The Australian Climbing Association Victoria has made a formal complaint to the Australian Association of Consulting Archaeologists regarding the conduct of a registered Archaeologist, Robert (Ben) Gunn in relation to the nature of his published work, reporting on alleged rock climbing impacts in the Gariwerd/Grampians region.
The outcomes we seek are: 1. To retract the accusation that climbers were responsible for Lil Lil graffiti as there has been no evidence provided to support his claims; 2. To amend the title “Rock Art and Rock Climbing an Escalating Conflict” in the Rock Art Research Journal, volume 37. It is extremely unprofessional to start with a title of this nature in an academic publication; 3. For Mr Gunn to acknowledge his indiscretions, clarify these matters publicly and apologise for his conflict-inducing behaviour; 4. For Mr Gunn to be removed from all future climbing-related archaeological contracts; and 5. A review of Mr Gunn’s registration with AACAI as a consultant to be conducted.
Parks Victoria has been quietly getting on with business during lockdown, entering into consultation over Declaration Crag / Taylors Rock at Arapiles with 3 community groups:
Arapiles District Community Group
Mount Arapiles Advisory Group
Gariwerd Wimmera Reconciliation Network.
No climbing groups were consulted. This is concerning. Alternative viewpoints from a climbing perspective are unwelcome it seems. ACAV has 1600 members and we are dedicated to climbing access with a strong legal focus. This is the first we have heard of the recent consultation meetings.
Why are we concerned about the proposed Interim Protection Declaration at Dec Crag?
“An interim protection declaration, or an ongoing protection declaration, that relates to an Aboriginal place or object has effect despite anything to the contrary in any of the following— (a) any other Act or law; (b) an approved cultural heritage management plan; (c) a cultural heritage agreement; (d) any other agreement.”
After 3 months as an interim order, the ruling is likely to be upgraded to an ongoing protection declaration. This powerful legislation is akin to locking it up and throwing away the key, no further questions. Maybe that’s appropriate at Taylor’s Rock, maybe not. Nevertheless a precedent is being set and many other sites at Arapiles are now being surveyed. Similar protections are highly likely if this goes through unchecked. We will follow this up accordingly.
We received this email from Parks Vic, explaining the recent events:
EMAIL FROM PARKS VICTORIA, 21 MAY 2020
This email provides an update on cultural heritage rediscoveries, assessments and protections at Mount Arapiles-Tooan State Park.
With public health measures in place to slow the spread of coronavirus (COVID-19), Parks Victoria has been adapting the way it works to keep progressing important conversations with our communities.
Taylors Rock Interim Protection Declaration – Aboriginal Victoria consultation
The feedback period on a proposed Interim Protection Declaration at Taylors Rock (Declaration Crag) closed on 22 April.
The consultation occurred in March to consider whether to approve the additional legally-enforceable protection for this Aboriginal cultural heritage place where rock art and other cultural heritage values were recently rediscovered.
In addition to recent finds at Taylors Rock, there are a number of rock art sites that have previously been identified in Mount Arapiles-Tooan State Park.
These sites are on the Victorian Aboriginal Heritage Register, which is a central repository for Traditional Owners to store information about cultural heritage.
Beginning this month, Parks Victoria and Barengi Gadjin Land Council will assess these registered rock art sites, checking their condition and, where required, undertake further site protection.
Ongoing community consultation by Parks Victoria
While it has not been possible to hold a follow-up community information session in Natimuk due to current circumstances, members of our regional team have met online with three local representative groups.
In the past month, we’ve held separate meetings with the Arapiles District Community Group, Mount Arapiles Advisory Group, and the Gariwerd Wimmera Reconciliation Network.
Conversations were positive and focused on the aspirations of each group and the relationship moving forward with Parks Victoria. General discussions were also held on the current and future cultural heritage protection at Mount Arapiles Tooan State Park, opportunities for local groups to build relationships with Traditional Owners and the proposed Interim Protection Declaration for Dyurrite 1 (which is being led by Aboriginal Victoria).
As circumstances allow, we remain committed to holding future information sessions with the broader community to discuss the cultural, environmental and recreational values of Mount Arapiles-Tooan State Park, and how they are managed, recognised and enjoyed.
In the meantime, here’s a summary of feedback received at the community information session held in Natimuk earlier this year.
Finally, a recurring theme from community conversations has been the creation of a ‘roadmap’ that outlines the process and timelines for cultural heritage assessments and park management developments. We are working with Barengi Gadjin Land Council to finalise this and look forward to sharing it soon.
We understand that Parks Victoria will soon commence extensive archaeological survey work at Mount Arapiles. We require evidence that proper process is being followed to be assured that this work will be carried out to the highest standards of propriety.
ACAV has coordinated the submission of four Freedom of Information requests to Parks Victoria on 12th May 2020. These applications will be rigorously followed up by the applicants to seek the information within the required 30 day timeline.
Who carries out the archaeological surveys and how are these contracts granted by Parks Victoria?
