Have you received a FORM LETTER from Minister ENOCH?

National parks were set aside to be preserves of nature.

 ‘’you don’t need to visit, it’s enough just to know it’s there’’ (the late Margaret Thorsborne A.O.)

​Visitation is a privilege, not a right.

Unpacking Ministerial form letters … what happened to the public service codes of conduct and writing? Plain language? Transparency? Honesty?

​
Until the requirement for formal consultation is brought back into law (ie implemented in every relevant piece of legislation) the government can go on keeping two sets of books: what it tells the public versus what it is really doing.
Form letters are the classic way of misinforming the public, taking advantage of public trust and the general public ignorance of process and legislation.  

In November 2018, on behalf of ASH, Margaret Moorhouse reported (twice) to Minister Enoch’s office staff that the public expects: ​

(1)  to have their letters answered; and 
(2)  truthful responses - not ‘’cobbled-together pre-approved paragraphs that do not answer our questions’’. In                 other words – propaganda.

If you are lucky enough to get a written response to your letter to a Queensland government minister, it is likely to be a set of cobbled-together pre-approved paragraphs that do not answer your questions; contrary to the values and principles set out in the public service codes. 

See links below for Queensland Public Service Code and Queensland Public Service writing style.  
Contrary to the public service codes, the ministerial form letter discussed below (Nov-Dec 2018) is clearly designed to fudge the definition of ‘’national park’’ without admitting it was the Palaszczuk Labor Government using a changed definition by stealth, and without public consultation. ​

Paragraph 2 – The flattery in the first sentence is a sure signal this letter is propaganda.

Two incompatible ideas (ecotourism and national parks) are joined by ‘’and’’ as if they belong together. They don’t.  National parks were declared for conservation - NOT for ecotourism business. National parks were set aside from other lands precisely to ensure they would NOT be subjected to development and increased visitation. This is an attempt to convince you that the legislated purpose of existing national parks can be changed retrospectively.
Next comes an attempt to justify this false association with a false argument - that increased visitation results in increasing advocacy and therefore better protection. (1) it is patently absurd to say that increasing human impacts on a natural area will protect it; (2) regardless of ‘’advocacy’’, the government has always had a formal public duty to carry out protective management of national parks.
 ‘’best practice’’ is not a principle or a standard. ‘’Best’’ could well be ‘’best of a bad lot’’. The Cardinal Principle is the only appropriate management standard for national parks whose natural condition is to be permanently preserved.
‘’sharing our national parks responsibly‘’... (1) There is no such requirement. What other public assets will the Palaszczuk government ‘’share’’ with the rest of the world? (2) Any claim to acting ‘’responsibly’’ would begin with the Cardinal Principle.
The pre-election ecotourism commitment did not refer to long term leases in national parks. The public was not told the Labor party intended to sell out our national parks. The relevant pre-election Labor commitment is its dishonoured pre-election commitment to reverse the Newman amendments to the Nature Conservation Act.

Paragraph 3​ – mixing fact and fiction

The first sentence is a factual description of Hinchinbrook Island.
The second sentence, however, is not factual: There is no legal requirement or other obligation to ‘’showcase’’ national parks and world heritage areas. 
FACT: The world heritage duty (UNESCO) is ‘’Presentation’’, a secondary duty after Conservation (which includes Rehabilitation) and defined as ‘’appreciation of the Area for its intrinsic values’’.  Presentation is the provision for public appreciation of the natural values of the place; limited by conservation constraints including wilderness and aesthetic values as well as ecological values.
FACT: The wilderness concept powerfully protects natural values because it PREVENTS impacts rather than ‘’managing’’ (repairing) the damage afterwards.  ‘’Managing impacts’’ implies cycles of allowed damage and repair – sometimes called MAD (Maximum Acceptable Damage) or LAC (Limits of Acceptable Change) (see below for links). MAD and LAC are use principles, not compatible with the Cardinal Principle of national park management . See links.
Ecotourism is the commercial use of the area primarily to make money - an extrinsic purpose.

