2013/07: Should Victoria's national parks have been opened to private developers?

What they said...
'We need to come to a clear decision as to why we have national parks, and how much we expect to be able to develop those areas to improve our economic return...'
Dr Kevin Tolhurst, an expert witness at the Royal Commission into the Black Saturday bushfires

'Victoria has the highest national park visitation in the country, yet the economic yield from this visitation is the nation's lowest'
Dianne Smith, Chief Executive Officer of the Victorian Tourism Industry Council

The issue at a glance
On March 31, 2013, the Victorian government released guidelines outlining the conditions under which private developers would be able to invest in establishing tourist facilities in the state's national parks. This is the first time such development has been allowed within the state's national parks. Previously, any private development within the national parks has existed only because it was there prior to the area being declared a national park.
The Victorian Minister for Environment and Climate Change, Ryan Smith, stated, 'Victorians, as well as interstate and international visitors, will have greater opportunities to experience and appreciate the state's wonderful natural environment following the release today of guidelines for environmentally friendly and sustainable tourism in national parks.'
Opponents of this policy shift see it as the commercialisation of the State's conservation areas and as a change likely to bring irreversible harm to the national parks, destroying the qualities for which they are currently valued.

Background
Victorian National Parks
Despite their name, most national parks are state and territory run, apart from six that come under Commonwealth jurisdiction (Kakadu, Uluru-Kata Tjuta, Booderee, Norfolk Island, Christmas Island and Pulu Keeling).

The Victorian National Parks Act 1975 states in its preamble 'that certain Crown land characterized by its predominantly unspoilt landscape, and its flora, fauna or other features, should be reserved and preserved and protected permanently for the benefit of the public.'
There are six main principles under which Parks Victoria, the body which manages Victoria's National and State parks operates:
i) They conserve the environment of the places they manage for current and future generations (including preparing for, responding to fires and helping restore land after fires).
ii) They acknowledge the Traditional Owners of the places they manage.
iii) They respect and protect the culture and heritage of the places they manage.
iv) They recognise the fundamental role of natural environments to human health
v) They plan and manage places to support use by all abilities and a diverse community.
vi) They plan and manage public land on behalf of and in partnership with the community.

Victoria has 2850 separate Protected Areas with a total land area of 39,273 kmę (17.26% of the state's area). Of these, 45 are National parks, totalling 28,023 kmę (11.32% of the state's area).
The Parks are managed by Parks Victoria, a state government organisation. There are also many smaller state areas which are subject to commercial activity such as logging.
The state of Victoria has also protected approximately 5.3% of coastal waters. In June 2002, legislation was passed to establish 13 Marine National Parks and 11 Marine Sanctuaries. Victoria is the first jurisdiction in the world to create an entire system of highly protected Marine National Parks at the same time.

