Analysis of Public Submissions National Park Draft Management Plan

The Flinders Ranges National Park Draft 7. addressed issues beyond the scope of the Management Plan was released for public plan; consultation, in accordance with the National 8. was already in the plan or will be Parks and Wildlife Act 1972, from 30 April 2015 to 31 considered during the development of a July 2015. subordinate plan; 9. offered an open statement, or no change The draft management plan was advertised in the was sought; Advertiser and was available at the DEWNR 10. clearly supported the draft proposals; Customer Service Centre (Pirie Street), DEWNR Port 11. was an alternate viewpoint received on Augusta Office, and from the DEWNR internet site the topic but the recommendation of the (www.environment.sa.gov.au/parkmanagement). draft plan was still considered the best option; Twenty-eight submissions were received on the 12. was based on incorrect information; draft management plan. Table 1 below provides a list of individuals and groups who made 13. contributed options that are not possible (generally due to some aspect of existing submissions. Table 2 below provides a breakdown legislation or Government policy); or of the source of submissions. 14. involved details that are not appropriate Following the careful analysis of all submissions, the or necessary for inclusion in a document feedback received meeting the following criteria aimed at providing management has resulted in an alteration to the management direction over the long term. plan; 1. provided additional information of direct relevance to management; 2. indicated or clarified a change in Government legislation, management commitment or management policy; 3. proposed strategies that would better achieve or assist with management objectives; 4. prompted a re-consideration of the objective and/or strategy and results in an alternative objective and/or strategy for the park; 5. was an alternate viewpoint received on the topic and is considered a better option than that proposed in the draft plan; or 6. indicated omissions, inaccuracies or a lack of clarity.

Feedback received meeting the following criteria has not resulted in an alternation to the management plan; Table 1 – Individuals and groups who made a submission Table 2- Summary of submission source No Name Type Author Number Percentage

1 Darryl Royans Individual Individual 17 61% 2 Elinor Alexander Individual NGO 8 31 % 3 Garry Patterson Individual Govt 4 Joanne Vine Individual 2 8 % 5 Kath McCullagh Individual Table 3 provides a summary of feedback received 6 Mal Cockburn Individual against each criterion and the number of 7 Maria Pearce Individual alterations made to the plan in response. 8 Pam Brookman Individual Table 3 – Summary of alternations made to the draft plan 9 Richard Milosh Individual COMMENTS 10 Roger Tinning Individual CRITERIA RECEIVED 11 Scott Adamson Individual 1. 12 12 Sallyanne Burton Individual 13 Sally Henery Individual 2. 0 14 Rob Marshall & Sue Barker Individual 3. 7 15 Richard Grimson Individual 4. 6 16 Bradley Pitt Individual 5. 4 17 Bob Ellis Individual 6. 21 18 Event Strategies Pty Ltd NGO Comments resulting in a 19 Gawler Trail Horse Riders Club NGO 50 change: 20 Horse SA NGO 21 Australian Retired Persons NGO 7. 14 Association Bushwalkers 8. 7 22 Nature Conservation Society of NGO 9. 12 23 Conservation Council SA NGO 10. 22 24 Friends of Heysen Trail NGO 11. 12

25 Friends of Flinders Ranges NGO 12. 1 National Park 26 South Australia Tourism Govt 13. 1 Commission (SATC) 14. 13 27 Department of State Govt Comments which have Development – Aboriginal 83 Affairs and Reconciliation not resulted in a change 28 Development Policy Advisory Govt Committee Table 4 below sets out a detailed analysis of feedback, whether the management plan was changed, and the relevant criteria used in making that decision. Table 4 – Detailed analysis of feedback Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

1 Recommended that references are added for 14 This level of detail is not necessary for this strategic plan. No 14 Directions for relevant sections of the Native Title Act 1993, similar management to how we reference Section 38 of the National Parks and Wildlife Act 1972.

2 Support the intention to manage the park primarily 25 No change. No 10 for conservation and visitors to achieve the objectives of the National Parks and Wildlife Act 1972.

3 Strongly support the statement: ‘The park will be 25 No change. No 10 managed to minimise any further alteration to the natural ecological processes that support life in the park, to protect natural and cultural values, to improve the integrity of important ecological communities and to enable people to enjoy the park and share in its Adnyamathanha culture.

4 Support this section 17, 16 No change. No 10

5 Support this section 14 No change. No 10 Park significance and purpose 6 Recommend to add the conservation of flora and 14, 22 The plan has been adapted to include a paragraph Yes 1 fauna and natural landscapes and the importance that highlights the significance of the park to of the park to biodiversity through habitat biodiversity conservation and the significance of the conversation. natural landscape. New paragraph (end of Park significance & purpose): ‘The park is significant in conserving biodiversity and providing habitat for threatened and regionally rare plants and animals. It is an important part of a broader landscape which includes Bunkers Conservation Reserve to the east, and connects areas managed for conservation in the northern and southern Flinders Ranges. This landscape connectivity is vital for the movement of species in response to changes that may arise as a result of climate change.’

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

7 Recommend that the Mawson Trail is included on 18 The Mawson Trail is included on the map and in the Yes 6 the map, not just in the legend. legend. The map has been adapted to make the Park significance and Mawson Trail more visible. purpose

8 Acknowledge the importance of the park to the 22 No change No 9 Adnyamathanha people.

9 Recommend that this section notes that the park 22 The plan has been adapted to include a paragraph Yes 1 adjoins the Bunkers Conservation Reserve which is that highlights the significance of the park to managed by the Yellow-footed Rock-wallaby biodiversity conservation and the significance of the Preservation Association. natural landscape.

