“I am a traveller – you are a visitor – they are tourists”1

Supplementary Submission to Taskforce on Tourism and National Parks

1. Introduction

This is a supplementary submission to the NCC and NPA’s primary submission lodged with the Taskforce on 29th August 2008. It is made specifically in response to feedback received from the Taskforce members at the presentation made by NCC and NPA on 9th September 2008.

This supplementary submission addresses two specific aspects of tourism in national parks: (a) accommodation in national parks – especially hard-roofed accommodation – and (b) the accreditation of tourism (‘ecotourism’) activities and guides.

2. Overnight Accommodation in National Parks

The NCC and NPA now believe that a more appropriate terminology to distinguish between accommodation types in protected areas is as follows:

Permanent – including buildings with foundations, and which cannot be removed without major damage to the structure, and which frequently have permanent connections to a combination of electricity, water, or sewage;

Semi-permanent – buildings, structures and transportable accommodation (e.g. demountable cabins, hard caravan sites, safari-tents) which utilise some form of permanent or semi-permanent foundation (piles, slab etc.), but where the structure itself can be relatively easily and quickly removed without damage;

Temporary – buildings, structures and transportable accommodation which is self contained and either capable of being driven under its own power (e.g. campervans), towed (e.g. campertrailers, caravans, portaloos), or lifted onto or into a vehicle (e.g. tent).

The policies that NCC and NPA have developed regarding overnight accommodation in national parks and other protected areas is influenced by:

a) The level of environmental impact that such accommodation may directly have upon the natural and cultural values of a reserve – bearing in mind that research has shown that the overall environmental impact of an overnight visitor can be up to three times greater than that of a day visitor;

b) The impact that such accommodation may have upon the aesthetic and landscape qualities of a protected area, and thus upon the enjoyment of visitors to that area; and,

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c) The expectation of visitors to NPs that they will not be surrounded by crowds of people engaged in noisy pursuits inappropriate to a national park setting.

Consequently, the ease with which any accommodation structure can be removed (either temporarily or permanently) is of particular concern to the NCC and NPA.

2.1 Permanent hard-roofed accommodation

There are existing permanent hard-roofed accommodation facilities (PHRAF) for public rental in thirty reserves within the NPWS estate in NSW (with 20 of them being within national parks), ranging from stone lighthouse keepers’ residences to shearers’ quarters in the outback, and from alpine huts to beachside cabins. These facilities are extensively distributed across all parts of New South Wales. One thing that nearly all of these have in common is that they were existing structures when the protected area was gazetted. There have, in fact, been very few examples of new accommodation structures being constructed. However, some upgrading, extensions and new facilities have been constructed which cater to visitors for other than national park appreciation purposes e.g. the Surf Club building at Little Garie in Royal National Park. It is also important to recognise that some existing buildings/dwellings are used for national park management purposes, such as on site accommodation of staff, and for visiting long/short term researchers and education groups.

This situation also applies to the other eastern states. Two exceptions are the Bay of Fires Lodge in Mt. William NP and the alpine cabins in Cradle Mountain-Lake St. Clair NP – both in Tasmania. Victoria and Western Australia have commenced trialling soft-roofed ‘safari tents’ as a high-end market compromise between camping and PHRAF.

The NSW PHRAF estate comprises 6 reserves with lighthouse keepers’ cottages, 12 with cabins, 22 with houses/cottages, 5 with shearers’ quarters, and 3 with hotel/lodges. In total, these existing hard-roofed buildings can provide accommodation for 651 persons.

It is relevant to note existing NPWS adaptive re-use policies (the NPA policies have reference to this issue). There is sometimes a dilemma in that buildings may be expensive to maintain or upgrade to an acceptable standard, yet heritage obligations may bias the need for retention.

In virtually all cases, excepting some remote western parks, they are all accessible by 2WD vehicles, and most have electricity, water and toilet facilities. A few are, in fact, quite luxurious with TV, DVD players, full modern kitchens and ensuite bathrooms. We maintain that many visitors, especially high-end market overseas ones, would be expecting electricity (for lighting, fridge, heating, charging cameras, razors etc), water, showers (preferably hot), and flush toilets. The majority of commercially-operated cabins in other NSW public reserves (e.g. State Recreation Areas, Regional Parks etc.) already have electricity supplied and there would be an expectation by the travelling public to find at least the same level of utilities in any national park cabins.

Some of the more remote NSW NP properties which were formerly pastoral stations have a wide range of buildings. In many of these areas it makes good sense to adaptively re-use structures for accommodation, thus reducing the amount of driving required for visitors who would not camp but who wish to spend more than a day in the park; Sturt NP and Gundabooka NP being two such examples, as was Mungo NP (where the shearers quarters

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recently burnt down). However Mungo NP is now served by a gateway off-park cabin site, as well as quite adequate, if basic, camp grounds.

In contrast, in Queensland there are no reserves containing hard-roofed accommodation structures for public rental. Any existing accommodation structures in Queensland protected areas are either maintained for their historic/cultural value, sometimes with interpretation/visitor information, or removed. [A number of these are similarly ‘adaptive re-use’ buildings, such as the lighthouses which were returned by Commonwealth only in last 15 years or so with heritage as well as locational issues]. In South Australia nine parks have PHRAF for rental, while in Victoria the figure is lower with only six reserves having PHRAF.