Paragraph 4 – ‘’jobs jobs jobs’’ – this is not even vaguely related to the purpose of national parks. 

National parks have been declared and dedicated for the preservation of nature; not for the benefit of private enterprise but to be held in trust by the Queensland government on behalf of all present and future Australians.

Paragraph 5 – the devil in the detail. Now that you’ve been softened up by paragraphs 1-4, we get to the guts of it: the Hinchinbrook Island National Park Management Plan (HINPMP) according to Palaszczuk-Newman. ​

FACT: The first sentence is true. It’s true because in 2017 the Palaszczuk government ditched the existing Cardinal Principle HINPMP and wrote their own new Palaszczuk-Newman HINPMP.
The incoming Palaszczuk government lied about reversing the Newman amendments to the NCA (promised in Opposition and as election commitments) because (as is now obvious) they had always intended to retrospectively strip national parks of the heart of their national park status: management under the Cardinal Principle. 
 ‘’to maintain and enhance visitor’s experience on the Thorsborne Trail … increase the opportunities for visitors to walk the Thorsborne Trail’’ ­– either this Minister just doesn’t get it, or she is as disingenuous as her predecessor.  It is patently ridiculous to state that wilderness experience is improved by increasing the numbers of visitors, and particularly in groups, when you can’t hear nature over the sound of footsteps and heavy breathing.
What would enhance visitor experience (but not on the agenda of the Palaszczuk-Newman government) would include QPWS supervision of the booking system; ensuring continuity of small scale local Channel transfers with local knowledgeable operators; ensuring a proper sequence of walker presence on the Trail (no bunching up, no unpermitted walkers); general ranger maintenance duties; and reintroducing the former QPWS and WHA shopfronts in Cairns, Townsville and Cardwell, where enthusiastic and knowledgeable QPWS officers once assisted walkers with interpretative and practical information.
‘’guided bushwalks … while maintaining … wild and remote’’ - pure spin. The word ‘’while’’ (meaning although, on the other hand) is used to join two incompatible ideas; intending you to believe in this entirely false association.
Visitors who want luxury accommodation and servants and vehicles to carry packs are clearly not visiting Hinchinbrook Island to appreciate its intrinsic natural values. They are using it as a backdrop to carry out extrinsic activities – ie, as entertainment. They and their infrastructure damage the landscape values (ecological, aesthetic, wilderness) and degrade its value as a national park. Virtual reality goggles a better option …
Nothing gives these operators and visitors any moral right to abuse this public good

Paragraph 7 (p2) - This paragraph is a frank denial of the Cardinal Principle. It represents a permanent loss of national parks.

We now know that by ‘’commercial use’’ the Palaszczuk-Newman government means selling out to private enterprise via leases, not permits.

FACT: The legislation quoted (Nature Conservation Act 1992) is the new Palaszczuk-Newman version, not the 1992 version (An Act is named to show the date the legislation was enacted, not the date of last amendment). The Palaszczuk-Newman version retrospectively gives the government the power to hand over to private interests those landscapes that had been dedicated to conservation in the public interest; and removed the ability to declare wilderness and world heritage management areas, among other things.

Paragraph 8 (p2) – the new ‘’spin’’ - commodifying national parks

FACT: The Bligh-Newman-Palaszczuk government has always refused to enforce lease conditions on Hinchinbrook Island (and other national parks), bouncing ‘’responsibility’’ from minister to minister to liquidator while doing not one thing to remediate or even reduce ongoing damage.  So much for ‘’best practice’’.
FACT:  when a lease is granted, government control is lost. All political parties have recognised this fact.  The lessee’s after-the-event economic arguments override any consideration of natural values and lease conditions. No public interest here – look at the recent history of national park leases.
Given the appalling ignorance and disdain of natural values displayed this year by DES and DITID BlackShoe publicists, the notion of ‘’rigorous assessment’’ is risible. ​

