Parks Victoria’s Consultation Report in relation to the GGLMP

A couple of months ago, representations were made to PV that its Consultation Report (summarising the feedback from the public on the draft GGLMP) should be released significantly in advance of the release of the final GGLMP, i.e. the Consultation Report should not be effectively ‘buried’ by being simultaneously released with the long-awaited final Plan itself.

PV listened to us… its Consultation Report has now been released (see the Engage Victoria website  https://engage.vic.gov.au/gariwerd-management-plan ).

The feedback about those aspects of the draft Plan that related specifically to rock climbing or bouldering is summarised below.

The text that I have highlighted in yellow is feedback that matches, or is very similar to, that provided by the VCC in its submission. Similar feedback may also have been provided by others (and, indeed, the VCC was happy to make a draft of its submission available online to help and encourage people who were considering composing their own submissions).

The very few extra comments that I have added are indicated in blue font.

From the report:

Designated rock climbing areas

Support for the designated rock climbing areas approach varied, the general support categories were:

• Support for restrictions on climbing and the use of designated areas but with major caveats on the scope, type and nature of those restrictions; use of designated areas that are smaller in size rather than keeping blanket bans across huge areas, changing the ‘all or nothing’ approach (climbing allowed or climbing prohibited) to instead encompass a category which allows climbing but with specified restrictions appropriate for the site concerned).

• Support for having designated areas but with the request for a reconciliation led review mechanism to be included in the decision-making framework so future mitigation measures can be agreed that may change the designation of a climbing area to green.

• Support for having designated areas provisional on reviewing an additional 36 areas for opening to achieve quality, popularity, and range of climbing experiences across Gariwerd.

• Designated areas approach accepted provisional on the need to break these areas up into much smaller areas to be assessed separately and creating an additional designation; ‘designated climbing area with restrictions’.

• Use different area designations; Prohibited Climbing Areas, Managed Climbing Areas, and Wild Climbing Areas. Managed Climbing Areas would have agreed conditions which would be monitored by climbing volunteers, and Wild Climbing Areas are low visitation sites that would not be monitored but visits would require climbers to register their visits with the land manager.

• Rejection of the designated areas approach and request it is replaced with a climb by climb approach where a ten-metre exclusion zone is placed around culturally significant sites and enforced by legal set asides. This would include adopting the volunteer-developed Victorian Climbing Management Guidelines.

• Rejection of the need to have climbing restrictions at all. The common concerns people shared with the current designated climbing areas approach and determinations were that:

• There are not enough designated (green) climbing area to meet the current aim of a ‘diverse and extensive range of climbing experiences’ in Gariwerd. [Said or implied in different ways in the VCC submission. Huge impacts were noted, across all styles of climbing (but, particularly, disproportionate impacts on bouldering and on the best quality roped climbing)]

• The current green areas do not include enough climbs that are difficult, internationally recognised, and appropriate for sport climbing.

• The current approach will put additional pressure on climbing areas that are open as more people are funnelled into fewer areas. This could create more environmental issues in those locations.

• The current determination impacts people with a disability, because the only all abilities climbing area is a designated Licensed Tour Operator (LTO) only area. This creates an economic barrier for people with a disability who want to climb.

• Having such large areas means crags are designated no climbing despite being significant distances away from cultural or environmental values.

• It does not allow for case-by-case considerations for sites where impacts could potentially be mitigated or managed. Nor does it consider the type of climbing undertaken and its risk profile for example, many felt traditional climbing posed less risk than sport climbing.

• The statement that a climbing area would be closed if there is evidence of harm or unauthorised anchors concerned people because many people should not be punished for the actions of a few, and this is not the approach taken for graffiti on walking trails.

• It does not allow for robust review of decisions based on further knowledge or changes to climbing practices.

• Many of the non-climbing designated areas can still be visited by walking which people feel is unfair because all recreation can cause harm.

Other suggestions for how climbing can be managed (in addition to those above) were:

• Limit the numbers of people who can climb in an area per day to reduce the impacts.

• Implement seasonal or rotational closures to ensure sites are protected and impacts can be managed.

• Development of a template for ‘rock climbing decision-making’, which could be considered for other recreation activities.

