The Revised Draft Freycinet Peninsula Master Plan is referred to as the Revised Draft Master Plan or Master Plan.
4. Existing conditions and 5.0 Options Analysis
Chapter 4 outlines very well the exiting visitor management issues, including overcrowding, traffic and parking constraints, lack of accommodation, brand impact, inadequate facilities to manage visitor arrival. Additionally, it outlines well that high visitor numbers can result in environmental impacts including littering and spread of weeds and pathogens (though others could have been added such as disturbance to wildlife) and social impacts such as disruption of residents and shack owners. It points to constraints and opportunities with which we largely agree.
But what is missing in this chapter and which gravely biases the options that are considered in Chapter 5 is:
- The failure to clearly define what we are seeking to achieve; and
- the failure to identify one ‘giant’ constraint i.e. the state government’s insistence that limits on numbers of visitors is not considered.
It is possible that all of the measures proposed in the master plan to address impacts of visitors are successfully implemented but with increasing number of visitors the impacts continue to increase. As with road management users of reserves may hear that facilities and experiences have improved and this causes growth to accelerate further.
Objective to limit visitor impacts
The Master Plan needs to aim to limit the impact of visitors to some agreed and measurable level. It seems obvious that to determine a benchmark for overcrowding there has to be some rules, charges or incentives that aim to reduce how many people are in particular places at the same time.
RECOMMENDATION: The Master Plan needs to incorporate measurable benchmarks that define acceptable impact of visitors for a range of values, locations and times.
Need to consider new controls on visitor numbers
In the absence of any measures to further limit visitor numbers it is much harder to manage the impacts of visitors. Proposed facilities may just become overrun and more capacity will be required. We note that controls on numbers currently exist in regard to popular camping sites and further similar controls could be considered to protect specific values and locations for particular times. The total number of visitors to Freycinet National Park or Coles Bay does not have to decrease from the current numbers to address certain issues such as over crowding. The overcrowding is most extreme during the summer months and strict caps could be introduced that simply cause some visitors to come at other times, thus achieving a reduction of overcrowding while maintaining visitor numbers. Such limits may be achieved through price mechanisms and/or regulatory caps. Controls on numbers may be achieved by encouraging visitors to go to less busy locations during peak times, going to Friendly beaches rather than the Wineglass Bay walk. This might be achieved through a reduced park entry mark fee. Even if these measures worked overcrowding problems will occur at other locations and times and ultimately a total cap will be needed for each major entry point.
RECOMMENDATION: The Master Plan process should start again. Critically the scope should include a requirement to address community interest in controls on the numbers of visitors to Freycinet National Park and other parts of the peninsula.
RECOMMENDATION: If the state government does not consider some new measures to control numbers of visitors then the final master plan needs to clearly acknowledge (in addition to the statement in section 1.4) how the proposed measures are likely to succeed without such measures.
Key initiatives will not reduce key problem of overcrowding
One critical flaw in the analysis is the assumption that the key initiatives - a new visitor gateway and a network of transport connections – will alleviate key concerns such as overcrowding on key attractions such as the Wineglass Bay track and lookout. The proposed new transport system should succeed in reducing the traffic flow and associated problems on Freycinet Drive but this just delivers the same number of people and does not reduce overcrowding.
Directing people to a visitor gateway has the potential to reduce pressure on key attractions at peak times through directing some visitor to other locations on the peninsula or convincing them to take the slow approach and use new tracks to access the Freycinet National Park. But this is not at all assured and given the attraction of Wineglass Bay and the comfort of the buses it is likely to result in minor changes.
6.0 The Master Plan
The Revised Draft Master Plan makes no specific reference to the relevant sections of legislation that define the purpose and objectives for Freycinet National Park and other reserves or the relevant management plans. Instead, there are a vision statement and principles provided as a replacement for the statutory requirements. These are not the same and are inadequate in many respected (see below).
There is an assumption that the specific developments recommended in the Revised Draft Master Plan are in accordance with the legislation and management plans for the land that they are located on and adjacent areas that may be affected by them.
It seems that many of the proposed visitor infrastructure projects may be compliant with the legislative and management plan, especially as the visitor hub is not on reserved land and the newest development and other facilities are in the Coles Bay visitor services zone. But this is beside the point. The Master Plan should have explicitly responded to these fundamental legal matters and not leave it to those writing submissions to argue that they are or are not consistent.
If the Master Plan is approved and later it is found that something needs to change such as a change to the zone or park boundary, there will be political pressure to have the changes made. There are also the accumulative impacts of all of the proposed changes, which will not be assessed as each project goes through its individual assessment process.
These concerns could have been dealt with as a part of the master planning process, but only if the master plan was developed to be in accordance with the management purposes and objectives of reserved land and the existing management plans.
It is important to not refer to management purposes and objectives as mere rules that are not to be contravened, they must be actively implemented. Conservation of biological diversity must involve active management directed at its specific conservation requirements.
The Revised Draft Master Plan only refers only to the need to protect or conserve natural and cultural values in a reactive and not proactive way i.e. it refers to the need to protect values when considering particular developments and infrastructure. If the document was a Tourism Master Plan then this might be acceptable but the title does not single out tourism.
RECOMMENDATION: As others have done the TCT recommends that if the state government does not intent to develop a true master plan for the Freycinet Peninsula then the document’s title needs to be changed to be ‘Freycinet Peninsula Tourism Master Plan’. Preferably, the current document should be abandoned and a true master plan is developed. This document would, in regard to reserved land, aim to help achieve the purpose and objectives for the different classes of reserved land and be consistent with the relevant management plan.