As of 2011 Victoria's 45 land-based national parks were as follows:
The Alfred National Park (3050 hectares) established in 1925; the Alpine National Park (646000 hectares) established in 1989;  the Barmah National Park (28521 hectares) established in 2010; the Baw Baw National Park (13300 hectares) established in 1979; the Brisbane Ranges National Park (7718 hectares) established in 1973; the Burrowa-Pine Mountain National Park (18400 hectares) established in 197; the Chiltern-Mount Pilot National Park (21600 hectares) established in 2002; the Churchill National Park (1668 hectares) established in 1941; the Cobboboonee National Park (18510 hectares) established in 2009; the Coopracambra National Park (35000 hectares) established in 1991; the Croajingolong National Park (87500 hectares) established in 1979; the Dandenong Ranges National Park (3215 hectares) established in 1987 (it includes the former Ferntree Gully National Park); the Errinundra National Park (26875 hectares) established in 1988; the French Island National Park (11100) established in 1997; the Grampians National Park (168000 hectares) established in 1984; the Great Otway National Park (103000 hectares) established in 1981; the Greater Bendigo National Park (17007 hectares) established in 2009; the Gunbower National Park (9330 hectares) established in 2010; the Hattah-Kulkyne National Park (49975 hectares) established in 1960; the Heathcote-Graytown National Park (12833 hectares) established in 2002;  the Kinglake National Park (22360 hectares) established in 1928; the Lake Eildon National Park (27750 hectares) established in 1957; the Lind National Park (1370 hectares) established in 1925; the Little Desert National Park (132000 hectares) established in 1968; the Lower Glenelg National Park (27300 hectares) established in 1969;   the Lower Goulburn National Park established in 1992; the Mitchell River National Park (14338 hectares) established in 1963 (includes former Glenaladale National Park, expanded 1986, and 2003); the Mornington Peninsula National Park (2686 hectares) established in 1988; the Morwell National Park (560 hectares) established in 1967; the Mount Buffalo National Park (31000 hectares) established in 1898; the Mount Eccles National Par (6120 hectares) established in 1960; the Mount Richmond National Park (1733 hectares) established in 1960; the Murray-Sunset National Park (633000 hectares) established in 1991; the Organ Pipes National Park (152 hectares) established in 1972; the Point Nepean National Park (470 hectares) established in 2005; the Port Campbell National Park (1750 hectares) established in 1962; the Snowy River National Park (98700 hectares) established in 1979; the St Arnaud Range National Park (13900 hectares) established in 2002; the Tarra-Bulga National Park (2015 hectares) established in 1986; the Terrick Terrick National Park (5882 hectares) established in 1999; The Lakes National Park (2390 hectares) established in 1927; the Warby-Ovens National Park (14655 hectares) established in 2009; the Wilsons Promontory National Park (50400 hectares) established in 1898; the Wyperfeld National Park (356800 hectares) established in 1921; the Yarra Ranges National Park (76000 hectares) established in 1995.

Internet information
On April 9, 2013, Urbanalyst published a detailed overview of the guidelines under which private development will be allowed within Victoria's national parks. The overview includes response opposing and supporting the guidelines.
This treatment can be accessed at http://www.urbanalyst.com/in-the-news/victoria/1747-victorian-government-releases-guidelines-to-support-tourism-investment-in-national-parks.html

On April 3, 2013, the conservation group, Friends of the Box-Ironbark Forests issued a media release titled 'National Parks for sale?'
The release gives the group's detailed objections to the government's decision to allow private development in Victorian national parks.
The full text of the release can be accessed at http://www.fobif.org.au/2013/04/national-parks-for-sale/

On April 3, 2013, Foster Community Online posted a detailed analysis of the guidelines under which the government intends to allow private development in the state's national parks. The analysis includes comments supporting and opposing the guidelines.
It can be accessed at http://www.foster.vic.au/government-sets-guidelines-for-tourism-development-in-victorias-parks/

On April 2, 2013, Peter Ryan, the Member for Gippsland South, Deputy Premier,
Minister for State Development and Minister for Regional and Rural Development issued a media release titled 'Enhanced opportunities for eco-tourism in national parks'. The piece argues in favour of the government's decision to allow private development on national parks.
The full text of this media release can be found at http://peterryan.com.au/_blog/Press_Releases/post/Enhanced_opportunities_for_eco-tourism_in_National_Parks_/

On April 1, 2013, Sunraysia Daily published an opinion piece by Dianne Smith, the chief executive officer of the Victoria Tourism Industry Council. The piece is titled 'Private investment in tourism hailed'.
The comment praises the government's decision to allow private development in national parks. The full text of this comment can be accessed at http://www.sunraysiadaily.com.au/story/1399766/private-investment-in-tourism-hailed/

