Federal Register of Legislation - Australian Government

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Kakadu National Park Management Plan 2016-2026

Authoritative Version
Plans/Other as made
This instrument provides for the management of the Kakadu National Park for the next 10 years.
Administered by: Agriculture, Water and the Environment
Registered 04 Jan 2016
Tabling HistoryDate
Tabled HR02-Feb-2016
Tabled Senate02-Feb-2016

Cover design for the report of the Director of National Parks on the preparation of the sixth Kakadu National Park Management Plan. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


 


Logo for the Director of National Parks

 

Report of the Director of National Parks

                                         on the preparation of the sixth

Kakadu National Park Management Plan

 

Responses to public comments on the
Draft Management Plan for Kakadu National Park
Prepared in accordance with Section 370(2) of the EPBC Act

 

 

 

Contents                                                                                                            Page

1.       Introduction                                                                                                                                             3

2.       Kakadu National Park                                                                                                                           3

3.       Management plans enable activities within Commonwealth reserves                           4

4.       Planning process                                                                                                                                    5

5.       Features of the new Management Plan                                                                                      6

6.       Comments received on the Draft Management Plan                                                             7

7.       Summary                                                                                                                                                   9

Appendices

A       Public comments that resulted in changes to the management plan

B        Public comments that did not result in changes to the management plan


1.       Introduction

The sixth management plan for Kakadu National Park has been prepared in accordance with the Environment Protection and Biodiversity Act 1999 (EPBC Act) and replaces the fifth management plan prepared under the EPBC Act which ceased to have effect on 31 December 2013.

Since 1 January 2014, Kakadu National Park has been managed under s.357 of the EPBC Act which states:

(1)           While a management plan is not in operation for a Commonwealth reserve, the Director must exercise the Director’s powers and perform the Director’s functions in relation to the reserve or to a zone of the reserve so as to manage the reserve in accordance with:

(a)      the Australian IUCN reserve management principles for the IUCN category to which the reserve or zone has most recently been assigned by:

                                    (i)          a Proclamation made under Subdivision B; or

                                   (ii)          a management plan that was in operation for the reserve (but is no longer); and

(b)     if the Director holds lands or seabed included in the reserve under lease—the Director’s obligations under the lease.

In doing this, the management of the park has been guided by the actions and principles of the previous management plan until the sixth plan comes into effect.

2.       Kakadu National Park

Kakadu National Park covers an area of 19,810 square kilometres within the Alligator Rivers Region of the Northern Territory. Kakadu is the largest terrestrial national park in Australia, extending from the coast in the north to the southern hills and basins 150 kilometres to the south, and 120 kilometres from the Arnhem Land sandstone plateau in the east, through savanna woodlands to the western boundary.

The majority of the Kakadu region is Aboriginal land under the Aboriginal Land Rights Act (NT 1976) and has been home to Aboriginal people for over 50,000 years. The Aboriginal people, Bininj in the north and Mungguy in the south, are the traditional custodians of the land.

There is an extensive network of rock art sites in the Kakadu region, recognised to be one of the greatest concentrations of rock art sites in the world. Some of the rock art is estimated to be up to 20,000 years old. This represents one of the longest historical records of any group of people in the world.

The Kakadu region includes a diverse range of landscape types, including lowland savanna woodlands, stone country, rainforest and floodplains and coastal zones. These landscapes dramatically change throughout the year in response to the six seasons recognised by Bininj people in the north and five seasons by Mungguy people in the south of the park. The park contains a diverse range of plants and animals, including high numbers of endemic species in the stone country.

Kakadu National Park was primarily proclaimed in three stages between 1979 and 1991, and inscribed on the World Heritage list for its outstanding cultural and natural values in 1981. Bininj/Mungguy have leased their land to the Australian Government to be jointly managed as a national park. One of the most important features of Kakadu National Park is the ongoing custodianship of the region by Bininj/Mungguy who continue to live in and jointly manage the park.

There are a range of significant threats to the internationally important cultural and natural values of Kakadu National Park. These include the encroachment of weeds, feral animals, altered fire regimes, climate change, loss of Indigenous cultural knowledge and visitor impacts (for example vandalism to rock art sites, dispersal of weeds, high concentrations of visitors at ecologically sensitive sites).


 

There has been a well-documented decline in small to medium sized native mammals across northern Australia, including within Kakadu National Park. The park now faces the significant challenge of addressing this issue and preventing any further declines or extinctions of native species. These threatening processes, in addition to differing value systems of Bininj/Mungguy and a broad range of park stakeholders, pose challenges and opportunities for the management of the park.

Reductions in resources and operational funding over recent years represents an ongoing challenge for the management of Kakadu National Park. This has required the progressive review of management priorities and approaches while continuing to incorporate new approaches for the management of threats.

World Heritage listed Kakadu contributes significantly to the regional and national economy through attracting visitors to Darwin, Jabiru and the greater region. The park attracted over 190,000 visitors in the 2014 calendar year, who came to experience Indigenous culture, ancient rock art sites, to camp, fish, bushwalk, take commercial tours on the wetlands and travel throughout the park. The plan aims to increase visitation to the park, to make new and improved experiences available to visitors, and through the establishment of experience development plans, increase opportunities for Indigenous participation and identify new opportunities for tourism and public investment.

3.       Management plans enable activities within Commonwealth reserves

The EPBC Act (ss.354 and 354A) prohibits certain actions being taken in Commonwealth reserves except in accordance with a management plan. These actions are:

·           kill, injure, take trade, keep or move a member of a native species; or

·           damage heritage; or

·           carry out an excavation; or

·           erect a building or other structure; or

·           carry out works; or

·           take an action for commercial purposes.

The EPBC Regulations control, or allow the Director to control, a range of activities in Commonwealth reserves such as camping, bushwalking, commercial activities, commercial fishing, recreational fishing and research. The Director applies the Regulations subject to and in accordance with the EPBC Act and management plans. The Regulations do not apply to the Director or to wardens or rangers appointed under the EPBC Act. Activities that are prohibited or restricted by the EPBC Act may be carried on if they are authorised by a permit issued by the Director and/or they are carried on in accordance with a management plan or if another exception prescribed by r.12.06 (1) of the Regulations applies.

The EPBC Act does not affect the operation of the Native Title Act 1993 and s.211 in particular, which in certain circumstances allows native title holders to hunt (and undertake other activities) in the exercise of native title rights without a permit or licence (s.8 EPBC Act). Prohibitions and other provisions of the EPBC Act and EPBC Regulations dealing with activities in Commonwealth reserves do not prevent Indigenous people from continuing their traditional use of an area in a reserve for hunting or gathering (except for purposes of sale), or for ceremonial and religious purposes, in accordance with the EPBC Act s.359A.

Section 358 allows the Director to grant a lease or a licence relating to land or seabed in a Commonwealth reserve in accordance with a management plan.

Access to biological resources in Commonwealth areas is regulated under Part 8A of the EPBC Regulations. Access to biological resources is also covered by ss.354 and 354A of the EPBC Act if the resources are members of a native species and/or if access is for commercial purposes.

Mining operations are prohibited in Kakadu National Park by the EPBC Act (s.387).


 

4.       Planning process

In 2011-12, a technical audit on the implementation of the fifth plan was undertaken to assess the progress of the plan and to provide recommendations for the development of the sixth plan. Nine independent auditors with expertise in different areas covered by the plan were engaged to evaluate whether the actions and policies in the fifth plan were implemented and assess whether they successfully met the aims in the plan.

The technical audit of the fifth plan made the following recommendations about areas for improvement:

·           monitoring and reporting to provide evidence-based measures of progress

·           monitoring and treatment of weeds and feral animals

·           addressing the decline in native species, notably small to medium sized mammals

·           improving consultation processes with Bininj/Mungguy

·           improving opportunities for employment and contracting of Bininj/Mungguy

·           assisting with proposals for establishing new living areas in the park

The audit also suggested there should be a clearer link (or line of sight) between the park’s management actions and outcomes, and that the performance indicators in the plan should be able to clearly demonstrate if the park is achieving the desired outcomes and objectives. The new plan has been prepared taking into account this feedback.

In February 2012, consistent with s. 368 (1) (a) of the EPBC Act, a notice was published in the Australian Government Gazette, The Australian and the NT News newspapers inviting comments on the proposal to prepare a draft management plan. A notice was also placed on the department’s website. A printed Have Your Say brochure was circulated amongst landowners and other stakeholders to stimulate awareness of the planning process and the opportunity to contribute to the plan. This initial opportunity for public comment closed on 13 April 2012 and seven submissions were received.

Following consideration of the issues raised within these submissions, the Director and the Board then prepared a draft plan in accordance with s.368 (1) (b) of the EPBC Act. This was released for public comment on 3 December 2014 and closed on 14 February 2014, allowing a much longer period than the required 30 days under the EPBC Act.

Invitations to comment on the draft plan were published on the department’s website, in the Australian Government Gazette and in The Australian and NT News newspapers. Copies of the draft plan were sent to stakeholders with an invitation to comment (including those who provided comments towards the preparation of the draft plan). Copies of the draft plan were also available from the park, from the department’s website and through the department’s Community Information Unit.

There were 31 written submissions received from a range of stakeholders in accordance with s.368 (1) (e) of the EPBC Act. The Board of Management met twice to discuss the comments on the draft plan and an additional one day out of session meeting was held by Board members to discuss the last outstanding issues and adjustments necessary to finalise the plan.


 

5.       Features of the new management plan

Consistent and enabling

·           Much of the substance of the management plan is consistent with the intent and direction of the previous plan. The plan consists of three parts. Part A provides a description of the park and explains the management planning framework. Part B sets out some general provisions and importantly assigns the park to an Australian IUCN management category. Lastly Part C sets out how the park will be managed. The plan applies the requirements of the EPBC Act and associated regulations and provides greater flexibility in management arrangements than the previous iteration.

·           The plan provides for the conduct of park management and certain recreational and commercial activities that would otherwise be prohibited by the EPBC Act. It does not alter existing management arrangements so as to place any additional burden on individuals or businesses compared to the previous management plan.

·           The plan covers the on-going protection and management of the natural and cultural values of the park, particularly through the management of fire, the control of weeds and feral animals and responding to and mitigating the impacts of climate change.

·           An emphasis is placed on the importance of taking a regional approach in the management of the park, acknowledging that it is part of a much larger natural, cultural and social landscape. The park will work with neighbours and government partners towards effective management of regional ecosystems.

·           More generic language has been used in this plan. This allows for reasonable responses to maintain or enhance park values in the face of unforeseen circumstances and to provide an adaptive framework to deal with the uncertainties of climate change and its implications for the management of the park over the life of the plan.

A strategic and adaptive approach to management of natural and cultural values

·           A range of plans and strategies will be developed and/or reviewed during the life of the plan to improve the conservation and presentation of the natural and cultural values of the park. These include:

u   training strategy

u   fire management strategy

u   threatened species strategy

u   tourism master plan

u   walking strategy

u   crocodile management strategy

u   cultural heritage strategy

·           In addition to ongoing activities, there are a significant number of actions detailed in the plan. These include the review of the existing plans and strategies described above. To achieve best practice management of the park it will be important to develop an effective implementation plan for the next decade, capable of being responsive to new issues and adaptive as knowledge and practices improve.

·           Kakadu is a significant site for ecological research and monitoring for individuals and organisations, based in Australia and overseas. Parks Australia is a partner on a number of research projects aimed at improving our knowledge about the park’s natural and cultural values and the management of threats. The Parks Australia management effectiveness framework provides a way to improve the integration of the results of this research into decision making and to adapt our management activities.


 

A review of joint management arrangements

Parks Australia has commenced a review of joint management arrangements for Kakadu, Booderee and Uluru-Kata Tjuta National Parks. The review will strive to consider and better understand the aspirations of traditional owners, to improve opportunities for Indigenous participation and to increase benefits to traditional owners. The new management plan supports this approach and work will occur during the life of this plan to improve joint management arrangements. The plan also requires that a review of the current joint management arrangements will take place during the life of the plan with a view to improving engagement of traditional owners in the overall governance and work programs in the park.

Providing new opportunities for visitors

The Kakadu Tourism Master plan is currently under review and will help plan new experiences for visitors by improving existing roads and providing new walking tracks for visitors to the park. New activities and infrastructure not currently available in the park will also be investigated during the life of the plan to provide more and diverse opportunities and experiences for visitors. New experiences in the park will need to be culturally appropriate, environmentally sustainable and match the desires of the target market for Kakadu.

An improved approach to measuring and reporting our results

One of the key findings from the independent audit of the fifth Kakadu management plan was the need for clearer management objectives, outcomes and measurable performance indicators to allow for improved reporting and accountability. The management plan includes a much stronger focus on management effectiveness, adaptive management and has a clearer line of sight between the cultural and natural values of the park, the desired outcomes of management actions and performance indicators used to measure success. Under the management plan, a performance monitoring plan will be developed and will establish the measures and targets for performance indicators in the plan.

6.       Comments received on the draft management plan

The invitation for public comment on the draft plan attracted moderate interest from individuals (12) and from stakeholder organisations and government agencies (19).

A number of submissions suggested the overall International Union for the Conservation of Nature (IUCN) management category for Kakadu should be amended from Category II (national park) to Category IV (managed resource protected area) and that the stone country section of the park should be zoned as Category IB (wilderness area). The Australian IUCN Category assigned to the park dictates the management approach for the area and potentially restricts the range of activities that should be able to occur within the park. For this management plan the Board decided to retain the IUCN Category II designation for the park, and during the life of the new plan consider if changes may be necessary in light of future activity and development proposals.

There were a range of comments regarding joint management arrangements for the park. Some comments were in support of current joint management practices in the park, and some sought improvements in the way that park staff engage and undertake consultations with Bininj/Mungguy. Parks Australia has initiated a review of joint management arrangements within all jointly managed parks, with and aim to improve engagement and consultation processes with traditional owners and related stakeholders.

Submissions from residents of the Northern Territory raised a broad range of issues. Several submissions expressed disappointment and frustration with accessing various parts of the park for camping and fishing due to seasonal closures and safety concerns. Kakadu is subject to seasonal closures as a result of flooding during the wet season, with roads requiring rehabilitation following the wet season to allow safe access for visitors.


 

Over recent years the park has worked hard to reopen sites as early as possible and has considered early access for commercial operators that can supervise visitors to ensure their safety and wellbeing. The new plan aims to increase opportunities for visitors in the park for camping, bushwalking, cultural experiences and commercial tours.

A range of submissions raised the issue of managing saltwater crocodiles in the park, given that numbers have been increasing since they were first protected across the Northern Territory in 1971. Several submissions suggested culling of saltwater crocodiles may be warranted because of the significant risk to public safety. One submission expressed the view that crocodile egg harvesting should be permitted in the park for commercial purposes (This occurs in some areas of land surrounding the park). Other submissions suggested that temporary closures of areas where there are problem crocodiles is not an effective way to manage the risk to public safety. The crocodile management strategy for the park will address these issues. The harvesting of crocodile eggs within the park will require further investigation and discussion outside the scope of the preparation of the plan.

Submissions from bushwalkers and bushwalking organisations expressed frustration with the process for obtaining bushwalking permits in Kakadu National Park, and the lack of publicly available information about approved bushwalking routes. The development of a walking strategy will take into account these issues and strive to offer a greater range of walking opportunities in the park, with various grades and lengths to suit all walkers.

Several submissions from Northern Territory residents raised concerns about threatening processes for the park including the impact of fire, weeds, feral animals and climate change. The majority of these submissions expressed concern at the increasing encroachment of significant weeds and the number of feral animals in the park, some suggesting regular culls of buffalo and pigs to improve public safety (an activity that does already occur). The park has a range of robust strategies to manage the issues raised, and the approach to the management of these threats will be reviewed as needed during the life of this plan.

A number of comments related to the extent and frequency of fire in the park and suggested a different approach to fire management is needed, including transparency about fire planning. The management of fire across the Parks Australia protected area estate is being reviewed and the approach to fire management in the park is constantly being reassessed to protect and enhance biodiversity, to improve the “patchiness” of the fire landscape and to consider opportunities to reduce the risk of wildfires. A leading Aboriginal Corporation in the park suggested the outsourcing of fire management to Bininj/Mungguy in the park. Such an arrangement can occur under the plan and discussions have already commenced to consider this arrangement, as well as the possible outsourcing of other management activities to Indigenous businesses, potentially increasing Indigenous employment and Indigenous management responsibility.

Through their comments on the plan, the recreational fishing industry sought greater access to areas for recreational fishing, including access to areas that have been closed to fishing to prevent the further spread of salvinia weed and to conserve fish populations. A review of recreational fishing in the park will be conducted early in the life of the plan. This will occur in consultation with stakeholders and will assess the areas both available and closed to the public, the risks of spreading salvinia through the wetlands of the park and the risks associated with saltwater crocodiles, with a view to improving opportunities for recreational fishers in the park.

Some submissions suggested that in the face of declining funding there may be opportunities to obtain assistance from the broader community through the use of volunteers in the park and through partnerships. Strong partnerships arrangements already exist (such as our partnership arrangements with Charles Darwin University) and volunteers frequently assist with projects in the park. Parks Australia is keen to continue pursuing and utilising new partnerships and volunteer arrangements where appropriate, while ensuring that staff and volunteers have safe working arrangements in the park.


 

The majority of comments on the draft management plan could be catered for under the document. A broad range of useful suggestions were received, which improved the effectiveness of the plan and helped respond to the issues described above. In light of this, the Board made a number of amendments when finalising the plan to improve its capacity to adapt to change, without committing to any significant additional management or stakeholder burden.

An analysis of public comments that resulted in changes to the plan appears at Appendix A.

An analysis of public comments that did not result in changes to the plan appears at Appendix B.

7.       Summary

The Board of Management of Kakadu National Park has worked tirelessly to prepare the draft management plan, to carefully consider all the public comments received, and to finalise the sixth management plan in the light of those submissions. I thank the Board and park planning staff for their patience, their attention to detail and commitment over an extended period in the preparation of this most important document. I would like to thank everyone who contributed ideas and comments throughout the process. Your engagement, participation and interest helps us manage this World Heritage Area, and is greatly appreciated.

The sixth Kakadu National Park Management Plan supports best practice management and will provide essential conservation guidance over the next decade for the management of one of the most popular educational and rewarding visitor experiences in the Northern Territory and Top End region.

 

 

 

Sally Barnes
Director of National Parks

November 2015


Appendix A – Public comments that resulted in changes to the management plan

Plan reference

Comments in the submission

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 1.1 A description of Kakadu National Park

1. 1.3 Establishment of the park

The descriptions of the unresolved land claim in the text are difficult to correlate to the names used in the keys to the map on figure 3. E.g. the Goodparla area is mentioned in the text, but not on the maps, and the Ngombur claim on the map but not in the text. It is difficult to work out which areas are which. It would be helpful if all names used in the text could be found on the map, and likewise all if all the names from the text were on the map especially where there may be some changes e.g. resolution of land claims. This is important given that many of these names are not found on other commonly available maps. Another example is where Koongara area is mentioned in Table 1 but not shown on any maps.

Amended Figure 3 to identify the fourth land claim area in the park. 

Section 5.1 Looking after culture

Bininj/Mungguy Cultural knowledge and practices; subheading Bininj/Mungguy access to country (low significance): states “Bininj/Mungguy access to or use of country is sometimes affected by tourism in visitor areas of the park, and this is managed through temporary closure of areas with timely advice to the tourism industry.”

The emphasis again is on the tourism industry as opposed to non-commercial visitation. This advice is also important for the public.

Amended Background text in Section 5.1 to acknowledge that timely advice on temporary closures will be provided to the tourism industry and the public. Policy 10.2.4 has also been amended to acknowledge the public as a key stakeholder to be notified of temporary closures.

Section 6.0 Kakadu as a visitor experience destination, commercial tourism and promotion

Section 6 needs a section dedicated to independent travellers. This could acknowledge their distinctive characteristics compared to those of commercial tourists/operators/local residents

Amended Background text to Section 6.1 to identify the range of traveller types to the park as suggested. The Tourism Master Plan (Action 6.1.6) will consider the specific needs of the range of traveller types to the park, including independent travellers.


 

Plan reference

Comments in the submission

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

The explicit articulation of issues pertaining to this group will provide very useful focus and clarity for the plans subordinate to this plan. It will also lead to a clearer assessment of this group [independent visitors], the issues close to them, and the management mechanisms that will address these.

The lack of explicit treatment and absence of structured consultation with the public during the development of the plan, leads to a lack of focus and emphasis in the plan on this crucial stakeholder group.

Amended Background text to Section 6.1 to identify the range of traveller types to the park as suggested. The Tourism Master Plan (Action 6.1.6) will consider the specific needs of the range of traveller types to the park, including independent travellers.

Appendix E provides a summary of the timeframes and consultation process used in developing this plan and this identifies the opportunities for input from the public on the plan during the Have your say process and the public comment period for release of the draft management plan.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

This section lacks delineation between the interests of commercial tourism and recreational visitors. These two groups have a number of things in common and distinctly different interests in others. By not distinguishing between the two, the needs and goals of the two groups are not acknowledged and a lack of clarity occurs. It also does not allow the plan to provide any guidance for the future specifically in relation to each of these groups.

Amended Background text to Section 6.1 to identify the range of traveller types to the park as suggested. The Tourism Master Plan (Action 6.1.6) will consider the specific needs of the range of traveller types to the park, including independent travellers. It is not necessary to describe each type of visitor to the park unless there are restrictions or special provisions in the EPBC legislation that need to be addressed.

Section 6.1 Destination and visitor experience development

In regard to increased visitation to the park, there appears to be much focus on increasing organised commercial tourism. It should be recognised that the majority, that is two thirds of the visitors to the park are independent tourists.

Little consideration appears to be given to enhancing the enjoyment of their experience in visiting the park.

With any increased commercialisation of park visitation, we believe it must be a priority that this is not at the expense of independent public access and enjoyment of the park.

Amended Background text to Section 6.1 to identify the range of traveller types to the park as suggested. The Tourism Master Plan (Action 6.1.6) will consider in more detail the specific needs of the range of traveller types to the park, including independent travellers.

Current precinct planning processes (Action 6.1.7) are helping to identify opportunities for enhanced visitor experiences and guide this process. This may include a 4WD track in the south of the park and new opportunities for overnight bushwalks.


 

Plan reference

Comments in the submission

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.1 Destination and visitor experience development

By not acknowledging the two groups [independent and commercial visitors], this again leads to a lack of explicit focus on the public. This is evident in the shared vision statement which contains elements focused on the Binji, commercial tourism and preservation of the environment, but nothing in relation to the public and non-commercial tourism e.g. the ‘shared vision refers to commercial tourism and development three times, but contains no elements relating explicitly to non-commercial recreational visitors.

The shared vision principles which were included in the draft management plan, and were drawn from the Shared Vision for Tourism in Kakadu National Park (Morse et al. 2005), have been removed from the management plan to enable review during the life of the plan.