With only a few exceptions, accommodation facilities in NSW protected areas are managed by the National Parks and Wildlife Service. Consequently, there is an issue of whether this is a good use of scarce government funds, and whether they might be more effectively operated by the private sector. In the absence of specific profit-loss data for each individual PHRAF, it is impossible to determine the economic effectiveness of NPWS management. However, the NCC and NPA would have severe reservations about private sector concessions due to the propensity of that sector (as evidenced in Kosciuszko NP) to pressure for expansion of the facilities and bed numbers, with attendant environmental and social impacts.

2.2 Semi-permanent and temporary soft-roofed accommodation and other park facilities

It is salutary to examine the level of facilities (including soft-roofed accommodation) provided in protected areas which do not involve PHRAF (see Table 1 for a comparison between the NSW and Queensland situations). It is important to note that most states have a large number of reserves (equivalent to ‘strict nature reserve’ under IUCN nomenclature) which are dedicated solely for nature conservation (often due perhaps to the existence of a threatened species), and are thus not deemed appropriate for any level of visitor access. In NSW, there are such 585 reserves (including 458 nature reserves), some of which are very small in size.

Well over half (59%) of all NSW Parks which have visitor facilities (and that includes all but 23 of the 127 National Parks) have formal car-based (including trailers) camping facilities, with about half of these reserves also being suitable for caravans. The vast majority of such areas have picnic tables, toilets and BBQs/fireplaces. Eleven reserves have kiosks providing information and items for sale (not always food).

The situation is relatively similar in Queensland, where nearly three-quarters of reserves with facilities have a camping site. However, in many cases, the facilities provided are limited to toilets, especially on the offshore island national parks. A greater emphasis in Queensland (as opposed to NSW) would appear to be placed upon the provision of water at public park facility areas. However, 65 Queensland national parks have no visitor facilities of any kind, whereas in NSW the figure is only 23 national parks. Overall, the level of visitor facilities, especially accommodation, is far greater in NSW than in Queensland. It is instructive to note that the reserve-specific Queensland National Parks webpages frequently provide direct linkages to local accommodation outside the park in nearby towns.

In Victoria, many national parks have camping areas, some of which are suitable for caravans, and some of which have showers provided. Three parks have small semi-permanent safari-

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tent accommodation facilities (‘Wilderness Retreat’), co-located with pre-existing camping grounds, some also with conventional cabins.

Impact LevelsIf there was to be any expansion of new permanent hard-roofed accommodation facilities in NSW national parks, the NCC and NPA believe that, almost irrespective of the level of care taken with construction, there could be unacceptable levels of impact from the following sources:

Construction impacts – roads for delivery, heavy traffic, excessive noise, soil disturbance, wildlife disturbance

Infrastructure impacts – provision of electricity involving clearing and maintenance of power line easements, provision of sewerage including disposal and involving either pipelines with easements or pump out, provision of water involving construction of dams or pipelines with easements

Operational impacts – additional noise, delivery of goods, extra people (cleaners, managers etc), extra traffic

Social impacts – degradation of aesthetics in natural areas, increased people pressure, diminution of ‘low-impact’ experience,

If it is essential to provide a higher-quality comfort (and the NCC and NPA would strenuously debate this point), we would suggest that NPWS could examine improving the levels of comfort and facilities provided in the existing PHRAF (eg ensuite facilities, hot showers, fridges, kitchenettes etc.) However, we believe that recreational facilities not related to the enjoyment, appreciation and learning of nature (e.g. tennis courts and swimming pools) are inappropriate to protected areas. We see no reason for NSW to provide higher quality facilities than Queensland, who have developed a successful tourism industry based totally upon all hard-roofed accommodation being located outside the protected areas system. But were the line of improving quality to be pursued, the NPWS must be aware of the potential environmental impacts attendant upon such a course.

CabinsWithin the term ‘cabin’ can reside a plethora of accommodation options. Although expensive, the provision of services can be undertaken with minimal environmental impact through the use of self-composting toilets, solar energy for electricity and hot water, and tanks for rainwater supply. It’s the fittings inside that often delineate the level of ‘luxury’. There are many architects within Australia who can incorporate these features into designs that blend aesthetically into bushland settings. We would term these ‘self-reliant cabins’ (SRC). That is, they must be capable of sustaining visitor use without the regular input of services from outside the site, any new cabins must be limited in number and size, and they must be aesthetically appropriate to a natural setting. It should be noted that existing NPA policy (currently under review) is opposed to any new cabin construction in national parks.

Semi-permanent Safari CampsAnother option that may be worth considering is the provision of ‘safari tents’. This is currently occurring in Victorian and Western Australian national parks (and also mooted for Cockatoo Island in Sydney Harbour NP), and is contingent upon the concept that they are removable (either temporarily or permanently) should the level of impacts be deemed unacceptable for whatever reason. But carefully designed, they could be virtually indistinguishable from the large older-style tents. However, it is still necessary to supply the electricity, water and sewage disposal systems. If the site is deemed otherwise appropriate,

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the impact of related permanent or transient facilities must also be part of the decision-making process.

Two examples (extracted from the relevant websites and direct research) are presented below for information – but NCC & NPA are not yet in a position to comment upon the acceptability of such facilities.