On March 31, 2013, the Victorian National Parks Association issued a detailed media release outlining their objections to private development in the state's national parks.
The full text titled can be accessed in five parts at
1. http://vnpa.org.au/page/nature-conservation/take-action/private-development-push-threatens-victoria%27s-national-parks
2. http://vnpa.org.au/page/nature-conservation/parks-protection/private-developments-will-grow-and-grow
3. http://vnpa.org.au/page/nature-conservation/parks-protection/regional-tourism-doesn%E2%80%99t-need-developments-in-parks
4. http://vnpa.org.au/page/nature-conservation/parks-protection/commercial-development-in-parks--_-neither-affordable-or-sustainable
5. http://vnpa.org.au/page/nature-conservation/parks-protection/victorian-policy-framework-is-flawed

On March 31, 2013, the Victorian Premier's Department issued a media release announcing the guidelines which will determine how private developments will be allowed in Victoria's national parks.
The media release can be accessed at http://www.premier.vic.gov.au/media-centre/media-releases/6388-guidelines-to-unlock-victorias-nature-based-tourism-.html

The guidelines themselves can be accessed at http://www.dse.vic.gov.au/__data/assets/pdf_file/0004/164290/DSE-Tourism-Guidelines.pdf

On September 23, 2012, The Conversation published an opinion piece by
Dr Sue Beeton, Associate Professor in Tourism at La Trobe University. The piece is titled 'Is nature-based tourism development really what our national parks need?'
The piece contrasts the arguments for tourist development within national parks against the arguments opposing such development. Overall it recommends caution.
The opinion piece can be accessed at http://theconversation.com/is-nature-based-tourism-development-really-what-our-national-parks-need-9090

On September 3, 2012, the Victorian Employers' Chamber of Commerce and Industry (VECCI) issued a media release supporting the Victorian government's decision to allow private development in the state's national parks. The comment was written by Dianne Smith, the chief executive officer of the Victorian Tourism Industry Council. The full text of this comment can be accessed at http://www.vecci.org.au/policy-and-advocacy/news/blog/2012/09/03/realising-victoria%E2%80%99s-tourism-potential

On August 28, 2012, The Star published a series of comments titled 'Prom not at risk: Ryan'. The piece gives comments from a range of government leaders and tourism spokespeople supporting the decision to allow private development in national parks.
The full text can be accessed at http://thestar.com.au/?p=4296

On August 27, 2012, The Wimmera Mail Times published a news report titled 'Tourism body backs Grampians investment plan'. The article gives a range of views in response to the government's decision to allow private development in national parks.
The full text of this report can be found at http://www.mailtimes.com.au/story/256151/tourism-body-backs-grampians-investment-plan/

On August 24, 2012, the ABC ran a news report titled 'National parks to be protected under tourism plan'. The report quotes state government assurances that the change in regulations governing national parks will be managed responsibly so as not to harm the parks.
This report can be accessed at http://www.abc.net.au/news/2012-08-23/national-parks-to-be-protected-under-tourism-plan/4218216

On August 23, 2012, the Victorian National Parks Association issued a media release responding to the state government's announcement of its intention to allow private development in nation parks. The Association is highly critical of the new regulations.
The text of this media release can be accessed at http://vnpa.org.au/page/publications/media-releases/parks-are-for-nature-not-private-development

In August, 2012, the Victorian Department of Treasury and Finance released 'Unlocking Victorian Tourism: An inquiry into Victoria's tourism industry'. The document details the Victorian government's response to Victorian Competition and
Efficiency Commission's (VCEC) Final Report on the state's tourism industry.
The VCEC recommended a number of actions designed to grow Victoria's tourism industry; included among these recommendations was allowing private development in the state's national parks.
In 'Unlocking Victorian Tourism', the state government accepted this recommendation regarding national parks. The full text of this document can be found at http://www.vcec.vic.gov.au/CA256EAF001C7B21/WebObj/GovernmentResponsetoVCECInquiryintoVictoria%27sTourismIndustry%28PDF%29/$File/Government%20Response%20to%20VCEC%20Inquiry%20into%20Victoria%27s%20Tourism%20Industry%20%28PDF%29.pdf

