lutruwita/Tasmania – A Wild State

Background

lutruwita/Tasmania is a wild state. Wildness permeates almost every aspect of our identity, community, culture and industry. It dominates our landscape, underpins our brand, sustains our people and defines our sense of place.

The Tasmanian Greens defend the integrity of Tasmania’s existing national parks and reserves to protect their ecological and Aboriginal heritage values and maintain authentic natural experiences for visitors. Parallel with this defence, we champion the creation of more formal reserves, both terrestrial and marine, to protect values, create new opportunities and enable Tasmania to live up to the reputation we sell to the rest of the world – that of an island of natural wonder with a reserve system that respects and protects our shared inheritance.

lutruwita/Tasmania’s rare and grand wilderness areas are a relic of the supercontinent, Gondwana, shaped over millions of years by the forces of nature and countless generations by the hand of the palawa.

The Tasmanian Wilderness World Heritage Area meets seven of the ten criteria for listing on the UN World Heritage List and is the only property with the word ‘wilderness’ in its name.

This island’s wilderness, wildness and national parks draw visitors from within the state, across the country and around the globe. They also underpin Tasmania’s clean, green, and natural brand, which gives our primary producers and export enterprises a critical edge in global markets.

Tasmania’s Aboriginal heritage tells a unique story of a resilient people able to adapt to change and manage the landscape for intergenerational sustainability.  The most southerly people to endure an ice age, lutruwita’s reserves harbour heritage and stories found no-where else on Earth.

In a time of climate emergency and biodiversity crises, Tasmania can show the world how to protect and restore large areas of natural habitat, both terrestrial and marine. Now, more than ever, government has a solemn responsibility to ensure wild places remain just that, safe from privatisation and exploitation, adequately protected from threats and celebrated as some of the best in the world. Government also has a key role in investing in and supporting the restoration of ecosystems across the island.

As intact natural and cultural landscapes, lutruwita/Tasmania’s national parks and other reserves protected under the Nature Conservation Act (2002), and private land covenanted under the Nature Conservation Act (2002), are precious environmental, cultural, social and economic jewels.

However, some are under-protected, remain threatened and as a whole, they do not protect the full range of biological diversity, natural heritage, ecosystem processes or Aboriginal cultural heritage values that exist in Tasmania.

Major additions are required to the parks system if the network of protected areas is to achieve the survival of significant components of the state's natural heritage and biodiversity, protect all wilderness and conserve all places that warrant it. 

The climate emergency makes this goal a necessity.  Significant intact ecosystems are more resilient to climate impacts than fragmented, degraded lands. Climate change presents both a significant threat to Tasmania’s national parks and reserves, and an imperative for their expansion. Preserving carbon and enhancing sequestration should also be recognised as a key role of Tasmania’s Reserve Estate.

Current land management practices are destroying large tracts of native vegetation and associated habitats for native fauna, and impacting on Aboriginal cultural heritage.

The management of Tasmania’s public reserves needs to be enhanced, through the development or strengthening of formal management plans, the creation of a statutory process for the assessment of proposed developments on public land, and an increase in funding for the Parks and Wildlife Service (PWS), for investment in the actual management and protection of natural and cultural values.

The management of our protected areas is often confused because of the failure to recognise and resolve such competing interests as nature conservation, Aboriginal heritage protection, recreation and tourism. The PWS should focus its attention on its principle role as a natural and cultural values conservation agency.

Tasmania’s reserves should be managed by the PWS under a stand-alone Environment Department that does not have competing interests with other sectors, as is currently the case with the Department of Primary Industry, Parks, Water and the Environment (DPIPWE).

The rights of lutruwita’s palawa to be on Country and their knowledge of ecological and cultural management systems for national parks and reserves must be recognised, enhanced and built into programs that progress land justice, equality and cultural health.

Tasmania’s Reserve Estate

While Tasmania’s official terrestrial Reserve Estate covers 50.3% of the island[1], many of these areas are under-protected and allow for destructive activities that threaten the natural and cultural values for which these places were proclaimed reserves in the first place.

