The Regional Manager
National Parks and Wildlife Service 21 April 2005
PO Box 656
MERIMBULA NSW 2548

Dear Sir

DRAFT PLAN OF MANAGEMENT
SOUTH EAST FORESTS NATIONAL PARK

The Coastwatchers Association Inc appreciates this opportunity to comment on the Draft Plan of Management for the South East Forests National Park and Egan Peaks Nature Reserve. Our association is committed to protecting the environment of the south coast of New South Wales and to ensuring the community's hard won environmental gains are not lost. Our members recognise that the long and difficult campaign to protect the South East forests, including significant wilderness areas, now warrants a solid conservation-oriented plan of management which acknowledges their important place as part of a comprehensive, adequate and representative reserve system and enables them to overcome the damage from relatively recent logging operations.

We welcome the introductory statement (paragraphs 3 &4, page iii) that the plan will have a strong emphasis on promoting regeneration of degraded vegetation ecosystems, increasing the proportion of old growth forests and protecting and maintaining rare vegetation ecosystems and habitats of threatened species. However, we are alarmed at the internal conflict within the draft POM that suggests so many ex-logging tracks will be left open to public 4WD use. As the maps in Appendix 3 show, this would mean much of the park would be covered by a cobweb of vehicle tracks creating a permanent scar on the landscape and an ever-present threat to ecosystems.

The following brief comments summarise our concerns and relate to the clause numbers in the draft POM.

2.1.3 & 2.1.4 Three critical points made in these paragraphs establish the context for the rest of the plan:

i. The South East Forests National Park is part of the comprehensive, adequate and representatives public reserve system in the Eden Region. This is its prime purpose.

ii. In the late 1980s the Coolangubra area was identified as wilderness. These wilderness values were damaged by subsequent forestry roading and logging operations. These wilderness values can be restored.

iii. Protection of natural values has priority over providing recreational use of wilderness areas.

2.2.1 We oppose the intention to seek inclusion of Egan Peaks Nature Reserve into the national park. Egan Peaks was listed in the Register of the National Estate on 21/3/1978 because it contained complete ecosystems at Jingera Rocks not found elsewhere in the region. At the time of listing, the brush-tailed rock wallaby was said to be there. We do not wish the nature reserve to be 'downgraded'. Nor do we want any new tracks or visitors' facilities built in the reserve.

2.2.2 The Coolangubra area still could meet wilderness criteria. We believe it is
possible for the area to regenerate if the intrusive roads are closed and we would like to see the Coolangubra Wilderness Area declared under the NSW Wilderness Act.

There are six high value catchments in association with the park and its well-forested landscape plays an important role in their protection. Many towns and rural dwellings in the vicinity of the park are dependent on their water supplies from surface and groundwater that has its origins in the park. The proposed continued public use of the many unsealed roads established for forestry activities will add considerably to sediment load and reduce the quality of this water supply.

4.1.1 We congratulate the NPWS on the work that has been completed at Nunnock Swamp, including closing the road across the swamp.

4.1.2 & 4.1.3 These sections are pivotal for the following sections of the draft POM. The issues are clearly spelt out and we support your application of the precautionary principle where current knowledge is inadequate. The Guidelines for Management of Threatened Fauna Species are commendable.

4.2.1 We strongly support Aboriginal involvement in management of the park.

4.3.2 Regarding recreational vehicle use, we strongly support the notion of 4WD recreational use outside the park. There are thousands of kilometres of tracks suitable for 4WD experience in nearby state forests.
We do not support 4WD vehicle-based camping on Postmans Track. We believe Postmans Track should be closed to vehicular access.

We understand the construction of a walking track from Waratah Gully linking Pheasants Peak and Myanba Gorge is all but a foregone conclusion as plans have been displayed at Waratah Gully and tags have already been tied along the proposed track. We ask that the track does not cross sensitive ecosystems.

The section on horse riding is inadequate. The details of the permit system and the horse riding policy (referred to on page 46) must be spelt out. We would like the opportunity to discuss with the NPWS which tracks should be accessible to horse riders under the permit system once the whole issue of roads in the park is sorted out. We flag that no horse riding should be permitted in what we see as the Coolangubra wilderness area and that we would like permits for horse riding to be limited to a very small number of designated tracks. As in the case of 4WDs, many opportunities for horse riding exist in land outside the park.

4.3.3 The Coastwatchers Association is most worried about this part of the draft POM. We cannot see any logic to the designation of an area for national park in recognition of its conservation values and opportunities for passive recreation and then have these values potentially compromised by the maintenance of a network of logging roads to be accessed mostly by four wheel drive and trail bikes. We strongly support the closure of all roads classified "C". Even after this closure we consider there are far too many small roads and tracks in the public road system and request a review of this part of the plan.

The Coastwatchers Association supports the closure of Wog Way (as indicated on page 49-59). Our preference would be for this road, which cuts through the Coolangubra wilderness, to be ripped and regenerated, we accept the position that it is now used for fire and other essential management purposes and therefore can be a "B" category road. We applaud your intent (last paragraph page 49) once closed to public vehicular access, to manage the area according to wilderness principles. The opportunity now exists to restore the areas damaged by forestry operations.

4.3.4 Coastwatchers is an association that has an ongoing interest in the management of this park and would like to receive a copy of the neighbours and key stakeholders newsletter.

In summary, it is stated that the draft plan of management sets out strategies for the protection of significant natural and cultural values while providing for sustainable public use. However, we believe that the planned access for off-road vehicles, trail bikes and horses threatens these special areas and is at odds with the claim that "conservation will have priority over public use".

South East Forests National Park, with its precious wilderness and old growth forests, needs to be managed for nature. We urge NPWS to plan for low key, low impact activities on the periphery of the park with provision for two wheel drive access to camping sites and walking trails. There should also be provision for the disabled.

Yours sincerely,

Jenny Edwards,
Secretary