Sydney Branch of 
National Parks Association of NSW inc (NPA)

Comments and Submission on 

Draft Final Quarantine Station Conservation Management Plan (1999)

Study Area

Section 4 of the “Brief for the Preparation of a Revised Conservation Management Plan for the Quarantine Station Sydney Harbour National Park” covers the Study Area.  Viz: “The study area will focus on the Quarantine Station proper plus all of the land within Sydney Harbour National Park bounded by North Head Scenic Drive……..”

This is reflected on page 9 of the Draft Conservation Management Plan (CMP):  “The brief specifically requested consideration of the ‘broader’ North Head area ie beyond the defined ‘Study Area’.  To this end aspects of ‘Quarantine Station’ within North Head were discussed in the context of the surrounding ‘use’ precincts:

Blue Fish Precinct

Former School of Artillery Precinct

North Fort Precinct

The ‘Loop’ Precinct

The North Head Sewerage Treatment Works”

The Draft  CMP only has short sections on The Spring Cove, Parkhill, Quarantine (South), and Marine precincts.   Brief references to the other precincts are included in the Historical Section and some of the sections on the Aboriginal and Natural Heritage cover North Head generally.   The most notable omission is a more thorough coverage of the former School of Artillery precinct.

Strong Move to delay the CMP and expand the Terms of Reference

At the outset the Reference group was unanimous in wanting the CMP to include the whole of North Head including the former Artillery School, still occupied by the Defence Dept.  The group felt that appropriate conservation management decisions, particularly on the natural environment, could not be made for the Quarantine Station (QS) in isolation from the whole of North Head.  It was strongly suggested that both the CMP and any agreement to lease the QS be held over until it was clear when the Artillery School site would be released.  Although it is understood that the Commonwealth Government is quite intransigent and uncooperative, estimates were given of their vacation at the end of 2000. 

Ironically, the interim Sydney Harbour Federation Trust is quoted in section 8.2 as part of their submission in relation to the 1992 NHQS Conservation Plan in a letter to the Consultants: “…The Trust would like to stress that it believes there is a strong cultural relationship between the Artillery School site, to be managed by the Trust, and the Quarantine Station and that these linkages should be explored in detail. The Trust is keen to work with the National Parks and Wild life Service in arriving at the best outcome for North Head.”

If the Trust and the Commonwealth Government were serious about achieving “the best outcome for North Head” it would advise a vacation date, set up an environmental audit, institute a decontamination and restoration plan at Commonwealth expense and hand over the site to Sydney Harbour National Park (SHNP) as soon as possible.   

This land is the subject of a 1910 “Memorandum of Transfer” from NSW to the Commonwealth for the express purpose of defence.  Under this agreement, once the land is no longer used for this purpose it should revert to NSW.

There is further reference to cooperation with the Trust in Section 9.3 under General Conservation Policy No.3.  The NPA strongly advises that the basis for any cooperative moves be predicated by bona fide moves by the Commonwealth to vacate the School of Artillery site and fund all the clean up and restoration work.

The Reference group urged the National Parks and Wildlife Service of NSW (NPWS) to delay the CMP until it could include the Artillery School site. One of the reasons for this delay was based on the understanding that the Artillery School, being a less sensitive and larger site, was far more suitable for adaptive reuse than the QS site.  The group felt strongly that the QS should be kept strictly under the direct control of NPWS with the interpretation tours continuing but with no commercial development.  It was envisaged that the funds generated from any adaptive reuse on the Artillery school site would be used to carry out further restoration on the QS site.  Clearly the group’s views on this have not been heeded.

General Comment

This plan is a great improvement on the 1992 Plan.  It is effectively a new Plan.  However there are major shortcomings in the document, which need to be addressed  before it can be considered complete and “user friendly”.   In fairness to Peter Freeman and Associates, the very short time allowed for the preparation of this plan is no doubt a factor in these shortcomings.

It is a very large document of 265 pages, with the Appendixes a further 46 pages.  It is therefore difficult to continually refer back to earlier sections when endeavouring to glean all the information on, say, the Little Penguins.  Few people will take the time to do this. This would not and should not be necessary if the many important observations and references to Policies, Strategies and Practices (eg included in such documents as SHNP PoM) in the leading sections of the document were incorporated in the Policies and Strategies in the concluding sections.

We believe that Section 8 “Conservation and Management Policy Issues”, Section 9 “Conserving and Managing the Place: Conservation and Management Policy”, and Section 10 “Implementing the Conservation Management Plan” should spell out short and longer term Policies, Strategies and Practices and that these should be complete for the ‘Core’ area. They should include many of the Policies and Strategies that already exist and apply to the ‘core’ area. 

They should provide clear courses of action or clear limitations of use of the site to protect sensitive areas or specific species. Naturally the background to such policies etc would require reference to the previous sections.  Welcome assistance for readers would be notations in the Policy sections as to earlier sections and/or page nos.