Section 6.1 Destination and visitor experience development

The small challenges overcome by the use of a four wheel drive vehicle to access remote sites within the park greatly enhances visitor experiences and yet there is no mention of 4WD recreational touring within the park. This is in contrast to a section on “Recreational boating and fishing”. (Section 10.7).

Amended Background to Section 6.1 to include additional text to describe 4WD touring as an existing popular experience. This matter is also covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will further consider the opportunities and experiences of 4WD touring.

Section 6.1 Destination and visitor experience development

There is also no consideration of the enormous growth area of four wheel drive holidays in recent years and to further develop opportunities here. This is an activity which is hugely popular amongst Australians and other visitors alike, yet despite this, there is a desire to improve access to enable other visitors to access areas without the need for 4WD vehicles. Without specific consideration, guidance and perspective about this in the plan, there is a great danger that important experiences will be eroded in the future.

Amended Background to Section 6.1 to include additional text to describe 4WD touring as an existing popular experience. This matter is also covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will further consider the opportunities and experiences of 4WD touring.

Section 9.07 Neighbours, stakeholders and partnerships

4WDNT is open to exploring with Parks Australia, any way in which we can work together in any planning of new tracks and the opening of the many tracks that have been closed since the park was declared. We would also welcome the opportunity to discuss any ways we can assist, such as in the busy period of seasonal opening.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.


 

Plan reference

Comments in the submission

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 10.4 Access

10.4 Road access: Further to our comments in relation to values, road and track development need to be undertaken in accordance with a road/track plan. This plan needs to address the tension that exists between the upgrading roads to improve access, and the value of the journey to destinations along (4WD) roads/tracks. Without a clear strategy to guide road development, it will be difficult to ensure this development supports and enhances the essence that needs to be preserved to maintain the essential character and attraction of Kakadu, and the value of the journey within the park which is a key part of the attraction of the park. To facilitate this, road/track classes could be established as part of the road/track plan, to articulate the target experience for each route.

 Amended Background text in Section 6.1 to include reference to 4WD touring as a popular activity. Policy 10.4.5 also amended to include reference to the park road management strategy which is in development and will assist in the strategic management of roads.

Section 10.4 Access

We understand the need to maintain roads and tracks to support a level of access for a wide variety of visitors and tour operators. We also understand that where the recent upgrades to the Jim Jim track occurred, challenges have existed with seasonal degradation of the track, managing the level of maintenance required, increasing the time the tracks are accessible each season and providing a track attractive and suitable for a wide range of users. We also understand that the recent improvements are expected to bed in over the coming season. However we do find the newly treated tracks unpleasantly rough to drive on and not reminiscent of a developed and formed road. We encourage continued exploration of methods of providing balance between demands for improved access and the experience of the journey – and it would be great to see outcomes that don’t make them seem too much like developed roads when they are in a track environment like Jim Jim falls.

 Amended Background text in Section 6.1 to include reference to 4WD touring as a popular activity. Policy 10.4.5 also amended to include reference to the park road management strategy which is in development and will assist in the strategic management of roads.


 

Plan reference

Comments in the submission

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 10.7 Recreational activities

10.7.7 Restricts a range of activities including gliders, ultralight aircraft, hot air balloons and other recreational light aircraft, airboats, amphibious vehicles and hovercraft, non-

motorized vessels to only being able to be conducted by commercial operators. Whilst we understand that controls need to be in place for these activities, it is not reasonable to restrict these to only commercial operators. Where non-commercial parties can demonstrate competence and acceptable controls and standards they should also be permitted. This reinforces the impression that Kakadu is not for the public. Even if non-commercial parties rarely undertake these activities, the principle of prohibiting them without discretion of park management is not appropriate.

Amended Section 10.7.7 to allow these activities to be authorised for commercial and non-commercial purposes. The Board was of the view that the assessment of the activity should consider risks and that whether the action was for commercial or non-commercial purposes did not matter.

Section 10.7 Recreational activities

Figure 16: This map is confusing. West Alligator Head is listed as a bush campground but it has toilets and showers. Koolpin and Graveside Gorge (and other sites) are not listed. If this is because permits are required then that is not clear. The difference between unmanaged and bush camp grounds is also not clear.

Amended Figure 16 as suggested.

General comment

5.1 Refers to rock art at Nanguluwurr. This is not shown on a relevant map so there is no way of understanding where this is.

Amended Section 5.1 to include a description of the location of Nangulururr. The proximity of Nangulururr to Nourlangie meant that it was not possible to mark it on the map in the management plan.


 

Plan reference

Comments in the submission

Response

Aboriginal Areas Protection Authority

Section 4.1 Making decisions and working together (Board of Management)

Table 3: Guide to decision-making (page 34) should refer to the NTASSA and ensure that Authority Certificates are sought and obtained especially for any non-routine actions proposed either by the Park or any external entity. This would ensure compliance with NTASSA and minimise risk of damage to any sacred sites.

Table 5 amended to include requirement to obtain an Authority Certificate from the Aboriginal Areas Protection Authority where there is potential to have an impact upon a sacred site.

Section 4.2 Making decisions and working together (on country)

4.2.10 should include AAPA with NLC in the review of cultural protocol documents, especially the Sickness Country protocols.

Amended plan as suggested.

Section 4.2 Making decisions and working together (on country)

4.2.7 AAPA suggests that this Action is replicated with a similar wording but to 'facilitate and assist AAPA to carry out its statutory functions in the park, commensurate with park resourcing'.

Amended Action 5.1.4 to recognise the role of the Aboriginal Areas Protection Authority.

Section 5.1 Looking after culture

5.1 of the Draft Plan notes that management of Kakadu's cultural values is guided by the An-garregen Strategy from 2011. AAPA remains disappointed that it was not included in the workshops, preparation and writing of the An-garregen Strategy. Given our statutory roles and functions, the AAPA considers the An-garregen Strategy to be inadequately informed regarding the management and protection of sacred sites in Kakadu and we would seek to be involved in any review or update of that strategy (Action 5.1.5).

Amended Actions 5.1.13 and 5.1.14 to acknowledge the need to work more closely with the Aboriginal Areas Protection Authority in park planning processes and to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them. The An-garregen strategy will be reviewed and updated during the life of the plan.

Section 5.1 Looking after culture

Given the stated principles for joint management in Kakadu, specifically that ...cultural and traditional knowledge, customs values and priorities will be respected and will inform management priorities and programmes (p29), the AAPA has some concerns that the processes of the Sacred Sites Act are not being incorporated sufficiently into the overall management and planning systems within Kakadu. We are particularly concerned that a number of incidents have occurred at sacred sites within the park under the current plan.

Action 5.1.14 amended to read: Work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.


 

Plan reference

Comments in the submission

Response

Aboriginal Areas Protection Authority

Section 5.1 Looking after culture

(c) AAPA should be fully engaged for the provision of specialised and expert advice in relation to the management of sacred sites in Kakadu through a variety of processes including the issuing of Authority Certificates where appropriate, input into management strategies/ plans and protocols (including visitor guidelines, bushwalking strategies, precinct plans, signage etc.); and

Action 5.1.14 amended to read: Work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.

Section 5.1 Looking after culture

(d) There should be further development of cooperative approaches to compliance and enforcement strategies utilising both the EPBC Act and the NTASSA.

Action 5.1.14 amended to indicate we will work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.

Section 5.1 Looking after culture

As set out in the draft management plan, the first guiding principle for the management of Kakadu states that: culture, country, sacred places and customary law are one, extend beyond the boundaries of Kakadu, and need to be protected and respected (page iii). Despite this principle/ members of Kakadu's Bininj/Mungguy joint management partners have expressed serious reservations to the Authority about the management of sacred sites within the park, and their capacity to raise these concerns directly with the Park authorities.

Action 5.1.14 amended to indicate we will work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.

Section 5.1 Looking after culture

(a) AAPA should be fully engaged to ensure that its independent and legislatively established register of sacred sites is utilised appropriately by Parks and enhanced through the ongoing sacred site registration work noted at 5.1.13. AAPA is happy to discuss the provision of relevant information on the sacred sites that exist within the park to assist in management and to identify any gaps in knowledge that there may exist;

Action 5.1.14 amended to indicate we will work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.

Section 5.1 Looking after culture

AAPA has longstanding good relations and links with custodians in the Park. Our view is that AAPA offers independent expertise regarding the identification and management of sacred sites in the Park and, if suitably engaged/ can also make a critical contribution to the joint management process and a broad range of the Draft Plan's stated objectives, policies and actions.

Action 5.1.14 amended to indicate we will work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.


 

Plan reference

Comments in the submission

Response

Aboriginal Areas Protection Authority

Section 5.1 Looking after culture

AAPA believes that there is potential for greater collaboration with Park management and Bininj/Mungguy custodians to achieve better outcomes in regard to the protection of Sacred Sites.

Action 5.1.14 amended to indicate we will work closely with the Aboriginal Areas Protection Authority in park planning processes to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.

Section 7.1 Research and knowledge management

We also consider that AAPA can make useful contributions to Actions 7.1.9, 7.1.10 and 7.1.11 given our statutory functions, specialised and expert knowledge and cultural data management systems.

Amended Section 7.1.10 of the plan to clarify that Kakadu National Park staff will work in consultation with the Aboriginal Areas Protection Authority and traditional owners, to develop Indigenous research protocols and review them as needed.

Section 9.05 Assessment of proposals

Table 5: Impact assessment process (page 137) should include a requirement for proponents of any category 2 or 3 actions to obtain an Authority Certificate from AAPA.

Table 5 amended to include a requirement to obtain an Authority Certificate from the Aboriginal Areas Protection Authority where there is potential to have an impact on a sacred site.

Amateur Fishermen's Association of the Northern Territory (AFANT)

Section 5.3 Managing park wide threats

While we do not support these closures we would be happy to participate or be involved in any research projects even though we believe that the management arrangements in place will show limited impact on the waterways of Kakadu from recreational fishing.

Amended Action 5.3.42 to acknowledge working with relevant stakeholders to monitor the impacts of recreational fishing.

The Director recognises that AFANT is the primary association representing recreational fishers in the park and will consult with AFANT when reviewing fishing and boating in the park.

Section 9.07 Neighbours, stakeholders and partnerships

We acknowledge that salvinia management is still an issue in the park and AFANT is willing to work with Kakadu the park and traditional owners on any programs across all waterways to improve the removal of salvinia or through educating rec fishers about protecting our waterways particularly from the spread of salvinia or other introduced plants.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 10.7 Recreational activities

AFANT would like the plan to recognise the use of landing nets as a legitimate fishing gear in the park as the plan is unclear on landing nets

Amended Section 10.7 to explain when landing nets are permitted under 12.35(4).


 

Plan reference

Comments in the submission

Response

Charles Darwin University – Partner in providing tour guide training

Section 6.2 Commercial tourism development and management

“The park lease agreements between the Director and traditional owners require the Director to implement an induction scheme for tour operators and their guides. In 2005, the Board introduced compulsory entry-level Knowledge for Tour Guides training that can be delivered flexibly – e.g. through e-learning. The training is based on core competencies related to the interpretation of cultural and natural values, minimising visitor impact, understanding permit and licence conditions and cross-cultural awareness. Over 800 guides completed the training in 2013 alone.

Reading “Over 800 guides have completed the training since its inception” …would be a far more accurate representation of 829 guides in total that completed by the start of 2013 and 896 that had completed in total up until the end 2013.

Section 6.2 Background Information amended as suggested to clarify that over 800 guides have completed the training since inception of the program.

Darwin Bushwalking Club

Section 6.1 Destination and visitor experience development

“As safe as reasonably possible” is an extremely high standard – “as safe as reasonably practical” is more usual and realistic.

Policy 6.1.2 amended as suggested to - visitor experiences in the park will be “as safe as reasonably practical”.

Section 9.07 Neighbours, stakeholders and partnerships

Recently, the Club donated its skills, experience, time and resources to examine a proposed new walking route in the Limmen National Park, and provided a written report to the Park managers. The Club could potentially provide similar support to Kakadu managers.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 1.1 A description of Kakadu National Park

Section 1.3: At the end of the first paragraph should be added the statement: ‘This was the first claim heard under the NT Land Rights Act.’

Plan amended as suggested.

Section 2.1 Management plan process

Section 2.1: p.19:

List of stakeholders: what about 23 million Australians? They don’t have an advocate here.

Amended Section 2.1 to include details of the public consultation process to confirm that the public were invited to provide comments towards the development of the plan and were also given an opportunity to provide comments on the draft plan - which were then considered when finalising the plan.

Section 5.1 Looking after culture

Section 5.1: p45:

‘Fire’: ‘a build-up of weeds or other vegetation close to sites’: delete ‘weeds or other’. The vegetation in those sites is native vegetation growing where it is not wanted.

The one exception regarding weeds is the para grass around the base of ground-level rock art sites at Cannon Hill.

Amended Section 5.1 to note that a build up of any vegetation close to rock art sites poses a significant threat.

Section 5.1 Looking after culture

Section 5.1: p45:

‘Insect damage (moderately significant)’: It is highly significant, far more significant than feral animals at the present time. Under current policies, unless feral animal eradication by helicopter shooting in remote areas is strongly reinstated as a matter of general policy, that problem will re-emerge.

Amended Section 5.1 so the threat of insect damage is recognised as being 'highly significant' as suggested.

Section 5.1 Looking after culture

Section 5.1: p45:

'Weathering (moderately significant)’: This is highly significant, in view of the recentness of X-ray art and the fact that the ochres have a very short life under weathering. The water does not have a dissolving action, it is direct erosion. It takes the pigment straight off. Weathering is thus of high significance in relation to X-ray art. Water seepage through the middle of, for example, a barramundi figure or human figure can be deflected by a drip line, and these should be applied at any site where such paintings are a priority, of which there are many.

Amended Section 5.1 so the threat of weathering is recognised as being 'highly significant' as suggested.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.1 Looking after culture

Section 5.1: p.51:

‘. . . uranium and other harmful metals’: That is a strange statement. What other harmful metals?

Amend Background text to Section 5.1 to improve specificity with regards to other harmful metals.

Section 5.1 Looking after culture

Section 5.1: p.52:

‘include some of the oldest Aboriginal occupation sites in Australia’: insert the word ‘known’ into this statement.

Amended plan as suggested.

Section 5.1 Looking after culture

Section 5.1: p.52:

Add a further item under ‘Existing threats to values’: ‘Loss of traditional occupancy’.

Amended text on existing threats to acknowledge that in some parts of the park there are limited opportunities to live on country and this contributes to loss of traditional knowledge.

Section 5.1 Looking after culture

Section 5.1: p.54:

Third paragraph, on uranium mining: Last line: No mention of royalties. The last sentence in this paragraph also fails to recognise the importance of uranium for the establishment of the Park itself. Mining at Ranger was the catalyst for declaration of Kakadu under Commonwealth administration. The Ranger proposal led to the Fox Inquiry which led to the declaration of a Park that included four resumed pastoral leases as well as the land north of Mudginberri and Munmalary and west of the South Alligator.

Amended the background section on Historic Sites to acknowledge the Ranger proposal and Fox Inquiry as suggested. Bibliography also updated to acknowledge the source.

Section 5.1 Looking after culture

Section 5.1: p.54:

First paragraph: It is not known if there was sustained contact between Alligator Rivers people and Macassans. This should instead say ‘The first documented knowledge that Aboriginal people from the Alligator Rivers Region had of non-Aboriginal people was of Macassan seafarers, when information of their activities was transmitted from the north coast.’

Van Diemen Gulf does not have an eastern opening.

Fort Wellington was established on Cobourg Peninsula in 1827.

The background text for the Historic Sites section of the plan has been amended to provide the correct information.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.1 Looking after culture

Section 5.1: p.54:

Second paragraph: The small-scale activities referred to did not begin in the Kakadu area until the 1890s, or in the case of some of those listed, well into the 20th century. The listing should also refer to mining and prospecting, possibly the most compelling inducement for outsider visitation.

Amended the background section on Historic Sites to acknowledge mining and prospecting as suggested.

Section 5.1 Looking after culture

Section 5.1: p44:

‘Performance Indicators’: should be redrafted to say ‘Impact of fire, flammable or abrasive plant material, insects and animals’. Insects are a major problem. In the past twelve months, people have sat and watched without doing a thing while the head on one of the figures at Nourlangie Rock was completely obliterated by a white ant tunnel. Yet it was easily preventable. Four dollar cans of Permethrin to treat the tunnels are all that is needed.

Amended rock art outcome to recognise that priority rock art sites will be managed to mitigate impacts from threatening processes. Amended the rock art performance indicator to recognise that management will aim to reduce the overall impact that weathering, fire, plants, animals, insects and human activities have on priority rock art sites.

Section 5.1 Looking after culture

Section 5.1: p.54:

Outcomes: Replace with: ‘Priority historical sites are protected from weathering and natural impacts, fire, ferals and human impacts’. Weathering and natural impacts include tree falls, windblown impacts, termites, burrowing and corrosion. These are inevitable impacts unless specific protection measures are maintained, as also applies to rock art.

In response to this comment and in alignment with the Outcome and Indicator for rock art sites, the Outcome for historic sites has been amended to read: Outcome - Priority historic sites are protected from the potential impacts of threats including weathering, fire, plants, animals, insects and human activities.

Section 5.1 Looking after culture

Section 5.1: p.54:

Performance indicators: Replace with: ‘Impact of weathering and natural impacts, fire, feral plants and animals, and human impacts on priority historic sites’.

In response to this comment and in alignment with the Outcome and Indicator for rock art sites, the Performance indicator for historic sites has been updated to read: Performance indicator - A reduction in the overall impact of weathering, fire, plants, animals, insects and human activities on priority rock art sites.

Section 5.1 Looking after culture

Section 5.1: p.54:

Fourth paragraph, first line: ‘people’, not ‘communities’.

Amended the background section on Historic Sites as suggested.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.2 Looking after country

Section 5.2: p.67 Floodplains:

‘a population of the pig-nosed turtle originally thought to be extinct in the area’: replace with ‘a population of the pig-nosed turtle only recently discovered to inhabit the area’. 

Amended Section 5.2 re pig-nosed turtle as suggested.

Section 5.2 Looking after country

Section 5.2: p.60 Stone Country:

Paragraph 3:

Replace ‘development’ with ‘evolution’.

Amended Background text to Section 5.2 Stone Country to clarify that the high rate of endemism is more due to the fact that these species have been protected through isolation from threats compared to their more exposed counterparts.

Section 5.2 Looking after country

Section 5.2: p.60 Stone Country:

Last paragraph, second last line: Replace ‘in the escarpment’ with ‘on the plateau’.

Amended to clarify that Bininj/Mungguy have a long history of camping in the stone country and not in the escarpment.

Section 5.2 Looking after country

Section 5.2: p.60 Stone Country:

The 32 threatened species should be broken down into plants and animals.

Amended Stone Country values as suggested to identify the number of threatened plant and animal species.

Section 5.2 Looking after country

Section 5.2: p.60 Stone Country:

Replace ‘has functioned as a refuge area for plants and animals from fire and changes in climate for millions of years’ with ‘has provided habitat secure from fire and changes in climate for plants and animals for millions of years’.

Amended Background text for Section 5.2 Stone Country as suggested.

Section 5.2 Looking after country

Section 5.2: p.64 Stone Country:

‘Feral cat (highly significant)’: The feral cat is insignificant. The damage the cat is thought to do is a fantasy. See comment on p.84.

‘native species’ should be ‘native animal species’.

Amended text as suggested.

Section 5.2 Looking after country

Section 5.2: p.66 Floodplains:

First line: there are large areas of salt flats too.

Amended the background text for Section 5.2 Floodplains to include salt flats as suggested.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.2 Looking after country

Section 5.2: p.67 Floodplains:

Existing threats to values’: Native plants are growing widely in areas where they did not grow in pre-contact times. Extensive areas that were once identifiable as open Aboriginal occupation sites are now completely obscured by native vegetation that is not being managed.

Amended the background text for Section 5.2 Floodplains with regard to the threat "fire" to provide clarification as suggested.

Section 5.2 Looking after country

Section 5.2: p.68 Floodplains:

The absence of traditional burning has caused environmental detriment in the form of increased shrub and tree coverage.

Amended the background text of Section 5.2 Floodplains with regard to the threat "fire" to acknowledge that the absence of traditional burning has caused environmental detriment in the form of increased shrub and tree coverage.

Section 5.2 Looking after country

Section 5.2: p.68 Floodplains:

‘The spread of weeds such as mimosa and olive hymenachne by pigs through foraging activities is of major concern’: Buffalo are far worse than pigs in this respect.

Amended the background text of Section 5.2 Floodplains with regard to the feral animal threat to acknowledge buffalo as suggested.

Section 5.2 Looking after country

Section 5.2: p.70 Lowlands:

Second paragraph, first line: Change to ‘Woodlands typically grow on sandy or lateritic soils, often shallow and gravelly’.

Amended the background text for Section 5.2 The Lowlands to identify the soil type as suggested.

Section 5.2 Looking after country

Section 5.2: p.70 Lowlands:

Add the following: ‘Where the woodlands form a riparian fringe to adjoining wetlands a special habitat dominated by Ironwood and Snappy Gums was especially used for wet season camping by Aboriginal people and for buffalo camps in hide shooting days.

Similarly the lowlands adjoining the stone country escarpment are often heavily accessed by stone country bird and mammal species e.g. Chestnut-quilled rock pigeon Petrophassa rufipennis, and macropods for feeding forays. 

Amended the background text for Section 5.2 The Lowlands to include additional information on Aboriginal use as suggested.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.2 Looking after country

Section 5.2: p.70 Lowlands:

Last sentence, re dry season being more stressful: This use of the term ‘stressful’ is, like the term ‘refuge’, emotional, and it is also a misconception. Ironwood, which is often a co-dominant species, shows vigorous leaf growth and sap flow from September on. Other species only flower after prolonged dry periods.

Amended the background text for Section 5.2 The Lowlands to clarify plant response to the dry season as suggested.

Section 5.2 Looking after country

Section 5.2: p.71 Lowlands:

Fire: ‘The numerous unplanned and unauthorised fires that are lit along major roads and in the park each year by people travelling through and using the park is a major issue’: These fires would have to be lit either by Aboriginal people or Park staff or myself. Other non-Aboriginal people don’t do this, and it is not a major issue. They are not the source of big fires. Indeed the best burning regime in Kakadu would have to be the roadside fire areas. Burning is continuous and contributes to isolated unburnt areas persisting. See comment on p.89.

Amended the Background text of Section 5.2 The lowlands to clarify that some unplanned fires may be lit by Bininj.

Section 5.2 Looking after country

Section 5.2: p.72 Lowlands:

‘management of pigs, horses, donkeys and buffalo in areas of high density’: In all areas where they occur. Observations on damaging impacts to Aboriginal occupation sites on floodplains by buffalo indicates that even two are too many.

Amended Section 5.2.12 (b) to emphasise that feral animal management will occur in areas of high density, but not exclusively in these areas.

