Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000)

October 2016 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000)

Prepared and published by:

Tasmanian Planning Commission GPO Box 1691 Hobart Tasmania 7001

October 2016 email address: [email protected] internet address: www.planning.tas.gov.au

Table of Contents Executive Summary ...... i Glossary ...... ii 1.0 Introduction ...... 1 1.1 Referral to the Commission ...... 1 1.2 Background to the Draft Plan ...... 1 1.3 Review process by the Commission ...... 2 2.0 Review of representations and the Director’s report ...... 5 2.1 Overview ...... 5 2.2 Horse Riding in Park ...... 6 2.3 Draft Plan Process ...... 8 2.4 Impacts on Shorebirds ...... 9 3.0 Conclusion ...... 10 Appendix 1 List of Representors ...... 11 Appendix 2 Letter of Clarification on the Director’s Report ...... 12 Appendix 3 Report from the Director of National Parks and Wildlife ...... 13

Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Executive Summary In September 2016, the Minister for Environment, Parks and Heritage referred 19 representations and the report of the Director of National Parks and Wildlife, regarding the Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) (the draft Plan), to the Tasmanian Planning Commission for review under Part 3 of the National Parks and Reserves Management Act 2002. The Commission’s role is limited to reviewing the representations received and the report of the Director, with reference to the draft Plan. It cannot approve, amend or refuse the draft Plan. Nor can it comment on the merit of the draft Plan. Narawntapu National Park, on the central north coast of Tasmania, lies in the municipalities of Latrobe and West Tamar and has a total area of about 4,500 hectares. Much of the Park contains a high level of biodiversity in a relatively natural state with a great diversity of mammals and avifauna, some in abundance. Native vegetation consists of a great diversity of predominantly dry sclerophyll plant communities, heathlands and coastal vegetation of high conservation value. The Park has significance for the Aboriginal community, and there are a range of historical sites and artefacts scattered throughout the Park. Local and interstate visitors also value the recreation opportunities that the Park provides. Hawley Nature Reserve, located on the outskirts of Port Sorell, is in the municipality of Latrobe and, with a total area of 49.66 hectares, is primarily important for its flora conservation values. The Commission noted that most, if not all, representors raised issues on areas of the draft Plan unrelated to the proposed alterations. It appears that this was due to the fact that a largely unaltered version of the Management Plan was included as part of the public exhibition process. The Commission is concerned that many representors may have been mislead by the public exhibition process and unnecessarily provided detailed submissions on issues that are not related to the proposed amendment. The primary concern raised in representations was about the current plan being amended to facilitate a commercial horse riding use within the Park. The majority of representors were concerned that this operation would lead to an increase in overall horse numbers and accessible areas in the Park, with a corresponding increase in impacts on flora and fauna. The Commission found that the Director’s Report was comprehensive and adequately detailed and addressed most of the concerns and comments from representors. In the Commission’s view, in the majority of cases, the Director adequately responded to the representations and issues raised, noting many issues were unrelated to the proposed alterations to the current Plan.

Executive Summary i Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Glossary Commission Tasmanian Planning Commission current plan Narawntapu National Park, Hawley Nature Reserve Management Plan 2000 Director Director of National Parks and Wildlife draft Plan Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) EOI Expressions of Interest EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (AG) Minister Minister for Environment, Parks and Heritage NPRM Act (the Act) National Parks and Reserves Management Act 2002 PWS Parks and Wildlife Service

Glossary ii Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) 1.0 Introduction

1.1 Referral to the Commission In September 2016, the Minister for Environment, Parks and Heritage, the Hon Matthew Groom, (the Minister) referred 19 representations and the Report of the Director of National Parks and Wildlife (the Director), regarding the Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 to the Tasmanian Planning Commission (the Commission) for review under Part 3 of the National Parks and Reserves Management Act 2002 (the Act). The Commission’s role is limited to reviewing the representations received and the Report of the Director, with reference to the draft Plan. This involves a review of the representations and how the Director has responded to issues raised in representations. The Commission cannot approve, amend or refuse the draft Plan. Nor can it comment on the merit of the draft Plan.

1.2 Background to the Draft Plan The Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 is an amendment to the existing Narawntapu National Park, Hawley Nature Reserve Management Plan 2000 initiated as a result of the receipt of a proposal for a commercial horse riding operation in the Park submitted through the Tasmanian Government’s recent Expression of Interest (EOI) process for new tourism opportunities in the Tasmanian Wilderness World Heritage Area, national parks and reserves. An element of the proposal, involved opportunity to utilise a link track to Bakers Beach while retaining horse riding access to the length of the beach east of this track. This was identified as not being provided for under the current management plan. The EOI Assessment Panel recommended that the Minister invite the proponent to proceed to Stage 2 of the EOI process. Following more detailed consideration by the EOI Assessment Panel, and on provision of advice, the Minister considered it appropriate to amend the existing management plan to allow the activity to be considered through the applicable assessment processes. The alteration would allow existing horse riding access to the full length of Bakers Beach to continue in the event that the Cradle Country Adventures proposal and associated link track received the relevant approvals to proceed. The draft Management Plan alters the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000 in Section 5.4.6 Horse Access, where the following sentence is deleted: “If a horse trail link from Bakers Beach is provided, discontinue the authority to use horses on Bakers Beach east of such a link.” In addition, minor changes of a technical nature are proposed to a number of sections of the current plan to replace out of date references to legislation and management documents. The natural values information is also brought up to date in sections 3.1-3.4, 4.2 and Appendix 1 together with the inclusion of a new appendix (Appendix 3c) that lists the threatened species of the Park. Other minor changes proposed include replacing the visitor numbers with the latest figures in sections 5.1 and 5.2, and removing completed actions from the Action list in sections 4.1 and 5.5 and adding a description of the outcome achieved in the descriptive text of those sections.

1.2.1 Public exhibition of the Draft Plan and representations The Director prepared the draft Plan in accordance with section 20 of the Act. The Director placed the draft Plan on public exhibition from 14 Nov to 16 Dec 2015, and subsequently received 19 representations. A list of the representors is provided under Appendix 1.

Introduction 1 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) 1.2.2 Director’s Report Under section 21 of the Act, the Director is required to forward to the Commission: (a) a copy of all the representations; and (b) a report containing – (i) a summary of the representations; and (ii) the Director’s opinion on the merits of the representations including whether or not he or she believes the representations to be of sufficient merit to warrant modification of the plan; and (iii) a summary of any proposed modification to the plan; and (iv) any additional information that the Director considers relevant. The Commission received a copy of the Director’s Report and a copy of the representations in April 20161.

1.3 Review process by the Commission The review process has been conducted in accordance with Part 3, sections 22 - 24 of the Act: 22. Review by Commission (1) The Commission, at the direction of the Minister, is to review the copies of the representations and the report of the Director forwarded under section 21 with reference to the draft management plan. (2) Within 21 days of receipt of the copies of the representations and the report of the Director, or within any further period the Minister allows, the Commission is to decide whether or not to hold a hearing to assist in its review of the representations. (3) If the Commission decides to hold a hearing, the Commission is to notify the Minister of that decision. (4) If the Commission decides not to hold a hearing, the Commission, within 14 days of making that decision, is to give written notice of that decision to – (a) the Director; and (b) the Minister; and (c) any person who has made a representation under section 20(12)(b)(iii). (5) A hearing is to be conducted in accordance with Part 3 of the Tasmanian Planning Commission Act 1997. 23. Public exhibition (1) The Commission, as soon as practicable after receipt of the copies of the representations and report of the Director forwarded under section 21, is to notify by public notice – (a) the places at which copies of the representations and report are to be exhibited; and (b) the period during which they are to be exhibited; and (c) any other information the Commission considers relevant. (2) At least one of the places referred to in subsection (1)(a) is to be near the area specified in the draft management plan. (3) The Director and the Commission may make available any information that may assist public consideration of the representations and the report of the Director at the places referred to in subsection (1)(a). 24. Report of Commission

1 iplan website: http://www.iplan.tas.gov.au/Pages/XC.Track.Assessment/SearchAssessment.aspx?id=448

Introduction 2 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) (1) The Commission, within a period determined by the Minister, is to provide the Minister with – (a) a report of its review under section 22; and (b) copies of the representations and the report of the Director forwarded under section 21. (2) As soon as practicable after the period referred to in subsection (1), the Commission is to publish in the Gazette notice of – (a) the making of its report; and (b) where copies of its report are available for inspection by the public. As required under section 23 of the Act, the Commission gave public notice in The Mercury, The Examiner and The Advocate newspapers on 17 September 2016 that electronic copies of the Director’s Report and the draft Plan were available for public inspection at LINC offices in Latrobe, Beaconsfield, Narawntapu National Park visitors centre, the Commission’s Hobart office and on the iplan website.

1.3.1 Hearing Section 22 of the Act provides that a hearing may be held at the Commission’s discretion to assist in the review process. A hearing under the Act is only held if the Commission considers that the information available is inadequate for it to properly undertake its review. The Commission considered that there was adequate information available and decided at its meeting of 3 October 2016 to not hold a hearing. The Commission gave written notice of its decision not to hold a hearing to the Minister, the Secretary and each person who made a representation.

1.3.2 Report to the Minister

A copy of this report has been provided to the Minister and Director, and notices published in the Tasmanian Government Gazette and The Mercury, The Examiner and The Advocate newspapers, as required under the Act. Figure 1 describes the review process for draft management plans pursuant to the Act:

Introduction 3 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000)

Director prepares and places management plan on public exhibition and invites representations.

Director provides Commission with a copy of representations & Director’s report. Minister directs Commission to undertake a review.

Commission reviews representations and Director’s report

Commission determines Commission determines Commission to hold a hearing & whether to hold a hearing determines not to hold notifies Minister & to assist in its review. a hearing. representors of decision

Commission holds a Commission provides Commission notifies hearing. Minister with a report of Minister, Director and its review, copies of the all who made a representations & representation. Director’s report.

Commission places notice in Gazette advertising report has been made and is available for public inspection.

Figure 1 Review process for draft management plans pursuant to the National Parks and Reserves Management Act 2002

Introduction 4 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) 2.0 Review of representations and the Director’s report

2.1 Overview

2.1.1 Scope of the Commission’s review Part 3 of the Act provides for the formulation of a management plan, the Director’s review of the subsequent representations on a draft Plan, the review by the Commission and the plan’s final submission to the Governor for approval. As summarised in 1.1 above, the review focuses on the representations and the Director’s Report, but not the merits of the draft Plan. The words ‘with reference to the Management Plan’ direct the Commission to the context in which the review takes place, not the merits of the plan. In this report, the Commission’s review is restricted to a consideration of adequacy of the Director’s responses to the representations. Therefore, the Commission notes that any review of the merits of the plan, and the ability to change the draft Plan, is solely the purview of the Director.