10 Recommend that this section recognises the park’s 22 The plan has been adapted to include a paragraph Yes 1 significance as the link between areas managed that highlights the significance of the park to for conservation in the northern and southern biodiversity conservation and the significance of the Flinders Ranges, and the importance of landscape natural landscape. connectivity to facilitate broadscale movement of species in response to changes to the ecosystem that may arise as a result of climate change.

11 Recommend that the proposed area for the 22 The map has been amended to include the Traditional Yes 1 traditional use zone is shown on the map of the Use Zone. park (Figure 1).

12 Recommend a colour with a stronger contrast to 22, 18 The map has been adapted to make the Mawson Trail Yes 6 the background green to mark the Mawson Trail on more visible. the map (Figure 1).

13 Comments that the significance and purpose of the 25 The plan has been adapted to include a paragraph Yes 1 park has not been explained that highlights the significance of the park to biodiversity conservation and the significance of the natural landscape.

14 Recommends an explanation of the significance 25 The plan has been adapted to include a paragraph Yes 1 and purpose of the park is included in order to that highlights the significance of the park to measure development against agreed goals. biodiversity conservation and the significance of the Recommends that this would refer to DEWNR and natural landscape. SA Government strategic plans. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

15 Recommend to move 'walking' to follow 'camping' 14 The plan has not been changed in regard to this No 11 What are we looking

as this is the style followed on p. 16 – many campers recommendation, the activities presented in the after? are also walkers dotpoint referred to have not been prioritised, nor have they been grouped. Many people participate in multiple activities within the park.

16 Recommended to refer to ‘quality’ tourism 14 This detail is not necessary for this plan. Potential tourism No 14 businesses in dot point 13 operators undergo assessment while applying for a licence, separate to this plan.

17 Supports the inclusion of cycling in the list of what 18 No change. No 10 the park protects

18 Comments that previous park managers and staff 25 This comment does not require change. No 9 have achieved excellent results over decades and that evidence of the park environment returning to its original state have been celebrated.

19 Recommends that if significant changes are 25 The plan isn’t intended to provide this level of detail but No 14 proposed for how the park is protected, then instead aims to provide strategic information. complete details are needed in this plan to enable monitoring against agreed goals and the objectives of the National Parks and Wildlife Act 1972.

20 Comments that the Wilpena Resort is referred to on 25 The plan has been amended to clarify that the Wilpena Yes 6 page 7, but is referred to elsewhere in the plan as Resort is outside of the co-managed area, but is being not within the co-management area. located within the park. Amended sentence, Directions for Management: ‘The Wilpena Resort and adjacent Contract for Services Area are not within the co-managed area but are located within the park.’

21 Recommends that the initial condition of key 23 A detailed assessment of the condition of No 13 environmental assets is provided. environmental assets has not been undertaken. The plan provides a brief overview of the assets and their condition, and includes a strategy to monitor environmental assets to increase our knowledge of their condition.

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

22 Support the challenges that refer to improving the 25 No change. No 10 What are the condition of ecological communities that were challenges? degraded by grazing, pest animals and pest plants; and improving the resilience of ecological communities, native plants and native animals to the changes associated with climate change.

23 Express concern that the first five challenges listed 25 No change. The challenges all refer to different aspects No 11 are not related to park protection. of managing an important cultural and natural landscape. Effectively managing a park requires acknowledging and dealing with challenges that relate to the numerous roles that a park presents.

24 Recommend that sub-headings are used to 25 The list of challenges is already grouped according to No 11 separate the challenges according to different theme. Several challenges cover numerous topics, objectives. making sub-headings inappropriate.

25 Recommend to not announce when knowledge or 16 This level of detail is not necessary for this plan, however No 14 access is being kept from the public due to cultural this recommendation has been passed onto the Co- reasons to avoid creating feelings of animosity management Board for consideration. towards Adnyamathanha people.

26 Recommends that any proposed closures to public 16 Any closures to public sites will be consulted on prior to No 14 access to protect sacred sites are consulted on closure. Reasons for closure or changes to access will adequately and that Adnyamathanha people are be made available as culturally appropriate to assist given the opportunity to fully describe (to the extent the public in making informed comment on the possible) the reasons for the proposed closure. changes.

27 Recommends that if Adnyamathanha people 16 No change. The adopted approach will be the most No 14 believe access to a site should be restricted for appropriate approach for protecting cultural sites of cultural reasons, then the site is fully closed rather importance for the Adnyamathanha people. than allowing access but openly advertising the disapproval of Traditional Owners. Comments that it would also be important to offer people with alternative visitor experiences.

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

28 Support measures that would eliminate or reduce 16 This comment does not require change. No 9 What are the the degradation of cultural sites in the Park. challenges? Provides examples of such measures including (continued…) allowing access by a trained guide (preferably Adnyamathanha) only, or by restricting access along roads with a locked gate and allowing public access with a key obtainable from the Resort (with a deposit paid to obtain the key).

29 Recommended to refer to ‘quality’ tourism 14 This detail is not necessary for this plan. Potential tourism No 14 businesses in dot point 3 operators undergo assessment while applying for a licence, separate to this plan.

30 Recommend to include an additional challenge: 14 This recommendation is included as an opportunity No 8 "Ensuring that the significance of natural features is within the plan, under ‘What are we looking after’. The adequately explained to stimulate visitor awareness second dotpoint refers to opportunities for people to and foster a sense of custodianship." learn about the park – this encompasses the natural features of the park.

