NPA SUBMISSION GUIDE – Submissions close 12 November 2021
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.
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.
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.
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.
Documents tabled in the NSW Legislative Council reveal that the NSW Government will only receive $1.65 million from Snowy Hydro Ltd for the dumping of 14 million cubic metres of spoil in Kosciuszko National Park.
“Not only is disposing of tunnelling spoil in a national park reprehensible, we now know that the NSW Government will receive barely 1/1000th of commercial waste disposal rates” stated Gary Dunnett, Executive Officer of the National Parks Association of NSW (NPA).
The NSW Government has exhibited an Environmental Impact Statement to build massive transmission towers through Kosciuszko National Park. The proposed ‘overhead’ connection links the new Snowy 2.0 powerstation with the electrical grid.
The National Parks Association of NSW is demanding that the Snowy 2.0 connection should be by underground cables rather than on overhead lines. Underground cables have far lower environmental impacts, are less vulnerable to fires and storms, are recognised as international best practice for environmentally sensitive sites, and avoid setting a terrible precedent for future connections through our precious national parks.
This guide will assist everyone who cares about the future of Kosciuszko National Park to make a submission demanding an underground connection for Snowy 2.0
SUBMISSIONS CLOSE: Easter Monday 5/4/2021
The EIS for the Snowy 2.0 Transmission Connection can be viewed at https://www.planningportal.nsw.gov.au/major-projects/project/10591
We recommend using the Planning Department Major Projects online form to make your submission. You’ll need to create an account with the NSW Department of Planning to be allowed to make a submission.
If you have any problems please email your written submission to Sharniec@npansw.org.au before the closing date and we’ll ensure it is forwarded to the NSW Department of Planning
It is always best to make a submission in your own words. You can be as specific or as general as you like, and remember there is no need to be an expert to offer a comment. Issues you might like to address include:
- State your connection to Kosciuszko National Park, whether as a visitor, bushwalker, camper, climber, cross country skier or someone passionate about the environment.
- Describe how the destruction of this part of Kosciuszko National Park will impact your visitation and spending in the local area.
- Note that our collective responsibility is to protect National Parks for future generations, not for the commercial advantage of electricity companies.
- State your strong objection to any new overhead transmission lines through national parks, including Kosciuszko National Park.
- Note that the last major transmission line to be constructed in a NSW National Park was in the 1970’s, more than half a century ago.
- Overhead transmission lines are no longer acceptable in environmentally sensitive locations such as national parks. Underground cables have less impact, last longer and are a far better option.
- Since 2006, the Kosciuszko National Park Plan of Management (POM) has required that any additional transmission lines in the Park be located underground.
- It is outrageous that the NSW Government is looking to overturn this very reasonable policy so that TransGrid and Snowy Hydro Corporation can use a cheaper, outmoded and environmentally destructive option, ie. overhead lines.
- The proposed overhead lines are far more visually intrusive than any of the existing single-circuit lines in the Park, with two sets of massive 75-metre-high towers traversing eight kilometres of Kosciuszko over a cleared swathe up to 200 metres wide. The towers and lines will be visible over an astonishing 250 square kilometres of wilderness.
- One square kilometre of national park will be permanently cleared, decimating the habitat of threatened species such as Yellow bellied glider, Squirrel Glider, Eastern Pygmy Possum, Gang Gang Cockatoo, Powerful Owl, Masked Owl and the Boorolong Frog.
- If such species aren’t safe in a national park where can they possibly survive?
- The Environmental Impact Statement is totally inadequate and should be withdrawn. If resubmitted it should propose an underground connection, in compliance with the POM and in keeping with world-best practice.
- If the EIS is approved this NSW Government will be the first to condone overhead transmission lines in a National Park for 50 years – a tragic legacy, especially when there are viable underground alternatives.
- Kosciuszko National Park is already under incredible stress from the bushfires which decimated much of the park in 2019-20, to the advancing effects of climate change. This area is already extremely fragile and cannot afford further destruction. Overhead transmission lines are completely unnecessary and inflict totally unnecessary permanent damage to our beloved Kosciuszko National Park.