Submission Ku-ring-gai Chase National Park
ISSUE: Opportunity to maintain and build positive outcomes related to boating SUBJECT: Plan of Management for Ku-ring-gai Chase National Park
SUBMISSION: • The Boating Industry Association is the peak industry body which represents the interests of recreational and light commercial boating industry businesses and is an advocate for boaters’ interests.
• Boating contributes to significant social, economic and environmental benefits.
Strategic context • In NSW, the State Government support an integrated strategic approach to the waterways that spans safety, infrastructure, social, economic and environmental benefits. The BIA supports such a balanced approach and commends it to the process of updating of Plan of Management for Ku-ring-gai Chase National Park (the Plan). Some of the key NSW State Government strategies are:
o The NSW Premier's Priorities1 aim to deliver social and economic benefits and quality local environments. The priorities include the following goals: - a strong economy - education - well-connected communities with quality local environments - putting the customer at the centre of everything the State Government does - make the state of NSW the best place to live, work and play.
o The NSW State Government Intergenerational Report2 suggests the NSW population is projected to grow by around 1.0 per cent each year, to 11.2 million in 2056. It also shows we are strongly placed to face the future. As it currently stands, and not to forget those in our community who are less fortunate, we are collectively wealthier, living longer and better educated than ever before; and settling in coastal areas for the lifestyle benefits which include boating. The Federal Government says more than 85 per cent of the population live within
1 https://www.nsw.gov.au/improving-nsw/premiers-priorities/ 2 The 2016-17 NSW Intergenerational Report (IGR), titled Future State NSW in 2056 Page 1 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
50km of the coast.3 Little wonder almost 1 in 5 households in NSW has a boat or watercraft4.
The Report says that strengthening the economy is enabling and growing opportunity and does not simply mean lifting economic growth. It also means lifting living standards by improving the environment, social outcomes and income distribution. A strong and flexible economy can support these objectives. The NSW Government aims to strengthen the economy by regulating and investing with an eye to making NSW an attractive place to live and work by ensuring that: - competition and innovation flourish across the economy; - investments in our people improve productivity and workforce participation; and - investments in infrastructure support a growing and ageing population and improve productivity. o Future Transport 20565 aims to ‘place the customer at the centre of everything we do’. It outlines a vision, strategic directions and customer outcomes, with infrastructure and services plans underpinning the delivery of these directions across the state. Future Transport 2056 acknowledges the vital role transport (which includes vessels) plays in the land and water use, tourism, and economic development of towns and cities. It includes issue-specific and place- based supporting plans that shift the focus away from individual modes of transport, toward integrated solutions. The strategy and plans also focus on the role of transport in delivering movement and place outcomes that support the character of the places and communities the State Government wants for the future. It cascades down to the State Government’s Regional Boating Plans, Maritime Safety Plan and Maritime Infrastructure Plan6.
The BIA recommends that boating is strongly supported via the Plan due to the significant role it can have in supporting key NSW Government strategies in economic, social and environmental outcomes for NSW.
Economic context • The Australian marine industry makes a significant contribution to the economy. In 2018-19 the industry had a turnover of $8.65 billion, directly employed more than
3 https://www.abs.gov.au/Ausstats/[email protected]/Previousproducts/1301.0Feature%20Article32004 4 Recreational Boating Participation Executive Summary, Transport for NSW (2018) 5 https://future.transport.nsw.gov.au/plans/future-transport-strategy/executive-summary 6 https://maritimemanagement.transport.nsw.gov.au/ Page 2 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
28,000 people with more than 14,500 contractors. Seventy-five per cent are in small businesses, employing local workers and supporting local communities. This includes the area in and around Ku-ring-gai Chase National Park which has a history of activity on the water that pre-dates European arrival. The Park also has two significant marinas within it at Bobbin Head and Akuna Bay and provides access to its waters through boat ramps at Akuna Bay and Apple Tree Bay. The waters of the Park generally are accessed by water via Cowan Creek from Pittwater and Broken Bay. Hawkesbury/Pittwater/ Broken Bay/ Brisbane Water provides on-water and dry-stack storage for more than 8500 boats7 and is Greater Sydney’s largest estuary making it an important waterway for recreational boating.
• Boating is also a valuable contributor to tourism which is a significant part of the NSW economy. In 2016-17, tourism contributed $40.5 billion (Tourism Consumption) to the NSW economy and employed 262,000 people.8
• Nationally more than 2 million people hold a licence to drive a power boat and there are countless more who sail and paddle.
