Submission to Peter Freeman from Friends of Quarantine Station.

November 23, 1999

Dear Sir,

The Friends of Quarantine Station Inc. (FroQS) makes this submission in response to the recent re-exhibition of the Quarantine Station Conservation Plan 1992 and the proposal to draft a Conservation Management Plan. We note that the National Parks and Wildlife Service's obligation is a consequence of the Heritage Act and the Plan's failure to be accepted by the NSW Heritage Council.

FroQS has been formed by a group of distinguished and concerned individuals who share a genuine concern about the future of the Quarantine Station at Manly. The group is seeking to ensure that the Quarantine Station is held in public control so that the widest number of people may be able to enjoy its history and heritage. This will be achieved through the implementation of a plan of management based on principles of environmentally-sustainable development which reflect the interest of both the community and the State.

We feel it is necessary to question the extremely short and unrealistic time made available for submissions for what is an extremely significant and complex matter of great sensitivity. Given the restrictive time frame, this submission has had to flag a number of points for consideration which may require elaboration later.

FroQS endorses the NSW Heritage Council's rejection of the Quarantine Station, Sydney Harbour National Park, Conservation Plan 1992. Our group is unanimous in its opinion that the existing Conservation Plan is a totally flawed document. There is ample evidence of inconsistencies, serious omissions and the incorrect application of conservation principles and guidelines to warrant the preparation of a completely new Conservation Plan.

The proposal by National Parks and Wildlife Service to prepare a revised Conservation Management Plan with its core built largely on the existing Conservation Plan prepared by itself must be challenged. If such a revised document were produced based on an updated and expanded Conservation Plan, its integrity and conservation benefit would be profoundly compromised.

A whole new Plan is needed which ensures that the cultural and natural significance of the Quarantine Station is retained and, in accordance with the Burra Charter, includes provision for its security, its maintenance and its future. The Burra Charter Procedures for Undertaking Studies and Reports requires that the content be the responsibility of a qualified heritage practitioner. We are pleased that Peter Freeman Pty Ltd has been engaged to prepare the Conservation Management Plan. We would anticipate that the new document be not only professional and independent but also transparent in its intent. To achieve this, it is essential that the work of the heritage practitioner should neither be influenced nor prejudiced by the Service's expectation of a leasehold arrangement which it has already set in train.

Notwithstanding our prefacing remarks above about the need for a new rather than revised Plan, the following points are raised with respect to the Conservation Plan 1992.

The section titled Terminology and Abbreviations indicates that some definitions are taken from the Burra Charter. We note that those definitions do not entirely accord with the Charter and in some cases are a subtle yet fundamental distortion. The playing with words undergirds the entire philosophical leaning of the Conservation Plan towards a preconceived outcome.... which seeks to facilitate the leasing of the Quarantine Station.

The definition of "Adaptation", for instance, refers only to Article 20 which provides that Adaptation is acceptable where the conservation of a place cannot otherwise be achieved. Importantly, it fails to also include the necessary limiting clause, Article 21, which stipulates that Adaptation must be limited to that which is essential to a use for the place determined in accordance with Articles 6 and 7.

Article 6 prescribes that Conservation policy appropriate to a place must be determined by an understanding of its cultural significance.

Article 7 dictates that the conservation policy will determine which uses are compatible.

The omission creates serious repercussions for the Conservation Plan. The Plan adopts the unrestricted view that adaptation is the only course of action available to it. This is determined primarily as a consequence of funding constraints, not cultural significance (see page iv, paragraph 7). The Plan neither seeks to limit adaptation to that which is essential nor formulate a conservation policy which will determine which uses are compatible. In other words, a reading of the Conservation Plan shows that the desired compatible use determines the adaptation which in turn dictates the conservation policy. Clearly this is the wrong way around.

The Conservation Plan's definition of Compatible use (refer to second sentence in definition) incorrectly substitutes the term "Compatible use" for "Conservation" (see Burra Charter, Articles 3 and 6). The apparent error is significant as it implies that Compatible use is synonymous with Conservation, which it clearly is not. The Conservation Plan, page 54, paragraph 2, repeats the confusion of terms. The Conservation Plan, by giving emphasis to compatible uses, favours adaptation above maintenance, preservation, restoration and reconstruction.

