16 December 2015 Director, National Parks and Wildlife GPO Box 1751 Hobart TAS 7001 [email protected] NARAWNTAPU NATIONAL PARK, HAWLEY NATURE RESERVE DRAFT MANAGEMENT PLAN 2015 (Altering the Narawntapu National Park, Hawley Nature Reserve Management Plan 2000) Representation by BirdLife Tasmania Dear Director, Thank you for the opportunity to comment on the Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015. BirdLife Tasmania wishes to raise a number of concerns regarding coastal bird values of the Narawntapu National Park, and the threats to them arising from current or proposed activities, and the failure of the Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 to recognise explicitly high conservation values present in the Narawntapu National Park. Thank you for considering this representation Yours sincerely Dr Eric J Woehler Convenor 1. Horse-riding on Bakers Beach Hooded Plovers were listed as a Threatened Species under the EPBC Act (1999) in 2014. Horses and horse-riding on beaches were identified as threats to Hooded Plovers in the Federal Minister’s Conservation Advice (see http://www.environment.gov.au/biodiversity/threatened/species/pubs/66726- conservation-advice.pdf) BirdLife Tasmania undertakes GPS mapping surveys of beach-nesting birds throughout Tasmania. Hooded Plovers nest on Bakers and Badger Beaches. A mapping survey of beach-nesting shorebirds breeding on Bakers Beach in 2014/15 located 16 breeding territories of Pied Oystercatchers and one pair of Hooded Plovers on Bakers beach. An identical survey in 2009/10 located nine and one territories, respectively. These data are publicly available in the DPIPWE NVA and Appendix 1 shows the mapped locations of breeding shorebird territories. Bakers Beach is also an important winter roosting beach for Hooded Plovers. Data from 1998 onwards show a steady decrease in the numbers of Hooded Plovers on Bakers Beach in winter months: June 1998 (46 Hooded Plovers), June 2000 (36), August 2006 (26) and August 2012 (5). As BirdLife Tasmania have no data to suggest a corresponding decrease in the breeding population on Bakers Beach or on surrounding beaches, it is likely that disturbance to roosting birds has contributed to the observed decrease. Horse riding occurs on Bakers Beach throughout the year. Horse visits to Narawntapu National Park have increased by more than 50% between 2010 – 2014, inclusive (DPIPWE data). More than 60% of horse visits of the October 2014 – September 2015 total occurred in October 2014 to March 2015 inclusive. This six-month period encompasses the breeding season for Hooded Plovers in Tasmania. Expansion of commercial horse riding on Bakers Beach in Narawntapu National Park will increase the threats to beach-nesting shorebirds, including Hooded Plover, year-round. Horse-riding on Bakers Beach will threaten nesting birds during the summer months, and roosting flocks during the winter months. The current code of practice (PWS Public Notice, Narawntapu National Park Horse Access Conditions, undated) does not protect beach-nesting shorebirds from horse-riding on beaches. Condition 3, “Horses are not permitted on Bakers Beach between 2 hours before to 2 hours after high tide” is presumably to reduce potential threats to nesting shorebirds. There is no condition requiring horses to be ridden on the wet sand. The nominated “horse trail” is simply mapped along the extent of Bakers Beach, potentially allowing horses to access the upper beach where beach-nesting shorebirds nest, lay their eggs and raise their young. BirdLife Tasmania believes that the PWS staff do not have the capacity to enforce compliance with conditions associated with horse-riding inside Narawntapu National Park. With limited staff and increased demand from visitors, BirdLife Tasmania believe that PWS staff do not have the capacity to ensure compliance by more than 500 horse visits per annum to the Narawntapu National Park. There is no evidence to support the expectation or belief that all horse riders adhere to the PWS Horse Access Conditions. Further, we believe that no monitoring of potential impacts of horse riding on beach-nesting birds occurs. This is not a criticism of PWS staff - it merely reflects staff numbers and capacity. BirdLife Tasmania opposes horse riding on all beaches in Tasmania in light of the massive threat they pose to beach-nesting birds. Since 2001, we have made multiple representations and engaged with regional PWS office staff to raise these concerns- most recently in dealing with horse-riding on Five and Seven Mile Beaches on Llanherne Peninsula east of Hobart. BirdLife Tasmania consider horses to be as destructive as 4WDs and quad bikes on sandy beaches. We do not support the concept of "co-existence" - one can have horses or successfully-breeding Hooded Plovers and other beach-nesting shorebirds, but not both. We have seen extensive disturbance to beach-nesting shorebirds from horses on beaches elsewhere in Tasmania to support our position. Recommendation 1. Given the recent listing of Hooded Plovers as Threatened under EPBC, BirdLife Tasmania urges PWS to immediately introduce a blanket ban on horses year-round on Baker Beach to protect Hooded Plovers (and other shorebird values). Recommendation 2. In addition, BirdLife Tasmania urges PWS to immediately rezone Bakers Beach from Recreation Zone to Conservation Zone, and to manage it accordingly to protect Hooded Plover (EPBC Threatened Species). 