Sal Salis Ningaloo Reef, Cape Range National Park, Western Australia

This privately-developed accommodation facility comprises five ‘safari tents’ and a communal lounge/dining structure located on the dunes behind a beach. The site is leased from the national park. Maximum accommodation is 12, and the resort employs three full-time and two part-time staff. Tariffs are about $685 per person per night. Additional tours and experiences are offered to guests as part of the package.

The facility was approved with the objective of expanding the range of opportunities in the park, not as a revenue earner. Public access to the beach was retained and standard camping areas are available at other locations in the park. A full environmental assessment was undertaken prior to construction and no cultural sites, rare plants or significant fauna habitat were affected. Park managers are comfortable with the ‘very small footprint’ and low level of impact created by the facility. No external services are provided and even water is carted in (a maximum of 20 litres per person per day). Visitors are encouraged not to drive at dusk in order to protect park wildlife.

From the website: “The camp has been designed to operate in tune with the fragile environment of Cape Range National Park and as such we abide by strict principles of minimal impact and sustainability.  All of our power is solar generated, each en suite bathroom has a natureloo (jargon for state of the art composting loos!), water usage is very carefully managed and no waste material escapes into the surrounding ecosystem.  Each room has a fan to ensure the circulation of air in the middle of summer.  Native herb soaps and ecologically sound shampoos are provided.  The tents are spacious and naturally comfortable – they are not intended to be 5 star hotel rooms in the bush so do not offer TVs, telephones, minibars or other modern appliances.”

Off-park v. On-ParkNevertheless, the NCC and NPA fail to understand the reluctance of the tourism industry topursue accommodation options on adjoining private and public lands. Many of the lands now coming into the protected areas system have areas of substantially modified lands –

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Tidal River Wilderness Retreat, Wilson’s Promontory NP, Victoria(Similar facilities also at Buchan Caves and Cape Conran). The 4 safari-style tents are completely weatherproof and include a covered hardwood timber deck and a lockable canvas door. Integrated private en suites (shower, vanity basin and toilet). In a separate tent there is a well equipped communal kitchen with gas cook top, microwave oven, fridge and tea & coffee making facilities. “The tents are low impact and touch the earth lightly as they sit on an innovative modular galvanised steel frame that doesn’t require concrete footings”.

mostly past farming, sometimes post mining/extractive industries – and many of these may also prove highly suitable as designed camp sites with managed rehabilitation.

The NCC and NPA are concerned that the industry’s reluctance is due to a hope that they might be able to acquire rights to the public resource at a lower cost, or that they are concerned at the cost and delay of meeting Council’s planning and environmental regulations and believe NPWS would have simpler and quicker processes – or be easier to influence. We fail to understand what is so special to a non-local tourist about crossing that magic invisible cadastral paper line that says ‘national park’ on one side and ‘freehold’ on the other.

We are sure that the skill of the industry in promoting a facility located “within a pristine natural environment directly adjoining Woop-Woop National Park” would outweigh any loss of response from not actually being 200 metres across the line inside the park. We believe that most tourists would be more concerned about the level and quality of the facility itself, rather than whether it was physically located a few metres inside a national park.

Costs and equityIn general, even if you rent the accommodation at peak time, and fill it to the maximum no. of people, most NPWS cabins/cottages/houses etc are still only charged in the range of $10-30 per person per night. Huts and shearers’ quarters are much cheaper, especially if you fill them right up to their maximum capacity! Lightkeepers’ houses, the Kosciuszko VIP Lodge, and the Sydney Harbour cottages are more expensive (up to $220 p.p. p.n. for the latter at Xmas/New Year).

For a week’s minimum rental (usually for two persons), NPWS houses (n=12, excepting the Sydney Harbour houses) average $1,005 ± $159 per week, while cabins (n=11) average $531 ±159, and cottages $381 ±186 per week.

Thus the PHRAF that NPWS already provides is reasonably low-cost and equitable given the rates for alternative accommodation and the level of average incomes in 2008. In fact, most motels in rural NSW (even of a dubious standard on a main road with trucks rumbling past all night) are costing about $40-50 pp pn. So there is potential to move fees upwards, particularly if the quality of the facility is improved. Perhaps many existing NPWS facilities are currently too cheap given that their supply is fixed and that they are often located in fantastic locations. This may be why some of them are crumbling, of low quality, or in poor decorative order (although the lighthouse cottages have been recently renovated).

The issue of park entrance fees also requires reviewing and standardisation, since some parks charge entrance fees but not camping fees, and others vice versa.

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Table 1. Comparison between NSW and Qld NP accommodation and visitor facilities

facility NSW Qldno. of reserves % NPs no. of parks % NPs

PHRAF 20 15.7 0 0.0Formal Camping 751 59.1 521 34.0Bush Camping2 35+ 27.6 38 24.83

Caravan sites 34 26.8 16 10.5Kiosks 11 8.7 0 0.0Picnic tables/areas 104 81.9 41 26.8Showers – hot or cold 20 15.7 16 10.5

- Showers hot (6) (3.9)- Showers cold (10) (6.5)

Toilets 100 78.7 60 39.2BBQs 91 71.6 20 13.1Fireplaces n.a.4 13 8.5Water provided n.a. 31 20.3Shelters n.a. 12 7.8No facilities 23 18.1 65 42.5Total 1275 153

Note: Percentages do not total 100% as categories overlap (e.g. camping and caravan sites).1 Total includes all ‘caravan sites’ as these also have camping facilities.2 ‘Bush Camping’ is described differently in Qld to NSW. In the former it can have

facilities, or no facilities, and can mean either a non-formal campsite or self-reliant camping. In NSW it usually always refers to back-country self-reliant camping with no facilities.

