Proposed changes to group sizes in Blue Mountains canyons

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Proposed changes to group sizes in Blue Mountains canyons

Post by T2 » 17 Apr 2019, 15:34

Earlier this month, the Blue Mountains Director of the National Parks and Wildlife Service wrote to commercial canyoning operators to discuss a proposal to increase the maximum group size to 12 -- including in wilderness areas -- while also changing the client ratios so no additional guides are required to run these larger trips (I have attached a copy of the letter).

The proposed changes cover a range of popular Blue Mountains canyons, including many in wilderness areas. The canyons listed are: Butterbox, Claustral, Danae, Deep Pass, Dione Dell, Empress, Fortress, Grand, Hole in the Wall, Juggler, Kalang, Kanangra Main, Bowens Creek North, River Caves, Twister / Rocky Creek, Serendipity (Why Don't We Do It In The Road), Starlight (Newnes), Tiger Snake, Whungee Wheengee, Wollangambe 1 and 2, and Yileen. It also covers a number of commercially run abseiling trips.

The letter leaves me with more questions than answers, but the key points seem to be:
1) National Parks are currently reviewing conditions for both commercial operators and "non-commercial groups", which suggests clubs and recreational canyoners;
2) The existing restrictions placed on commercial operators regarding group sizes, trip types, client ratios, etc, are not always consistent with planning processes and policies, including the Plans of Management and Wilderness policy;
3) The current conditions are inconsistent, for instance in some canyons recreational groups are restricted to a group size of 8 but commercial operators are permitted 10 including guides;
4) A new online booking system now manages commercial canyoning trips and abseil sites in the greater Blue Mountains;
5) The release of the Australian Adventure Activity Standards (AAAS) and associated Good Practice Guides are the motivation for the review; and
6) The proposal replaces current licensing conditions that govern trip numbers and ratios depending on the specific conditions of a canyon or activities and replaces them with "a simplified minimum ratio recommendation approach ".

I have written to the acting National Parks Director for the Blue Mountains seeking clarity and further information. They have confirmed that the review is ongoing, but did not provided any further information about when and how recreational canyoners would be consulted about the proposed changes.

Bushwalking NSW is aware of this and it is hoped that they will provide a coordinated response, signed by the many clubs that run active canyoning programs.

Personally, I have a number of serious concerns not only with the proposal, but with the process. With regard to the process, it is deeply concerning that consultation about a major change to the management of canyons has initially only occurred with commercial operators and not with clubs or recreational canyoners. This creates a very worrying perception that commercial operators have greater access, and a greater say, in how our canyons are managed. The failure to have this conversation with the many thousands of recreational canyoners until after an arrangement was nutted out with commercial operators greatly undermines the credibility of the process. I believe National Parks should extend the consultation process and actively engage with clubs and recreational users immediately.

The proposal to increase maximum group sizes to 12 has serious safety and environmental implications. The fact that these larger commercial groups will have no additional guides also increases the risks for all involved. For recreational groups, the potential of being caught behind a large commercial group containing 10 people with no canyoning experience in a cold, wet canyon environment could be catastrophic. There appears to have been no assessment of the safety implications of this change, whether on the commercial groups, or on recreational groups caught behind them.

It appears that the proposal would also lift the group size for recreational canyoning groups in remote wilderness areas to 12. From my experience, it is very hard to manage a group of more than 8 people, with larger group sizes leading to more delays at abseils and the greater likelihood of problems. A 50% increase to the group size also means substantially higher environmental impacts, such as erosion, soil compaction, damage to vegetation, and disruption to native fauna. It appears there has been no analysis of these potential impact in proposing this substantial change.

Changing group sizes in wilderness areas should involve substantial research and consultation, not a casual mention in a letter to commercial operators. It would appear to breach existing wilderness policies and park plans of management. There is no explanation as to what justifies this change, although it could be speculated that commercial operators may have been lobbying to allow them to take bigger groups with the same number of guides to increase profitability.

The reliance on regulating groups under the new Australian Adventure Activity Standards are also potentially alarming for recreational groups. These have been designed for groups with dependent party members, like commercial operators or Scouts. They are not designed for individuals doing trips with friends or most club trips.