Is Parks Victoria following its mandatory procurement and tender process in spending public money to appoint archaeological consultants and advisors?
Who has been receiving all this contract work and how much has been spent? ($1.2 million was committed in mid 2019)
What archaeological advice has been submitted to Parks Victoria in relation to rock climbing impacts?
Did Parks Victoria follow the advice of this discredited Grampians report?
If not this report, then what archaeological advice did Parks Victoria follow when instigating the Grampians climbing bans in 2019?
Which consultants and advisors have already been appointed for the archaeological surveys at registered sites within The Mount Arapiles/Tooan State Park?
Which consultants and advisors will be appointed to carry out the archaeological surveys for the proposed whole-of-park assessments at Arapiles?
The Freedom of Information application forms can be viewed here. The document requests are as follows:
FOI #1Please provide all documentation, from 1 January 2018 to present, relating to the procurement of archaeological and/or cultural heritage surveys of sites where rock climbing is known to occur in the Greater Gariwerd Area (Grampians National Park, Black Range State Park, Red Rock Reserve and associated areas) for potential damage to archaeological and/or cultural heritage values. Please include as a minimum any market engagement plan, request for quotation / specification, supplier selection or engagement briefs, approvals for deviation and/or exemption from standard process, bid evaluation reports / briefs and conflict of interest declarations. As the purpose of our request is of public interest and benefit, we expect that additional fees will be waived in accordance to Clause 22(1)(h)(i) of the Freedom of Information Act 1982.
FOI #2Please provide all documentation, reports, plans, correspondence and meeting notes, from 1 January 2018 to present, relating to archaeological surveys of sites where rock climbing is known to occur in the Greater Gariwerd Area (Grampians National Park, Black Range State Park, Red Rock Reserve and associated areas). As part of this request, please include any and all reports from, and all correspondence with consultant archaeologists and all cultural heritage advisors. As the purpose of our request is of public interest and benefit, we expect that additional fees will be waived in accordance to Clause 22(1)(h)(i) of the Freedom of Information Act 1982.
FOI #3Please provide all documentation, from 1 January 2018 to present, relating to the procurement of archaeological and/or cultural heritage advice regarding the surveying for potential damage to archaeological and/or cultural heritage values in Mount Arapiles State Park. Please include as a minimum any market engagement plan, request for quotation / specification, supplier selection or engagement briefs, approvals for deviation and/or exemption from standard process, bid evaluation reports / briefs and conflict of interest declarations. As the purpose of our request is of public interest and benefit, we expect that additional fees will be waived in accordance to Clause 22(1)(h)(i) of the Freedom of Information Act 1982.
FOI #4Please provide all documentation, reports, plans, correspondence and meeting notes, from 1 January 2018 to present, relating to archaeological surveys in Mount Arapiles State Park, As part of this request, please include any and all reports from, and all correspondence with consultant archaeologists and all cultural heritage advisors. As the purpose of our request is of public interest and benefit, we expect that additional fees will be waived in accordance to Clause 22(1)(h)(i) of the Freedom of Information Act 1982.
A year ago, Parks Victoria listed Bundaleer as one of five Grampians locations where climbing was acceptable and “not in a protected area”.This week we have received a set of attachments from the March round table meeting showing contradictory information. Now we are informed that Bundaleer has been defined as a Special Protection Area since 2003 via a red dot on a map and climbing will need to be banned across a major portion of the cliff line.
We have been informed that:
“Pending the new plan being finalised, Parks Victoria may need to put in place some additional protection measures in the coming months. Parks Victoria expects that the area from 30m to the north of “Manic Depressive” (and northwards of this point) are unlikely to be affected by additional cultural heritage protection measures. Climbing routes south of this point are likely to be affected by additional cultural heritage protection measures.”
What is going on at Parks Victoria?
Bundaleer, one of the climbing jewels of The Grampians/Gariwerd Blimp (grade 20) a climb of national significance and historic importanceA year ago, Bundaleer was an “approved” climbing location. Now we are advised that it is not.
Licensed Tour Operators (LTOs) running climbing and abseiling activities in Gariwerd at Summerday Valley and at Lookout Point Wall have been offered new license conditions by Parks Victoria for the financial year starting July 1st 2020:
Each LTO must apply for a cultural heritage permit (previously held by Parks Victoria)
LTOs become legally responsible for any ‘harm’ – fines of up to $1.65 million
The definitions of harm present significant real-world risks for the LTOs
If LTOs sign up to this by 19th May, Parks Victoria will cover the cost of permit applications (otherwise $600 per LTO)
The new Grampians Landscape Management Plan, due in December, may override these permit conditions during the permit period
Only 7 of the 29 LTOs attended the dial-in briefing
This is a test case, anticipated to be rolled out for all activities, across Victoria
This new scheme presents a new level of risk for Licensed Tour Operators and their insurers. Noalternatives have been offered.
Links to documents issued by Parks Victoria to LTOs on 6th May 2020:
Australian Climbing Association (Vic) Inc. 