TAMS Community Engagement
GPO Box 158,  Canberra, ACT 2601

Subject: Canberra Bushwalking Club Comments on Draft ACT Trails Strategy, 2014-2024

Dear Madam or Sir

Thank you for the opportunity to comment on the draft ACT Trails Strategy 2014-2024. The Canberra Bushwalking Club (CBC) considers the development of the strategy a welcome and important initiative by the ACT Government, as the Territory’s trail network is a recreational resource that is highly valued both by our club members and other members of the community. We would be grateful if you could add us to your mailing list for any future community consultations on this subject.

We fully support the ACT Government’s view that there is a need for a consistent policy framework to improve the management and use of recreational trails on public land, especially in light of population growth projections. As frequent users of these trails, CBC members have seen the negative impacts that developmental and other land use pressures – along with inappropriate, unregulated or competing uses – can have on them. For example, certain areas of Mt Ainslie are now covered with an unattractive network of informal tracks that may contribute to erosion; closure of some of these for revegetation would provide a more appropriate balance between public use and the natural values of this much-loved area.

Overall, the CBC feels the strategy has been thoughtfully developed and covers many key issues in trail planning and management. Regarding specific elements of the draft strategy, we would offer the following comments:

[Please note that the version of the draft strategy which we downloaded from the TAMS website contains a different section numbering system in the table of contents to that used in the main body, though the page numbers remain the same. We will use the numbering system in the main body as a reference to our comments, with the alternative from the table of contents in brackets]

Section 1.11 (3.7) Events and Tourism, pp 18-20: The further development of the trail based tourism industry in the ACT, leading to increased revenue for conservation management, is a worthwhile objective. We wish to stress the importance of preparing implementation plans for any such developments, as an element of cohesive tourism promotion strategies, in close consultation with community stakeholders. This includes sufficient consideration of the different needs of different users, such as cyclists vis-a-vis walkers/bushwalkers.

Section 1.16 (4.3) Recreational walking and running, p 23: We concur that the proportion of people in the ACT who take up bushwalking (unpaved experiences in a non-urban setting) is likely to increase from current figures, with an expanded network of well-maintained trails. We base this assessment on the CBC’s experience of enquiries from members of the public, as well as the expressed interests of new members joining the club. We would note that another organisation which promotes bushwalking in the ACT appears to be missing from paragraph 4, the Brindabella Bushwalking Club (BBC).

Section 1.23 (4.10) Conservation and environment stakeholders, p 27: The draft strategy commendably recognises the importance of balancing the delivery of conservation objectives with the demand for recreational opportunities in this section. The CBC feels that this message could be made more visible and prominent in the strategy by including reference to it at the beginning of the ‘Stakeholders’ part of the report, rather than as a point mentioned under one stakeholder group.

Section 1.24 (5.1) Inventory of Trails, pp 28-29: The CBC fully endorses the intent of the strategy to seek community input into strengthening the trails inventory. We have access to useful references in this regard, for instance, a database created by one of our members called Johnny Boy’s Walkabout Blog (http://www.johnevans.id.au/). The Blog contains detailed maps of bushwalking routes, including routes to sites of historic and cultural interest around the ACT (e.g. remains of homesteads/buildings, ACT-NSW border markers, etc). Photos also are provided. This website is visited by both Australian and international audiences.

The inventory not only can be used to facilitate trail management, but also as a useful reference for those seeking to identify new or different places to undertake their recreational activities. It would be helpful for the Strategy to include some information about the approach that will be taken to obtaining community input.

Section 1.26 (5.3) Trail sharing, pp 30-31: This is a very important part of the strategy, as balancing the needs and interests of different stakeholder groups – along with environmental considerations – can become an area of contention. The CBC’s view is that some of the messages in this section could be stated more directly (ie use more ‘plain English’). The implications of issues, such as land tenure and the application of the Plans of Management, to decisions regarding multiple trail use do not come across clearly in the text; this perhaps could be resolved through the identification of linkages to later sections which address these subjects. However, the key messages re multiple trail use should come through in this section. As an example, this part of the document should specify that the strategy is not going to open the door for expansion of trail use in parks and reserves from the current focus on low-key and non-motorised activities, where there are ecological or cultural values at stake.

Section 1.28 (5.5) Reporting of issues, pp 32-33: The increased availability of open source mapping offers tremendous potential for cost-effective, community-based monitoring of trail damage or maintenance needs – as identified in Section 1.12 (3.8). In line with the actions outlined in section1.28, the CBC supports the recommendation of the Brindabella Bushwalking Club (BBC) that a ‘Fix My Trail’ website be created, modeled on the ACT Government’s ‘Fix My Street’ website, so that individuals and organisations can report track damage, fallen timber, illegal trail uses, etc. Such a website also would support the work to further develop an inventory of trails (section 1.24).

Bushwalking clubs regularly make use of Google Earth/Maps, in combination with GPS/Smartphone technology, to identify key navigation features and points of interest. There is good potential to support the trial and development of online mapping systems to complement the use of phone and online form-based reporting facilities. This is an area where effective collaboration between bushwalking clubs and the ACT Government could potentially generate some very useful inputs into the successful implementation of the Trails Strategy. As an example, bushwalking clubs would be well placed to advise on the formats for geographic co-ordinates used to report an incident or issue, and on how these could be linked to online maps.

Section 1.28 notes the need to develop formalized reporting mechanisms regarding conflicts or illegalities in the use of trails, in order to prioritize management intervention.  The CBC would suggest that the Strategy should describe the grievance redress process by which serious conflicts will be resolved or, at least, make a commitment to the formal development of a grievance redress process during the early stages of Strategy implementation (to be included under the ‘Actions to achieve’ section). This is important for ensuring the transparency and accountability of these decisions, as well as effectively communicating the basis of PCS prioritization and decision-making.