Section 5.2 Looking after country

Section 5.2: p.73 Rainforest:

Second paragraph: ‘Anbinik forms shady canopies and provides an important refuge for other plants and animals’: It is usually sterile underneath, as is often the case with trees. The ground is littered with their leaves and nothing grows.

Amended the background text of Section 5.2 Rainforest to clarify the significance of Anbinik as a cool refuge for a range of animals.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.2 Looking after country

Section 5.2: p.74 Rainforest:

Weeds: ‘Weeds are not currently having a significant impact on rainforest environments in the park’: This ignores the epidemic infestations of Hyptis suaveolens from the 1970s to the 1990s, which are now set to return with the cessation of buffalo control.

Now, although there is a low density of buffalo on the woodlands, their concentrated usage of small canopy zones of rainforest is having a heavy-density impact around the South Alligator, and the previous experience with Hyptis is returning.

Amended the background text of Section 5.2 Rainforest to include the issue of Hyptis as suggested.

Section 5.2 Looking after country

Section 5.2: p.75 Riparian fringe:

Riparian fringe should be recognised in the Plan as a separate habitat, or else comment should be made either in the Lowlands or Floodplains sections about riparian vegetation. It is not mentioned in this Plan. It is the vegetation found along stream beds and in the inter-zone connecting the lowland savannah with the wetland. It has an association with rainforest, it is characterised by white gum and ironwood, and it is an important Aboriginal area. The greatest concentration of Aboriginal sites are located in this fringe zone, and some of them are ancient, pre-dating the estuarine period. Torres Strait Pigeons nest in the riparian vegetation around Goose Camp.

It is relevant to weeds and to buffalo. It is a sub-category within the larger categories of wetlands and lowlands, but some of the factors that are assessed in this Plan in terms of their overall significance for wetlands or lowlands have a specific intensity for the riparian sub-category. It is a sub-category that also has a specific significance for activities still maintained by a few Aboriginal people. 

Amended background text in Section 5.2 Floodplains to include additional information about riparian areas and the vegetation found along them.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.3 Managing park-wide threats affecting values

Section 5.3: p.80:

Weed risk assessment: Para grass is not of very high risk for rainforest. It is more of a problem for sandstone outliers, where the floodplain abuts directly against the sandstone. Fire in para grass in those locations can destroy rock art painted at ground level, particularly secure older art that is otherwise protected by a natural silicon glaze.

Feasibility of control: There is no feasibility of control of any of these weeds other than mimosa. Para grass, olive hymenachne and gamba grass cannot be controlled because they integrate visually with other grasses. You can’t see them. There is no point in attempting control except to reduce the fire fuel load at specific priority locations, such as to protect ancient rock art and around Leichhardt and Banyan trees. Apart from those cases, partial weed control leaves bare areas that are then reinvaded by the same weed. We have huge fluctuations of salvinia infestations because of the way the seasons accommodate salvinia. In a bad year for salvinia, the weevil can have an impact, but if the season is favourable for salvinia, the weevil is irrelevant. Also see comment on p.69 (5.2.3).

Hyptis suaveolens is totally overlooked; it is significant in rainforest. See comment on p.74.

Kakadu landscape: There is an inconsistency in categorisation in that the landscape for salvinia is said to be ‘Floodplains and wetlands’, while for para grass, olive hymenachne and mimosa the term ‘Floodplains’ is taken to include wetlands.

Amended Section 5.2 Rainforest to include reference to Hyptis.

Table 4 prioritising management of weeds in the park has been removed. Prioritisation of weed management will occur in the weed management strategy. Action 5.1.1 includes measures to reduce the fuel loads of weeds around rock art sites.

Section 5.3 Managing park-wide threats affecting values

Section 5.1: p.50:

Example 3: boats and vehicles taken off-road without restriction pose the hazard of transferring exotic weeds to new locations. This is an issue that was dealt with in the early years of the Park with regard to Aboriginal vehicles entering the Park from mimosa-infested regions outside the Park, and visiting off-road hunting areas while inside the Park.

Amended Action 5.3.5 to include communication of information on the transfer of weeds on vehicles, trailers and vessels


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 5.3 Managing park-wide threats affecting values

Section 5.3: p.84 Feral animals:

Buffalo and cattle: BTEC ‘removed most buffalo from the park and enabled disturbed areas to recover’: The recovery of disturbed areas was only limited, because Parks haven’t done the work to reintroduce those plant species that were made locally extinct. And now, if such species were re-introduced onto the floodplain they would probably be uprooted by pigs. And the recovery that occurred in disturbed areas was not natural, because those kinds of vegetation that did recover now exceed in extent the tolerance that Aboriginal people would have had for them in traditional times. It is a complex situation, and this Plan does not show an appreciation of the complexity. 

Background text in Section 5.3 Feral animals has been amended to clarify that the removal of buffalo from the park during BTEC enabled some disturbed areas to recover. It would not be possible identify the original vegetation of all areas in the park and undertake revegetation programmes for these areas as suggested by the respondent.

Section 5.3 Managing park-wide threats affecting values

Section 5.3: p.85 Feral animals:

Management issues, high priority species: ‘a very significant impact on threatened species and other biodiversity in the park’: Add: ‘Pigs and buffalo also impact on yams and Aboriginal heritage sites’.

Section 5.3 on Feral Animals has been amended to identify that pigs and buffalo have a significant impact on yams and cultural heritage sites as suggested.

Section 5.3 Managing park-wide threats affecting values

Section 5.3: p.89 Fire:

Unplanned large late-season fires: ‘enter the park from the western rim of the Arnhem Land Plateau’: the western rim is already in the Park. Needs re-writing.

Section 5.3 amended to read: These continue to be an issue in some areas of the park, in particular within the stone country where fires may originate from neighbouring areas or be ignited by lightning strikes.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Section 6: p.99:

Many of the references to Bininj/Mungguy here are repetitive and simply unreal. These principles could be condensed to one paragraph.

The shared vision principles which were included in the draft management plan, and were drawn from the Shared Vision for Tourism in Kakadu National Park (Morse et al. 2005), have been removed from the management plan to enable review during the life of the plan.

Section 6.1 Destination and visitor experience development

Section 6.1: p.103:

Viewing rock art: ‘are provided at these sites to limit visitor access and impacts’: Poorly written. Delete and replace with: ‘are provided to give the best possible controlled experience for visitors at these sites’. The positive side should be given first, and the minimisation of undesirable impacts is secondary.

Amended Background to Section 6.1 (Viewing Rock Art) to use more positive language as suggested.


 

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 6.1 Destination and visitor experience development

Section 6.1: p.103:

‘Visitors need to be more actively encouraged to become ambassadors for the park’: The quality of the Park experience should make that inevitable. There should be no need to lobby people.

Amended the management issue under Section 6.1 to use more positive language and illustrate that visitors will become ambassadors for the park if they have exceptional experiences in the park.

Section 6.3 Promotion and marketing

Section 6.3.1(f): p.109:

There should be some acknowledgement here or elsewhere in this section of the fact that use of the Park is highly circumscribed for about 3 months of the year because of the heat. There have been deaths. Heat exhaustion events are regular at the top of Jim Jim Falls.

Section 9.1 has been updated to include a new management issue on the weather extremes in Kakadu and a new action 9.1.11 on providing appropriate interpretive material to visitors that communicates the steps they need to take to stay safe in the park.

Section 7.0 Research and knowledge management

Section 7: p.113:

‘define what species and environments are present in the park’: Change ‘species’ to ‘plant and animal species’.

Amended the plan as suggested.

Section 7.0 Research and knowledge management

Section 7: p.113:

‘Knowledge derives from: targeted and highly specific scientific experimentation’: replace ‘experimentation’ with ‘investigation’.

Amended the plan as suggested.

Section 7.1 Research and knowledge management

Section 7.1: p.115:

‘Effective methods for storing, managing and retrieving park data and information are required but are costly’: Replace ‘required but are costly’ with ‘essential, notwithstanding cost’.

Amended Section 7.1 to remove reference to costs associated with data storage and management.

Section 9.07 Neighbours, stakeholders and partnerships

(3) Implement new and novel ideas to get many volunteers to frequently assist with weed and feral animal control. These problems are now too big for the park to manage in-house. There are many ways that people can be brought into the park to assist with this work, in a mutually agreeable way. All it takes is a bit of innovation and thinking ‘outside the box’. Of course there will be costs involved, but a cost benefit analysis should show that the park would get much more ‘bang for its buck’ in this way, rather than persisting with the old, in-house methodology.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Plan reference

Comments in the submission

Response

Park resident 1 - (with long term association and history of living in the park)

Section 9.07 Neighbours, stakeholders and partnerships

(2) The park needs to consider bringing in working volunteers to help with weed control. They could be rewarded for their services in a number of creative ways. Maybe a package deal where they split their activities between real work such as weed control and ‘fun’ work such as accompanying scientists on sandstone fauna surveys to exotic localities.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 10.13 Bringing plants, animals and other materials into the park

Section 10.13: p.184:

Provision should be made for the authorised use of horses.

Amended Policy 10.13.12 to provide greater flexibility within the plan with regards to the entry of horses in the future.

Section 10.13 Bringing plants, animals and other materials into the park

Section 6.1.17: p.105:

Add a further Action to this list: ‘6.1.20: Authorise and regulate recreational horse-riding by visitors and residents in Kakadu.’ It is ridiculous that this activity is restricted and yet Parks are not allowed by traditional owners to shoot brumbies. Organised recreational riding with guides out of Jabiru or Cannon Hill would be ideal.

Amended Policy 10.13.12 to provide greater flexibility within the plan with regards to the entry of horses in the future.

Section 10.03 Living in the park (outstations and Jabiru)

Section 10.3: p.158:

Jabiru: ‘r.12.19 – prohibits taking animals into Commonwealth reserves’: Review this regulation to allow for the introduction of recreational horse-riding. See comment on p.105.

Amended Section 10.13.12 to provide greater flexibility within the plan for possible horse riding ventures in the park in the future.

Appendices

Section 5.1: p.52:

‘Weeds:’ ‘Exotic plant species’ should be the expression used, not ‘weeds’.

Amended the glossary of terms to include a definition of "weed". Weed is an accepted term and is used extensively in Australian Government programmes. Exotic plant species can have several interpretations.

General comment

p.iii Guiding principles:

‘consultation with Bininj/Mungguy is conducted appropriately (the right way)’: the words in brackets are not necessary. Aborigines reading this will know what ‘appropriately’ means.

Amended the wording of the guiding principles as suggested.


 

Plan reference

Comments in the submission

Response

Environmental Systems Solutions

Section 5.1 Looking after culture

A major symposium on cultural heritage was held in the park in 2011 which brought together over 100 Bininj/Mungguy, researchers and other stakeholders to hear about the park’s cultural values and consider priorities for management in the future. A cultural heritage information management system (CHIMS) was also developed during the life of the fifth management plan, and cultural data and information is continuing to be uploaded into it.

Agree but this is downplaying the intended role of the system.

The CIMS is not just about storing data in an archive – it has been designed so that park staff can revisit sites, describe their condition, prescribe and schedule work. The idea is that this system will help parks staff schedule and prioritise future site recording and maintenance works.

Amended introduction of section 5.1 to recognise that the cultural heritage information management system can be used to schedule and prioritise future work as needed.

Section 7.1 Research and knowledge management

Effective methods for storing, managing and retrieving park data and information are required but are costly.

Disagree

I think this is inaccurate. We think this is very affordable if the correct approach is taken I think there is an assumption that anything related to technology is expensive – this is not the case. In reality, KNP has a variety of technical infrastructure already available that can be used to manage information efficiently and effectively. The park possesses GIS software, PC hardware, networking infrastructure, data collection hardware and software and a Cultural Information Management System (CIMS). What is missing is an overarching plan , methodologies, data model and some basic training that communicates the processes that are required by staff to collect , manage and utilise data effectively. KNP may need to engage an expert (internal or external) that can scope out the information management requirements of the park then devise a logical and inexpensive solution where the available infrastructure is fully utilised.

Amended Section 7.1 to remove reference to costs associated with data storage and management.


 

Plan reference

Comments in the submission

Response

Environmental Systems Solutions

Section 7.1 Research and knowledge management

The document states that the storing and retrieval of data is “costly“ however we believe that it will be more costly for KNP to not improve their information management practices. Current data collection and management methods (or lack of them) encourage significant work inefficiencies. Decision making can also be blinded by the fact that there is little readily available information that quickly communicates project progress, outcomes of work activities, risks, and the condition of cultural and environmental assets/values.

Amended Section 7.1 to remove reference to costs associated with data storage and management.

Humpty Doo resident 1 (long term park user and Ex Kakadu ranger)

Section 2.2 Management plan framework

Within the framework of the Threatened Species Strategy, there is an urgent need to learn more about the population status, distribution and biology of the numerous endemic (and near endemic) plants and animals of the stone country. These species should be clearly identified as Kakadu’s “significant species”. The draft plan frequently refers to the park’s “Significant species” even though the reader is not clearly told what they are. I would argue for instance, that - because of its relative abundance and distribution – the Flatback Turtle is not a significant species to Kakadu. Also for the reason of distribution, I would argue that the northern quoll is not a significant species in Kakadu.

Amended Table 2 and Action 5.2.2 to include endemic species as an example of significant species as suggested.

Section 3. General provisions and IUCN category

a zoning scheme could see high quality parts of the park retained as Cat II, including all of the stone country and perhaps the Ramsar listed wetlands.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.


 

Plan reference

Comments in the submission

Response

Humpty Doo resident 1 (long term park user and Ex Kakadu ranger)

Section 3. General provisions and IUCN category

There are too many activities happening within the park, which undermine this status.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

Section 3. General provisions and IUCN category

Reclassification would also help to harmonise the current disconnect between the public face of the Park and the reality of the Park. It would also open an avenue to market the park in a different way.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.


 

Plan reference

Comments in the submission

Response

Humpty Doo resident 1 (long term park user and Ex Kakadu ranger)

Section 3. General provisions and IUCN category

More importantly, such a reclassification could go a long way to repair the ailing relationship between Parks Australia (PA) and many of the Traditional Land Owners (TOs). In my experience, TOs often wish to do things that are incompatible within a Cat II national park.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

Section 3. General provisions and IUCN category

Kakadu is big enough to allow more exploitative or damaging activities (such as more outstations) without substantially harming the natural or cultural values of a Cat V1 Park.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

Section 5.3 Managing park-wide threats affecting values

(1) Reverse Para Grass and perennial Mission Grass in table 4 on page 80.

Table 4 prioritising management of weeds in the park has been removed. Prioritisation of weed management will occur in the weed management strategy.

Section 5.3 Managing park-wide threats affecting values

Define what action is proposed to deal with the issue of uncontrolled cats and dogs on outstations and Ranger Stations. De-sexing cats and dogs on outstations is a good start. But is it enough?

Additional text added to the background of Section 5.3 - Feral Animals to identify desexing programs that were undertaken in 2014 and the results of these programs.


 

Plan reference

Comments in the submission

Response

Humpty Doo resident 1 (long term park user and Ex Kakadu ranger)

Section 5.3 Managing park-wide threats affecting values

“Loss of cultural knowledge.” I think that this applies to all landforms in Kakadu, not just the floodplains. I would have thought that traditional knowledge of the floodplains is the most enduring of all the landforms. This remains the most used environment by Bininj for hunting and fishing etc. Perhaps the least known is the stone country.

Background to section 5.3 (Fire) amended to identify traditional burning as suggested.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Finally, where is the joy, the enthusiasm, and the ‘sunshine’ in the “Shared Vision Principles”?  It reads more like the ten commandments from the mount, than a template for people enjoying themselves.

The shared vision principles which were included in the draft management plan, and were drawn from the Shared Vision for Tourism in Kakadu National Park (Morse et al. 2005), have been removed from the management plan to enable review during the life of the plan.

Policy 6.1.1 amended to delete reference to the Shared Vision Principles.

Section 9.07 Neighbours, stakeholders and partnerships

(2) that the park embrace relatively radical and innovative ideas that would see a major role for volunteerism in a greatly expanded research and survey program – designed and supervised by the NT government biologists - in consultation with Kakadu traditional owners and park staff.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 10.13 Bringing plants and animals and other materials into the park

(4) That Kakadu enter into a trial to allow tourists to bring their dogs into the park and visit certain destinations – maybe not all.

Amended Section 10.13.8 to provide greater flexibility within the plan with regards to the entry of dogs in the future.

Section 10.5 Commercial use of resources

(2) Section 10.5.5. (b) Should read “where a proposal involves activities that impose significant stress or physical injury to an animal, the proponent to seek approval from an independent Animal Ethics Committee or be required to demonstrate that proposed activities are consistent with animal welfare legislation.”

Amended Section 10.5.5 to provide an example of where animal ethics approval will be required.

Section 10.5 Commercial use of resources

(1) Change the wording “capturing live fish for sale to aquariums and pet shops” to read “capturing live fish for captive breeding and sale of their progeny to aquariums and pet shops”

Amended the Background text of Section 10.5 as suggested.


 

Plan reference

Comments in the submission

Response

Gundjeihmi Aboriginal Corporation

Section 5.3 Managing park-wide threats affecting values

6. 1 Existing text (Section 5, Fire, Actions, page 91, item 5.3.24)

5.3.24 Develop a set of thresholds and acceptable ranges for fire regimes for all threatened terrestrial animal and plant species, and ensure that fire management is maintained within that range.

6.2 Suggested replacement text

5.3.24 Develop a set of thresholds and acceptable ranges for fire regimes for all threatened terrestrial animal and plant species for targeted application to relevant habitat, and ensure that fire management at those sites is maintained within that range.

6.3 Reason for change

To avoid ambiguity about scale and location of application of target fire regimes for particular species and circumstances.

Amended Section 5.3.24 to identify targeted application to relevant habitat as suggested.

Section 5.1 Looking after culture

The Technical Audit also identified a problem with Indigenous hunters who are not Bininj or authorised by Bininj/Mungguy accessing the Park. Clearly, park staff would need to be prepared to make proper distinctions between local Bininj/Mungguy traditional owners and other Aboriginals to address this ongoing problem.

There are difficulties in ascertaining who is authorised to hunt in the park (i.e. who is a Relevant Aboriginal) but the wording of Policy 10.6.1 has been amended to improve specificity. Under Action 5.1.10 a strategy will be developed to promote sustainable customary harvest practices and will further consider the issue of unauthorised hunting.

Section 5.3 Managing park-wide threats affecting values

Attachment 2:

Add to Section 9.9

6. Progressively transfer all weed and feral animal management work to Bininj organisations in the life of this plan

Section 4.2.6 (d) has been amended to specifically acknowledge threat abatement and fire management activities are aspects of park management to be outsourced to Aboriginal corporations or enterprises where appropriate and where capacity exists.


 

Plan reference

Comments in the submission

Response

Gundjeihmi Aboriginal Corporation

Section 5.3 Managing park-wide threats affecting values

7.1 Existing text (Section 5, Fire, Actions, page 91, item 5.3.26)

5.3.26 In collaboration with the Darwin Centre for Bushfire Research and other partners, develop an education and communication programme for residents, contractors, tour operators and park visitors on fire to emphasise the essential part fire plays in the ecology of Kakadu but also include the wise use of fire at campgrounds, impacts of wildfire, and fire control methods and responsibilities.

7.2 Suggested additional text

5.3.27 Structure fire management programs to engage resident Bininj and attract their active support for preventing and reporting unplanned ignitions.

7.3 Reason for change

Bininj are currently disengaged from present practice and have no incentive to support existing programs. The proposed savanna burning project will offer incentives for locals to prevent, report and extinguish unplanned fires, as has been an important contributor to the WALFA success.

Amended by adding a new action 5.3.27 as follows:

5.3.27 Structure fire management programs to engage resident Bininj and attract their active support for preventing and reporting unplanned ignitions.

Section 6.1 Destination and visitor experience development

To this end, the GAC submits that the Australian Government should join the Bininj/Mungguy community in beginning to develop, within 12 months of the life of the Plan, a comprehensive Indigenous Tourism Development Strategy. A coordinated focus on Indigenous planning and engagement in the tourism industry is critical to the Park advancing its other noteworthy tourism strategies. Terms of reference for such a process should be jointly developed by Parks authorities, tourism agencies in the NT and Australian Governments and Bininj/Mungguy.

Amended Action 6.1.8 to include a focus on investigating strategies to enhance Indigenous business opportunities in the tourism industry as suggested.

Section 8.1 Outstations and living on country

Also, in order to better reflect the social reality, an amendment to clause 8.1.4 (at page 119) is required. The words “were established before the national park” should be replaced with “were either established before the national park or have been established since that date with the permission of the Board”.

Amended Policy 8.1.4 as suggested.


 

Plan reference

Comments in the submission

Response

Gundjeihmi Aboriginal Corporation

Section 5.3 Managing park-wide threats affecting values

9.1 Existing text (Section 5, Climate change, Background, page 93, para 1)

5.3.28 The Board may approve fire management activities and projects, including projects carried out by Bininj/Mungguy, that:

(a) contribute to addressing or minimising the impacts of climate change

(b) are additional to and consistent with fire management carried out in accordance with Sections 5.3.17 to 5.3.26

9.2 Suggested replacement text

5.3.28 As a matter of priority, the park will work with Bininj/Mungguy to implement a new Bininj/Mungguy-managed savanna burning project that:

(a) contributes to addressing or minimising the impacts of climate change

(b) complements and provides security for fire management carried out in accordance with other provisions of this plan.

9.3 Reason for change

To recognise the proposed Director commitment.

Amended Policy 5.3.29 to ensure fire management activities and projects complements fire management in Sections 5.3.17 to 5.3.27. Wording of Policy 5.3.29 was drafted in consultation with the Emissions Reduction Fund Division and generally should not be changed. The primary party responsible for developing a new Bininj/Mungguy-managed savanna burning project is not the DNP or the Board.


 

Plan reference

Comments in the submission

Response

Gundjeihmi Aboriginal Corporation

Section 5.3 Managing park-wide threats affecting values

10.1 Existing text (Section 5, Climate change, Background, page 94, item 5.3.30)

5.3.30 Work with research partners to improve understanding of the carbon cycle within the park and how much carbon is stored and released due to different management actions. Use this information to refine weed, feral animal and fire management strategies to reduce the carbon footprint of the park.

10.2 Suggested replacement text

5.3.30 Work with research partners to improve understanding of the carbon cycle within the park and how much carbon is stored and released due to different management actions. Use this information to refine all relevant management strategies to minimise the carbon footprint of the park.

10.3 Reason for change

Many weed management actions will reduce carbon stored in park landscapes (e.g. Mimosa control, Gamba grass control). Conservation objectives will sometimes be best achieved by emissions intensive use of fire (e.g. floodplain burning, resisting woody encroachment of grasslands). Feral animal control may contribute to greater methane emissions from wetlands. It is unreasonable to suggest that the net effects of meeting all obligations on the park's carbon footprint are sufficiently understood to specify outcomes in advance of the research proposed.