• In New South Wales there are:
o more than 500,000 people who hold a licence to drive a powerboat o almost 250,000 people who have a registered vessel o a countless number of small sail and paddle craft (actual numbers are unclear as these craft are not required to be registered or require a licence to operate) o almost 1 in 5 households in NSW have a boat or watercraft (eg., canoes, kayaks, standup paddle boards etc)9
• In the Greater Sydney Region10 which encompasses Ku-ring-gai Chase National Park there are:
7 https://maritimemanagement.transport.nsw.gov.au/documents/hawkesbury-pittwater-brisbane-water-regional- boating-plan.pdf 8 https://www.destinationnsw.com.au/wp-content/uploads/2018/04/economic-contribution-of-tourism-to-nsw- 2016-2017.pdf 9 https://maritimemanagement.transport.nsw.gov.au/documents/Boating_Incidents_in_NSW_Statistical%20Report_ 17_18.pdf 10 As defined by Transport for NSW Page 3 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
o almost 4000 commercial vessels ranging from ferries that carry commuters and tourists, to working barges that support jobs o more than 70,000 registered vessels o more than 210,000 people with a licence to drive a powerboat o innumerable small sail and paddle craft
• The most recent available boating incident data from Transport for NSW (which incorporates the maritime regulator) for the 10 years to 30 June 2019 for the Waters of Ku-ring-gai Chase National Park show there were: o 124 official cautions and 51 penalties o 6 serious injuries and no fatalities.11
This indicates a relatively high level of presence by compliance officers and a low serious injury statistic of less than one serious injury a year. For context, the provisional state-wide totals for the same 10 year period were 662 serious injuries and 138 fatalities.12 As such the waters of Ku-ring-gai Chase National Park are some of the safest and compliant in NSW. The BIA recommends that boating is strongly supported via the Plan due the importance of the Parks waters to the boating public of NSW and its significant capacity to deliver employment and economic benefits to NSW along with a relatively high degree of safety and compliant users within its waters.
Social context • Boating however is more than numbers, it is a way of life for many Australians and that is very much the case in the area around Ku-ring-gai Chase National Park where use of the waterways for transport, fishing or recreation has a long history which pre-dates European arrival. Today, boating is a vibrant and significant part of the social, economic and environmental fabric of the area.
• The award-winning marine biologist Dr Wallace Nichols is internationally renowned for his study which, though a scientific evidence-based approach, has shown getting out on the water in a boat promotes a restful state, with significant
11 Centre for Maritime Safety, Transport for NSW 12 Centre for Maritime Safety, Transport for NSW Page 4 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
physiological and psychological benefits. He has found that with our lives getting increasingly busy and stressed, boating is the perfect way to unwind and relax.13
• His research includes the vast cognitive, emotional, psychological, social, physical, and spiritual benefits that we can all derive from healthy waters and oceans throughout our lives.
• Dr Nichols says: “Being on a boat is one of the best ways to access the wellness benefits of the water”.
The BIA recommends that boating is strongly supported via the Plan due to the significant and proven social benefits it can provide to NSW. Environment context • The Boating Industry Association is committed to the care and sustainability of the marine environment which is fundamental to ensuring ongoing and improving social, economic and environment benefits.
• Boating is best enjoyed in a clean and healthy environment and the industry is a strong advocate of measures and controls to enhance the quality of the environment.
• The NSW State Government has an overarching NSW Marine Estate Management Strategy 2018-202814 which as a ‘triple bottom line’ of social, economic and environmental benefits. This strategy provides a host of actions including those relating to boating which are contained in: ‘Initiative 7 - Enabling safe and sustainable boating’ and of which many are already underway.
The BIA supports the principles of Initiative 7 which recognizes ‘Recreational boating brings significant social, cultural, and economic benefits to the NSW community’.
13 http://www.wallacejnichols.org/122/bluemind.html 14 https://www.marine.nsw.gov.au/__data/assets/pdf_file/0007/815596/Marine-Estate-Management-Strategy- 2018-2028.pdf Page 5 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
The strategy also refers to the NSW Maritime Safety Plan 2017-2021 which has a goal of reducing fatal and serious injuries by 30% by 2021 and Towards Zero by 2056. This plan contains 81 priority actions dealing with Safe People, Safe Vessels and Safe Waterways.
The Strategy also now links to the NSW Maritime Infrastructure Plan 2019 – 2024 which aims to improve access and infrastructure statewide. This plan will see priorities for maritime infrastructure aligned with broader economic, social and environmental outcomes for the state; for example, working towards installation of environmentally friendly moorings, waste collection and safe/ convenient access.
