Submission to Peter Freeman from Manly Greens.

Dear Mr Freeman and colleagues,

The Sydney Branch of the National Parks Association is pleased to have the opportunity to comment on the above plan and the amendments advised by the Heritage Council. We fully support the intentions of the Heritage Council and generally the detailed advice they have provided.

The current Conservation Plan was flawed from the outset, by being prepared to justify leasing of the Quarantine Station and by a number of significant omissions, and it is now obsolete. We believe that more than amendment is required to this Plan. The Conservation Plan needs to be rewritten and must address at the very least the following critical points.

We encourage you to write a new Quarantine Station Conservation Plan (QSCP) which starts by placing the Quarantine Station (QS) within the context of the whole of North Head. Not only are historical features relating to Quarantine outside the QS core area, the natural environment cannot be considered in isolation from its surroundings. Flora and fauna have no regard to lines drawn on maps.

Additionally, since the 1992 QSCP was written the ownership of the Artillery School land has changed and the future use of the site must be taken into consideration when considering the conservation and management of the QS. The area of the former defence site is almost three times that of the QS and the facilities are more suited to a number of adaptive uses than the QS. Any commitment to a long-term commercial lease for QS would be premature in light of changing ownership of the Artillery School. A meeting with the recently formed Sydney Harbour Federation Trust is necessary so that you are fully aware of their intentions and the options for the site. There is also the issue of ownership of this land which appear to be in dispute between the Commonwealth and State governments then needs to be addressed. We do not believe appropriate conservation management decisions can be made for QS in isolation from the whole of North Head.

The enormous historical value of the built heritage of the QS is due to the very intact nature of the site. The individual elements as discussed in Section 6.4 of the current Plan cannot be valued in isolation. Their highly significant value lies in their relationship to the whole. This section must be rewritten using this principle.

The current plan shows a lack of appreciation of the public health and immigration history of the site and QS's international importance in these areas of history. This history must be included in the new QSCP.

We recommend Dr Jean Foley, historian and author of In Quarantine, who has had a long professional association with the site, be contacted for assistance in relation to the historical details of QS. At the recent seminar organised by Friends of Quarantine Station (FroQS) held at the QS, Dr Foley admitted that there is extensive work still required to gather and document the history of the QS.

Alan Madden, representing the Metropolitan Local Aboriginal Land Council, also spoke at the seminar and pointed out that the QS was a significant site for the local aborigines and again a great deal more research was required to document the indigenous peoples history at the QS.

In view of the above the new QSCP must include a rewrite of the historical overview of Quarantine on the whole site and develop conservation and management plans in context of the whole of North Head. We recommend that the current low impact use of the site be maintained until both the indigenous and non-indigenous histories of the site are fully documented.

The QS is not only a highly significant historical site but also has highly significant natural values. The information in the 1992 QSCP on the topography, native vegetation and fauna of the site are at the most cursory and we recommend a rewrite of the overview of the natural values at the QS.

Geology: This is a rare geological site and being an island it is fragile with unusual soils, plants and animals. Dr Armstrong Osborne, a senior lecturer in Geology at Sydney University, provided an excellent overview of the geological history of the whole site while speaking at the recent seminar organised by FroQS. This information must be included in the QSCP and a plan to protect these significant natural features must be developed and particularly to address the question of how to deal with intensification of use of this fragile site.

Marine Environment: Along with other sections of the natural environment details of the marine environment were not adequately understood or covered. Spring Cove is part of the North (Sydney) Harbour Aquatic Reserve gazetted in 1982 because of its diversity. Its protection is crucial for the survival of the fairy penguins. The fairy penguin colony is the last surviving breeding colony on the mainland of NSW and has since been gazetted as a threatened population under the Threatened Species Conservation Act 1995 (TSC Act), yet is referred to on page 41 as being of local interest. The protection of the marine environment must be strengthened to conserve the diversity of marine life.

Dr Osborne pointed out that any increased use of the wharf will have an effect on the Marine Reserve. Again this is not covered in the current QSCP and must be investigated and considered when planning for any change in the future use of the QS. There must be no recommendations for an increase in the use of the marine environment off QS until the Recovery Plan for the Fairy Penguin has been completed and effectively implemented.

Terrestrial Flora and Fauna: As stated previously plants and animals do not recognise our arbitrary boundaries and so the conservation of the significant flora and fauna at QS must be considered in context to the whole of North Head.