Under-protection includes the provision for extractive industries (logging and mining) under some categories of reserve tenure, including Regional Reserves, Conservation Areas and Unallocated Crown Land (‘Future Potential Production Forest’ land (FPPF)).[2] 43% of Tasmania’s current reserve estate allows for logging and/or mining.[3]

Inaction and turning a blind eye have also contributed to compromised values, with both the permitted and illegal use of off-road vehicles on reserves such as the Arthur Pieman Conservation area and Southwest Conservation Area impacting on sensitive vegetation, shorebirds and irreplaceable Aboriginal cultural heritage.[4]

Industry-driven decisions have become increasingly common. In the first of a series of assaults on the reserve management system by the Liberal Government, in 2016, the Tasmanian Wilderness World Heritage Area (TWWHA) Management Plan was changed to facilitate the development of private commercial tourism accommodation. Longstanding protections were overturned and specific provision was made in the revised management plan for developments such as the South Coast Track Huts, South East Cape walk and hut, Lake Malbena helicopter-accessed huts, Lake Rodway Lodge and additional huts on the Overland Track.[5]

Also shortly after coming to office, the Liberals opened up 356,000 hectares of former future-reserves (now classed as Future Potential Production Forest Land) to the potential for logging, including clearfell and burning of high conservation value forest ecosystems.[6]

Protecting our Reserve Estate

 

We will review the Tasmanian Reserve Estate to upgrade the reserve status of appropriate areas to National Park through the Nature Conservation Act 2002. This includes all areas of existing or proposed World Heritage listing.

We will amend the Nature Conservation Act (2002) to remove the provision for extractive industries, including special species rainforest logging and mining, in any form of reserve.

We will protect all 391,000 ha of FPPF land as a formal reserve under the Nature Conservation Act (2002).

We will establish a new reserve tenure under the nature Conservation Act to provide for the proclamation of Aboriginal-owned and managed national parks.

We support the Aboriginal Land Council of Tasmania’s formal land return claim for kooparoona niara/Great Western Tiers to become an Aboriginal-owned and managed national park under this tenure when presented to Parliament later in 2021. This tenure could be replicated for similar returns of land to deliver a measure of land justice, cultural recognition and development, and to protect natural values.

Private Land Conservation

Biodiversity, carbon, Aboriginal cultural and other values exist on private land and there is significant interest in conservation and land management in the private sector.

The Government’s private land conservation program, offering payment for covenants on private land has been woefully underfunded for many years and the program of recruitment of new covenant uptake has stalled.

Re-investing in Land Conservation

 

We will restore funding to the Private Land Conservation Program, including for incentives and outreach to farmers and other landowners in order to expand the important private land reserve estate.

Wildcare, Coastcare, Landcare

Much of the vital remote-area work within our reserves is undertaken by dedicated volunteers. Just some examples are –

There has been a decline in Commonwealth funding to support for these activities.

Investing in Environmental Care

 

We are deeply thankful for the work of volunteers assisting with management of Tasmania’s parks and reserves.

We will allocate increased funding of $250 000 per annum to support Wildcare, Coastcare and Landcare volunteers’ vital conservation work.

World Heritage

The TWWHA is lutruwita’s wild and ancient heart. It meets more World Heritage listing criteria than any other property on UNESCO’s World heritage list, and is the only World Heritage site with the word ‘wilderness’ in its name.

The TWWHA protects natural and Aboriginal cultural values of immeasurable significance. Similarly, its existence offers Tasmania a global icon that is now central to our identity as a people, to our clean, green Brand and to the economy.

The TWWHA was borne from conflict and stands as a testament to the power of people,[12] to their commitment to wild Tasmania in the face of immense corporate and government power. It reinforces the critical role the Tasmanian Greens play in Tasmania’s politic and Parliament in driving conservation outcomes.

Declared in 1982, the TWWHA has been extended numerous times. The most recent was in 2013, with Greens in a powering sharing Parliament The addition of the tall, wet eucalypt forests of the Styx, Weld and Florentine and northern foothills of the Central Plateau, the forests known as kooparoona niara/Great Western Tiers[13], largely resolved conflict over the eastern and northern boundary.

Now firmly protected from logging and mining, the greatest threats to the TWWHA come from climate change and the drought, fire and pests that come with it, and the ever-expanding agenda of the exploitation faction within the tourism sector.

Recent (2016) changes to the TWWHA Management Plan have diminished protection for wilderness, done away with long standing protections from huts and made other changes to facilitate commercial developments that would degrade the very values the TWWHA was listed to protect – such as intact and remote wilderness. [14]

Meanwhile, other areas of equal World Heritage significance remain excluded from the boundary to languish unprotected or as lesser level conservation reserves directly threatened by mining, rainforest logging,[15] off-road vehicles and the general mismanagement that comes with a lack of recognition in an ever-diminishing land management budget.