On March 21, 2011, The Education Age overviewed the arguments for and against allowing private development in Victoria's national parks.
This treatment can be found at http://education.theage.com.au/cmspage.php?intid=135&intversion=341

Arguments in favour of private development in national parks
1. Private development in national parks will advantage the Victorian economy
It has been claimed that Victoria's national parks are an under-developed resource which could be far better exploited to the benefit of the state's economy.
Dianne Smith, Chief Executive Officer of the Victorian Tourism Industry Council has stated, 'Victoria has the highest national park visitation in the country, yet the economic yield from this visitation is the nation's lowest. This is largely due to the lack of appropriate infrastructure and experiences available to visitors.'
Ms Smith has added, 'Nature-based tourism is a huge drawcard for those travelling to Victoria ... and we must work hard to produce competitive offerings.
These changes will encourage and facilitate investment in sensitive, appropriate and sustainable tourism infrastructure.
Victoria's tourism industry contributes almost $16 billion to the state's economy each year and employs more than 200,000 people. Tourism diversifies the economy, particularly in regional Victoria, and infrastructure built for use by tourists adds greatly to local communities as well.'
Victorian treasurer, Kim Wells, has stated, 'If we hope to attract more international visitors to Victoria, particularly from markets such as China, we must meet the rapidly growing demand for nature-based tourism.'
Victoria's Tourism Minister, Louise Asher, has stated, 'The independent Tourism Forecasting Committee predicts that by 2020 Victoria will receive approximately 500,000 Chinese overnight visitors - almost double the current level - and expenditure is forecasted to reach $1.5 billion.'
Ms Asher has indicated that the changes allowing for greater private development within the state's national parks were designed to capitalise on this huge potential market, grow the tourism sector and improve access to Victoria's world-class natural assets.

2. Private development in Victoria's national parks will make them accessible to greater numbers and types of tourists
Those supporting private investors being able to fund developments in national parks argue that this will result in improved facilities which will make the parks accessible to a wider range of visitors.
It has been claimed that without improved facilities many people, including the elderly, those with some physical disability and families with young children are simply precluded from enjoying Victoria's national parks.
Peter Ryan, the Gippsland South MLA and Deputy Premier, Minister for State Development and Minister for Regional and Rural Development has pointed to the way in which some existing development has appropriately enhanced the state's national parks, making them more accessible to the citizens of this state and to tourists from other states and countries.
Mr Ryan has stated, 'Wilsons Promontory is a good example of how we can have a marriage of a park environment with limited forms of development.
The cabins at the Prom enjoy an occupancy rate of 98 per cent and no one will say in any shape or form that they have harmed Wilsons Promontory. On the contrary, it has enabled a lot of people to stay at the Prom and there is no reason to be concerned.'
As early as 1991, in reference to the Lower Glenelg National Park, Victoria's then Department of Conservation and Environment noted that as part of the Department's social justice strategy, it had an obligation to provide 'equitable access to the experiences and facilities in the Park through design for disabled access, and direction of publicity, information and education services to a wide range of interest groups and individuals.'
One of the six main principles under which Parks Victoria is intended to operate is that 'They plan and manage places to support use by all abilities and a diverse community.' Supporters of the current arrangements allowing limited private development within national parks argue that all these new regulations do is assist national parks to meet their social justice objectives.