31 Recommend that it is made clear that all sites, 27 The plan has been adapted to reflect this information. Yes 6 Theme 1 – Advancing objects and remains are protected from damage, ‘All Aboriginal sites, objects and remains are protected Adnyamathanha disturbance or interference regardless of whether from damage, disturbance or interference by the spiritual, cultural and they have been registered or reported. Aboriginal Heritage Act 1988, regardless of whether economic they have been registered or reported.’ relationships with Country 32 Concerned re Table 1 ‘Lighting a fire’ activity does 1 The plan has been amended to refer to the Fire and Yes 1 not refer to fire restrictions. Emergency Services Act 2005 and the Flinders Ranges National Park Indigenous Land Use Agreement where appropriate.

33 Would like to see a table of activities for all park- 1 As Native Title holders, the Adnyamathanha people No 11 users, not just Adnyamathanha Traditional Owners. have specific rights for the land encompassing Flinders Ranges National Park. Activities accessible to non- Adnyamathanha people are discussed throughout the plan, in particular within Theme 3.

34 Support the objectives in general. 25, 14 No change. No 10

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

35 Recommend that the plan reflects the Friends of 25 The fourth strategy listed refers to facilitating and No 14 Flinders Ranges National Park’s willingness to work supporting opportunities for Adnyamathanha Theme 1 – Advancing with others to facilitate opportunities for traditional owners to participate in training and skill Adnyamathanha Adnyamathanha people to participate in training, development and volunteering. The Friends of Flinders spiritual, cultural and skill development and volunteering related to park Ranges National Park are encouraged to support this economic services. strategy, however it is not necessary to specify relationships with individuals or organisations who wish to be involved in Country (continued…) the strategy. The Co-management Board has been informed of the Friends’ interest.

36 Concerned that visitors may observe traditional 25 This comment has been passed to the Co- No 8 owners undertaking activities as listed on page 11 management Board for consideration in developing and undertake the same activity without realising the Engagement and Interpretive Strategy for the park. that it is not acceptable for all park visitors. Recommend that the plan provides guidelines on how this will be dealt with and how the traditional owners and other park visitors will be educated in regard to this potential issue.

37 Supports this theme in providing a balanced and 17 No change. No 10 appropriate response to the theme subject

38 Comments that the term ‘dreaming’ is not 17 The plan has been adapted to use the Yes 1 appropriate as it suggests that the stories are made Adnyamathanha term ‘Yura Muda’ in place of up, and not a matter of Law. Comments that the ‘dreaming’. term ‘histories’ may be more appropriate.

39 Comments that Table 1 is useful but contains a tone 17 The Co-management Board has assisted in the No 11 of ‘big brother’ and officialdom. Recommends development of Table 1 and support the structure and saying ‘the Co-Management Board has resolved wording. The only reference to people not being that’ rather than ‘Adnyamathanha/ people may permitted to undertake an activity is in regard to the not’. hunting of threatened species, where the current wording is considered the most appropriate.

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

40 Recommended that the statement “Rabbits, foxes 22 The plan has been adapted to reflect that rabbits, Yes 6 Theme 2 – Healing and goats became widespread in the park...” be foxes and goats are widespread and abundant Flinders Ranges revised to acknowledge that these pests are throughout the region. National Park widespread and abundant throughout the region, Revised sentence: not a localised issue. ‘Rabbits, foxes and goats became widespread in the park and throughout the region and many...’

41 Recommend that the statement that “strategic 22 The plan has been adapted to reflect that the strategic Yes 6 culling of kangaroos will be implemented ...... ” culling of kangaroos will continue, and is not a new be rewritten to acknowledge that a strategic initiative. culling program has been in place for many years. Revised sentence: ‘The strategic culling of kangaroos will continue in conjunction with...’

42 Strongly support the intention for kangaroo 22 No change. No 10 management programs to be based on rigorous and long-term monitoring and the consideration of commercial options for utilisation of kangaroo carcasses.

43 Recommend that the statement “fire may assist in 22, 14 The plan has been adapted to clarify that fire can assist Yes 6 the displacement of Triodia spp grasslands as a in the regeneration of Triodia spp grasslands rather than result of the spread of Vinba (Northern Cypress displace Triodia spp grasslands. Pine)” be revised to clarify that fire can assist in Revised sentence: regeneration of Triodia spp grasslands in some ‘For example, fire can assist in protecting habitat for the areas where they have become dominated by endemic Short-tailed Grasswren by enabling the Northern Cypress Pine. regeneration of Triodia spp grasslands in some areas where they have become dominated by Vinba (Northern Cypress Pine) (Callitris glaucophylla).’

44 Recommend to acknowledge the importance of 22 The plan has been adapted to include reference to the Yes 6 Triodia spp grasslands as habitat for the Short-tailed Short-tailed Grasswren within the text of Theme 3 to Grasswren to provide a better link to Dot Point 4 in better link with the related strategy. the Objectives and strategies for this theme.

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

45 Support the proposal for Opuntioid cacti to be 22 The plan has been amended to acknowledge the Yes 1 managed in line with the State Management Plan resourcing for Opuntiod cacti over the past two Theme 2 – Healing however strongly recommend that the significant decades. Flinders Ranges resources that have gone into control of Opuntioid New sentence: National Park cacti both on the park and across neighbouring ‘Significant resources have been invested into the (continued…) properties over the past two decades is control of Opuntioid cacti both on the park and across acknowledged. neighbouring properties over the past two decades.

46 Recommend that the paragraph about the 22 The paragraph about Bounceback has been Yes 6 Bounceback program acknowledge the significant amended to reflect the significant improvement to the increase in numbers of Andu that has occurred Andu population. across the park due to control of feral animals since Revised sentence: the program commenced. ‘Bounceback has established a strong foundation for biodiversity conservation, resulting in regenerating native vegetation communities, a significant increase in numbers of Andu, and gradual recovery of other fauna such as Echidna and Short-tailed Grasswren.’

