This is hopefully my final submission. The earlier drafts should not be used, please. Those who have posted here or contacted me by PM have added greatly to the following. Many thanks.
I should have guessed that more information would come to light. Point 13 is new, added 7.12.15 6.30 am. Sorry about the constant changes but people keep giving me information.
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Falls to Hotham Alpine Crossing – second submissionIntroduction1 On 20 November 2015 I made a submission regarding the proposed Falls Creek to Mt Hotham walk. Since then further and better particulars have become available. The following discusses that information.
Greater Alpine National Parks Draft Management Plan2 The June 2014 Greater Alpine National Parks Draft Management Plan (ANP draft plan) appears to be the latest form of a management plan for the region. Hence, ANP draft plan shows the direction of Parks Victoria regarding the regions in the ANP draft plan, which includes between Falls Creek and Mt Hotham.
3 Starting on page iii, the Executive summary of the ANP draft plan says:
"The plan focuses on the outstanding natural, cultural and recreational values within the parks”
“The parks will be managed consistent with the National Parks Act 1975, to protect the natural environment, flora, fauna and features of scenic ... interest”
“People's heritage and connections to the land will be recognised and respected in the management of the parks”
“The key strategies are to ensure the public can enjoy a wide range of recreational and tourism experiences across the parks by ... pursuing key tourism initiatives including ... a serviced walking experience between Falls Creek (and) Mt Hotham”
“Improvements to visitor access will include ... development of a supported walk to be known as the Falls Creek to Mt Hotham Alpine Crossing".
4 Page 17 deals with zoning. A Conservation zone is defined as "Areas of high natural value where the emphasis is on protection of the environment." A Conservation and Recreation zone is defined as "Areas where the management emphasis is on protection of environmental and cultural values while allowing for recreation."
5 Page 62 has a goal: "A diverse range of opportunities for visitors to experience parks is maintained." (sic) Strategies include "Minimise the impact of visitors on environmental values ... develop a new hut‑based walk experience between Falls Creek and Mt Hotham (wild walk)".
6 Page 75 has a goal of "Sustainable nature‑based tourism" and a strategy to "Investigate the feasibility accommodation options for the Falls to Hotham Alpine Crossing (wild walk), including Red Robin Mine and demountable standing camps ... Feasibility study completed 2017".
7 There's a map showing zones at
http://parkweb.vic.gov.au/__data/assets ... e-2014.pdf8 The above gives a good basis for discussion.
Conflicts between the ANP draft plan and the proposed Falls-Hotham walk9 Mt Feathertop and the Razorback are in a Conservation zone - "Areas of high natural value where the emphasis is on protection of the environment." The Preliminary concept plan for the proposed Falls-Hotham walk (“the walk Plan”) implies that there will be a new demountable standing camp or hut near Feathertop or approaches. This is contrary to Conservation zone values.
10 The ANP draft plan says: "The plan focuses on the outstanding natural, cultural and recreational values within the parks”. The proposed Falls-Hotham walk will compromise these values by having infrastructure and numbers that are not in keeping with a Conservation zone.
11 “People's heritage and connections to the land will be recognised and respected in the management of the parks.” The vast majority of people that that I know with long and profound contact with the region are strongly against the planned Falls-Hotham walk. I've been going to Feathertop and the Bogong High Plains for 42 years, long enough to have a right by association to claim connection. I've been involved in hut building, clearing tracks and weed suppression. We've been to these places summer and winter in starlight and storm, and place a very high value on them.
12 “Improvements to visitor access will include ... development of a supported walk to be known as the Falls Creek to Mt Hotham Alpine Crossing". There is no requirement in the ANP draft plan for this walk to go up Diamantina Spur. "Investigate the feasibility accommodation options for the Falls to Hotham Alpine Crossing (wild walk), including Red Robin Mine and demountable standing camps ... Feasibility study completed 2017". So the ANP draft management plan envisaged a walk up Machinery Spur, not Diamantina Spur. There's another year or two for the feasibility study to be done, and I discuss this below at point 25. There's also the question of how easy the walk should be and if everyone has a right to do such a walk. I suggest not. Not everyone can do everything – it's simply not possible. To do such a walk requires fitness, stamina and mental toughness. Short of carrying a person, no amount of support will allow people who do not have these personal traits to safely do the walk.