Amended Action 5.3.31 as suggested so the individual management strategies are not identified.


 

Plan reference

Comments in the submission

Response

Gundjeihmi Aboriginal Corporation

Section 9.06 Resource use in park operations

11.1 Existing text (Section 9.6, Resource use in park operations, Background, page 140, para 3)

The park is committed to reducing its carbon footprint and is working with research partners to improve understanding of the carbon cycle and how much carbon is stored and released due to different management actions. This information will be used to refine weed, feral animal and fire management strategies and reduce the carbon footprint of the park (see Section 5.3: Managing park-wide threats affecting park values).

11.2 Suggested replacement text

The park is committed to manage its carbon footprint actively and is working with research partners to improve understanding of the carbon cycle and how much carbon is stored and released due to different management actions. This information will be used to refine all park management policies and practices to minimise the carbon footprint of the park (see Section 5.3: Managing park-wide threats affecting park values).

11.3 Reason for change

As in 8.3 above.

8.3 Reason for change

The current text ignores benefits to the park of using carbon farming mechanisms, and requires strengthening to reflect the proposed commitment.

Amended the background to Section 9.6 as suggested.

General comment

The maps in the plan depicting the Jabiluka and Ranger mineral lease need to be updated. The Ranger mine operates under an authority under the Atomic Energy Act 1953 and is not called a mineral lease. The Ranger mine operates in the Ranger Project Area.

Amended maps within the plan as suggested.


 

Plan reference

Comments in the submission

Response

Jabiru Town Development Authority

Section 9.07 Neighbours, stakeholders and partnerships

Should the JTDA be named as a key stakeholder at item 9.7?

Amended the background text of Section 9.7 to include the Jabiru Town Development Authority in the list of regional stakeholders.

Appendices

“West Arnhem Regional Council”/ “WARC” should be included in Appendix F – Glossary and interpretation.

Amended the plan as suggested.

General comment

All references to “West Arnhem Shire Council” should be changed to “West Arnhem Regional Council” – the name was changed at the end of 2013. All references to “Jabiru Town Council” should be changed to “West Arnhem Regional Council”.

Amended plan as suggested.

Commercial fisherman

Section 10.10 Commercial fishing

...Agree with the submission for access to the West Alligator for Barramundi fish transportation and believe that it would provide a much needed access for product providing that participating people are heavily controlled by V.M.S. And rules whereby they can't do the wrong thing...

Amended Background text of Section 5.2 to incorporate information on the importance of the West Alligator River as the only river system in the Top End entirely protected from recreational fishing and boating.

The Board resolved not to support the transit of commercial fishing vessels down the West Alligator River for the purpose of unloading their catch to road transport on the Arnhem Highway.


 

Plan reference

Comments in the submission

Response

Northern Land Council

Section 1.1 A description of Kakadu National Park

This currently reads “when landscapes formed, human beings transformed themselves into animals and sacred places set themselves into the landscape”. The NLC suggests that this should be changed to “when landscapes formed, ancestral beings transformed themselves into animals and sacred places were created”. (Section 1.2, page 2)

Plan amended as suggested.

Section 1.1 A description of Kakadu National Park

This currently reads: “Some human beings could also transform themselves into animals. We recommend removal of this sentence as it is an inaccurate representation of the dreaming. (Section 1.2, page 2)

Plan amended as suggested.

Section 1.1 A description of Kakadu National Park

This currently reads “Members of a particular clan … sacred sites in their clan estates”. The NLC suggests that this sentence should read: “Each clan and moieties have a number of totems and emblems. Sacred sites and other special places on each clan estate are the focus of religious life”, because this better describes the relationship between sacred sites and totems.

Plan amended as suggested.

Section 1.1 A description of Kakadu National Park

In the last paragraph on this page, the text after the reference to the ALRA should be replaced with: “In the Kakadu area primary responsibility to land is determined according to traditional Aboriginal law and custom and involves making important decisions about the management of country such as protecting resources and sacred sites. While a person belongs to the clan of their father they still have responsibilities to their mother’s clan estate. Both men and women may be acknowledged as senior traditional Aboriginal owners.” This better describes the means by which traditional ownership is determined.

Plan amended as suggested.

Section 1.1 A description of Kakadu National Park

This currently reads “Through the use of skin groups Aboriginal peoples organise marriages and use skin group names as important ways of addressing and referring to Aboriginal people.” We recommend changing this to “Skin groups are used in regulating marriages and addressing or referring to Aboriginal people in culturally appropriate ways,” because the current form implies that the function and protocols relating to skin groups are a mere social convention and does not capture adequately the pertinent cultural aspects embedded in kinship.

Plan amended as suggested.


 

Plan reference

Comments in the submission

Response

Northern Land Council

Section 1.1 A description of Kakadu National Park

The text of the first paragraph on this page should be changed to:

“Creation Ancestors were also responsible for the various languages that exist in the Park. These are associated with different tracts of land and the people who own them. The traditional countries of some language groups are large and divided into distinct estates, others are smaller.”

Plan amended as suggested.

Section 1.1 A description of Kakadu National Park

Jeffrey Lee’s statement refers to the integrated natural/cultural landscape, however the following discussion maintains the western dichotomy between “natural” and “human”. As such, we propose the following sentence be amended to read: “The park is a vast and continuous natural environment that comprises four main landscape types, each with distinct natural and cultural values.”

Plan amended as suggested.

Section 5.1 Looking after culture

This section does not adequately address or capture the intangible aspect of culture with regard to rock art and the wording should be strengthened to better capture this. For example the lack of intergenerational transfer of knowledge and loss of knowledge should be listed as the primary threatening process as it is in the mini plan for Kakadu released on 23rd January 2015.

Amended Background text of Section 5.1 as suggested to recognise the lack of intergenerational transfer of knowledge and loss of knowledge as a significant threat to rock art.

Section 5.1 Looking after culture

Actions should clearly reflect protection of values. Values indicate that rock art is “a storehouse of traditional knowledge including stories and law and is a powerful teaching tool for young Bininj/Mungguy” however 5.1.3 only refers to Bininj/Mungguy recording cultural knowledge. 5.3.1 should specify assisting with passing knowledge on to younger generations not just recording of site information.

Amended Action 5.1.3 as suggested.


 

Plan reference

Comments in the submission

Response

Northern Land Council

Section 5.1 Looking after culture

Social Issues on p48 states that “The park can support the maintenance of culture through the provision of resources and programmes; however, many factors that influence culture are outside the park’s control, including participation in cultural management programmes and intergenerational transfer of sensitive cultural knowledge.”

This sentence lacks clarity in that it states that resources and programmes can be provided, but that participation is beyond control of Parks Australia. Obviously Binij/Mungguy participation is within the sphere of influence of ‘the park’ (Parks Australia) given that it can develop and run programmes. What this statement seems to be alluding to is that traditional owners must take a leadership role in such programmes. This statement should be rephrased to clarify this. Also, as previously mentioned the term ‘the park’ should be changed to Parks Australia.

Amended Action 5.1.7(f) to include provision of support to facilitate Bininj/Mungguy leadership in management programmes.

Section 5.1 Looking after culture

This section refers only to recording cultural knowledge, not passing it on. The action should be to record and pass on knowledge to younger generations. While it may seem semantic this clarification can affect the manner in which information is recorded and stored and this is important.

Action 5.1.12 amended to read: Assist Bininj/Mungguy to access cultural sites in the park, to record cultural knowledge associated with them, and provide opportunities to pass this knowledge on to younger generations.

Section 5.3 Managing park-wide threats affecting values

Figure 12, p. 78 The An-garregen Strategy is not mentioned as a relevant subordinate strategy under protection of cultural values in the table.

Figure 12 has been amended so that the Cultural Heritage Strategy is identified as a relevant strategy under the outcomes for cultural values, feral animals and fire.

Section 8.1 Outstations and living on country

The Draft Plan states that a consideration when looking at new outstations is that they do not impact on park values. This statement seems to foreshadow a situation where natural values are at odds with cultural values (such as the establishment of an outstation). In line with the vision statement (specifically, “the cultural and natural values of the park are protected and Bininj/Mungguy culture is respected”), the Draft Plan should be careful not to appear to prioritise natural values over cultural values. In the previous plan, the stated aim was “Bininj establish living areas in the Park that meet their needs while minimising the impact on Park values”. This formulation does not imply that either of natural values or cultural values is dominant.

Amended background to Section 8.1 so the desirable aim is that the impact of new outstations on park values is minimised.


 

Plan reference

Comments in the submission

Response

Northern Land Council

Section 9.10 Implementing and evaluating the plan

In the fifth plan section 8.9.9 p. 150, point three was as follows: “in the case of any prescribed policy and action that was not implemented, or which failed to achieve the desired aim (s), determination of the cause”. This requirement should remain in section 9.10.10

Amended Section 9.10.11 as suggested to include words from the fifth plan that for any policy or action not implemented during the life of this plan the cause will be determined.

General comment

At various points throughout the plan ‘the park’ is used in different ways, in some instances it refers to Parks Australia, in others, the physical land comprising Kakadu National Park, in others some kind of social entity distinct from traditional Aboriginal owners. If reference is being made to Parks Australia, this name should be clearly stated to avoid ambiguity. Also, a reference to ‘the park’ which implies an entity that is separate from traditional owners should be avoided altogether.

(Throughout)

Amended plan as suggested to ensure that "the park" is not used to represent park management, the Director or Parks Australia (i.e. removal of the term: "the park will...." etc.). All remaining occurrences of the phrase "the park" refer to the area of land known as Kakadu National Park.

General comment

The Draft Plan uses a number of different phrases to refer to “traditional Aboriginal owners”, such as “relevant Indigenous people”. The NLC recommends that language is used consistently and ideally reflects statutory definitions, and as such prefers that the term “traditional Aboriginal owner” is used throughout the Plan.

(Throughout)

Amended plan as suggested and included a definition of "relevant Aboriginals" which is consistent with the definition in the Aboriginal Land Rights (Northern Territory) Act 1976 to the glossary.

Northern Territory Government

Section 1.1 A description of Kakadu National Park

The NTG(NTG) recommends updating figures in the draft management plan in 1.4 to reflect the latest figures available, i.e. for tourism this would now read:

• Tourism is very important to the regional economy, particularly in terms of employment. For the financial year 2012-13, Tourism NT reported that the direct value of tourism to the Northern Territory was $821 million GVA (NT TSA 2012-13)) and in 2013-14 the Northern Territory attracted 1.3 million visitors (Tourism NT 2014). It is estimated that in 2012–13 Kakadu National Park attracted 200,260 visitors. In addition to its significant contribution via the tourism market, the park purchases significant quantities of goods and services from regional suppliers.

Amended plan to include the most current data.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 1.1 A description of Kakadu National Park

Recommend including a reference to national tourism statistics in the section on the National economy (p.16). This information can be sourced online at http://www.tra.gov.au/publications/tourism-and-the-australian-economy-State_Tourism_Satellite_Accounts.html

Amended plan as suggested.

Section 2.2 Management plan framework

In addition to the lack of clarity around the performance indicators in Part C of the draft management plan, structurally there is often a lack of coherence between the stated ‘Outcomes’, ‘Performance Indicators’ identified, ‘Management Issues’ and related ‘Actions’. For example, on (p.103) in 6.1 ‘swimming’ is identified as a management issue, however none of the ensuing actions addresses it.

Amended plan to further improve the line of sight and ensure the management actions are addressing management issues to meet specified outcomes. For instance the following amendment has been made to the Background of section 6.1:

      Swimming
In the hot, tropical climate of the Top End swimming is an enjoyable activity. However, there are a number of potential risks and impacts associated with swimming or entering waters for other purposes, particularly below the escarpment (see Section 9.1: Safety and incident management).

Section 4.3 Bininj/Mungguy training and other opportunities

The NTG recommends that this section specifically identify some of the potential social and economic benefits that may be gained by the Bininj/Mungguy (i.e. identify opportunities that may be allowed under the EPBC Act to deliver on the performance indicators listed in this section).

This has been done effectively in section 5.3 (p.77), where it states that ‘outsourcing of park weed management and feral control functions within a district, clan estate or specific area of the park to Aboriginal corporations or enterprises will be supported and facilitated where there is capacity to do so’. Similar specific activities could be listed in section 4.3.

Action 4.3.2 was amended to provide adequate information on the approach that will be taken to promote and support opportunities for Bininj/Mungguy enterprises.

Section 4.3 Bininj/Mungguy training and other opportunities

Policy 4.3.2 should recognise the importance of working in collaboration with existing businesses, the broader tourism industry and other stakeholders working within the park.

Amended Action 4.3.1 to better recognise that the Director will work collaboratively with Bininj/Mungguy and existing businesses, the broader tourism industry and other stakeholders within the park to develop partnerships and other ways of increasing opportunities for Bininj/Mungguy that are related to implementation of the plan.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 5.1 Looking after culture

AAPA has flagged some concerns about the way in which its processes are incorporated into the overall management and planning systems within KNP, and as such it is AAPA’s intention to provide a comprehensive submission to the DNP as it looks forward to enhancing its relationship with PA under the sixth Management Plan for KNP.

Action 5.1.14 amended to acknowledge the need to work more closely with the Aboriginal Areas Protection Authority to increase the protection and registration of sacred and other cultural sites, recording and documenting information about them.

Section 5.1 Looking after culture

The wording used in many of the performance indicators is ambiguous. In the absence of a baseline figure or measurable target, a reflection of whether the aim is to reduce or increase the indicator is important. For example the performance indicator for Rock Art outlined on (p.44) is simply ‘impact of fire, feral plants and animals, and humans on priority rock art sites’. The NTG recommends that the wording be changed to include the word ‘reduce’ in front of ‘impact’. (This would more appropriately fit with the performance indicators in other sections). This comment relates to the performance indicator in the ‘Bininj/Mungguy cultural sites’ and ‘Historic sites’ sections.

Amended performance indicators for rock art and historic sites to recognise that a reduction in the overall impact of threatening processes at priority sites is the aim of management.

Section 5.1 Looking after culture

Overall the NTG supports the promotion of cultural protocols to the public, visitors and business.

Action 5.1.7(h) amended to include promoting awareness of and respect for cultural protocols and practices.

Section 5.1 Looking after culture

In relation to 5.1.7 (b) the NTG agrees in principle and understands the intent in relation to the support of Bininj/ Mungguy place names, however consideration must be given to the NT Place Names Register, and any changes made would need to be consistent across all collateral including business, road, maps and directional signage.

Amended Action 6.4.2 to recognise that place names will be consistently used and maintained across all collateral.

Section 5.1 Looking after culture

In 5.1.1, the NTG supports the development of an educational program focused on educating both visitors and Bininj/Mungguy about threats to rock art and cultural sites. This may increase overall understanding of threats to cultural sites, while also increasing public / community reporting of damage, and encouraging people to actively look after cultural sites. This would assist in addressing the existing threat in the Historic Sites section, which states that there are ‘varying perceptions of the significance and value of historic sites among Bininj/Mungguy, park staff and other stakeholders’ (p. 55).

Covered by Action 5.1.20(d) amended to identify opportunities to improve awareness of the significance of heritage sites in the park. 


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 5.2 Looking after country

The NTG advises that the information in 5.2 (p.66), last paragraph is incorrect according to The NTG Fisheries data (logbook returns data). Commercial fishing pressure along the Kakadu coast as a result of the commercial barramundi closures to Chambers and Finke Bays has not increased. It should be noted that the closures included the buy-back of commercial barramundi licences from the fishery, reducing the total number of commercial barramundi licences in the Northern Territory from 20 to 14 commercial licences.

Amended the Background text in Section 5.2 Floodplains to describe only factual information regarding potential for increased fishing pressure in Kakadu resulting from closures under consideration or introduced elsewhere.

Section 5.3 Managing park-wide threats affecting values

While 5.3.35 and 5.3.36 seek to address the management issues relating to ‘direct and indirect visitor disturbance’) (p.96), it is not clear whether these policies will address the specific issues identified (unauthorised fires, collection of firewood, unburied waste, noise pollution, feeding native animals, erosion on walking tracks and roads, vandalism, dust from roads). For example, an education program may be considered to increase visitor awareness about these issues. Additionally, there may be a need to train and support staff in regulation and enforcement activities when dealing with illegal activities in parks and reserves.

Amended plan by adding a new Action 5.3.43 to communicate with park visitors about their direct and indirect impacts on park values to increase awareness and reduce impacts.

Section 5.3 Managing park-wide threats affecting values

In relation to 5.2, the NTG experience in pest animal management programs on Indigenous land has indicated that there are varying opinions within the Indigenous community about management, considerable opposition to management of pest animals, and different values placed on pest animals. If this is also the case within KNP, it may be valuable to include this issue in a ‘management issues’ subsection within each of the Floodplain, The lowlands, and the Rainforest sections. This could be linked to an action, such as to increase Bininj/Mungguy education and awareness of the damage caused by pest animals and the need for management activities to reduce damage.

Amended Background to Section 5.3 on feral animals to better recognise the varying ways that some Bininj/Mungguy view introduced animals. Action 5.3.14 covers communicating with park residents and visitors the impacts of feral animals.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Overall, the NTG recommends that a significant shift in focus is required to deliver on the objective outlined in section 6 on (p.98): To increase visitation in a sustainable way and provide opportunities for diverse and enriching visitor experiences which are promoted in an appropriate way.

Amended Background to Section 6 to use more positive language to describe how the park will be managed to foster collaboration with the tourism industry and increase visitation.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Shared Principles 4 and 5: The NTG understands and respects the intent of these principles, however there needs to be an acknowledgement that commercial operators and their investment will require that Bininj/Mungguy understand their responsibilities to participate and support these ventures to realise the benefits. Otherwise the investment and visitation will be lost to alternative destinations.

The shared vision principles which were included in the draft management plan, and were drawn from the Shared Vision for Tourism in Kakadu National Park (Morse et al. 2005), have been removed from the management plan to enable review during the life of the plan.

The park is primarily Aboriginal land. As owners of the land, Bininj/Mungguy have the right to direct changes in the impact and direction of tourism on their land. The terms of the Lease to the Director of National Parks includes a range of obligations to ensure that the culture of Bininj is respected and that we ensure that benefits are made available to Bininj as a result of the operation of the park. We cannot impose requirements upon Bininj/Mungguy to participate or support enterprises and developments on their land.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Related to the overall above, the NTG makes the following comments in relation to the Shared Vision Principles outlined on (p.99):

• Shared Principle 1: The NTG recommends removal of the word “manage” as the connotation is that this is an all-encompassing role of the Bininj/Mungguy which could potentially inhibit private sector investor interest.

The shared vision principles which were included in the draft management plan, and were drawn from the Shared Vision for Tourism in Kakadu National Park (Morse et al. 2005), have been removed from the management plan to enable review during the life of the plan.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Shared Principle 9: The NTG recommends excluding any promise of “profitable investment” and consider rewording to “avenues for investment”.

The shared vision principles which were included in the draft management plan, and were drawn from the Shared Vision for Tourism in Kakadu National Park (Morse et al. 2005), have been removed from the management plan to enable review during the life of the plan.

Policy 6.1.1 amended to delete reference to the Shared Vision Principles.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

On (p.100) The NTG recommends removing the last dot point (of three) as it is superfluous and reinforces potential negative perceptions using words such as ‘remote’ and ‘undeveloped’.

Background text to Section 6 amended as suggested.

Section 6.03 Promotion and marketing

The NTG recommends that this section of the draft management plan address any relevant findings from the Kakadu Commercial Image Capture Survey undertaken by parks management in early 2015.

Amended Section 6.3 in include reference to the commercial image capture survey conducted early in 2015 and how the findings of this survey will be used to develop guidelines and improve processes for commercial image capture in the park.

Section 6.1 Destination and visitor experience development

Section 6.1 should give consideration to the development of cycle tracks in and around major population areas (mainly Jabiru and Cooinda.). NTG understands that cycling is gaining popularity and some single-use cycle tracks through areas of natural beauty would be an attractive activity option for visitors.

A new Action 6.1.20 added to recognise that consideration will be given to possible development of bicycle riding tracks in and around major population areas. Minor amendments also made to Actions 10.4.6 and 10.7.6 to clarify how bicycle riding is managed in the park.

Section 6.1 Destination and visitor experience development

The NTG recommends 6.1.9 also considers including a reference to investment and upgrade opportunities for existing and new experiences.

Action 6.1.9 amended as suggested.

Section 6.1 Destination and visitor experience development

The NTG recommends 6.1.9 also considers including a reference to investment and upgrade opportunities for existing and new experiences.

Action 6.1.9 amended to include reference to investment and upgrade opportunities as suggested.

Section 6.1 Destination and visitor experience development

The NTG recommends that action 6.1.15 also gives consideration to the importance of encouraging repeat and new visitation.

Amended Action 6.1.15 as suggested to give consideration to the importance of encouraging repeat and new visitation.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 6.2 Commercial tourism development and management

6.2.10 cites Australian National Landscapes as a key vehicle to communicate to tourism stakeholders. The NTG recommends that the most appropriate conduits to the industry locally are through the industry development team at the Department of Business, through Tourism NT and the industry membership body Tourism Top End.

Amended Action 6.2.10 to recognise that industry will be engaged in forums through relevant NT government agencies and the Tourism Top End as well as through the Australia's Timeless North National Landscapes Steering Committee.

Section 6.3 Promotion and marketing

6.3.1 sets out that The park will be promoted and marketed in accordance with the Shared Vision Principles, the following key messages, and other messages as determined by the Board:

1. Kakadu is an Aboriginal place and a cultural landscape

The NTG recognises the importance of this key principle, however, in order to achieve the goal of increased visitation, KNP must act as a holiday destination, before it acts as a place of landscapes. Therefore, the importance of showing KNP in a light that is accessible, appealing (in that it has hotels and guided tours) alongside the unique indigenous culture will create positive impact for the entire offering rather than just reinforcing all the things people already know about KNP when it comes to sight-seeing.

Action 6.3.1 amended to include recognition that when Bininj/Mungguy sites are closed for cultural reasons that the closure will be announced in order to demonstrate and reinforce that Kakadu is a living cultural landscape.

Section 6.3 Promotion and marketing

In relation to 6.3.3, the NTG does not recommend using the Australia's Timeless North National Landscape as a model for marketing. Australia’s Timeless North has little marketing appeal or benefit and in fact is quite detrimental in its description of what's on offer to the consumer, creating a lack of urgency to visit the region. It does not consider the potential visitors perspective and is built on geological, landscape based features, not benefits to the visitor from a holiday perspective. In addition, promotion of the Timeless North brand competes against KNP and adds to the confusion about what is on offer in the park.

Amended Action 6.3.3 to acknowledge Parks Australia will develop a cooperative promotion and marketing strategy with the tourism industry and the Australian and NT Governments as well as other stakeholder groups. Parks Australia considers that the National Landscapes Programme plays an important role in the promotion of nature-based tourism and the park remains a part of the program.