The combination of the references to the AAS and the new online booking portal also ring alarm bells for me about the potential for parks to move recreational canyoners into a system when permits / booking is required, and additional paperwork and restrictions are placed on trip leaders.

I would encourage people to read the attached letter. I will post further information as I receive it. I will also provide updates on progress at getting a combined response from clubs via Bushwalking NSW.

For people who are members of clubs, I would encourage you to discuss this with the club executive and examine either putting in a submission on behalf of your club, or supporting a joint effort.

For people who canyon purely with friends, or people who are particularly passionate, I would suggest making a simple submission outlining your own concerns, both about the proposal and the process.

Submissions must be emailed to louise.clifton@environment.nsw.gov.au by close of business Tuesday 7 May
2019. I would suggest also sending any submissions and concerns to NPWS Blue Mountains Director David Crust (David.Crust@environment.nsw.gov.au) and acting Director Cameron Chaffey (Cameron.Chaffey@environment.nsw.gov.au).

It's important that as recreational canyoners we have our voice heard in this process to ensure there are not substantial negative impacts on the safety, sustainability, or enjoyability of canyoning in the Blue Mountains.
PROPOSED CHANGES TO ACTIVITY NUMBERS.pdf
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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by johnmurray49 » 17 Apr 2019, 16:16

Should this be handled by this forum or should the NSW Canyoning Association take it on board and get back to its members and this forum with updates and more information.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by T2 » 17 Apr 2019, 16:30

johnmurray49 wrote:
17 Apr 2019, 16:16
Should this be handled by this forum or should the NSW Canyoning Association take it on board and get back to its members and this forum with updates and more information.
John, I think it's definitely something the NSW Canyoning Association should take action on. If you're a member, I'd suggest contacting the executive and raising it with them. They are also affiliated to Bushwalking NSW, so will hopefully be part of any coordinated response.

I would point out that of the thousands of recreational canyoners around Sydney and the Blue Mountains, only a tiny fraction are a member of the NSWCA and much less than half are members of formal bushwalking clubs, so there's lots of people who aren't represented or engaged via a club or other organisation. I think it's important that they also have some opportunity to find out about this sort of thing and have their say. I'd encourage them to put in brief submissions of their own in response to this.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by JulieB » 17 Apr 2019, 16:54

The NSW Canyoning Association is aware of this, liaising with various canyoning guides, and already drafting a response on behalf of commercial and recreational canyoners. Updates will be posted to the website when the submission is completed.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by dyl_jo » 17 Apr 2019, 19:10

Hey T2

I really appreciate your post, but wanted to point out a few areas where I think your post is a little biased and/or incorrect.

- It looks to me that this document is targeted at those groups who are already required to gain consents or licences for their activities. In that sense it makes sense to consult with those user groups. There have always been conversations from NPWS with commercial operators about guide:participant ratios and maximum party sizes and even numbers of trips per day for those commercial parties. I don't see a need to consult with the wider public where those conversations happen inline with the existing planning documents, frameworks and legislation. (I do however admit that the changes to the Max Party Size in wilderness is an interesting point - more on which below).

- I disagree with your assertion that "The existing restrictions placed on commercial operators regarding group sizes, trip types, client ratios, etc, are not always consistent with planning processes and policies, including the Plans of Management and Wilderness policy". I have looked in to this pretty carefully and the Regional Manager has discretion on these things and the last 3 RM's have acted consistently, not just with commercial parties, but with any group seeking a consent, including film and television productions, major events, club trips and the general public.

- "The current conditions are inconsistent, for instance in some canyons recreational groups are restricted to a group size of 8 but commercial operators are permitted 10 including guides" This is partially true. Recreational groups can also lodge trip intentions with the NPWS and be given exemptions to have larger groups. My understanding is that the idea is that those parties who register their intentions a) have to demonstrate their credentials/plans in terms of safety, environmental impact and impact on other users groups, and b) they also have something to lose if they don't abide by the rules (i.e. they won't be allowed back again with a larger group, or in the case of commercial could lose access).

- "The release of the Australian Adventure Activity Standards (AAAS) and associated Good Practice Guides are the motivation for the review" This is partially true. It is also due to the new online reservation system, new staff in the roles after the recent 'restructure' and a desire to simplify an overly complex system. It is also worth noting that the Aust AAS will not apply to non-dependent groups.

