The Nature Conservation Society of South Australia (NCSSA) has serious apprehensions concerning the proposed Belair National Park Trails Masterplan prepared by Taylor, Cullity and Lethlean (RE01_9).
We feel that trail development as proposed in the plan has significant potential to result in deleterious and unmanageable ecological impacts on Belair National Park's biodiversity, native vegetation, threatened species populations, wildlife and natural features.
We appreciate that there is public demand for recreation facilities and infrastructure however we feel that as an integral part of South Australia's Protected Area System, Belair NP needs to be just that, protected, from adverse human impacts.
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Recreational planning for Belair NP needs to consider the park's significance to nature conservation in a landscape context, as well as in the region and State, and the reserve's irreplaceable natural assets. The Adelaide and Mount Lofty Ranges region contains just 13% remnant native vegetation. Belair NP, being one of the largest reserves of the region, is therefore a core conservation asset.
In this document we begin by explaining the conservation significance of Belair National Park, detailing the threatened species, ecological communities and habitats it protects and its significance for South Australian Government policy initiatives. In our opinion it is also salient to re-examine the objects of the South Australian National Parks and Wildlife Act 1972. Following this we provide:
· an outline of the likely impacts of the trails development proposed by the plan;
· comments on specific details of the plan (referenced by section);
· a discussion of reserve management planning issues;
· a discussion of legal issues arising from the Trails Masterplan
· an explanation of our concerns over the wider implications of the trails planning process
Belair is an internationally significant National Park, and not a Mountain Bike or Horse riding facility. It would appear that the plan effectively seeks to downgrade the status of Belair NP by transforming it into an unfettered recreation park with little safeguard for the park's high nature conservation values. This is implied through the use of terminology in the plan such as "maximising trail experience for riders" and planning ‘principles' that aim to "exploit" the reserve's unique features, including the park's high conservation zones. Clearly such aims are inappropriate for a reserve so crucial to nature conservation in the region and to South Australia.
Conservation significance of Belair NP's biodiversity assets
Belair National Park contains some of South Australia's most precious biodiversity assets.
The park conserves over 800 hectares of high-rainfall, temperate natural ecosystems. The park includes remnant examples of 5 state threatened ecosystem or vegetation types and protects probably the best remnant examples of mesic grassy woodlands in the state, in addition to providing habitat critical to the survival of a large number of national and state threatened species (see Robertson 1993). Of prime importance are areas of Belair NP that contain: threatened species habitat (existing and potential); threatened ecosystems and vegetation communities; intact native vegetation communities; and areas with a high richness of indigenous species. Although these are well known to DEH, the conservation values of particular significance for Belair NP are highlighted below.
Threatened ecosystems and plant communities
· The most intact remnants of the state threatened and EPBC nominated Grey Box (Eucalyptus microcarpa) woodland communities in South Australia (Davies 1982).
· Some of the most significant remnants of grassy Manna gum (Eucalyptus viminalis ssp. viminalis) woodlands in South Australia.
· Threatened riparian vegetation communities including Red gum and Manna gum Woodlands and Silky tea tree shrublands.
Nationally and state threatened species
· Known population and habitat for the EPBC Endangered Southern Brown Bandicoot (Isoodon obesulus)
· South Australia's largest most important population of the EPBC Vulnerable Leafy Greenhood orchid (Pterostylis cucullata), and the largest outside southeastern Australia.
· Populations important to the recovery of the EPBC Endangered plants Caladenia behrii and Caladenia rigida and EPBC Vulnerable, Prasophyllum pallidum and Glycine latrobeana.
· The second largest remaining population of the SA Vulnerable Prasophyllum pruinosum
· Important populations of the state threatened Diuris behrii and Prasophyllum fitzgeraldii.
· South Australia's largest population of the State Rare Pterostylis curta.
· The largest reserved population of the SA Vulnerable Juncus amabilis in the region.
