The National Parks Association will be putting out a submission guide early in 2022. Submissions may be made until 30 January.
There are three documents:
- policy statement
- outline of the strategy
- guidelines for implementation of the strategy
We are concerned with a number of aspects of these documents:
- The three documents give a very conflicted picture of priorities for mountain bike management in national parks. While the conservation purpose of national parks is emphasised the development of new tracks is being actively encouraged.
- ‘Stakeholder’ groups will be able to propose new mountain bike trail routes for which a standardised assessment method has been outlined. This is a job that should be initiated by the NPWS and many areas should be off limits.
- There is no strength in the proposals to deal with the issue of what they call unauthorised tracks. The number of tracks has increased significantly over the COVID lockdown period and this has been an intractable issue for a long time.
- There is insufficient emphasis on education of mountain bike riders about the conservation objectives of national parks and the damage caused to habitat by illegally constructed tracks and their use.
We recognise that the demand for riding on tracks, as against management trails, has increased significantly but the use of tracks and their construction has to be controlled in the same way as other activities in national parks.
A quick Google search shows that this has been a problem for many years. Attempts by the NPWS to close down illegal tracks and fine bikers found riding on walking tracks have met strong resistance.
Significance of numbers of mountain bike riders
We need to put this issue into perspective. Statistics based on surveys undertaken by AusPlay, a federal government agency, show that in 2020 in NSW, 1.8% of adults participated in mountain biking compared with 8.6% who bushwalked. The majority of mountain bikers would be riding on management trails or signposted tracks. A minority engage in challenging downhill rides such as the Gahnia and Serrata tracks in Garigal NP near Bantry Bay. In our experience of the northern Sydney region this minority are the people demanding new trails.
Is it reasonable for the NPWS to be expending so much time and their limited budget on developing and managing more facilities that will benefit such a minority? There will be limited opportunity to get a financial return from these facilities.
The first statement in the policy seems well measured:
A range of cycling experiences, including mountain biking, may be provided in some national parks and reserves managed by NPWS, where cycling can be undertaken sustainably and consistent with the conservation of natural and cultural values.
However, the strategy documents are all about increasing cycling opportunities in national parks through the creation of new dedicated tracks and formalising unauthorised tracks.
NPWS recognise that many unauthorised tracks have been created due to the demand for single track and more technical cycling experiences. As NPWS looks to invest in enhancing existing tracks, and creating new tracks on park, we will be engaging early with stakeholders to explore sustainable experiences that protect the natural and cultural values of our parks and ensure NPWS legislative requirements are being met.
The mountain biking community will relish the opportunities presented. The question is whether the NPWS can stand firm against the pressure that will be applied by the vocal biking advocacy groups and ensure that the objectives defined in the National Parks Act for the management of national parks are enforced.
Planning and assessment processes for new track proposals
The strategy guidelines set out processes for deciding whether a proposed new track or formalisation of an unauthorised track is suitable for the national park. It seems that proposals can be put forward by interested parties. This totally overturns the general principle that NPWS should be deciding where any new track could potentially be placed and areas that are totally off limits.
Under the current process NPWS does the background research into the protection requirements of the location and suitability of the route and drafts an amendment to the plan of management that will be open for public consultation. This was the process for the development of the new tracks in Garigal National Park. This will still be the case, but having the plan initiated by outside stakeholders, could make it difficult to justify refusal against strong lobbying.
The document does acknowledge that:
Not all parks will be suitable for cycling activities, and in some parks cycling experiences will be limited.
The proposal is to be assessed in stages:
- Site suitability – even pristine, unmodified bushland is not completely eliminated from the development possibility. Generally land that has been modified to some extent is a possible candidate for further consideration – see stage 2.
- Then an analysis is applied according to a list of criteria that are given a point score under three equally weighted categories:
- protection of park values and whether use will be ecologically sustainable
- an enjoyable and safe visitor experience
- construction and maintenance cost
The actual application of these criteria is highly questionable and basically incomprehensible. For example, it is possible for a proposed track to go through an area with threatened flora or ecological community. A low score is given but that is just one item that could be swamped by the other criteria. Protection of park values should outweigh the other categories.