- "it is deeply concerning that consultation about a major change to the management of canyons has initially only occurred with commercial operators and not with clubs or recreational canyoners" It would be worrying if there was never any consultation with clubs or recreational canyoners, but the document itself states that this is the first step in a consultation process: "Consultation with key stakeholders including: not for profits/non-commercial user groups... and Blue Mountains Branch Regional Advisory Committee" (N.B. the BMBRAC fills the role of the voice of the public to the NSW NPWS regarding changes like this that aren't required by legislation/plans/policies to go to the broader public/minister/etc).

- I can appreciate the comment about the "worrying perception that commercial operators have greater access, and a greater say, in how our canyons are managed" however it seems to me the primary focus of this document is to groups who seek out permits to operate in park, and they are noted as parties to be consulted with. This is clearly NOT a review of the Wilderness Act or Plans of Management for any of the affected reserves (which absolutely would/should have a broader review!)

- I partially agree that "the proposal to increase maximum group sizes to 12 has serious safety and environmental implications". But you have left out the fact that commercial parties already have party sizes of 12 in many canyons, as do the general public (any non-abseiling canyon).

- The assertion that "these larger commercial groups will have no additional guides also increases the risks for all involved" is a little inflammatory. Why are commercial groups more risky than recreational or other parties? Last I checked (with you!) there was no requirement for bushwalking clubs to have qualified guides, certified equipment, or emergency plans etc. I do not believe that recreational users should be taking any position on guide to participant ratios for commercial parties unless they can demonstrate a) that there is a safety, environmental or visitor experience issue, and/or b) that clubs/recreational parties can demonstrate that they have the higher ground when it comes to operational standards. (To be clear: I think clubs and recreational parties have every right to have a say on maximum party size, [MPS] but not guide to participant ratios.)

- "For recreational groups, the potential of being caught behind a large commercial group containing 10 people with no canyoning experience in a cold, wet canyon environment could be catastrophic. There appears to have been no assessment of the safety implications of this change, whether on the commercial groups, or on recreational groups caught behind them." Is again a little inflammatory, and this could be flipped entirely to "For commercial groups, the potential of being caught behind a large recreational group containing 10 people with no canyoning experience in a cold, wet canyon environment could be catastrophic." But ideally should read: "For any party, the potential of being caught behind another large group containing 10 people with no canyoning experience in a cold, wet canyon environment could be catastrophic. There appears to have been no assessment of the safety implications of this change, whether on the groups that are given permission to operate at these party sizes, or on any other group that might get caught behind them". Again, I think that clubs and recreational parties have every right to have a say on MPS, but that conversation is not unique to commercial operators, it also applies to clubs, schools, scouts, and anyone who seeks permission for their activity.

- "It appears that the proposal would also lift the group size for recreational canyoning groups in remote wilderness areas to 12." This was my initial reading too, but having read it again I'm unsure if this is the intent. Having said that, I support maintaining the MPS of 8 in wilderness areas (except where a group seeks exemption from the RM), and I think that an increase to 12 is not inline with the intent of the MPS described in the PoM's for the reserves.

- I agree with you that "Changing group sizes in wilderness areas should involve substantial research and consultation, not a casual mention in a letter to commercial operators". It is not true that it would be a breach of existing wilderness policies and park plans of management (there are provisions for the RM to vary them) but I agree that increasing from 8 to 12 whilst permissible is not even close to being 'in the spirit of the law'.

- I'll allow your speculation "that commercial operators may have been lobbying to allow them to take bigger groups with the same number of guides to increase profitability" but would like to state a case that I have made many times before: The "US" vs "THEM" mentality should not be about commercial vs recreational. It should be about people who do the right thing vs dickheads. There are recreational and commercial users who seek to degrade wild places to their own benefit. So while some commercial operators (and other user groups who have permits like schools, or scouts) may have made those requests, it doesn't mean that they all did.

