Submission to Peter Freeman from the North Head Alliance

By Facsimilie: 02 6295 6517

15th November, 1999

Dear Mr. Freeman,

Re: Conservation Plan Revision - Quarantine Station, North Head

Quarantine Station is a unique, fragile and very important part of
Australia's natural and cultural history and we are concerned that it be
properly protected, maintained, conserved and managed for future
generations.

We have studied the documents on exhibition and offer the following comments:

1. We endorse the finding of the Heritage Council that the 1992 Conservation Plan is an inadequate document for the conservation of Quarantine Station.
The language of the Council's comments is less directive than it should be and the NPWS must address each of the points with great specificity to
ensure that the Council's concerns are met.

2. One of the major criticism of The Plan is that it appears to have been written as a leasing document. This is in contrast to the draft Plan of 1987, which it replaced, and which recommended that the site be retained in the management of NPWS. Indeed a crucial paragraph was added to the 1992 Plan which states
' The Conservation plan does not specify a particular management structure to oversee the leasing and future conservation of the Quarantine Station'
(QS conservation Plan 1992:72). This is in direct contravention of
Section 2.5 of the Burra Charter which states:-

2.5 Management

The Conservation policy should identify a management structure through
which the conservation policy is capable of being implemented. It should
also identify those to be responsible for the subsequent conservation and management decisions and for the day to day management of the place

This failure to specify a particular management structure, or even canvass the possibilities is one of the fundamental flaws in The Plan which must be addressed in a new conservation plan. This will take more time than is allowed in the brief. The 1992 document has so many missing components that the task should be undertaken fully and properly without the very short time constraints currently placed on your work.

3. Quarantine Station must be considered in its geographic, environmental and cultural contexts. There are areas of historic and environmental significance which are outside the current borders of the Station (eg cemeteries). North Head must be treated as one entity. This includes the surrounding NPWS land and the School of Artillery site and the Australian Institute of Police Management site. To consider the Quarantine Station in isolation, as has been done to date, will lead to the same errors being continued into the future. Historically the sites were integrated. This should be respected and a new conservation plan must reflect this inter-relationship. We refer you to the Planning Study prepared by Clouston for the Section 22 Committee on North Head and the Section 22 Report to the Minister written by the community members in October 1999. Sue Sacker has sent you a copy of this last document.

4. The timeframe for comments, consultation and drafting of the new plan is much too short. There is a wealth of research and information available on North Head and time must be allowed for you to access and evaluate it.

5. North Head contains many Aboriginal sites, however, the 1992 Conservation Plan contains minimal documentation of the Aboriginal heritage contained therein. The Plan itself acknowledges that "the significance of these sites to the local Aboriginal community has not been assessed" (Conservation Plan,1992 p.18)

Notwithstanding the above statement, the Plan then notes under section 6: Statement of Significance "The Aboriginal sites are of minor scientific
/research value but have educational potential and are likely to have
social and contemporary significance to the Aboriginal community"
(Conservation Plan,1992 p.51) Much more systematic investigation of the QS is needed in collaboration with the Metropolitan Local Aboriginal Land Council to identify and further investigate the Aboriginal heritage of North Head area and QS in particular.

It is imperative, and necessary under government legislation, that the
local Aboriginal community and the Land Council are consulted as to the
proposed development on Quarantine Station and the likely impact on this valuable Aboriginal cultural heritage. Throughout Sydney urban development has already destroyed much of our indigenous heritage. The new Plan must address this issue in detail.

6. The 1992 plan is grossly deficient in regard to the natural environment and the endangered colonies. The little penguins, the seagrass beds and the bandicoots require special consideration.

7. Access to Quarantine Station is very important. The current plan
recommends water access - this may not be feasible in the light of the
paragraph above. Road access means that all traffic passes through the
narrow isthmus of Manly Town Centre, which is already overcrowded. The carrying capacity of North Head needs to be established. We refer you to Manly Council's Traffic Report on the Town Centre, prepared by Rust PPK.

8. Quarantine Station is a fragile site. It is important to remember that, even at its period of heaviest usage, intense activity was followed by long periods of minimal activity. Management options and uses must not cause any trauma to the site. The conference centre currently operating onsite must be evaluated as to the damage it has caused to the site as well
as the benefits it brings. This requires an evaluation of the site in
1984 compared to the present day.

9. The 1992 Conservation Plan allows for rebuilding some buildings and construction of new buildings. This must be carefully reviewed. We suggest you refer to the Council comments submitted in June 1992 which raise important issues including the inappropriateness of altering existing buildings to provide en suite facilities. Every indication is that users of the conference centre enjoy the different lifestyle it offers: 5 star facilities are
available everywhere.

10. An interpretation policy is essential. Due to the threat of leasing, very
little has been done to build on the excellent tours provided by NPWS. The site offers many opportunities for excellent (and lucrative) educational interpretation and this must be encouraged.

11. Public access to the site must be encouraged but managed in light of the fragility of the site. At present public access is too limited in timing
and convenience. There are also many educational opportunities yet to be
explored.

12. There is no doubt in our minds that it would be preferable to use the
heritage listed School of Artillery site buildings for an appropriate
adaptive reuse as it is less fragile and has more space and facilities than
the Quarantine Station. By considering the sites together this option
could be explored.

In conclusion, this site is one of Australia's premier historical sites; it
is fragile and precious. Our research shows that it is probably the
largest, most intact and best preserved quarantine station in the World.
It is currently financially maintained through the conference centre
activities. Head leasing to a developer would inevitably lead to compromise and dollar-driven decision making. Management models such as trusts should be explored.

Finally, the process over the last 10 years has been driven by financial
considerations. Luckily no irrevocable decisions have been made. Please
let us consider heritage, education and the natural environment over money.

Yours sincerely,

Digby Hughes

President