To the west of the TWWHA, the boundary remains unresolved and World Heritage status for the glacial mountains of the West Coast Range, the coast and hinterland of the Spero-Wanderer Wilderness, The Vale Catchment and grand old rainforests of the takayna/Tarkine should be progressed.

Strengthening World Heritage Sites

 

We will strengthen the TWWHA Management plan by:

·        Reinstating the prohibition on the development of huts in the Southwest National Park;

·        Reinstating wilderness protection as an explicit, overarching management objective;

·        Reinstating and extending the scope of the Wilderness Zone;

·        Reviewing the road network, currently zoned ‘recreation’ to establish which should be closed and rehabilitated, which remain open for apiary or other access and which are genuinely required for recreational purposes.

We will seek to achieve World Heritage recognition for areas outside the TWWHA, including the takayna/Tarkine, the Spero-Wanderer Wilderness (Southwest Conservation Area), The West Coast Range, the Vale River Catchment, Granite Tor Conservation Area and Recherche Bay.

The Tasmanian Greens do not support the proposal for a cable way accessing Dove Lake at Cradle Mountain, nor do we support the kind of high impact, mass tourism Parks infrastructure being constructed at Dove Lake becoming a model for other protected areas.

Next iconic walk

The Tasmanian Greens do not support the proposal for a Three Capes-style ‘iconic walk’ being developed in the Tyndall Range, a view shared by many in Tasmania’s conservation and bushwalking communities.

The Tyndalls are a much loved, though infrequently visited area of Tasmania, comprising sensitive alpine ecosystems in a quintessentially Tasmanian geological setting. It has wilderness and other values of recognised World Heritage value. It forms part of the proposed extension to the Tasmanian Wilderness World Heritage area.

A development of this nature and associated high volume visitation will have a negative impact on those values.

The Tyndalls also experiences a high frequency of poor weather events, high rainfall and regular strong winds. This makes the construction, maintenance, operation and marketing of a commercial tourism venture in the Tyndall Range an unviable exercise likely to fail on both environmental and financial grounds.

Exploration of new walk opportunities should be limited to those likely to generate significant public support and financial viability, in areas with lower wilderness value and less sensitive ecosystems, with existing access and impacts. Examples include the hut-free Trans-Tarkine Track or the current Future Potential Production Forest land, once they are formally protected under the Nature Conservation Act (2002).

Regenerative Tourism

The Tasmanian Liberal Government’s policy of “unlocking our national parks” is developer driven and facilitated by the secretive Expressions of Interest (EOI) process, the Parks and Wildlife Service’s Reserve Activity Assessment (RAA) process and Tourism Master Plans. Collectively, these non-statutory instruments are usurping the role of statutory park management plans. They are also increasingly excluding Tasmanians from having a say in the future of their protected areas.

The EOI process seeks development proposals for parks and reserves even if they contravene the current management plan. History shows the EOI process has been used for two key purposes.

  1. It has been used for public relations purposes and to build public and political momentum behind development concepts, ahead of assessment and irrespective of their compliance with management plans and relevant legislation or impacts on natural and cultural values.

 

  1. The process has been used to identify blockages to formal approval (such as management plan prescriptions) so as to formally remove them ahead of assessment. This has been seen with the Lake Malbena, South Coast Track and Overland Track hut developments.

Ultimately released by the Greens MPs in Parliament after being leaked by a Government whistleblower, the RAA for the Lake Malbena development was exposed as woefully inadequate. This document which would not have been seen by Tasmanians had a whistleblower not come forward to the Greens, denied community consultation, failed to fully assess impacts like those on wilderness and virtually waved through the development despite expert advice and non-compliance with the TWWHA Management Plan.[16]

A Wilderness Impact Assessment, conducted by PWSsubsequent to the Step 7 RAA approval of the Lake Malbena development, demonstrated significant impacts on wilderness values. As wilderness is supposed to be protected under both the Management Plan and National Parks and Reserve Management Act (2002) this assessment should be terminal for the project. As the RAA is not fully approved, this new information should now be considered and the development rejected.

The Lake Malbena debacle highlighted the failures of the current RAA process.