- You are correct in identifying that the Australian Adventure Activity Standards are not designed for individuals doing trips with friends or most club trips. The Australian Adventure Activity Standards are also not a regulatory document: they are a voluntary standard. However I acknowledge that the NPWS in this instance have made it a compliance document for commercial groups or others who seek/obtain consents for their trips on park. The only recreational parties who would be bound by these standards on park are those that both a) lead dependent groups and b) apply for a consent and would be subject to these conditions.

And mate, you know I agree with you that it's important that as canyoners (of ANY persuasion) that we have our voice heard in this process to ensure there are not substantial negative impacts on the safety, sustainability, or enjoyability of canyoning in the Blue Mountains.

Thanks for your contribution here mate, but let's try and make sure that it's not us vs them, but rather us for the bush.

(Full disclosure: I am currently the manager of Blue Mountains Adventure Company, a commercial guide, a recreational canyoner and a member of the NSW Canyoning Association.)

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by tom_brennan » 24 Apr 2019, 23:34

johnmurray49 wrote:
17 Apr 2019, 16:16
Should this be handled by this forum or should the NSW Canyoning Association take it on board and get back to its members and this forum with updates and more information.
John - while the NSW Canyoning Association (I understand) will make a submission, I don't seen any harm in a discussion going on in this forum.

Keep in mind that any NSWCA submission is going to have to be written by individuals, and (considered!) comments from forums like this can help inform the content of the submission.

Also, the NSWCA is going to have to balance any submission across the range of its members (recreational, club, guides, commercial etc). Other organisations (or individuals) may want to make their own submission specifically on behalf of their own members.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by tom_brennan » 25 Apr 2019, 00:54

Thanks for posting this Tim. I had heard about this but not seen any details of the proposal.

To me there is one main concern, and a couple of areas that make me slightly uneasy.

The main concern is the increase of party sizes for commercial groups in wilderness areas.

I was unaware that commercial groups were currently allowed up to 10 in wilderness areas, as recreational and club groups are only allowed 8.

I support the current limits in the plan of management for party sizes of 8 in wilderness areas (any activity) and 8 for abseiling canyons (whether wilderness or not). There is a clause in the plan of management for Blue Mountains NP to allow for larger groups in wilderness - but only "in exceptional circumstances", which seems appropriate:
Group size will be limited to 8 people within the wilderness setting to ensure that environmental impacts are minimised and opportunities for solitude are not compromised. Approval may be given by the Regional Manager for larger parties in exceptional circumstances. This limit for wilderness areas may be revised if ongoing monitoring indicates that larger or smaller party sizes are acceptable or necessary to achieve wilderness management objectives.(p61)
The proposal allows for standard commercial group sizes of 12 (10 clients/2 guides) both in wilderness areas and in all abseiling canyons. This does not seem like "exceptional circumstances", and is excessive. There is an additional statement that: "Trainee guides are permitted and are not included in group sizes and ratios". So it may be that party sizes of 13 or 14 are possible, but this is unclear.

There were a couple of items in the letter that made me a touch uneasy, not because of anything specific, but because they could be a precursor to further changes:

1) "Blue Mountains Branch has been reviewing the conditions in place for Commercial Tour Operators (CTOs) and non-commercial groups undertaking activities in National Parks across the Branch."
It's not clear what is meant here by "non-commercial groups", and perhaps it was just meant to imply TAFE/RTOs, as mentioned on p4. However, it would be a bit concerning if NPWS had been reviewing conditions for clubs and recreational groups without any consultation.

2) There's also the combination of the new booking system and the introduction of the new AAAS into the mix. This is obviously jumping at shadows, but it does raise the spectre of these being used for recreational or club canyoners at some point in the future.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by tom_brennan » 27 Apr 2019, 13:41

The other thing that concerns me in this is that it feels like the Blue Mountains NP Plan of Management is being overridden. My understanding is that the Plan of Management is a legal document, that operations in the park must be carried out in line with it, and that the Regional Manager has discretion in certain circumstances - but these are outlined in the PoM, and the RM (now Branch Director) does not have carte blanche.

The letter states:
The existing rules are now not always consistent with established planning processes, policy and documents including the Reserve Plans of Management and Wilderness policy.
Surely if this is the case, the rules should be brought into line with the Plan of Management?!