Section 1.29 (5.6) Provision of Maintenance, pp 33-34: The strategy appropriately identifies the key roles to be played by the ACT Parks and Conservation Service in trail maintenance and the resource limitations/prioritization inherent in this process. We think that the Trails Strategy should further recognise the current and potential role played by community organisations, including bushwalking clubs, in the provision of voluntary support to trail maintenance. It is suggested that the strategy include a commitment to coordinated consultation with community organisations to identify the areas of trail maintenance for which voluntary assistance may be sought.

1.30 (5.7) Proliferation of the trail network, p 34: This section deals with some of the practicalities (i.e. resourcing) of trail development and maintenance. The CBC would suggest that a paragraph needs to be added to cover the subject of the potential proliferation of trails in declared wilderness areas. As a principle, we feel that new trails should not be developed in these areas and that the authorities should be supported to remove cairns and other markers on unofficial and unapproved trails in wilderness areas. The caveat would be the provision of signage to notify possible users of the illegality and/or risks of use of unapproved trails (comment also relates to section 1.34 and 1.38).

1.31 (5.8) Trail closure and 1.32 (5.9) Access to trails, p 35-37:  The CBC notes the comment that recreational stakeholders have suggested that further environmental investigation be undertaken to assess whether some trails in the Namadgi NP, Cotter area and Brindabella Ranges could be re-opened. While supporting the view that environmental considerations should be a key factor in any decision to re-open a trail, the CBC notes that such investigations are resource-intensive. The PCS’s resources are already under strain, and the benefits of further investigations in areas where a management plan has already been prepared may not justify the costs. Maintenance of existing trails is in our view a higher priority than re-opening of closed trails.

We also would suggest that the Strategy should include public notification of any future trail closures and the rationale behind the closures, through appropriate forms of media (eg ACT Government websites).

1.34 (5.11) Need for a trail identification and classification system, pp 37-38: The initiative to create a trail identification and classification system is excellent, with many potential benefits as outlined in the strategy. We concur with the analysis and would stress that the system will only work effectively if there is sufficient budget and focus on ensuring the presence of clear signage at major trail entry points and maintenance of this signage. These visual signs reinforce the information that trail users may pick up through online and Smartphone systems, and allow for those who may not use this technology or be able to access it in wilderness areas. We also would observe that sometimes the junctions on trails are not adequately marked (ie markers/signage not placed where directional choices need to be made). This needs to be considered in trail signage as a safety issue.

1.39 (5.16) Unexplored tourism potential, p 42: It is not clear from the document whether a strategy or plan for the promotion of commercial tourism on trails is under consideration by the ACT Government. If it is, it would be useful to clarify this point and to identify the need for community consultation on the strategy/plan.

1.40 (5.17) Management structure and funding, pp 42-43: It would be useful to have a rough breakdown of the budget required to implement the Trails Strategy, including an estimate of human resource requirements. Any gaps in resource availability also should be identified in order to give a realistic picture of implementation needs and processes for meeting them.

1.44 (6.3), Key values, p 44: The Strategy mentions ‘strong leadership from industry and government’ as a key value.  The CBC feels that it is the role of government to provide leadership, rather than industry. We see industry and the community as key stakeholders, which should be mentioned in a separate dot point.  The dot point should give reference to the key roles that industry and the community can play in supporting the implementation of the strategy and the importance of regular and robust consultation with them. It also useful to provide more detail on the envisaged role of industry in strategy implementation, as they are not specifically described as a stakeholder group in the earlier part of the document regarding stakeholder groups.

1.46 (6.5) Delivery of the vision, pp 45-49: The CBC considers the use of criteria to assess the relative importance of existing and proposed trails as a transparent and accountable method of ensuring the quality of the trails network. However, we think the criteria could be further developed and strengthened by:

  • Including definitions for some criteria (e.g. what constitutes an impact on areas of significant natural or cultural heritage? What constitutes effective and efficient maintenance?)
  • Better balancing the weightings between emergency services and other uses and/or making provision for negotiation of multiple uses.

For example, we used the development of a fire trail and/or walking track at Stockyard Spur above the Corin Dam as a test of the proposed criteria. This development has already occurred, and was an example of a successfully balanced process. Emergency services originally proposed the construction of a wide, zigzagged vehicular track up this narrow spur, which would have greatly diminished the natural beauty of the area. After consultation and negotiation with other user groups, it was agreed to instead construct a considerably upgraded walking trail to connect to an existing fire trail (which also was upgraded). If this process had been conducted solely according to the Strategy’s proposed criteria, the fire trail would easily have won out. While the importance of emergency access to sensitive water catchment areas is not disputed, the use of the criteria does not make allowance for the kind of compromises that may be beneficial to consider.

The introduction of an assessment process that allows for this sort of balanced consideration, and based on sound risk management principles, would make the system more flexible and responsive to different trail needs and uses in our view.

Goals and Actions, No. 34, p 57: There is a need for clarification of the parameters to be identified for the establishment of a ‘marketable identity’ for the trails network, as some trails may not be well suited to the increased use that would presumably follow a marketing program (i.e. will the strategy be focused on popular, low-impact trails?).

Goals and Actions, No 47, p 59: We recommend strengthening the action points regarding blocking off informal, inappropriate tracks and protecting sensitive areas from environmental degradation (in line with our points re section 1.26).

Once again, please accept the sincere appreciation of the CBC for the opportunity to contribute our views on the draft ACT Trails Strategy 2014-2024. If you have any queries in relation to our submission, please do not hesitate to contact me on 6281 4917 or president@canberrabushwalkingclub.org.

Linda Groom, President, CBC
9 January 2014

cc CBRE, GPO Box 1987, Canberra, ACT 2601