 |
Fraser Island Defenders Organization FIDO, “The Watchdog of Fraser Island”, aims to ensure the wisest use of Fraser Island’s natural resources. |
Review of Recreation Areas Management Act, Regulation and By-LawThe Queensland Government is reviewing the Recreation Areas Management Act, Regulation and By-Law and have released a discussion paper.
The following letter is FIDO's Comments:
Web Site: www.fido.org.au — E-mail: john@fido.org.au 26 February, 2002
The Secretary
Dear Secretary, Re: Review of Recreation Areas Management Act, Regulation and By-Laws
Fraser Island represents the major area covered Act in terms both of physical size and in the overall proportion of the Recreation Areas Management Board budget. (The only other RAM sites are Moreton Island, Green Island and Inskip Point). Fraser Island therefore is the RAM site that has the greatest significance to the Board. Fraser Island should not be a RAM site: While FIDO is making a submission on the proposed review of potential changes to the Management Act, Regulation and By-Law, FIDO wants Fraser Island removed from the provisions of the RAM Act for the following reasons:
Fraser Island generates about $250 million annually for the Queensland economy. This is the outcome of a recent independent study initiated by this organization and commissioned through the Australian Tropical Research Foundation. An almost completed report by independent corporate consultants, Kleinhardt FGI Pty Ltd makes this clear and elaborates how this quarter billion figure is derived. It is not available at present but will be concluded by 20 March and a copy pasted in full on the FIDO web site and can be reviewed there.
Other proposed new legislation ignored: It is this organization's view that the Review has failed to recognize a commitment by the Beattie Government and in so doing has overlooked a most critical option to those set out in the Discussion Paper. The Beattie Government was elected in February 2001 making the following "core promises":
It is in the light of that promise by the Queensland Government that FIDO proposes that the RAM Act legislation should no longer cover Fraser Island. FIDO proposes that Fraser Island should have a separate single authority governed by its own Board. This Board should have the same powers as a local authority with the additional powers to raise its own revenue from visitor access fees in ways which would not be restricted entirely and exclusively to recreation management which is the stated and exclusive purpose of the Recreation Areas Management Act. FIDO has clearly set out its proposal based on the Lord Howe Island model in the attachment MOONBI 100. FIDO believes that with the revenue from access fees gathered (roughly the same rate as would be gathered under the RAM Act) plus rate revenue from private property as well as the contributions from the State and Commonwealth Governments it would have a viable financial base on which to operate. As a small local authority, it would have a very small bureaucracy and would operate mainly through contracts and consultancies plus the existing parks service management for most matters. Response to the Review Despite FIDO’s position that Fraser Island should not be included under the RAM Act we wish to make a submission on the provisions of the Act as it could potentially severely affect the Cooloola section of the Great Sandy National Park, which has been identified as a potential RAM area. Include cultural and natural resource management: Even without the proposed special legislation for Fraser Island this organization wants to have Fraser Island excluded from the provisions of the existing RAM Act unless the act is extended to cover cultural and natural resource management. It is FIDO’s view that people choose to recreate in natural areas such as Fraser Island and Cooloola and Moreton Island because of the significant natural resources (and in the case of Moreton and Fraser Islands the significant cultural resources). That the RAM Act should entirely ignore cultural and natural resource management denies the main value of recreation there. Safety and Fire: The failure to address issues such as fire management (which is deemed to be a natural resource issue) for many years has resulted in a dramatically changed ecology which a development of a denser understorey that has made Fraser Island more dangerous for recreation. The neglect of fire management under RAM has created a situation on Fraser Island which is not only impacting on natural resource management but is also affecting the safety of visitors and property. Definition of Recreation: FIDO believes that there has been a most unsatisfactory and arbitrary definition of "recreation" which is inappropriate for National Parks and World Heritage sites. The appreciation of the natural values of the World Heritage values of Fraser Island represents a most significant part of that recreational experience. However by narrowly defining "recreation" to covering only provisions of access and facilities such as campgrounds and toilets etc., the RAM Board has contributed significantly to changing the natural values. FIDO remains appalled that it is part of the Ranger’s duties to remove fallen palm fronds from Wanggoolba Creek at Central Station at the behest of Commercial Tour