Halls Island, Lake Malbena

Time to brush the cobwebs off an old blog of mine.  A couple of years ago Forestry Tasmania changed their name to Sustainable Timber Tasmania which inspired me to write my first political blog entry.  I got a bit coy and took it down for some reason.

Anyway, here I go again.  I am really worried about the development application for private hut accommodation at Halls Island, Lake Malbena, Walls of Jerusalem National Park in Tasmania's precious World Heritage Area.

So...  Here's the representation I've written to the Central Highlands Council.

10th February 2019

DA2018/50

Halls Island Development Application Representation

General Manager, Central Highlands Council

19 Alexander Street, Bothwell 7030 C/- kbradburn@centralhighlands.tas.gov.au

Dear General Manager,

Thank you for the opportunity to respond in relation to the proposal by Wild Drake Pty Ltd to establish a Standing Camp on Halls Island, Lake Malbena, Walls of Jerusalem National Park.

I am against the proposal.

I strongly believe this proposal sets several dangerous precedents which damage Tasmania’s reputation as an eco-tourism destination. If allowed to proceed, developments like this will compromise one of the last great wilderness areas on earth.

My objections are based on the following points:

1. Establishment of a Solid (Type C) Standing Camp

2. Impact of Helicopter Landings in a Remote Area

3. Granting of the lease over Halls Island without consultation

4. Removing Public Access

5. Plumbing

6. New Tracks in Self Reliant Zone

7. Management Plan Issues

7.1. Helicopter Access Sites

7.2. Wilderness Zone versus Remote Recreation Zone

Before expanding on these objections, I would like to offer a positive suggestion.

There are many other ways this type of project could proceed. Many private blocks of land exist just outside the boundaries of Tasmania’s World Heritage Area. Much of this land is quiet, remote and in a wonderfully natural state. Developments on such land could be exclusive and private while still offering a unique way to access and engage with some parts of the public reserve estate. I believe the Central Highlands Council could play a key role in identifying such areas for development.

Please find attached more detail regarding the objections listed above.

Yours sincerely,

Clinton Garratt

1. Establishment of a Solid (Type C) Standing Camp

The Halls Island proposal seeks to establish a solid Type C Standing Camp as per the Parks and Wildlife Standing Camp Policy 2006. There is no justification for this in the DA documentation. The policy states a strong preference for a Type A Standing Camp and insists that all standing camps must be temporary in nature and appearance. The current proposal does not comply with this. Justification should be supplied as to why Type C has been chosen. It should be noted that economic or target market preferences are not valid justifications for choosing Type C under the policy.

The standing camp policy requires the standing camp should be contained within a 40m diameter. The Halls Island proposal has a 60 metre diameter from the furthest accommodation pod to the communal pod. Again, the proposal offers no justification for not complying with the size restriction in the policy.

2. Impact of Helicopter Landings in a Remote Area

No commercial operator has been granted a license to land guests in a remote part of the World Heritage Area. This is how it should stay. The overflight noise impact of helicopters is far worse than fixed wing aircraft.

I have worked extensively in the Tasman National Park. Since construction started on the Three Capes Track the impact of helicopters has been significant. Even now the track is built there are still many helicopter trips servicing the private lodges, public cabins, the track itself and scenic flights. In the past 4.5 years I have visited Tasman National Park approximately twice a week. It is now rare to visit without hearing a helicopter and this is without any guests being landed in the park.

I do not want the World Heritage Area to suffer the same fate as Tasman National Park. Many people visit the remote parts of the central plateau for fishing and hiking in a quiet, off-the-grid environment. Many of these people, myself included, patronise businesses in the Central Highlands Council area. Guests arriving by helicopter from other parts of Tasmania are much less likely to use local services.

Granting permission to access Lake Malbena commercially by helicopter sets a dangerous precedent for the Central Plateau and broader World Heritage Area.

3. Granting of Lease over Halls Island without Consultation

The Standing Camp policy mentioned above requires that a Type C Standing Camp must undergo a Development Application and public consultation process. However, there appears to have been no such process around the granting of a lease over the entire Halls Island.

Several years ago, I was involved in the Crown Land Assessment and Classification Project where many parcels of crown land were made available to adjoining land owners. This was a very fair and open process. There were opportunities for interested parties to object.