3. Private development in Victoria's national parks will make them better able to compete with other states and other countries
The Victorian government has stressed that private investment in national parks will assist the state to compete with other potential tourist developments interstate.
In its response to the Victorian Competition and Efficiency Commission's Final
Report on Victoria's Tourism Industry the Victorian government stated, 'Jurisdictions in Australia and internationally, have moved to allow ecologically sustainable development in line with the natural and cultural values of the land. This includes in New South Wales, which has opened up opportunities for sustainable visitor use and enjoyment in their National Parks, and in Queensland, which has sought private sector partners to deliver eco-friendly accommodation under tight environmental controls.'
Louise Asher, the Victorian Minister for Tourism and Major Events, has emphasised that Victoria is competing with other states, the Northern Territory and New Zealand to gain market share in the lucrative eco-tourism sector. Ms Asher has argued that this state needs to improve its offerings to travellers to induce them to stay longer in regional Victoria. Private development in national parks is seen as a key means of helping to make Victoria competitive.
Ms Asher has stated, 'Eco-tourism is an important driver of jobs and money for local communities, and as is the case with other iconic destinations such as the Cradle Mountain Huts, Wilpena Pound, Kingfisher Bay Lodge in Tasmania and Milford Sound Huts in New Zealand, they can co-exist with national parks and other natural areas.'
The same point has been made by Peter Ryan, the deputy premier and member for Gippsland South. Mr Ryan has stated that the new arrangements would mean that Victoria could compete with other states to gain a market share in the lucrative eco-tourism sector.
The Environment Minister, Ryan Smith, has said that facilities similar to the Cradle Mountain huts in Tasmania, resort-style accommodation in the Flinders Ranges National Park in South Australia and Karijini Eco Retreat in Western Australia would be the sorts of developments likely to be viewed as appropriate.
Mr Smith concluded, 'There is no reason why Victoria can't compete on the same playing field as those other states.'
Terry Robinson, the chief executive officer of tourism lobby group, Destination Gippsland, has stated, 'This [new policy] would then allow Victoria, and in our case Gippsland, to better compete with Tasmania and New Zealand for new investment funds and high yield visitors.'

4. Private developers can assist in managing Victoria's national parks
It has been claimed that allowing private investors to fund developments in national parks will reduce the pressure on state governments to fund the management of these parks. The private developers will be able to assist in the management of the parks.
It has been argued that private development that results in appropriate accommodation and infrastructure facilities such as paths and walkways removes from the state government the obligation to supply such facilities and so assists in the management of the state's national parks.
Terry Robinson, the chief executive officer of tourism lobby group, Destination Gippsland, has stated, 'It can be done, there are good examples in Tasmania and New Zealand, and it can enhance the environment as well as being good economically - but there is a need for checks and balances.'
In South Australia, Grant Hunt runs the Wilpena Pound Resort in the Flinders Ranges, paying more than $100,000 for the right to be in a national park. State authorities match his fees, and the money is co-invested back into the park for improvements and maintenance.
Mr Hunt argues tourism can add value to Crown land 'because when you're in there every day, it's in the interest of the operator to protect and conserve'.
Victoria Tourism Minister, Louise Asher, has indicated that in some cases, developers might be urged to invest in the environment - possibly by contributing to revegetation projects or local native animal funds - as a condition of approval for their commercial development; in others, they could contribute to infrastructure upgrades such as walking tracks or toilet facilities.

5. There are guidelines to ensure that any private development in Victoria's national parks is sensitive and appropriate
It has been argued that the new developments funded by private investors will not harm the national parks as investment will only be approved if it meets a strict set of guidelines.
Supporters of the new arrangements argue that the respect the environmental value of national parks. A key indicator of this is that the most sensitive wilderness areas will not be available for private development.
The Victorian treasurer, Kim Wells, has stated that the changes will encourage investment in accommodation for tourism areas like the Great Ocean Road, but will exclude areas deemed to be environmentally sensitive.
Mr Wells has explained, 'No investment will be considered in areas classified as wilderness parks, wilderness zones, reference areas and remote and natural areas under the National Parks Act of 1975.'
Supporters of the new arrangements have also noted that strict guidelines will be applied before any private development will be approved in those areas where it may take place.
Mr Wells has stated, 'Any investment will be subject to rigorous environmental controls and will need approval from the Environment Minister before it can proceed.'
Ryan Smith, Victoria's Minister for the Environment and Climate Change, has stated, 'The guidelines follow the release of an independent report by the Victorian Competition and Efficiency Commission which recommended "sensible and sensitive developments in national parks" as a measure to unlock Victorian tourism...
The guidelines...will provide strict environmental protections as part of a comprehensive approvals process.
Proposals for major new tourism projects will require a detailed environmental management plan supported by an independent environmental risk assessment and auditing of the plan.
There must also be proper community consultation and projects will be asked to generate a net public benefit for the community use of the park.'

