2020-2030 Management plan comments

My comments on the 2020 - 2030 management plan are outlined below, make sure you make Parks Australia and the Board aware that you do not support the ban on access to the world's finest desert views. For details on how to submit see this earlier POST.

Draft 2020 - 2030 Management Plan

General Comments and recommendations

1. Plan breaches section 17-2 of lease agreement

The Draft plan breaches section 17-2 of the lease agreement. Section 17-2 reads: “The Leasee covenants that the flora, fauna, cultural heritage and natural environment of the park shall be preserved, managed and maintained according to the best comparable management practices established for National Parks anywhere in the world or where no comparable practices exist, to the highest standards practicable.”

The draft plan fails to provide, in fact deliberately diminishes the history of the Park by moving non-Anangu history to an appendix and omitting important aspects of the park's history. In doing so it fails to preserve, manage and maintain Cultural heritage to the best comparable management practices established for National Parks anywhere in the world or where no comparable practices exist, to the highest standards practicable.

Cultural Heritage includes the rich history of Yankunytjatjara and Pitjantjatjara elders who climbed and supported visitors climbing the Rock. These are men like Paddy Uluru, Toby Naninga, Tiger Tjalkalyirri and Mitjenkeri Mick. The management plan is highly disrespectful of the views and actions of these men by completely omitting then from the Management Plan. There should be a prominent section in the plan covering the differing views of these past traditional owners.

Cultural Heritage includes the rich history of non-Anangu discovery of Ayers Rock, development of the park as a major tourist attraction and climbing by over 7 million visitors. The management plan is disrespectful of the rich history of non-Anangu discovery and visitation of the park.

Cultural heritage includes the wonderful work done by past Rangers including men like Derek Roff and Ian Cawood who played a pivotal role in the return of Traditional Owners. The management plan is disrespectful of past managers at the Park. A section of the plan should be devoted to past ranger staff.

Overall the Plan forgets the main purpose of the Park: a place for tourists to visit and enjoy regardless of their religious views. The Park is not there solely for the enjoyment of Parks staff and locals. If that were the case it could be run as a private park.

2. Plan breaches Racial Discrimination act

Overall the plan is racist and breaches the Racial Discrimination Act. Under the RDA visitors to National Parks have the right to exercise their own cultural beliefs. If Anangu wish to enforce their religious views on visitors they need to run the park privately without tax payer support. Provision needs to be made in the plan for visitors to be able to exercise their own views.

Recommendations:

• It is recommend that Parks Australia establish a museum in the Park that provides information and celebrates the points above.
• It is recommended that Parks Australia re-open the climb at Ayers Rock in respect and celebration of the rich Aboriginal and non-Anangu cultural traditions of climbing it. 
• It is recommended that Parks Australia reopen public access to the Kata Tjuta Lookout.
• The document does not meet the goals and aims of a National Park as it excludes visitors in the decision making process. A visitor representative is required to ensure the plan meets visitor expectations. Based on the draft plan the Land Owners should withdraw from the lease agreement and run the park as a private park.
• Plan breaches the 1987 World Heritage agreement – climb needs to be re-instated, or Parks need to withdraw from the 1987 world heritage agreement.
• The plan breaches the Racial Discrimination Act as it does not allow visitors to exercise their own cultural beliefs and forces Anangu beliefs on them. Requires provision for non-Anangu visitors to exercise their own cultural beliefs.
• The plan breaches the Lease Agreement section 17(2).
• Plan needs to be re-framed to provide for:
• Recognition of past history
• Respect the wishes of past elders who climbed and shared their space with visitors
• Provide for greater public access including to summits.
• Provision to be made for access changes within life of the plan.
• The management plan must include provisions for re-opening access to the summits of both Ayers Rock and Mt Olga and the Kata Tjuta Lookout and any other areas should owners change their minds about access. We know past owners did not have any issues with visitors going to these places and if a change in leadership occurs over the life of the plan and the new leaders are amenable to changing access then the plan needs to provide a means for this to occur.

