NPA ACT comments on Draft Namadgi Management
Plan
Key
Issues
1.
Fire:
1.1. Fire trails
1.1.1.
We strongly oppose new fire trails in the
wilderness area, which includes the proposed upgrading of
Cotter Hut
Road which, in effect,
becomes a new road.
1.1.2.
We strongly oppose float standard fire
trails to move heavy equipment into areas such as
Upper
Cotter Valley and
Stockyard Spur:
1.1.2.1.
Use of such equipment is inappropriate and
ineffective in such steep and wooded areas;
1.1.2.2.
The role of float standard fire trails,
their placement and size does not reflect zoning, has no supporting needs
analysis and pays no attention to the impact of the use of such equipment on
wilderness areas; and
1.1.2.3.
More effective methods of fire suppression
and hazard reduction are being developed which do not require the use of large
bulldozers; these roads would be redundant before the noxious weeds they would
introduce had even begun to take hold.
1.1.2.4.
Note: upgrading
Cotter Hut
Road to float standard would
require sufficient work as to classify large stretches of the road as a new
road.
1.1.3.
Maintenance, security and rehabilitation
of fire trails is not dealt with, nor is there any process of review of the fire
trail system as new fire management strategies emerge.
1.1.4.
There is no reflection in the proposed
fire trail system of the different uses for fire trails, eg for routine fire
suppression, for prescribed burnings or are they sited to deal with extreme
wildfire events?
1.2. The plan of management needs to address the widely held view that
forests litter is merely ?fuel loads? and ?fire hazards? which must always be
reduced. The plan needs to more clearly establish the value of forest litter and
soil biota as essential elements of the eco-system and critical to the
prevention of soil erosion and land degradation.
2.
Wilderness
2.1. Zone 1B should be included in defined wilderness area while retaining
its additional restrictions required by water catchment management eg no
overnight camping.
2.1.1.
In the present plan, inappropriate uses in
the area is still permitted eg camp fires for day walkers are not excluded and
powered flights at low altitude are permitted here (p 23) but not in wilderness
area;
2.1.2.
The existing wilderness boundaries are
arbitrary and do not reflect the topography or wilderness values of the
area;
2.1.3.
Inappropriate activities within the
existing boundaries are extremely difficult to monitor.
2.2. The land between the Blue Gum Creek remote area and zone 1B (Cotter
catchment) should be upgraded to wilderness to create a contiguous wilderness
area with existing Upper Cotter wilderness area.
2.3. Upgrade the remaining zone 2A (wild semi-remote) area, Booth Range,
to the Victorian standard which gives same legal protection as wilderness
classification eg no new uses or infrastructure; except that it allows existing
uses eg horse trail.
2.4. Make specific provisions in Land Management Agreements with ACT?s
rural lessees to protect areas of yellow box redgum woodland adjacent or close
to the park.
2.5. The proposed arrangement for Conservator to allow mechanical access
(bicycles and cars) to wilderness is not acceptable:
2.5.1.
The Conservator should be a statutory
appointment, independent of park management, and
2.5.2.
There should be no private mechanical
access to wilderness areas. All routine management activities within the
wilderness area should be undertaken in park vehicles.
2.6. There should be stronger recognition in the plan that
inter-generational equity (p 5) requires the need to preserve wilderness for its
own sake and not just a ?wilderness/solitude experience? for the current
users.
2.7. There should be a clear statement that wilderness values should
predominate over water catchment values, if only on the grounds that the best
protection for water values is preserving existing environmental values
2.8. There should be no low altitude flying above the park ? except for
management/emergency purposes. The size of the park means that low flying
permitted almost anywhere would create intrusion into wilderness and could
threaten water catchment quality (eg the plane crash in Bendora Dam 2003 was the
greatest threat to water quality for many years before the fires actually
reached the dam.)
3.
Recreation
3.1. The Park is not suitable for large groups or intensive recreational
use and this must be stated clearly and backed up with appropriate restrictions
on organised events, tours and activities.
3.2. Licensing and permits for activities in the park should only be
granted according to:
3.2.1.