47 Recommend that the reference for the statement 22 The plan has been adapted to reflect this reference. Yes 6 that “Bounceback takes a landscape scale approach to management.....how a natural system functions” be amended to Alexander & Naismith (2001). The information referred to in this statement was part of a specific section in the Biological Survey of the Flinders ranges Report edited by R. Brandle. The reference should be amended to reflect this.

48 Recommend that Dot Point 6 in the Objectives and 22 The plan has been adapted to reflect threatened Yes 3 strategies is amended to include threatened species as well as ecological communities. species as well as ecological communities.

49 Support this section in general. 25, 17 No change. No 10

50 Commented that the Tunbridge quote was not 17 The quote is considered to be an accurate description No 11 helpful and too negative of the circumstances facing Andyamathanha people at the time. Acknowledging the past is a vital step toward reconciliation, which is promoted by this plan and to Co-management Board.

Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

51 Recommend to include specific references to an 23 The Park Significance and Purpose section has been Yes 1 end-goal of biodiversity corridors (or Naturelinks) amended to reflect the role of the park in an Theme 2 – Healing connecting the various land parcels – both private integrated landscape that allows for the movement of Flinders Ranges and public - to facilitate movement of species in species in response to climate change. The National Park response to climate change pressures. connectivity between various land parcels and areas (continued…) of conservation in other land parcels is described. The plan also draws attention to the importance of the Bounceback program and its landscape scale approach.

52 Recommend to include more information on the 23 The strategy related to Bounceback has been Yes 3 Bounceback program in reference to outcomes of amended to include the regular publication of threatened species. Provides an example of program outcomes and monitoring results. committing to regularly publish monitoring results on Additional sentence (following original strategy): threatened species. ‘Use existing publications to regularly publish outcomes of the program and monitoring results’.

53 Recommend to relocate and rehabilitate the 14 The quarry is operated by DEWNR for park No 11 operational quarry near the Golden Spike. management purposes. Material from the quarry is used for campsites and management tracks.

54 Recommend to establish a World Class or IMBA Epic 3 The plan refers to improving and diversifying No 14 Theme 3: Sharing the Mountain Biking Trail in the park utilising the existing opportunities for cycling in the park. It is not necessary spirit of the Flinders trail network and developing fingers that run off the to include specific trail information in this strategic plan, Ranges main loop. however this recommendation has been passed onto the Co-management Board for consideration.

55 Recommend to allow horse-riding within the park. 6, 15, 8, The plan has been amended to clarify that horse riding Yes 6 19 and the leading of a horse are permitted on vehicle tracks available to public vehicles. New sentence: ‘Horse-riding and the leading of a horse is permitted on vehicle tracks available to public vehicles.’

56 Recommend to allow horse-riding in the park for 4, 5, 7, 8, The plan has been amended to clarify that horse riding Yes 6 individuals and not-for-profit horse clubs. 15, 12, 19, and the leading of a horse are permitted on vehicle Recommended that this should not need a case- 20 tracks available to public vehicles. by-case application process for less than 20 horses. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

57 Recommend that horse riding opportunities should 8, 19 Opportunities for new horse riding experiences are No 7 continue to be improved. referred to within the text of Theme 3. These Theme 3: Sharing the opportunities are not precluded by the plan and spirit of the Flinders require further discussion. Ranges (continued…)

58 Recommend a permit system is used to allow horse- 5, 8, 15, The plan has been amended to clarify that horse riding No 11 riding in numbers over 20 on a case-by-case basis. 20 and the leading of a horse are permitted to use vehicle tracks available to public vehicle use. People who wish to ride horses as part of an organised event are encouraged to apply for an event permit. More information on event permits can be found here: http://www.environment.sa.gov.au/licences-and- permits/events-permits

59 Recommend a permit system for horse riders, 20 This opportunity is not precluded by the plan and No 7 carriages or visitors leading a horse who wish to ride requires further discussion. off formed roads, tracks or trails.

60 Recommend that horse carriage drivers may drive 20 The plan has been amended to clarify that horse riding Yes 6 on formed roads and tracks where vehicles are and the leading of a horse are permitted on vehicle permitted. tracks available to public vehicles.

61 Recommend that camping be allowed with horses 20 This opportunity is not precluded by the plan and No 7 at permitted locations. requires further discussion.

62 Recommend the development of guidelines for 5, 8, 19 This opportunity is not precluded by the plan and No 7 horse riding and camping with horses within the requires further discussion. park to ensure compatibility with park values and aspirations.

63 Recommend that horses share multi use trails with 5, 8, 19, These opportunities are not precluded by the plan and No 7 walkers & cyclists in the parks & also use existing 20 require further discussion. service tracks in the park. Advised that only allowing horse riding on roads is unacceptable due to traffic and safety issues.

64 Recommend that horse riding be an activity along 5, 19 This opportunity is not precluded by the plan and No 7 with cycling for the proposed cycling trails in the requires further discussion. Wilpena area (page 18). Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

65 Recommend that designated areas for camping 5, 8, 19 This opportunity is not precluded by the plan and No 7 with horses be established, with water & shade for requires further discussion. Theme 3: Sharing the horses & toilet facilities for the riders. Yards are spirit of the Flinders encouraged but not mandatory as temporary Ranges (continued…) fencing (electric) could be used. Advised that if camping with horses within the park cannot be allowed, that a camping area be provided/sourced outside the park with daily access into the park onto a number of loop trails, in this case float parking would be the minimum requirement. Advised that numerous campsites suitable for horses would enable full enjoyment of the whole park and minimise the impact at each campsite.