6.1 Vision
As evidence of my claim that the plan is tourism focused on the exclusion of other values, the vision statement is heavily slanted. It refers to natural and cultural values being ‘treasured’ which is not the same as being conserved. It refers to the Pensinula’s values being protected but only through ‘journeys, stories and experiences’. Given that most of the Peninsula are reserved land the vision should refer to protecting natural and cultural values in the broadest sense, not just in regard to tourism?
The vision goes on to refer to ‘appropriate amenities, infrastructure and services’ for visitors and locals. Again this is just about managing visitors and other users of reserves and not protecting natural and cultural values in the broadest sense.
RECOMMENDATION: The vision should be abandoned and a new one created that reflects the requirements of the relevant legislation and management plans,in relation to reserved land, and compatible additional statements regarding unreserved Crown land and private land.
6.2 Principles
Instead of referring to the objectives for management of reserves as defined in
Schedule 1 of the National Parks and Reserves Management Act 2002, the Revised Draft Master Plan only refers to a series of principles.
There are six principles referred to and natural and cultural values are but one of them, clearly demonstrating the document’s bias. And what does the plan say about natural and cultural values? Protection of them is a ‘keystone’ for the master plan, whatever that means. Developments need to be ‘Sensitive to these values’ but not ‘consistent with the conservation of the national park’s natural and cultural values’ which the legislation requires. The reason given for development needing to be ‘Sensitive to these values’ is because these values are the reasons for people wanting to visit the area. So the sensitivity required just has to measure up to the demands of current visitors. These statements are absurd and are an affront to the Tasmanian public for whom the ‘public’ land is managed.
The principles states that all infrastructure recommended in the Master Plan is to be assessed and surveys are done prior to construction. I can’t believe these words are included. We are talking about reserved land including Freycinet National Pak and Moulting Lagoon Ramsar wetland. We would expect that developments would be assessed and surveys done pre-construction as a basic first step, not a matter of high principle. The principle fails to even state that recommendations from the assessments and surveys are to be implemented.
But the biggest weakness in not referencing legal and management plan requirements is that the elephant in the room is missed. What is the impact from having more visitors? Yes, new and upgraded facilities are proposed to enable Freycinet National Park and other reserves to cope with growing visitor numbers but the Master Plan provides no evidence or commitments that these will actually result in less impacts on natural and cultural values.
I note in Chapter 5 Options Analysis there is no reference to any environmental or cultural conservation benchmarks if the proposed key initiatives are built. So how do we know there will be any improvements?
RECOMMENDATION: The principles should be abandoned and new ones created that reflect the requirements of the relevant legislation and management plans.
Key initiatives
Improve wastewater management
If there is to be a major change to wastewater management on the Freycinet Peninsula then the tourism and residential development potential will very likely expand massively. This would require the revision of the Master Plan and the plan should acknowledge this as a prescriptive recommendation
A new visitor gateway
The analysis supporting a new visitor gateway and a new transport system is very light on. Then options analysis is mainly concerned with what type of gateway and where, and does not consider another option seriously.
Rather arrogantly we are told, in relation to the gateway, that ‘it has always been recognized that there is broad support for the concept of a central parking area outside the national park and a new shuttle bus system’. There is no evidence presented that supports this claim and key local advocates support other options instead e.g. the main visitor centre remaining at ranger Creek and additional parking provided nearby. Certainly, if this was implemented along with measures to limit visitor numbers I would endorse the idea.
The preferred option identified in the Master Plan involves the gateway being 500m outside of the Coles Bay town which seems destined to result in a large proportion of visitors rushing past and heading for the national park or town, which they have presumably planned to get to.
RECOMMENDATION: That the proposed preferred option for a gateway is not supported.
Transport strategy
I support some of the approaches recommended, such as including shuttle buses (which would reduce carbon emissions as well as congestion and parking problems) and encouraging people to visit other locations and use new tracks to access key locations. As explained in response to chapters 4 and 5, the new transport system is unlikely to address the critical problem of over crowing on key tracks, in particular, the Wineglass Bay track.
Also stated previously, there is the potential for the strategy to fail dramatically if users do not want to use the shuttle buses or do not want to stop at the gateway. Critically, the Master Plan refers to ‘encouraging’ visitors to park their car and use alternative transport and not requiring this. The Master Plan states that currently ‘the arrival point into the peninsula is almost exclusively singular – via car from the Tasman Highway’. The preference for cars is very strong and shifting this needs further research and market analysis.
We note concerns that the bus service could be subsidized but this was not specifically considered in the Draft Master Plan.
RECOMMENDATION: That further research and market analysis is undertaken before proceeding with a new transport strategy.
RECOMMENDATION: The use of shuttle buses, in particular, is supported but in addition to further research being required to support the demand and an explicit policy confirmed who pays, it is noted that the shuttle bus idea can apply even if the preferred gateway is not supported. Consideration should be given to buses leaving from multiple key entrance points, the township, Ranger Creek and a site to the north of the town as recommended but not necessarily with the complete Gateway complex.
There are likely to be many problems with the proposed boat connections, including impacts from a new jetty proposed at the old quarry. This includes visual impacts on the key locations used by visitors to view the Hazards. There will also be impacts of a considerable increase in visitors walking along the track from the old quarry past the Youth Hostel and houses in the Fisheries.
RECOMMENDATION: While supporting boat use in principle, the idea needs to be assessed more closely and consideration given to using existing facilities and not proceeding with the new jetty. I note that the boat that takes walkers to the start of the Three Capes Track simply runs up onto the beach.
Yours sincerely,
Peter McGlone
Director
Tasmanian Conservation Trust