13 If the draft plan is the latest plan – and I cannot locate anything later – then taking action prior to that draft being approved is questionable. On a related matter, Falls Creek and Hotham resorts are promoting walks from their resorts with very similar wording. The Falls Creek walk is called “Falls to Hotham Alpine Crossing” - very similar to the one under consideration - and follows a different route to that of Parks Victoria. Like the Hotham to Falls Creek walk promoted by Hotham Heights, this walk information has a very significant number of errors and will entice people into jeopardy. There's also enticement to break the law, hardly a suitable action of a government department.
Inaccurate information14 The walk Plan website
http://www.tourismnortheast.com.au/alpine-crossing/ says
Day 1 Wallaces to Tawonga Huts
Day 2 Tawonga Huts to either Blairs or Diamantina Horseyards
Day 3 "involves a hike up Diamantina Spur to High Knob (night three) where walkers have the opportunity to walk to the summit of Mt Feathertop."
Day 4 is "via the Razorback finishing at Diamantina Hut near Mt Hotham".
15 The Plan poster at
http://www.tourismnortheast.com.au/wp-c ... educed.pdfhas conflicting and questionable information. It is also appallingly laid out, with far too much information for easy comprehension. The walk Plan is also very badly laid out. The soft fonts and poor contrast breach Equal Opportunity legislation, and remedies exist. It is unclear if this was intended or if those involved are unaware of good design maxims. If the poor design was intended, the only reason that I can envisage is to stop people from reading it easily or at all. Why is the design so poor?
16 The poster map is combined with a gradient section, and does not work. Cope Hut to Tawonga Huts is shown as 177 metres of climbing or descent; it does not say which. Wallaces car park to Tawonga is also shown as 177 metres. No descent or climbing from Wallaces car park to Cope Hut? Oops. My map shows that from Wallaces car park at about 1670 metres the track goes to the aqueduct at about 1600 metres, a descent of 70 metres. The climb to Cope Hut is about 100 metres. There's several ascents and descents to the high of 1810 metres before descending to Tawonga Huts at 1650 metres, down 160 metres. From the Wallaces car park to Tawonga Huts I calculate up 215 metres and down 210 metres. That is, the poster map has an error of 15% for this section. This does not inspire confidence.
17 The climbs and descents are indistinguishable from each other if you don't know the area or how to read maps. By glossing over ascents and providing false information, the walk appears easier than it is. Westons is shown as 1480 metres. It's closer to 1580 metres.
18 Night two is in two places, Blairs Hut and Diamantina Horseyards. This fits with the point 14 options. The horseyards are incorrectly shown as being above Blairs. Facts: Blairs 1120 metres, horseyards 1080 metres. The walk after the horseyards is labelled "Tawonga Huts to Diamantina Spur, 3 km 470 metres". Oops. Night three is wide: Diamantina Spur at 1540 metres (2 kilometres distance, 200 metres altitude and a good two hours up the spur to High Knob, possible camp #2. It's 40 minutes from here to Federation Hut, and another 30 minutes to Feathertop. Blairs-Diamantina Spur-Razorback is a solid and exhausting day for many.
19 Day 4 on the poster finishes at the summit of Mt Hotham. The other information says "finishing at Diamantina Hut near Mt Hotham". Diamantina Hut is on Mt Hotham. Why are two documents prepared at the same time for the same process in disagreement?
20 Hotham Heights is in the wrong place on the Plan map. (Hint: Hotham Heights is about a kilometre south-east of the shown position.) If they can't place a major ski resort accurately on a map then the capacity to manage the walk Plan is again cast into serious doubt.