A complete set of Policies, Strategies and Practices clearly stated is a key and necessary element in establishing the CMP as a robust document.

It is to be noted, as set out in Section 7, that the QS site satisfies all seven criteria for listing as State Heritage Significance.  Whilst one criterion is sufficient for listing, the fact that QS meets all seven must surely put it in a very special category and hence should be afforded VIP protection treatment by the NSW Government.

Great concern was expressed by all members of the group upon the announcement on 27 January that NPWS had signed a conditional agreement with Mawland to lease the site.   This places an even greater emphasis on the need for this plan to be very robust and to not leave any gaps that can be misinterpreted.  It is in the hands of NPWS to ensure that the Final Plan meets these criteria.

Whilst the Draft CMP should stand on its own, the proposals set out by Mawland do provide specific foci against which to test the adequacy of the Draft CMP.

Specific Areas to be strengthened with clearer Policies and Strategies

a) Threatened Species

In Section 6.3.6 The Condition of Animal Biodiversity,  the Draft CMP states:

“The North Head populations of Long Nosed Bandicoot and Little Penguin are listed as endangered, and the Red-Crowned Toadlet and Powerful Owl are listed as vulnerable under the Threatened Species Conservation Act 1995.  The process of natural decline of species has been recognised for centuries…;however in the case of the four species in this study area, the decline is the direct result of human activity and therefore can only be reduced or removed by humans.  Some other species may be under threat but have not yet come to the attention of the Scientific Committee….”

Little Penguin

Section 6.3 includes a reference to the sensitivity of these birds to human disturbance whilst coming ashore to nest sites at around dusk.  It is important to stress that the sensitivities of these Penguins are quite different to those many people will have seen on, say, Phillip Island or Victor Harbour.   At these sites they seem oblivious of human intrusion when coming ashore in the evening to nest.

In the case of the Spring Cove colony, if the parents are disturbed when coming ashore they go back to sea and therefore do not feed their young.  If this goes on for several nights the hungry chicks die. It should be noted that, as reported by the Service, the 1998 breeding season was disastrous in that 90% of the chicks were lost. 

NPWS has recognised this sensitivity and imposed a curfew on the current operation of spoil barges servicing the construction of the North Shore Sewage Tunnel from one hour before dusk to one hour before dawn.  

In the Draft CMP, Access and Interpretation Policy No.5  Water Access seeks to encourage water access by the Wharf with some provisos “The timing and frequency of boat access, and the size of vessels allowed access, should be informed by environmental impact assessment on the conservation of seagrass and marine species; the Recovery Plan for the Little Penguin population; and ongoing monitoring of sea bed impacts.

The Draft Recovery Plan not yet implemented includes bringing more Penguins from now urban areas to shore sites in the vicinity of the Quarantine Station.

This Policy No.5 implies the need to carry out some assessments of the impacts on these areas.  On going monitoring and research is always important but many of the sources of impacts on the survival of the Penguins are already known.  Hence some very clear Policies and Strategies based on all the existing knowledge are needed in the Draft CMP to protect the Little Penguin colony now.  These need to include measures of a similar nature to the curfew above, particularly in view of the intention to increase water borne traffic to the Wharf area and a proposed restaurant also on the Wharf.

Section 9.4 includes Conservation Practices Policy No.5.  Regarding the Penguins it only advocates implementing the Recovery Plan.   This can only be considered as a longer term policy, which itself will need to be augmented by appropriate strategies.

Long Nosed Bandicoot

Section 6.3.7 contains useful information about this species and the human impact on its population.  Current measures to protect the Long Nosed Bandicoot are contained in the Sydney Harbour National Park (SHNP)  Plan of Management(PoM) and in a Draft Recovery Plan – in preparation. 

The Draft CMP observes that “Long-Nosed Bandicoots are exposed to a high risk of death or injury when moving at night between habitats separated by roads.”  Measures currently in place include speed humps on North Head Scenic Drive and gates that are locked at 10pm  “to assist in protecting this nocturnal animal.”

Also in this Section the Draft CMP states “The ‘core’ Quarantine Station area is habitat for Long-Nosed Bandicoots which are often seen at night foraging on grassy areas and are therefore vulnerable to road traffic generated by NPWS staff and people attending residential courses in the Conference Centre.” 

The only Policy referring to the Long-Nosed Bandicoot is Conservation Practices Policy No.5 in Section 9.4.  This states “Implement the Draft Recovery Plan for the Long-Nosed Bandicoot North Head – in preparation.”

This or a separate Policy needs to bring together these observations and existing Policies and Strategies.  Prior to this Plan being finalised and implemented, and in view of the increased numbers of visitors associated with a proposed hotel holding around 180 people and a restaurant holding 150 people such clear Policies and Strategies probably need to include curfews on the movement of vehicles and people on the QS site at night.