The BIA supports the principles of these strategic documents for NSW and recommends that the Plan is updated to reflect and complement these statewide strategic approaches covering safety, infrastructure and environment relating to boating to avoid duplication and inconsistencies.
• The BIA advocates for an appropriate balance of education and regulation when it comes to the environment.
• Education must come before regulation. It must be based upon contemporary evidence, understandable by the public, and be innovative, engaging and ongoing.
• Regulation must be based upon contemporary evidence, balanced against social and economic benefits, and supported by appropriate compliance.
• The BIA believes the mutual interests of industry, community, regulators and environment are best served by maintaining a collaborative approach to achieve workable solutions towards sustaining and enhancing marine bio-diversity via a legislative framework which is sensible and not overbearing in regulatory red tape.
• The industry continues to move with the times and powerboats have increasingly lower emissions and improved fuel efficiency. In fact, there is an increase in the availability of electric-powered boats which produce zero emissions and virtually zero noise.
Page 6 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
• Vessel waste containment systems are improving all the time, as are the marine coatings used for anti-fouling paints on the hulls of vessels.
• Marinas and slipways now employ environmental systems to prevent pollutants from entering the waterways.
• Boats in fact provide a relatively low-impact opportunity to access and explore the marine environment when compared with the significantly higher impact (eg., roads and pathways) necessitated by the use of other modes of transport such as motor vehicles and bikes, bicycles and even foot traffic in popular areas.
• Responsible use of paddle, power and sail boats to access the marine environment can provide a unique opportunity to visit an area and to leave no visible signs when compared with virtually any land-based mode of transport.
• The BIA supports evidence-based actions to deliver measurable social, economic and environmental benefits and which includes the following: o Speed restrictions o Vessel wash restrictions o Safe distance off requirements o Courtesy moorings o Environmentally friendly moorings o Maritime infrastructure that attracts and supports marine life o Waste capture and disposal systems o Education programs o Appropriate regulatory frameworks o Compliance programs.
The BIA recommends that boating is strongly supported via the Plan due to its significant capacity to deliver environmental benefits to NSW.
MORE SPECIFIC RECOMMENDATIONS:
In addition to the General Submission, the BIA recommends the following items from the existing Plan be actioned:
Page 7 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
• 3.1 GENERAL OBJECTIVES FOR MANAGEMENT of the Plan which states: the provision of appropriate recreation opportunities. o Recognize that boating can deliver social, economic benefits and environmental benefits. As for the latter, boating is a relatively low-impact activity and transport option in the park when compared with other transport modes such as motor vehicles which require substantial infrastructure including roads, and bicycles and pedestrians which require pathways etc.
• 4.1.2 Water Quality and Catchment Protection of the Plan o Update this section to reflect contemporary practice, regulation, education and compliance relating to boating. Especially with installation of sewage pumpout facilities for boats, fully contained hardstand facilities at marinas for boat maintenance, rubbish collection and recycling facilities and the modernisation of boats with holding tanks to comply with Environmental Law there has been a dramatic improvement in water quality and preventative environmental practices o Change Section 4.1.2 of the plan to provide for boat storage and servicing facilities to be concentrated in the existing and accredited commercial marina facilities within the Park to reduce environmental risk, improve environmental outcomes and public benefit o Consider increasing the size capacity of existing courtesy moorings from 15m to 18m and allowing two vessels to be rafted up on courtesy moorings. Investigate the potential for this to be funded by a grant from the Transport for NSW Boating Now program.
• 4.1.5 Aboriginal Heritage of the Plan o Update this section as it appears to fail to mention any use of the waterway by Aboriginal people; this seems amiss considering the use of bark canoes in region pre European arrival. This matter should be considered by NPWS and amended in this heritage section ie., recognition of the use of vessels by Aboriginal people.
• 4.2.2 Recreation Opportunities in Ku-ring-gai Chase National Park which states Policies and Actions that include:
Page 8 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
▪ Preference will be given to recreation activities which do not degrade the natural or cultural values of the park and which maintain the quiet and restful atmosphere desired by most visitors to the park. ▪ All visitors will be encouraged to minimise their impact on the park and on other visitors to the park ▪ Regular surveys of park visitors will be undertaken to provide an on-going understanding of the activities and perceptions of visitors o Update this section to reflect the fact that boats can provide relatively low-impact access to the park when compared with other modes of transport (eg., roads for motor vehicles and paths for bikes and pedestrians). o Recognise the relatively high compliance activity that occurs in the area for boating activity, together with the relatively safe waterways as evidenced by Transport for NSW incident data o Greater support and frequency be given to surveys of visitors and that this should include visitors by boats and watercraft (incl., paddlecraft).