These proposals are degrading the very values our tourism sector relies on. Instead, we should have a tourism sector underpinned by genuine eco-tourism principles.  The same principles articulated by famed wilderness photographer, the late Olegas Truchanas, when he said;

Is there any reason why Tasmania should not be more beautiful on the day we leave it, than on the day we came?… If we can revise our attitudes towards the land under our feet; if we can accept a role of steward and depart from the role of the conqueror, if we can accept that man and nature are inseparable parts of the unified whole, then Tasmania can be a shining beacon in a dull, uniform and largely artificial world.”

Regenerative tourism understands and respects the living systems of a place. Rather than just minimising environmental impacts, regenerative tourism aims to improve the ecological values of an area.[17]

As a wild state, transitioning our tourism sector to a regenerative sector will ensure we can build on its strengths and contribution for future generations, restore our landscapes and special places, and enrich lutruwita/Tasmania by providing opportunities for palawa peoples to share their stories and knowledge of country.

With active support of the tourism sector, expanding the Tasmanian Reserve Estate with new national parks such as the takayna/Tarkine and formal reservation of the FPPF land, offers new opportunities for tourism and a chance for Tasmania to truly live up to its Brand.

To be delivered concurrently with conservation, there exists opportunities for new tourism attractions and infrastructure in currently threatened wild places of immense and iconic potential. The Trans Tarkine Track is one such proposal, a new multi-day walk through the heart of the Tarkine, proposed by conservationists to protect takayna/Tarkine while improving visitor access and boosting the regional economy.

Similarly, the Tasmanian Greens can support a new process to audit, assess and appropriately zone tourism opportunities, including commercial opportunities, as part of formally reserving the future reserve (FPPF) forests as new national parks or other reserves.

Iconic areas such as Wielangta, the Blue Tier, Douglas-Apsley and takayna/Tarkine languish as FPPF land. It is unallocated Crown Land that is part of the Tasmanian Reserve Estate, managed by the Parks and Wildlife Service yet in limbo with an irresponsible and unworkable plan for commercial logging.

These areas are spectacular, iconic and scattered across regional Tasmania. They are located where we need attractions and economic activity in nearby towns. Many have existing roads, bridges, campgrounds and walking tracks and some, like Derby, have already had significant and successful tourism investment deliver tangible benefits.

As part of properly protecting these wild places as the national parks and reserves they should be, we can look for new tourism options and deliver visitor and conservation opportunities hand in hand.

Regenerative Tourism Licence Process for Parks

 

We will abolish the secretive EOI process and replace it with a regenerative tourism licencing process. This will be an open and transparent process and allow for public input.

We will ensure a statutory replacement for the Reserve Activity Assessment process that enshrines a rigorous and independent assessment and includes guaranteed community involvement and third-party rights of appeal.

We will limit infrastructure in existing formal reserves to sensitively designed and constructed public infrastructure that protects and enhances the values of our reserves.

We will not permit any further privatisation of public protected areas.

We will initiate an audit of tourism opportunities across all areas of new, formal conservation reserves proclaimed under the Nature Conservation Act (2002), with the view of zoning appropriate areas as tourism zones, concurrent with the conservation process that proclaims them.

Stand Alone Environment Department

Within Cabinet, there should be healthy debate and contestation between a Minister for the Environment who cares and advocates for the protection of environmental values and Ministers for alternative portfolios, such as Primary Industries, which demonstrably impact on environmental values.

Sadly for this island’s living systems and its people, the reverse is happening in Tasmania today.

So long as the Parks and Environment portfolios are lumped in a mega department that is dominated by Primary Industries (Department of Primary Industry, Parks Water and the Environment – DPIPWE) the interests of this island’s natural environment will always be subjugated.

A stand-alone Environment Department responsible for parks management, threatened species management and other core environmental agencies should be established in Tasmania.

Department of Environment

 

We will establish a stand-alone Environment Department, overseen by a Minister for the Environment, with responsibility for Parks and reserve management, and environmental protection.

We will increase funding for the Parks and Wildlife Services land and ecosystem management activities to employ an additional 15 FTE Parks rangers, and 15 FTE field officers to maintain tracks in our iconic parks.

kunanyi/Mt Wellington

kunanyi/Mt Wellington is a place of deepest and sacred significance to palawa people, over countless generations. This locally beloved and mighty backdrop to Hobart is a beacon to our changing weather and an anchor to our sense of place. kunanyi sets Hobart apart from every other city in Australia.

Developers see it as an opportunity to make money.