2.1.2 Representations on draft Plan The Director received 19 representations on a number of issues. The principal concern raised in the representations was the plan being altered to allow for a commercial development (Cradle Country Adventures) that would increase horse riding within the Park. Representors considered that the proposed alteration would impact on: nesting and feeding shorebirds; threatened flora; and the introduction of, and increase in, the spread of weeds and disease. Concerns were also raised regarding the level of detail available for the proposed commercial development. The Director also noted in his Report that representors were under the misapprehension that the public were being asked to comment on the draft Plan in its entirety. This resulted in the representations raising issues on areas of the draft Plan unrelated to the proposed alterations. These issues include: 1. comment on the adequacy of the level of detail/information provided regarding natural and cultural values and the management of potential future impacts; 2. concern about vehicles being permitted on Bakers Beach and their impact on environmental (beach structure, nesting shore birds) and cultural heritage; 3. opposition to the establishment of a camping area at Copper Cove; 4. concern about the environmental impacts of, and safety around, mountain bikes; 5. concern about zoning for specific areas; 6. suggested changes and additions to sections of the Management Plan to better recognise Aboriginal values of the area; and, 7. recommendation that a complete review of the Management Plan be completed.

Review 5 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000)

2.1.3 General comment on adequacy of Director’s responses As part of the statutory process set out under section 21(b)(ii) of the Act, the Director must include in his Report to the Commission commentary regarding the merits of the representations and whether or not they warrant modification of the draft Plan. Whilst the Director’s summary generally contains detailed responses to each issue raised, he did not explicitly address the merits in a large number of cases. The Director stated in his report that responses to representations must be limited to those matters that pertain to the proposed alterations. He recognised that there may be a number of other matters in the current plan that may require review, however, he stated that it was not the intent of the alteration to address all possible issues requiring review, rather the alteration was largely to allow for a single change, although the opportunity was taken to update some technical information without changing any policy intent of the current plan. Accordingly, the Director limited his detailed responses to matters that relate to the proposed alterations to the current Plan. The Commission supports this approach. The Director’s response to ‘relevant’ issues raised in representations, and the recommendations that appear in the Director’s Report that are not reviewed in detail below are regarded as adequate by the Commission. Section 21(b)(iii) also requires the Director to forward to the Commission ‘a summary of any proposed modification to the draft management plan’. This was initially not included in the documents forwarded to the Commission, but provided shortly afterwards in a letter dated 28 September 2016. The letter clarified that, of the changes agreed to by the Director in his Report, only the changes to section 3.3 are to be included in the Draft Plan for final approval. In relation to the other changes, the Director has advised that they were inappropriately categorised as ‘Plan change warranted’ and should have been ‘Consideration/consultation warranted – consider in any future full review’. A copy of the letter is presented as Appendix 2.

2.2 Horse Riding in Park Representations The majority of representors (4, 5, 6, 7, 8, 10, 11, 13, 14, 15, 16, 17, 18) were concerned that the proposed commercial development (Cradle Country Adventures) would lead to an increase in overall horse numbers and accessible areas in the Park, with a corresponding increase in impacts on the Park’s values, particularly flora and fauna. Of those representors, most (6, 10, 11, 15, 16, 17) advocated a ban of horse riding activities within the park as opposed to restricting access to certain areas or other mitigating measures. Concern about the impact of current and potentially increased horse riding activity on shore nesting birds was raised by several representors (4, 5, 10, 11, 13, 16, 18). Birdlife Tasmania (16) noted that horse riding has been identified as a threat to the Hooded Plover in the Federal Minister’s Conservation Advice and consider that expansion of commercial horse riding will increase the threats to beach nesting shore birds year round on Bakers Beach. Other representors cited that the potential impacts of horses on shore nesting birds are recognised in the current plan and that no change to the Plan should occur which would increase the likelihood of further impacts. Birdlife Tasmania (16) stated that the Parks and Wildlife Service (PWS) Code of Practice for horse access does not protect beach nesting shorebirds from horse riding on beaches. The organisation also highlighted that there is no condition to require horses to be ridden on wet sand away from nesting areas. Birdlife Tasmania also considers that with limited park staff, PWS do not have the capacity to ensure compliance. They believe that there is no evidence to indicate that all horse riders

Review 6 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) adhere to the PWS Horse Access Conditions and that no monitoring of the potential impacts of horse riding on beach nesting birds occurs. Two representors specified that the proposal to extend horse riding along the fire trail increases the risk of spreading weed and disease as well as exacerbating erosion. It was stated that allowing horses into relatively weed free areas of the park will exacerbate weed management problems and further stretch limited resources. Concerns were also raised about impact on water quality from use of horses and potential impact from increased use of horses. One representor acknowledged horse riding as a valid recreational pursuit but believed that it is inconsistent with Park values and should occur outside the park. They further queried what studies have been done on the impact of horses and the carrying capacity of horses in the Park, stating that there should be scientific monitoring of the activity. Director’s response The Director stated that the potential expansion of horse riding via the new commercial proposal, beyond what is currently allowed for, is subject to assessment processes that would require and consider the development of appropriate mitigation measures. The Director commented that the existing allowance referred to, for horse riding along the fire trail, is not the subject of the proposed alterations but can be reviewed in any future plan review. He also noted that horse riding on the beach is an existing activity and that the proposed alteration only allows for continued horse riding on Baker Beach in the event that the short loop track is utilised. The Director noted that Schedule 1 of the Act prescribes ten management objectives for the reserve class of national park. These are not ranked and include encouragement of tourism, recreational use, and enjoyment, consistent with conservation of natural and cultural values. He stated that assessment of the proposal will ensure that a balance between the objectives is achieved and the requirements of the Act are met. He considers horse riding a legitimate recreational pursuit in the Park that can be managed to ensure it is compatible with protection and conservation of values. In response to Birdlife Tasmania’s comment regarding the PWS Code of Practice the Director stated that the Code of Practice can be reviewed if required. Commission’s findings The Commission notes that the Director responded to the concerns regarding Park values in terms of flora and fauna, which were the issues specifically raised by the representors. The Commission considers that the Director has considered and adequately responded to the concerns about the potential impacts on the Park’s flora and fauna arising from a likely increase in horse riding within the Park by providing reasons for the proposed amendment to section 5.4.6 of the current plan. However the Commission considers that the Director could have provided a more detailed response to those representations that raised concerns regarding increased commercial activity within the Park.

Review 7 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) 2.3 Draft Plan Process Representations A large number of representors (2, 6, 8, 10, 11, 13, 17, and 18) contended that there was a lack of transparency regarding the proposed change with it not being clear that this was just an amendment and not a full plan revision. The representors were also concerned that there was an absence of discussion regarding the transferral of public assets to the private sector and in regard to the tourism proposal the management plan is designed to facilitate. There were also concerns with the lack of public consultation during the formulation of the draft Plan. One representation (18) commented that the incremental revision of management plans could lead to sub-optimal outcomes and that management planning should be thorough and holistic. A number of representors (8, 10, 11, 13, 17) contended that no rationale or information was provided to explain or justify the amendment, making informed community input into the draft Plan difficult. Director’s response The Director responded in his Report that the process undertaken for altering the Plan has been undertaken in accordance with the statutory process set out under the Act. He considered that the nature of the proposal was self-evident but did provide further information on the EOI assessment process in his Report. He commented that the new commercial proposal is subject to an assessment process that will evaluate the final, detailed proposal and, if approved, will determine and impose appropriate conditions to mitigate any potential impact on values or other park users. The Director also stressed that it is important to understand that this proposal has already under gone a level of assessment through the established EOI assessment process and that it was on this basis that the change was considered appropriate. He noted that the proposal, if approved, will be a regulated activity through the provision of a licence or lease granted under the Act. In response to representation 18, the Director commented that the Act provides for management plans to be altered, in recognition that minor changes may be required from time to time. He stated that these provisions reflect the understanding that a management plan may not anticipate all circumstances over the life of the plan, and this is why there is a process for alteration. He noted that any alteration is subject to the full extent of the statutory process, there is no reason to suggest that minor alterations would lead to sub-optimal outcomes for either tourism or natural conservation. Commission’s findings The Commission is concerned that many representors may have been mislead by the public exhibition process and unnecessarily provided detailed submissions on issues that are not related to the proposed amendment. The Commission considers that there should have been further clarity of the EOI process and the proposal that was the catalyst for the amendment at the time of advertising the draft amendment. On balance the Director has considered and adequately responded to both concerns raised by the representors about the draft plan process and the lack of information about the commercial proposal under the EOI process in his Report.

Review 8 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) 2.4 Impacts on Shorebirds Representations The majority of representors (4, 5, 6, 8, 10, ,11, 13, 14, 15, 16, 17) were concerned that any amendment to the current plan that potentially relax restrictions on activities along Bakers Beach (i.e. vehicles, horse riding) would adversely affect a range of conservation values, including flora, fauna, cultural heritage and threatened species. Representors noted that the Park provided important habitat for a number of species and many held particular concern for shorebirds such as the Pied Oystercatcher and Hooded Plover, the latter of which has recently been listed as threatened under the EPBC Act. Representors noted that vehicles and horse riding are a known source of disturbance to both feeding and nesting birds. They further noted that the potential impacts of horses were recognised in the current plan which also included several policies/actions for monitoring breeding success and decreasing impacts. One representor (15) queried what monitoring of fauna has been undertaken since 2000, particularly in relation to beach nesting birds. Another representor (17) cited the Birdlife Tasmania submission referring to noted changes since the current plan in shorebird numbers and listing of the Hooded Plover under the EPBC Act. They commented that while the draft Plan acknowledges the EPBC Act listing of the Hooded Plover, it fails to mention any management changes that this may require. Birdlife Tasmania (16) suggested several areas of foreshore which they recommended be rezoned from Recreation Zone to Conservation Zone and managed accordingly to protect Hooded Plovers, Pied Oystercatchers and smaller numbers of other wader species. One representor (18) commented that the Plan is inadequate in areas of natural and cultural heritage conservation giving the examples of inadequate attention to threatened species, many of which are concentrated in the recreation zone and the access of horses and 4WDs to Bakers Beach threatens the hooded plover populations that survive there. Director’s response The Director responded to these representations by stating that the alteration does not substantially alter current allowances for horse riding. He noted that the new commercial proposal is subject to an applicable assessment processes which will consider potential impacts on shore birds while general usage is regulated. In response to the suggestion by Birdlife Tasmania that areas of foreshore be rezoned as Conservation Zone, the Director noted that further consideration/consultation is warranted and that the matter requires further exploration and discussion with stakeholders in any future full plan review. In response to representor 17’s comment regarding the adequacy of the attention paid to natural and cultural heritage protection, the Director stated that the plan should include updated information on the status of the saltmarsh community and hooded plover in the revised description in section 3.3 Flora. In response to representation 15 the Director stated that issue raised (monitoring of fauna) was outside the scope of the proposed alteration. With regard to representor 18, the Director acknowledged that there are areas in the current plan that require review, stating that this would be undertaken during any future full review.