• 4.2.2.1 Access and Sightseeing o Update this section to recognise and include boats and watercraft (eg., paddlecraft) as low-impact (when compared with motor vehicles for example) transport options for responsibly and sustainably accessing the park.
• 4.2.2.7 Boating o Update this section to ensure it applies contemporary evidence-based data which, according to Transport for NSW statistics, indicates boating in this area is relatively safe and subject to significant compliance activity. o To reflect the fact that boating is a relatively low-impact transport mode when compared with other modes such as motor vehicles, bicycles etc. o To reflect the fact the existing marinas create a sense of ‘place’ which is a key State Government strategic goal and support social, economic and environmental benefits. o To reflect the fact that waterways of the Ku Ring Gai Chase NP are within a ‘drowned river valley’. As such the shorelines are steep and rocky, with a few small sandy pocket beaches towards the more exposed downstream
Page 9 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
parts (e.g. Hallets beach) and sensitive habitats like seagrass and mangroves being mostly confined to the heads of bays, where inflowing creeks have created small deltas of sandy mud. This means that, for the most part, the shorelines are likely to be resistant to any vessel wash. The sensitive seagrass and mangrove habitats, being mostly at the ends of long narrow bays, are out of the path of any likely wash. Beaches like Hallets Beach, Hungry Beach, the beach at Refuge Bay etc. consist of coarse sand and are in areas naturally exposed to a fair bit of wave action: ie., vessel wash is unlikely to cause any significant environmental problems there either.
Furthermore, update the Plan to accommodate the following strategies in relation to water management within the Park: o Ongoing NPWS collaboration with Transport for NSW (now incl., maritime regulator) in the regulatory approach and education to reflect the fact that this must be sustained and in step with contemporary communication methods. o Appropriate signage at boat ramps regarding respect for other people and activities, minimising wash, keeping a proper lookout and keeping to the correct (right-hand) side of channels o Produce material to be distributed online and to marinas within and outside the park (who’s customers access the waters of the park) outlining the appropriate conduct of all people who use the waterway within the park and park specific rules for safe, responsible and enjoyable use. o Recognise that the waterways within the park should be maintained and promoted as a place for safe, responsible and enjoyable boating and the access to which should not be unduly restricted. o The paragraph beginning: ‘The increased popularity of boating on Cowan Creek and Pittwater has led to a decrease in the long-term quality…’ has been superseded by the inclusion of holding tanks in modern vessels. Furthermore, the commentary regarding boater behaviour and wash is also superseded and been addressed by changes in locations of no-wash zones and speed zones since the Plan was drafted. Also, the Transport for NSW Regional Boating Plan and a review of the boating safety and incident statistics confirms that the waters within Ku-ring-gai Chase National Park are some of the safest and have some of the lowest incident rates in NSW.
Page 10 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
Consequently, this paragraph should be deleted from the new Plan of Management.
• 4.2.2.9 Other Recreational Activities o Update this section re., boats damaging swimming enclosures and remove reference to boats causing such damage unless substantiated by contemporary evidence-based data.
• 4.2.2.10 Commercial and Organised Activities - Policies and Actions o That the existing plan be reviewed and redundant or superseded sections of the plan be deleted or reworded depending on the circumstance to reflect the progress made in relation to the existing marina and boating facilities, and the strategic commitments by the State Government to address social, economic and environmental benefits through the following: Regional Boating Plan, Maritime Safety Plan, Maritime Infrastructure Plan, Marine Estate Management Strategy, and the relatively high standards of safe boating behaviour reflected in the boating statistics.
Furthermore, the recreational maritime heritage within the park is a dominant value that should inform future use and the provision of additional boat storage options within existing facilities provides the lowest impact outcomes and may provide relief solutions to identified issues such as traffic and car and trailer parking.
In relation to the list of priority issues that commence under Plan Implementation of the current plan the following items pertaining to Empire Marina Bobbin Head or the Bobbin Head precinct have been actioned and should be deleted. 4.2.2.9, 4.2.2.1, 4.2.2.7, 4.2.2.7, 4.2.2.9.
Additional recommendations • The discussion paper recognises under the Visitor Services Section that boating services are delivered by the existing marinas within the park under leases and subleases. It is important to note that marina leases are long term and involve the investment of substantial capital and have high operating costs and operating risks
Page 11 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
that are managed by the Lessees. Leases of this nature are significantly different to low capital short term commercial and retail leases.