• Have different restrictions based on the type of climbing, for example traditional climbing which does not use bolts or chalk could be allowed in more areas than other types of climbing. [Not directly suggested. But the VCC recommendation for having another classification possibility for climbing areas/sites – climbing allowed, but with specified restrictions – would, if adopted, enable such distinctions to be made if appropriate.]

• Allow climbing but prohibit fixed anchors, chalk, and mats across the whole landscape.

• In sensitive areas stipulate that climbers must abseil down to climb rather than climb from the base of a cliff.

• Have a fee for access pass or permit to climb in the landscape that generates funds to be put back into the monitoring and rehabilitation of climbing areas.

• Use directional signage, access track alterations, platforms, and barriers to protect values while continuing to allow climbing in the area.

• Have more education programs about what values exist, the cultural landscape and how to climb with minimal impact. If possible, these programs could be led by Traditional Owners.

Licensed Tour Operator Only designated climbing areas

Many respondents expressed concerns about the climbing category Licensed Tour Operator (LTO) Only. They felt it favoured commercial interests and created equity issues. Some believed this goes against the aims of the national park and Parks Victoria’s goal to encourage people to enjoy parks. They also pointed out that the LTO Only areas have some of the best introductory climbs and the only all-abilities climbing areas, which can entrench disadvantage for people with lower income and people with a disability.

They provided two alternative suggestions:

• Allow groups, clubs, or organisations to undergo the same process to access the LTO Only areas, including using the booking system, cultural inductions, having a code of conduct etc. This will allow people to access these areas under the same conditions without incurring a cost.

• If a climbing permit is put in place (including a cultural induction) for all climbers this could then allow all climbers to access the LTO Only sites if they operate under the same conditions.

Possible climbing areas and new climbing areas

A lot of respondents expressed concern about the number of Possible Climbing Areas that remain and timeframe to have them all assessed, and a decision made about whether climbing can occur or not. They believed that the precautionary approach where climbing is not allowed until assessments have taken place is inconsistent with how other recreation is managed in the landscape, for example allowing walking on tracks where possible cultural values have been reported.

Some respondents requested that Possible Climbing Areas stay open until assessments are completed and the presence of values under threat are found. While some respondents agreed with the strategy to not allow any future climbing areas, others thought this was short-sighted and inconsistent with other activities in the park. They believed if assessments were undertaken new climbing areas should be able to be established, especially as this may help alleviate pressure on the existing designated climbing areas.

Rock climbing permit

Respondents opinions on the proposed rock climbing permits were mixed. Some supported the proposal, especially if it remained free and was for the purpose of education and awareness. Others did not support the proposal, they did not understand why rock climbing would be required to get a permit when other comparable users such as hikers, four wheel drivers and geo-cachers are not.

Most respondents who did not support a permit did support a voluntary online induction for education purposes instead.

Some respondents expressed concern that a permit would make it hard for people to take a friend or family for an introductory climb.

An alternative proposal to a permit suggested by some respondents, was developing a code of conduct in collaboration with climbing representative groups. They believed this would ensure greater uptake and engagement from climbers.

Respondents were asked to provide suggestions for making the permit system a simple and straight forward process. Their key suggestions were:

• An online process that involves education and a short quiz at the end.

• Provide people with a document via email that can be shown on a phone or printed. Picking up a permit was not recommended due to people entering the landscape from many different points.

• Ensure the process is available in multiple languages, so international tourists can complete it.

Fixed anchors

Responses to the management of fixed anchors was mixed. Respondents agreed that climbers should remain responsible for the safety of anchors, they also supported continuing to allow temporary protection and temporary anchor points. There were consistent concerns, however, with not allowing the installation of new anchors and having to seek authorisation for the replacement of anchors. Many respondents feel that installing bolts has minimal impact and would like to see an ‘independent ruling’ of whether installing bolts is permitted under the National Parks Act 1975. They highlighted that using fixed anchors can at times mitigate impacts of climbing. Some expressed concern about the resource inefficiencies of having to seek authorisation to replace anchors, others supported the proposal.

Many respondents shared the benefits of allowing abseiling descent bolts because they minimise wear and tear and reduce erosion at the top of cliffs. Respondents consistently did not support using the defence force to remove fixed anchors to rehabilitate areas. Some explained this was because they believe the defence force does not use the latest minimal impact climbing techniques. They believe working with climbing groups was a better solution.

