• PV questions if regulations are an effective use of Gov funds
• Cultural heritage plans have led to minimal overall benefit
• Excessive costs led to heritage protection project cancellations
• PV only completed protection work at 4% of Vic rock art sites in 2017

We obtained an interesting and quite damning document penned by Parks Victoria themselves back in 2017 *. It does not directly address issues with rock climbing and cultural heritage – but the implications of what it reveals are certainly evident in the issues that Victorian climbers are now facing with the world’s largest climbing bans. To most climbers PV appears to lack the will to do anything but put paper bans around large areas of the Grampians climbing areas instead of actually doing trackwork, proper signage or allowing cleanups of chalk etc to protect cultural heritage. After reading this document it will be clear why they are standing back and watching the climbing community burn whilst washing their hands of the problem. And it boils down to money and an overly burdensome permit process that PV calls “unsustainable“.

What is the document?

It is a public submission from Parks Victoria to Aboriginal Victoria (a Victorian Government Dept) regarding a review of the Aboriginal Heritage Regulations 2007 prior to them being revised in 2018. It was a chance for PV to have a whinge about problems they had experienced since these regulations were last updated in 2007. And whinge they did. Take a read of the short five page submission.

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The gist

In this document PV complains (a lot) that the process of complying with the Aboriginal Heritage Regulations is a financial and staffing burden that hinders their own attempts to protect cultural heritage on land they manage (17% of the total landmass of Victoria). In their own words:

“Parks Victoria is regularly required by the Act and on advice from Aboriginal Victoria to prepare Cultural Heritage Management Plans (CHMP) and Cultural Heritage Permits (CHP) allowing for ‘harm’ of cultural heritage during land management and infrastructure projects. Many of these projects require the engagement of a heritage advisor. Even if heritage advisors were employed in house, the scale of the Parks Victoria estate and the cultural heritage work required would still require significant and unsustainable resourcing.

Parks Victoria is concerned that the required resources and overall cost of preparing CHMPs and CHPs has led to minimal overall benefit for the management and protection of Aboriginal cultural heritage and Traditional Owner benefits on the parks estate.”

Yikes. That is not exactly a glowing review of the process. The words “minimal overall benefit” doesn’t need detailed analysis – PV make their point clear from the start. They don’t believe this process is worth doing.

Runover by costs

According to their submission the average cost for Parks Victoria to prepare a CHMP is approximately $50,000, with some costing up to $200,000, while Cultural Heritage Permits cost an average of $6,000. They also present examples where the cost of obtaining a Cultural Heritage Management Plan sometimes outstrips the actual cost of doing the work by a factor of six. Again in PV’s own words:

“A CHMP is currently being prepared to enable the construction of a boat ramp. The boat ramp will cost around $10,000. However, the CHMP will cost approximately $60,000 once completed.”

Even a simple bit of road maintenance on their land requires an assessment and permit it seems. Their example given was:

“A cultural heritage assessment was recently conducted that involved a site inspection of 80 kilometres for proposed future road maintenance. This inspection required participation of a total of 12 Parks Victoria staff and Traditional Owner representatives over a period of 3 days. 27 isolated artefacts were located on the roads. A heritage advisor will be required to record the artefacts and prepare the permit, with an estimated cost of assessment and permit application totalling $23, 000 for the 80 Kilometres. Even with heritage advisors employed in house, the cost and resources involved in replicating this exercise across the entire Parks Victoria road network is unsustainable with no clear positive outcomes for cultural heritage.”

Parks Victoria are responsible for an extraordinary 30,342 kilometres of road in Victoria at the time this document was published. If it costs $23,000 for 80km ($287 a kilometer) – that would mean the whole network would cost $8.7 million to inspect before they could even lift one finger to actually maintain it. Maybe those rough car destroying corrugated roads in the Grampians are like that for a reason? And it doesn’t end there. Even getting the permits for maintenance of walking tracks is a major cost:

“The cost to Parks Victoria preparing CHMPs for the state in relation to walking tracks alone is prohibitive and unsustainable in the long term.”

And if this is all a huge waste of money where do they think it would be better spent?

“This funding could be better directed toward Aboriginal burial protection works, cultural mapping, rock art conservation or any number of projects that would involve meaningful partnerships with Traditional Owners.”