Arguments against private development in national parks
1. The new development plans are motivated by profit
It has been claimed that the new development provisions are putting an emphasis on profit generation ahead of the purposes for which the parks were originally established.
The Victorian National Parks Association has stated, 'The primary role of national parks is the conservation of nature on behalf of all Victorians. Our parks were not created to end up as building sites for hotels and large-scale infrastructure that can only be used by a privileged few who can afford it.'
The conservation group, Friends of the Box-Ironbark Forests, have similarly stated, 'Worldwide experience shows it is the investors who benefit most from private developments in parks, not the majority of park visitors and certainly not the parks themselves.'
The group further notes, ''The government asserts without evidence that private developments would contribute to the management of our parks, but international and national examples show they actually skew resources away from much-needed conservation management...
For good reason, less than 1% of the 20,000 national parks worldwide have any significant tourism infrastructure within them. And most of these developments pre-date park establishment or are on pre-existing enclaves of private land.'
The Friends of the Box-Ironbark Forests conclude, 'National parks and other reserves have been created to look after some 300 different habitat types in Victoria, and the tens of thousands of native species they support.
Rather than acting as a real estate agent for parks, the government should take its role as guardian and steward of our national parks seriously.'

2. Private development in national parks will harm Victoria's remaining natural areas
The Victorian National Parks Association has noted that 'Victoria has cleared far more of its natural areas than any other state in Australia'. The Association has further stated, 'National parks and conservation reserves make up approximately 18% of the land in Victoria, and are a refuge for plants and animals in a state with relatively little intact native habitat left.'
The Association concludes, '[This] makes it even more important to be vigilant in protecting our remaining natural areas.'
Referring to the proposed development within the Point Nepean National Park, Blairgowrie resident, Des Smith, stated, during a visit to Point Nepean, 'We get inundated with idiots here every summer; we don't want more of them. The whole point of a national park is to escape people, not [to be] dodging hotels and latte sippers.'
The Victorian National Parks Association has also noted, 'Exposing our parks to tourism development could lead to irreversible damage to some of our most precious natural areas and undermine the integrity of our magnificent system of parks and reserves.'
Referring again to the proposed development within the Point Nepean National Park, Frankston resident, Michael Jackson, has stated, 'All we're doing is going back to the Kennett era. Once the developers have it, it's lost forever.'
Under the new development provisions, land lease terms are being extended from a maximum of 20 years to 99 years. This has raised concerns among many that the new developments will permanently alienate areas that were intended to be undeveloped, in order to preserve flora, fauna and conservation values.
It has also been argued that increasing development in national parks will heighten the fire risk.
Dr Kevin Tolhurst, an expert witness at the Royal Commission into the Black Saturday bushfires, has stated, 'The issue we have with people going to national parks is that these people are often from out of town, from other countries, and they aren't really well prepared for bushfires. And so a lot of onus then goes back onto the park management to protect and defend them...'
Dr Tolhurst concluded, 'If you have commercial enterprises in a national park there's major vested interests from outside parties invested in that area - so it's very hard to move them out.
Campers, walkers, you can close the park - but if you've got facilities in there worth millions of dollars, it's a much harder decision for governments and agencies to evacuate the area... the facilities will still be there and that will put a lot of pressure on the fire authorities to protect them - and that's what we saw in the 2003 and 2007 fires...'
Dr Tolhurst has also argued that expensive accommodation facilities within national parks will impede the burn-offs necessary to help reduce the fire risk. He states, 'We need to come to a clear decision as to why we have national parks, and how much we expect to be able to develop those areas to improve our economic return... Primarily they are there to protect the natural values of the areas...'