SA Government conservation policy and planning
The Trails Masterplan disregards the presence of threatened species and communities in Belair NP whose recovery and management is essential for achieving state and national conservation obligations. Belair NP forms a critical component of the SA Government's Borda to Barossa Nature Links Biodiversity Corridor and its protection and management for biodiversity conservation is crucial to achieving the SA Government's "No-Species loss": Nature Conservation Strategy. Both Nature Links and No-Species-Loss are components of the South Australian Government's State Strategic Plan (Government of SA 2007).
Many threatened flora species of Belair NP are the focus of the DEH Southern Lofty Block Threatened orchid recovery program, and program activities of the Friends of Belair, Native Orchid Society of South Australia, and Threatened Plant Action Group. Most of the threatened species mentioned above are included in the priority list of the recent DEH Regional Recovery Plan for the Adelaide and Mount Lofty Ranges region, and there is substantial public support for, and continuing involvement in the recovery of these species.
A Recovery Plan prepared for three of the EPBC threatened orchid species (Caladenia behrii; C. rigida; and Pterostylis cucullata) that occur in Belair NP has been adopted by the SA Government This plan specifically states that mountain bike and horse riding are either direct or potential threats to extant sub-populations of these three species as well as vectors of weeds and Phytophthora, which are also either high or moderate threats (Quarmby 2006). A National Recovery Plan has also been prepared for Pterostylis cucullata (Duncan 2007). This plan also indicates the importance of the Belair NP population, and lists as threats: site and soil disturbance caused by tracks, as well as weed invasion and Phytophthora.
Purposes of Park Proclamation under the SANPW Act 1972
The aims of the Trails Masterplan also appear inconsistent with the actual purpose of Belair National Park. Section 28 of the South Australian National Parks and Wildlife Act 1972 states "The Governor may, by proclamation constitute as a national park any specified Crown land, Aboriginal-owned land, the Governor considers to by reason of the wildlife or natural features of that land".
The meaning of this is unequivocal. The primary reason for proclaiming Parks under this Act is for their wildlife or natural features, not for other purposes. Any human use of parks is therefore secondary to the protection and conservation management of their wildlife and natural features. This point is emphasised further by the Act's Objectives of Management which state:
"The encouragement of public use and enjoyment of reserves and education in and a proper understanding and recognition of their purpose and significance"
Park management and public use must therefore be contingent on the actual purpose of proclamation and proper understanding and recognition of their purpose and significance, not erroneous interpretation by recreational user lobbyists. It is important for the agency with stewardship responsibilities for Belair NP to make decisions on the basis of the Act's constitutions and Objects, rather than on the basis of coercive high-impact users who attempt to shift the goalposts and who will undoubtedly degrade and detract from the natural values of the park.
We feel that far greater consideration needs to be given to the views of the hard-working and dedicated conservation volunteers such as the Friends of Belair, Native Orchid Society of South Australia and the Threatened Plant Action Group Park who play a crucial and under-appreciated role in maintaining and restoring the biodiversity assets of the park.
Likely impacts of the Trails Masterplan
We understand that the trails plan for Belair will authorise mountain bike and potentially horse riding use along trails currently used by walkers and management vehicles only. These trails have not been specifically constructed for bikes or horses. The proposal intends their 'upgrade' through resurfacing and widening and in some sections conversion of narrow walking trails (single track foot pads) to a wider "multiple-use" trails. This will involve earthworks, vegetation clearance and bringing in exogenous material for resurfacing as well as wider long-term, direct and indirect impacts to adjoining natural areas.
Foreseeable impacts of the trails proposal include:
· Increasing trail usage and compaction (through authorising new, large user groups);
· increasing the level of recurrent disturbance to soils and substrates;
· increasing surface runoff;
· accelerated erosion of hillslopes (through the much greater weight and surface area of bikes and horses compared with walking);
· increasing Phytophthora and weed spread by bikes and horses, resulting in degradation of native vegetation habitats;
· incursion of riders into and out of native vegetation and creation of illicit routes, jumps etc. (there is evidence of this already occurring); and
· creating high risk of collision, safety hazards, and conflict between mountain bikers and horse riders and more environmentally benign, traditional users including family groups, walkers, picnickers, photographers, artists, bird watchers and naturalists.