66 Advised that horse riding for individuals and not-for- 5, 19 This comment did not require change. No 9 profit clubs is a great way to enjoy nature based tourism in the park with minimal impact on the environment.

67 Advised that trails for horses are simple and consist 8 This comment did not require change. The information No 9 of posts marking the trail and guidelines to ride is appreciated, however this level of detail is not within a 10m or 20m distance from the post. Trails appropriate for a strategic plan. preferably should form circular routes from the campsite. A days horse ride at trail riding pace is about 25 -35 kms and a half day about 15 kms. Horses and other non-motorised trail uses are quite compatible on any four wheel drive track. They are also compatible with vehicles so long as vehicle speed is restricted and there is room for the vehicle and horse to safely pass each other. Advised that marked trails are good for areas in the park where there is a high density of use, but other areas are suitable to allow horse riding anywhere in that area, ie east of the road and a lot of the area east of the ABC range to the Blinman Road. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

68 Recommended that trails and areas to ride should 8 This opportunity is not precluded by the plan and No 7 incorporate Aboriginal heritage, European heritage requires further discussion. Theme 3: Sharing the and ecology. spirit of the Flinders Ranges (continued…) 69 Recommended that a trail between the Heysen 8 This opportunity is not precluded by the plan and No 7 Range and ABC range is developed as riding on requires further discussion. the road is dangerous due to crests and unpleasant from the dust of passing vehicles.

70 Advised that cycling offers the best opportunity for 18 No change. No 9 increasing visitor numbers to the park

71 Disagrees with the word ‘popular’ in the statement: 18 The word popular in this context refers to all cycling No 12 “Cycling in the park is popular and utilised by activities, not just through planned cycling events. school groups, tour groups, individuals and through planned cycling events” (p 17) as there is only one event a year. (p17)

72 Supports the statement “There is demand for further 18 No change No 10 cycling opportunities including short rides from Wilpena and longer rides that link into and enhance the existing opportunities such as the Mawson Trail (Figure 1).”

73 Recommend that to improve and diversify 18 The plan has been amended to reflect that existing Yes 3 opportunities for cycling, more support could be culturally appropriate events will be supported. given to events that are predominantly delivering New dotpoint 6, Strategy 4: this service to the park already at their own ‘Continuing to undertake and support culturally financial and resource expense. appropriate and low impact events.

74 Recommend that the last point in the Objectives 22 An additional dotpoint to the 4th strategy on Theme 3 Yes 3 and strategies (Page 18) include an additional has been added to include the monitoring of impacts point that identifies the need for ongoing of nature-based tourism activities on key biodiversity monitoring of the impact of nature-based tourism assets of the park. activities on the biodiversity values of the park. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

75 Objects to the realignment of the Heysen Trail. 9, 10, 11, The plan has been adapted to reflect that a multi-day Yes 4 Concerned that the realignment will diminish the 24, 21 walk within the park is a strategy to improve and Theme 3: Sharing the walker’s experience by missing out on views and diversify walking opportunities, without referring to spirit of the Flinders interesting aspects of early European settlement realigning the Heysen Trail. Further consultation will take Ranges (continued…) history. place about how the multi-day walk can be established and options regarding the Heysen Trail. New strategy dotpoint: ‘Developing a world class multi-day walk (with minimal impact hiker accommodation) focused on the Heysen Trail.’

76 Objects to the constant realigning of the Heysen 9 The plan has been adapted to reflect that a multi-day Yes 4 Trail by government and private landholders walk within the park is a strategy to improve and diversify walking opportunities, without referring to realigning the Heysen Trail. Further consultation will take place about how the multi-day walk can be established and options regarding the Heysen Trail.

77 Good description of the values of the Flinders 26 No change No 10 Ranges to tourism.

78 Recommend to include an additional objective that 26 A new strategy has been included to reflect that Yes 3 demonstrate continued support for tourism activities existing culturally appropriate events will be supported. that already exist (eg support access to the park for The Co-management Board will retain power to tours operating from adjoining pastoral properties, approve tourism activities. supporting implementation of the Flinders Ranges Experience Development Strategy, supporting the ongoing operation of the Wilpena Pound Resort) to make it explicit that current tourism activities will be supported by the Co-management Board Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

79 Recommend to include plans to enhance visitor’s 2 A new strategy has been included to develop an Yes 3 experience of the geology of the park; and engagement and interpretive strategy for the park to Theme 3: Sharing the increase visitor understanding of South Australia’s encourage visitors to experience and learn about the spirit of the Flinders role in developing our understanding of Earth park’s cultural and natural landscape. Geology is Ranges (continued…) history. included within this natural landscape. This is further supported by other sections in the plan including the second dot-point in ‘What are we looking after’ refers to the park protecting opportunities for people to experience and learn about the park. Dot-point three and four in ‘What are we looking after’ refer to the complex and internationally significant geology of the park.

80 Supports the investment in upgrading the hiking 24 No change No 10 opportunities within the park

81 Recommend the plan provides the vision of a 24 The plan has been amended to clarify that the multi- Yes 6 diverse trail network of well managed trails covering day walk proposed will traverse diverse landforms and the many diverse landforms, and the natural and pass key natural and cultural features of the park. cultural features of the park.