3 This refers to bush camping with facilities.4 ‘Fireplaces’ and ‘BBQ facilities’ in NSW are used interchangeably.5 Figure from “2008 Guide to NSW National Parks”.

3. ‘Ecotourism’ Accreditation

"What's in a name? That which we call a rose by any other word would smell as sweet."  --From Romeo and Juliet (II, ii, 1-2)

3.1 General Principles on Criteria and Standards

NCC and NPA believe, and tourism research confirms, that many travellers are already looking for tourism services associated with low or positive environmental impacts and with high social and economic benefits. Responsible ‘ecotourism’ travelling is clearly expanding as a major market segment.

There are hundreds of certification systems and best practices that define sustainable tourism currently in operation around the world. Recognising that tourism companies are seeking advice on identifying internationally recognised sustainable criteria to launch their initiatives

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based on solid ecological sustainability requirements, and that consumers are turning towards products that can assure their ecological sustainability, UNEP, the Rainforest Alliance, the World Conservation Union (IUCN), the UN World Tourism Organization, have partnered to develop the Sustainable Tourism Criteria Initiative. This compares sustainability requirements from 40+ certification, ecolabeling, best practice, and codes of conduct as well as other international guidelines with the purpose of identifying common sustainable tourism requirements from initiatives across the world. The Initiative, “has been designed as a way to bring together -for the first time- a globally relevant set of sustainability criteria for the hotel and tour operator sectors. Through this common understanding of what ecologically sustainable tourism really means, the travel industry, media, governments, and consumers will be better positioned to differentiate, recognize, promote and support sustainable tourism products and services” (http://www.uneptie.org/scp/tourism/topics/resource/ecolabels.htm ).

The Steering Committee of the Sustainable Tourism Stewardship Council is a proposed global accreditation body for sustainable tourism and ecotourism certification programs (http://www.rainforest-alliance.org/tourism.cfm?id=council ).

The Big Volcano Ecotourism Resource Centre (based in northern NSW) provides excellent links to a wide selection of ecotourism accreditation and certification programs, codes of conduct, codes of practice and operational guidelines; including sustainable tourism, geotourism and responsible tourism for stakeholders, policy makers, tour operators, outdoor guides and visitors to destinations. Reference is: http://www.bigvolcano.com.au/ercentre/codes.htm.

Without the time to obtain detailed responses from the major players in this field on their specific assessment processes for accreditation, NCC and NPA wish to comment upon the principles that must underpin any accreditation system to be adopted in respect of activities in the NSW protected areas estate.

NCC and NPA wish to endorse the generic principles detailed in the Mohonk Agreement (attached as Appendix 1). We believe that these principles establish a framework upon which to construct an ecologically, ethically sound, independent and transparent accreditation process with implementable enforcement.

The NCC and NPA endorse the following principles of any accreditation scheme:

The scheme should provide tangible benefits to local communities and to conservation;

The scheme should set minimum standards while encouraging and rewarding best practice;

There is a process to withdraw certification in the event of non-compliance; The scheme should be designed such that there is motivation for continual

improvement - both of the scheme and of the products/companies to be certified; Criteria used should meet and preferably exceed regulatory compliance; Criteria should embody global best practice environmental, social and economic

management; Criteria should be adapted to recognizing local/regional ecological, social and

economic conditions and local sustainable development efforts; Criteria should be subject to a periodic review; Criteria should be principally performance-based and include environmental, social

and economic management process elements;8

The certification program should be transparent and involve an appeals process; The certification body should be independent of the parties being certified and of

technical assistance and assessment bodies (i.e., administrative structures for technical assistance, assessment and auditing should avoid conflicts of interest);

The scheme should require audits by suitably trained auditors; and, The scheme should require mechanisms for consumer and local community feedback.

Specific criteria espoused in the Mohonk Agreement (See Appendix 1, and http://www.rainforest-alliance.org/tourism/documents/mohonk.pdf ) , and of special relevance to tourism in protected areas in Australia include;“Overall

Environmental planning and impact assessment has been undertaken and has considered social, cultural, ecological and economic impacts (including cumulative impacts and mitigation strategies);

Environmental management commitment by tourism business; Staff training, education, responsibility, knowledge and awareness in environmental,

social and cultural management; Mechanisms for monitoring and reporting environmental performance; Accurate, responsible marketing leading to realistic expectations; and, Consumer feedback.