Review 9 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Commission’s findings The Commission notes the discussion in the Director’s Report on these matters, including a proposal to provide more information in section 3.3 of the draft Plan about the vulnerable listing of the saltmarsh and Hooded Plover under the EPBC Act. The Commission notes that a change to the description in section 3.4 Fauna would also be necessary to include a statement about the vulnerability of the Hooded Plover as section 3.3 only relates to Flora. The Commission considers that the Director has adequately responded to the majority of representations. 3.0 Conclusion The Commission conducted its review of the Director’s Report on the draft Plan and the representations, as set out under sections 22 - 24 of the Act. The Commission’s review was restricted to considering the adequacy of the Director’s responses to the representations. The Commission determined that as there was enough information in the documents received in order for it to undertake its review, it was unnecessary to hold a public hearing on the matter. The Commission noted that most, if not all, representors raised issues on areas of the draft Plan unrelated to the proposed alterations. It appears that this was due to the fact that a largely unaltered version of the Management Plan was included as part of the public exhibition process. The Director acknowledged that this process may have resulted in a lack of clarity as to the purpose and limited nature of the altered draft. He advised that the current Management Plan will be subject to a full review in the future and that these comments will be considered at that time. The Director stated in his Report that responses to representations must be limited to those matters that pertain to the proposed alterations and accordingly, he limited his detailed responses to only those matters. The Commission supports this approach. In general, the Commission found that the Director’s response was adequately detailed and addressed the relevant concerns and comments from representors.

Review 10 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Appendices Appendix 1 List of Representors 1 Bob & Helen Ashby 2 James Sharman 3 Phil Collier 4 Philip Milner 5 Ian & Marsha Ferris (in support of Philip Milner) 6 Malcolm & Karen Mars 7 Christine Needham 8 Cassy O’Connor MP (obo The Greens) 9 Vishnu Prahalad 10 Catharine Errey (obo Tasmanian National Parks Association) 11 Patricia Jane Wilson 12 Beverly Rockliff (obo Port Sorell History Group) 13 Catharine Errey 14 Susanna Van Essen 15 Cathie Plowman 16 Eric Woehler (obo Birdlife Tasmania) 17 Peter McGlone (obo Tasmanian Conservation Trust) 18 Malcolm Wells (obo National Parks & Wildlife Advisory Council) 19 Heather Sculthorpe (obo Tasmanian Aboriginal Centre)

Appendix 1 11 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Appendix 2 Letter of Clarification on the Director’s Report

Department of Primary Industries, Parks, Water and Environment Hobart GPO Box 44, Hobart TAS 7001 Launceston PO Box 46, Kings Meadows TAS 7249 Devonport PO Box 303 Devonport TAS 7310 Ph 1300 368 550 Web www.dpipwe.tas.gov.au Inquiries: Andrew Harvey Phone: (03) 6165 3068 Email: [email protected] Our Ref: H591409 Your Ref: 28 September 2016 Mr Greg Alomes Executive Commissioner Tasmanian Planning Commission GPO Box 1691 HOBART TAS 7001 CLARIFICATION ON THE DIRECTOR'S REPORT NARAWNTAPU NATIONAL PARK, HAWLEY NATURE RESERVE DRAFT MANAGEMENT PLAN 2015 (ALTERING THE NARAWNTAPU NATIONAL PARK, HAWLEY NATURE RESERVE MANAGEMENT PLAN 2000) I wish to provide clarification concerning a particular matter arising from the response in the above Director's Report to the representation submitted by Birdlife Tasmania. The representation included a map showing coastal avian values (included as 'Appendix 1') and an updated bird species list extracted from the Birds Tasmania database (included as 'Appendix 3'). The response in the report (page 28 and 29) to these components of the representation was that this information would be reviewed for inclusion in the proposed alteration to the relevant values statements in the Management Plan. Following further consideration, the suggestion that this information would be considered in the proposed alteration to the Plan does not properly account for the practical requirements of the verification that would be necessary for such an inclusion. Therefore it would have been preferable to respond with the suggestion that this information should be considered in any future full review of the Management Plan rather than in the alteration that is the subject of this current process. In other words, the response should have been 'Consideration/consultation warranted - consider in any future full review', rather than 'Plan change warranted'. In addition to being a more practical response, this response is also more definitive and therefore better meets the statutory requirements of the Report. I would therefore ask that the Commission considers this ·response to these matters, rather than the response in the Report that indicates that a Plan change is warranted. If you wish to seek further clarification, please do not hesitate to contact Andrew Harvey by email, [email protected] or by phone, 6165 3068. I trust this assists the Commission in its review.

Tim Baker A/DIRECTOR OF NATIONAL PARKS AND WILDIFE

Appendix 2 12 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000)

Appendix 3 Report from the Director of National Parks and Wildlife

DEPARTMENT OF PRIMARY INDUSTRIES, PARKS, WATER AND ENVIRONMENT Report from the Director of National Parks and Wildlife to the Tasmanian Planning Commission on the Public Representations received on the Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) 1. Introduction In accord with s 20(12)(b) of the National Parks and Reserves Management Act 2002 (NPRMA), a draft management plan for Narawntapu National Park, Hawley Nature Reserve altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000 was made available for comment by the public and the National Parks and Wildlife Advisory Council (NPWAC) from 14 November until 16 December 2015. The NPRMA requires that the Director of National Parks and Wildlife (the Director) review any representations made during the public comment period (s 21). This review is to be in the form of a report containing a summary of the representations, the Director’s opinion on the merits of the representations, including an indication of whether the representations are of sufficient merit to warrant modification of the draft management plan, a summary of any proposed modifications and any additional information the Director considers relevant (s 21(b)). This report (the Director’s Report) is intended to satisfy that requirement. The draft plan was an alteration to the existing Narawntapu National Park, Hawley Nature Reserve Management Plan 2000 and was initiated as a result of the receipt of a project proposal for the park through the Tasmanian Government’s recent Expression of Interest (EOI) process for new tourism opportunities in the Tasmanian Wilderness World Heritage Area, national parks and reserves. Cradle Country Adventures submitted an EOI proposal for a commercial horse riding operation in the Narawntapu National Park. An element of the proposal, involving opportunity to utilise a link track to Bakers Beach while retaining horse riding access to the length of the beach east of this track, was identified as not being provided for under the current management plan. The proposal was considered by the EOI Assessment Panel. The panel recommended to the Minister that the proposal met the guiding principles and criteria for the EOI process. The Minister invited the proponent to proceed to Stage 2 of the EOI process, where more detailed information was provided for consideration. Following the more detailed consideration and on provision of advice, the Minister considered it appropriate to amend the existing management plan to allow the activity to be considered through the applicable assessment processes. The alteration would allow existing horse riding access to the full length of Bakers Beach to continue in the event that the Cradle Country Adventures proposal and associated link track received the relevant approvals to proceed. Comments were received from nineteen respondents, including the NPWAC. These are summarised and responded to in Table 1. 2. Proposed Alterations The main change to the existing plan is in section 5.4.6 Horse Access, which has had the following section deleted: “If a horse trail link from Bakers Beach is provided (see Map 5), discontinue the authority to use horses on Bakers Beach east of such a link.” This change will enable the current opportunity for the full beach ride to continue, as well as enable the proposed shorter loop trail to be implemented. In addition, minor changes of a technical nature were made to replace references to out of date legislation and management documents. Natural values information was brought up to date, (sections 3.1-3.4, 4.2, Appendix 1, new Appendix 3 13 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Appendix 3c Threatened species). The latest visitor figures were provided (sections 5.1 – 5.2). Some minor provisions of the 2000 plan that have been completed are moved from “actions” to the descriptive sections - removal of unsafe play equipment (section 5.5) and assessment of the old vehicular track behind Copper Cove for fire management purposes (section 4.1). The scope of the changes in the 2015 plan are not intended to and do not extend to any change, other than the main change described, to the principle policy settings or management prescriptions of the 2000 plan. 3. Cradle Country Adventures Proposal A proposal by Cradle Country Adventures to expand the horse riding experiences within Narawntapu National Park has passed through initial EOI assessment process and is now going through the Parks and Wildlife (PWS) environmental assessment and approval process, the Reserve Activity Assessment (RAA). The proposal includes new horse yards and implementation of the short horse riding loop from the middle of Bakers Beach that was identified in the 2000 plan. The proposal also includes conversion of Springlawn farmhouse to visitor accommodation. These proposals are all in keeping with the 2000 management plan, subject to assessment. The main alteration to the management plan will allow the existing use of the full length of Bakers Beach by horse riders to continue should use of a link trail be authorised. For many years horse riding has been taking place on Bakers Beach under authority, with conditions imposed to avoid impacts on shorebirds. Appropriate contemporary conditions of access will continue to be applied to horse riding activities on Bakers Beach, and within the broader national park, to ensure adequate protection of the park’s natural and cultural values. 4. Overview of Representations Nineteen representations were received. A common theme across many of the representations were concerns regarding the process undertaken for altering the plan. Concerns were also raised regarding the level of detail available for the Cradle Country Adventures proposal and that the plan was being altered to allow for a commercial development, as well as general concerns regarding the role of commercial tourism in national parks. Many representations raised concerns regarding the impact of horse riding on nesting shore birds and were opposed either to current usage of the area for riding or to any new increase or change in opportunity for riding through the utilisation of the link track and extent of Bakers Beach under the proposed alteration. It is apparent from the content of representations that many representors were under the misapprehension that the public were being asked to comment on the draft plan in its entirety. Although both the public notice inviting comment on the draft, the website and the draft plan itself referred to the purpose of the alterations, it is acknowledged that the provision of the alterations in the form of a complete draft which largely consisted of an unaltered version of the current management plan may have resulted in a lack of clarity as to the purpose and limited nature of the altered draft. Many representations therefore provided sometimes extensive comment on areas unrelated to the proposed alterations. It is understood that the current management plan requires a review in some areas of management. All management plans undergo a process of updating over time and the current management plan will be subject to full review in the future. The views and information provided in representations with respect to the plan as a whole are acknowledged and will have value in any future review. 5. Review of representations and proposed responses Responses to representations must be limited to those matters that pertain to the proposed alterations. It is recognised that there may be a number of other matters in the current plan that may require review, however, it was not the intent of the alteration to address all possible issues requiring review, rather the alteration was largely to allow for a single change, although the opportunity was taken to update some technical information without changing any policy intent of the current plan. As such, those comments that relate to matters that were not the subject of the main alteration, or other minor alterations are noted in this report but no response is provided. Table 1 summarises the representations and provides a response from one of the following categories: Noted - in relation to assertions/statements of opinion, where the comment relates to issues that are either beyond the scope of the management plan generally, for example, comments related to the EOI process itself, or the