2. Rubicon Estuary Important Bird Area (IBA) An international program to identify areas of importance to birds was initiated by BirdLife International using standard, internationally-agreed and internationally-applied criteria for all area assessments. The Important Bird and Biodiversity Area (IBA) Programme identifies, monitors and protects a global network of IBAs for the conservation of the world's birds and other wildlife. Although bird faunas define each IBA in the network, the conservation and appropriate management of these areas will ensure the survival of a high number of other animal and plant species. IBAs are the sites critical to ensure the survival of viable populations of most of the world’s bird species. IBAs also support a large and representative proportion of other biodiversity, providing a holistic approach to conservation rather than the species-based approach that is more often used. IBAs overlap with Ramsar sites and their criteria for selection, but the IBA selection criteria include all species of birds not just waterbirds. Briefly, the criteria used to identify IBAs are: 1. Globally threatened species (where the site is known or thought regularly to hold significant numbers of a globally threatened species, or other species of global conservation concern), 2. Restricted-range species (where the site is known or thought to hold a significant component of a group of species whose breeding distributions are constrained, such as endemic species), 3. Biome-restricted species (where the site is known or thought to hold a significant component of the group of species whose distributions are largely or wholly confined to one biome), and 4. Congregatory species (where the site supports >1% or >20,000 individuals of congregatory species of waterbirds, seabirds or terrestrial species). To date, approximately 12,000 IBAs have been identified around the world, and they represent the largest global network of important sites for biodiversity. Full details and descriptions are available at http://www.birdlife.org/datazone/info/ibacritglob The identification of Australian IBAs was undertaken by BirdLife Australia and all state branches, applying the international criteria to existing survey data. Full details of the project are available at http://birdlife.org.au/projects/important-bird-areas and http://www.birdlife.org.au/projects/important-bird-areas/iba-maps for details of the Rubicon Estuary IBA. The Rubicon Estuary supports more than 1% of the world population of Pied Oystercatcher and smaller numbers of other wader species. A full description of the bird values and threats is shown in Appendix 2. With more than 1% of the world population of Pied Oystercatchers, the Rubicon Estuary is of international significance year-round for the species. Recommendation 3. BirdLife Tasmania urges PWS to immediately rezone the foreshore from Griffiths Point to Bakers Point to the park boundary at the eastern most point of NE Arm from Recreation Zone to Conservation Zone, and to manage it accordingly to protect the internationally significant High Conservation Values (Pied Oystercatcher) values present in the Rubicon Estuary IBA (Appendices 1 and 2). 3. Subtropical and temperate coastal saltmarsh A glaring and troubling omission is any reference to EPBC listed threatened vegetation community, Subtropical and temperate coastal saltmarsh that was listed as Vulnerable vegetation community on 10 Aug 2013. Details of the Conservation advice and associated information are at https://www.environment.gov.au/cgi- bin/sprat/public/publicshowcommunity.pl?id=118 Of direct relevance to the proposed Narawntapu National Park, Hawley Nature Reserve Draft Management Plan 2015 is the following extract from Conservation Advice (http://www.environment.gov.au/biodiversity/ threatened/communities/pubs/118-conservation-advice.pdf), pp 32-33: Tasmania Tasmania has classified its vegetation state-wide through the Tasmanian Vegetation Monitoring & Mapping Program (TASVEG) (Harris and Kitchener, 2005; DPIPWE, 2013). Four