New sentence, paragraph 3 p 17: ‘Feasibility studies have confirmed that a multi-day walk that traverses diverse landforms and passes key natural and cultural features within the park, focused on the Heysen Trail and utilising hikers huts would become a significant drawcard and would increase the profile of the park and the Heysen Trail.’ Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

82 Oppose the suggestion to re-align the Heysen Trail. 24, 21 The plan has been adapted to reflect that a multi-day Yes 4 Advise that if the track is realigned to continue walk within the park is a strategy to improve and Theme 3: Sharing the along the valley floor, walkers would miss out on: diversify walking opportunities, without referring to spirit of the Flinders the magnificent vistas looking across the ABC realigning the Heysen Trail. Further consultation will take Ranges (continued…) Range to the rugged profile of Wilpena Pound and place about how the multi-day walk can be the Heysen Range; walking through the 'Three established and options regarding the Heysen Trail. Sisters' from Sir Hans’s paintings; the great vistas from the peaks of the ABC Range, across the hills and valleys to the high, rugged Heysen Range; the Golden Spike at Trezona – Enorama Creek – Australia’s most significant geological feature, a world renown feature; the historic landscapes which include two hiker huts converted from old shepherd huts.

83 Concerned about the cost of realigning the Heysen 24, 21 The plan has been adapted to reflect that a multi-day Yes 4 Trail in trail construction and hiker accommodation. walk within the park is a strategy to improve and Advised that re-routing the Heysen Trail should only diversify walking opportunities, without referring to occur if there are issues of: safety, route realigning the Heysen Trail. Further consultation will take sustainability or enhanced walker experience place about how the multi-day walk can be established and options regarding the Heysen Trail.

84 Advised that the Friends of Heysen Trail are happy 24 No change required. No 9 to continue providing ongoing assistance with the management of the trail within the park, working with Department of Environment, Water and Natural Resource (DEWNR) to enhance and improve the trail and walker experiences.

85 Advised that the principal issues with the Heysen 24 This comment has been noted and passed to the Co- No 9 Trail for multi-day hikers in the FRNP are limited management Board for information. These issues will be information for pre-walk and while on the trail; addressed in the development of a multi-day walk limited availability of camping provisions for hikers in within the park. the Wilpena ‘store’; access nodes and transport options; very basic camping amenities.

86 Support the aim in general to upgrade and create 21 No change. No 10 new trails. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

87 Opposed to realigning the Heysen Trail due to lack 21 The plan has been adapted to reflect that a multi-day Yes 4 of reason given for the need to realign the Trail; walk within the park is a strategy to improve and Theme 3: Sharing the unclear who will benefit from realigning the trail; diversify walking opportunities, without referring to spirit of the Flinders detrimental impact of being closer to traffic for realigning the Heysen Trail. Further consultation will take Ranges (continued…) walkers and the trail; previous realignments due to place about how the multi-day walk can be withdrawal of consent by owners of private land established and options regarding the Heysen Trail. have been to the detriment of the trail.

88 Advised that the money to cover the cost of 21 The plan has been adapted to reflect that a multi-day Yes 4 realigning the Heysen Trail would be better spent for walk within the park is a strategy to improve and essential future realignments/land purchase diversify walking opportunities, without referring to realigning the Heysen Trail. Further consultation will take place about how the multi-day walk can be established and options regarding the Heysen Trail.

89 Support the objectives in general. 25 No change No 10

90 Support the installation of interpretive signage and 25 No change No 10 the use of modern technology to inform visitors about all park features that they encounter.

91 Disagree with managing the European heritage 25 The strategy referred to has been amended to reflect Yes 5 sites with the least amount of on-site interpretation that an appropriate amount of information will be provided. Concerned that visitors are already provided. seeking more information, so providing even less would be less likely to meet their needs and would deny the visitors a link to the history of this part of Australia.

92 Comments that the park interpretive centre holds 17 The development of interpretive information related to No 7 little or no information about Adnyamathanha Adnyamathanha history and culture will be considered history and culture, and fails to identify the in an engagement and interpretive strategy for the Adnyamathanha as the Native Title holders of the park. These comments have been passed to the Co- park. Comments that staff within the centre are not management Board for further consideration. adequately trained in these areas. Comments that the Wilpena Resort also holds very little information about Adnyamathanha and their history. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

93 Recommend that the interpretation centre and the 17 The second strategy within Theme 3 discusses No 8 entrance to the park display signs (or other welcoming people to Adnyamathanha Country Theme 3: Sharing the communications) acknowledging that the area is through park signage and through other innovative spirit of the Flinders the subject of a Determination of Native Title that technologies. Ranges (continued…) recognises the traditional ownership of the Adnyamathanha peoples.

94 Recommend that the plan address the problem of 17 Encouraging visitors to learn about Adnyamathanha No 8 visitors not meeting Adnyamathanha people or culture is a continuous thread throughout the plan. This staff and not learning about Adnyamathanha is a key part of the objective of Theme 3. Theme 1 culture. includes a strategy to facilitate and support opportunities for Adnyamathanha traditional owners to participate in employment, volunteering, and contracting of park management services.

95 Comments that the Experience Development 17 The Experience Development Strategy has been No 8 Strategies should include instruction for developed separate to this park management plan. interpretation in the visitor centre to adequately This comment will be addressed in the engagement communicate the cultural and heritage values of and intpretive strategy for the park, referred to in the Adnyamathanha co-managers. Theme 3, Strategy 2.

96 Recommend to further support the statement that 17 This comment has been passed onto the Co- No 11 ‘all forms of communication should welcome visitors management Board for decision. The plan has not to Country (and) encourage them to experience been changed but the Co-management Board may Adnyamathanha culture’ by adding that the wish to communicate the Native Title Determination in Adnyamathanha are the traditional owners of the various forms of interpretation throughout the park park and have achieved a Native Title Determination.

