Proposed changes to group sizes in Blue Mountains canyons

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T2
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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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johnmurray49
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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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