Paragraph 9 (p2) – a disingenuous explanation that IUCN ‘’protected area’’ guidelines support the Palaszczuk-Newman commercialisation of national parks. ​

FACT: the IUCN document broadly discusses ‘’protected areas’’. (1) National parks are a separate category – guidelines for ‘’protected areas’’ do not apply necessarily to national parks. (2) ‘’Concessions’’ includes all types of commercial access. (3) The IUCN Guidelines point out the pitfalls of leasing including the loss of control of the government and public. 
FACT: Unlike many of the countries wanting to manage and market ‘’protected areas’’ under IUCN categories, Australia is a wealthy first-world country where the GOVERNMENT has, for 110 years, had the responsibility for legislating, protecting and managing national parks – for the people, in perpetuity. 

.

LINKS – landscape management

Attachment 1 - Parliament House  https://www.aph.gov.au/DocumentStore.ashx?id=5dace941-bec7-4b18-94e7... vegetation maps will change only in one direction – towards increasing the area under ... using the principle of Least Acceptable Change (LAC) (a rebadging ... of Maximum Acceptable Damage orMAD); knowing that as time passes and old ...

Limits of acceptable change - Fact sheet    www.environment.gov.au/water/wetlands/.../factsheet-limits-acceptable-change

Limits of Acceptable Change    www.esf.edu/for/kuehn/www/CC-LAC-03.ppt      
The maximum level of use that an area or resource can sustain before deterioration occurs. ...Minimum numbers (at which a park is viable) ... LAC or. Limits of Acceptable Change. What is LAC? A process which requires managers to: ... Indicator: Loss of vegetation along trails; Standard: Trail width no more than 2 feet.

Ecological Conservation, Ecotourism, and Sustainable ... – MDPI  https://www.mdpi.com/1999-4907/6/7/2345/pdf     
by S Kaffashi - ‎2015 - ‎Cited by 9 - ‎Related articles
Jul 7, 2015 - Sara Kaffashi 1,*, Alias Radam 2, Mad Nasir Shamsudin 1,Mohd Rusli ... Received: 30 March 2015 / Accepted: 4 June 2015 / Published: 7 ... Abstract: Penang National Park (PNP), as Malaysia's smallest ... second-highest value on improvements in the park's ecological ..... zone, no construction is allowed.
 
LINKS – public service codes conduct and writing

Code of Conduct for the Queensland public service | For government ...https://www.forgov.qld.gov.au/code-conduct-queensland-public-service 
About the Code of Conduct | For government | Queensland Governmenthttps://www.forgov.qld.gov.au/about-code-conduct
Jun 7, 2017 - The Code of Conduct was developed to strengthen the integrity and accountability of the Queensland public service: demonstrate the government's commitment to the highest levels of integrity and accountability.
[PDF]
Download the Code of Conduct for the Queensland Public Service   https://www.forgov.qld.gov.au/file/11856/download?token=_56PSLue    Jan 1, 2011 - Statements that reflect and support the values and principles.
Writing style guide - DSDMIP style guide - Queensland Governmentservices.dip.qld.gov.au/opendata/digit/styleguide/writing-style-guide.shtml 
 These writing style guidelines outline the department s preferred use of words, phrases and punctuation for all digital and print content.

Web writing and style guide - For government  https://www.forgov.qld.gov.au/sites/default/files/web-writing-and-style-guide.docx
 For more information see the Public Sector Ethics Act 1994 (Qld). See the Web style guide for more information
Web writing and style guide | For government | Queensland Government    https://www.forgov.qld.gov.au/web-writing-and-style-guide   Oct 13, 2017 - Find out how to write clear, consistent and accessible web content.
Download The Queensland Cabinet Handbook - Department of the ...
https://www.premiers.qld.gov.au/publications/.../qld-cabinet-handbook-2017.pdf?a 5.3 General formatting and style for submissions . .... the collective responsibility of Ministers for government decisions requires collective adherence .... reports or studies within or for theQ