Appendix 3 14 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) proposed alterations that are the subject of the statutory process, for example, comments concerning areas of the plan that are not proposed to be altered. Consideration/consultation warranted – although outside of the scope of this process, this response is provided in relation to recommendations that may have merit requiring further exploration and discussion with stakeholders in any future full plan review. Plan change warranted – where a change to the proposed alterations is proposed based on the merits of the representation No change warranted – where a change to the proposed alterations is not considered necessary based on the merits of the representation The table and the provision of the responses is provided to meet all the requirements of s 21(b) of the NPRMA, including an indication of the merits of the representation where it pertains to the proposed alteration. The table also functions as a summary of changes given that it provides an explicit indication of where a change to the proposed alterations is proposed on the merits of the relevant representation. 6. Recommendations The key policy change effected by the proposed alteration is to allow for the use of the short link track from the inland road network through to the middle of Bakers Beach, as identified in the current management plan, for the purposes of horse riding without such use impacting on the ability to continue to utilise the full length of Bakers Beach for horse riding. This change was in response to a proposal from Cradle Country Adventures for a commercial horse riding venture which sought to use the link track, however it will be applicable to all horse riders using the park. It is important to understand that this proposal has already under gone a level of assessment through the established EOI assessment process and that it was on this basis that the change was considered appropriate. It is equally important to recognise that while this additional opportunity of use was provided, it in no way removes the need for the proposal to undergo any applicable assessment process. These processes will assess the final, detailed proposal and, if approved, will determine and impose conditions to mitigate any potential impact on values or other park users. The proposal, if approved, will be a regulated activity through the provision of a licence or lease granted under the NPRMA. On this basis it is not considered necessary on the merits of any representation to amend or remove the proposed alteration to section 5.4.6. The other minor alterations to the current plan are in the form of updated natural values information. It was rightly pointed out in a number of representations that this information neglected to identify that the park contains areas of salt marsh listed under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBCA) as a threatened ecological community; ‘subtropical and temperate coastal saltmarsh’ and that the hooded plover is listed as ‘Vulnerable’ under the EPBCA. It is proposed to amend the alteration to the relevant flora and fauna values section to rectify this omission. In addition a number of representations provide natural values information that, as indicated in the summary, should be reviewed and included in the final natural values alteration as required. Collectively the representations have provided valuable information on management issues, values and potential future directions for the management of the national park that should be fully considered in any future plan review. Many have provided operational advice that has been passed on to managers. The time and effort put into the representations is acknowledged and is appreciated.

Appendix 3 15 Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000)

Table 1 Summary of Representations and Responses

Summary of Representations Director’s Response

Representation 1 Bob and Helen Ashby

Strongly oppose further development of tourist facilities in the park, in particular Noted - the buildings precinct within Narawntapu National Park is more accommodation, as this will irreversibly degrade it. There are plenty of other relatively concentrated. There is no intention to remove or reduce places in the region where people can stay close to wildlife. Would like children and current managed camping opportunities within the national park. grandchildren to experience camping in a national park as it was when they were Accommodation is allowed for within the Springlawn Visitor kids. Leave this part of Tasmania alone for those who love Tasmania as it is. Services Zone in section 5.5.1 and the proposed accommodation as part of the horse riding operation will make use of an existing building. The proposal is subject to assessment. Representation 2 James Sharman

Draft plan is misleading as public could believe it has been revised to consider Noted – the proposed alteration was detailed and identified in the appropriate management of natural, cultural and social aspects of park rather than draft. just deletion of one sentence. Plan should include detail of relationship between tourism EOI and alteration of Noted- opinion. It is not necessary or appropriate to include the plan to provide clarity on costs, risks, opportunities and benefits of transferring information referred to in a management plan. public asset to private sector and implications for research funds, logistics etc. A commercial lease arrangement is required for any commercial use of Crown property. Plan does not consider anticipated impacts on key values such as nesting Noted - impacts on cultural and indigenous features and native shorebirds, cultural and indigenous features and native flora. flora are required to be fully considered in the applicable assessment processes. Public statement that this is an updated plan is misleading and inappropriate given Noted – the purpose of the alteration was identified and described lack of discussion on mitigating impacts of increased horse-riding on bird nesting in the draft. sites, Aboriginal middens or weed management.

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Altering park management plans in this manner to allow for development for Noted- the alteration allows for an opportunity only; management private business over management of natural and cultural values for which parks of natural and cultural values will be informed by the applicable are reserved undermines the purpose of plans and their implementation through assessment processes. PWS. Representation 3 Phil Collier

The draft plan Summary includes a focus on threatened species but the body of the No change warranted – preparation/implementation of plan does not provide any detail. The plan should indicate the current status of the management programs for flora and fauna are already included at species in the park; provide a statement of significance of the Park and Reserve for 3.3 and 3.4, the alteration was limited to updating information. the species within the local region and Tasmania generally; and then provide a statement about the desired outcome for each species, any actions necessary to manage the species within the Park, estimated cost of actions and likelihood that actions will provide desired outcomes. Threatened flora species can then be prioritised and actions prioritised. For high priority species there should be an overlay on the Management Zone map Consideration/consultation warranted – consider in any future full to ensure any proposed visitor activities do not directly conflict with the desired review. outcomes for priority species. Community Support section could be strengthened, titled “Community Consideration/consultation warranted – consider in any future full Engagement”, include a program of active engagement with volunteers from the review. community and acknowledge past and on-going support and engagement. Noted – this is not a matter to be addressed through the Noted lack of response to recommended actions for Spyridium obcordatum in management plan Reserve, and need for feedback from PWS. Narawntapu and Hawley are very important protected areas on the mid-north coast Noted of Tasmania, providing natural systems that are home to many threatened species, these species and systems need to be the highest priority in the plan Park and Reserve should be primarily managed for its natural values in a natural Noted – The proposed alteration does not significantly alter setting, including peace and quiet, and only permit recreational activities that do existing use. Schedule 1 of the NPRMA prescribes ten management not significantly detract from this priority. objectives for the reserve class of national park. These are not ranked and include encouragement of tourism, recreational use

Appendices 17

and enjoyment, consistent with conservation of natural and cultural values. Assessment of the proposal will ensure a balance between the objectives is achieved and the requirements of the NPRMA are met. Endorses Philip Milner’s submission Noted, see responses below

Representation 4 Philip Milner

Proposal to extend horse riding into additional areas of the park (5.4.6 and Map 5) Noted- potential expansion of horse riding beyond what is Reconsider proposal to permit horse riding along the fire trail adjacent to the south- currently allowed for is subject to assessment processes that west boundary of the park as there is an unacceptably high risk that important would require and consider the development of appropriate biological values will be compromised. Many locations along trail are key places for mitigation measures. The existing allowance referred to is not the orchids, particularly sun orchids, including endangered Thelymitra antennifera. This subject of the proposed alterations but can be reviewed in any area of park is largely free of weeds. Weeds spread through horse droppings pose a future plan review. specific threat to the integrity of the orchid habitat. Horses should be excluded from known and potential habitats of all threatened species. Also high probability of disease spread and exacerbation of erosion on fire trail. Proposal to relax restrictions on horse riding along the full length of Bakers Beach No change warranted – the alteration does not substantially alter (5.4.6. and 3.4) current allowances. The new commercial proposal is subject to The management and control of horses on Bakers Beach should be strengthened as applicable assessment processes while general usage is regulated. it is key habitat for wading birds, such as the Pied Oystercatcher and nationally threatened Hooded Plover. Birds are present on the beach all year round and horses have been observed disrupting feeding birds. Maintain restrictions during breeding season, limit and designate locations for horses to enter the water, do not permit access to the full length of the beach, particularly the eastern third which is the key location for the species. Limit horse numbers permitted on the beach at any one time.

Appendices 18

Proposal to relax restrictions on vehicle use along the length of Bakers Beach (5.4.3) Consideration/consultation warranted – consider in any future full There is no sound reason for any increased use of vehicles along the full length of review. Bakers Beach. There is documented evidence of vehicle damage to the structure and bio-ecology of beach sands, disruptive of wading birds and the quiet unspoiled atmosphere for other low impact users. Vehicles using beach should only be for park management. Proposal to establish a public camping area and licenced camp at Copper Cove Consideration/consultation warranted – consider in any future full (5.5.4). Area of Copper Cove where Winifred Creek meets Bass Strait has been review. degraded by inappropriate use since the 1970s. Camping proposals are unnecessary and undesirable as there are very limited areas for the purposes and environmental impacts on sensitive coastal vegetation would be excessive. If additional camping needed, consider western end of Badger Beach or on adjacent freehold land. Proposal to construct a boat ramp facility at West Head at eastern end of Badger Consideration/consultation warranted - consider in any future full Beach (5.5.2) This is the most inappropriate location for a boat ramp in every review respect as the infrastructure required would severely compromise natural and environmental values (Coastal Heathland on Dolerite heathland community, Allocasuarina verticillata forest restricted to this part of the park and threatened plants, including Millotia muelleri with West Head its only known occurrence in Tasmania. The location is also exposed, requiring a substantial breakwater to be safely useable. Mountain bike access (5.4.5) Notes increasing use of mountain bikes and safety Noted – there is no proposed alteration to policies for mountain hazard to walkers due to speed and limited visibility. There should be an assurance biking, compliance is an operational matter. in the plan that any fire trails or walking tracks made accessible for cycling are not closed to walkers. Mountain bikes should not be permitted on walking track between Greens Beach Noted – there is no proposed alteration to policies for mountain and West Head or on any other dedicated walking tracks within the park, because of biking, limitations on bicycle use within the park are included at conflicts with walkers. 5.4.5 which notes bicycles are only allowed on public roads and designated vehicle tracks.