Operators to present a "tidier" image of this creek. Natural leaf fall is a part of the natural environment but since the bulk of the revenue going to Fraser Island is derived under the RAM Act there has been a distortion in priorities which the clearing of palm fronds in Wanggoolba Creek epitomize. The shooting of kookaburras because of a knee jerk "risk assessment" carried out by rangers and the massacre of so many dingoes also epitomizes the issue that recreation has been elevated in precedence above the protection of the natural resources. Free range camping has and continues to damage foredune vegetation. Commissioned reports have shown the degradation of the areas resulting from free range camping. Despite this, the issue is not being addressed despite studies showing the impacts because permit it is seen as an important aspect of Fraser Island recreation. The fact that free range camping is not tolerated on any other Queensland National Parks outside RAM areas demonstrates the distortion of management priorities towards fostering recreation irrespective of environmental impacts. Recreation must be sustainable: There is no provision in the review which circumscribes that in managing recreation the recreation must be sustainable without adverse impacts on other resources. For many years this organization has been concerned about the degradation of the lakes through siltation and run-off from adjacent roads. Notwithstanding that these are one of the most outstanding and self evident of Fraser Island’s World Heritage values, the run-off into the lakes continues. This was confirmed in an inspection last January and there has been nothing done to try to limit this except to place signs advising visitors not to enter the sites where the alluvial plumes are occurring. This is clear evidence that recreation in the form of unfettered access continues to take precedence over preserving the natural values. The options to address this degradation of the lakes apart from implementing overdue remedial works on the site are to close some of the routes which are contributing the silt and to establish alternative forms of access. This isn’t even entering consideration. It again epitomizes the fact that under RAM, recreation has such precedence that World Heritage values can be clearly ignored. A reference to MOONBI for the past decade would show many issues where the World Heritage values are being degraded through recreation but where no attempt has been made to address our legitimate complaints through "recreation management". The provision of new toilet blocks and new campgrounds, widening and hardening roads (even though these are eroding the natural values) and shooting dingoes and kookaburras take precedence over World Heritage values. The run-off from roads is changing the soil profiles. This whole issue has been neglected under RAM management which as by its inaction helped reinforce the existing non-sustainable patterns of recreation on Fraser Island. FIDO believes that where the existing patterns of recreation are unsustainable as demonstrated by recent studies by EDAW then the patterns of recreation have to be addressed more diligently. In this respect the RAM Board has failed in its responsibility even to effectively manage recreation even by its narrowest interpretation. Recreation Impact Statements: For these reasons FIDO urges that the legislation specify that there must be an annual impact of recreation statements to show that the recreation in each of the RAM sites is sustainable. Commercial Operations: While this organization welcomes moves to widen the operation to cover other commercial operations, particularly vehicle recovery services, we remain alarmed that there is mention of mobile vending machines. We are of the view that these should be kept right out of National Parks or even on beaches adjacent to them. Commercial Tour Operators: The fact that there has been negligible progress towards the implementation of the Report of May 1998 "Managing visitor and commercial operators for ecological sustainability" is an indication that RAM has failed in one of its most important areas of responsibility. The fact that there is still no move to review the existing licencing system for Commercial Tour Operators is preserving an oligopoly which is not in the best interests of Fraser Island. It is perpetuating a system of perceived rights such as allowing vehicles to drive along the shores of Lake Birrabeen which is detracting from the recreational experience of many other Fraser Island visitors. It is assigning management priorities to meeting the demands of Commercial Tour Operators )such as road repairs) above many other aspects of management deserving of higher priority. It condones whatever form of transport the operators want to employ as long as it meets vehicle licencing standards without consideration of environmental impacts. Aircraft on the beaches: We are also concerned that there is nothing to address the commercial operation of aircraft taking off from the beaches on joy flights. It is our view that if the RAM Board was really serious about public safety and visitor safety issues as outlined in the summary then the practice of allowing pilots to land on Fraser Island beaches and then tout for passengers for joy flights would be