Social/Cultural Impacts upon social structures, culture and economy (on both local and national

levels); Appropriateness of land acquisition/access processes and land tenure; Measures to protect the integrity of local community's social structure; and, Mechanisms to ensure rights and aspirations of local and/or indigenous people are

recognised.Ecological

Appropriateness of location and sense of place; Biodiversity conservation and integrity of ecosystem processes; Site disturbance, landscaping and rehabilitation; Drainage, soils and stormwater management; Sustainability of energy supply and minimisation of use; Sustainability of water supply and minimisation of use; Sustainability of wastewater treatment and disposal; Noise and air quality (including greenhouse emissions); Waste minimisation and sustainability of disposal; Visual impacts and light; Sustainability of materials and supplies (recyclable and recycled materials, locally

produced, certified timber products, etc.); and, Minimal environmental impacts of activities.

Economic Requirements for ethical business practice; Mechanisms to ensure negative economic impacts on local communities are

minimised (we prefer to use the word ‘avoided’) and preferably there are substantial economic benefits to local communities; and,

Requirements to ensure (‘ecotourism’) contributions to the development/maintenance of local community infrastructure (NCC/NPA have reservations over this one, unless it can be achieved without fostering local social conflicts).

Ecotourism Criteria9

Ecotourism is sustainable tourism with a natural area focus, which benefits the environment and communities visited, and fosters environmental and cultural understanding, appreciation, and awareness. In any ecotourism certification scheme, the criteria should address standards (preferably mostly best practice) for sustainable tourism (as per above) and at least minimum standards for:

Focus on personal experiences of nature to lead to greater understanding and appreciation;

Interpretation and environmental awareness of nature, local society, and culture; Positive and active contributions to conservation of natural areas or biodiversity; Economic, social, and cultural benefits for local communities; Fostering of community involvement, where appropriate; Locally appropriate scale and design for lodging, tours and attractions; and, Minimal impact on and presentation of local (indigenous) culture”.

For walking and camping in remote areas, the NCC and NPA endorse the principles detailed in the international ‘Leave No Trace’ guidelines – reproduced as Appendix 2.

3.2 Ecotourism Australia

Ecotourism Australia (ETA) has been suggested as operating appropriate accreditation schemes for commercial tourism facilities in protected areas in NSW. Unfortunately, the NCC and NPA has not yet received a copy of ETA’s assessment criteria for review, so we are currently unable to specifically endorse, or otherwise, such schemes. We are also sceptical about the level of independence in the assessment and accreditation process.

The definition of ecotourism adopted by Ecotourism Australia is:"Ecotourism is ecologically sustainable tourism with a primary focus on experiencing natural areas that fosters environmental and cultural understanding, appreciation and conservation".The NCC and NPA accept this definition.

Ecotourism Australia believes that the ultimate definition of ecotourism is compliance with the core criteria stated within their Eco Certification Program. This Program accredits products not companies. Three types of nature tourism or ecotourism product may be accredited:

Tours Attractions Accommodation

Many operators manage more than one of these types of product.

ETA base their accreditation upon the following criteria:

Triple bottom line The nature tourism or ecotourism product principles: Nature Tourism Ecotourism/Advanced Ecotourism

Economic Sustainability

1.       Business Management and Operational Planning2.       Business Ethics3.       Responsible Marketing4.       Customer Satisfaction

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Environmental Sustainability

5.       Natural Area Focus6.       Environmental Sustainability 7.       Interpretation and Education N/A

8.       Contribution to Conservation N/ASocial Sustainability 9.       Working with Local Communities N/A

10.    Cultural Respect and Sensitivity N/A

ETA further believe that Nature Tourism and Ecotourism certification provides “benefits to operators, managers, communities and travellers through providing:

criteria to assist operators plan and develop their nature tourism and/or ecotourism product ;

a guide to assist operators implement the principles of ecologically sustainable development ;

an opportunity for operators to continually improve performance to a standard recognised as best practice ;

a recognised logo for operators to use in their marketing material ; a recognised means for protected area managers and travellers to identify genuine

nature tourism and ecotourism operators ; a tool for protected area managers to encourage improved practices that lead to less

environmental impact ; a tool to help local communities determine a mix of tourism activities that maximises

benefits and minimises negative impacts ; and, an essential educational and information tool”.  

However, nearly all these ‘benefits’ relate to the tourism operator, and not necessarily to nature conservation or to the protected area involved. Before NCC and NPA could endorse Ecotourism Australia’s certification schemes, we would need to review their assessment criteria and process in line with the principles of the Mohonk Agreement.

According to their website, “The Eco Certification Program is an initiative of Ecotourism Australia, which has established an Eco Certification Program Management Committee to provide policy and management support for the program. The Management Committee oversees an Audit and an Assessment Panel, which are Chaired by a person independent of Ecotourism Australia. When an application is received it is forwarded to an independent trained Assessor who reviews and scores the application, and contacts referees and the operator for clarification. The Assessor's report on the application is considered by the Assessment Panel at a monthly meeting before a final decision is made on the applicable level of Certification”.

We are unsure whether this process meets international standards for independence of process, and it is also unclear whether it meets transparency requirements. For example, the assessors need to be independently selected and audited, with penalties attached if assessments are shown to be incorrect or falsified.

We understand that the Eco Certification Program operates as a self-funding, not for profit program. The following three examples of a certified activity operating in a NSW national park are drawn from ETA’s website.