Satisfactory training and expertise of
leaders and the commitment of the organisation to long term appropriate park use
and environmental values;
3.2.2.
Size of groups, including aggregated
annual use of the park by that
organisation;
3.2.3.
Relevance of the purpose/intent of the
activity to the park, eg experiencing wilderness has a correlation with the
stated values of the park but endurance events or large camp-based entertainment
events have little relevance;
3.2.4.
Impact on natural values of the park, both
immediate and long term; and
3.2.5.
Cost to park of servicing the use and/or
restoring the area.
3.3. The granting of licenses, permits, fees and charges should reflect
the practices and expertise of the operators and the costs of the environmental
impact of the activities as well as the for-profit or not-for profit status of
the operators.
3.4. There should be no special access for commercial use of
wilderness areas (38.45 and 38.86 p117), even if they are doing ?wilderness
management? projects.
3.5. Horse riding should not be permitted down Grassy Creek nor into Long
Flat; horse riding should only be along designated management trails. Horse
numbers should be restricted to 10 horses (40 hooves) per group. No special
vehicle access should be given to allow horse riders vehicle access to
management trails.
3.6. Zone 3 Roaded and Recreation should only extend 10 metres from the
centre of the road, not 40 metres.
3.7. No overnight accommodation should be permitted at Gudgenby Homestead
except for park staff.
3.8. There should be no events allowed for groups which are far too big
for the nominated areas, eg up to 400 people for a single event in the Booth
semi-remote area (p 181).
4.
What?s missing?
4.1. There is inadequate reference to managing the park under climate
change.
4.2. There is no commitment to appropriate funding or research especially
for fire management and pest control.
4.3. There is inadequate reference to birds, eg
4.3.1.
the impact of too-frequent prescribed
burning on birds due to the time required to build complex bird habitats;
4.3.2.
the interrelationships of bird habitats
in the park and in surrounding areas; and
4.3.3.
there is no listing of bird species in the
park.
4.4. There is no reference to responsibilities of ACT lessees to behave as
good neighbours to the park.
4.5. There is no commitment to repair heritage sites such as Orroral
Woolshed
4.6. There is no process for public scrutiny of decisions eg event management, commercial
licences
4.7. There is no indicative implementation, evaluation and reporting
plan.
4.8. The commitment to wider consultation on Joint Management Agreements
only after the parties have reached agreement could undermine the public
consultation process.
4.9. Mt Namadgi stone arrangements are not listed as either Heritage or
Interim Heritage sites.
5.
What do we strongly support:
5.1. The primary purpose of Namadgi as stated on p51: ?The primary goal
for all national parks is biological diversity conservation?
5.2. Restrictions and changes to horse riding and vehicle based horse
camping ? though the proposed extension of camping facilities and locked gate
access is strongly opposed.
5.3. Exclusions of recreational off road driving (p 107) and motorised
biking
5.4. Overall conservation and minimum impact strategies
5.5. Role of volunteer groups such as GBRG, NPA, COG, Waterwatch
etc
6.
Legislative/legal strategies
required
6.1. Negotiate Land Management Agreements with ACT rural lessees and other
land managers, which promote a special role for rural areas adjacent or close to
Namadgi
National
Park by:
6.1.1.
Prohibiting grazing or cultivation of
potentially invasive plants or animals, eg deer and olive
trees
6.1.2.
Developing individual lease-specific land
management strategies which protect areas of special interest eg yellow box
redgum woodland adjacent or close to the park;
6.1.3.
Make specific provision for co-operative
fire management strategies and use of fire management
resources;
6.1.4.
Encourage productive use of the leases
which complement the park plan of management eg by providing services to park
users and tourists; and
6.1.5.
Make public those lease provisions which
relate to land management strategies.
6.2. Review and amend the Nature Conservation Act to:
6.2.1.
Enable the appointment of an independent
statutory Conservator who has no direct role in management of
Namadgi
National
Park;
6.2.2.
Reflect changes to and provide appropriate
legal status for other areas of the plan of management, eg use of
permits.