prohibited. This is clearly a commercial operation and the businesses benefiting should be paying. However, in the interests of public safety we don’t thing that beaches used by many vehicles and other recreational users should be allowed to be also used by aircraft. It is like allowing aircraft to land at will on busy country roadways. Extending RAM area into the marine zone: One of the main claims of RAM and the arguments advanced for continuing the Act is that it covers a multitude of operations and coordinates management. This is not true if it is limited only to the terrestrial areas. Each of the existing RAM sites has a coastline but RAM extends only to the low water mark. The Fraser Island World Heritage area extends 500 metres into the marine area from the shore. In three of these areas recreational fishing is a major part of the recreational fishing and boating yet the management of recreational fishing and boating (as well as the natural resources which the recreationists are targetting can’t be adequately addressed unless the RAM sites are enlarged to include at least the inshore waters. Adequate Funding: FIDO strongly believes that Fraser Island needs an annual budget of at least $10 million to ensure that it is managed sustainably. This is based on the budget for the far more robust environment of Kakadu National Park which attract slightly fewer numbers annually and which has enjoyed a budget of over $10 million since 1979. The RAM Board must ensure that there is sufficient revenue from all sources to adequately address all aspects of management for RAM sites. . Redefine the purpose of the RAM fees: It is FIDO’s submission that the public sees the fees they pay for access to Fraser Island is just "User Pays" and they are unaware of the constraints imposed by the RAM Act that this revenue can only be spent on recreation management. They are unaware of the differentiation made between the various aspects of management — recreation, culture and natural resources. The public expects the fees collected under RAM to be applied to whatever needs to be done to manage Fraser Island, not just "recreation". We assume the same philosophy would apply to other RAM sites. Increase "User-Pays" Fees: If adequate revenue cannot achieved from other sources then the scale of the "user pays " fees need to be increased significantly. The review does not propose any increase or mechanisms for increasing funds. Non-discriminatory application of RAM provisions: While FIDO is not opposed to the idea of fines and penalties, FIDO remains extremely critical of the discriminatory way with which the RAM Act has been applied on Fraser Island. In 1990 the RAM Act was used to frustrate environmental protesters trying to bring an end to logging on Fraser Island. It was used quite intentionally to make them move their entire camp every 3 weeks. Yet for years before and for the 12 years since professional fishers have maintained permanent camps on the beach at Waddy Point. Despite the Community Advisory Committee unanimously urging in July, 2001 that these camps be moved under the RAM Act as the greenies were forced to move, nothing has yet been done and more excuses are being invented for deferring any action. This can only be construed as a very discriminatory application of the RAM Act. Carrying Capacity: The EDAW Studies have indicated that many parts of Fraser Island are being used beyond their carrying capacity. They also show that the carrying capacity can be increased by up to 18% over the next 10 years. However, the growth in the rate of visitation to Fraser Island is increasing at about the rate of 5% annually. This seems to indicate that even with the best prescriptions for management the growth in visitor demands are not capable of being met without further degradation. This indicates that more limits need to be placed on visitation to Fraser Island. This is an issue which if Fraser Island were to remain under the auspices of the RAM Act has to be urgently addressed. The annual foreshadowed Annual Recreation Impact Statements would be one step towards addressing the issue of carrying capacity. Management Plans: While we applaud the idea of Management Plans for RAM sites we should point out that Fraser Island is covered by a Management Plan which has been very inadequately implemented particularly with respect to cultural resource management and to a lesser extent natural resource management. We would also point out that there is a commitment by the Beattie Government to enact legislation to give effect to the Great Sandy Region Management Plan and the Management Plans of other World Heritage sites in Queensland.
The RAM Act was once seen as having the potential to provide more revenue to better manage significant natural areas that have been popular for recreation. However, as our analysis above has shown, this Act has adversely impacted on Fraser Island. It is for this reason that this organization wants Fraser Island removed from the provisions of the RAM Act. However, we believe that if the RAM Act is going to continue then it should be reassessed particularly to ensure that revenues collected under the RAM Act can be used for natural and cultural management as well as for recreation management. Yours sincerely, (signed) John Sinclair Honorary Project Officer |