3. The guidelines surrounding private development in Victoria's national parks are inadequate
It has been claimed that the guidelines supposed to protect the integrity of Victoria's national parks are insufficient.
These guidelines are titled 'Tourism Investment Opportunities of Significance in National Parks: Guidelines'. Critics of the guidelines claim that this is reflective of their emphasis - the intention is to facilitate private investment rather than protect the parks and the conservation values they are supposed to represent. The introduction to the guidelines states their intention as to 'boost eco-tourism in Victoria...enabl[ing] us to better compete with similar attractions in Australia and overseas and...provid[ing] people the opportunity to experience, appreciate and care for their natural environment.'
Victorian National Parks Association executive director, Matt Ruchel, has complained of the guidelines' lack of rigour, describing them as 'another step on the path of putting "For Sale" signs on national parks.'
The conservation group, Friends of the Box-Ironbark Forests, has noted, 'The guidelines have a number of vague principles, and outline a five-stage approval process, but the provisions for community consultation are weak...
Alarmingly, it is not until development of a full proposal that a detailed environmental management plan will be required, leaving no opportunity for community comment on this critical aspect.'

4. National parks are currently being enjoyed by large numbers of people
It has been claimed that the suggestion that private development is needed to make Victoria's national parks available to large numbers of visitors is false. Opponents of private development within the parks claim that these special places are already much visited.
In 2008, the Victorian government released a report titled 'Victoria's Nature based tourism strategy 2008-12' which included the information that the state's national parks received 28.6 million visitors in the 2004-5 financial year - more than any other Australian state. The environmental group, Friends of the Box-Ironbark Forests, has stated that this is 'a figure which puts paid to the idea that parks "lock out" people.'
Thus, it has been argued that private development to provide better facilities is not needed to ensure that large numbers of Victorians have the opportunity to visit the state's national parks.
Relatedly it has been suggested that not only are Victoria's national parks well frequented, but that private development could actually discourage many potential tourists, especially eco-tourists, from visiting the parks. These tourists are seeking to enjoy an unspoiled environment. They are likely to reject locations that boast substantial development as this is not the simple, environment-based experience they are seeking.
The immediate commercial response to the new relaxed provisions has caused concern among conservationists. A coalition of councils in Victoria's south-west has already received proposals for high-end accommodation - offering about 50 to 100 beds - and luxury recreational facilities such as golf courses and restaurants within the parks.
The Victorian National Parks Association has stated, 'National parks are already good for tourism. We are in danger of "killing the goose that lays the golden egg" if we overdevelop them. Emphasis should be placed on encouraging tourism on private land, not within parks...
We already have large tourism developments such as the Alpine resorts outside national parks. Many of the 'tourism' experiences can be facilitated by improved eco-tourism services such as tours rather than new large-scale infrastructure.'
Similarly, the environmental group, Friends of the Box-Ironbark Forests, has noted, that even such tours should be appropriate and sensitively managed in order to satisfy eco-tourists.
It has stated, 'Many "high yield" customers are looking for something quite modest-like engagement with local culture and people, and a sense of place. This is the very thing that packaged, expensive tours can insulate people from.'

