It took 12 months for the query to be addressed but a result was eventually achieved in September 2021. The Auditor General found major problems with the manner in which Parks Victoria procured Archaeological reports pertaining to perceived rock climbing damage in Grampians/Gariwerd and at Arapiles/Dyurrite. Their procurement findings are summarized in Section 5 of this VAGO report (follow link and scroll down).
Hopefully it doesn’t take as long this time to hold our park managers to account. They are compelled to demonstrate an evidence-based scientific approach and they have failed to do this.
We contend that the climbing restrictions noted within the Greater Gariwerd Landscape Management Plan are based upon false information and we again assert a management approach based upon the Victorian Climbing Management Guidelines.
ACAV remains available for consultation on this matter.
The Plan was published in November 2021 and it is likely to remain active for 15 years.
Ethan Pringle on The Groove Train (33) on Taipan Wall in the Grampians (photo : Simon Carter)
Sadly, Parks Victoria has failed to genuinely consult over the new climbing rules. Parks Victoria has recently informed us that “Consultation continues, with Parks Victoria regularly meeting with the newly established Climbing Victoria Advisory Council.”This organisation does not exist.
Several practical and legal failings affect the proposed rules:
Many of the “open” cliffs cannot be accessed via the proposed “designated tracks” under the proposals to limit off-track walking.
The “closed” cliffs are not identified anywhere in the plan.
The mapping provided by Parks Victoria is inadequate. Climbers remain unaware of key location details.
Widespread closure signage is impractical, yet it is required by law, to clearly identify the hundreds of “closed” locations.
If Parks Victoria went ahead and issued climbing permits, they would become legally responsible for bolt integrity and bouldering pad safety. In the event of a serious accident, any disclaimers would be deemed invalid in court.
The provision of only 13 bouldering locations will lead to overcrowding.
Coloured chalk is impractical – see title photo.
Discriminating against and excluding one user group (climbers), runs contrary to Parks Victoria’s responsibilities under the National Parks Act.
Parks Victoria must demonstrate “evidence-based park management” under their Statement of Obligations. Their Archaeological reporting does not meet this standard (referred to the Auditor General).
Parks Victoria cannot issue a legal infringement notice for climbing or walking in the wrong places and hence cannot police the new climbing rules.
Climbers and boulderers seeking clarification will be disappointed and they face a choice to either selectively break rules or continue to stay away from the Grampians.
Recent correspondence from Parks Victoria has been dismissive i.e. read the Plan.
ACAV remains available for consultation and will continue to support its members.
In this election year, you are encouraged to email your local member of parliament to make your feelings known on this issue. Lily D’Ambrosio is the Victorian Minister responsible for this portfolio email@example.com
The GGLDMP is a critically important document as it will direct management of the Grampians for possibly the next 15 years and it may also used as a template for management of rock climbing in other areas. Climbing in the Grampians/Gariwerd is going to be absolutely decimated if this plan is implemented in it’s present form.
The ACAV has prepared a 22-page Submission to Parks Victoria in response to the draft plan. We have major concerns over these proposals and we have made a number of recommendations. Our response has been prepared in-line with international precedent and best practice for climbing and bouldering management around the world.
We have formatted our recommendations into a Word document, linked below, which you may wish to use as a template for your own submission to Parks Victoria. Simply download the Word document, fill out your details, edit accordingly, add your own recommendations if you wish, and most importantly email it to Parks Victoria by Sunday, 24 January. Email address: firstname.lastname@example.org
This document has been issued to interested parties at all levels. It is intended to inform and advise with a view to establishing excellent climbing management practices for the benefit of everyone.
We are indebted to Matt Brooks, who took on the lead role of pulling all this information together, managing the consultation process and closing out this major piece of work to produce a high quality document and a forward plan for rock climbing and bouldering in Victoria, Australia.