The Plan of Management allows for group sizes of:
- 4 persons per roped party on individual rock climbs;
- 8 persons for abseiling and canyons involving abseiling; and
- 12 persons (8 in wilderness) for canyons not involving abseiling.
which is fairly clear.

Under section 4.3.9 of the Blue Mountains Plan of Management, there are several clauses relating to commercial recreation and how it interacts with public recreation:
Where there are competing commercial demands or conflicts between general recreational use of the park and commercial activities, commercial activities will not be permitted to exceed a small proportion of the total use of any setting or location.
In the case of Empress, it seems like commercial access is being granted a considerable proportion of the total use of the canyon, and this is likely to increase with the proposed changes.
Commercial recreation activities will be required to conform to any group size limits imposed for various activities within the park, including those specified in this plan (see sections 4.3.2 to 4.3.8).
Commercial recreation activities do not appear to be conforming to the same group size requirements as for other groups. As noted above, commercial groups are already allowed groups of 10 in abseiling canyons and in wilderness areas, and the proposal is for 12 or more.

There is a clause under 4.3.2:
Group size will be limited to 8 people within the wilderness setting to ensure that environmental impacts are minimised and opportunities for solitude are not compromised. Approval may be given by the Regional Manager for larger parties in exceptional circumstances. This limit for wilderness areas may be revised if ongoing monitoring indicates that larger or smaller party sizes are acceptable or necessary to achieve wilderness management objectives.
However, as far as I am aware there has been no change to the limits for wilderness areas in Blue Mountains NP, and the Regional Manager is otherwise only allowed discretion in "exceptional circumstances".

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by T2 » 30 Apr 2019, 11:10

Julie, great to hear you are across this and that the NSW Canyoning Association is putting in a submission. I look forward to reading it when complete. Interestingly, from the discussions I've had with a few guides, it seems the concerns they have a very similar to those recreational users would have.

Dylan, thanks for that very detailed response. You've clearly thought a lot about this. I would point out that some of the points you pulled me up on -- such as the existing rules being inconsistent -- were not my statements. Those numbered points were simply an attempt to paraphrase the National Parks letter.

I agree that this process only directly impacts those organisations or businesses currently required to gain consent or licenses, but it does have the potential to set a precedent that covers everyone. Slippery slopes and all that...

I disagree that consultation should occur with certain groups first. This proposal will impact on other recreational users, along with the environment of these places more generally. Discussions should occur with all stakeholders, not just those who are likely to financially benefit from the change.

I have also heard reliable rumours that this consultation only took place because National Parks had started allowing larger group sizes into certain canyons, without any review, and commercial guides raised concerns about the change. I would be interested to know if you can confirm that.

I'm not trying to make it "us" versus "them", although there are clear winners in this change (the companies that run commercial canyoning trips) and clear losers (the guides who will see bigger groups with no additional staffing, so at best they will be doing more work for no additional pay, and at worst they will lose work because there will be less trips needed for the same number of customers). I also think there are very real environmental and safety issues that should be examined in this process.

I also agree wholeheartedly that the problem of "dickheads" is very real. It's been great to see a growing push from within the recreational community, whether from the NSW Canyoning Association, Bushwalking NSW, clubs, or individuals, to try to improve standard and better educate recreational users. There's a long way to go, but as a community I actually feel we're moving in the right direction for the first time in many years.

Tom, I think your concerns align very much with my first reaction. The issue about National Parks overriding the plans of management, in a way which not only doesn't fit the spirit of the law but also seems to run counter to the broader purpose of the plan to protect these amazing places, is quite alarming. I wasn't aware that the licensing arrangements for commercial canyoning companies already overrode this plan, and I'm not sure many park users or conservation groups are aware of that either.

If you have submitted your own response to the review, it would be great if you could share it here. Likewise anyone else. I will do so once I've had time to write something. I'm also trying to chase down a copy of a joint submission that was made by a group of commercial guides.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by T2 » 30 Apr 2019, 11:15

Also, below is a reply that I received from the acting Director of NPWS in the Blue Mountains to my enquiry about the review.