21 The walk starts near Wallaces Hut, not Falls Creek. Describing the walk as between Falls Creek and Mt Hotham is misleading and arguably in breach of section 18 of Australian Consumer Law, which relates to misleading or deceptive conduct. Remedies exist. If as shown on the poster the walk finishes at “Diamantina Hut near Mt Hotham” then the finish is misleading as well, and s. 18 of ACL can be applied here as well. Oops.
22 There's ample evidence that the people managing the Plan have minimal idea about the terrain, details or how to present information. They don't know where Falls Creek or Hotham Heights are located. There's a huge number of other basic obvious errors in the Falls-Hotham walk information, rendering it unfit as a basis for consideration of the proposal. These errors are so significant that the entire process is of a very questionable standard and it must be started again. Any money paid to consultants must be recovered, as their efforts are abysmal, totally unfit for publication. If these monies are not recovered, it could be asked why public funds have been wasted. The consultant should also pay consequential damages. There are legal precedents for this; the case law is quite simple and well-established.
Economic analysis23 The Plan has a heading Economic and social benefit which says:
"The Falls to Hotham Crossing will provide demonstrable economic benefits to the local community, the region and the State. It will support a wide range of investment opportunities for tourism, complementary services and infrastructure that provide an holistic and integrated walking experience."
24 This statement is presumptuous and should not be in the Plan. There has been no economic or cost-benefit analysis, so it's impossible to state how much the Plan will cost to set up and maintain. People will base their submission on the false and misleading advice that there will be economic benefits, apparently of substance with the benefits worth the cost. Hence, the entire process is cast into doubt. The quote in point 23 led to a comment: “What a wonderful sentence - absolute marketing fluff”. Quite.
25 The feasibility study is due to be completed 2017. Absent this study it is very hard to see why the Plan has been prepared. Parks Victoria recently advised that the economic component of the project “is programmed to commence early in the new year. The consultant team will work this up with Parks Victoria and make it available to the public for comment in mid-2016.” So the economic basis for the Plan is yet to be determined and will not be finalised until late-2016. It beggars belief that the consultants – who are most likely very highly paid – did not realise that the entire process is being done backwards. It's like Alice in Wonderland, “Sentence first, verdict afterwards.” For the matter under consideration it's “Plan first, economic justification afterwards.” More and more I'm coming to the conclusion that the consultants have not the faintest idea what they are doing, and are being paid under false pretences. Remedies exist at law for recovery of monies paid for results that do not meet a desired or acceptable standard.
26 Based on local and interstate experience, the total cost for the Plan will be approximately $1.28 million. (This will rise substantially if helicopters are needed more than anticipated.) Allow depreciation of 8% per annum, which is what Parks Victoria should be spending now to stop asset deterioration. (I note with interest that the state government will not provide adequate resources for Parks Victoria now. It very much appears that there will not be adequate resources for maintenance of the proposed walk infrastructure.) Maintenance will be about $200,000 a year. So there needs to be about $300,000 a year to pay for the proposed walk. This must come from commercial walks.
27 It's important to realise that the new infrastructure is only for commercial interests. Current users have no need for new infrastructure and strongly reject the need. New infrastructure is only for commercial interests, so it follows that these commercial interests should pay for it. This falls very firmly under user pays.
28 The weather is too risky for guided walking between late-March and mid-October, so allow 180 days of viable walking per year.
29 It's physically impossible to have more people at some campsites, and larger parties are discouraged under the ANP draft Plan and Parks Victoria policy, so allow eight per party. There must be two staff in each party for safety reasons, so there will be six paying walkers per party, around 1100 paying walkers a year for one party starting every day. This works out at about $300/person just to pay for the infrastructure. When trip costs and – presumably – profit are added and an allowance is made for tax at the corporate rate the cost per paying walker is about $1500, around $400/day, far higher than many will pay.
30 However, there will not be trips leaving every day for six months. Initially at least the take-up rate is likely to be quite low, and a little higher on an ongoing basis when the walk is established I can't see more than two or three trips per week. Hence, the commercial costs and all establishment and ongoing expenditure come to about $2000 per walker for just four walking days. Due to the initial capital expenditure and necessary replacements, a commercial operation will most likely be running at a loss for a few years. This means that the commercial operation will probably have to be a company big enough to sustain a loss. Key business metrics such as return on equity, return on investment, profit per equivalent full-time employee and net profit after tax are unattractive. Fixed costs will make losses more likely.