For guidance on written material to include in the management plan to address the above points we refer Parks Australia to my book A Guide to Climbing Ayers Rock, and past Management plans prior to 1985 and historical guides and tourist brochures, along with books by Charles Mountford and Bill Harney.

Comments about specific sections of the plan.

Part A Establishment of the Park P2

Park history is very poorly described. Completely omits park history prior to 1977!

Recommendation: Provide complete park history starting with first Aboriginal discovery circa 35K BP  to present including details of European discovery and tourism. Refer to past Management plans, guides and tourist information. Refer to A Guide to Climbing Ayers Rock for detailed history of climbing Ayers Rock.

Aboriginal land and joint management P2

Omits mention of Ngaanyatjarra language group. 

Plan states: This means that our system of government must govern the way the land is protected here.  This statement is incorrect. The Park is managed under regulations provided for the in the governing act and associated regulations:  Environment Protection and Biodiversity Conservation Act 1999 ( EPBC Act). The statement would be true if the Park was run as a private park.

Plan states: The park is owned by the Uluṟu-Kata Tjuṯa Aboriginal Land Trust. This is not true. The land is owned by the trust, but the Park is owned by the Australian people.

P.4 State: “Joint management of the park has been in place since 10 December 1985 when the Board of Management was first established.” This statement downplays the important consultations that occurred between the NT Reserves Board NT conservation Commission and Rangers between 1958 and 1977. It is recommended that the collaborative approach of former administrations be acknowledged in the management plan.

World Heritage listing P8

Omits mention that the 1987 World Heritage listing preserved summit access and summit views. The ban on climbing instituted in the previous management plan breaches the 1987 listing: “Distant ranges, especially to the south and west, and Mt Connor to the east highlight the scenic grandeur of the monoliths and create a landscape of outstanding beauty to both Aboriginal and white Australian culture. Views of the ranges which lie outside the boundaries of the Park (as does Mt Connor) add to the visual experience of the visitor. In addition, however, they form part of the land system of which the Park is an integral part. They also provide the visitor with visual illustrations of the extent of Aboriginal religious geography which relates land within the Park to land beyond its boundaries. “

Actions required: If Parks Australia and Board persist with the ban then they must withdraw from the 1987 World Heritage listing.

Part B

Chapter 1

1. General provisions and IUCN category

Plan needs to honour the wishes and actions past elders who climbed and supported visitors climbing the Rock: men like Paddy Uluru, Toby Naninga, Tiger Tjalkalyirri and Mitjenkeri Mick. In banning the Climb and access to other features (Kata Tjuta Lookout) and omitting any mention of these past elders the Plan Parks Australia and the Board disrespect their memory and Tjukurpa.

Table 1 Plan states: The park’s first priority is conserving the significant natural and cultural values of the area. Plan is in breach of section 17-2 of the lease agreement – see general comment above.

Table 1. Natural values- list omits reference to the views available from the summit. Refer to 1987 World Heritage Nomination.  

Values statement: Omits mention of past elders climbing, omits non-Anangu history and values.

Section 1.3. Planning process is not valid as visitors have been omitted from consultation process.

1.5.4 Mutitjulu Township zone and road reserve for town access should be completely excised from the Park and managed by NT Government.

Figure 4. This is incorrect. The Park is managed under Australian Law alone.

Chapter 2.

Snapshot: Performance indicators need to include measurable outcome. Include visitor numbers as performance indicator.

Objectives need to include visitor satisfaction. The implication of the table is that tax payers are contributing to the running costs yet are effectively excluded from the Park. It is clear Parks Australia need to consult more widely in formulating the new Management Plan.

A place on the board is required for visitors to ensure visitor expectations, interests and tax payer interests are being met. I would be happy to fulfil the role. Recommendation:  Appoint Marc Hendrickx to the Board of Management as Visitor representative.

P29. Director of National Parks has a conflict of interest in responsibilities and should stand down from the board.

Table 2. Consultation requirements across all categories require consultation with visitor representative to protect visitor interests.

Chapter 3.