It is interesting that the expansion from groups of 10 to 12 in wilderness abseiling canyons -- 50% above what recreational groups are allowed and a 25% increase of customers per guide -- is described as "similar" to the conditions currently in place. I feel like there is a real lack of awareness among National Parks leadership of the significance of this change.
I can confirm that there is currently a review of activity numbers and ratios for commercial and non-commercial groups undertaking adventure activities on national parks in the Blue Mountains. The review is restricted to commercial tour operators (CTOs) and non-commercial groups who would routinely require a consent to undertake the activity. This includes registered training organisations (eg TAFE), schools, the ADF and any other group operating under the auspices of an organisation and its public liability insurance. It doesn’t apply to recreational users outside of these groups.

The ratios and numbers being discussed are similar to those already applied to CTOs in their current licences. The changes are proposed to ensure a simpler and more consistent approach to the management of canyons and to fit the Digirez system requirements. The canyons listed are all currently available to CTOs but many of them are sparingly used. It is not envisaged that there will be a significant change to the way canyons are currently utilised due to the proposed changes.

The Blue Mountains National Park plan of management is in the process of being updated. There will be an opportunity through this process for recreational users to provide submissions with regard to adventure activities within the park. Notwithstanding this, I would be interested to get your perspective on how the proposed changes may directly impact your use of the canyons. If you could provide some detail, we will consider this along with the submissions provided by the CTOs and non-commercial groups.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by ainemrg » 05 May 2019, 17:33

For those who have yet to submit to NPWS an element of the NPWS proposed changes which I have not yet seen mentioned is the removal of the current Weekly Trip limits on canyons.

The contextual weekly trip limits used in the pre-DigiRez booking system were developed to take into consideration canyon environments, to manage sustainability and canyoning experience. This particularly applied in the case of Wilderness canyons.

It is my understanding that the new DigiRez booking system cannot/does not want to manage the previous trip variables. A dumbing down/levelling of maximum trip numbers to accommodate the limitations of the program is the result. Reducing our canyons to the lowest common denominator of an inflexible computer program (vs a canyon management approach).

The response you received from NPWS "The changes are proposed to ensure a simpler and more consistent approach to the management of canyons and to fit the Digirez system requirements", confirms this.
(Not withstanding that canyons are neither simple or consistent environments).

For example. Under the old booking system Butterbox had a maximum of 2 trips per day and 8 per week. Maximum group size 8 plus 2 guides = 10 and no additional Trainee guides.

Under the proposed changes there can be a maximum group size of 10 clients, plus 2 guides = 12, plus trainee(s) - the number of trainees not specified. There is a maximum of 2 trips per day = 14 per week, which is an increase of 6 weekly trips (42%) = potentially > 72 additional people - per week.

Go through the recommended ‘Maximum Trips per Day’ chart and do the math on other canyons - Wilderness canyons (in bold). There is a similar picture. Even if the current ratios and maximum group sizes were retained the overall potential increase in canyon trips = numbers people will impact on canyon environments and all users.

It could be argued that higher weekly limits will not be realised, they are there as guidelines. This would be naive and demonstrate a lack of attention to history.

This could of course mean more work for guides. However, if we are serious about protecting our canyons and the experience of all canyoners, this potential increase and associated impact(s) should be of concern to all.

(NPWS Blue Mountains, Commercial Licensing Officer 2009/2017)

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by DaveJones » 05 May 2019, 18:00

4) A new online booking system now manages commercial canyoning trips and abseil sites in the greater Blue Mountains;
Will we have read-only access to this booking calendar?
It would be really nice if we all had access so we could avoid commercial groups. And I'm sure they like to avoid us as well.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by tom_brennan » 06 May 2019, 08:07

I have made a submission on behalf of Sydney Bush Walkers (SBW) (as President). I consulted with our canyon leaders, committee and conservation secretary before putting in a submission. It largely covers the comments I have made above, plus a few other areas.

I won't post it here but am happy to share privately. That said, I think each person/org should make their own comments that reflect their or their members views.

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Re: Proposed changes to group sizes in Blue Mountains canyons

Post by JulieB » 07 May 2019, 12:06

The NSW canyoning Association sent a submission last night.