Blanket bans on rock climbing in Gariwerd/Grampians National Park and Tooan/Arapiles State Park have been introduced by Parks Victoria under the advice of one consultant archaeologist. When a site has been assessed by this archaeologist, the Aboriginal Heritage Act comes into play and the barriers go up. This has brought about climbing exclusions on a scale never before seen in the climbing world. To date, all sites that have been closed remain closed. No reviews, no questions, non negotiable.
Climbing groups have taken issue with many of the archaeological findings and allegations. Refer to previous news stories on this site for details. In May 2020, ACAV made a formal complaint to the Australian Association of Consulting Archaeologists. No substantive response has been received.
The procurement process for archaeological advice is highly questionable. Documents obtained under the Freedom of Information Act show that Parks Victoria claims that only this particular archaeologist can do the work; allegedly the “sole supplier in the market” and “the only qualified person to complete this task in the state”. In fact there are multiple highly qualified consultant archaeologists willing and able to carry out work of this nature. The “sole supplier” reasoning may have been inappropriately used by Parks Victoria to avoid following a competitive tendering process. It makes the paperwork easier and Parks Victoria is clearly happy with the outcomes. No peer reviews have been carried out.
An audit application has now been submitted to the Victorian Auditor General – Audit application.
Supporting paperwork includes procurement documents recently obtained from Parks Victoria under the Freedom of Information Act – FOI applications and responses.
Further revelations within these FOI documents will be of interest to climbers piecing together how bans on this scale have been able to occur in Western Victoria but nowhere else in the world.
While the procurement paper trails have been released with heavy redaction, Parks Victoria has flatly refused to release any information surrounding archaeological reports, findings and recommendations. The two FOI requests seeking reports have been rejected or have stalled. The Aboriginal Heritage Act gives some justification for this, since a degree of discretion is required over site locations. That’s why we need the Government auditor to step in to cut through the veil of secrecy. If everything is above board then Parks Victoria has nothing to worry about. If malpractice has occurred there will be serious consequences and remedial action will follow. The forthcoming Grampians Landscape Management Plan has been drafted under the assumption that the archaeological advice is sound.
We have redacted point 5 from the audit application form as this relates to a connected matter raised by ACAV and currently under Ministerial review. It takes a very hot issue for ACAV to consider keeping access news under wraps. Watch this space for updates.
This is a sensitive area. Many climbers are reluctant to challenge the behaviour of Parks Victoria for fear of giving offence to Aboriginal representatives. This quandary has so far led to a wipe-out of rock climbing in the state with all hopes being pinned on a climbers’ reconciliation group.
Let’s see what the auditors find.
ACAV work of this nature has lost support. We will be holding a Zoom AGM in October. Along with several committee members, I will be stepping down. Any member may nominate for a role. If you are interested, please get in touch: Contact page
This ACAV update covers Victorian climbing access issues in the lead up to the proposed release of the draft Grampians Landscape Management Plan 2020 by Parks Victoria, due for review by the Environment Minister in June 2020.
The 2003 management plan defined the Special Protection Areas (SPAs) that were later invoked in 2019 to ban climbing and bouldering from 100 locations across the Grampians. The draft GLMP 2020 will be issued for public consultation once the Minster has reviewed it. We may see the draft plan in July or August.
Recent climbing access events and stories in Victoria – please follow the links for more detail.
Victorian Climbing Club ongoing delays over the 2019 SPA legal challenge. Refer to VCC for details.
This ACAV letter requested that the VCC return the $30,000 legal contribution made by ACAV in February.
Arapiles known art site surveys in progress by Ben Gunn. Whole-of-park surveys proposed to look for more artifacts. ACAV concerns prompt national media story.
It is possible that the Grampians Landscape Management Plan 2020 will map out a fair and reasonable place for rock climbing in 2021. However, considering the ongoing lack of meaningful consultation with rock climbers and the actions of Parks Victoria thus far, we are not optimistic. You are invited to draw your own conclusions.
We would like to hear from any members with legal, financial or IT experience to assist with the running of ACAV at this critical juncture for climbing in Victoria. Please email email@example.com if you can help in any way.
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.
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.
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?
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.”