31 Unlike walks such as Tasmania's Overland Track (OLT) and New Zealand's Milford Track, it's possible to walk on many routes between near Falls Creek and Mt Hotham. The navigation is generally not hard – just follow the poles. There's dozens of places to camp and there's only one climb, much less climbing than Diamantina Spur, much easier. It's possible to hire gear and buy food for far less than $2000 and have essentially the same experience as a commercial package. Many would agree that a non-commercial trip is vastly superior to a commercial trip, and this is reflected in visitor numbers on the OLT. Once word gets around that there's a simpler less expensive option that gives greater freedom, then the attractiveness of any commercial trip will plummet and people will literally vote with their feet. With a gentle nudge and good information, most people will manage without support.
32 The OLT guided walks cost $3125 for 6 days, or around $500/day. This is staying in luxury huts with chefs cooking meals on a vastly superior walk, far more spectacular. Independent trips on the OLT cost $200, including staying in huts. The Milford Track takes four days and costs $A140 staying in huts, also more spectacular than Falls to Hotham. There's no comparison. If the Bogong High Plains region was on par with the OLT then the Bogong High Plains numbers would reflect this. They do not. Wilsons Prom is about the best Victoria can come up with compared to the OLT, and it's still way behind.
33 Paying $1500 to $2000 is not going to happen. The economics do not stack up. The preceding analysis should have been done first, prior to a public preliminary plan. The fact that there was no economic analysis first is hugely disappointing, and shows again that the proponents have no idea how to manage such a venture.
34 There will be something like seven full-time equivalent jobs. However, due to the uncertain nature of the walks, these jobs will not be ones that can be relied on for regular income. Instead, I suggest that there will be a pool of leaders who can be available at relatively short notice. The walker clients will spend nothing while on the walk but will spend in nearby towns, notably Mt Beauty, Bright, Harrietville and Mt Hotham. The spending will be of the order of $2-300 each for accommodation (probably arranged via the commercial walking company), meals, and sundry other smaller items.
35 Spending multipliers are difficult to measure, and a best estimate needs to be explored. The commercial walking company will incur expenditure related to their clients: food, fuel, accommodation and other items. There will be extra costs associated with higher tourism numbers such as utilities and garbage collection. Shortcomings in sampling mechanisms can throw the multiplier results out. Due to the preceding I decline to make even an estimate of the economic impact; to estimate is foolhardy.
36 However, while measuring the economic impact of the proposed walk is quite hard, there's a much simpler option. The number of winter visitors to Falls Creek and Mt Hotham is some orders of magnitude more than the 1000+ people that will use the proposed walk each year. Falls Creek and Mt Hotham are big enough to have thousands on the slopes at any one time. There are also numerous support staff. Many visitors stay for several days. Resort visitors and staff spend every day at the resort or in nearby towns, and much more than the modest walker. So the resorts have many more people in one day than would do the walk in a year, and the resort people will be spending multiples of the annual walking spending in just one day.
37 That is, the economic impact of the proposed walk is totally insignificant compared to winter visitation. This will not change. So while there may be “demonstrable economic benefits” from the Plan, these benefits are minuscule, with a very low ROI, and most probably a loss.
Environmental and safety matters38 It seems that there may be an intention by commercial interests to have vehicular access to their first two overnight camps at Tawonga Huts and Diamantina Horseyards. If so then there's a conflict with the ANP Plan. Tawonga Huts has a 4WD track that's closed to non-management vehicles at the Pretty Valley gate. Allowing non-management vehicles past this gate detracts from the natural values of the region and is to be deplored.