Ignores wishes and actions and disrespects past owners.

No mention of non-Anangu Heritage

Does not take visitor interests into account.

Figure 8 omits important summit sites (eg Uluru rock hole and various camps sites) Ref Mountford Ayers Rock 1965

Supporting retention of cultural knowledge P50

This section is somewhat ironic as the ban on climbing instituted by the board deliberately ignored the rich traditions and history of past owners who supported the Climb and public access to other parts of the Park now banned (eg caves along North face and Kata Tjuta Lookout) including men like Paddy Uluru, Toby Naninga, Tiger Tjalkalyirri and Mitjenkeri Mick.

Traditional beliefs have been documented by Charles Mountford and Bill Harney, yet no mention to their work is made in the plan.

3.3.1 and Table 4. potential impacts of proposed actions must be assessed by visitor representative.

Chapter 4.

Mutitjulu township to be excised from park and run in conjunction with NT government. Public access to be as for any other public land in Australia.

Chapter 5.

Snapshot: To provide fulfilling experiences based on culture and nature that benefit Aṉangu, who welcome visitors as their guests. This is a racist statement that breaches the Racial Discrimination Act unless reference to culture include non-Anangu culture. Under the RDA visitors to National Parks have the right to exercise their own cultural beliefs including accessing the summit of Ayers Rock and Mt Olga. .

5.1.10 any working group to include a visitor representative.

5.2 Information, education and interpretation

Refer to general comments about denial of Park history. Park requires a museum to provide information about and celebrate past owners, managers and non – Anangu history.

5.3 Photographic control are overly restrictive and should be changed to reflect broad community values of freedom of the press, freedom to roam and freedom of expression.

5.4 visitor representative to have a say on commercial activities.

Chapter 6. Consideration to be given to hand over Park Management completely to Local owners over the life of this plan to run as a private park free from tax payer influence.

Appendix c. Omits reference to natural values in the 1987 World Heritage nomination that provide for access to the summit for visitors. “Distant ranges, especially to the south and west, and Mt Connor to the east highlight the scenic grandeur of the monoliths and create a landscape of outstanding beauty to both Aboriginal and white Australian culture. Views of the ranges which lie outside the boundaries of the Park (as does Mt Connor) add to the visual experience of the visitor. In addition, however, they form part of the land system of which the Park is an integral part. They also provide the visitor with visual illustrations of the extent of Aboriginal religious geography which relates land within the Park to land beyond its boundaries. “

Appendix D  and E. Omits mention of the landscape values visible form the summit. These are referred to in the 1987 World Heritage Nomination. “Distant ranges, especially to the south and west, and Mt Connor to the east highlight the scenic grandeur of the monoliths and create a landscape of outstanding beauty to both Aboriginal and white Australian culture. Views of the ranges which lie outside the boundaries of the Park (as does Mt Connor) add to the visual experience of the visitor. In addition, however, they form part of the land system of which the Park is an integral part. They also provide the visitor with visual illustrations of the extent of Aboriginal religious geography which relates land within the Park to land beyond its boundaries. “

Appendix F. Fails to acknowledge provisions of the lease agreement, namely section 17(2) that have been breached and continue to be breached if the 20-30 plan passes unchanged.

Appendix G. Timeframe confirms that visitors have never been properly consulted in determining management actions and priorities in the park. A Visitor representative must be included on the Board with veto rights over Board decisions.

Appendix J: The section includes a lot of unnecessary commentary and should be kept factual.  There is no such thing as a “colonisation process”. This term is post modernist nonsense. Recommend changing to “Ernest Giles and William Gosse were the first Europeans to visit the area and named features in honour of political figures of the day.”

Omits mention of Ngaanyatjarra language group.

States: It was not until passage of the Land Rights Act and the subsequent establishment of the Central Land Council that Aṉangu began to influence the ways in which their views were represented to government. Factually incorrect Pitjantjatjara and Yankunytjatjara people were actively influencing management in the Park from the late 1960s coinciding with the management by Derek Roff.