The proponent’s existing lease only covered a very small area representing the historic hut and a modest 5 metre curtilage. Leasing the entire island in this manner sets another dangerous precedent. If this development is allowed to proceed then, potentially, what other areas of reserved public land in Tasmania’s central highlands could be handed over without a fair and open process?

4. Removing Public Access

A major problem with this proposal is removing the opportunity for members of the public to access a significant area of public land. This proposal is very different to other commercial developments in parks where there is only a small area which is off-limits. Other standing camps and private huts are tucked away in areas which are not particularly unique.

For example, the private huts on the Overland Track do not bar access from any particular views or unique vegetation types. However, the Halls Island proposal seeks to dramatically restricit public access to one of the only islands on a Tasmanian highland lake which is big enough to support a variety of forest and vegetation types.

No other private developer has been granted such exclusivity over a significant point of interest in a public reserve.

5. Plumbing

The proposed development claims all black and grey water will be helicoptered out. The drawings show 4 WCs, 3 showers and 4 hand basins along with sub-floor rain, grey and black water storage. There appears to be no indication of the storage volumes or data to indicate whether it will be feasible to helicopter the quantities of black and grey water produced by each trip.

On the Three Capes Track, Parks and Wildlife underestimated grey water production volumes for their new ‘cabins’ and have had to increase their grey water handling capacity. I suspect this could also be a problem for this proposal.

I note there is no kitchen sink included in the proposal. To avoid environmental contamination all kitchen liquid waste would need to be included in the grey water budget as it would be unacceptable for dishwashing water to be disposed of in the surrounding environment.

6. New Tracks in the Self Reliant Zone

The World Heritage Area Management Plan 2016 does not allow for new track development in the Self Reliant Zone. However, the proposal includes new tracks on Halls Island and in the area surrounding Lake Malbena.

7. Management Plan Issues

Under the Central Highlands Interim Planning Scheme 2015, Halls Island is zoned Environmental Management which only allows development, “…if a reserve management plan applies.” In this case the relevant Management Plan is the Tasmanian Wilderness World Heritage Area Management Plan 2016.

The 2016 Management Plan was vastly different to the draft version released for public comment in 2015. There was therefore no opportunity to publicly respond to the dramatic changes effected by the 2016 amendments. There has therefore not been public consultation on issues affecting this proposal such as management plan zones and helicopter access.

7.1. Helicopter Access Sites

In the 2015 draft management plan a small number of specific locations were identified for helicopter access up to 10 return trips per year. Lake Malbena was not listed.

In the 2016 management plan, instead of listing specific landing locations, a number of exclusions were listed opening the potential for helicopter flights to land almost anywhere within the Recreation and Self-Reliant Recreation Zones. This is a massive change to bring in without public consultation and a change which I object to strongly.

7.2. Wilderness Zone versus Remote Recreation Zone

In the 1999 management plan and the 2015 draft management plan Halls Island was in the 4th and most remote and undeveloped of the zones. This was called the “Wilderness Zone” in the 1999 plan and the “Remote Recreation Zone” in the 2015 draft.

In the 2016 management plan the 4th zone is back to being called the “Wilderness Zone”. However Halls Island and the rest of Lake Malbena was moved to the 3rd or “Self-Reliant Recreation Zone.” This rezoning was done without any public consultation. To make matters worse, none of the management plans outline any process or criteria for rezoning.

This project would not be allowed in the Wilderness Zone and, in my opinion, should be assessed accordingly.

Even if the rezoning is considered valid this project is incompatible with the management objectives for the Self-Reliant Recreation Zone. The following text is from the 2016 management plan:

“The Self-Reliant Recreation Zone is generally an area where visitors can conduct recreational activities that require a challenging and relatively unmodified setting… Visitors exhibit a higher level of experience and commitment in this type of zone.

“Infrastructure, such as tent platforms, toilets and hardened tracks, may be installed to mitigate environmental damage or to provide for recreational use appropriate for the zone. However, minimal management input and presence is intended.

“The Self-Reliant Recreation Zone aims to: … maintain, as far as possible, characteristics of remoteness and isolation and … retain a largely unmodified natural setting for a challenging experience…”

There is nothing “challenging” about stepping out of a helicopter.

A solid, permanent set of pods and boardwalks is not “relatively unmodified”.

This proposals requests permission to build more than, “tent platforms, toilets and hardened tracks.”

Having access to a hot shower does not show a “higher level of commitment.”

A helicopter landing nearby or flying low overhead does nothing to maintain “characteristics of remoteness and isolation.”