Other Threatened or Vulnerable Species

The Draft CMP’s only reference to any Policy or Strategy covering these is Conservation Practices Policy No.5 in Section 9.4. in which it states:  “Recovery Plans should be developed for the following species either as discrete threatened communities or as parts of wider populations:………”

As stated in Section 6.3.6  “… in the case of the four species in this study area, the decline is the direct result of human activity and therefore can only be reduced or removed by humans.”   Clear Policies and Strategies need to be established for the protection of the Threatened and Vulnerable Species before there is any commercial development and increase in numbers of visitors to the site.

b) Weeds, Exotic & invasive species

Rabbits

Whilst there is reference to the many rabbits on the QS site there is no Policy or Strategy to either deal with them or accept them!  There needs to be a clear statement as to their impact on the native flora and fauna together with a Policy and Strategies to address it.

Weeds

The Draft CMP quotes the SHNP PoM  and Clouston identifying a number of noxious weeds in the Park.  At the QS amongst other locations there is clearly a major infestation that is almost impenetrable particularly on the slopes between the First and Second Class buildings and the shore line.

Section 6.3.3 includes the SHNP PoM Policy for weed control: “Priority for the control of introduced plants will be given to those which are declared noxious weeds under the Noxious Weeds Act; are new or isolated occurrences; are damaging to cultural heritage values and; conflict with significant natural values; have a high capacity for dispersal or spread; and are in areas of high public use.”

Strategies to implement this Policy are identified as:

“A weed control program will be prepared and implemented. Priority will be given to the removal and replacement with the locally indigenous species of isolated introduced plants which have spread into bushland areas; lantana, coral trees, pellitory and fig suckers affecting historic buildings and structures; alligator weed at Collins Flat and along the Hermitage Foreshore;……………”

Policies and Strategies need to be developed specifically for the QS site.  These will need to include a proviso that bush regeneration be conducted so as not to reduce the cover over too great an area at any one time which might have a negative impact on the Long-Nosed Bandicoots habitat.

Conservation Practices Policies Nos.4 & 6 refer to prohibiting the introduction of weeds and exotic species but there is no clear Policy or Strategy to deal with the existing infestation and maintenance of the site to control further spread of weeds.   It is important to spell out this requirement in a detailed strategy of bush regeneration, so that it is clear whether the lessee or NPWS has the responsibility to carry this out.

It is clear from the earlier sections of the Draft CMP a major factor in the spreading of weeds and exotic plants is human visitors whether by vehicle or foot.  Hence this is another factor in the need to control Public Access.

c) Aquatic Reserve

The significance of The Aquatic Reserve is covered briefly in Section 6.3.8.

An important point to be added is that Spring Cove is designated an ecologically sensitive area by the Environmental Protection Authority (EPA). This is due to the fact that pollutants collecting in the Cove are not flushed out – a function of the topography and wind pattern.  Hence prevention of pollutant and nutrient run off from the land within the Cove acquires an even greater significance than normal.

It has been suggested that the present septic system at QS is inadequate allowing sewage into the Cove.  If this is the case it must clearly be made good immediately.

It also needs to be a subject under very careful scrutiny if visitor numbers are significantly increased.

The Draft CMP General Conservation Policy No.12 and Strategy contains an interesting requirement which is applauded.  “…..The implementation of policies regarding site access and referencing of water access will preceded by studies and the collection of base data to ensure that the impact of any new or altered access arrangement can be carefully monitored and, if the impact is found to be unacceptable, stopped altogether (underline added).  NPWS will work closely with the NSW Fisheries to monitor impacts in the Reserve.  NPWS will discourage all activities in the immediate vicinity of the Quarantine Station that could have a negative impact on the Aquatic Reserve.

The requirement for boats to remain at least 30m from the shore should also be part of this policy to protect the Sea Grasses.

Visitation, Access and Use Capacity

In many contexts the Draft CMP identifies human visitation as having a major impact on Threatened Species, Weed infestation, Site erosion and the Aquatic Reserve.  Sound policies to control numbers need to be formulated with rigorous monitoring systems.  General Conservation Policy No.15 Visitation and Use Capacity appears to have the main elements to do this.  The reports must be made public.

Access & Interpretation Policy No. 1 Public Access  and associated Strategy also addresses visitation and limitation of vehicles.  Vehicles should be confined to parking near the current gatehouse.  The development of further Car Parks on the site should not be allowed. 

This submission has been confined mainly to the Natural Heritage aspects of the Draft CMP. The NPA fully recognises the value of the Aboriginal, Cultural, Historical and Medical Heritage on the site.  In their critique of this plan others with their particular expertise, in particular the Friends of Quarantine Station, have covered these areas adequately both in the Reference group meetings and in their submissions.

Peter Caldwell,

On behalf of the

Sydney Branch of 
National Parks Association of NSW inc (NPA)