Namadgi NP new Plan of Management - opportunity to input

To: "Canberrabirds" <>
Subject: Namadgi NP new Plan of Management - opportunity to input
From: "Jenny Bounds" <>
Date: Thu, 3 Nov 2005 16:46:41 +1100
Greetings all: Those of you who enjoy birding in our national park, might consider making a submission to this new (draft) plan which will apply for ten years.  It can be just a short letter.  Comments are due 30 November.  Key issues which are of concern to environmental groups, are opening up for increased recreational use and fire management.  The POM can be accessed on: or at the ACT government shopfront at Lyneham (Macarthur House).
The National Parks Association has sent the note at the end of this email to its members to provide more information and to encourage them to write a letter or submission.  Numbers of responses matter!!
If you want to retain the park for its natural values and for low impact enjoyment, if you want Warks Road to stay as a quiet place to enjoy birding, then you need to read this and put your views.
Julie McGuiness and I will be putting together a submission on behalf of COG.  It will focus on the impacts for birds.  These are some of the things we will comment on:
. page 54  - information on birds - very limited, poor and very general information and references to birds and no bird list.  COG will be providing a list from its database
. fire management and effect of prescribed burning on threatened species and birds with specialised habitat preferences is key issue, eg wet forest/wet forest floor specialists, wet gully areas, Ribbon Gum and Brown Barrell forest   Species potentially impacted include: Pilotbird, Red-Browed Treecreeper, Brush Bronzewing (Pigeon), Brown Treecreeper in woodlands on forest edges in Naas Valley, Powerful Owl
. should be more principles for biodiversity conservation generally, and the long-term conservation of particular species in specialized/complex habitats which may be at at risk, eg from too frequent or broadscale burns, some information about ecological needs and management of these sensitive species
. Page 107 Tourist Route which includes Warks Road - dont support significant upgrading or widening of road which would remove native forest - should be left as a low impact road/management road, for hikers, bikers, birdwatchers etc. Warks road area is rich for birds in spring and summer, may be potential for bird fatalities with more traffic; would be difficult for bikers and hikers, birdwatchers etc if this were widened or sealed as a tourist route
. re-establishment of woodland around Gudgenby Homestead - NPA idea - support this, including linkages with other remnant woodland in the valley; they should investigate restoring this habitat for Brown Treecreepers, Hooded Robins and other woodland birds
Text of the email sent by NPA - please have a look at their summaries

Dear NPA members,


In this special edition of Burning Issues we are encouraging every member of NPA ACT to make a submission on the Namadgi National Park Draft Management Plan. It can be as informal as you like, but it is absolutely essential that we all put in individual submissions because the end result of the consultations on the plan will be about NUMBERS! We understand that, in reporting public response to the plan to politicians, emphasis will be put on the NUMBER of responses on controversial issues like fire trails and motor bikes, not the amount of work which has gone into them, and not the number of members a submission may represent. So, if every member sends in even a few dot points, our concerns would have to be taken seriously.


To help you do this, the NPA working group has prepared two documents that are set out below and are also posted on NPA?s website.  Either cut and paste the 10 major points of the Member?s Brief and email your submission direct to the address given below; or use the Key Issues document to write a more detailed submission.  Add your own thoughts and experiences; write about what walking in the park means to you and your family; about what the quiet enjoyment of the bush has meant for you over the years; about visitors you have taken to the park to experience its unique landscape, flora and fauna. This isn?t just an academic exercise; we are trying to influence park management ? and our own bush experiences ? for the next ten years. Get involved, write and have a say.  Submissions close on 7 November.


The formal NPA ACT submission will be a comprehensive set of comments which will cover just about every aspect of the draft plan and it will be posted on the NPA website as soon as practicable.  But it can?t stand on its own, it needs a groundswell of opinion to support its case for protecting the unique natural values of the park which are threatened by aspects of the draft plan.  Submissions can be sent to m("","EnvironmentAct");"> or PO Box 144 Lyneham ACT 2602 by 7 November 2005.  If you have no objection, we would like you to send a copy to NPAACT which we will keep confidential.




Christine Goonrey


Tuesday, 25 October 2005



NPA ACT Member?s Guide to Draft Namadgi Plan of Management


NPA ACT will put in a detailed submission but the committee encourages individual members to make private submissions on aspects of the draft plan which concern them most or which they support strongly so that those assessing comments can report on the actual strength of support/opposition to parts of the draft plan.


The committee recommends that members pay particular attention to the following points:


  1. Wilderness: We strongly oppose increased access for private vehicles and bicycles in the wilderness areas, and for special access to wilderness by commercial operators.
  2. We strongly support the remote and natural values of the wilderness and key principles for management (p 4) set out to achieve protection of those values eg the precautionary principle, adaptive management and inter-generational equity.  We would like to see those principles more clearly supported in the body of the plan itself, eg in fire management and recreation.
  3. Fire: we strongly oppose new fire trails in fragile and sensitive areas, eg Stockyard Spur, east Orroral Ridge and the widening of Cotter Hut road and Mt Franklin Road.
  4.  We oppose the minimum fire intervals of prescribed burning in sensitive areas in map 8 of the Strategic Bushfire Management Plan (Appendix 7 p 174) and the right given to this plan to override the prescribed burning frequency and fire regimes which park management determines as right for specific areas of Namadgi.
  5. Recreation: We strongly oppose the frequency and size permitted for ?medium? groups, eg up to 400 in the semi-remote Booth Range once a year, because it is incompatible with purpose and nature of the park.  Licensing and permits for activities in the park should only be granted according to established standards eg, the level of training and expertise of leaders; size of groups, including aggregated annual use of the park by that organisation; and relevance of the purpose/intent of the activity to the natural values of the park.  (p19 and p181)
  6. We strongly support the confinement of cars and motorbikes to public roads, the exclusion of bicycles from walking tracks and the restriction of horses to designated trails.  Any compromise in these restrictions would seriously damage the natural values of the park.
  7. All planning and management standards for Namadgi National Park should be at least equal to or better than the highest standards of environmental protection set in other jurisdictions of the Australian Alpine Park, eg group sizes, fire regimes and feral horse free (the latter is where we are better than the others).
  8. There should be a defined, costed and funded research and monitoring program that addresses the management needs of the park eg ecological assessment of the Mt Booth area and detailed assessment of fire response in specific plant, bird and animal communities.  
  9. The position of the Conservator should be a statutory appointment, the role being independent of park management responsibilities.
  10.  We oppose any exclusive commercial accommodation in Namadgi and the potential for commercial accommodation suggested by the proposed use of Gudgenby Homestead by tour operators (p74).

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:            Use of such equipment is inappropriate and ineffective in such steep and wooded areas;            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            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.            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.

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