submission to help protect the future of Kosciuszko National Park.