The existing Conservation Plan refers to the "Planning Area", not Study Area. This presupposes that planning, rather than conservation, is the intended goal. The existing Conservation Plan also fails to adequately consider the natural and indigenous heritage values of North Head which need to be understood and interpreted within an integrated topography.

The Study Area for a Conservation Management Plan should include all that area which is pertinent to the full and proper assessment of natural and heritage significance and its management as well as its surroundings.

Clearly, the Study Area should include (but not be limited to) the whole of North Head, including the St Patrick's Estate. The reasons for this can be established in terms of past, present and future significance

Past Significance

The Quarantine Station in its earliest period occupied the whole of North Head and, prior to 1874, also included that land which now forms the St Patrick's Estate at Manly. The Study Area, therefore, of necessity, should include all of the historic lands.

Present Significance

The natural significance of North Head as a unified and unique biological and geological system requires that the whole of North Head and adjacent waterways be included in the Study Area. The habitats of threatened species, for instance, are not limited to the boundaries of the Quarantine Station. There have been a number of previous studies and reports (including that by the North Head Section 22 Advisory Committee) which highlite the importance of regarding North Head as a whole in any conservation or management plan. Impacts on the Manly residential area and town centre also need to be included in terms of access, traffic, usage and amenity. Views of the Quarantine Station from Little Manly Point, Manly Point and the water are also very significant.

Future Significance.

The Guidelines to the Burra Charter: Conservation Policy, clause 2.8 states that the Conservation Policy should set guidelines for future developments resulting from changing needs.

The proposed transfer of the Artillery School and later the Australian Institute of Police Management sites to National Park needs detailed consideration in the new Conservation Management Plan. The sites are significant not only for their previous cultural association and current nature interdependency with the Quarantine Station, but also for the potentially dramatic impacts that their changes of use will bring to North Head. The inclusion of these sites in the Study Area is paramount and becomes even more so given the National Parks and Wildlife Service is proposing a lease arrangement in excess of 40 years in which time significant changes will have occurred. A unified Conservation Management Plan which considers the conservation and adaptation of the combined sites will be far more beneficial in the long term than a study of the Quarantine Station alone.

The Conservation Plan provides a totally inadequate description of the geodiversity of the Quarantine Station, in particular the significance of the Pleistocene high level dune sands which occur on much of the site. The hydrogeology section makes no mention of the wetlands and source of the spring. The fragile soil landscapes are prone to wind and water erosion and need assessment prior to any intensification of use.

Whilst the Conservation Plan briefly describes the flora and fauna, the policy for protecting them and actions relating to them (section 8.2.9) are too broad usefully to define future actions. No mention is made of where threatened, rare and significant plant communities are located. The focus of the document is clearly on the cultural or built heritage of the area and the natural areas require the same level of attention in order to derive clear and unambiguous management goals regarding the natural heritage of the Quarantine Station. Inadequate concern has been given to the likely effect of intensification of use on the natural values of the place, surrounding headland environment and North (Sydney) Harbour Aquatic Reserve.

The plan also does not recognise the importance of the site for scientific research and teaching. The unique bio diversity is in such close proximity to the centre of a major international city. Many of the management goals (feral animal control, management of fire regimes, restoration of habitat for fauna, bushland regeneration) require research in order for appropriate management to be carried out. One of the major natural heritage values of North Head was that it was an area where research into the ecology of bushland remnants would result in findings relevant to the management of other similar habitat fragments.

The requirement to protect the colonies of the long-nosed bandicoot and little penguin are inadequately addressed. The principles for implementation (Section 9) do not indicate any strategies to do this, although the intention to undertake more detailed conservation plans is stated.

When the distribution of the vegetation and habitat used by the long-nosed bandicoots at the Quarantine Station is taken into account, the preservation of both the existing native vegetation and native fauna and their habitats may require that the entire area be reserved. Such limitations would be contrary to the planned intensification of use proposed in the Conservation Plan.

Given that the fairy penguin colony is the last surviving breeding colony on the mainland of NSW the comment that it is of local interest (p41) is hardly applicable. Adequate management and conservation strategies are needed which properly consider the marine and coastal environment as critical habitat.

