The Secretary,
Taskforce on Tourism and National Parks
GPO Box 7050, Sydney 2001
30 August 2008
Dear Sir/Madam
Submission on Tourism in National Parks
The Nambucca Valley Conservation Association (NVCA) considers the two page media release on the above subject lacks detail and sufficient information to make a subjective submission.
The Taskforce faces a huge challenge in identifying an acceptable source of income revenue, without compromising the natural and biodiversity values of National Parks or alienating the people of NSW against National Parks.
The following comments are offered for consideration:
Aims:
It is essential that National Parks and their environments, including Wilderness areas continue to be protected under the regulations of the National Parks Act 1974 and the Wilderness Act 1987.
National Parks have traditionally been used by those seeking a nature experience, so ‘Appropriate Use’ must not endorse or adopt any practice or usage that threatens or compromises the environmental values or sanctity of parks.
Priority must be given to environmental protection from visitor impacts in natural areas and maintenance of biodiversity in parks through clear, enforceable Plans of Management.
"Creating a platform’, should consider the establishment of ‘off park’ bases in adjacent towns, communities or on neighbouring opening space (that does not involve clearing of native vegetation). It is unacceptable to assume that increasing tourism can only be met by enlarging development areas within a national park.
Criteria for increasing tourist numbers should not be focused firstly on raising revenue, but rather raising public awareness of the importance of our natural assets, biodiversity and conservation. 
Tourism expenditure should be focused on securing adjoining or nearby suitable property for accommodation, auxiliary entertainment and activities, rather than diminishing park values with purely revenue generating tourism infrastructure. 
There is still a strong need to continue research within National Parks, as the discovery of the Wollemi Pine suggests.
The NSW Government must continue to fully fund the National Parks estate from core revenue, in recognition of the outstanding public good which it provides to all the citizens of NSW – including those who do not even visit such areas. The search for revenue must not out-price National Parks accessibility for the community or affect the environment of our National Parks in a detrimental way.
Terms of Reference:
Point 1
This proposes development on a projection basis. How is the demand justified in all areas of the National Park estate? How will proposed development costs be based on projected income figures if tourism numbers are a projection of requirement by 2016? Who will be able to afford a visit to a National Park, based on projected fuel availability and cost? Amendments should be via a transparent process and involve community consultation.
Point 2
Consider developmental consultations with other agencies and private bodies that will minimize proposed developments on National Parks estate in the longer term and the utilization of alternate departmental lands as an alternative. The implication of this point is that the National Parks Service will be advised by other agencies on the best use of its estate lands.
Point 3
This point appears to overlook some of the expertise that has previously provided outstanding interpretive signage and brochures and is available internally. If this point is given the consideration it deserves, what is the advantage in identifying the first two aims?
Point 4
The NVCA encourages the strengthening of constraints for environmental protection, not the seeking means to “overcoming any such barriers”. The NVCA totally opposes point 4.
Point 5a
‘developing opportunities associated with the park’s estate’ - What a broad ranging cover all excuse to escape responsibilities under the National Parks or Wilderness Acts. Any such opportunities in National Parks estate must be individually identified and discussed in the public forum.
‘Adaptive re-use of existing facilities’- Great idea, on existing built or provided facilities, but should not be considered as an excuse to expand or developed facilities without thorough justification established by demand.
‘Volunteering opportunities’ - The NVCA fully supports the use of trained/qualified volunteers for interpretive work or as research assistants. Volunteers can effectively reduce costs and provide a valuable human resource. They also provide a valuable training base for personnel undertaking higher educational training and deserve to be positively identified.
‘Opportunities for other new tour/experienced-based products’ – The NVCA supports in principle new opportunities providing they are appropriately controlled, monitored and reviewed. Any such activity or commercial agreement must not result in any loss or degradation of biodiversity or environmental values within the park involved. Any proposal to increased commercial access to pristine or wilderness areas must be subject to an environmental Impact Statement undertaken by independent experts, specifically aimed to protect the environment from such an activity.
The NVCA does not support any roading for vehicular access or off road 4wd activities in parks under any circumstances.
Point 5b
Without consideration of the basic wage earner, single income family, single parent family, there should be no thought to increasing National Park visitor fees. Transport, accommodation and food costs are all major points to be considered in evaluating the impact any increase to visitor fees will have on the average park visitor.
Point 5c
All existing and any proposed commercial operations/tours in National Park estate should be reviewed annually. Such review must weigh up the revenue generated against impacts and cost of mitigating/managing impacts to park infrastructure and natural assets. Any financial benefit must demonstrate that park values have not been compromised and that such use is sustainable in perpetuity.
Point 5d
Appropriate training of staff and volunteers, interpretive signs, interpretive facilities help to promote National Parks. There is no better advertisement than an employee or volunteer who is informative, knowledgeable, keen and courteous.
Point 6
Leave this purely as a study in tourism conservation benefits. Trying to compare with case studies overseas or even from other states on themes that are similar/different can become complicated and may not be productive, considering seasonal, environmental and visitation differences. Use what is locally working and expand/explain.
Point 7
The preparation of an MOU is admirable, but it must include all Federal and State departments with any specific or inferred interest in the adjacent area of a National Park. Why is it being restricted to an MOU between DECC and Tourism NSW, it could possibly involve a large portion of other State Govt. departments as well as external private bodies.
Point 7a
Stated visitation objectives must be agreed to by all parties involved and funded/developed as approved on a pro rata basis.
Point 7b
The NVCA supports the continuing protection of conservation and biodiversity values without any attempt to subvert these values or decrease their effectiveness being considered in the future.
Point 7c
The NVCA objects to any legislative amendments which would allow development in National Parks for unjustified tourism or purely for the sake of income generation. 
Point 7d
This is considered to be the most difficult point that the Taskforce has to consider. How to increase tourism without alienating the tourist or compromising the conservation and biodiversity values of the National Park estate. The NVCA does not support any increase per se, in the application of fees, as a revenue maker to support research. The association does however strongly support the need for continuing research.
Utilization of natural resources in National Parks is absolutely opposed by this Association. 
Resource information, substantive research and the benefits to come from such works cannot be over-emphasized. 
Any increase in income generated as a result of this process should be supplementary to substantial and recurrent core funding of the National Parks and Wildlife Service from both State and Federal government. 
The NVCA considers that the Taskforce has been given the onerous task of justifying unsustainable and unacceptable development within National Parks for purely revenue generating purposed. Whilst this Association supports increasing park visitation it does not support the primary objective of raising funds through development and increased (other than bushwalkers) accessed to sensitive areas.
Paula Flack
President
Nambucca Valley Conservation Association