The New South Wales Canyoning Association Inc (NSWCA) has been sent a copy of NPWS, Blue Mountains Branch proposed changes to the conditions in place for Commercial Tour Operators (CTOs) and non-commercial groups undertaking activities in National Parks across the Branch.
The NSWCA was formed in 2018 to be a voice for the canyoning community, which includes commercial canyoning.
NSWCA believes the proposed changes have potential to impact on the canyoning environment and experience of all canyoners.
Some guides, to support their concerns raised by these proposed changes, have approached the Association. Submissions and discussion on Social Media have been shared with NSWCA .
The following is the NSWCA position in support of these guides and the wider canyoning community. It has been complied by NSWCA members, who include Aine Gliddon. Aine’s historical knowledge of commercial canyoning is reflected in this submission.

Definitions:
The document refers to non-commercial groups. NSWCA believes this refers to TAFE and other groups who operate under consents for approved activities in canyons.
However, it is not clear in the document. The document has been distributed widely and caused disturbance within recreational canyoning groups. They are concerned the changes in group sizes and inappropriate application of the Australian Adventure Activity Standards (AAAS) will be applied to them.
Another confusion exists around the term “Minimum ratios”. Some guides have interpreted this to mean a minimum total group size of 6 with the upper limit undetermined.. ‘Maximum’ is generally the accepted term when describing participant limits or guide/client ratios.
 Can NPWS please clarify?

Australian Adventure Activity Standards (AAAS)
NSWCA understands that the proposed changes to group sizes and ratios come in concert with the upcoming introduction of the Australian Adventure Activity Standards (AAAS), to encourage self regulation and risk based management by commercial tour operators.
The Association recognises that NPWS is not responsible for the safety of commercial operations and supports the adoption of the AAAS as a sound risk management tool for commercial canyoning with dependent groups..
The AAAS provides for Land Managers to set their own ratios as NPWS has done.
In more than one submission guides have expressed concern that, in the interests of commercial viability, operators may adopt the NPWS maximum ratios/group sizes even if at variance with their own AAAS risk management assessment (a lower ratio).
“My feeling is that self-interest will ultimately see canyons being guided at maximum ratios regardless of the spirit of the AAAS. In order to maximise profits, canyon operators will do the necessary risk management justification to run every canyon at the maximum ratio allowed if they get five clients or 10 clients booking to do the same canyon.” Guide
The primary author of a letter, signed by 26 other guides, was guiding in 2011. Blue Mountains Branch may remember a ‘commercial viability ‘ call and what followed.

Compliance
“It's up to operators to do the right thing. If organisations comply with the AAAS then I don't think the changes are going to be a major issue. Any operators fully compliant with the AAAS is going to be operating safely.” Guide
Non-compliance affects other operators, guides, clients and general canyoning public.
While NPWS may remove itself from operational risk management of licensed commercial canyon operators, it should not divorce itself from the consequences of mismanagement.
 What measures do NPWS intend to employ to ensure CTOs have adequate AAAS risk management plans in place and compliance with them?

Proposed changes to Group sizes/ratios and trip numbers
While NPWS is not responsible for ensuring the safety of commercial operations it has legislated responsibly for the conservation of the environments and experience of all those who visit our canyons.
The document states the proposed changes are “to implement a more consistent and simple approach”
Canyons are neither consistent nor simple environments. A consistent approach does not fit for all. Canyon management should reflect this.
The proposed changes put all canyons into the same ‘basket’, regardless of difficulty, water considerations and commitment- benchmarks the AAAS employs. The NPWS document does not appear to reflect The AAAS/Core Good Practice Guidelines.
The document states that previous ratios were not contextual. NSWCA believe they were, although not in the sense of NPWS’s current AAAS interpretation – ie “weather, experience of guide or group”.
“In the proposal NPWS has chosen not to use the supervision ratios outlined in the AAAS and ended a long standing NPWS practice of setting ratios which are context specific (e.g. specific to the canyon, common aquatic conditions, known vertical obstacles, communications and the known history of incidents/usage).
I believe any change to canyon ratios should be in line with the AAAS commonly used supervision ratios. If the changes are not in line with the AAAS ratios, then the old ratios are far better than a flat ratio of 1:5 when it comes to being context specific and workable for industry.” Guide. Setting ratios is not a matter of a mathematical equation; ratios are a tool to manage risk in diverse, complex, canyon environments.
“The proposed new ratios of 1:5/2:10 for every single canyon seem to have no more science to them than their standard simplicity and symmetry. Where is the logic, the empirical data, that suggests the current ratios are wrong and the new ratios superior?” Guide.
 NSWCA asks NPWS how and why the proposed ratio of 1:5/2:10 was determined and why applied uniformly to all canyons (other than the previous being “overly complex to administer”).