The cable car dream that has dogged kunanyi for a century has again reared its head over the last decade and the Mountain faces a renewed, concerted push for its approval. The development is however about much more than just cable cars crossing the iconic Organ Pipes day and night, with towers and lights and a base station carved into a profoundly bushfire-prone forest.

It’s about access to undeveloped, cheap yet priceless public land at the Pinnacle, for the construction of a 4000m3 private commercial entertainment precinct, including restaurant, café, whiskey bar, conference centre and associated services. This 7-level construction would involve excavation up to 12 meters deep on the sensitive alpine summit.

Special legislation has been passed through the Tasmanian Parliament, with support from the Liberal and Labor parties, to facilitate approval of the cable car. The Liberal Government’s Major Projects assessment process is tailor-made to approve developments like the cable car, developments that would fail to be approved under proper, independent planning processes.

Meanwhile, the developer has turned to the courts to appeal an expert-informed request that it carry out a comprehensive on-site survey of the Aboriginal heritage affected by its development. In a shameful attempt to low-bar Aboriginal heritage, this case demonstrates the contempt shown for the protection of Aboriginal heritage by some in the private sector. It is a contempt led by the Liberal Government and its planned expansion of off-road tracks on the irreplaceable takayna coast, home to some of the world’s richest archaeological sites.

Simultaneously, the Aboriginal and European heritage of kunanyi is being increasingly researched and understood. Renewed attempts to have kunanyi/Mt Wellington added to the National Heritage list are building.

kunanyi/Mt Wellington

 

We will revoke the Cable Car (kunanyi/Mt Wellington) Facilitation Act (2017).

We will initiate a process to scope and develop a proposal for National heritage listing of kunanyi/Mt Wellington.

Biosecurity and invasive species

Feral species are impacting on the values of Tasmania’s environment, terrestrial and marine, within and outside of protected areas.

Pathogens like phytophthora, fungal infections such as chytrid and feral species like cats, deer, sea urchins, gorse, sea spurge and rock snot kill threatened species or damage the qualities and places that make Tasmania unique in the world

Populations of some invasive species are exploding.

Deer are actively protected by an approach that refuses to declare them official pests and manages them instead as a part-protected species. Official apathy sees management agencies stand by and watch as the population and range of deer expands into Tasmania’s reserve Estate, including the TWWHA, Douglas-Apsley and Freycinet National Parks.

Pressure from hunters and private landowners who profit from commercial hunting safaris has hobbled Government policy on fallow deer for decades. It continues to do so at the expense of natural values and agricultural productivity.  This is a fundamental failure in species management.

This, despite the damage deer do to vegetation waterways, fences and the economics of some forms of farming.

Despite clear evidence that recreational hunting is not an effective feral species management strategy, let alone an eradication strategy, the Government’s approach has been to open up an ever-expanding list of conservation reserves for hunting. Meanwhile, a properly funded, professional eradication program is nowhere to be seen.

To date, rock snot has been kept at bay. Ravaging New Zealand’s freshwater systems after introduction from the Northern Hemisphere, this algae clogs rivers and lakes causing significant degradation. Most likely to be introduced via the gear of freshwater fishermen, Tasmania’s biosecurity and parks managers need to be ever vigilant for the introduction of rock snot. 

Concurrently, the spread of pathogens and fungal infection is desperately countered and deeply feared.

Phytophthora can infest vast areas of susceptible vegetation, transported on vehicles, boots and bikes. It attacks root systems of plants causing significant dieback. Existing biosecurity measures are helping to manage phytophthora spread, however the risk increases with ever-growing numbers of users, diminishing land management budgets and the opening up of new infection points, including new walking and bike tracks.

Chytrid infects frogs, causing shocking rates of mortality in some species. It poses a real and present danger to Tasmania’s already-endangered frog species, some endemic to this island.

Biosecurity and Invasive Species Eradication

 

We will declare deer a pest species and set eradication as the management objective in the TWWHA and other relevant reserve management plans.

We will ban recreational hunting in Tasmania’s formal reserve estate and instead initiate a professional program of eradication in Tasmania’s reserves.

We will develop and fund, through Biosecurity Tasmania and the Parks and Wildlife Service, an Invasive Species Eradication Plan for Tasmania’s reserves. In addition to deer, species such as cats, sea urchins, gorse, sea spurge, and others, will be targeted by the program.