Section 6.4 Visitor information

The NTG recommends that policy 6.4.2 should note that signage along the NTG managed roads should be placed outside Safety Clear Zones and conform to the NTG and national safety policies and guidelines.

Amended Policy 6.4.2 to recognise that signage in the park will be in accordance with the Kakadu Brand Identity Guidelines and all Northern Territory and applicable signage standards and policies, where appropriate and relevant. Policy 6.4.2 also amended to specify that consistency will be maintained across all collateral, including marketing material, business naming, building names, road signage and directional signage.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 8.2 Jabiru

• (p.121) (para 2) states “Jabiru has had a significant impact on Aboriginal people, lifestyles and traditions in the region.” Similar statement is made at section 8.2.14.

• Suggest this statement be removed from the draft management plan; it is subjective and there is no evidence in the draft management plan which supports the statement, including how the Town has had a “significant impact” on Aboriginal people. Rather, the draft management plan should acknowledgement that the Mirarr People and the Northern Territory Government, in partnership, have reached in-principle agreement on the future development of Jabiru such that statements noting the harmful impact of the Town on Aboriginal people/challenges etc should be removed).

Amended the background of Section 8.2 to recognise the significant benefits that Jabiru provides as a commercial and social services hub for the region, including retail, financial, tourism and government services.

Also amended Action 8.2.14 to acknowledge the potential beneficial outcomes for Aboriginal people before reference to the possible adverse impacts of Jabiru.

Section 8.2 Jabiru

The following comments from the Solicitor for the Northern Territory address specific details of the draft management plan:

• (p.121) (para 1) refers to the 2009 agreement to settle the native title claim. The draft management plan should refer to the agreement as “in principle” whenever reference is made to the settlement.

Amended Policies 8.2.2 and 8.2.3 and action 8.2.13 to reflect the fact that the Jabiru native title agreement has not yet been finalised.

Section 9.01 Safety and incident management

The NTG recommends that 9.1.10 includes additional activities that are high risk to visitors and park residents such as bush walking, camping and the need to carry suitable provisions (e.g. water, food, etc.).

Amended Section 9.1 to include a new management issue that visitors need to be aware that weather extremes do occur in Kakadu and a new action (9.1.11) that appropriate interpretive material will be provided to visitors that communicates the steps they need to take to stay safe in the park.

Section 9.03 Authorising and managing activities

In relation to 9.3.1, it should be noted that in order to make significant capital investment required to establish commercial ventures, businesses require security of tenure for a meaningful period of time (for example upwards of 25 years). If sustainable growth of commercial activity is to occur, the guidelines must allow for long-term leases, with transferrable titles.

Amended Action 9.3.1 as suggested to recognise that subleases and leases will be offered for periods necessary to provide security of tenure to attract and support the level of investment required for tourism activities and developments.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 9.04 Capital works and infrastructure

The NTG has responsibility for the care and management of the Arnhem Highway, Kakadu Highway, Old Jim Jim Road, Cooinda Road, Oenpelli Road, including Cahill’s Crossing and Gimbat Road (“the arterial roads”). The arterial roads are public roads under the Land Rights Act and cannot be returned to Traditional Owners, meaning the roads will never formally be Aboriginal land. The Territory managed roads are part of the Territory arterial network, but are also within the park and as such are subject to the Environment Protection and Biodiversity Act.

The land underneath the arterial roads may technically be under the Director of Parks, as it was compulsorily acquired by the Australian Government at self-government. It is the opinion of the NTG that this land should revert to roads under the Control of Roads Act. All other roads in the park are under the care control and management of the Director of Parks because these roads do not fulfil an arterial function for the Territory. This is not acknowledged in the draft management plan.

The NTG therefore recommends that the care, control and management of the arterial roads be held by the NTG and the land should either be acquired with consent from the Australian Government or by an amendment to the Control of Roads Act to allow Roads in KNP to be managed under the Act.

Amended Section 9.4 to clarify that the Northern Territory Government has responsibility for the arterial road network in the park.

Section 9.05 Assessment of proposals

The NTG advises that the current Impact Assessment Process outlined in Table 5: Impact Assessment Process (p.137) has been problematic in its interpretation and implementation and has led to significant delays for projects. For example, difficulties gaining access to gravel and water has made continued maintenance of unsealed roads difficult and costly.

Amended plan by including a new action 9.5.6 to review the Environmental Impact Assessment guidelines for assessment of proposals. The revised guidelines should prescribe criteria for when proposed actions should be subject to public consultation.

Section 9.05 Assessment of proposals

The NTG recommends that the impact assessment process be reviewed and that particular emphasis be placed on clarifying definitions on what constitutes a moderate (Level 2) versus major (Level 3) capital works or infrastructure upgrade. Without specific definitions this becomes a case of individual interpretation of the management plan.

Amended plan by including a new action 9.5.6 to review the Environmental Impact Assessment guidelines for assessment of proposals.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

Section 9.08 Revenue and Business Development

9.8 identifies the opportunity to expand revenue generation opportunities to assist in resourcing park operations. The section identifies one of the management issues as ‘specialist marketing and business skills and expertise are required to develop this area of park management.’ The NTG supports the requirement to address this issue and would be pleased to engage with PA to work collaboratively to implement action 9.8.2.

This particular issue, among others, is a good example of something the currently embryonic Jabiru Region Working Group could look into. The plan is an important document in the context of Jabiru’s non-mining future and should be of considerable interest to the Group.

Amended by adding Action 9.8.5 to address the need for specialist marketing and business skills and expertise.

Section 10.3 Living in the park (outstations and Jabiru)

Additionally, it appears that a number of functions and responsibilities that were previously undertaken by the Jabiru Town Council and/or Jabiru Town Development Authority (as per the previous 2007-2014 Management Plan for KNP) have transitioned in the plan to being functions and responsibilities of the NTG or West Arnhem Council under the draft management plan.

For example, (p.161) - 10.3.22 The NTG should regularly monitor waste water discharges in and from the town, and water supply quality, and provide reports to the Director. This contrasts to the 2007-2014 Management Plan for KNP (Page 126 – 7.1.9) which states The JTC (or JTDA) should regularly monitor waste water discharges in and from the town, and water supply quality, and provide reports to the Director.

The transition of any functions and responsibilities which were previously undertaken by the Jabiru Town Council and/or Jabiru Town Development Authority, and which the NT Government does not have currently, require further consultation and, subject to that consultation, may require amendment to the draft management plan.

Amended Actions 10.2.22 and 10.3.23 to identify West Arnhem Regional Council (or successor to this function) as the responsible authority.

Section 10.3 Living in the park (outstations and Jabiru)

Policy 10.3.25 of the draft management plan (p. 161) states that Northern Territory laws, including Acts, Regulations and by-laws, relating to the town should be amended as required to ensure consistency with the EPBC Act, EPBC Regulations and this management plan. Prima facie, the implication of this requirement is onerous. This policy requires further consultation and subject to that consultation may require amendment.

Action 10.3.24 amended to recognise that laws of the northern territory should be reviewed by the relevant agency where necessary to address any inconsistencies with the EPBC Act, EPBC Regulations or the management plan to avoid unintended inconsistencies.


 

Plan reference

Comments in the submission

Response

Northern Territory Government

General comment

Despite the adoption of a Management Effectiveness Framework for this draft management plan, many of the identified management issues are not tied to specific actions or measurable performance indicators and there is limited reference to resourcing within the draft management plan, leaving the detail to be found in poorly referenced subordinate strategies. The NT Government recommends in its response that PA consider including greater detail on the development, implementation, governance and performance assessment of these subordinate strategies, thereby providing a level of confidence that the key management challenges are under control and that the specified actions will be implemented.

Amended the plan to improve the referencing of management strategies that will be used to implement sections of the plan.

The management plan is an enabling document. It provides for the development of management strategies to implement actions in the management plan. The Board can undertake public consultation on management strategies developed under the plan (which it recently did for the draft walking strategy). The plan also provides for the development of an implementation schedule for the management plan and a performance monitoring plan.

General comment

The use of community names such as Oenpelli (Kunbarlana) should be consistent with those recognised in the NT Place Names Register. Oenpelli is now known as Gunbalanya. This would be applicable throughout the document.

Amended plan as suggested.

General comment

References made to ‘West Arnhem Shire Council’ should be changed to reflect the current title ‘West Arnhem Regional Council Shire Areas’.

Amended plan as suggested.


 

Plan reference

Comments in the submission

Response

NT Seafood Council

Section 10.10 Commercial fishing

Under the Barramundi Management Plan closure lines are used to determine areas and gear permitted for use. The closure line for the East Alligator River (Barramundi Management Plan Schedule 5) is at 2478 E 86560 N to 2478 E 86596 N, which is just below the mouth of Coopers Creek (see Figure 1). In Schedule 6 of the Barramundi Management Plan the 7” net closure line on the East Alligator River is at 2440 E 86620 N to 2440 E 86580 N as shown in Figure 1.

Current diagrams of the Kakadu National Park boundary that are available are conflicting in the messaging as to where the Park boundary lies with respect to East Alligator River. For example, Figure 1 which uses geographic shape files available from Government, gives the impression that entry into East Alligator River is in fact entry to the Park. On page 6 and 8 of the Draft Management Plan 2014 maps depict the boundary as being the western bank of the East Alligator River, with a clear and open access to Coopers Creek within East Alligator River.

It is the NTSC’s understanding that below the tidal limit of the East Alligator River the boundary of the park is the low water mark along the right (i.e. eastern / Arnhem Land) bank of the river.

Amended maps in the plan to clarify that below the tidal limit of the East Alligator River the boundary of the park is the low water mark along the right (i.e. eastern / Arnhem Land) bank of the river.

Senior Research Fellow, Aquatic Ecology and Management, Charles Darwin University

Section 5.2 Looking after country

The statement 'The park also provides critical habitat for two endangered species of speartooth shark, one of which is endemic to the park, one vulnerable sawfish species and two inshore dolphin species.' is factually incorrect. The park provides critical habitat for: the Critically Endangered Speartooth Shark and the Endangered Northern River Shark (which can collectively be referred to as 'river sharks' (genus Glyphis); neither of these are endemic to the park) and two species of Vulnerable sawfish (Largetooth Sawfish and Dwarf Sawfish). Alternative text to replace the text above is: The park also provides critical habitat for one Critically     Endangered and one Endangered species of river shark, two Vulnerable sawfish species and two inshore dolphin species.

Amended the background text for Section 5.2 Floodplains to correct species status as suggested.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 3. General provisions and IUCN category

The IUCN website compares category II to category VI [Managed resource/Protected Area], saying that "Category II will not generally have resource use permitted except for subsistence or minor recreational purposes." Section two mentions that park management could be improved by "assisting with proposals for establishing new living areas within the park." I cannot see how this can possibly be considered consistent with IUCN category II.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

Section 3. General provisions and IUCN category

The IUCN definition of category VI states that it is, "Protected areas that conserve ecosystems and habitats, together with associated cultural values and traditional natural resource management systems. They are generally large, with most of the area in a natural condition, where a proportion is under sustainable natural resource management and where low-level non-industrial use of natural resources compatible with nature conservation is seen as one of the main aims of the area."

Under the heading of 'other objectives', is states that one of these objectives is, "To facilitate inter-generational security for local communities' livelihoods – therefore ensuring that such livelihoods are sustainable." There are many parts of the Draft Plan which talk about Binninj/Mungguy. Many of these are consistent with IUCN category VI. They are not consistent with IUCN category II.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 3. General provisions and IUCN category

I am not in a position to say how well joint management is working, but I believe that it would work better if the park were redefined so that the aspirations of the traditional owners were recognised in a way which is not possible with a category II classification.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

Section 3. General provisions and IUCN category

Overall, I am in general agreement with this section but I think that one problem is that the aims and objectives of a national park cannot ever be in complete harmony with the aspirations and life choices of the traditional owners. As stated in the previous section, changing the IUCN category to category VI would go a long way to overcoming this.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 3. General provisions and IUCN category

Kakadu is Aboriginal Land. It is also listed as IUCN category II -- 'National Park'. I have long felt that this was a mistake. Now that I have found and read the IUCN categories, I am more convinced of this than ever.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

Section 3. General provisions and IUCN category

Comment made in relation to Section 10.3 Living in the park (outstations and Jabiru)

As mentioned in section three, much of what is here does not appear to be consistent with IUCN category II. Many of those things are consistent with IUCN category VI.

The Board resolved that the park should continue to be assigned to the IUCN category II – national park as assigned by the previous (5th) management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In considering the comments received on zoning the Board however agreed to include in Section 3.4 of the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 5.2 Looking after country

As the plan notes, much of the rainforest in Kakadu exists in patches in the stone country. Over the past 40 years, I have seen only slight changes to the boundaries of the rainforest patches. On the other hand, over the past 10-15 years, I have seen a huge increase in the amount of damage due to feral pigs. The Plan says that feral animals are a significant threat. It says, "The decline in yams may be related to activity of pigs." 'May be related' ... I cannot see how there can be any possible doubt. Current management practices do not work.

Amended the background text of Section 5.2 Rainforest to clarify the impact of pigs is likely related to decline in yams.

Section 7.1 Research and knowledge management

While bushwalking tour guides are not qualified to do any significant conservation work, they are certainly qualified to remove potentially damaging vegetation. They are equally qualified to report back on any changes in the condition of those sites. Why not encourage this? It would cost the park nothing and would do an important job which would otherwise remain undone.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.

Section 7.1 Research and knowledge management

Introduced ants. Giving interested people, especially bushwalkers who visit parts of the park that others seldom visit, a kit so that they could identify and report possible infestations. I often have keen macro photographers on my trips. A good photo early on could make it possible to control an outbreak before it became too big to control.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.

Section 7.1 Research and knowledge management

"Effective methods for storing, managing and retrieving park data and information are required but are costly."

When I read the statement above, I couldn't help but wonder how much work has been duplicated because the original records have been misplaced. I also couldn't help but wonder why it should be costly. That statement almost reads like an admission of defeat.

Amended Section 7.1 to remove reference to costs associated with data storage and management.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 7.1 Research and knowledge management

In the back country, bushwalkers could be issued with information kits so that they could report the locations of any specific weeds of concern. Volunteers could be sought to assist with weed management, particularly if this was done in conjunction with some sort of research project WA Parks did this successfully for many years with their Landscope Expeditions. People paid to assist with research that would otherwise not have been done at all. To minimise use of park resources, park management could set priorities and contract particular projects out to private enterprise. Not only would the work get done, but the park should be able to turn a modest profit.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.

Section 9.07 Neighbours, stakeholders and partnerships

Finally, with respect to Historic (Balanda) sites, surely this would be an ideal place to use outside volunteers at little or no cost to the park.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 9.07 Neighbours, stakeholders and partnerships

I made some suggestions in the previous section about how outside sources could assist with fire management. Another example which to me appears to be a failure to think outside the box came a year or two ago when I offered to bring a group in to help clear and re-mark a walking track. I was told that that wouldn't be a good idea as it would take employment from local Bininj. From an outside perspective, that seemed to be saying that the park had nothing else that those people could do. If Kakadu is to avoid becoming listed as 'World Heritage in Danger', park management will need to be prepared to use all the outside help that they can get for specific operations so that they can use their limited resources on things which would otherwise not get done. 

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

The park does obtain assistance from volunteer groups such as Conservation Volunteers Australia and uses a range of volunteers and contractors to provide assistance and expert advice.

Bininj do provide advice and assistance particularly where there are cultural sites or places that require a sensitive approach to undertaking. Bushwalking tracks often come within close proximity of sensitive cultural sites, therefore assistance from Bininj is, for the most part, essential.

Section 9.07 Neighbours, stakeholders and partnerships

1) I see the biggest threat to Kakadu as being political/financial. Park management is struggling now, a situation which I believe will get worse. Unless all governments come to see how much benefit Australia gets from international tourism and how cutting park budgets will damage this in the long term, I can’t see this getting any better. The only hope I can see is if Kakadu reaches outside the park to enlist support from volunteers, clubs and associations

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 9.07 Neighbours, stakeholders and partnerships

I have cited instances where I was able to offer support that could have freed park staff for other work. For whatever reason, those offers were refused. Park management needs to be flexible and look at every possible way to maximise the limited resources at their disposal or it is simply a matter of time before Kakadu becomes listed as a World Heritage property ‘In Danger’.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 9.07 Neighbours, stakeholders and partnerships

Why not use a bushwalking tour operator like Willis's Walkabouts to assist with fire management? Our liability insurance would cover this. The same would be true of any other tour operator doing similar work. People would feel involved. They would feel that they were doing something which would benefit the park. There is no one else on the ground in the wet season. Sometimes conditions would permit wet season burns, sometimes not. They would never permit a major fire to get out of control. Why not give it a try. it would cost nothing and would mimic what I believe was the most probable traditional burning pattern for the stone country.

Given the financial stress that the park is under, that would have to be a win-win situation for all concerned.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 10.13 Bringing plants and animals and other materials into the park

When I’ve stayed in caravan parks in Australia, I’ve often met grey nomads who are travelling with their dog. Most of these dogs are fairly small and well behaved. Many of those people wouldn’t dream of visiting Kakadu simply because they couldn’t bring their dog. I don’t know how much revenue the park is losing because of this, but it must be substantial.

People in Jabiru have dogs. People on outstations have dogs, often far less under control than the dogs accompanying people in their caravans. The Draft Plan notes, "Domestic dogs are often left unattended on outstations when people relocate either temporarily or permanently. The dogs are left to fend for themselves; they scavenge for food and may interbreed with dingoes and become a public safety risk especially around residential areas." If pet dogs are not going to be banned or even properly controlled in outstations or in Jabiru, where is the sense in banning them from the rest of the park?

Amended Section 10.13.8 to provide greater flexibility within the plan with regards to the entry of dogs in the future.


 

Plan reference

Comments in the submission

Response

Commercial tour operator (bushwalking)

Section 10.13 Bringing plants and animals and other materials into the park

Pet dogs would pose far less a danger to Kakadu’s wildlife than the wildlife would present to them. I think it would be worthwhile to run a trial where a few campgrounds and a few of the shorter walks were made dog-friendly for a year, or perhaps two so that the word could get out. People living in most Australian cities are accustomed to cleaning up after their pets. It should be the same in Kakadu. If Kakadu were to become the first major Australian park to do this, it would certainly help to counter the ‘Kakadon’t’ message that still exists. It would almost as certainly increase park revenue.

Given the state of park finances, I believe that anything which will increase revenue without detracting from park values needs to be considered.

Amended Section 10.13.8 to provide greater flexibility within the plan with regards to the entry of dogs in the future.

Palmerston (Darwin) resident and long term park user

Section 6.2 Commercial tourism development and management

Commercial tour operators should be reprimanded for clients doing toilet and leaving toilet paper in abundance on the side of the tracks etc. How about using a shovel, or have some sort of portable loo?

Amended Section 9.3 to include additional Action 9.3.7 Develop a range of ecologically sensitive practices to be included in permit conditions to assist in the appreciation and protection of park values.

Where evidence is found of such violations to permit conditions action would be taken by park management to ensure that 'leave no trace' practices are adhered to.

Section 7.1 Research and knowledge management

P20  The audits findings suggest that some aspects of Park Management could be improved. Long term local park users could be used for monitoring and reporting to Park Management. E.g. The effects of fire. Spread of exotic weeds; Illegal activities. No encouragement is given to locals to become involved at any level. Local park users could be the eyes and ears for park management i.e. reporting of illegal gill netting (it happens) & hunting. Weed infestations. Breaching bag limits, taking of undersize fish etc.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.


 

Plan reference

Comments in the submission

Response

Blue Mountains Conservation Society

Section 9.05 Assessment of proposals

The Society has a number of concerns about the capacity of the 6th draft Plan of Management (dPoM) for Kakadu National Park to adequately protect the heritage values of this extremely important area. Development in national parks, if it occurs, should be strictly controlled with a prescriptive and transparent assessment process, which allows for public exhibition and comment, and penalties for breaches of the prescribed standards.

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.

Section 9.05 Assessment of proposals

There should be specifically stated limits to activities which impact on a park’s heritage values, as is the case, for instance, for Kosciusko National Park in NSW in which specific bed numbers are stipulated.

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.


 

Plan reference

Comments in the submission

Response

Blue Mountains Conservation Society

Section 9.05 Assessment of proposals

In particular, the Society strongly believes that the 6th dPoM should be amended to include:

public listing and description of all development proposals together with the requirement of compulsory public exhibition of each proposal for comment; and,

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.

Section 9.10 Implementing and evaluating the plan

In particular, the Society strongly believes that the 6th dPoM should be amended to include:

provision for a “State of the Park” report during the period of the 6th dPoM that will provide benchmarks for the Plan’s policies and actions.

Amended Section 9.10.8 to include the preparation of a performance monitoring plan which will be used to monitor the performance indicators in the plan. A new action (9.10.7) was also added to specify how the Director of National Park’s will report to the public on performance monitoring in the park.

Bushwalking Australia

Section 7.1 Research and knowledge management

See comments regarding the use of volunteers under 5.2 above, which can also apply here too. It is likely that bushwalkers undertaking extended trips in the park will be the only visitors through those areas and therefore perfectly placed to assist in say identifying and reporting feral animals and invasive weeds.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.

Section 9.07 Neighbours, stakeholders and partnerships

Given the immense size and complexity of Kakadu, and the seemingly ever decreasing willingness of the community (and hence government) to provide adequate funds to manage protected areas, Kakadu park management should be looking to employ volunteers to undertake simple and routine works where possible and appropriate. Volunteers play an important role in national parks around the world, including in other parts of Australia.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.


 

Plan reference

Comments in the submission

Response

Bushwalking Australia

Section 9.07 Neighbours, stakeholders and partnerships

In Victoria for example bushwalking clubs and Bushwalking Victoria volunteers under Parks Victoria supervision, undertake activities such as track clearing, track making and constructions, weed removal and spraying and weed identification and mapping. Many of Victoria’s national parks have friends groups that contribute significant volunteer hours to the park they have adopted.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Section 9.07 Neighbours, stakeholders and partnerships

Many of the bushwalking visitors to Kakadu, whether walking independently or with a tour operator like Willis's Walkabouts are likely to be interested in contributing in a practical way to management of the park such as removing fuel from rock art sites in the remote areas they visit on their trip.

Amended Section 9.7.8 to foster and encourage relationships with volunteer organisations, groups and individuals that participate in and support park activities.

Nedlands (WA) resident, visitor and bushwalker

Section 7.1 Research and knowledge management

5.3 Managing park-wide threats affecting values

Bushwalkers go to places that park staff don’t regularly visit. I think it would be useful if bushwalkers were given a small info kit so they could report any sightings of non- native ants or weeds. It is conceivable that this would allow an infestation to be stopped before it got out of hand. Same goes for feral animal populations which seem to be on the rise- especially pigs.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.