Comments on specific parts of the plan
Reserve management planning
The Trails Masterplan appears inconsistent with the Belair NP Management Plan and Belair NP Vegetation Management Plan.
The Belair National Park Management Plan states that there are three forms of cycling currently taking place within the park both legally and illegally. Trail cycling is currently an unauthorised use on fire tracks and walking trails. Downhill cycling is currently an unauthorised and undesirable use in the park. The plan also states that cycle trails shall not be designated in high conservation areas as identified in the Vegetation Management Plan and reflected in the zones prescribed in this plan (eg trail cycling is not permitted in Conservation 1 Zone) and that cycle trails shall be of:
· a width to minimise conflicts between other cyclists and walkers and also to allow a clear line of vision to upcoming obstacles and other trail users;
· a gradient which will not restrict access to the recreational cyclist and will not lead to significant erosion problems.
Despite these conditions for cycling trails the Masterplan proposes an alignment that includes problem areas which are too steep and limited with respect to lines of sight to be appropriate or even safe (see comment for 7.10).
We believe that sections of proposed mountain bike and horse trails are incompatible with such areas and their high conservation values and will destroy native plant species during construction. What effective measures will be undertaken to preclude mountain bikers and horse riders from using out-of-bounds trails? As walking is more compatible with nature conservation this should be the primary recreation use and hence the focus for trail planning. How will bike and horse riders be prevented from using other trails? We oppose any new trail development in areas of threatened species habitat (Pterostylis cucullata populations along Queens Jubilee Drive and Tilty Track, Caladenia rigida population near junction of Mulara Track and Melville Gully Drive etc.) or more intact tracts of native vegetation.
We also feel that the park conservation zones urgently need to be expanded in several areas to reflect Belair's biodiversity conservation values, namely national and state threatened species, their existing and potential habitat, as well as state threatened ecosystems and vegetation communities that occur in the park. We feel that no trail redevelopments should be approved until this important measure has been undertaken.
Legal compliance and enforcement issues
The prevailing lack of park enforcement staff and resources will mean that mountain bike and/or horse users are likely to be self-regulating with very little other than 'goodwill' or non-binding codes of conduct to prevent riders to keep to authorised trails.
While the need for compliance and enforcement of trail use conditions is identified in the plan, no action is documented or resource allocation made. Without a genuine and transparent commitment to compliance, identified in the plan there is a serious risk of adverse impacts on threatened species and communities. This is a critically important consideration given that the proposed trail alignments bisects existing critical habitat for EPBC listed species and in sections come within 1 metre of known threatened species populations.
Of the EPBC Acts Significant impact criteria, the trails plan proposal has the potential to:
● adversely affect habitat critical to the survival of an EPBC listed threatened species;
● modify, destroy, remove, isolate or decrease the availability or quality of habitat to the extent that the species is likely to decline;
● result in invasive species that are harmful to a listed species becoming established in the listed species' habitat;
● introduce disease that may cause the species to decline; or
● interfere with the recovery of the species.
On the basis of information in the plan it is impossible to determine that the proposed trail developments will not have an adverse impact on threatened species in Belair NP. It is necessary to at least provide a map which overlays proposed trail developments with the location of threatened species populations, critical habitat areas, and threatened communities. DEH already have such information for many of the threatened species inhabiting the park, such as Caladenia behrii and Pterostylis cucullata. Maps would need to be presented at an appropriate scale.
As the plan doesn't demonstrate that there will be no significant impact on matters of national significance, EPBC threatened species populations and habitat in the park, nor how potential adverse impacts will be mitigated, a referral to the EPBC needs to be made as part of the planning process.