Expensive & with questionable benefit

So, in their own document, Parks Victoria admits that these mandatory management plans and permits are a) excessively expensive, b) give minimal benefit to protecting cultural heritage and c) don’t benefit traditional owners. We have to ask the question then – who do these actually benefit? We can only guess the small amount of people who work in the assessment industry and the staff employed to manage the permits at Aboriginal Victoria.

Where does climbing fit into this?

This type of regulatory burden is affecting the Licensed Tour Operators as they are being told to apply for a Cultural Heritage Permit if they want to work at Summerday Valley this coming financial year. But that is only the window dressing on this whole affair. The real worry is what happens on the ground in the National Parks themselves.

Perhaps the real reason that PV failed to notice climber’s impacts in the Grampians for the last decade was because they were tied up in this bureaucratic and expensive nonsense? We have a quote from them for that!

“Parks Victoria is responsible for managing 87 percent of the recorded rockart in Victoria, which includes over 140 sites. The time and cost taken to complete inspection forms and prepare Cultural Heritage Permits means Parks Victoria are only able to complete protection works at an average of 6 rockart sites per year.”

Parks Victoria was only completing protection work at 4% of the art sites they were supposed to be managing per year. At that rate it would have taken them 23 years to get around to all of them. And those six sites were presumably mostly the caged tourist sites – there are five of them listed in this tourism website. And of course this pathetic maintenance and inspection regime didn’t include stone tool quarries like at The Gallery, Bundaleer and Summerday – areas all now closed to recreational climbing. It is really quite sad reading this document. Evidence presented by Parks Victoria themselves seems to suggest that their own lack of awareness of climbing activities in cultural heritage areas was brought about by Aboriginal Victoria’s expensive regulations. Oh the irony. But this is all old news really – dating back to late 2017. Perhaps it’s all changed for the better with the 2018 regulations? It doesn’t appear so.

What changed in 2018?

It appears the 2018 Regulations remained similar to the 2007 version but dealt further blows to PV’s day to day management budget through expanded definitions and fee increases.

They did get one win with the mandatory CHMP requirement for walking tracks being extended from minimum 100m to 500m in length. A small win is still a win right? Unfortunately for them Aboriginal Victoria added “fuel breaks” (fire breaks) onto the mandatory CHMP list. Back to square one for PV. At least climbers and PV can wallow in the shared knowledge they are both being screwed by this system.

Permit or Plan?

It is worth knowing the difference between a Cultural Heritage Management Plan (CHMP) and Cultural Heritage Permit (CHP). We will be the first to admit it still confuses us.

A Cultural Heritage Management Plan (CHMP) is a written report prepared by a Heritage Advisor. It includes results of an assessment of the potential impact of a proposed activity on Aboriginal cultural heritage. It outlines measures to be taken before, during and after an activity in order to manage and protect Aboriginal cultural heritage in the activity area. A CHMP is required when a “high impact activity” is planned in an area of ‘cultural heritage sensitivity’. These terms are defined in the Aboriginal Heritage Regulations 2018. In these circumstances, planning permits, licenses and work authorities can’t be issued unless a CHMP has been approved for the activity. In general these are the big expensive ones costing in excess of $10k and involve a lot of paperwork. As an example, an expensive CHMP has enabled PV to construct the new 160km Peaks Trail walking track that splits the entire Grampians – despite being an area of “cultural heritage sensitivity” . You can read more about that at our article Peaks Trail – Destruction by the Book.

A Cultural Heritage Permit (CHP) is usually a smaller and single use permit for a specific task involving cultural heritage. By law you need to apply for this permit if you are planning to disturb or excavate land to uncover or discover Aboriginal cultural heritage, rehabilitate land at an Aboriginal place, inter Aboriginal ancestral remains at an Aboriginal place, carry out research on an Aboriginal place, carry out an activity that will, or is likely to, harm Aboriginal cultural heritage, sell an Aboriginal object (where it was not made for the purpose of sale) or remove an Aboriginal cultural heritage object from Victoria. The fees for this are pre-defined and usually in the hundreds of dollars. The permit itself is a generic document. A CHP is what PV is asking individual Licensed Tour Operators to obtain so they can work in Summerday Valley. In our humble opinion the requirement for the guides to get this permit seems a misuse of the regulations. You can find plenty more info at Aboriginal Victoria’s website. We like PV’s own words about permits:

“These are required for much of the work Parks Victoria conducts and hold up the management and protection of Aboriginal cultural heritage.”