 

Plan reference

Comments in the submission

Response

Nigthcliff (Darwin) resident

Section 5.3 Managing park-wide threats affecting values

Actions 5.3.5 “Develop a weed education programme for park residents, contractors, tour operators and visitors” (P 82) This is a great idea but is it going to be implemented?

Amended Actions 5.3.5 and 5.3.26 to develop and implement education programmes on weeds and fire.

Section 5.3 Managing park-wide threats affecting values

5.3.27 “(d) communicating the implications of, and our management response to, climate change.”

The above is a policy statement but there is no mention of this in the Actions. I would like to see this communicated to visitors as it maybe one way of showing the impacts of climate change.

Amended by adding a new action 5.3.35 for a communication activity similar to other threatening processes in the plan. Note that this activity is also listed under the current climate change strategy for the park.

5.3.35 Communicate information on the implications of, and the park’s management response to, climate change to park residents, contractors, tour operators and visitors.

Humpty Doo resident 2

Section 7.1 Research and knowledge management

Many locals feel that they have been forgotten by park management and are not considered as stakeholders. It is recognised that Kakadu is a National Park and first and foremost Aboriginal Land. However, there are locals with over forty years experience in use of the park who feel an attachment or affinity with this area also, although obviously not a cultural affinity. Nevertheless, these locals want to contribute and would, by and large, be willing ambassadors for the park, available for data collection with regard to weed infestation, feral animal location and numbers, unauthorised fires, illegal pig hunting and in conjunction with a checklist, monitoring of various other plants, animals or activities that Park Management does not have the resources to conduct.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.

Section 7.1 Research and knowledge management

P20 "The audit's findings suggest that some aspects of park management could be improved". The use of long term local park users for monitoring and reporting is a resource that is available to park management, but is totally ignored. Long term local park users often observe the effects of fire management practices, weed infestation, feral animal densities and illegal activities. There is no encouragement for locals to become involved at a practical level.            

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.


 

Plan reference

Comments in the submission

Response

Humpty Doo resident 2

Section 7.1 Research and knowledge management

7.1.9 (c) Members of the public, local park users could be helpful for monitoring a wide range of issues in the park. Check lists could be developed and supplied when permits are issued or even be readily available to those who not requiring a permit. The public could be made to feel that they are contributing to the welfare of the park. Many locals have accumulated a lot of knowledge over the years and although it may not be considered significant it would still contribute to data and statistics.

Action 7.1.12 added in response to several comments highlighting the significant role stakeholders can play in providing valuable information (e.g. incidental sightings) to park staff. The additional action has been added to include opportunities for citizen science in the park.

Section 9.07 Neighbours, stakeholders and partnerships

Many locals feel that they have been forgotten by park management and are not considered as stakeholders. It is recognised that Kakadu is a National Park and first and foremost Aboriginal Land. However, there are locals with over forty years experience in use of the park who feel an attachment or affinity with this area also, although obviously not a cultural affinity. Nevertheless, these locals want to contribute and would, by and large, be willing ambassadors for the park, available for data collection with regard to weed infestation, feral animal location and numbers, unauthorised fires, illegal pig hunting and in conjunction with a checklist, monitoring of various other plants, animals or activities that Park Management does not have the resources to conduct.

Amended by adding Section 7.1.12 to promote opportunities for citizen science in the park.

Professor - Institute for Culture & Society, University of Western Sydney

Section 4.3 Bininj/Mungguy training and other opportunities

The review [Technical Audit] also identified the need to establish a database of frequency and nature of training and development opportunities for Traditional Owners, in order to assess targets and achievements of the advancement of Traditional Owners into higher level Park service positions, and Guiding and Interpretation roles. This issue is not particular to Kakadu and warrants support and attention.

Amended plan by adding a new action to maintain a database of training and development opportunities for Bininj/Mungguy (Action 4.3.6).


 

Plan reference

Comments in the submission

Response

Karama (Darwin) resident

Section 6.2 Commercial tourism development and management

The commercial tour operators should be given a lesson in hygeine when taking people into the park. The amount of toilet paper left on the side of the road, always together, is a disgrace. Do as the long termers do when no facilities are available bury or take it with you.

Amended Section 9.3 to include additional Action 9.3.7 Develop a range of ecologically sensitive practices to be included in permit conditions to assist in the appreciation and protection of park values.

Where evidence is found of such violations to permit conditions action would be taken by park management to ensure that 'leave no trace' practices are adhered to.

Colong Foundation for Wilderness

Section 9.10 Implementing and evaluating the plan

We request that you amend the sixth Kakadu National Park plan of management so that it contains: • Directions for a state of the park report that will benchmark all actions and policies in the plan, to be produced within two years of the publication of the sixth plan of management.

Submission page reference: 2

Amended Section 9.10.8 to include the preparation of a performance monitoring plan which will be used to monitor the performance indicators in the plan. A new action (9.10.7) was also added to specify how the Director of National Park’s will report to the public on performance monitoring in the park.

Section 9.05 Assessment of proposals

The Colong Foundation is pleased that the sixth draft plan acknowledges the risk of proliferation of living areas in Kakadu. The draft plan notes that this proliferation should not be just a matter for consideration by the Board and the Director and has granted some rights for comment and review through environmental assessment under Category 3 actions. The other development actions in the plan should also be subject to public comment and review processes.

Amended by adding Section 9.5.6 to review the Environmental Impact Assessment guidelines for assessment of proposals. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.


 

Plan reference

Comments in the submission

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

The Colong Foundation considers there should be no development in national parks, but if there is to be development imposed upon a park, then a statutory (Black Letter) planning system, as opposed to a flexible strategic planning system, must regulate it. The citizens of Australia must be able to have certainty on the range and location of development permitted by the draft plan.

The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan. The Board considers that IUCN Category II National Park is not inconsistent with the management of activities in the park.

In response to the comments received on zoning the Board agreed to include in the management plan background information on the guidelines that the IUCN provides for assigning protected areas to zones, and clarification regarding the Australian IUCN management principles.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values.

In response to this comment, and other comments on the EIA process outlined in section 9.5 of the plan the following action has been inserted into Section 9.5:

Action:

9.5.6 As a matter of priority, review the Environmental Impact Assessment guidelines for assessment of proposals to ensure adequate protection of the park’s values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.


 

Plan reference

Comments in the submission

Response

Colong Foundation for Wilderness

Section 9.05 Assessment of proposals

We request that you amend the sixth Kakadu National Park plan of management so that it contains:

• A schedule of all development proposals indicated on a separate map and summarised in the text, with provisions to ensure that all these proposals are placed on public exhibition and subject to public comment and review, (not just category three proposed actions that will be subject to environmental impact statement processes);

Submissions page reference: 1

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.

Section 9.05 Assessment of proposals

The plan of management for any national park should not simply refer all development and use decisions to Board members without, at the very least, setting out public review procedures within a strong framework of nature-based prescriptions that regulate development and use. Draft plan six fails to do this, just listing a ‘cookbook’ for impact assessment of proposed actions, as if Kakadu were just any piece of ordinary land and not a World Heritage listed national park.

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.


 

Plan reference

Comments in the submission

Response

Colong Foundation for Wilderness

Section 9.05 Assessment of proposals

Under the proposed plan, the Board of Kakadu National Park can, for example, permit commercial 4WD tours or the construction of luxury camps and lodges in the current wilderness zone, without adequate public comment and review, as these actions are not category 3 actions.

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.

Section 9.05 Assessment of proposals

Flexible and discretionary development controls (i.e. described under this draft plan as adaptive management) are not acceptable for town planning, and will prove extremely detrimental to park management for the preservation of heritage values. The current administrative framework is toxic to mutual understanding by the Indigenous Bininj/Mungguy and Balanda. It is the people’s national park and they want it protected, under their lease. All Australians have a right to say how the park is regulated to ensure that protection. The development control arrangements proposed in the draft plan will one day fail Kakadu and will be exposed for what they are – a regime to facilitate park development.

Amended the plan to include a new action (9.5.6) to review the Environmental Impact Assessment guidelines for assessment of proposals as a matter of priority.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA in place under the plan are used to protect natural and cultural values. A review of the guidelines will include consideration of the need to seek public comment on certain classes of proposals, such as those which have more than a negligible impact to park values and are likely to be of public interest.

 


Appendix B – Public comments that did not result in changes to the management plan

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 1.4 Park values and local, regional, national and international significance

b. How Kakadu is significant nationally - why is recreation not mentioned? There is a distinction made in the previous section between tourism (presumably commercial) and recreation - why not here?

No change to the plan necessary.

Kakadu is significant regionally for recreation purposes because many people from Darwin and Katherine use the park for fishing, camping and bushwalking. In the national context, the park is a major tourism attraction for domestic and overseas visitors who come to view rock art and the natural landscapes.

Section 1.4 Park values and local, regional, national and international significance

The Values Statement is very comprehensive; however we note one important area in which it needs to be supplemented. One of the two purposes of establishing the park was for the encouragement and appropriate use, appreciation and enjoyment of the area by the public. The values statement and the policies and actions that cascade down from it, don’t reflect this emphasis on the public use and enjoyment. Whilst it may be implicit, the lack of explicit focus on this purpose is then diluted by the many other elements of the vision that are afforded explicit treatment.

No change to the plan.

The Board recognises the purposes for which the park was declared, including appropriate use, and is keen to develop tourism in the park and make Kakadu an exciting destination for visitors. In developing values statements for Commonwealth reserves there has been a conscious decision to only include those values that are in situ, the values that people come to see, the values that we strive to conserve and manage appropriately.

From this, we then consider how these values are utilised, through tourism, through research, through recreational and commercial activities. The natural and cultural values of the park are valuable for tourism, recreation and science.

Tourism and use of the park is appropriately addressed in the plan.

Section 1.4 Park values and local, regional, national and international significance

The public access and enjoyment need to be explicitly in the values statement to reflect its significance, and then this also needs to cascade down through the principles, policies and actions in the plan. Even though the plan is in the order of 250 pages long, this lack of emphasis in the Values Statement, leads to the primary explicit treatment of public recreational use only comprising about four pages of the plan – and in this there is no distinction drawn between non-commercial and commercial use and access. This is despite the fact the independent visitors constitute 2/3 of the visitors to the park.

We believe this is a significant omission that needs to be addressed.

No change to the plan.

The Management Plan for the park is an enabling document. It allows activities to occur that would otherwise be restricted by the EPBC Act and Regulations.

It is not necessary to describe each type of visitor to the park unless there are restrictions or special provisions in the EPBC legislation that need to be addressed.

Relevant tourism strategies and programmes for the park will address the special needs of visitors.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 1.4 Park values and local, regional, national and international significance

1.4 How Kakadu is significant regionally – Conservation

a. The statement “Kakadu is important for conservation in the region because it is a large area managed as a national park, whereas other areas of Top End habitats are managed primarily for purposes such as pastoralism, mining, or defence force use.” Omits mention of the very significant aboriginal land holdings in the region

No change to the plan.

The statement in the plan is about types of land use in the region. This is different from land tenure which is what is being suggested by the comment.

Section 2.2 Management plan framework

We note that the management plan uses the park values statement to establish the policies and actions needed to protect, present and understand the values of the park, with principles which apply to the management of all aspects of that section and then detailed policies and actions relating to particular issues. We note that the purpose for establishing the park was

- the preservation of the area in its natural condition.

- the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

No change to the plan. Statement only.

Section 5.1 Looking after culture

5.1.14 d - It might be helpful to broaden this to include any areas where people may access or be likely to access?

No change to the plan.

This matter is covered by the park compliance and enforcement strategy (Action 9.2.2) which includes actions to help address unauthorised access to areas in the park and installation of signage to indicate restricted areas (Action 5.1.15c).

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

Part C Managing Kakadu: needs an explicit section to address non-commercial recreation as per comments above. This is not the same as commercial tourism and so not adequately articulated currently in the plan. The current content does not adequately reflect one of the purposes for which the park was formed which was: “the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public”. A good example is Figure 13 which does not reflect non-commercial use, but does address commercial opportunities.

No change to the plan.

The Management Plan for the park is an enabling document. It allows activities to occur that would otherwise be restricted by the EPBC Act and Regulations.

The range of traveller types to the park is identified in Section 6.1 but it is not necessary to describe these in more detail unless there are restrictions or special provisions in the EPBC legislation that need to be addressed. The Tourism Master Plan (Action 6.1.6) will consider the specific needs of the range of traveller types to the park, including independent travellers.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

This lack of distinction between commercial and non-commercial visitation is further confused by the use of the word “tourism”. The word appears on many occasions to refer to commercial tourism (e.g. tourism industry), but on other occasions a broader use to include non-commercial visitors appears to be implied.

No change to the plan.

Covered by Section 6.2 that specifically relates to commercial tourism in the park. Section 6 of the plan relates to tourism in general and is not limited to Commercial or non-commercial tourism within the park.

The term "tourism" in the plan refers the practice of travelling (touring) for recreation, the provision of experiences that are appreciated by visitors (tourists) in the park and the guidance or management of visitors in the park.

Section 6.1 Destination and visitor experience development

In addition to being explicitly mentioned in the relevant part of the plan and principles and policies, there needs to be an additional section, or significant further elaboration of an existing section [re purpose of park - public access and enjoyment], which explicitly deals with this.

No change to the plan.

Public access and enjoyment are covered in Section 6 and specifically Section 6.1 which provides for visitor experience planning for a range of traveller types.

Section 6.1 Destination and visitor experience development

Another area which we would like to see the plan strengthen is in identifying the essence of what makes Kakadu special to the public and therefore needs to be preserved. The plan is well developed in relation to Binji and conservation, but not explicitly in relation to recreational users. Among the attractions to visitors is the isolation and natural beauty of the park. The plan doesn’t draw out what are the elements of this which are important to preserve except by saying that a goal of the establishment of the park was the preservation of the area in its natural condition. Without some definition of the essence that needs to be preserved to maintain the essential character and attraction of Kakadu, there is insufficient guidance provided by the plan to inform the management of the park about these things over the life of the plan. We believe it is important that the plan better articulates more of the essential essence that must be preserved in maintenance, upgrades and development of the park so that unguided maintenance doesn’t, through time, dilute important elements of visitor’s experiences.

No change to the plan.

The in-situ values of the park for visitors to experience are articulated in the values statement and throughout the plan.

There are a range of mechanisms to further describe and maintain the essential essence of the park including the Shared Vision for Tourism, the Tourism Master Plan (Action 6.1.6) and Visitor Experience plans for each precinct (Action 6.1.7). In addition there are other strategies that go into further detail such as the Cultural Heritage Strategy and the Walking Strategy. Each of these documents picks up on and supports or recommends the relevant actions to maintain that essential essence through protection of the park values.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.1 Destination and visitor experience development

Kakadu as a visitor experience destination, commercial tourism and promotion. In the objectives, vision etc, it doesn't articulate what is significant to preserve in terms of experience other than varied and enriching experiences as per comments above

No change to the plan.

The in-situ values of the park for visitors to experience are articulated in the values statement and throughout the plan.

There are a range of mechanisms to further describe and maintain the essential essence of the park including the Shared Vision for Tourism, the Tourism Master Plan (Action 6.1.6) and Visitor Experience plans for each precinct (Action 6.1.7). In addition there are other strategies that go into further detail such as the Cultural Heritage Strategy and the Walking Strategy. Each of these documents picks up on and supports or recommends the relevant actions to maintain that essential essence through protection of the park values.

Section 6.1 Destination and visitor experience development

ABS statistics show that the sales of SUV’s have trebled since 2000 illustrating the huge rise in the popularity of these vehicles in recent years. With the focus of the federal and territory governments on developing the north of Australia, we can expect a significant decrease in land available for recreational four wheel driving as land use changes. However, there have been no new four wheel drive opportunities opened in Kakadu in recent years. Instead road and track standards keep improving to the degree that some areas such as Maguk, which are still nominated as four wheel drive access, can now generally be accessed by a normal car.

No change to the plan.

Covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will consider 4WD touring, opportunities and experiences.

Section 6.1 Destination and visitor experience development

Even though it may seem that four wheel driving is synonymous with Kakadu, there are many people who visit Kakadu without a 4WD vehicle or trip. itineraries. Ubirr, Nourlangie and Yellow Water for example is wholly 2WD. Without specific focus and discussion on the role of the 4WD experience to visitors to Kakadu, the value of this may be eroded over time if it is not necessarily being given a deliberate strategy or adequately considered.

No change to the plan.

Covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will consider 4WD touring, opportunities and experiences.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.1 Destination and visitor experience development

There is a great opportunity for Kakadu to develop additional four wheel driving opportunities which are consistent with its guiding principles. One opportunity could be an iconic trip from Manyallaluk through Sleisbeck and Gimbat. This could even be promoted as an iconic route right through to the northern coast at West Alligator Head. Opening the old track from Manyallaluk into the south of the park would be a fantastic trip which would be very attractive to many four wheel drivers and open up a currently inaccessible part of the park. This new entry would have the potential to draw tourists into the south of the park and be consistent in trying to encourage an increase in visitation to that area. We understand that challenges relating to sickness country exist on this route but encourage the consideration of whether this opportunity could be developed.

No change to the plan.

Covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will consider 4WD touring, opportunities and experiences.

Section 6.1 Destination and visitor experience development

Opportunities could also be explored for access into other areas of the park which provide a four wheel drive experience through areas with minimal facilities.

No change to the plan.

Covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will consider 4WD touring, opportunities and experiences.

Section 6.1 Destination and visitor experience development

6.1 We would like to see a section added here about new and increased 4wd opportunities

No change to the plan.

Covered by the Tourism Master Plan (Action 6.1.6) and via precinct planning (Action 6.1.7) which will consider 4WD touring, opportunities and experiences.

Section 6.1 Destination and visitor experience development

The plan does not acknowledge the importance of swimming to the public in such a hot region. This should be developed further.

No change to the plan.

Covered by Section 6.1 that identifies swimming as a visitor experience.

Section 6.1 Destination and visitor experience development

6.1.10 Walking strategy – there is currently little published information on bushwalking in Kakadu yet it is a very popular activity. We understand there is reluctance amongst some of the Binji relating to publishing some of the routes, however the complete silence on this issue leads to impressions of secrecy. If specific things can’t be published, then the public need to be informed about this and why. As almost no information on walks is currently published, it makes it very difficult for the public to understand enough about the walks available.

No change to the plan.

Covered by Actions 6.1.7 and 6.1.10 where opportunities for more walking routes throughout the park will be considered in the walking strategy and through the precinct planning process.

Unsupported bushwalks in the park present a high level of risk to visitor safety and require a high level of experience. For these reasons overnight bushwalks are not promoted on the park website, however, interested walkers can make enquiries at the park.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.1 Destination and visitor experience development

[“Park management will aim to ensure that public areas are open to visitors for as long as possible each year.”] This is a prime issue for recreational users of the park and is an example of the type of issue that would be valuable to develop further in this plan.

No change to the plan.

Covered by Action 6.1.17 and further considered and addressed in the Tourism Master Plan (Action 6.1.6).

Section 6.1 Destination and visitor experience development

6.1.18 “Consider implementing staged opening of sites over the shoulder season and providing exclusive use or access to sites.” The issue of seasonal access and opening times could be further developed in the plan given its significance. In terms of exclusive access, we do not support commercial operators being given exclusive access to some parts of the park. This is a National Park which was established for the public and it should not evolve to be only accessible for those who have enough money to experience some areas.

We would support exclusive access for non-commercial groups who have demonstrated responsible behaviour.

No change to the plan.

Action 6.1.18 does not specify that exclusive access will be provided to commercial operators or any other specific group.

Section 6.4 Visitor information

Communication Opportunities

Communication – there is an opportunity to further develop communication with the public. Communication is currently directed at the commercial tourist industry (such as through the industry update) but the same focus does not apply to the public.

No change to the plan.

Covered by Action 6.4.4 Continue to provide up-to-date information to visitors using a variety of means, including social media, the website, the tourism industry, visitor information providers, visitor guides and park notes.

Section 6.4 Visitor information

Currently there are a number of areas in Kakadu that should only be access by 4WD. Each of these routes have different characteristics, levels of difficulty and vehicle requirements. This makes it difficult for visitors to know what to expect from each route, and what vehicle and skill level is needed for the different routes. This isn’t helped by the road to Maguk which is sign posted as 4WD only, but often accessible by normal vehicle nor by the enormous growth in types of 4WD vehicles in popular use – including ‘soft roaders’.

We suggest it would be helpful for visitors to be provided with clearer information on what they can expect and clearer information on what vehicles are suitable.

No change to the plan.

Comments noted. This matter is covered by the Tourism Master Plan (Action 6.1.6) which includes a recommendation to develop both a web page and park note addressing 4WD opportunities in the park. Also covered by Action 9.4.11 develop and implement a road management strategy for the park.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 6.4 Visitor information

We would like to see objectives in the plan to improve communication with the public in these areas [e.g. clearer information on what visitors can expect in terms of road types and clearer information on what vehicles are suitable].

No change to the plan.

This matter is covered by the Tourism Master Plan (Action 6.1.6) which includes a recommendation to develop both a web page and park note addressing 4WD opportunities in the park. Also covered by Action 9.4.11 develop and implement a road management strategy for the park.

Section 6.4 Visitor information

It would be great to make some information easier to obtain. e.g. to fill out a permit for Graveside Gorge you need to provide information including a map showing where you will camp – however until you have been there, how can you know where to camp without being provided information on suitable locations if you haven’t been there before? It’s a chicken and an egg situation that makes it unnecessarily hard for people.

No change to the plan. This issue will be addressed as part of the Walking Strategy under development (6.1.10).

Section 6.4 Visitor information

The web site (even though it has been redeveloped) makes it harder than it should to find information e.g. if someone wants to find information on a particular site, it not a very direct route to the information.

No change to the plan. This issue will be considered as part of the Interpretation Strategy being developed (6.4.3).

Section 6.4 Visitor information

There is no specific information on bushwalking available on the web site. Even though there is sensitivity amongst the Bininj for publicising some routes, better communication would be great so that the public have more opportunity to learn about the bushwalking possibilities in the park, what they offer, and how to access them. Where there are limits on the information that can be provided, it would be great to see this more clearly articulated so the public understand.

No change to the plan. This issue will be addressed as part of the Walking Strategy under development (6.1.10), which includes a commitment to improving communication about bushwalking opportunities in the park.

Section 6.4 Visitor information

Information on projected opening times is very valuable for the public to plan visits early in the dry season. Publication of historical and projected opening times would be most useful.

No change to the plan. The management plan includes a specific action on providing up to date information to visitors (6.4.4) and using best endeavours to ensure that public areas are open for as long as possible, particularly early in each year (6.1.17).

Section 8.2 Jabiru

8.2.10 Re Jabiru management: “The Director will only approve or proceed with a proposed action if it will provide more benefits than costs to the natural and cultural environment of the park, to Bininj/Mungguy, and to the appropriate use, appreciation and enjoyment of the park by the public.” This is a great objective. This objective should be at the top of objectives for the whole park and not just relate to Jabiru.