Wider implications of the trails planning process
While the Nature Conservation Society of South Australia are happy to provide the trails reference group with advice about the threatened flora and other natural assets in the park and how the negative impact of trails development can be avoided, it is not our responsibility to undertake a comprehensive environmental assessment on behalf of the reference group, DEH or the consultant.
It is surprising to see the large amounts of government funding being channelled into new trail upgrades in national and conservation parks around Adelaide when there remains huge funding shortfalls in the active management of weed and feral animal threats to native vegetation and biodiversity in the reserve system with most of the burden falling on volunteer groups who already prop up the entire management effort and save the State Government millions of dollars per year in doing so.
Mountain Bike and horse riding proponents have used the degraded condition of some native vegetation in Belair NP as a reason for allowing mountain bike use despite having done nothing themselves to shoulder any responsibility in addressing the situation. Being party to the degradation of native vegetation through a ‘do nothing' acquiescence towards biological invasions does not justify using the degraded state of some of Belair NP's vegetation communities as a reason for authorising bike and horse trails. Invaded native vegetation is still of ecological value and can be restored using the appropriate methods (Robertson 2005, Jury & Croft 2008). As their ratings suggest threatened ecosystem types are declining due to such threats as weed invasion and ongoing human disturbances. As current vegetation condition reflects a past of inadequate management effort and funding allocation, vegetation condition cannot therefore be used as an excuse for increasing recreation impacts.
There is also some thought that the Belair Trails Masterplan may represent the thin end of the wedge with respect to future recreational developments in parks around Adelaide. Given the thousands of community volunteer hours spent each year restoring and maintaining the native vegetation and biodiversity of these reserves moves to exacerbate human impacts are unjustifiable and would send an unfavourable message to the public on the legitimacy of the State Government's conservation credentials and policy commitments.
Based on the aforementioned issues and shortcomings of the plan we recommend the following:
· Referral of the proposed action to the Australian Government due to likely significant impacts on matters of national environmental significance (listed threatened species);
· Revise the conservation zones of Belair NP to reflect the distributions of threatened species and communities;
· Review and update the Native Vegetation Management Plan to incorporate current information on threatened species and communities;
· Develop a formal process for recreation planning in the state reserve system with due consideration of the biodiversity conservation assets and management objectives;
· Plan further recreational infrastructure around proper conservation planning for and protection of Belair NP's natural biodiversity assets, rather than the other way around.
Davies R J-P (1982) The Conservation of Major Plant Associations in South Australia. Conservation Council of South Australia Incorporated.
DEH (2003) Management Plan for Belair National Park. Government of South Australia.
DEH (2008) About Nature Links: Implementing South Australia's Strategic Plan. Government of South Australia. http://www.environment.sa.gov.au/naturelinks/pdfs/about_naturelinks.pdf
DEH (2007) No Species Loss: A Nature Conservation Strategy for South Australia 2007-2017. Government of South Australia. http://www.environment.sa.gov.au/biodiversity/pdfs/nsl_strategy.pdf
Duncan M (2007) National Recovery Plan for Pterostylis cucullata in Victoria, South Australia and Tasmania. Department of Sustainability and Environment, Melbourne.
Government of South Australia (2007) South Australia's Strategic Plan 2007. http://www.saplan.org.au/images/pdf/South_Australia_Strategic_Plan_2007.pdf
Jury T & S Croft (2008) Comparison of managed with unmanaged grassy woodlands at Belair National Park. Xanthopus, Vol 26, 1, pp 16-19. Nature Conservation Society of South Australia, Adelaide.
Quarmby J (2006) Recovery Plan for Twelve Threatened Orchids in the Lofty Block Region of South Australia 2007-2012. Department for Environment and Heritage, South Australia. http://www.environment.sa.gov.au/biodiversity/pdfs/threat_orchid_recovery_plan.pdf
Robertson M (2005) Stop Bushland Weeds. Nature Conservation Society of South Australia.
Robertson M (1993) Regional Vegetation Study: Native Vegetation in Happy Valley, Mitcham and Stirling Local Government Areas.