The Conservation Plan pays scant regard to the historical and cultural significance of Aboriginal sites found within the Quarantine Station. The documentation is minimal. The Plan itself acknowledges that "other sites have not yet been properly recorded or assessed" (see page 19). Indeed, more disturbing is the notation in the Plan that "the significance of these sites to the local Aboriginal community has not been assessed".

Not withstanding the above statements, the Plan under Section 6: Statement of Significance states; "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" (page 51). While these sites are of special significance to the Aboriginal community, they are also of great importance to the whole community and should be seen as an integral part of the whole community's heritage.

Much more systematic investigation is needed in collaboration with the Metropolitan Local Aboriginal Land Council to identify and further investigate the Aboriginal heritage of the North Head area and Quarantine Station in particular. It is imperative and necessary under government legislation that the local Aboriginal community and Land Council be consulted and made aware of the impacts on these Aboriginal heritage sites of any potential development at the Quarantine Station.

The Quarantine Station is the best example of an intact quarantine station in the world and holds a distinguished place alongside other famous sites such as Ellis Island in New York and Grosse λle in Quebec.

Foremost, the new Conservation Management Plan must place the preservation of the site and its surroundings above all other objectives. The opportunity for interpretation of the site and its context should be guaranteed for the public as a whole.

Financial determinants should not be allowed to become the guiding principle in determining the future for the site. The commercialisation of the Quarantine Station inevitably will compromise conservation values, if not in the short, then surely in the long term.

The philosophy of "sampling" adopted in the existing Conservation Plan is entirely rejected as it provides a way-out clause which would allow a commercial operator to eventually divide up the Quarantine Station into discordant parts.

The new Conservation Management Plan must ensure that the entire Quarantine Station, with all its individual buildings including their interiors as well as its nature be seen as significant to the interpretation of the whole. It is the intactness of each of the individual items as well as the whole which is essential to the unique experience that is to be gained from the Quarantine Station.

The plan does not provide conservation plans for each precinct of buildings. By deferring this important process to a prospective lessee is a confusion of priorities. The proper process requires the completion of a conservation plan with definite policies for fabric, interpretation, use, development and management.

The planned lease agreement which requires the operator to prepare an Environmental Impact Statement for any development provides no certainty that conservation values will be protected.

The Conservation Plan (page 23) acknowledges that the survey conducted in 1988 and used to assess the buildings according to significance was "brief". The brevity and lack of analysis in the survey betrays its inadequacy. That such an inadequate survey has been adopted as the basis for the categorisation for the Conservation Plan is even more ludicrous.

The inclusion, for example, of the largely intact Second Class buildings in Category 3 as buildings that do not have components of high significance and may be sympathetically adapted or reconstructed is a travesty. It is an irony that the Second Class building P12 also happens to command the best views of Cannae Point and the Harbour and as such would be most attractive to a developer for use as upgraded accommodation suites. One questions to what extent other buildings have been similarly classified to suit their development potential rather than conservation value.

The statement (page 22) that the individual Quarantine Station buildings are not considered to have architectural significance in their own right is a gross generalisation and undervaluation. Most of the buildings and connecting walkways provide remarkable architectural quality and spatial juxtaposition which should not be tampered with. Their predominantly domestic style does not detract from their merit as fine examples of their era. The visual interrelationship of the buildings with the landscape is fundamental to their architectural significance.

The Quarantine Station provides in great detail a record of quarantine medical practice, public health administration and treatment of many infectious diseases. The site also documents in microcosm the history of immigration to Australia, providing insights into the cultural mix and social class of those who made the journey and who had the misfortune to be quarantined.

At its recent biennial meeting, the Australian Society of the History of Medicine expressed concern at the possible impacts commercialisation may have on the site. Professor Yvonne Cossart of the Infectious Diseases Department of the University of Sydney believes that the native mammals at the Quarantine Station are still carriers of the infectious diseases for which patients were once quarantined. Testing of fauna has not been done and should be carried out, with assessments made for the destabilising impacts of increased occupancy and development on the hitherto contained ecosystem.