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Example 1: Advanced Ecotourism Certification

“Lane Cove River National Park boasts four amenities blocks, all cleaned daily. Separate disabled facilities and baby bath facilities are also available. The Lane Cove River Tourist Park is part of the Lane Cove National Park and is operated by the National Parks and Wildlife Service (NSW). The area was established as a caravan park in the 1960s and was subsequently leased to private operators on a twenty-five year lease.

National Parks took the enterprise over in the late 1990s and has continually developed the site to the standards outlined in the Lane Cove National Park Plan of Management in order to develop a harmonious mix of business and environment.

The Tourist Park is self funding with any profits being contributed back to Lane Cove National Park and environmental programs administered by the Department of Environment and Conservation”.

Example 2: Certified Ecotourism

“Sapphire Coast Ecotours are for people who love walking, are interested in the environment, natural forms, flora and fauna, aboriginal culture and like to ask WHY?

The fully guided tours of half and one day duration are conducted in and around the beautiful Mimosa Rocks National Park on the far south coast of New South Wales. The full day tours are complemented by a gourmet picnic, highlighting local produce. The small size of the interpretive tours ensures a quality experience with the flexibility to cater to your special interest be it bird watching, photography, aboriginal culture or just purely exercise.

Full packages can be arranged, including transport, accommodation and meals as well as the tours. It is easy to spend a weekend or longer exploring this region and all that it has to offer – pristine beaches, breathtaking scenery, places of historic interest, local indigenous culture, a rich art community wonderful gardens and fabulous fresh south coast produce”.

3.3 Other Tourism Accreditation Schemes

3.3.1 Green GlobeEC3 Global is an internationally recognised environmental advisory group which provides “a wide range of pathways to sustainability” including the Green Globe Standard, “which is designed for organisations within the travel and tourism industry and sets out the criteria to attain Certification. It provides an environmental management framework for organisations to achieve sustainability. The Green Globe Benchmarking and Certification processes focus on making operational improvements to sustainability performance”.

Green Globe’s (see Appendix 3) accreditation scheme states that it specifically addresses the key performance areas of:

Reduction in green house gas emissions; Energy efficiency, conservation and management; Reduction in the consumption of fresh water and resources; Ecosystem conservation and management; Support for local community development; Improved management of social and cultural issues;

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Example 3: An Industry driven Certification Program for Nature & Ecotour guides

The EcoGuide Australia program provides a credential, endorsing the recipient as a guide who will deliver an authentic, environmentally responsible, and professional Ecotourism experience.

Tour Guides of AustraliaCode of Guiding PracticeThis Code of Guiding Practice outlines the responsibilities and standards of behaviour expected of Tour Guides working within Australia. 1. To provide a professional service to visitors -professional in care and commitment, and professional in providing an objective understanding of the place visited - free from prejudice or propaganda. 2. To ensure that every effort is made to present true and accurate facts and ensure that a clear distinction is made between this truth and stories, legends, traditions, or opinions. 3. To act honestly, fairly and professionally in all dealings with all those who engage the services of guides and with colleagues working in all aspects of tourism. 4. Ensure that guided groups treat with respect the natural, cultural and heritage environments, and minimise impacts on these at all times. 5. As representatives of Australia, to welcome visitors and act in such a way as to bring credit to the country and promote it as a tourist destination. 6. Regularly update and upgrade my guiding skills and knowledge through training and professional development activities. 7. Declare to customers any relevant personal commercial interests, including commissions, and never force visitor purchases or solicit tips. 8. Be mindful at all times of duty of care and other health and safety issues. 9. Provide all goods and services as presented in the tour itinerary and promotional material. 10. Abide by all national, state or territory legislation governing the operation and conduct of tours, tour operators and tour guides.

Improved land use planning and management; Improved air quality and noise reduction; Improved waste water management; and, Waste minimisation, reuse and recycling.

By monitoring these key performance areas, Green Globe believes that organisations can reduce their carbon footprint; increase operational efficiencies and boost staff commitment to the organisation’s sustainability policy.

Green Globe state that their standards are “based on the principles of Sustainable Development as detailed in the Mohonk Agreement”.

However, cursory examination of their website would seem to indicate that accreditation is centred around energy, waste and water, with less attention being paid to standards of ecological and nature conservation performance.

The NCC and NPA have not yet had an opportunity to critically examine Green Globe’s assessment criteria and process. Noting criticism by WFF-UK in its 2000 report “Tourism Certification: An analysis of Green Globe 21 and other certification programmes”, the NCC and NPA would urge caution before adopting any Green Globe programme unconditionally.

3.3.2 AAA Tourism Green Star

In conjunction with Australia’s Auto Clubs, AAA Tourism:  Manages the Australian STAR Rating Scheme for approximately 10,000 properties

across Australia Publishes the National Accommodation Guide and National Tourist Park Guide Provides comprehensive and reliable information available online via the Auto Club

websitesSTAR Ratings Australia, the division of AAA Tourism managing the Australian STAR Rating Scheme, is a Registered ISO 9001:2000 Quality Management System.  The standards for Green STAR Accreditation were developed in a partnership between AAA Tourism and GREEN GLOBE under the guidance of the Australian Government established Sustainable Tourism cooperative Research Centre.