Again the current plan does not consider in any detail the highly significant flora and fauna that have evolved on this island site. All island species are fragile as they evolve over long periods in isolation. This significance must be included in the new CP and considered when making recommendations for appropriate use of the site. Here again it is imperative that the CP address the question of the impacts of more intensive use of the site on this fragile flora and fauna.

There are a number of plants of significance and over 600 species of flora on North Head. Some of these have national significance and three regional significance. The unusual life forms, endangered and rare species have high botanical interest and significant importance for scientific research and teaching.. A survey of the flora of QS need to be completed before impacts can be assessed.

Dr Dieter Hochuli when discussing the Natural Heritage of the QS at the recent seminar said that major changes to the site will probably cause a decline in populations and so lead to a high risk of extinction. One of the reasons for this extinction in the fauna will be the increased threat and impact of predators through changes in habitat causing a reduction in food and shelter. In addition the Recovery Plan under the TSC Act for the Long-nosed Bandicoot has not been implemented and so there must be no recommendation for increase in use of QS until then. As part of the Recovery Plan the extended survey recommended by Dr Ian Hume from the Institute of Wildlife Research has still to be conducted. As with the fairy penguin colony the bandicoots have been gazetted as a threatened population and the protection of their habitat is crucial for their survival. Decisions on likely impacts or monitoring for impacts of the changed use of the site cannot be conducted without the full knowledge of their numbers and structure of the population. The new QSCP must give due regard to the significant natural heritage values of the site.

Science and Education: Many of the management goals regarding flora and fauna require research in order for appropriate management to be carried out. This has been ignored in the current plan and must be included in the new CP. This research also has a wider significance as research here into the ecology of bushland remnants would result in findings relevant to the management of other similar habitat fragments. The importance of the QS to science and education is ignored in the current CP and must be included in the new QSCP.

The recommendations in the new QSCP for future use of the site must give appropriate consideration to the highly significant natural heritage values in the QS in context with the whole of North Head. We insist that no conservation plan can deal adequately with this question of conserving the endangered populations of penguins and bandicoots until the critical habitat is defined in NPWS Recover Plans under the TSC Act.

We do not accept that leasing is the only way to ensure the preservation of an historic site of such national and international importance. Further, we do not accept that a long term lease, greater than five (5) years is appropriate or advisable for the conservation of such a significant site. By entering into a long term lease the commercial imperatives of the lessee will slowly overshadow the conservation requirements of any CP. We also do not accept that a head lease is an appropriate way to ensure the conservation of a significant site. More particularly, a site with such national and international importance must not be allowed to be managed in such a way that any group has exclusive access and by so doing alienate the public from the National Park.

As the National Parks and Wildlife Service and Mawland Developments have been negotiating the conditions to lease for about eighteen months we feel it would be wise for you to have a look at the details. This information would enable you to better understand the likely requirements of such a long term head lease and so include safeguards in the Conservation Plan to conserve the QS.

The historical site needs to be considered and conserved as a whole. The very intact nature of the site has very high national and international importance. To isolate portions of the site or alter discrete buildings or sections of the site can only be regarded as inappropriate in the conservation of this site.

Any new use of the Quarantine Station must be in keeping with its past level of use and show due respect of the site as a place where people suffered great pain, sorrow and death. It continues to be the burial ground for those people who died there. The ambience of the site can only be retained by low impact use which shows respect and understand of its past uses.

Our remaining comments are directed to improving the "user friendliness" of the Conservation Plan. Firstly, the maps require improving to place the QS within North Head and to include buildings and their number on each map. Secondly, the pagination should be arranged so that each map and its legend or table are on facing pages. Thirdly, the syntax in several places obscures the intended meaning as may the unexpected use or omission of commas (e.g. section 5.1 para 1 line 3 & Section 7.1 para 6 line 2). Finally, is it correct to use the work "internee" to include patients, potential carriers and healthy passengers and crew or should it mean only illegal immigrants or enemy aliens? (e.g. the forth para. On page 38 in the context of the neutral zone and compare item 72 on Fig. 5).

We note that you are facilitating a community workshops and appreciate the opportunity to participate and the professional manner in which they are being conducted. We wish to nominate Peter Caldwell, our Sydney Branch President, as an additional representative of the National Parks Association of NSW Inc. in this workshop group. Peter has a long standing interest in the Quarantine Station. We will be returning from an overseas trip later this month and may be contacted through the above address.

Again we would like to thank you for the opportunity to have our comments considered in the amended Quarantine Station Conservation Plan. The writer can be contacted on 02) 9389 3014 or be email at Patricia_Meagher@rbgsyd.gov.au.

Yours sincerely

Patricia Meagher

National Parks Association – Sydney Branch