No change to the plan. Supportive comment.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 9.01 Safety and incident management

9.1 Safety and incident management

o “In a remote national park covering a large geographic area, response times to incidents can be lengthy due to difficult terrain, communications and mobilization of experienced and equipped staff. Mobile phone coverage in the park is limited and needs to be improved.” and

 “9.1.12 Work with government and non-government agencies and other stakeholders to improve mobile phone coverage in the park.”

Both these statements support increase mobile coverage in the park. However the remoteness is one of the allures of Kakadu. See previous comments about what makes Kakadu special and maintain the essence of why it’s there. We understand the pervasive role that digital technology plays in our worlds and particularly in the sharing of visitor experiences. We would like to see further development of the locations where experiences and areas of the park, will be maintained as isolated and without facilities such as mobile phone coverage. There are lots of ways to manage safety, and this has been done very well without mobiles for many years.

We encourage further development of this issue to further explore and acknowledge the benefits and implications of mobile phone coverage, and how assessment will be made of where remote experiences should be preserved from mobile coverage.

No change to the plan. This matter is covered by Section 6.1 which includes the tourism master planning and precinct planning processes. These processes will identify locations where experiences and areas of the park will be maintained as isolated and remote. Any measures to improve mobile phone coverage will be subject to the Environmental Impact Assessment process outlined in section 9.5, which aims to protect the highly significant cultural and natural values of the park, and consultation with traditional owners and approval of the Board.

Section 9.03 Authorising and managing activities

It would be great to see improvements to make it easier to obtain permits e.g. simpler ways to obtain available dates for permitted areas. Currently needing to make phone enquiries with permit staff is not very efficient for permit seekers or staff. Also the very extensive permit conditions and the requirement to sign legal deeds is quite bamboozling for the average member of the public who just want to go camping – particularly coupled with the several other documents issued with them. It would be desirable to see this more user friendly.

No change to the plan. The permit system will remain an ongoing requirement under the current legislation to allow a range of activities to be conducted within the Park. It exists as a mechanism to allow individuals, organisations and businesses to utilise the resources of the Park without undermining the values of the reserve.

Under Action 9.3.4 the park is committed to reviewing and, where possible, improving systems for the processing, administration and management of permits.


 

Plan reference

Comments in the submissions

Response

Four Wheel Drive Northern Territory – 4WD Club

Section 9.07 Neighbours, stakeholders and partnerships

In regards to the credentials of 4WD NT, we have an MOU agreement with NT Parks and Wildlife to enable our member clubs to actively participate in the opening of old disused tracks within the Northern parks and assist in the opening of public 4WD tracks each year after the wet season.

We are also being contracted to survey a 4WD route in the East Kimberly region of WA for the Indigenous land Corporation Perth Office. The purpose of the route is for Tourism.

No change to the plan. Commentary only.

The Director acknowledges the credentials of 4WD NT and looks forward to further developing a relationship with them over life of the 6th plan. This has begun already with 4WD NT taking up a position on the Kakadu Tourism Consultative Committee.

Section 9.07 Neighbours, stakeholders and partnerships

4WD NT represents the views of a large stake holder group for the Kakadu area. We are available and keen to provide consultation and advice to Park management as and when considered appropriate.

No change to the plan.

The Director acknowledges the credentials of 4WD NT and looks forward to further developing a relationship with them over life of the 6th plan. This has begun already with 4WD NT taking up a position on the Kakadu Tourism Consultative Committee.

General comment

This lack of emphasis on the public was also reflected in the stakeholder engagement process for this plan. Unlike other key stakeholder groups, there was no structured consultation with the public during the development of the plan or the public review period.

We would encourage an increased focus on the public to convey the message that they are a priority for Kakadu.

No change to the plan. The public were invited to submit comments towards the development of the draft management plan on 29 February 2012. All of the comments received through that consultation period were considered in the development of the management plan.

Under the EPBC Act only 30 days must be provided for public consultation on management plans. However in recognition of the high level of public interest in the Kakadu management plan the Board opted to make the plan available for public comment for over 70 days. The public consultation period on the draft management plan ran from 3 December 2014 to 14 February 2015, providing 73 days for the public to comment on the plan.

General comment

In the Fact Sheet on the Management Plan it says “Park management will aim to ensure that public areas are open to visitors for as long as possible each year.” (Action 6.1.16) (It actually refers to 6.1.17)

No change to the plan. The suggested edit relates to the factsheets supporting the draft plan and are acknowledged. They will be considered when the factsheets are revised upon finalisation of the plan.


 

Plan reference

Comments in the submissions

Response

Aboriginal Areas Protection Authority

Section 5.1 Looking after culture

The AAPA looks forward to exploring, addressing and enhancing its relationship and partnership with Kakadu National Park under the 6th Plan of Management. We are happy to make ourselves available to discuss any aspect of this submission.

No change to the plan.

The Director acknowledges this offer of support which will be considered during the life of the plan.

Section 5.1 Looking after culture

(b) Parks staff need to be aware that many high-use areas of the Park are sacred sites or have sacred sites nearby, and that management activities at these areas need to be cognisant of the NTASSA (exemplified by the Gunlom tree incident in May 2013);

No change to the plan.

Action 4.2.10 In consultation with NLC, review cultural protocol documents (including Sickness Country protocols and Indigenous research protocols), and consolidate where possible to ensure decision-making and other activities on the ground are guided by appropriate protocols and in a consistent manner.

Section 6.1 Destination and visitor experience development

6.1.10 notes the bushwalking strategy, AAPA considers that it has a critical role to offer in the development of this strategy to ensure that sacred sites are avoided or accessed in a ways considered appropriate for Bininj/Mungguy.

No change to the plan.

The draft walking strategy was developed in consultation with a steering committee and other key stakeholders and was released for public comment early in 2015.

Section 7.1 Research and knowledge management

7.1 of the Draft Plan details research priorities and knowledge gaps with the stated policy at that Park management is based upon the best available evidence. AAPA is concerned that neither the Kakadu Board of Management or the Kakadu Research Advisory Committee (KRAC) have any form of communication with AAPA.

We consider this problematic on two levels:

(a) Research projects and activities may be approved which could facilitate entry or work on sacred sites within Kakadu; and

(b) Research projects conducted or fostered by AAPA aimed at recording and registering sacred sites, and thereby targeting knowledge (and management) gaps, as well as contributing to the maintenance and intergenerational transmission of cultural knowledge, are not being considered.

No change to the plan. Kakadu National Park has stringent processes in place to manage the areas accessed by researchers working in the park. The plan contains provisions for working in partnership and collaborations in undertaking research and monitoring activities in Kakadu National Park (Policy 7.1.4).

Aboriginal Areas Protection Authority

Section 7.1 Research and knowledge management

AAPA considers that Policies 7.1.1 and 7.1.4 (along with other comment in this submission) demonstrate a need to enhance the relationship with AAPA so that appropriate sacred site research and management advice in Kakadu can be funded and undertaken.

No change to the plan. The need to enhance the relationship with AAPA is recognised in sections 4 and 5 of the management plan.


 

Plan reference

Comments in the submissions

Response

Amateur Fishermen's Association of the Northern Territory

Section 5.3 Managing park wide threats

AFANT strongly supports recreational fishing practices that are low impact, sustainable and ensure a high quality experience whilst protecting the special natural assets of the Kakadu NP.

We would be the first organisation to support or recommend measures to address actual identified impacts or sustainability concerns.

No change to the plan.

Comment noted.

Section 5.3 Managing park wide threats

In regards to research into the impact of fishing pressure and boat traffic on bank erosion (5.3.40) AFANT believes that Kakadu NP has had the opportunity to conduct research into these issues more so than other areas of the Northern Territory with a number of areas off limits to recreational fishing and boating but we are surprised that this has not been undertaken when this was the justification for the closure of rivers like the west alligator.

No change to the plan.

Comment noted. Action 5.3.42 commits to monitoring the impacts of recreational fishing in the park which will inform the review of recreational fishing prescribed in Action 6.1.11. These actions are a priority in the sixth plan.

Section 5.3 Managing park wide threats

While the draft plan does not specify access or restricted areas for recreational fishing other than the current areas that remain open the draft does make a number of negative comments regarding concern with fishing pressure and number of boats. AFANT notes that these comments are not based on any scientific research or justification which is a concern.

No change to the plan.

Statements about fishing pressure and number of boats are based on observations during compliance activities, visitor comments and concerns raised by Bininj in consultations during the preparation of this plan.

Section 6.1 Destination and visitor experience development

AFANT also has concerns regarding the comments within the draft plan regarding recommending recreational fishers avoid areas such as bird rookeries on the East Alligator and South Alligator rivers.

No change to the plan.

Covered by Action 6.1.12 that confirms recreational fishers in the park will continue to be encouraged not to disturb bird rookeries. This approach ensures that surrounding areas remain open for fishing.

Section 7.1 Research and knowledge management

AFANT would also like to offer our members services as volunteers for fisheries tagging or catch and effort data collection, this is research which we currently undertake in a number of river systems across the Northern Territory and we believe targeted research in Kakadu could provide valuable information to parks management on the state of fish stocks.

No change to the plan. The plan contains provisions for working in partnership and collaborations in undertaking research and monitoring activities in Kakadu National Park (Policy 7.1.4).

Section 10.7 Recreational activities

AFANT would like to work with traditional owners and park managers in the process of reopening the waters that were closed on the basis of the now non-existent risk of salvinia spread.

No change to the plan.

This issue will be considered under the review of fishing and boating in the park (Action 6.1.11) and policies 4.1.4 and 9.7.3 which provide for consultation with stakeholders where their interests are likely to be affected.


 

Plan reference

Comments in the submissions

Response

Amateur Fishermen's Association of the Northern Territory

Section 10.7 Recreational activities

AFANT believes that the following areas should be considered for improving access:

• Island billabong

• Jabaluka billabong

• Ja Ja billabong

• Magela billabongs south of the Oenpelli Road

• Nourlangie River below Anbangbang billabong

• Extension of the access at the top of the South Alligator River to take in the 2km above the current closure

• Jim Jim upstream of the communities

• West Alligator River

No change to the plan.

This issue will be considered during the review of fishing and boating in the park (Action 6.1.11).

Section 10.7 Recreational activities

AFANT would also like clarification on the purpose of the provisions that allow the implementation of a licence system in the park.

No change to the plan.

Provisions in 10.7.17 that allow the implementation of a licence system give the Board flexibility to introduce one if needed. This is the same provision that was in the fifth plan.

Section 10.7 Recreational activities

AFANT supports the review of areas within the park and would welcome the opportunity to be involved as a key stakeholder. We believe that some of the areas that are currently closed on the east of the Kakadu highway could be opened up to land based lure and fly only catch and release fishing, with negligible impact on the fish stocks. Exclusions could be put into place around swimming areas or high tourist areas.

No change to the plan.

This issue will be considered during the review of fishing and boating in the park (Action 6.1.11) and in accordance policies 4.1.4 and 9.7.3 which provide for consultation with stakeholders where their interests are likely to be affected.

Section 10.7 Recreational activities

AFANT has identified a number of billabongs and areas that are currently closed or without access that with the implementation of reasonable management arrangements, could be reopened to recreational angling whilst still protecting the values and principles of the national park.

No change to the plan.

This issue will be considered during the review of fishing and boating in the park (Action 6.1.11).


 

Plan reference

Comments in the submissions

Response

Amateur Fishermen's Association of the Northern Territory

Section 10.7 Recreational activities

AFANT believes that the current areas that are closed in the park are not clearly defined or explained and justified and AFANT believes that clearer maps and information for recreational anglers is required.

No change to the plan.

This issue will be considered during the review of fishing and boating in the park (Action 6.1.11).

Maps indicating where recreational fishing is presently allowed are available to members of the public on the website and in park notes.

The plan states that determinations in effect at commencement of the plan that relate to recreational fishing (including areas closed) will continue to apply unless varied by a future determination. This gives the Board flexibility to review the areas where people can fish and boat during the life of the .plan.

Section 10.7 Recreational activities

AFANT would like clarification on the ability of the Director to change rules in the park (10.7.15) and what consultation agreement and process will be undertaken before any change which may impact on recreational fishing and boating access or operation.

No change to the plan. This comment is seeking clarification only.

Policy 10.7.15 gives the Director the ability to prohibit or regulate the use of vessels in the park. This gives the Board flexibility to prohibit or regulate the use of vessels during the life of the plan if needed.

Consultation processes for any changes in park rules that may impact on stakeholders are comprehensive and clearly identified in Section 4.1.4

Section 10.7 Recreational activities

While we accept the need for flexibility within the plan over its lifetime and the ability of parks management to make required changes based on unforseen issues, AFANT has real concerns with some clauses in the draft that could have a negative impact on recreational fishing within the Kakadu national park.

No change to the plan. Statement only.

The Board needs flexibility over the life of the plan to make changes based on unforseen issues.

This issue will be considered in the review of fishing and boating in the park (Action 6.1.11). Consultation processes for any changes in park rules that may impact on stakeholders are comprehensive and clearly identified in Section 4.1.4.

Section 10.7 Recreational activities

A number of provisions within the plan which would seem to allow the director to make significant changes to boating or fishing in the park with limited consultation are a real concern.

No change to the plan. Statement only.

Consultation processes for any changes in park rules that may impact on stakeholders are comprehensive and clearly identified in Section 4.1.4.

Section 10.7 Recreational activities

AFANT also questions the provisions to allow the carriage of mud crab pots through the park for their legitimate use outside the park boundary’s without a similar provision to allow the carriage of a legal catch of mud crabs

No change to the plan.

The plan clearly states that crabs cannot be lawfully taken within the park, but fish can.

If someone is transporting crabs through the park it is impossible to determine if the crabs were caught in the park or outside the boundaries of the park. To assist in compliance activities within the park, it is necessary to prohibit the transit of crab catch into/through the park.


 

Plan reference

Comments in the submissions

Response

Amateur Fishermen's Association of the Northern Territory

Section 10.7 Recreational activities

We would welcome the opportunity to provide additional information or to discuss any of the issues raised in this submission.

No change to the plan. Statement only.

Section 10.7 Recreational activities

AFANT welcomes the opportunity to comment on the draft plan of management for Kakadu National Park.

No change to the plan. Statement only.

Section 10.7 Recreational activities

The rivers and billabongs in Kakadu are some of the most important areas for recreational fishing in the Northern Territory and as such AFANT has a strong interest in ensuring the best outcomes for recreational fishing are delivered in the management plan.

No change to the plan. Statement .only.

Consultation processes for any changes in park rules that may impact on stakeholders are comprehensive and clearly identified in Section 4.1.4.

Section 10.7 Recreational activities

The recreational fishing sector has some significant areas of Kakadu that are off limits, we are strongly of the view that management of access not exclusion of recreational fishing from areas will deliver the best benefit not just for the recreational fishing but also the future visitation, management, public standing and use of the park.

No change to the plan.

This issue will be considered under the review of fishing and boating in the park (Action 6.1.11).

Section 10.7 Recreational activities

Like many areas across the Territory, Kakadu NP has seen an increase in fishing effort. This is predominantly managed in the NT with possession limits. With the exception of reef fish species like snapper and jewfish, the sustainability of fish stocks in the NT is very good and the current possession limits of fish like barramundi are sufficient to manage the stocks and leave a significant buffer to ensure quality fishing is available into the future.

No change to the plan. Statement only.

Section 10.7 Recreational activities

AFANT is strongly of the view that spreading the recreational fishing effort through improvements to accessible areas has the potential to improve the Kakadu recreational fishing experience and reducing any real or perceived fishing pressure concerns.

No change to the plan.

This issue will be considered under the review of fishing and boating in the park (Action 6.1.11). The management plan does not set the restrictions for fishing and boating access in the park.

Section 10.7 Recreational activities

AFANT has concerns that areas closed to recreational fishing/boating due to salvinia which was first detected in the Magela catchment in 1983 have remained closed in the park, although it is acknowledged that salvinia has since still spread through a range of areas where it was not previously present and that the transfer or spread was most likely due to water birds or other vectors.

No change to the plan.

This issue will be considered under the review of fishing and boating in the park (Action 6.1.11).

The spread of salvinia within the park remains a significant concern and there is a high likelihood of increased spread through boat infestation and turbulence.


 

Plan reference

Comments in the submissions

Response

Amateur Fishermen's Association of the Northern Territory

Section 10.7 Recreational activities

The justification for closures of fishing areas to prevent salvinia spread was based on the perceived risk of boats and trailers spreading the weed. While we acknowledge that salvinia can be spread by vessels, it is currently established in all waters open to recreational fishing vessels as well as a number of closed waterways and this spread has not been attributed to boat trailers.

No change to the plan.

This issue will be considered under the review of fishing and boating in the park (Action 6.1.11).

The spread of salvinia within the park remains a significant concern and there is a high likelihood of increased spread through boat movement and turbulence.

Section 10.7 Recreational activities

The proposal in the draft plan for the reduction in the possession limit of barramundi from 5 to 3 (10.7.17) in Kakadu, while not based on current sustainability concerns, is supported by AFANT as a prudent management tool change to ensure the protection of the barramundi stocks. AFANT believes that this change will add value to the Kakadu barramundi fishery whilst still allowing anglers to retain a reasonable number of fish for the table.

No change to the plan. Supportive comment

Blue Mountains Conservation Society

Section 3. General provisions and IUCN category

In particular, the Society strongly believes that the 6th PoM should be amended to include:

a zoning table and maps to protect its heritage values, particularly those of wilderness, from the adverse impacts of visitor facilities;

No change to the plan.

The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 9.05 Assessment of proposals

In particular, the Society strongly believes that the 6th dPoM should be amended to include:

prohibition of new visitor accommodation and roads;

No change to the plan. The Board does not support the prohibition of new visitor accommodation and roads but proposed new accommodation or roads are assessed in accordance with the environmental impact assessment (EIA) process outlined in section 9.5.


 

Plan reference

Comments in the submissions

Response

Bushwalking Australia

Section 1.1 A description of Kakadu National Park

Bushwalking Australia endorses the description of Kakadu National Park and the Values Statement.

No change to the management plan necessary. Supportive comment.

Section 4.1 Making decisions and working together (Board of Management)

Bushwalking Australia (BA) supports joint management of Kakadu in cooperation between the traditional owners and the Australian National Parks Service.

No change to the plan. Supportive comment.

Section 4.1 Making decisions and working together (Board of Management)

However BA feels that many visitors and potential visitors view joint management as resulting in opaque and overly bureaucratic decision making and too many complex rules and restrictions especially when compared to other national parks. We believe that the level of knowledge and understanding of the number of traditional owner groups involved, their differing aims, desires and concerns for the cultural and natural environment in the park, and the extensive consultations this must inevitably require, could and should be made better known to visitors it must not only cost substantially more to run the park under this model, but the decision making processes must also take considerably longer than in comparable situations.

No change to the plan.

This plan and other park communication material available for visitors do describe the joint management process. An interpretation strategy will be developed and reviewed under Section 6.4 and consistent with the key messages in Section 6.3.1.

Section 5.1 Looking after culture

Bushwalking Australia believes that more can and should be done to better educate visitors concerning the deep emotional and spiritual connections and traditions that Bininj/Mungguy have with country and cultural sites.

No change to the plan.

This matter is covered by the park interpretation strategy (Action 6.4.3) and the park signage project (Action 6.4.10).

Section 5.3 Managing park-wide threats affecting values

Bushwalking Australia also believes that there is a role for suitably skilled and qualified contractors, under supervision, in managing threats, for example from feral animals such as pigs and cats.

No change to the plan. The plan does not prohibit engagement of contractors to assist in managing threats.

Section 6.1 Destination and visitor experience development

To maximise the number of bushwalking visitors to Kakadu, and to encourage them to stay longer in the park, Kakadu needs to offer a range of opportunities from short walks of an hour or so, tho day walks, walks of two to three days and extended walks.

No change to the plan.

Covered by Actions 6.1.7 and 6.1.10 where opportunities for more walking routes throughout the park will be considered in the walking strategy and through the precinct planning process.


 

Plan reference

Comments in the submissions

Response

Bushwalking Australia

Section 6.1 Destination and visitor experience development

Bushwalking Australia (BA) notes that over the life of the plan, new experiences will be considered consistent with this plan. While BA is supportive of new experiences being developed, we are also keen to see better management and administration of existing experiences to encourage and facilitate more people to visit and experience Kakadu.

No change to the plan.

Covered by Action 9.3.4 which commits to reviewing and, where possible, improving systems for the processing, administration and management of permits. Also Actions 6.1.7 and 6.1.10 where opportunities for more walking routes throughout the park will be considered in the walking strategy and through the precinct planning process.

Section 6.1 Destination and visitor experience development

The author of this submission first visited Kakadu in 1987, has returned several times since that time and has travelled extensively in outback Australia. The view of Kakadu as Kakadon’t has gained currency over that time and is now quite common. The reasons for this are many and complex and some are mentioned elsewhere in this submission.

No change to the plan. Commentary only.

The current practice of managing access within the park is a result of the recognition of the significance of the World Heritage values of the park and reflect best practice.

Section 6.1 Destination and visitor experience development

Most visitors have little understanding or appreciation of the reasons behind access restrictions, believing that they are arbitrary and overly restrictive and contributes to the widely held and widely repeated Kakadon’t message often referred to by travellers.

No change to the plan.

The current practice of managing access to the park is a result of recognition of the significance of the World Heritage values of the park and reflect best practice and this message is conveyed through information available to visitors. The potential for opening up new areas is considered through the Visitor Experience/ Precinct Planning process (Action 6.1.7).

Section 6.1 Destination and visitor experience development

It would help if there were more approved routes. It should be possible to identify and map routes that avoid sites of significance.

If people saw more areas being opened than closed, it would be one more thing to counteract the 'Kakadon't' message which is encountered all too often.

No change to the plan.

Covered by Actions 6.1.7 and 6.1.10 where opportunities for more walking routes throughout the park will be considered in the walking strategy and through the precinct planning process.

Section 6.1 Destination and visitor experience development

Bushwalkers are by nature independent, self-reliant and adventurous. Kakadu offers opportunities to experience a unique combination of a near wilderness environment, stunning landscapes and the cultural history of the traditional owners and custodians of the land. Most bushwalks are of short duration, often of less than a day. Most bushwalkers only undertake walks of up to one day’s duration, and even those who prefer overnight or extended walks will undertake short walks too.

No change to the plan. Commentary only.

Section 6.2 Commercial tourism development and management

Bushwalking Australia (BA) recognises that commercial tour operators play an important role in providing visitor experiences in the park, including bushwalking. BA is not opposed to the licensing of additional commercial operators in the park, provided that they are properly accredited and managed.

No change to the plan. Supportive comment.

Plan reference

Comments in the submissions

Response

Bushwalking Australia

Section 6.2 Commercial tourism development and management

Bushwalking Australia fully supports efforts and initiatives that will facilitate the establishment and development of Bininj/Mungguy tourism opportunities, so long as they do not impact negatively on the environmental and cultural integrity of the national park.