To be awarded a Green STAR rating the property must achieve adequate points against a set of practical environmental criteria, including:Energy efficiency - eg: energy efficient light bulbs and fixtures, zoned heating and cooling, signage reminding guests to turn off lights and air-conditioning, correct seals on doors and windows and natural ventilation available. Waste minimisation - eg: recycling program, towel re-use option, optional newspapers, printer cartridge recycling, linen no change options.Water management - eg: dual flush toilets, environmentally friendly cleaning products, unbleached paper products, no leaking taps, water efficient dishwasher, use of recycled water on gardens.

However, Green STAR is a self assessment program followed by a desktop audit conducted by AAA Tourism. And an independent audit is only undertaken at the time of the cyclical STAR Rating assessment.

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3.3.3 Rainforest AllianceThe Rainforest Alliance relevantly state “Accreditation & Certification Programs generally concentrate on the built environment, with the focus on environmentally friendly infrastructure design and advanced environmental monitoring systems.  Interpretive material about local history, flora and fauna, and guide programs designed to foster environmental and cultural awareness amongst guests and visitors, need to be included.  These interpretive criteria in particular are popular with resort developments seeking ecotourism commendation. While this recognition is encouraging developers to implement projects that are less environmentally damaging than in the past, the question for many people remains ... is this "ecotourism"”?

In its August 2000 report, WWF- UK warned that certification schemes for environmentally and socially responsible tourism can be misleading to consumers and often fail to guarantee high standards of environmental practice."

The Rainforest Alliance has produced a ‘Guide for Sustainable Tourism Best Practices’, which can be referenced at http://www.rainforest-alliance.org/tourism/documents/tourism_practices_guide.pdf.

3.3.4 Wildlife Tourism AustraliaWildlife Tourism Australia have established a set of criteria relating to tourist interactions with wildlife. NCC and NPA support these well-considered criteria and recommend that they must form part of any accreditation scheme accepted for tourism operations in NSW protected areas.

The criteria are detailed in Appendix 4, and cover the following key areas of activity: Business Management – business planning, market research, teamwork and building

relationships; Environmental Management – keep to tracks, do not drive off-road, awareness at dusk

and dawn, become involved in habitat restoration, small group sizes; Wildlife Interpretation – develop interpretive programmes, obtain visitor feedback,

highlight importance of wildlife in conservation and ecosystem processes, present wildlife ecology and natural history, address conservation threats and wildlife management issues, offer practical opportunities for visitors to conserve wildlife, provide minimal impact guidelines; and,

Planning and Managing Wildlife Encounters – encourage natural experiences, avoid handfeeding, undertake research, use technology, be flexible, utilise habituation, use a ‘spotter’, minimise disturbance, contribute to conservation, build relationships, learn scats tracks and traces, educate visitors, ensure safety, and use cameras.

Although a number of existing accreditation schemes have potential to be applied to tourism operations within NSW protected areas, all have their strengths, weaknesses and limitations. NCC and NPA cannot therefore endorse any single scheme or combination of schemes at this stage. We also believe that an over-riding principle for the adoption of any scheme is that NPWS retains quality control and approval of criteria, assessment and performance and review (even if some processes are outsourced). That is, it would be inappropriate to entirely ‘contract out’ accreditation schemes and processes to a third party. This principle is consistent with our position that NPWS must remain the regulator for all aspects of commercial use of protected areas in NSW.

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4. Supplementary Recommendations

Recommendation S1. NPWS and the tourism industry should explore opportunities for providing higher quality accommodation, within clear environmental guidelines using the existing provisions of the NP&W Act, and funded by the tourism operators/industry, through upgrading facilities (eg bedrooms, bathrooms, kitchens) existing public hard-roofed accommodation facilities under a strict adaptive re-use policy. Sensitivity must be given to cultural heritage issues.

At this stage NPA is conducting a review of its policies on accommodation in NPWS reserves. In that review we are actively looking at a number of options that we do not presently support, that would be compatible with the NP &W Act. We do not wish to pre-empt this review by suggesting that NPA and NCC will necessarily support these approaches or options. Two options we are looking closely at are:

a) new cabin accommodation in selected locations in remote parks more than 2 hours drive from a regional centre, where there is high potential visitor interest (but without alienating day visitation), subject to an approved Plan of Management, and outside wilderness areas or the undeveloped cores of large parks; such cabins to be ‘self-reliant’ and built within strict environmental guidelines (see below); and,

b) a small number of ‘safari-style’ tent facilities similar in design, operation and environmental footprint to those at Wilson’s Promontory NP, Vic and Cape Range NP, WA. These would be sited outside wilderness areas or undeveloped cores of large parks

Recommendation S2. In the provision and operation of any overnight accommodation within a protected area, whether hard- or soft-roofed, adherence should be made not only to the Plan of Management but also to the following principles and criteria:

i. Minimal environmental footprint;ii. Minimal disturbance (from the structure, traffic or from visitor activities) to native

wildlife (this could require re-routing of existing access roads, or restrictions on time of use to minimise roadkills);

iii. Minimal loss of aesthetic or landscape values through:- careful site selection,- use of natural materials wherever feasible, and- screening of structures

iv. No new ‘easements’ for power, water or sewage;v. Encouragement of ‘self-reliant’ facilities utilising solar power, composting toilets

and rainwater collection systems;vi. An ability to relatively easily and cheaply relocate the accommodation unit or

camping/dayuse site to enable site rehabilitation/restoration;vii. Consideration of temporary closures of sites for site rehabilitation and subject to

emerging ecological parameters – eg bird nesting sites, bat colony re-location etc.;viii. Provision of a range of accommodation options to ensure equity of visitor use;ix. Limitation of the scope and scale of activities associated with the accommodation to

ensure they are related to the values of, and appropriate to, a national park; x. Restrictions on the size and number of accommodation units to maximise both day

and overnight visitor appreciation of natural settings; and,xi. Adherence to strict design parameters and guidelines to minimise impact of

accommodation units/sites upon other PA visitors.