Appendices 19

No new bike tracks should be established in the West Head, Wentworth Hill area as Noted – this is currently not provided for under the existing plan it has been excessively impacted by clearing for access roads and fire breaks. and is not the subject of the proposed alteration.

Threatened species of flora – Issues (3.3) The park is a key location for a number of Noted – there is no substantive proposed alteration to threatened threatened species of flora which are highly localised and their protection and flora policies or actions. Threatened species have legislative conservation should receive the highest priority in the plan. No impact should be protection under the Threatened Species Protection Act 1995 or, if the requirement for all threatened species in the park. applicable, the EPBCA. Threatened flora species are given scant attention in the plan and a more targeted Noted – there is no substantive proposed alteration to threatened approach for the effective conservation and management of them is required. flora policies or actions. Queried whether there are any plans for species as prescribed on p.16. Noted – the action refers to programs but is not relevant to the proposed alteration.

Fauna and threatened Fauna issues (3.4). There needs to be more recognition and Noted emphasis on the sound management of specific fauna habitat. There needs to be a more proactive approach to address specific management issues when they arise and not left until there are few options remaining as has been the case in the recent mass culling of wombats. Wombat - Culling should be a very last resort and this should be stated in the plan Noted as well as the intent to investigate and implement other methods of wombat and wombat mange management, such as practiced in Victoria. Tasmanian Devil – significant risk to devils from motor vehicles, reduce risk by Noted – this can implemented operationally. reducing dusk to dawn speed limits on roads within and adjacent to park, in cooperation with other authorities, involving policing with speed cameras. Hooded Plover – Bakers Beach is key location for HP along Tasmanian’s north coast Noted as there are few other beaches within secure reserves between here and Rocky Cape. See above recommendations re vehicles on beaches and horse riding. Eastern Curlew – tidal flats around North-east Arm are important habitat for Noted – this is not within the scope of a management plan. migratory wading birds, including Eastern Curlew which is now listed as a threatened species. Rubicon estuary is an important nursery for fish and other marine life. Only northern half of North-east Arm is include in the park and this

Appendices 20

should be rectified as a priority by including the remaining half in the park.

Bird conservation – there are numerous bird species recorded in the park that are Noted – feral cat management can be implemented operationally, vulnerable to predation by feral cats (eg Hooded Plover, Ground Parrot, others this issue can be considered in any future review listed). A more proactive and targeted approach to feral cat management is required and should be an essential component of the plan. Small mammals – same comments as above apply. Noted

Introduced Fauna (4.2.1). It is likely that feral cats are having a significant impact on Noted - feral cat management can be implemented operationally, native fauna in park, especially smaller bush birds, ground nesting species and small this issue can be considered in any future review mammals. Same comments as for Bird Conservation above. Weed Management Issues (4.2.2) Weed management does not seem to be a high Noted – weed management was not the subject of the proposed priority in the plan and looks to have been put in the too hard basket because of alteration. Euphorbia paralis is identified. The alteration does not limited resources. No mention of Euphorbia paralis, a significant weed impacting substantially alter current allowances for horse riding. The new sand dunes at Bakers Beach or serious infestation of Polygala myrtifolia at Badger commercial proposal is subject to applicable assessment processes Head entry to park which has established and extended into the park after the while general usage is regulated. Weed control is part of standard recent management burn. Allowing horses into relatively weed free areas of the park management, under the management objectives for national park will exacerbate weed management problems and further stretch limited parks. The newly formed Friends group will be of great assistance resources. Plan should include a weed management strategy to cover preventative in tackling weed management. measures and proactive strategy for controlling and managing weeds in and adjacent to the park. Disease management issues (4.2.3) – Phytophthora also reads as if it is too hard. It Noted. The alteration does not substantially alter current is having significant impact on sensitive heathland vegetation, particularly allowances for horse riding. The new commercial proposal is heathland dominated by Xanthorhoea australis. Complete mapping the distribution subject to applicable assessment processes while general usage is of the disease should be the first priority. A more effective and proactive strategy regulated for disease management should be included in the plan, considering hygiene stations at appropriate locations in order to restrict spread of disease. Proposal to allow horses into further areas of the park will result in disease spread.

Appendices 21

Fire Management Issues (4.1) – Ecological principles should be over-riding and first Noted. Weed and erosion control are part of standard park objective of fire management. Plan should be re-worded to ensure good vegetation management, under the management objectives for national management in the use of fire is given priority. Most recent management burn on parks. These comments can be taken into account in park edge of Badger head has allowed serious weed to spread (see above) and also burnt operations fragile vegetation on the coastal crest of the headland which resulted in significant soil erosion in some locations. Follow up management is required. The firebreak around the park adjacent to Wentworth Hill is excessively wide and Noted. These comments can be taken into account in park has had significant impact on vegetation here. This firebreak area should be operations. reviewed with the aim of reducing it to a sensible width. National Park boundaries (1.2.2 and 7.1). A more proactive approach to correcting Noted – this is not within the scope of a management plan. fragmented park boundaries should be included in the plan with the aim of achieving effective ecological boundaries and maintaining and/or establishing ecological connectivity. Two obvious improvements: (1) inclusion of important wading bird and marine fauna habitat, the balance of the tidal flats south of the centre point of North-east Arm and (2) transfer of the Briggs Regional Reserve located on the east facing slopes of the Asbestos Range into the park. Both would be important additions to the park and should be given priority. Make concerted effort to rectify disjointed boundary around Badger Head and Noted – this is not within the scope of a management plan. northern end of Asbestos Range. And add these critical areas to the park.

Transfer all or part of Briggs Regional Reserve into the park where it adjoins the Noted – this is not within the scope of a management plan. southern part of the park, making an ecologically sound boundary considering catchments and ridgelines. Zoning Issues (2.5 and map 4) Consideration/consultation warranted – consider in any future full West Head and Wentworth Hill at eastern end of the park should be in the review. Conservation Zone to ensure the biological diversity is considered in future management decisions. Recreation and Visitor Services are inappropriate zonings over this area, here these zones should be limited to linear zones of minimal width along track lines and the access road, as has been applied at other locations in the park.

Appendices 22

A relatively small area at western end of Badger Beach should be re-zoned to Consideration/consultation warranted – consider in any future full become part of the Visitor Services Zone to potentially accommodate an alternative review. camping area to that original proposed for Copper Creek, The coastal walking track between Little Badger Head and Badger Head entry to the Consideration/consultation warranted – consider in any future full park extends through some of the most fragile and sensitive vegetation in the park. review. For this reason the coastal headland, crest-line, the headland slopes and the shoreline of Badger head, Little Badger head and Copper Cove should be included in the Conservation Zone, with the Recreation Zone restricted to a linear zone of limited width alongside the existing walking track. Conclusion and Summary The changes to the plan focus on entertainment and Noted – the proposed alteration only allows for continued horse sporting /recreation rather than the key objectives of protection and conservation riding on Bakers Beach in the event that the short loop track is of flora and fauna and the entire ecosystem of this most important area. There is a utilised. clear disconnect between the vision and objectives on p 7 and the inappropriate development proposals detailed in the document. The introduction of additional impacts – horses, bikes, cars, camping grounds, boat ramps etc. can only degrade an detract from the qualities of the park. There are suitable areas of private land in the surrounding locality where these activities could take place and where the operators have an interest in protecting and maintaining the positive aspects of the land. Representation 5 Ian and Marsha Ferris

We have read Philip Milner’s submission, and being very familiar with the area Noted. described, endorse the comments, and agree with the recommendations.

Representation 6 Malcolm Mars and Karen Mars

Appendices 23

The park is under severe stress from pests, diseases and other risks such as weeds, Noted – the proposed alteration only allows for continued horse wombat mange, DFTD, healthy devil road kill, feral cats, stray dogs etc.- State riding on Bakers Beach in the event that the short loop track is Government should be instigating measures to eradicate threats as a priority. utilised. Inexplicable to even consider facilitation of detrimental proposals such as extended horse riding trails. The Hooded Plover, which would be particularly affected by expanded horse riding Noted - the new commercial proposal is subject to applicable along Bakers beach, is listed as Vulnerable under EPBCA. Horses spread weeds as, assessment processes while general usage is regulated. diseases and damage native vegetation, therefore we consider that they should be completely prohibited from the park with the current operation re-located outside the park. Provides information and links to National Parks Association of NSW report on horse riding impacts in natural areas. Extremely concerned about potential proposals (p. 33) to construct new roads and Noted – this is not the subject of the proposed alteration, however allow motorised vehicles on Bakers Beach. We consider that no new roads should it should be noted that the policy referred to does not suggest or be constructed and vehicles completely prohibited from beaches. recommend the construction of new roads. Note that the reference to use of vehicles on Bakers Beach is from the 2000 plan and is no longer permitted by park management. Use of bikes should be prohibited. Noted

Draft plan is representative of arrant disregard of the State Government towards Noted protection of our natural environment. Call upon State Government to revoke approval of the Narawntapu Adventure Precinct and amend the draft plan accordingly with the aim of prioritising protection of the park’s natural values. Representation 7 Chris Needham

The plan amendment would have an impact on native flora and fauna and also Noted - the new commercial proposal is subject to applicable cultural and indigenous features of the park may be compromised by extended use assessment processes while general usage is regulated of horse trails. Weed species will also be introduced.

Appendices 24

Totally against any further opening up of our National Parks to commercial Noted operators, the effect is to privatise and commercialise our National Parks.

Please leave the 2000 management plan in place, no amendments. Noted

Representation 8 Cassy O’Connor MP Tasmanian Greens Representation

No rationale or information provided to explain or justify the deletion, making Noted – regardless of the current proposal, which is subject to informed community input into the draft plan not possible. assessment, the proposed alteration is considered to be self- evident. Suggest a second period of public consultation with the following information Noted – the statutory process provided under the NPRMA is provided: considered appropriate and sufficient given the limited nature of 1. The reason for current management plan being written the way it is, ie the relevant alteration. particular risks with horse riding in the park that the current plan was attempting to manage? 2. What risks, if any, to the values of the park if the sentence is deleted? Notes Hooded Plover use Bakers Beach, the bird is listed as vulnerable under the EPBCA and the number at Bakers Beach is in decline. 3. How will those risks, if any, be managed? 4. Information on the tourism proposal that the amended plan is designed to facilitate. Notes that only information available is on Coordinator-General website but that does not reflect the current proposal, diminishing the ability for an informed submission to be made. Hopes second period of public consultation can take place as our national parks are for everyone and changes to their management plan should be fully explained and consulted upon.