97 Comments that true reconciliation (healing the land 16 No change. No 14 and its people) will occur through the reciprocal respect of spiritual and cultural beliefs by all people who live in and visit the Flinders Ranges.

98 Recommend to include instruction regarding 14 The plan has been amended to include instruction Yes 6 generators, as referenced in Theme 1. regarding generators.

99 Recommend to amend the first sentence of the last 14 The first sentence has been amended to include Yes 6 paragraph on page 16 to include visitors. reference to visitor access. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

100 Recommend to include reference to popular self- The plan has been amended to refer to shorter, self- Yes 1 guiding day walks, suitable to quieter activities guided walks. Theme 3: Sharing the including birdwatching. spirit of the Flinders Ranges (continued…) ‘A number of popular self-guided day walks offer an alternative to the longer trails. The more remote of these short walks provide opportunities for birdwatching, photography and a quiet appreciation of the surroundings.’

101 Support the provision of information in electronic 14 No change. No 10 form.

102 Recommend to expand the second strategy to 14 An additional strategy has been developed which Yes 3 include reference to landscapes, cultures, native refers to the development of a engagement and plants and native animals. interpretive strategy to encourage visitors to experience and learn about the natural and cultural features of the park.

103 Recommend to alter the description of the trail from 14 This level of detail is not appropriate for this strategic No 14 Wilpena Creek to Tanderra Saddle to include plan. reference to returning to Wilpna across the floor of the Pound.

104 Recommended to change the name of the park to 13 The term ‘Flinders Ranges’ is a well known brand for the No 11 NAME CHANGE Ikara Wilpena National Park to remove the park. The ranges within the park are a quintessential confusion of having a small section of the Flinders component of the visitor’s experience when they visit Ranges referred to as Flinders Ranges National Park the park. Keeping the term ‘Flinders Ranges’ within the name provides an accurate description of the dominant landform of the park. Wilpena Pound is a very important feature of the park, however the term ‘Flinders Ranges’ enables the park to connect with the broader landscape that it resides in.

105 Support the suggested name change to Ikara- 14, 17 It is proposed that the final plan be released No 10 Flinders Ranges National Park incorporating the new park name once this has been formally accepted. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

106 Recommend that it would be useful to clarify how 22 A description of how the list of rare or threatened flora Yes 1 APPENDIX 1 the list of rare and threatened flora has been and fauna has been generated has been added to generated i.e. are they from confirmed records for the document. the Park? Recommend to acknowledge that further

surveys may record other species of conservation Description significance. ‘This list has been generated from information on threatened flora and fauna from DEWNR’s biological databases. The databases include survey information collected during multiple surveys and ad-hoc sightings. Data that has been used to compile these lists can be accessed via NatureMaps: http://www.environment.sa.gov.au/Science/NatureMa ps

107 Recommend the asterix against the Great Sun- 22 A review of the threatened species lists has resulted in Yes 6 Orchid NPW Act Conservation Status needs further the removal of the Great Sun-Orchid. clarification or deletion.

108 Recommend that further information is provided 22 A description of how the list of rare or threatened flora Yes 1 APPENDIX 2 about how the information for the list was and fauna has been generated has been added to generated. the document.

109 Recommend that Yellow-footed Rock-wallaby be 22 The plan has been amended reflect the Vulnerable Yes 6 amended to reflect its Vulnerable rating under the status of the Yellow-footed Rock-wallaby under the NPW Act. NPW Act SA.

110 Recommend to review the reference to Brandle 22 The Reference has been amended. Yes 6 References (2001); it should be 1997-1999. Alexander, P. and Naismith, T. (2001) in Brandle, R. (ed) (2001). A Biological Survey of the Flinders Ranges, South Australia 1997-1999. Department for Environment and Heritage, South Australia.

111 Recommend that a link to the information about 22 This link has been added to the Reference list. Yes 1 General Bounceback on the Natural Resources SA Arid Lands website is included in the plan. http://www.naturalresources.sa.gov.au/aridlands/pl ants-and-animals/native-plants-and- animals/bounceback Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

112 Add captions to images 14 No change. It is not considered necessary to provide No 14 captions on images. General (continued)

113 Note that some comments on earlier discussion 14 No change. No 9 papers have been considered

114 Recommend to clarify spelling on ‘Munda’ or 27 The plan has been adapted to use the spelling Yes 6 ‘Mundtha’. Page 8 fourth dot point refers to ’ ‘Mundha’ on advice from the Co-management Board. Munda sites’ as does page 17. In the Arkaroola plan page 11 there is a reference to ‘Mundtha sites’. Recommend to check whether there should be a standardised reference across the plans covering Adnyamathanha country.

115 Recommend that the plan contain a brief 22 The Directions for Management section has been Yes 5 explanation of how the management plan links to amended to include an explanation of how the plan the operational plans in order to increase links with operational plans. stakeholder awareness of the broader park New paragraph: management planning processes. This information This plan will be supported by operational plans could either be included on Page 4 under developed to provide more detailed information Directions for management or Page 21 along with including visitor facility development, fire management, timeframes for review of the plan. pest plant and animal control, interpretation and other operational park activities.

116 Recommend that the plan better acknowledge 8 Theme 3 is about sharing the spirit of the Flinders No 11 that the park is a spiritual and uplifting place to Ranges. This theme is based on welcoming all visitors to many non Adnyamathanha people by providing the park and describes several mechanisms to improve easier access to enjoy the park by walking, cycling, various visitor activities within the park. The plan has horse riding, painting or any other activity that will been amended to clarify that horse riding is a still maintain the environmental integrity of the area. supported activity within the park.