• That the Plan recognises the unique nature of marina leases within the park and provide for an approach to these leases that encourages public access and the maintenance and re-investment in the marinas to meet future market and community expectations.
o It should be further noted that the commercial and public infrastructure in the park relies on robust electrical infrastructure and this has historically been an issue of reliability due to damage to the overhead wires from wildlife or falling trees. With the advent of electric cars and green energy sources the Plan needs to provide for and encourage the provision of alternative energy infrastructure and access to publicly available mains green energy.
• That the Plan of Management encourage the access to, development and use of alternative green energy sources within the Bobbin Head precinct.
o It is also important to note that all lessees within the park invest in fitout, infrastructure and goodwill. As Bobbin Head is a destination, these lessees do not have the benefit of a consistent passing trade and are vulnerable to the implications of weather where on very hot days or on cold or rainy days the visitor numbers may be minimal. On these days the businesses remain open at a financial loss and rely on peak holiday or weekend days with fine weather to make a profit to balance out these days of loss. The importance of raising this is that the Plan should not facilitate the granting of short term licences or leases for operations or pop-ups that only operate on peak days in competition to long term lessees as this undermines the financial viability of the long term lessees. In circumstances where demand for services (for example food and beverage) exceeds supply on peak days the Plan should allow for temporary expansion of the existing lessee operations (by addition of pop-ups or otherwise) to meet these demands.
• That the Plan restrict the granting of short term licences to third parties to provide goods or services on peak days and provide for temporary expansion of the
Page 12 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
operation of existing lessees within the park to meet increased demand on peak days.
• To reduce carparking demand within the Bobbin Head Precinct the Plan of Management should accommodate: o A public bus service from Hornsby station with regular services o Hourly parking Charges (as against a day rate) to increase carparking churn and maximise visitor access o Implement a satellite carpark with “Park and Ride” service to reduce the cars entering the park o Use demand pricing for carparking on peak days to assist load shedding of demand to non-peak days.
• To better manage the public and public flows, do not collect parking fees or provide visitor information at the entrance gates. The entrance gates should be used for controlling access in emergency situations only. Utilise the human resources that would ordinarily man the entrance gates to confirm compliance with the paid parking and park rules within the precinct and the manning of the visitor information centre in the Bobbin Inn.
• Provide provisions with the Plan that allow for the inclusion of additional dry boat storage, PWC and RIB storage and paddlecraft storage and launching at existing marinas, and improving safety by restricting pedestrian access to the access roads to the precinct and limiting cycling on the access roads to single file and maximum group sizes.
• That the Plan recommend that ongoing education of the public in relation to the conduct of water based activities within the park including fishing, paddlecraft and boating is a priority. This should include appropriate signage at boat ramps and on the shoreline at the entry to the park, and through information distributed to marinas and at boat ramps where boaters gain access to the park.
• That the Plan recognises that accommodation on boats within the Park and with marinas is another form of acceptable, suitable, safe and environmentally- responsible visitor accommodation within the Park. A feature that meets the State Government strategic goals of putting the customer at the centre of everything you
Page 13 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465
Submission Ku-ring-gai Chase National Park
do, creating a sense of place whilst also delivering upon social and economic benefits.
• That the Plan recognises the impact of large planned events within the Park on other people and activities, and require organisers to take all reasonable steps to mitigate the impact of the event on other Park users.
• That boating activity (paddle, power and sail) be identified as a key low-impact and sustainable activity to be encouraged within the park ensuring that there is equitable and sustainable access to the waterways for water based activities for the public.
• That the Plan recommend that a plan be established in conjunction with Ku-ring- gai Council to minimise stormwater pollution entering the park though the stormwater system discharges into Cowan Creek and improved waste facilities be provided in the picnic areas within the Bobbin Head precinct.
• That the maritime heritage of the park be the foundation upon which the Plan addresses the various uses and users within the park.
• Explore opportunities for increased indigenous educational tourism within the Park including boat-based tours.
The BIA commend NPWS for progressing the review on the Plan of Management. This is a unique opportunity to create a framework that delivers great outcomes for the people of NSW for decades to come and we appreciate the opportunity to provide our input.
The BIA is available to consult further with the State Government on this subject. Please do not hesitate to contact Mr Neil Patchett, General Manager Policy and Advocacy, on e. [email protected] or m. 0418 279 465 on this matter.
Issue date: September 11, 2019
Page 14 of 14 Contact: Neil Patchett, Policy & Advocacy, e. [email protected]; m 0418 279 465