Environmental and canyoning experience impacts:
Guides and NSWCA are concerned about the impact these changes may have on environmental and canyoning experience of all canyoners, particularly in Wilderness Areas.
The Association shares guide concerns for the environmental sustainability of commercial [all] canyoning if these proposed changes are implemented.
Canyoning has seen an increase in participation over recent years. Most canyons are showing some impact others significant wear and damage. These impacts are being seen within canyons and on access/exit tracks.
As guides point out, increased numbers of canyoners add to congestion, waiting times, overall trip times, all factors which affect the canyoning experience. These can also contribute to influencing safe outcomes for canyon trips.

Removal of contextual Weekly Trip Limits
The NPWS document states that using the new DigiRez booking system “per week limits are not possible”.
Of concern to the Association the chart presented in the document. Page 3, ‘Recommended Max Trips Per Day’ which illustrates a potential marked increase in canyon trips, with the associated increased group sizes, particularly Wilderness canyons.
• Under the ‘Previous Max Trips’ Butterbox could have 2 trips per day and 8 per-week.
• The proposed 2 trips per day translates to 14 trips a week = 42% increase. Those 14 trips potentially put an additional 72+ people (if add Trainee guides) into this popular canyon.
• Similar applies to other canyons.

In a response to a question raised by a recreational canyoner NPWS replied:

"The ratios and numbers being discussed are similar to those already applied to CTOs in their current licences. The changes are proposed to ensure a simpler and more consistent approach to the management of canyons and to fit the Digirez system requirements. The canyons listed are all currently available to CTOs but many of them are sparingly used. It is not envisaged that there will be a significant change to the way canyons are currently utilised due to the proposed changes. "
NSWCA believes that canyon management should not be reduced to the lowest common denominator of a booking system.
NPWS may not envisage a significant change to the way canyons are currently utilised; in 2014/2015 the commercial use of Empress doubled. A new operator took advantage of unused capacity in an unforseen manner. If the opportunity is there to exploit, what is to say someone will not?
The document states “Maximum groups per day will be monitored and can be adjusted in DigiRez if needed e.g. if exceeding the previous per week guideline”
Even if the previous weekly limits were restored, the increase in overall group size(s) will see increased traffic and associated impacts in canyons; environmental and on the experience of all users.
In popular canyons it is likely the maximum groups will exceed the previous per week guideline.
 Do the ‘Recommended Maximum Trips per Day’ apply solely to CTO’s or also intended to account for non-commercial groups? (TAFE, Schools – those who require consent)
 How does NPWS propose to ensure that the previous per week guideline is not exceeded?

NSWCA does not support:
• Increased maximum group sizes, across the board, to 12 (or more if add Trainee guides)
• In non-abseil canyons – support maintaining the current 1:8.
• Increases that raise the maximum group size to in excess of 4 in Wilderness above that in the Plan of Management.
• We believe a change in overall group size of this magnitude is a matter to be referred the review of the Plan of Management.
• The recommended group size (excl guides) in wilderness canyons being 10 participants. We believe should be a max of 2:8 and not have trainee guides permitted as extra
• Removal of contextually based weekly trip limits
• Specifying 8am to 6pm (with exception of Empress)
• Inconsistencies in group separation times in Wilderness canyons. Is it 30 or 60 minutes. 30 applied in the past.
• Change in Pre 12:30 separation in Empress from 60 to 30 mins.
• Empress: apparent removal of commercial trip restrictions before 12:30 on weekends, school and public holidays.
During the 2014/2015 season it was demonstrated (complaints and survey) that the weekend, PHs and School Holiday pre-12:30 use of Empress by commercial groups was unacceptable to recreational canyoners. Subsequently, these trips were blocked in the then booking system.
We look forward to discussing these important issues face-to-face during the next consultation stage.



Julie Burton
President on behalf of NSWCA

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