117 Supports the plan 13, 26 No change. No 10 Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

118 Recommends that geology is more of a feature in 2 A new strategy has been included to develop an Yes 5 the final plan based on the 2012 Discussion Paper engagement and interpretive strategy for the park to General (continued) and consultation process. encourage visitors to experience and learn about the park’s cultural and natural landscape. Geology is included within this natural landscape. This is further supported by other sections in the plan including the second dot-point in ‘What are we looking after’ refers to the park protecting opportunities for people to experience and learn about the park. Dot-point three and four in ‘What are we looking after’ refer to the complex and internationally significant geology of the park.

119 Recommend to develop a website and App 2 This level of detail is not appropriate for this strategic No 14 featuring the geology of the Park. Refer to the work plan. An engagement and interpretive strategy for the by Dr Vic Gostin in the 2012 Discussion Paper. park will consider various technologies to encourage learning about the park’s features.

120 Proposes that the geology of the park is equally 2 This comment does not require change, however this No 9 important to globally significant fossil and comment has been passed to the Co-management geological sites such as Chengiang, the Jurassic Board for consideration when the engagement and Coast in the UK or in Devon. Proposes that lessons interpretive strategy for the park is developed. can be learnt and opportunities sought about the management and promotion of these sites.

121 Commends the plan’s presentation and as a 24 No change. No 10 valuable addition to the strategic planning for the region

122 Support the role of the Flinders Ranges National 25 No change. No 10 Park Co-management Board in bringing Adnyamathanha culture and European culture together.

123 Interested to see a balance in the plan between 25 No change required. No 8 the needs of the Adnyamathanha people and the needs of all other stakeholders including visitors and park neighbours. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

124 Recommend that the management plan should 25 The park management plan is a strategic document No 7 inform people of operational objectives, that guides the direction of the park, while providing General (continued) timeframes, budget considerations, performance information on the park’s management, significance & indicators, and strategies. purpose, values, opportunities, challenges and discusses key themes relevant to the park. The plan is a long-term plan that guides the development of operational plans. Considerations including budget and operational objectives are developed in operational plans. In the aim of keeping the plan flexible, simple, readable, and applicable in a changing environment, the plan is intentionally kept at a strategic level.

125 Question the endorsement of commercial 25 No change required. Commercial activities are No 9 enterprise within the park. relevant for many parks and reserves across Australia. Commercial enterprise can enable more people to enjoy and get involved with parks, thus generating more support for parks and allowing the multiple benefits of parks to reach more people.

126 Recommend that future drafts available for public 17 This comment has been acknowledged and passed No 7 comment be more easily readable for people with onto the Visual Communications Unit within DEWNR for declining eyesight. future plans.

127 Support the Draft Plan for demonstrating a well 17 No change. No 10 balanced and well informed appreciation of Adnyamathanha interests and cultural concerns.

128 Recommend that the draft plan include discussion 17 Land outside of the park is not within the scope of the No 7 on acquisitioning land adjoining the park important plan. However this comment has been passed onto to Adnyamathanha heritage such as The Sacred the Co-management Board for consideration. Canyon.

129 Comments that the park interpretive centre 17 No change required. This comment has been passed No 9 contains little or no information about onto the co-management Board for their information Adnyamathanha history and culture, and fails to and consideration. identify the Adnyamathanha as the Native Title holders of the park. Comments that staff within the centre are not adequately trained in these areas. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

130 Supports the inclusion of Mura (history stories) and 17 No change. The first strategy of Theme 3 advises that a No 10 recommends that these stories are used in park series of site specific policies will be developed for all General (continued…) interpretation. key cultural sites. These policies will be authorised by Adnyamathanha traditional owners and will advise on appropriate interpretive themes for the site.

131 Numerous minor edits 17, 23, 1, The plan has been adapted to correct the editorials Yes 6 22, 14 provided in submissions.

132 Comments that climate change is insufficiently 23 The plan has been amended to reflect the importance Yes 5 recognised. of the park in enabling landscape connectivity and thus the movement of species in response to climate change (Park significance and Purpose).

133 Raises concern that the level of resources available 23 This comment is beyond the scope of the plan but has No 7 to the department to manage the park is been passed onto regional and central-based staff. insufficient and does not allow for the objectives DEWNR is not the only agency involved in resourcing and strategies outlined in this plan to be met. The the Flinders Ranges National Park – several agencies plan therefore conveys an inaccurate picture are involved in resourcing the park. about what actions will actually be undertaken.

134 Strongly recommends that monitoring activities be 23 Monitoring activities are imbedded throughout the No 8 firmly implanted in all management plans given the plan in reference to various strategies. Monitoring need to resource them effectively. activities specified are related to the monitoring of total grazing pressure and predators; monitoring infestations and control of Vinba (Northern Cypress Pine); conducting regular inspections to detect buffel grass; and monitoring the condition of environmental assets.

135 Recommend to include a third Appendix to include 14 The geological monuments have not been listed as an No 11 the Geological Monuments and Golden Spike additional appendix. Their importance is highlighted in mentioned within the plan. the ‘What are we looking after?’ section of the plan. The plan tries to maintain a streamlined, easy-to-read function for management purposes, which means that there are numerous features of the park, natural and cultural, which are not specifically listed in the plan. Comment Sub. No. Proposed Response Plan Criteria Section in plan Amended

136 Supports the plan for having a good level of regard 28 No change required. No 10 to the principles and policies of the Far North General (continued…) Region Plan and the Land Not Within a Council Area Flinders Development Plan.

137 DPAC advises that if development of one of the 15 28 This comment is duly noted. No change required. No 9 State Heritage listed sites within the park is proposed, then an application must be lodged for approval with the Development Assessment Commission.