We will ensure the Parks and Wildlife Service maintains monitoring and programs to prevent the spread of Phytophthora, chytrid and other destructive processes.

Fire

Some vegetation communities in Tasmania have adapted to, or have a dependency on fire,[18] while others, such as alpine conifer communities, rainforest, deciduous beech, sphagnum moss and organic soils[19],[20] are deeply vulnerable to fire.

Some of Tasmania’s most vulnerable and valuable natural treasures are at increased risk in a warming world.  The increase in soil dryness and  the frequency and severity of dry lightning storms in Tasmania is a portent of a dangerous future.

We need to build resilience in to natural systems and increase our capacity to mitigate fire damage to the sensitive alpine and rainforest ecosystems that date back to Gondwana.

Areas of buttongrass are able to support a fire as soon as four years after a burn,[21] as of 2014, the majority of buttongrass moorland had not recorded any fire within the previous 50 years.[22] In addition to this the fuel-reduction burn plans for buttongrass have not been properly funded.[23] This contributes to a significant risk to natural values.

Remote-area prescribed burns, however, need to be underpinned by science and ecological principles and informed by Aboriginal cultural knowledge. These burns should be conducted in such a way that maintains and enhances the ecological integrity of an area.   

While well-managed prescribed burning may help to protect some areas, more must be done to prevent and fight wildfires. This includes early detection and rapid, sustained deployment of appropriately trained fire-fighters. As well as these wildfires potentially destroying ancient and irreplaceable wilderness, if not fought hard and early they can grow into unstoppable conflagrations that spread to settlements, as seen in the 2019 Gell River Fire.

Remote Area Firefighters

 

We will invest $3 million per year for 30 rapid response, remote area firefighters in our Parks Service to ensure that values in Tasmania’s parks and reserves are better protected in a warming climate.

We will also fund staffing for the remote area firefighter volunteer training.

 



[1] Department of Primary Industries, Parks, Water and Environment, Tasmanian Reserve Estate Areas as-at 30th June 2020, 2020.

[2] Mackey, B, Cadman, S, Rogers, N and Hugh, S, Assessing the risk to the conservation status of temperate rainforest from exposure to mining, commercial logging, and climate change: A Tasmanian case study, Biological Conservation, Vol. 215, 2017.

[3] Ibid.

[4] McGlone, P, Arthur-Pieman Conservation Area and Recreational Vehicles, 2010.

[5] Tasmanian Government, Tasmanian Wilderness World Heritage Area Management Plan, 2016.

[6] Department of State Growth, Future Potential production Forest, 2020.

[7] Flinders Council, Deal Island, n.d.

[8] Landcare Tasmania, Friends Of Bass Strait Islands - Removal Of Boxthorn From Roydon Island, 2019.

[9] Workabout Australia, Volunteer Campground Hosts Sought - Cockle Creek And Melaleuca, 2012.

[10] Birdlife Australia, Volunteer in the Winter Surveys, 2020.

[11] Wildcare Tasmania, Wildcare Sprats, n.d.

[12] See: Tasmanian National Parks Association, Creating Todays Tasmanian Wilderness World Heritage Area – A Brief History of its Reservation, 2017.

[13] Ibid.

[14] Tasmanian Government, Tasmanian Wilderness World Heritage Area Management Plan, 2016.

[15] Mackey, B, Cadman, S, Rogers, N and Hugh, S, Assessing the risk to the conservation status of temperate rainforest from exposure to mining, commercial logging, and climate change: A Tasmanian case study, Biological Conservation, Vol. 215, 2017.

[16] O’Connor, C, Tasmanian Greens Submission: Wild Drake Pty Ltd, Halls Island, Lake Malbena - Walls of Jerusalem National Park, DA 2018/50, Central Highlands Council, 2019.

[17] Earth Changers, Regenerative Tourism - What is it? (And What is it Not?), 2020.

[18] Tasmanian Government, Tasmanian Wilderness World Heritage Area Management Plan, 2016, p. 114.

[19] Parks and Wildlife Service Tasmania, Fire, flora and fauna, 2006.

[20] Department of Primary Industries, Parks, Water and Environment, Tasmanian Threatened Native Vegetation Communities, 2018.

[21] Ibid, pp. 6-7.

[22] Department of Primary Industries, Parks, Water and Environment, Fire Management in the Tasmanian Wilderness World Heritage Area, Evaluation Report, Nov 2015, p. 12.

[23] Ibid, p. 16.