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Recommendation S3. The following principles and criteria should be applied when licensing commercial tour/recreational activities in protected areas:

i. Minimal ecological and environmental footprint of all activities;ii. Restrictions upon size of groups;

iii. No motorised ‘back-up’ or support vehicles (inc. helicopters) to be used beyond access which is available to the general public – ‘carry-in, carry-out’;

iv. Introduction of a permit booking system to manage/ensure numbers, quality of experience, and low environmental impact;

v. Accredited guides/operators to demonstrate knowledge of the reserve’s natural and cultural values and history;

vi. Set levels of OH&S proficiency, including remote area first aid; vii. Licence fees to be set at a level which, as a minimum, cover all NPWS costs in

managing the licence system, monitoring operators, search and rescue, and possible rehabilitation of damaged tracks and camping areas; and,

viii. All commercial operators to have attained and maintain the highest level of accreditation under a relevant ecotourism and/or other accreditation scheme(s) accepted by NPWS (see S4 below);

ix. All licence terms and conditions to be on an Internet-based public register for inspection; and,

x. Licence terms to be of minimal duration (1-3 years depending on risk, track record and sensitivity) to provide opportunity for regular review).

Recommendation S4. The following principles and criteria should be applied to any ecotourism and/or other accreditation scheme(s) to be accepted by NPWS as meeting their requirements for licensing commercial operators within the NPWS estate:

i. NPWS must retain the right to select an appropriate accreditation scheme, review and monitor that scheme’s performance, and vary the requirement to abide by the scheme, or to replace it with alternative conditions if it is no longer suitable or sufficiently rigorous;

ii. The scheme must provide tangible benefits to local communities and to conservation;

iii. The scheme must set minimum standards while encouraging and rewarding best practice;

iv. There is a process to withdraw certification in the event of non-compliance;v. The scheme must be designed such that there is motivation for continual

improvement - both of the scheme and of the products/companies to be certified;vi. Criteria used must meet and preferably exceed regulatory compliance;

vii. Criteria must embody global best practice environmental, social and economic management;

viii. Criteria must be adapted to recognizing local/regional ecological, social and economic conditions and local sustainable development efforts;

ix. Criteria must be subject to a periodic review;x. Criteria must be principally performance-based and include environmental, social

and economic management process elements;xi. The certification program must be transparent and involve an appeals process;

xii. The certification body must be independent of the parties being certified and of technical assistance and assessment bodies (i.e., administrative structures for technical assistance, assessment and auditing must avoid conflicts of interest);

xiii. The scheme must require audits by suitably trained auditors;xiv. The scheme must require mechanisms for consumer and local community feedback;

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xv. Any accreditation scheme must embody specific assessment criteria as detailed in the Mohonk Agreement.

Recommendation S5. The following improvements be made to the leasing system applying to the commercial use of buildings and land on NPWS lands:

i. The full details of draft leases are made available to the public for comment before finalisation

ii. Environmental performance indicators, set in the plan of management, be included in all leases. The legislation governing the leasing of Jenolan Caves Karst Conservation Area serves as a model for these provisions.

iii. A mechanism for an arms-length audit of lease compliance be put in place to ensure that local NPWS staff that have a close relationship to lessees do not carry out all lease compliance activities

iv. The maximum term of any lease should be limited to 21 years. This ensures that lease terms can be reviewed at a regular interval (roughly a human generation), is consistent with the Local Government Act leasing provisions and is ample time to allow an operator to make investments in the business and generate a sufficient profit.

v. The terms and conditions of all finalised leases be placed on an Internet-based public register as required (but not applied) by S 151D of the NP & W Act.

5. References

AAA Tourism Green Star. http://www.aaatourism.com.au/AAATDefault.aspx?sit=1&pid=366

Mohonk Agreement (2000). http://www.rainforest-alliance.org/tourism/documents/mohonk.pdf

NPWS (2008). 2008 Guide to NSW National Parks. NSW NPWS, Sydney.

Queensland National Park accommodation. http://www.epa.qld.gov.au/parks_and_forests/find_a_park_or_forest/

Sal Salis Ningaloo Reef Resort. http://www.salsalis.com.au/page/accommodation

Sustainable Tourism Initiative.http://www.uneptie.org/scp/tourism/topics/resource/ecolabels.htm

Tourism Stewardship Council. http://www.rainforest-alliance.org/tourism.cfm?id=council

Wilderness Retreats, Victoria. http://www.parkweb.vic.gov.au/4wilderness.cfm

WWF – UK (2000). Tourism Certification: An analysis of Green Globe 21 and other certification programmes. WFF-UK http://www.wwf-uk.org/news/n_0000000132.asp

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