Appendices 25

Representation 9 Vishnu N. Prahalad

The North East Arm Section of the park has expansive saltmarsh areas which are Plan change warranted - plan should include this information in the listed as a “threatened ecological community” (category: vulnerable) under the revised description in section 3.3. EPBCA. The area near Springlawn Beach has large Tecticornia arbuscula shrubs which are rare in Tasmania (photo provided) The saltmarsh has previously been cleared and levees built, visible on land and by Consideration/consultation warranted – consider in any future full aerial imagery (photo provided). There is a push, internationally and in Australia, review. This action could also potentially be implemented under for levees to be removed so that saltmarshes can regain lost territory and also help the existing management plan. them adapt to rising sea levels (references provided). It would be worthwhile to identify this possibility in the plan where Narawntapu can take a lead in State-wide restoration of saltmarsh. Saltmarsh is a sensitive vegetation community with important natural values Consideration/consultation warranted – consider in any future full (references provided). Notes that Map 4 identifies the entire saltmarsh area as a review, noting that existing trails would need to be excluded. Recreation Zone. Recommends the area to be re-zoned to Conservation Zone. Representation 10 Tasmanian National Parks Association

A major rationale for park management planning is to obtain credibility and public Noted – the alteration has been undertaken in accord with the acceptance for the proposed management approach through meaningful public statutory process set out under the NPRMA. engagement. PWS has previously had a high standard in this regard but this draft plan has been released for comment without any prior public engagement. No rationale is provided for the proposed change or explanation that it is to Noted -– regardless of the current proposal, which is subject to facilitate a commercial horse-riding operation in the park. Little information is assessment, the proposed alteration is considered to be self- available on the proposal which has since been modified but clearly involves a loop evident. track and use of the full length of the beach that will result in a significant increase in horse use of the park.

Appendices 26

Observes that no explanation of original trade-off: if new horse-riding loop trail is Noted. constructed a section of Bakers Beach will be closed to horse-riding. Assumes it was to compensate for increase in horse-traffic on one section of beach by providing a horse-free section of the beach for other users and enhance protection of natural values, in particular by removing a source of disturbance for shore-nesting birds. Updating of natural values information has not included recognition of the values of Plan change warranted - plan should include this information in the extensive saltmarsh now listed as a vulnerable ecological community under the the revised description in section 3.3. EPBCA. The management prescriptions have not been updated to reflect the new values Consideration/consultation warranted (zoning of saltmarsh areas) information, especially the importance of the saltmarsh community much of which – consider in any future full review. Management actions are is zoned Recreation and some of which is likely to be used by the horse-riding adequate given the updated values information. The possible proposal. impact of changes in use on any value will be considered through the assessment processes. Notes that the potential impacts of horses on shore nesting birds is recognised in Noted – the new commercial proposal is subject to applicable the 2000 management plan on p.34 and that pp 15-17, contain several assessment processes which will consider potential impacts on policies/actions relevant to the proposed plan change, including monitoring shore birds while general usage is regulated breeding success of shore birds and conservation status of the Hooded Plover. No change to the plan with the potential to increase impacts on shore nesting birds (such as the current proposal) should be contemplated until the above monitoring has been completed and demonstrated that populations of shore nesting birds are thriving with current levels of horse use. TNPA considers horse use in the park should be banned (as in most other national Noted – the new commercial proposal is subject to applicable parks) to protect the values for which it was reserved. If this is not acceptable, the assessment processes which will consider potential impacts on proposed amendment should not be approved until studies have been completed values while general usage is regulated to confirm that increased horse use will not impact on shore nesting birds, the saltmarsh community, Aboriginal heritage and the experience of other users of the area. TNPA’s greatest concern is that the government’s determination to facilitate private Noted development in the national park with the absolute minimum of public involvement demonstrates its contempt for both the values of the park and the concept of

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management planning. Representation 11 Patricia Jane Wilson

The 2015 draft plan does not provide the reason behind the need for this change to Noted -– regardless of the current proposal, which is subject to the 2000 plan or any explanatory information to justify the amendment. As a person assessment, the proposed alteration is considered to be self- making a representation I ought not to have to guess what is going on. This is a evident. Allowance of the activity in the management plan does lamentable failure of proper process for park management planning. PWS has the not remove the need to undertake the detailed assessment. duty of explaining in a draft plan why a change to the original plan is warranted and must demonstrate that all projected impacts on key values of the park have been given due consideration. This has not been done. Also, before a draft plan is published, PWS carries out extensive consultation with Noted – the alteration has been undertaken in accord with the all relevant stakeholders to ensure the draft plan is welcomed and accepted as statutory process set out under the NPRMA. valid. This has not been done. The original rationale for the section to be deleted is not clear, also a failing. The Noted – the new commercial proposal is subject to applicable inference is that should a new horse-link trail be provided, as shown on Map 5, assessment processes which will consider potential impacts on then a trade-off will occur on the eastern side of Bakers Beach where horse-riding shore birds while general usage is regulated. will be prohibited, providing protection for park values on that part of the beach. The proposed deletion shows that, in the unlikely event that the new link trail is constructed, the government is prepared to put the priorities of a commercial horse-riding venture over and above preservation of park values. This is not acceptable. Horse riding is incompatible with preservation of natural and cultural values with Noted impacts on nesting shore birds and on fragile saltmarsh habitats of particular concern. Horse riding in the park should be banned and the 2000 plan revised accordingly. If this is not done and the proposed plan amendment is still considered worthy of scrutiny then it needs to be subjected to a thorough planning process and not approved until it can be shown that it will not have an impact on the natural and cultural values of the park.

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Of great concern is that the government has put in place the commercial tourism Noted EOI process which is undermining the PWS national park management planning processes. The Narawntapu 2015 draft plan is a regrettable demonstration of this betrayal. Representation 12 Port Sorell History Group

Port Sorell History Group seeks an amendment to the management zone relating to Consideration/consultation warranted – consider in any future full Rabbit Island and Shell Island, from Conservation Zone to Recreation Zone. review.

Notes the definition of Conservation Zone and questions the suggestion that the Noted islands include high quality natural landscape values, old growth or priority forest communities and key fauna habitat for threatened species. The islands have a remarkable story to tell of early life at Port Sorell. While the Noted – PWS will continue to liaise with the Society. status of the islands remain as Conservation Zone, those stories and history is in danger of being lost. Lists findings in relation to use of the islands, including: as the site of the first Noted- PWS will continue to liaise with the Society. permanent residence in the Port Sorell area (Tom Rogers 1834); 1835 stay on Rabbit Island by John Batman and crew before they sailed off to found Melbourne; 1837 home invasion by bushrangers Brown and Jenkins ending in a police shoot out; evidence from correspondence that Cap George Robson lived on the island in 1844; capture of bushranger, Woolfe and gang on Shell Island in 1844. Up until the middle of the 20th century local residents grew crops and kept stock on the islands. Relics of the former history of Rabbit Island, including bricks from a residence, a Noted – regardless of zoning these values can be managed in well, burnt lime mounds and chimney site are identifiable. Would be a loss to accord with recognised heritage conservation principles Tasmania’s history if such an interesting part of the local cultural heritage cannot be preserved, explained and protected for years to come. Map of Shell and Rabbit Islands (noting key sites) provided.

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Port Sorell History Group offers to further research the history of the islands and Noted - with thanks for research efforts. PWS will continue to liaise develop and maintain, in cooperation with PWS, the sites of historical and cultural with the Society significance along with relevant interpretation. Believe that such an undertaking would enhance aspects of tourism in Port Sorell as well as enhancing and preserving the cultural heritage of the islands. This cannot be achieved as long as the islands form part of the Conservation Zone. Representation 13 Catharine Errey

Section 5.4.6 – opposed to deletion of the sentence prohibiting horse access to the Noted – addressing points 1-6 regarding 5.4.6 as follows. eastern end of Bakers Beach once a new link trail is constructed. 1. Noted – the legislated purpose of national parks is for the Reasons are: protection and maintenance of the natural and cultural values 1. Proposed change would be counter to the legislated purpose of the park of the area of land while providing for ecologically sustainable because it would mean that recreational activity was being given precedence recreation consistent with conserving those values. The over protection and maintenance of the natural and cultural values of the park. proposed alteration is considered to be consistent with that 2. Lack of transparency on the reason for the proposed change, sets a worrying purpose. precedent in lack of openness and transparency in decision making. 2. Noted -– regardless of the current proposal, which is subject 3. Privatisation of a public asset, Tasmanian parks and reserves are publically to assessment, the proposed alteration is considered to be funded public assets and the recreational amenity of these places is for all self-evident. Tasmanians, not just those who can pay. 3. Noted - general public access to the park will remain similar 4. Threats to shorebirds – horses and shorebirds which nest on beaches are a to the present. disastrous mix. The 2000 plan recognises this and sets out a clear plan for 4. Noted - the new commercial proposal is subject to applicable monitoring and minimising impacts on shorebirds. This has clearly not been assessment processes which will consider potential impacts followed and the draft 2015 plan appears to let go of any pretence of offering on shore birds while general usage is regulated. protection to shore birds on Bakers Beach. While horse numbers on the beach 5. Noted – as above. All values will considered in any have been greatly increasing, numbers of hooded plovers have been steadily assessment of the new proposal, while other use of horses is decreasing and in recent years there has been no observed breeding success regulated and subject to operational management as for pied oyster catchers on Badgers Beach. The Tasmanian government has an required. obligation under the Federal EPBCA to protect threatened species in the park. 6. Noted. 5. Threats to EPBC listed saltmarsh areas – the 2000 plan lists saltmarshes and

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lagoons as areas to be given high flora conservation priority. Horses do sometimes walk through the saltmarsh and cause damage. This must be discontinued and the provisions of the 2000 plan carried out. The proposed plan change encourages greater horse presence in the park and thus increases threats to vulnerable communities of conservation significance. 6. No more “untouched beaches” in the park – PWS website leads visitors to expect “untouched beaches”. This does not apply at present and the beach will be busier in the future if the proposed plan change takes place. One of the primary reasons that people visit national parks is to reconnect with nature and enjoy the peace and quiet that naturalness offers. Tasmania’s national parks, including Narawntapu, were established primarily to Noted. protect their natural and cultural values and to allow for public access and minimal impact recreational activities. The proposed plan change poses a threat to the natural values of the park, including EPBC listed species and communities but also has potential to adversely affect the visitor experience of the park. Horses must not be allowed in the park and the plan needs to be changed to bring about this exclusion. Representation 14 Susanna van Essen

World-wide crisis in shorebird decline due to ever increasing loss of habitat. Human Noted. impacts, including horse riding on beaches are causes of many species population crashes. National parks should be at least one sanctuary where habitats are protected for biodiversity not allowing greater human disturbance on already stressed species. Please protect Narawntapu from further incursions. Representation 15 Cathie Plowman

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Astounded that 2015 draft plan deletes goal of 2000 plan to discontinue authority Noted. to use horses on Bakers Beach. Horses have no place in Tasmanian national parks, in particular no place on beaches which provide critical habitat for shore birds. 2.2.1 What monitoring and evaluation has been undertaken since the 2000 plan to Noted. This section sets out evaluation requirements for a full evaluate planning outcomes? If this has not been undertaken how can the public review of the management plan. They are not required to be have any confidence it will be undertaken as a result of the new plan? addressed for a minor alteration. 3.2 Concerned about impact on water quality from use of horses and potential Noted - the new commercial proposal is subject to applicable impact form increased use of horses. Is there monitoring of water quality? assessment processes which will consider potential impacts on water quality while general usage is regulated. If required both processes can include mitigation measures for water quality. 3.3 What recent flora surveys have been done, especially in relation to Phytopthora Noted – this is outside the scope of the proposed alteration. and also in relation to the wildfire (thought to be arson associated) of several years ago? 3.4 What monitoring of fauna has been undertaken since 2000, particularly in Noted – this is outside the scope of the proposed alteration. relation to beach nesting birds, status of New Holland mouse, invertebrates?