5. Good facilities for visitors are already being supplied near Victoria's national parks
It has been claimed that visitors to Victoria's national parks are appropriately catered for and can readily access accommodation and have their other needs met.
The environmental group Friends of the Box-Ironbark Forests has noted, 'Most of our parks already have ample accommodation, restaurants etc within a few kilometres of the park boundary.'
It is argued that where additional facilities are needed they should be supplied in areas adjacent to the parks, not within the parks themselves. This claim has also been made by the Friends of the Box-Ironbark Forests, 'And wherever more services are needed, there is plenty of opportunity to allow for sensitive world-beating ecotourism accommodation on private land adjacent to our parks.'
The need to limit substantial development to areas outside the national parks has been stressed by the Victorian National Parks Association. The Association has stated that there has been 'a long standing position that private investment into any new large scale facility, particularly accommodation other than adaptive re-use of existing infrastructure, should be sited outside the park.'
The Association has further stated, 'There is a lot of tourism potential on private land adjacent to our national parks that allows for certainty of investment, particularly in and around regional towns. Opening up parks will damage the viability of these businesses.'

Further implications
The need to balance potentially conflicting objectives has long been a feature of Victoria's national park management goals and the strategies intended to give them effect.
As early as 1991, the then state government noted that it had developed 'three major strategies - the Conservation Strategy, the Economic Strategy and the Social Justice Strategy - to help achieve the interrelated major goals of environmental conservation, economic development and social justice.' That is, the government was seeking to retain the conservation values of Victoria's national parks in line with their role in preserving unique flora and fauna and environmentally and culturally significant landscapes. The government was also seeking to achieve some economic advantage to the state through the exploitation of its national parks and, finally, it was seeking to achieve a social justice outcome by facilitating access to these parks for as wide-ranging a group of Victorians as possible.
In the twenty-two years since this statement was made the competing objectives have not altered and the challenge has remained to strike a balance between them.
The guidelines under which private development will now be allowed in Victoria's national parks refer to the need to demonstrate 'a net public benefit for the community use of the park'. The problem becomes determining what 'a net public benefit' is. Does the provision of top-end accommodation, a restaurant or a golf course constitute 'a net public benefit'? Certainly there would be members of the public who would benefit from such facilities. However, does their enjoyment of the park come at the cost of those who believe that the very purpose of a national park is to provide visitors with a less commercialised experience? There are those who have argued that certain types of land use are not compatible and thus that if one element is allowed it will be at the expense of another.
Dr Kevin Tolhurst, an expert witness at the Royal Commission into the Black Saturday bushfires, has stated, 'We need to come to a clear decision as to why we have national parks, and how much we expect to be able to develop those areas to improve our economic return...'
It would appear that the current Victorian government has made a decision that gives greater importance than has previously been the case to gaining an economic return from the state's parks.
This change of emphasis is in line with the Victorian government's attempts to allow cattle to graze in the Alpine National Park and to grant prospectors' licences within the parks. It can also be seen as in accord with the government's decision to extend the Victorian duck season to three months and to give provisional licences to young shooters and to foreign national tourists who have not passed a duck recognition test.
There are those who argue that all these developments represent a desire to exploit the state's environmental resources for economic advantage.
It will be interesting to see whether this change in emphasis is endorsed at the next state election. If it is not, some of the changes may prove difficult to undo.
Concern has been expressed that the developments allowed under the new regulations will have irreversible effects on Victoria's national parks, impacting on their unspoilt nature. Of particular concern is the fact that those private individuals or corporations that win approval to develop accommodation or other facilities within the parks will be granted 99 year leases on the areas they develop.

Newspaper items used in the compilation of this issue outline
AGE, September 2, 2012, page 4, analysis (photo) by Wilkins and Tomazin, `Mind the gap: park tourism plan sparks green backlash'.
http://www.theage.com.au/environment/conservation/mind-the-gap-park-tourism-plan-sparks-green-backlash-20120901-257id.html

AGE, April 3, 2013, page 8, news item by R Willingham, `Activist Baillieu horrified as "sharks circle" Nepean park'.
http://www.theage.com.au/environment/activist-baillieu-horrified-as-sharks-circle-nepean-park-20130402-2h56x.html

AGE, April 14, 2013, page 5, news item by F Tomazin, `Height fears for Point Nepean plan'.
http://www.theage.com.au/victoria/height-fears-for-point-nepean-plan-20130413-2hsjo.html