Use of chalk

The PV recommendation that any climbers’ chalk used in Gariwerd should be coloured, in order to minimise visual impact, was, imho, one of their least contentious climbing-related suggestions. It was one of the few for which we didn’t offer a preferred, alternative recommendation.

Continuing to allow people to use chalk in designated areas, but stipulating that the chalk must be coloured, was the climbing condition which received the least objections from respondents. Many felt this was a sensible and easy solution.

There were a few conditions raised:

• Allowing a phase-in period for there to be coloured chalk available in Australia.

• Confirm that coloured chalk is safe for human use and environmentally safe.

• Recommend a few colours for use in Gariwerd, as the rock varies greatly in colour and it would be hard to perfectly match every colour.

Those who did not support the proposal for coloured chalk believed that it was better to work with climbing representative groups to agree how chalk use can be monitored and cleaned up regularly by climbing volunteers.

Some noted that chalk is mostly an issue in areas that are not rain-washed and changes could be confined to specific areas, such as overhangs.

Lastly, some respondents suggested that liquid and chalk balls should be encouraged as in this form less chalk is used.

Designated tracks

Respondents felt the requirement to access designated climbing areas via designated tracks was both inconsistent and impractical. They highlighted that off track walking is allowed in the park and the process of walking to some cliffs requires off track walking so it should be treated the same as any other activities in the park. They also expressed concern that many of the current green climbing areas did not have designated tracks to them, which could lead to a greater reduction of climbing areas.

Instead they proposed that designated tracks are developed for high visitation climbing areas, while off-track walking is permitted for the less popular areas. They believed the climbing community would welcome the opportunity to volunteer to build and maintain these designated tracks.

Designated bouldering areas and use of mats

There was confusion among some respondents about whether bouldering was to be permitted as there were very few bouldering areas designated green. Many respondents felt if that was the only sites to be permitted bouldering is essentially being eliminated in the landscape.

They also believe that because bouldering mats are required for safety they should continue to be permitted.

It was acknowledged that the use of bouldering mats does have impacts on the base of boulders, so alternative suggestions were provided:

• Use rotational or seasonal closures to allow vegetation to grow back.

• Restrict the numbers of people who can be at a bouldering area at once.

• Create platforms to use mats on so values are protected, similar to building board walks.

• Provide signage or barriers that indicate the extent of area mats can be put down and to educate people not to drag mats.

It was noted that some respondents felt that certain sites can withstand more intensive use than others.

Our submission was not that all of the above mitigation strategies should be rolled out across all bouldering sites but, rather, that there should be careful consideration of such strategies at individual sites as feasible options in preference to banning.

Some respondents also requested that bouldering areas outside of designated climbing areas are considered for assessment. This is because roped climbing and bouldering do not always occur in the same locations, and not allowing standalone bouldering areas could exclude some internationally renowned bouldering problems.


Engagement with climbers

Respondents consistently requested more opportunities for rock climbers to engage with land managers and Traditional Owners. They believed more engagement would improve the relationships between the three groups, provide additional resources and result in better solution for managing climbing areas.

There were three common suggestions for how future engagement could be formalised in the management plan:

• Create a consultative group/advisory committee of rock climbers that regularly meet with land managers. The purpose of this group would be to:

• Provide feedback and resolve issues early

• Create a priority list of possible climbing areas for assessment

• Assess future proposals from climbers about climbing management and development

• Review applications for replacing new and existing fixed anchors.

• Work with volunteer groups such as Crag Stewards Victoria to enable volunteer management of climbing areas and access tracks.

• Create a process where a third party (for example a volunteer group) could be entrusted with managing a climbing area through a memorandum of understanding. This group would need to promote and support the goals of Traditional Owners.

It is heartening that PV seems to have accurately captured the essence of the various concerns and suggestions proffered by the climbing community.
The big question now is whether PV and the Traditional Owners, having heard the feedback, are prepared to take key aspects of it on board and amend the final Plan accordingly.

We will know soon enough – we are now told by PV that the final Plan is due to be released before the end-of-the-year.

KL