From the Outdoors NSW & ACT Submission to National Parks Wildlife Service for Blue Mountains National Park and Kanangra-Boyd National Park Draft Plan of Management 2023.
Outdoors NSW & ACT's (ONSWACT) aim is to advocate and promote responsible and sustainable access to our parks so that we can continue to connect people with nature for their health and well-being. We understand that this Plan of Management (POM) is also a delicate balance between conservation and access as the most visited National Park in Australia. We appreciate the National Parks & Wildlife Service's (NPWS) efforts in working with us to ensure guided access by eco-pass holders continues to ensure communities can access nature in a safe and sustainable way, and that independent recreator needs are considered as well.
Our organisation and its members respect and appreciate our First Nations communities and their understanding and knowledge of Country. Aboriginal culture and respect for country is a key component of our education of the place. We aim to continue working with community to ensure the right balance of protection, conservation, education, and access is maintained. We support NPWS doing everything it can to encourage First Nations opportunities when it comes to
engaging in park management, offering cultural experiences, and interpretive signage. Encouraging Indigenous-owned commercial tourism operations in the parks is a huge part of increasing collaboration and access for community. Our own industry’s risk management tools, in the Australian Adventurous Activity Standard, also endorse this approach.
We would like to extend our thanks to NPWS for their inclusion of many user groups at the face-to-face consultations as feedback from our members complemented your approach and engaging conversations. Unfortunately, the conducive conversations held in person in some cases have not reflected the outcome in the current draft POM so we will highlight these below in the relevant activity sections. In addition, we would like to see an increasing consultative process with NPWS regarding commercial operators and outdoor leaders when it comes to decisions about ratios, track/area closures, maintenance requirements that affect commercial operators. We wish to work in true partnership with NPWS to get the balance right but fear we are not considered in many cases as a legitimate stakeholder on managing park.
COMPLIMENTS ON THE PLAN
We support many of the inclusions of the POM, including installation of minor infrastructure in wilderness areas where that infrastructure is for the benefit of the environment (eg toilets in the wild dogs, or track care). In addition, we would like to highlight support for maintaining the party limit of 8 in wilderness areas. The new inclusions in the Jamison Valley also support the increase in visitation and the need to disperse visitors so impact is lessened. Having more walking tracks and more campsites to spread the load over a bigger area and stop places like the Ruined Castle campsite and the Mt Solitary track being loved to death.
In the case of the Jamison, some extra campsites and tracks could also mean the valley is still accessible to campers and hikers the next time there is a landslide on the Mount Solitary track.
SLACKLINING & HIGHLINING
The slacklining and highlining community were at the consultation meetings with some excellent
discussions and understanding gained about the low impact on the environment while being a growing sport that attracts world-wide engagement. Despite these positive discussions, we were surprised to read that the activities were not included as a valid user group in the new plans. Quoting the draft: “Basic slacklining (webbing is less than 2 m off the ground) is allowed unless sites have been identified as closed for this activity by park signage and/or routine park visitor notification channels. Other slacklining variations are not permitted (except with the consent of NPWS). The group size limit for slacklining is 8 people."
This wording is then contradicted further in the document when highlining is then mentioned to be included under permit. We understand the need to monitor activities that are somewhat emerging and growing so ask that NPWS allow the activity under a permit approval system for specific locations of which we can help to identify to minimise impact, that could be applied for a period of time. We suggest a 6- or 12-month permit would be best to limit red tape and administrative processes.
As a growing activity we encourage NPWS to understand it and allow in a managed way as if not recognised will encourage people to conduct this activity in unsafe locations leading to possible incidents. This is where Outdoors NSW & ACT and our member, the Australian Slacklining Association, can assist NPWS to best manage this emerging activity.
Requests for consideration;
Include Highlining as a legitimate activity across all relevant parks within NPWS including the POM. This is a growing sport with international appeal that needs to be managed, not ignored.
A consent process allows Highlining (slacklining above 2m high) access in a managed but inclusive way. Permit by each activity is not suitable due to time requirements. Permits need to cover a broad timeframe to allow for changes due to weather or other conditions that may not suit a particular day or time.
We believe that integrating highlining into the POM is a logical step forward, aligning with global recognition and responsible practices observed in other locations.
Canyoning is an activity that is synonymous with the parks in question. There are some concerns with inclusions in the POM that would limit significant canyoning activity. This relates to the new inclusion of ‘ziplines’ being disallowed. Zip-lines are often used as safety mechanisms or retrieval methods in canyoning. An example is Juggler canyon, where a zip-line must be used as a safety option in high water.
To ban zip-lines would possibly increase incidents and they need to be recognised for the role they play. In addition, slot canyons can be used as places of refuge and located in areas where multi-day canyons are explored by eco-pass holders and independent recreators. They are infrequent in visitation, and slot canyons are safe refuges.
Requests for consideration;
Allow zip-lines as a safe retrieval method, to ban could mean increased incidents in canyoning.
Allow slot canyon use on multi-day canyons where they are a safe refuge for canyoners.
ROCK CLIMBING AND ABSEILING
Rock climbing refers to all styles of outdoor climbing including Traditional Climbing, Sport Climbing, Bouldering and Deep Water Soloing. To access or descend many climbing routes it is necessary to descend ropes (abseil). Users include eco-pass holders and Independent recreators. We support the following inclusions in the POM;
• The policy of individual climber responsibility for assessment of fixed protection.
• Fixed protection can be considered appropriate in certain contexts in Wilderness areas.
Whilst we appreciate the inclusion of rock climbing as a legitimate and low-key recreational activity compatible with the objects of the NPW Act 1974 (s 30 E) there are clarifications and omissions we wish to have reviewed.
Requests for consideration;
Climbing in Glenbrook Gorge should be allowed in a managed way, instead of excluding access to this significant site.
Clarification of what is an “unacceptable risk” to walkers is required and alternative management solutions should be examined rather than banning climbing. We can help with this in a managed way.
A complete ban on climbing on limestone is limiting and impacts a wide range of historical climbing locations. Climbers need to abseil to access climbing routes in the Jamison Valley and Mt Banks cliff line. The ability to do so needs to be clarified as it was in the 2001 PoM.
Just as bushwalking heritage is acknowledged, rock climbing heritage should also be recognised.
FUTURE ACTIVITIES OR OPTIONS
Traditionally POM’s have limited innovation options, newfound values and experiences. We would like to request that NPWS consider the use of terms like “and any future recognised values” (eg cultural or geo or scenic heritage) in its plans. Anticipating additions to the park(s) through the acquisition of holdings or other land is also part of this mechanism to ‘future-proof’ the POM without having to undergo a full review to ensure compliance. The POM should have a mechanism for dealing with future outdoor activities that haven't been invented yet but that ARE in line with the rest of the POM instead of limited to access to ways in which the community can connect with nature for their health and well-being.
OFFER OF EDUCATION TO PARKS STAFF & STAKEHOLDERS
Where staff are not aware of the requirements of any of the above activities or other outdoor pursuits, including the Australian Adventurous Activities Standard, ONSWACT would like to offer to assist. This can be arranged to ensure the knowledge is current and engagement is also opened for future discussions on best practice within activities. This would also help staff with compliance monitoring.
We at ONSWACT would like to continue to work closely with NPWS on ways to preserve and ensure managed access for the best community engagement and connection to place we can.