3.5.1 Support plan being developed and implemented with real consultation with Noted members of the Aboriginal community. Wherever possible community to be involved in park management, staffing and any business developments. 4.2.2 Queries what action and evaluation taken in relation to liaison with local Noted – this is outside the scope of the proposed alteration. residents re garden plants that may escape into the park?

4.4 Commentary on visitor impacts and the need for education targeted at car- Noted based campers as this needs to be different to that provided to remote area bushwalkers and also to provide for interstate users. 5.2 Supports 2000 plan aim to provide a place where people can “get away from it Noted all”, this should be maintained in the face of proposals for increasing commercial developments in parks.

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5.4.2 Draft plan should deal with drones, consider their potential impacts and Noted – this is outside the scope of the proposed alteration. A management response. state-wide drone use policy for reserved lands is under development. 5.4.3 Motorised vehicles should not be permitted on Bakers Beach because of Noted – this is outside the scope of the proposed alteration. Note environmental and cultural heritage degradation and intrusion to a long unspoilt that the reference to use of vehicles on Bakers Beach is from the beach. Untouched, wild scenery brings joy and inspiration to people and parks 2000 plan. It is no longer permitted by park management. should protect this amenity for people of today and the future. Bakers Beach is especially valuable as it is readily accessible by road and close to Launceston, Devonport and rural areas. 5.4.4 The Walking track from Badger Head to Bakers beach is the only relatively long Consideration/consultation warranted – consider in any future full distance (about 3 hours) bushwalking track that is readily accessible to West Tamar review. residents. It is a valuable recreational resource and should be maintained and protected, not be subject to a new campsite and commercial developments. 5.4.5 Plan does not indicate how illegal use of bicycles might be controlled. Noted Noted – this is outside the scope of the proposed alteration. currently poor and sometimes confusing signage regarding use of bicycles on Improving signage is an operational matter. walking tracks. 5.4.6 Opposed to horse riding in the park and in particular on any beaches in the Noted – horse riding on the beach is an existing activity. park. The long and relatively unspoiled beach landscapes of Bakers beach and Badger beach are a valuable amenity in an increasingly developed world. Bakers Beach should be maintained and protected as a natural area for conservation of natural and cultural resources and so that people can enjoy its relatively unspoilt state. Horse riding is not compatible with this. Traditional use of horses in the park is not justification for the ongoing increase in Noted activity.

Acknowledges horse riding as a valid recreational pursuit but inconsistent with park Noted. Schedule 1 of the NPRMA prescribes ten management values and should occur outside the park. objectives for the reserve class of national park. These are not ranked and include encouragement of tourism, recreational use and enjoyment, consistent with conservation of natural and cultural values. Assessment of the proposal will ensure a balance

Appendices 33

between the objectives is achieved and the requirements of the NPRMA are met. Horse riding is considered a legitimate recreational pursuit in the park that can be managed to ensure it is compatible with protection and conservation of values. What studies have been done on the impact of horses and the carrying capacity of Noted - the new commercial proposal is subject to applicable horses in the park? assessment processes while general usage is regulated. There should be scientific monitoring of the activity. Horse riding should be limited to current usage, the numbers capped and no Noted increased development of horse riding tracks and facilities. Increasing horse riding trails and facilities increases the risk of spreading disease into newly developed areas. Commentary on damaging behaviour by campers identified in the plan and Noted reflection on the advantages of PWS staff residing in the park and building positive relationships with campers. Recommended that Springlawn homestead be maintained as a staff facility and where possible staff be encouraged to reside in the park. Noted that in USA national parks, rangers patrol campgrounds of an evening, engaging with visitors to promote care of the park. This was previously done in Tasmanian parks and should be encouraged, recruiting volunteer wardens if paid staff not available. 5.5.1 Any proposal for additional accommodation needs to consider the impact on No change warranted – the proposal utilises existing infrastructure current users, including traditional campers, and perhaps relocate current users to and is subject to assessment. other areas. Lodges, hostels and group accommodation bring noise and lighting impacts. The development of showers is not appropriate, the park cannot supply the water Noted – this is outside the scope of the proposed alteration. These required and there will be ongoing costs and management issues as well as matters would be considered in any assessment. greywater management issues. 5.5.4 Opposed to either of the proposed campsites at Copper Cove as the site is one Consideration/consultation warranted – consider in any future full of the few undeveloped and “remote” areas readily available to West Tamar review. residents. Informed commentary on current use of the site as a low key bush

Appendices 34

Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Summary of Representations Director’s Response camping area and likely damaging impacts of developing a formal camping area here.

Copper Cove should be made a fuel stove only area to reduce risk of wildfire and Noted – this can be implemented if required through the National limit further vegetation damage. Parks and Reserved Land Regulations.

5.5.7 Any proposals for business development in the park should be based on Noted. proper business planning (including environmental and recreational amenity costs) rather than “development at any cost”. 6.6.1 More needs to be done to increase positive links between the wider Noted – the sentiment is strongly supported. This is a broader community and the values of the park. Tasmanian national parks and wildlife are policy or administrative issue across the management of reserved valued by interstate and overseas visitors and many Tasmanians but a lot of lands. Tasmanians are disconnected from national parks and their values, hence issues with arson, littering, etc. Wildcare Inc can provide an effective link between community and national parks but needs more resources to do this effectively. At a minimum there should be a community engagement officer in each PWS region to foster and develop Wildcare membership. Also there needs to be adequate administrative support for Wildcare. 7.5.1 Reword staff training section to require more staff with appropriate tertiary Noted – this is outside of the scope of the proposed alteration but qualifications in park management. would not be an appropriate provision in a management plan.

Representation 16 Birdlife Tasmania

1. Horse riding on Bakers Beach Noted - the new commercial proposal is subject to applicable Hooded Plovers were listed as Threatened Species under the EPBCA in 2014. Horses assessment processes which will consider the potential impact on and horse riding on beaches were identified as threats to these birds in the Federal this species, while general usage is regulated Minister’s Conservation Advice (web links provided)

Appendices 35

Information from BirdLife Tasmania GPS mapping surveys of beach nesting birds Noted – the information provided is appreciated and will be throughout Tasmania indicates 16 breeding territories of Pied Oystercatchers and reconciled with DPIPWE natural values databases. one pair of Hooded Plovers on Bakers Beach in 2014/15. Map of locations provided. Bakers Beach important winter roosting beach for Hooded Plovers. Data from 1998 Noted on shows steady decrease in birds during winter, from 46 in 1998 to 5 in August 2012. Birdlife Tas considers it likely that disturbance to roosting birds has contributed to this observed decrease. Notes that horse riding occurs on Bakers Beach throughout the year and that horse Noted visits to the park have increased by more than 50% between 2010 and 2014. In 2014/15 more than 60% of horse visits occurred in the 6 month period encompassing the breeding season of Hooded Plovers. Expansion of commercial horse riding on Bakers Beach will increase the threats to Noted - the new commercial proposal is subject to applicable beach nesting shore birds year round – threatening nesting birds during summer assessment processes which will consider the potential impact on and roosting flocks during winter. shore bird species, while general usage is regulated The PWS Code of Practice for horse access does not protect beach nesting Noted – The Code of Practice can be reviewed if required. shorebirds from horse riding on beaches. There is no condition to require horses to be ridden on wet sand and horses are potentially able to access the upper beach where beach nesting shorebirds nest and raise their young. With limited park staff, Birdlife Tas considers that PWS staff do not have capacity to ensure compliance by more than 500 horse visits per annum to the park. No evidence to indicate that all horse riders adhere to the PWS Horse Access Conditions. Believes that no monitoring of potential impacts of horse riding on beach nesting birds occurs. Oppose horse riding on all beaches in Tasmania because of the massive threat they Noted pose to beach nesting birds. Consider horses to be as destructive as 4WDs and quad bikes on sandy beaches. Based on evidence of extensive disturbance to beach nesting birds elsewhere in Tasmania, do not support concept of “co-existence” – can have horses or successfully breeding Hooded Plovers and other beach nesting shorebirds, but not both.

Appendices 36

Given recent listing of Hooded Plovers as Threatened under EPBCA, PWS is urged to Noted - the new commercial proposal is subject to applicable introduce immediately a blanket ban on horses year-round on Baker Beach to assessment processes which will consider the potential impact on protect Hooded Plovers (and other shorebird values). this species, while general usage is regulated Immediately rezone Bakers Beach from Recreation Zone to Conservation Zone and Noted – this is outside the scope of the proposed alteration. manage accordingly to protect Hooded Plover.