The guidelines claim that:
A standard process to assess and enable proposed new cycling experiences in a park will provide certainty for proponents of cycling experiences on the process to be undertaken and the issues that need to be considered. A consistent approach for assessment ensures that all appropriate environmental and cultural values, as well as visitor needs, are considered.
If a proposal is acceptable under the assessment outlined above then it is assessed at a regional level taking into account higher level factors such as demand, connectivity with nearby tracks and compatibility with other users such as walkers.
The method seems to be mainly aimed at creating longer tracks that can be regarded as a ‘destination’, a visitor drawcard. Our conclusion is that the assessment method will be a waste of time. Mountain biking groups can present proposals and then why can’t the assessment be left in the hands of the NPWS?
The assessment process is not suitable for the Sydney region because the topography is most areas is too steep and incised by waterways. Only relatively short tracks could be built and the potential areas are already covered by management trails.
Tracks in Sydney cannot contribute to the local economy as they are primarily used by local residents. The two tracks built in Garigal NP cost over $1 million are only 6.5km long and can be completed in 1.5 hours according to the NPWS website.
STEP’s Position Paper on Bushland Tracks and Trails takes a much simpler approach. Basically tracks, whether new or existing unauthorised bike tracks, should not be built in high quality bushland. This applies particularly in Sydney where the national parks are compromised by their proximity to urban areas, often deeply incised by waterways, have erodible soils. These parks are already being degraded by their location and need to be carefully managed to mitigate the effects of climate change.
Response to issue of unauthorised tracks
This statement is made in the policy document:
NPWS will progressively close and rehabilitate unauthorised tracks unless identified through appropriate planning processes (e.g. plans of management) to be formalised as part of a park cycling track network. Subject to available resources and identified priorities, NPWS will also undertake community engagement and compliance activities to address ongoing illegal track building and the risks associated with the use of unauthorised tracks.
The strategy goes into a lot of detail about these ‘appropriate planning processes’ with a potential outcome that illegal tracks could be formalised, vindicating illegal activity as an outcome of strong advocacy from mountain biking groups.
Unauthorised tracks can be managed and reduced by proactively establishing cycling networks that meet both environmental and user requirements, and through establishing processes by which NPWS can prioritise and rehabilitate unauthorised tracks.
Positive experiences for cyclists and NPWS can be forged through the creation of partnerships to ensure all perspectives are considered. There are currently numerous great examples in our parks of community groups working with parks to maintain and monitor tracks and reduce unauthorised tracks.
In our experience in Sydney’s national parks, these statements are very optimistic!
Rehabilitation of unauthorised tracks
Even before the COVID lockdowns the construction of unauthorised tracks has proliferated. This was recognised as an issue back in 2011 when the previous strategy was written. NPWS just hasn’t had the resources to close down these tracks. Will this new strategy make any difference?
Walkers in Sydney’s national parks come across these unauthorised tracks all the time. Many are quite short and provide an alternative more exciting route than the official management trail or a short cut from streets to a management trail. Some seem to be built just for the fun of trying out skills at building jumps and tight curves. Often it seems the people building these get bored with the track they have built and move on to another area. We don’t often see them actually being used.
The NPWS claims they can:
Develop a consistent and firm approach to non-compliant activities and work with user groups to develop a self-regulating culture of stewardship for the parks they enjoy.
But how many of the young illegal track builders are members of user groups? Education is inadequate and should be increased through signage and social media. Publicity about imposition of fines would help.
The culture and attitude of some mountain bike riders has to be changed so they accept that national park land is not available for their exclusive enjoyment. It is a rare asset that needs to be cared for and appreciated.
The attitude of bike riders on shared tracks also has to be changed. Too often they ride too fast to the extent that some walkers are scared to use some management trails.
Points for submissions
As STEPs primary concern is damage to bushland in our region, the main points we would like made in submissions are:
- Our local national parks are not suitable locations for the development of cycling experiences envisaged by the draft cycling strategy.
- NPWS has to make it clear in the documents that they are in control in determining where new mountain biking tracks may be built.
- More resources should be allocated to the closure and rehabilitation of unauthorised tracks.
- NPWS should encourage user groups to get their members to engage with all riders to instil a culture that regards the destruction of natural bushland as unacceptable.
- The strategy provides for NPWS to work with user groups and other land managers, such as councils. These groups should work together to develop stronger education programs about the appropriate places for developing mountain bike tracks and their use.