39 The Diamantina Horseyards are just short of the locked gate on the West Kiewa River, and as such there's no issue with non-management vehicles entering where prohibited. However, there's a possible problem at both places in that there may be the intention in peak periods to have a fixed camp for the two or three parties a week. This would most likely be in Christmas-New Year, Australia Day and Easter. Fixed camps are acceptable for private groups but are unacceptable for commercial groups.
40 Diamantina Spur is over 700 metres of often steep exposed climbing. The climb is rated a medium or medium-hard and will take an unfit walker most of a day. As one gets higher the destination gets closer but tiredness will start to prevail. I know this spur – it's necessary to flex the mental muscles to keep going. Diamantina Spur is categorically not a place for unfit walkers. It's much harder than Milford or the OLT. The demographic of the target market for the walk is those who cannot manage without support. Such people will not have the requisite fitness to undertake the spur, making it highly probable that rescues will be necessary. If the weather is bad the chance of a death is increased. It's now a matter of public record that I have made this prediction. I hope I'm wrong. If I'm right then those responsible for suggesting this dangerous walk should be charged. Custodial sentences are apt.
41 Point 14 above shows how there is a proposal to camp at High Knob for night three. (Another variation of the 1540 metres Diamantina Spur or Federation Hut cited elsewhere in the Plan documentation.) High Knob is very exposed and has no water. Disposal of human wastes means that a toilet will have to be built. If the weather really deteriorates then a party a few hours below High Knob has two choices, neither of them very palatable. Walk to Federation Hut and down the Bungalow Spur. I've been in strong winds there and have been blown off my feet. In a blizzard, novice walkers would be put at risk. Can't happen? As I write this in early December the Victorian alps has a blizzard, snow falling. The other option is to go down Diamantina Spur, much of which is exposed and quite steep. A rock bluff needs to be negotiated, easy to slip, with injury or death resulting. High Knob and 1540 metres are dreadful places to camp on a regular basis. People without tents have died attempting to reach a hut, so the risks of establishing a hut or standing camp at High Knob are known.
42 Any proposal to build a hut or allow a standing camp at or near at High Knob is contrary to the ANP Plan and breaches a number of very basic park axioms, including visitor safety.
Market understanding
43 The Plan says:
"The Falls to Hotham Alpine Crossing is recognised by the Victorian government as one of four long-distance walks being developed under the Walk Victoria Icons brand which will position Victoria and the Australian Alps as a key nature-based destination."
44 Falls to Hotham is not a long-distance walk; it's a weekend via Dibbins and a moderate three days via Blairs and Feathertop. Calling Falls-Hotham long distance will not “position Victoria and the Australian Alps as a key nature-based destination." The long-distance description will bring Victoria into disrepute and make Victoria the subject of adverse remarks; this is already the case. “Long-distance” must be removed.
45 Long-distance walking is at least 6-10 days, depending on the terrain and climate. The lack of understanding of what constitutes a long-distance walk again shows that those managing the Plan have no idea what they are doing. The Plan is driven by false ideology that is most probably based on wishing to be seen as better than places such as the OLT. Tasmania has vastly superior scenery, and this will not be changed by marketing and spin. Ideology is never a good basis for action.
46 One person said “An icon is an image or a representation … so an 'icon walk' will be an image of a walk - no reality, that will be lost with the exploitation, just an image, or a representation, of what was.” This sums up the Plan nicely.
Summary47 This misguided attempt to create silk from straw will not succeed. There are serious conflicts between the 2014 Greater Alpine National Parks Draft Management Plan and the Falls-Hotham walk proposal. Those involved do not know the region and cannot even get basics right like placing a ski resort correctly on a map or stating where the walk ends. The Plan is economically, environmentally and aesthetically irresponsible, with false and misleading information that breaches the the ANP Plan and consumer laws. The Plan is manifestly dangerous, placing visitors at risk, which is contrary to the Draft Management Plan. Very little makes sense. The walk proposal is borne from fundamentally flawed ideology and is unlikely to succeed. The walk proposal will bring Victoria into disrepute. Already there is much mirth at the Plan – Victoria and the government are the subject of derision.
48 To make it quite clear, I'm strongly against the Plan.
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