2. Rubicon Estuary Important Bird Area (IBA) Noted - the Important Bird and Biodiversity Areas (IBA) program is Information provided about the IBA programme, IBAs are critical to ensure the an international non-governmental conservation scheme lead by survival of viable populations of most of the world’s species and also provide a BirdLife International Partners such as BirdLife Australia. The work holistic approach to conservation. Criteria for IBAs and weblinks provided. The can certainly be considered in the management of birds in the Rubicon Estuary supports more than 1% of the world population of Pied area, however there are a number of legislative mechanisms for Oystercatcher and smaller numbers of other wader species. the protection of threatened species (EPBCA and the State Threatened Species Protection Act 1995) and threatened vegetation communities such as wetlands (Nature Conservation Act 2002) in addition to recovery plans for specific species. All of these are in addition to the general protection afforded by the NPRMA and, for Matters of National Environmental Significance, the EPBCA. Immediately rezone the foreshore from Griffiths Point to Bakers Point to the park Consideration/consultation warranted – consider in any future full boundary at the eastern most point of NE Arm from Recreation Zone to review. Conservation Zone and manage it to protect the internationally significant High Conservation Values (Pied Oystercatcher) values present in the Rubicon Estuary IBA (described in Appendices 1 and 2) 3. Subtropical and temperate coastal saltmarsh Plan change warranted - plan should include this information in A glaring and troubling omission is any reference to EPBC listed threatened the revised description in section 3.3. vegetation community, Subtropical and temperate coastal saltmarsh that was listed as Vulnerable in 2013. Weblink provided to conservation advice and information. Information and links are provided to explain relationship between Tasmanian TASVEG saltmarsh mapping units and the national definition of Coastal Saltmarsh. Appendix 1 shows the extent of ASS Succulent saline herbfield that is included in the

Appendices 37

EPBC listed coastal saltmarsh, presently zoned Recreation Zone.

Immediately rezone the foreshore from Griffiths Point to Bakers Point to the park Consideration/consultation warranted – consider in any future full boundary at the eastern most point of NE Arm from Recreation and Visitor Services review. Zones to Conservation Zone and manage it to protect the EPBC listed community ASS Succulent saline herbfield areas present. 4. Protection of breeding seabirds on islands Noted Information about present and former bird breeding on the small islands in Rubicon Estuary – The Carbuncles, Penguin Island, Rabbit Island, Shell Islands – subject to varying degrees of human disturbance. Penguins have been recorded breeding, but with high levels of disturbance, this is no longer likely. Immediately increase protection to the breeding seabirds and other bird species Noted – this can be monitored for an operational response. present on the small islands in Rubicon Estuary and eastward of Port Sorell in light of the high levels of disturbance from dog walkers. 5. Invasive coastal plant species Noted – these species are identified in the plan. Weed control is Extensive areas of Sea Spurge, Euphorbia paralias are present in the park, Rice Grass part of standard park management, under the management Spartina anglica also. Both species have potential to fragment and alienate coastal objectives for national parks. The newly formed Friends group will feeding and roosting habitats used by shorebirds and seabirds. be of great assistance in tackling weed management. Eradicate Rice grass and Sea Spurge from critical feeding, roosting and potential Noted – this action is already provided for. nesting areas used by shorebirds and seabirds. 6. Updated bird list for the park Plan change warranted – this information to be reviewed for Birdlife Tas has an extensive database of sightings for the state, including the park. inclusion in the proposed alteration to the relevant values A total of 167 species has been recorded. Updated list provided for PWS use with statements. acknowledgement of Birdlife Tas as source. Opposes alteration of the 2000 plan to facilitate commercial interests. Noted The reserve estate in Tasmania was established to protect Tasmania’s biodiversity, Noted. The reserve estate is comprised of various reserve classes, cultural and natural heritage. Diminution of a park management plan to facilitate each of which has associated management objectives. While those commercial interests that over-ride conservation of natural heritage and are objectives include conservation of natural diversity and cultural

Appendices 38

Review of the Director’s report and representations: Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Summary of Representations Director’s Response destructive of biodiversity values in inappropriate and unacceptable. heritage, they also require encouragement of tourism, recreation and, for some reserve types, allow for utilisation of natural resources. Schedule 1 of the NPRMA prescribes ten management objectives for the reserve class of national park. These are not ranked and include encouragement of tourism, recreational use and enjoyment, consistent with conservation of natural and cultural values. Assessment of the proposal will ensure a balance between the objectives is achieved and the requirements of the NPRMA are met. Understands that current commercial horse riding proposal has been modified from Noted - the new commercial proposal is subject to applicable that on CG website. Questions how can the public make informed representations assessment processes, if approved the activity will be determined when the information available in the public domain is no longer relevant? through licence or lease conditions. The 2015 draft plan is not best practice for managing threats to coastal birds, or to a Noted threatened saltmarsh community or to an internationally significant estuary.

Rejects the proposed plan alteration, urges Tasmanian Government to actively Noted protect EPBC listed species and communities recognised in the park.

Appendix 1. Coastal avian values of Narawntapu National Park – map showing Plan change warranted – this information to be reviewed for breeding territories of Pied Oystercatcher, Sooty Oystercatcher and Hooded Plover; inclusion in the proposed alteration to the relevant values Rubicon Estuary Important Bird Area and North East Arm EPBC listed saltmarsh statements. community. Appendix 2. Rubicon Estuary Important Bird Area description Noted

Appendix 3. Updated bird list for Narawntapu National Park, based on Birdlife Plan change warranted – this information to be reviewed for Tasmania database, December 2015 inclusion in the proposed alteration to the relevant values statements.

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Representation 17 Tasmanian Conservation Trust Inc Peter McGlone, Director

PWS has requested public comment on the draft plan but failed to provide reasons Noted -– regardless of the current proposal, which is subject to for the change; assess the potential implications for management of reserve values; assessment, the proposed alteration is considered to be self- or update critical information regarding natural values. evident. The nature of the proposed alterations is provided in the draft. PWS did not name EOI or provide link to brief project outline on CG website. Noted – as above.

PWS did not provide information to enable judgement of the claim that the Noted proposed change will provide for improved recreational opportunities.

No analysis of what latest information on park values is or what this means for Noted management of horse riding.

No information demonstrating that the impacts of horse riding have been Noted monitored by PWS.

Given changes in knowledge and status of some park values since the 2000 plan and Noted - the new commercial proposal is subject to applicable likelihood that these values are negatively impacted by horse riding, TCT assessment processes, which will be undertaken on the basis of recommends horse riding should cease in the park. current knowledge of values. Noted changes since 2000 - Birdlife Tasmania submission re decline in shorebird Plan change warranted - plan should include updated information numbers on Bakers Beach; EPBC listing of Hooded Plover and coastal saltmarsh on the status of the saltmarsh community and hooded plover in community. Plan does not mention any changes required due to listing of Hooded the revised description in section 3.3. Plover. Plan does not acknowledge EPBC listing of saltmarsh. The approach taken to public consultation is unfair and deceptive for the public to Noted be asked to comment on changes to a plan without provision of essential information. It is not possible for the public to make an informed response.

Appendices 40

TCT recommends that the proposal to amend the plan cease. A new draft plan Noted should be prepared incorporating an assessment of the conservation requirements of EPCA listed Hooded Plover and saltmarsh and other shorebirds, including an assessment of impacts of horse riding. The revised draft plan should then be released for public comment. Commercial or recreational horse riding should then be confined to what the final plan permits. Representation 18 National Parks and Wildlife Advisory Council Malcolm Wells, Chair

Poor process, draft plan should have put forward as amendment to previous plan Noted – this is the intention of the proposed alterations. with much needed full plan revision later.

Many areas in full plan that deserve closer attention than can be given in time Noted – it is acknowledged that there are areas in the current frame for comments. management plan requiring review, this will be undertaken during any future full review. Plan is inadequate in areas of natural and cultural heritage conservation, eg. Noted – it is acknowledged that there are areas in the current Inadequate attention to threatened species many of which are concentrated in the management plan requiring review, this will be undertaken during recreation zone; no provision for eradication of sea spurge, access of horses and any future full review. 4wd to all of Bakers beach threatens hooded plover populations that survive there. Incremental revision of management plans to facilitate single potential Noted. The NPRMA provides for management plans to be altered, developments and activities is likely to lead to sub-optimal outcomes for both in recognition that minor changes may be required from time to tourism and nature conservation. Management planning should be thorough and time. These provisions reflect the understanding that a holistic. Expense and time in an amendment seems unjustifiable when existing plans management plan may not anticipate all circumstances over the can allow new activities and development in appropriate areas. life of the plan, and this is why there is a process for alteration. Any alteration is subject to the full extent of the statutory process, there is no reason to suggest that minor alterations would lead to sub-optimal outcomes for either tourism or natural conservation. In this instance, the proposed alteration has been assessed through the EOI process.

Appendices 41

Sees no compelling case to amend the plan when the proponent is being given Noted - the new commercial proposal is subject to applicable access to new opportunities for horse-riding and the beach is an important assessment processes. environment for a number of threatened species. NPWAC were not provided with sufficient information about the proposal for the Noted – this is not matter relevant to the proposed alteration. proponent to lease the existing PWS house and is concerned about potential impacts on the PWS budget that is already in perilous situation. NPWAC recommends: Noted. As indicated above, the NPRMA allows for minor alterations • Management plans be revised after appropriate consideration and research of management plans, in recognition that these are sometimes and with proper prior consultation with stakeholders required over the life of a plan, and should be able to be made • EOIs be implemented within the constraints of such plans without undergoing a full review in every instance. There is no • The Narawntapu national Park, Hawley Nature Reserve Management Plan reason not to seek a minor alteration to a management plan in should be properly revised before the EOI is progressed. order to achieve a sensible outcome that is not provided for in an existing plan. Given the ability to alter a management plan it is reasonable to encourage proposals that require an alteration providing they are determined to be appropriate. Representation 19 Tasmanian Aboriginal Centre Heather Sculthorpe, CEO

The representation draws attention to the attachment of the Tasmanian Aboriginal Noted – the content of the attachment is acknowledged and will community to the area due to its long association with their history and culture as have considerable value in any future full review of the well as the fact that it was the first national park in Tasmania to have an officially management plan, however it addresses issues that are not sanctioned Aboriginal name. The representation includes an extensive attachment relevant to the proposed alterations. containing suggested changes and additions to sections of the management plan. The major themes in the representation for suggested changes are that the plan: • Acknowledge and provide for Tasmanian Aboriginal community involvement in the preservation, restoration, management, research, monitoring and interpretation of Aboriginal heritage values in the park; • Specify the importance of protecting Aboriginal heritage and providing opportunity for visitors to the park to understand Aboriginal heritage; • Promote, encourage and provide for the undertaking of Aboriginal culture and

Appendices 42

cultural practices and access to Aboriginal cultural resources (fauna and flora) in the park by the Tasmanian Aboriginal community; and • Identify and continue traditional Aboriginal land management practices, including traditional Aboriginal burning.

Appendices 43