Today’s climbing reality under this system

There has been a lot of optimistic chat among climbing access groups in the last year about solving the bans by doing a fine-grained approach to managing climbing in the Grampians. The idea is that each crag could have a group of local climbers who act as stewards for the area and they should be proactively doing crag maintenance to stop problems flaring up. The hope was PV would get on board to help with this – supply track building materials and expert advice on chalk removal for example. The reality is this idea is entirely doomed because of exactly what this submission document from PV outlines. Every time there is a chance of ground disturbance in a National Park it appears to trigger one of these plans or permits from Aboriginal Victoria because it is considered a) a high impact activity and b) all National Parks are areas of “cultural sensitivity”. Small jobs done with free labor is incompatible with this entire system.

Climbing access groups are not technically allowed to build a retaining wall to stop erosion, replace old bolts or even install a simple sign without applying and paying for one of these permits. We hazard a guess these regulations were not followed when PV and climbers built the wooden walkways at Bundaleer and track up to The Gallery. Basic crag maintenance by volunteer labour from either PV or climbers is impossible using this system. PV explains the problem they face:

“Many activities conducted by Parks Victoria as part of usual operations are defined as high impact activities. Often these activities and projects are conducted in-house by staff using existing or cheap materials, resulting is an improved visitor experience or rectification of safety issues. As such, the activity and resources require little cost, yet may require a CHMP with associated costs that outstrip the cost of the project significantly. As such, the activity or project is often cancelled as there are inadequate funds for cultural heritage management expenses.”

Park rangers are unable to do basic maintenance work that would cost the government literally nothing but the ranger’s wages. PV’s example given in the submission shows what climbers are up against:

“According to Regulation 43 (1)(xv) and under the planning provisions, establishing a barbeque area where the only ground disturbing works would be the use of machinery for post-holes for a picnic table, a CHMP would be triggered. Harm to cultural heritage would be highly unlikely in many areas, and the cost of preparing a CHMP would be prohibitive.”

Just how ridiculous is this? We have been told by a reasonably reliable source that PV was not legally allowed to hammer in a sign post at Summerday Valley to erect their “climbers piss off” sign at the entrance without one of these permits. So what did they end up doing? Erecting a floating tripod and chaining it to a tree. Classic.

We suspect any attempt by climbers to publicly self manage our climbing areas will be stone walled by PV due to expensive permits that no-one can afford. The days of knocking together a walkway and tripod at Bundaleer, or building a few steps to stop erosion up to Taipan are well in the past. Unfortunately it looks like all that stewardship programs will be able to do is educate climbers and register and report crag conditions. This has already been told to climbers by PV at a local Melbourne crag in dire need of maintenance.

PV is so skint that the signs they put up in the Vic Ranges 18 months ago are faded, water damaged and in once instance, blown down from wind. That is the full extent of the PV’s efforts to look after the cultural heritage in that area since 2018. Click here to read a great letter from the ACAV about the lack of appropriate signage at Grampians climbing areas. PV have not been following their own regulations so it shouldn’t be a surprise if climbers also fail to do so.

Final words from PV

As a final wrap-up we will let Parks Victoria tell it like it is from their submission document:

“it is unclear that the current system set out in the Regulations equates to the effective expenditure of Victorian State Government funds allocated to Parks Victoria. Further, in many CHP or CHMP cases, the real benefits for Traditional Owners and the protection of Aboriginal cultural heritage values within parks which PV has an obligation to maintain and conserve remains unclear.”

Please share this article and don’ t forget to check out the other 50+ articles on this blog for further background reading including an update at the bottom of last weeks scandalous Sandinista article which now includes the original permit documents.

Key dates to look out for in the future:

• Late May – PV’s CEO Matthew Jackson said the next (and final) Roundtable Meeting would be held in “late May” – but no specific date has been announced. Don’t hold your breath on this one. Covid might be a convenient excuse for them to cancel this.

• June – The draft version of the Greater Gariwerd (Grampians) Landscape Management Plan is handed over to the Victorian Minister – and then presumably presented to the public for feedback. Get those protest letter writing pencils sharpened. This will be big.

* Is this submission document real? Looking at the embedded metadata in the PDF it was created on the 24 Oct 2017 with the author tagged as “Wendy Luke”. The date lines up with the Submission Deadline of 10 September 2017 mentioned in AV’s own review material we also found online. The document was downloaded from Aboriginal Victoria’s website in June 2019 but is now unavailable – possibly due to the entire AV website being relaunched recently. The authors name, Wendy Luke, appears in several other PV related documents we found online. This document is legit.