Submission to Peter Freeman from the North Head Alliance

Dear Sir,

The NHA is dedicated to the protection of North Head and its open space, bushland, wildlife, landscape views and historic structures. The Alliance comprises community and environment groups including National Parks Association of NSW, Defenders of Sydney Harbour Foreshores, Residents and Friends of Manly, Members of Save St. Patrick's Estate Action Group Inc. and St. Patrick's Estate Joint Precinct Working Committee, Manly Resident Alert, The Total Environment Centre, Bandicoot Watch, Nature Conservation Council and Manly Environment Centre.

Members of the group have participated on the North Head Section 22 Advisory Committee as community representatives.

1.1 The plan does not adequately address the following matters:

• Social significance and an assessment of the site's importance to the local community.

• Alternative management options including public trusts and compatible use sub-leasing arrangements.

• Effects on public access and interpretation in the light of different management options.

• Impacts of alternative adaptive reuses on the integrity of the internal fabric of the buildings.

• Principles of ESD (as defined by Environment Administration Act 1991) and implications of different development scenarios on Aboriginal sites, heritage landscapes, natural systems and native flora and fauna, in particular the threatened species recovery plans for affected Long-nosed Bandicoot and Little Penguin colonies.

1.2 The Conservation Plan has not taken into account the public submissions to the draft Conservation Plan. A comparison between the draft Conservation Plan which went to public exhibition with the final amended 1992 edition shows that they are identical with the exception of two minor additions to the schedule on page 67 and the inclusion of the concluding sentence on page 72. Clearly, scant regard has been given to the submissions.

2.0 The document is out of date and needs to be re-evaluated in the context of new information and developments affecting North Head and other Sydney Harbour foreshore sites:

2.1 The recommendations of the North Head Section 22 Advisory Committee (signed off by the National Parks and Wildlife Service) have not been considered. The North Head Advisory Committee set up by the Minister for Planning under Section 22 of the EPA Act and involving National Parks and Wildlife Service, The Department of Defence, Sydney Water, Australian College of Police, Manly Hospital, Catholic Church, Manly Council and community representatives has met since 1995 in order to formulate an overall planning and conservation strategy for North Head.

One of the key recommendations of the Committee is that the Quarantine Station must be conserved and managed in relation to the rest of North Head. A piece meal approach will threaten the desired outcomes for North Head as a whole.

2.2 The Conservation Plan fails to consider the adjacent North Head Artillery School land which is to be incorporated into the Sydney Harbour National Park. The two interrelated sites need to be considered together in a Conservation Management Plan.

The Artillery School land occupies centre stage on the crown of North Head extending almost to the ocean cliff face. The area of the former defence site is almost three times that of the Quarantine Station. The facility contains a number of large, heritage listed brick buildings built around a parade ground, old munition structures, a museum and underground fortifications surrounded by natural bushland. The facilities are more suited to a number of adaptive uses than the Quarantine Station.

2.3 The NSW Premier's Statement for Sydney Harbour Foreshore, August 1997, and the new State Environmental Planning Policy 56 governing significant sites on the foreshore have not been considered in relation to conservation values.

The Premier's first two principles are:

• Maximise public access to, and use of, land on the foreshore.

• Land made available for public access and use should be retained or placed in public ownership.

The new State Environmental Planning Policy (SEPP) 56 for significant sites around Sydney Harbour includes the Quarantine Station. The SEPP requires master plans be developed for sites prior to development being approved. A Conservation Plan should address the SEPP's objectives and the planning requirement for master plans, particularly as it is such a significant foreshore site.

The NSW National Parks and Wildlife Service's preferred strategy and outcome for the Conservation Plan could see the whole of the Quarantine Station leased out to a commercial hotel operator for a period of 40 to 45 years.

The NHA believes a head lease arrangement is likely to result in the site being inappropriately developed and public access and control restricted, thus compromising future options for the Quarantine Station. A long-term, head lease arrangement could also jeopardise potential adaptive reuses for the former North Head Artillery School if adaptive reuses for each site were found to be incompatible with each another.

The Quarantine Station does not need to be leased to a head operator in order to be commercially viable. A new conservation and management approach for the whole of North Head provides a number of opportunities which would allow the Quarantine Station to operate under public management by the National Parks and Wildlife Service with the full support of the community.

The Conservation Plan 1992 provides an inadequate basis for such a long term lease arrangement which in effect removes the Quarantine Station from future public control and review. The Plan fails to give adequate long term safeguards to protect the site from future development by a commercial operator and thus could threaten the integrity of the Quarantine Station.

Please give these matters your serious attention. This letter has been prepared in order to meet your deadline. I would pleased to provide additional information to assist.

North Head Alliance