No change to the management plan. Section 9.4 sets environmental impact assessment processes for new development proposals in the park.

Section 6.3 Promotion and marketing

One of the contributory factors is the lack of awareness by many visitors of seasonal changes and of the good reasons to visit Kakadu in each-season that should be promoted more widely. For example, too much of the promotion and marketing information seen by potential visitors feature stunning wet season images of attractions such as Jim Jim Falls and Twin Falls. Dry season visitors are therefore disappointed and worse when they discover that these features do not look anything like the marketing.

No change to the plan.

Covered by actions in Section 6.1. including Action 6.1.8 Investigate, develop and implement strategies to increase annual visitor numbers to the park, the spread of visitor numbers across the seasons and the average length of stay in the park; and Action 6.3.2 Liaise with the tourism industry to ensure that promotion of the park helps to create appropriate visitor expectations about all activities including awareness of seasonal changes and unique opportunities for visitors throughout the year.

Section 9.01 Safety and incident management

“Bininj/Mungguy feel a sense of responsibility for all people visiting their country, and feel distressed if a visitor is injured or dies.”

While this may be known by some visitors, Bushwalking Australia believes that most visitors do not know this, and even those that do, do not really understand. It is probably impossible for a Balanda to fully understand the effect on a traditional owner should a visitor be injured or die however we strongly encourage park management to provide more information on this on the Kakadu web site and especially to those visitors applying for walk permits.

No change to the plan. This matter is covered by Section 9.1 Safety and incident management and specifically Actions 9.1.10 and 9.1.11 about communicating the importance of staying safe in the park.

Section 9.01 Safety and incident management

Every bushwalk undertaken by every bushwalker involves a level of risk management, with the longer and more difficult (and more remote) the walk, the more risk that needs to be understood and managed. However even on the best organised, best planned walk by the most experienced and prepared bushwalkers, accidents can and do occur.

BA endorses the current requirement that all groups undertaking overnight walks in Kakadu carry at least one Personal Locator Beacon (PLB) or satellite phone.

No change to the plan.

Safety and incident management including communication with visitors is covered by Section 9.1.


 

Plan reference

Comments in the submissions

Response

Bushwalking Australia

Section 9.03 Authorising and managing activities

The current process for applying for a bushwalking permit is widely seen in bushwalking circles as being complex, unwieldy, unfair and not transparent. It is deterring visitors and adding to the idea of Kakadon’t in the bushwalking community. This must change.

No change to the plan. The permit system will remain an ongoing requirement under the current legislation to allow a range of activities to conducted within the Park. It exists as a mechanism to allow both individuals, organisations and businesses to utilise the resources of the Park without undermining the values of the reserve.

Under Action 9.3.4 the park is committed to reviewing and, where possible, improving systems for the processing, administration and management of permits.

Section 10.7 Recreational activities

For a start, details of walking routes that can be booked must be made available online. An on-line map of approved/available routes with information on availability included. Applying for a permit and/or booking camp sites in particular is becoming common across Australia and is something that most bushwalkers accept.

No change to the plan.

The park does not provide a map of approved routes and campsites on-line because overnight bushwalking, and bushwalking in remote and off-track areas in Kakadu presents a much higher level of risk to visitor safety than marked walks. These walks can be physically demanding and require a high level of navigation skills. By not advertising the routes, people are required to do their own research and talk to local clubs to find out about the routes. Applicants need to demonstrate they meet the required level of preparedness and skill before a permit can be issued.

Walking in the park will be managed under the walking strategy (Action 6.1.10). Consideration will be given to some of the issues around walking routes and permits.

Section 10.7 Recreational activities

A permit fee or security bond refundable on completion of the planned trip might discourage speculative booking and permit holders doing the wrong thing on their walk such as visiting sensitive or unauthorised sites.

No change to the plan. Issues around bushwalking permits will be considered in the walking strategy (Action 6.1.10).

General comment

The Draft Management Plan is a large and complex document reflecting the size and complexity of the national park itself.

BA sought comment, suggestions and ideas on the draft plan from the bushwalking community across Australia however the number of responses received have been small.

No change to the plan. Commentary only.

The plan itself is a legislative instrument and enables activities otherwise restricted by EPBC Legislation. It covers the management of the park for a 10 years period and could not be condensed further.

The plan recognises the importance of Kakadu as a destination for bushwalkers and visitor experience plans being developed for precincts (Action 6.1.7) will explore new opportunities for bushwalking in the park as will the walking strategy (Action 6.1.10).


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

The removal of park zones has not resulted in more park visitation, which has declined over the last ten years. The costs of effective park management have increased, with the emergence of new threats to heritage values from new invasive species.

Submission page reference: 1

No change to the plan. The plan identifies that visitation started to decline around 2009 due to a number of factors including the effects of the global financial crisis. The plan does not suppose that park visitation has been effected by the removal of park zones (that were used in the 4th management plan for the park).

Section 3. General provisions and IUCN category

The location of proposed living areas should be defined by a zoning map, along with resorts and other commercial activities. Figures 2 and 16 and section 9.5 are not adequate to track these matters. This non-regulation of extensive and intensive visitor use and tourist infrastructure development is unacceptable for a national park.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

Commercial tourism can be almost as damaging as mining to Kakadu National Park. Large concentrations of people mean lots of sewage, sealed roads, an airport, clearing, large resorts and infrastructure, power lines, telephones, mountains of rubbish and all the air conditioned comforts of home. It was and is madness to remove the park’s zoning scheme, particularly the wilderness zone. The public have no certainty regarding the future protection, development and use of the park.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

The description given to adaptive management (page 147) fails to acknowledge that such regulation does not protect any part of the national park from any particular class of development or actions permitted under the Environment Protection and Biodiversity Conservation Act and its regulations.

Submission page number: 2

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

Without a zoning map the Board and Director are made vulnerable to unreasonable political pressure and demands of the day. The draft plan of management continues to allow park management operations to be politicised and unfortunately enables the Director to make decisions some of which will inevitably be construed as unreasonable and controversial.

A plan with zones is or should be a shield that will defend the park (and its managers) from political expectations of the day.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

An equivalent town plan to the Kakadu draft plan, for say Darwin, would be a blank map. In other words, the sixth draft plan gives carte blanche, a free hand, within the bounds of the law, to the Board and the Minister, and this is an unacceptable. A plan of management for a national park should be prescriptive and define what activities should take place and where these activities should occur. The Board and the Minister should be required to place these intentions on the table through the plan. The draft sixth plan of management is not a plan in the town planning sense.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

The ecological and technological footprint of a settlement usually increases through time. It follows that over time Kakadu will have a growing number of increasingly sophisticated villages, along with a growing number of roads and more infrastructure. The sixth draft plan fails to regulate this, except to require environmental assessment, abdicating any responsibility for the location of these activities, something no town plan for a settlement in Australia would do. In other words, the draft plan unfairly disadvantages heritage values in the national park by not providing protection that in other areas of Australia is mandated through town plans. This is unfair and unreasonable.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

There are no prescriptions in the draft plan as to where intensive or moderate use areas will be located. Development could take place anywhere under the life of the sixth plan of management. This is highly undesirable because it provides no certainty for the protection of the park’s heritage values. In effect, any part of the national park could be developed as an intensive use zone to the detriment of heritage conservation.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

Given that development has already taken place in Kakadu, zoning and land use tables can and should require the protection of heritage values and limit the intensity of permitted activities. Without these provisions, the public can have little confidence in the park’s future management.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

It may be that Kakadu should be reclassified as a regional park or Indigenous reserve if these developments continue as they are incompatible with national park status.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

The Colong Foundation for Wilderness believes that Australia’s premier national park, Kakadu, is not adequately protected by the fifth plan of management or the draft sixth plan. The fifth draft plan of management removed all zoning controls and the table of defined permitted activities within each zone. Removal of these zones by plan five has placed the preservation of the park’s heritage values at risk.

Submission page reference: 1

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

We request that you amend the sixth Kakadu National Park plan of management so that it contains:

• A zoning table and zoning map, securing protection of its heritage values, particularly its wilderness values from inappropriately located visitor facilities (i.e. reinstate Zone 4 from the fourth plan);

Submission page reference: 1

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan.

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

The prior removal of zones made development control in this national park far less prescriptive and it concentrated power in the hands of the Board and the Director of National Parks. The Colong Foundation strongly objects to this concentration of power and the contingent erosion of statutory protection afforded this World Heritage listed national park.

Submission page number: 2

No change to the plan.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan ensures protection of natural and cultural values.

Section 3. General provisions and IUCN category

Wilderness protection in Kakadu National Park should be reinstated as a matter of priority and greatly expanded to protect environmentally sensitive park areas and to protect them from increasing development pressures that are proposed to be facilitated by the draft plan under section 10.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 3. General provisions and IUCN category

Wilderness management is the highest possible standard of conservation because it precludes all forms of development. The fact that Aboriginal people lived in it is testimony that wilderness and traditional Aboriginal land use are compatible (provided the use of permanent dwellings, vehicles and guns is not encompassed in the definition of traditional land use).

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

Section 3. General provisions and IUCN category

It is also completely unacceptable to establish park visitor ‘safari camps’ in an ad hoc manner as the Board and Director see fit. These kinds of developments should be subjected to zoning regulation, to decide whether these facilities should be established at various locations or not. There should not be an endless proliferation of camping areas. New areas should not be established, except through definite proposals indicated in the draft plan and on a map. As no developments are indicated, there should be none developed during the life of this plan.

No change to the plan. The Board resolved that the park continue to be assigned to the IUCN category II – national park and the park should not be divided into zones by the management plan

The category to which the park is assigned is guided by the purposes for which the park was declared. The Environmental Reform (Consequential Provisions) Act 1999 deems the park to have been declared for the following purposes:

 - the preservation of the area in its natural condition

 - the encouragement and regulation of the appropriate use, appreciation and enjoyment of the area by the public.

This is equivalent to IUCN category II - National Park.

Section 6.1 of the plan provides actions for visitor experience development. It provides for precinct planning (see action 6.1.7). Through the development of precinct plans decisions will be made by the Board and the Director about the areas in which particular visitor experience developments will be considered.

The environmental impact assessment (EIA) process outlined in section 9.5 of the plan are rigorous, and the Guidelines for EIA (2008) in place under the plan help to ensure protection of natural and cultural values.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 4.1 Making decisions and working together (Board of Management)

In most of Australia development control on private land is vested in local government. Where there is a conflict of interest in development control under local government, those with interests are required to declare them and not partake in related decision-making. The current administrative arrangement of the Board is open to the risk of corruption. There needs to be a separation of decision-making from land owners, regardless of the issues of land rights. The protection of decision-makers from temptations of self-interest is important to ensure due process.

No change to the plan.

The Board of Management has an agreed set of meeting rules supported by the EPBC Regulations which require members to declare any conflict of interest.

Section 4.1 Making decisions and working together (Board of Management)

There are several Aboriginal groups in Kakadu and each has different ideas as to what development within the park is appropriate. There are for example land trust areas and three land claim areas shown on Figure 3 in the draft plan (page 8). Some groups are no doubt more preservationist, while others want a lot more tourism development. The sixth plan of management fails to indicate that the different opinions of the traditional owners will potentially fragment the park according to these different aspirations. Against these interests and claims is the park lease, which should unify through the plan of management in the same way a town plan unifies development control and management despite there being many land interests.

No change to the plan. The park has a strong Environmental Impact Assessment process (Section 9.5) via which development proposals are assessed and then considered by the Board as a whole for a decision. Tourism development is considered through precinct planning (Section 6.1) with representation of the relevant clan groups.

Section 4.1 Making decisions and working together (Board of Management)

The Colong Foundation is strongly opposed to a Kakadu Board of Management that has a majority of members that are pro-development. A prerequisite of Board membership should be the protection of the park’s ecological integrity and heritage.

No change to the plan.

The park has a strong Environmental Impact Assessment process (Section 9.5) via which development proposals are assessed and then considered by the Board. Tourism development is considered through precinct planning (Section 6.1) with representation of the relevant clan groups.

The Board of Management has an agreed set of meeting rules supported by the EPBC Regulations which require members to declare any conflict of interest.

Section 5.3 Managing park-wide threats affecting values

There is a decline in threatened small mammal species due to the incursion of fires from outside the park as well as the increase in invasive species.

Submission page reference: 1

No change to the plan.

Covered by Sections 5.2 and 5.3 which acknowledge that increased fire intensity and frequency and invasive species are acknowledged as key threats to small mammals. This is also acknowledged in the Threatened Species Strategy.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 5.3 Managing park-wide threats affecting values

 It is incredible that concepts of critical fire threshold frequencies (5.3.24) are not already a cornerstone of park management, suggesting the basics of park management are still deficient after 40 years. This is unacceptable by any standard, let alone for a Federal Government managed World Heritage listed national park.

Submission page reference: 1

No change to the plan.

The park has invested significant resources in fire management since the declaration of the park, ensuring that regeneration of vegetation provides habitat and resources for fauna in the park, while minimising any impact of such burns. The development of thresholds and acceptable ranges for fire regimes for all threatened terrestrial animal and plant species is an outcome of discussions with the Kakadu Research and Management Advisory Committee which includes the outcomes of significant scientific research and advice. The action described in 5.3.24 will further improve current fire management processes and does not suggest that the basics of park management are deficient.

Section 6.0 Kakadu as a visitor experience destination,

commercial tourism and promotion

The Colong Foundation believes that the reason for reduced visitor numbers is more to do with perceptions that the park is no longer effectively managed.

No change to the plan.

The decline in visitor numbers is directly related to a decline in tourism across the globe as a result of the September 2001 terrorism attacks and the global financial crisis in 2009.

Visitation to the park started to decline around 2009 due to a number of factors including the after effects of the global financial crisis. However, this trend appears to have been arrested with visitation to the park increasing since early 2014, particularly from the domestic market. Significant resources are being committed to improving visitor experiences in the park and increasing visitor numbers in a sustainable way.

Section 6.1 Destination and visitor experience development

There is no statement explaining visitor levels or analysis as to what is needed for expected use levels over the life of the new plan, whether and where visitor facilities should be provided, if use levels should be capped or if any areas should be protected from development. The consideration of sustainable use levels and ecologically sustainable use is totally absent, such as ultimate desirable use levels for various sites, including those specified in Figure 16.

No change to the plan.

Covered by Section 6 that identifies the changes in visitation over recent years and specifically commits to increasing visitor numbers in a sustainable way and providing opportunities for diverse and enriching visitor experiences which are promoted in an appropriate way.

The Policies and Actions included in Section 6.1 emphasise that tourism will be managed to protect natural and cultural values. The Tourism Master Plan and precinct plans (Actions 6.1.6 and 6.1.7) provide for more detailed planning of visitor facilities and ensure they are culturally appropriate and environmentally sustainable.

Section 6.1 Destination and visitor experience development

We request that you amend the sixth Kakadu National Park plan of management so that it contains: • A cap on annual visitor levels at 200,000 to prevent over use of popular areas; and

Submission page reference: 2

No change to the plan.

Covered by Section 6 which commits to increasing visitor numbers in a sustainable way and providing opportunities for diverse and enriching visitor experiences which are promoted in an appropriate way.

The permit system (managed in accordance with Section 9.3) is also used to restrict visitation to sensitive areas and manage overuse of popular areas.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 6.1 Destination and visitor experience development

The draft plan apparently operates on the assumption that tourism development can take place anywhere without specifically defined limits.

No change to the plan.

Covered by Section 9.5 that specifies how proposed actions will be assessed - including tourism developments.

Section 8.1 Outstations and living on country

Further, the draft plan offers no adequate explanation of the leases and subleases for the three land trusts or how these relate to outstations. Will the number of outstations multiply by a factor of three?

No change to the plan. It is not anticipated that there will be a significant increase in the number of outstations in the park. Proposals for establishing new outstations will be assessed in accordance with Section 9.5 (Assessment of proposals) and managed according to the Outstations Guide to Development (2014) (Policy 8.1.3).

Section 8.1 Outstations and living on country

The draft plan facilitates inappropriate expansion of the human footprint on the park, and the only measure to limit this growth is environmental impact assessment. The draft plan does not propose minimum standards for the regulation of waste, sewage, and facilities that will accompany the growing number of living areas.

No change to the plan. There are provisions and processes in place under Section 9.5 (Assessment of proposals) to assess proposed developments in the park. The park is working with stakeholders in the park on waste management issues and in accordance with Policy 8.2.18 will take all reasonable steps to have environment protection and waste management measures undertaken in Jabiru to a high standard.

Section 8.1 Outstations and living on country

The proliferation of Aboriginal on-country camps need to be planned so that these do not unduly impact on the natural environment or further limit public use of Kakadu. The sixth draft plan should at least have initiated a conversation about why settlement areas are closed to the public, what if any area around on-country camps should be closed to the public, and how many other parts of the national park may become closed under this exclusionary policy.

No change to the plan. The supposition that there is a proliferation of Aboriginal on-country camps being allowed in the park without environmental impact assessments occurring is inaccurate. The environmental impact assessment (EIA) process outlined in section 9.5 of the plan, and the Guidelines for EIA (2008) provide protection of natural and cultural values.

Settlement areas are closed to the general public to provide privacy to Aboriginal families in these communities. In addition, access to Aboriginal land in the NT is regulated through permits. Hence access restrictions for the general public to outstations in the park is supported by the Director of National Parks. Kakadu is a jointly managed park and over 50% of the park is owned by Aboriginal land trusts

Section 8.1 Outstations and living on country

The draft plan does not acknowledge these problems or consider any realistic resolution of the living area issue. Burying controversial issues demonstrates the administrative weakness of this draft plan of management. These issues need to be brought into the daylight and discussed.

No change to the plan. The number of outstations has remained relatively constant since the park was established. Outstations are private living areas that are essential for Traditional Owners to maintain connection to and care for country. The presence of people on country is regarded as integral to managing landscapes of northern Australia.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 8.1 Outstations and living on country

The public has a right to know how many living areas there are now and how many more living areas are going to be proposed under the life of the plan and the locations of these. These matters should be clearly stated in the plan of management: they have continued to be secret for decades as the number of people living in the national park and living areas have never been specified. This is unacceptable for a national park. This is like stating that a local government town plan need no longer need to specify where villages and settlements can occur. Any government that made such a law would be voted out of office.

There should be no further settlements established in the national park and existing settlements should be phased out. Yet the opposite is proposed.

No change to the plan. There is no requirement for the management plan to specify the location or number of living areas within the park. Outstations are private living areas that are essential for Traditional Owners to maintain connection to and care for country and the number of outstations has remained relatively constant since the park was established.

Proposals for establishing new outstations will be assessed in accordance with Section 9.5 (Assessment of proposals) which provides for protection of the natural and cultural values, and managed according to the Outstations Guide to Development (2014) (Policy 8.1.3).

Section 8.2 Jabiru

The township of Jabiru was established to house people associated with uranium mining in the region. The town was opposed by the conservation movement at the Fox Inquiry and in reply the mining industry stated it would only be temporary. If natural and cultural values of this national park are to be respected, Jabiru must be relocated to a site outside the park when uranium mining ceases.

No change to the plan.

This matter is covered in Section 8.2 which explains the following: In 1997 the Mirarr applied for a determination of native title under the Native Title Act 1993 over the Jabiru lease area and two other adjoining areas of the park excluded from the grant, and are the registered native title claimants. In 2009 an agreement was reached to settle the native title claim. Under the settlement the claim areas would be granted as Aboriginal land under the Land Rights Act and leased by the relevant Aboriginal Land Trust to a suitable lessee for the purposes of continued use as a town.

Section 8.2 Jabiru

Contrary to the recommendations of the Fox Report, Jabiru is to continue and, ironically, its development is regulated by the zones in the town plan (8.2.6 (c), page 122). This arrangement condones serious ongoing environmental degradation and increased sewage and waste disposal problems similar to those that have significantly degrade Kosciuszko National Park. Urban expansion after Ranger may require a high tension powerline through the national park or a gas pipeline, if natural gas is to power the Ranger generators, given the heavy use of air conditioners in the town’s existing dwellings.

No change to the plan. This matter is covered in Section 8.2 which contains provisions for the future of Jabiru township and minimising environmental impacts on the environment and Section 10.3 covers some of the responsibilities of West Arnhem Regional Council in terms of sewage and waste management in Jabiru.

Section 8.2 Jabiru

The draft sixth plan fails to discuss the consequences of Ranger’s closure in relation to the power supply that would terminate.

No change to the plan. Decisions around electricity generation following decommissioning of the Ranger mine will be made in a manner consistent with Section 9.4 Capital works and infrastructure and Section 9.6 Resource use in park operations. Construction of any generation facility would also involve Environmental Impact Assessment (Section 9.5) of the management plan.


 

Plan reference

Comments in the submissions

Response

Colong Foundation for Wilderness

Section 8.2 Jabiru

It [the draft plan] fails to explain how the Jabiru airfield will be maintained. The Jabiru and the Cooinda airfields should be decommissioned and rehabilitated, or if needed for management purposes, maintained at a suitable standard.

No change to the plan. Decisions around maintenance of the Jabiru airfield following decommissioning of the Ranger mine would be made in a manner consistent with Section 9.4 Capital works and infrastructure. The closure of airfields would be inconsistent with shared vision principles for tourism in the management plan; and would present significant public safety issues as air transport can be critical for airlifting to Darwin in the case of emergencies. Neither the Jabiru or Cooinda airstrips are currently within the park - they are in areas under lease.

Section 9.01 Safety and incident management

The sixth draft plan has is no policy to protect pristine mountains from telecommunication facilities. The plan’s policy of providing mobile phone coverage takes priority over protection of mountains and wilderness. This is not appropriate decision-making or priority setting for a national park.

No change to the plan. Action 9.1.12 is to work with government and non-government agencies and other stakeholders to improve mobile phone coverage in the park. Any measures to improve mobile phone coverage will be subject to the Environmental Impact Assessment process outlined in section 9.5 of the management plan. The Environmental Impact Assessment process recognises and aims to protect the highly significant cultural and natural values of the park, particularly the stone country.

Section 9.03 Authorising and managing activities

All leases and licences should be placed on an internet accessible public register under Sections 9.3 and 10.3 of the draft plan. Alien uses should be eliminated and occupancy rights only provided where they benefit the protection and management of park values. The pretence that there is no clash between traditional owners and national park values is unhelpful. These inconsistent values need to be acknowledged.

No change to the plan. This matter is covered by Section 6 which refers to the Shared Vision for tourism which was developed in 2004 and adopted in the fifth plan of management as a guide to balance the primary importance of Kakadu’s natural and cultural values with the development of a strategic approach to tourism.

To facilitate development of visitor experiences consistent with the Shared Vision, the Tourism Master Plan (DNP 2009) was developed and supported by the joint management partners.

Section 9.03 Authorising and managing activities

A moratorium should be established on new occupancy entitlements, leases and licences until a review of these concessions identify those that are consistent with national park ethics. All tenure and oc