The role of developing trends in ecotourism has not been considered for the Quarantine Station and North Head. The focus must be, in the words of Sophie Elias-Varostis, Professor of Tourism at the University of Paris and member of the International Association of Scientific Experts in Tourism who recently attended the Quarantine Station, on reinforcing the "sense of place" for the tourist. "Not about consuming a given environment, but about the inter-cultural activity and shared knowledge that takes place therein." The maintenance of the social fabric of the host community requires that local values, culture and sustained vitality of the natural resources and landscape be reinforced while providing equitable economic benefits to the local community.

The application of the Australian Accounting Standard AS 1037 for Self Generating and Regenerating Assets which defines an economic value for the natural heritage, flora and fauna is essential. The presence of threatened colonies magnifies this responsibility. The Standard provides a basis for undertaking an environmental audit, an accepted practice applied to significant sites.

An audited environmental value for the Quarantine Station would produce a very different result to that of an audit of infrastructure and real estate alone. The value of the Quarantine Station would be vastly increased if environmentally audited. Any commercial lease value should be determined on a real environmental value for the site. Given a proper assessment, the National Parks and Wildlife Service may well have an entirely different view as to how the site should be valued and managed.

The Executive Summary of the Conservation Plan 1992 presents a conclusion to allow the Service to lease the Quarantine Station to one or more commercial operators. No management structure is examined.

The Guidelines to the Burra Charter Conservation Policy, clause 2.5, stipulates that the Conservation policy should identify a management structure through which the conservation policy is capable of being implemented.

The purpose of the Conservation policy is to state how the conservation of the place may best be achieved both in the long and short term. Management structure should not be determined on the basis of political or fiscal expediency.

The Conservation Plan would best serve its purpose if it were to consider a number of options for short term and long term management structure. The investigation would include an assessment of the benefits and limitations of each option. Potential options should include:

• Management by NPWS

• Management by NPWS with subleasing of facilities

• Head lease of entire site

• Links with the Sydney Harbour Federation Trust

• Public trust - eg Jenolan Caves Trust, Presidio Trust in San Francisco

• Management structures used for comparable quarantine facilities

• Other management options

The objective of maintaining public control of the Quarantine Station should also be addressed in line with the National Parks and Wildlife Service Corporate Plan 2000/2003 which states as its mission; working with people and communities to protect and conserve natural and cultural heritage.

The Guidelines to the Burra Charter: Conservation Policy, clause 2.9 states that the Conservation policy should contain provision for adoption and review.

The Quarantine Station has a high degree of social significance not only to the residents of Manly but also nationally. The future of the site is a matter of considerable public interest.

The process for adoption and review of the Conservation Management Plan should be cognisant of the public interest and the valuable contribution that the community has made to fostering the Quarantine Station. Adequate time and resources should be given to ensure full community consultation, participation and review.

A so called water-tight Conservation Management Plan which enshrines conservation values and policy can provide some safeguards against commercial opportunism, but then, even this remains open to abuse after time. This is why management by a public authority or instrumentality is necessary, as it can provide a suitable mechanism for on-going public scrutiny and accountability.

The Friends of Quarantine Station is committed to the following objectives:

1. To ensure that the Quarantine Station is preserved and protected in all its heritage aspects - natural, cultural and built - in order that it be appropriately conserved.

2. To make the history and heritage of Quarantine Station available to and appreciated by the widest number of people through interpretation and education.

3. To support the Quarantine Station by fundraising, provision of volunteers to undertake work on site, pro bono professional work, advocacy and any other suitable avenues.

4. To ensure that planning for Quarantine Station is integrated into planning for the whole of North Head.

5. To ensure public access to all parts of Quarantine Station under appropriate management to protect its integrity and fragile environment.

It is hoped that the new Conservation Management Plan will take on board the concerns raised by this submission and also capture the vision advocated by the Friends of Quarantine Station, that states:

The Quarantine Station provides Australians with an intact example of cultural heritage and natural environment which is unique in the world. Preserved by its history, isolated by its geography, and standing at the gateway to Sydney Harbour, the Quarantine Station deserves to be managed by the people of NSW, for the people, to ensure the maintenance of its natural and cultural values, character and ambience.

We shall await with interest the development of the new Conservation Management Plan. We also look forward to the opportunity to make further input through the Reference Working Group and to elaborate the points raised. Please keep us informed of progress and changes to the timetable.

Yours faithfully,