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Martin 2020. Public Report: Archaeological Field Survey of Climbing Areas, Grampians (Gariwerd) National Park Page 1 of 69

ARCHAEOLOGICAL FIELD SURVEY OF CLIMBING AREAS

Grampians (Gariwerd) National Park

Public Report November 2020


AV Aboriginal Victoria

AHA Aboriginal Heritage Act 2006

CHMP Cultural Heritage Management Plan

RAP Registered Aboriginal Party

NOI Notice of Intent

BGLCAC Barengi Gadjin Land Council Aboriginal Corporation

EMAC Eastern Maar Aboriginal Corporation

GMTOAC Gunditj Mirring Traditional Owners Aboriginal Corporation

MPL Martang Pty Ltd

PV Parks Victoria

GPT Grampians Peaks Trail

OHS Occupational Health and Safety

LDAD Low Density Artefact Scatter

All coordinates are in GDA 94 MGA Zone 54

All images of Aboriginal people in this report are used with permission.

Please note that this document may contain references to deceased Aboriginal people and use directly quoted historical documents containing language that may be considered offensive in a modern context.

Copyright © State of Victoria, Parks Victoria 2020

Published on parks.vic.gov.au

This publication may be of assistance to you but Parks Victoria and its employees do not guarantee that the publication is without flaw of any kind or is wholly appropriate for your particular purposes and therefore disclaims all liability for any error, loss or other consequence which may arise from you relying on any information in this publication.

Contact us if you need this information in an accessible format such as large print. Please phone 13 1963 or email

[email protected]

This document can also be found in PDF and Word formats on the Engage Vic website: engage.vic.gov.au

Front cover image (Figure 1): Billawin (Southern Victoria Range) aspect: north towards Red Rocks

https://www.parks.vic.gov.au/mailto:[email protected]://engage.vic.gov.au/


Table of Contents

1. Assessment of Climbing Areas within and outside Special Protection Areas ........................................................................... 6

1.1 Assessment Aims and Methodology .................................................... 6

1.1.1 Traditional Owners .................................................................. 7

1.1.2 Notifications ............................................................................ 8

1.1.3 Aim of Field Survey .................................................................. 8

1.2 The Assessment Areas .......................................................................... 9

1.2.1 Aboriginal Cultural Heritage within the Grampians National Park ....................................................... 11

1.2.2 Selection of Survey Locations ................................................ 13

1.2.3 Constraints; Area Surveyed and Ground Surface Visibility .................................................................... 13

1.3 Rediscovered Aboriginal places .......................................................... 14

1.4 Discussion ........................................................................................... 15

1.4.1 Legal Requirements at Aboriginal Places .............................. 16

1.5 Results ................................................................................................ 18

1.5.1 Aboriginal Cultural Heritage .................................................. 18

1.5.2 Observed Compliance Issues within Climbing Areas ............. 20

2. Recommendations ..................................................................................... 47

2.1 General Recommendations ................................................................ 47

2.2 Where Aboriginal Places are Rediscovered........................................ 48

2.3 Where no Aboriginal places are Rediscovered .................................. 48

3. References ................................................................................................ 49

4. Appendix ................................................................................................... 55


Figures: Figure 1: Billawin (Southern Victoria Range) aspect: north towards Red Rocks ................. Error! Bookmark not defined.

Figure 2: Pre DStretch image – RGB – The Promised Land registered Aboriginal place................................................. 13

Figure 3: Post DStretch – CRGB – The Promised Land registered Aboriginal place ....................................................... 13

Figure 8: Cairns marking informal access trail - Forrest Rock ....................................................................................... 25

Figure 9: Heavily eroded informal access trail - below Taipan Wall.............................................................................. 25

Figure 10: Informal access trail leading to Mt Pleasant climbing area .......................................................................... 25

Figure 11: Rubbish on informal access trail - Chatauqua Peak – 400m off Chatauqua Peak Loop Walk ........................ 25

Figure 12: Pink flagging tape used to mark informal trail - The Upper Goon ................................................................ 26

Figure 13: Cairn indicating start of climbing area (bolts pictured) - Western Wall ....................................................... 26

Figure 14: Cairn and informal access trail - Rosea Right Wing ...................................................................................... 26

Figure 15: Informal access trail - Mountain Lion - erosion registered Aboriginal place ................................................ 26

Figure 16: Small cairn marking start of informal access trail - Gilhams's Crag .............................................................. 27

Figure 17: Worn informal access trail at ‘unpopular’ climbing location - River Road Rocks .......................................... 27

Figure 18: Quarry with chalk impact – Gunn Buttress registered Aboriginal place ....................................................... 30

Figure 19: Spurt Wall – quarry with chalk impact registered Aboriginal place ............................................................. 30

Figure 20: Chalk impacts within rockshelter - Green Olive Cave................................................................................... 30

Figure 21: The Snake Pit – extensive chalk visible ........................................................................................................ 30

Figure 22: Quarry with chalk impact - The Snake Pit registered Aboriginal place ........................................................ 30

Figure 23: Chalk impact of quarry - Gunn Buttress ....................................................................................................... 30

Figure 24: Destroyed vegetation - The Upper Goon .................................................................................................... 33

Figure 25: Compromised vegetation along the cliff line - The Ravine ........................................................................... 33

Figure 26: Dead Xanthorrhoea on informal access trail. Main Cliff – Mt Rosea ............................................................ 33

Figure 27: Faeces in association with an uncatalogued Bouldering location - Sundial Peak ......................................... 33

Figure 28: Sandinista Cliffs – context of base of cliff .................................................................................................... 33

Figure 29: Sandinista Cliffs – no vegetation – registered Aboriginal place (width 5-6m) ............................................. 33

Figure 30: ‘Climb’ marker cut into tree - Giant's Staircase............................................................................................ 34

Figure 31: Marker cut into tree burnt in 2013 - informal access trail – Upper Wuzelgummage .................................... 34

Figure 32: Sawn vegetation – The Upper Goon ............................................................................................................ 34

Figure 33: Pedestrian impacts (known LTO area) below Lookout Point Wall ............................................................... 34

Figure 34: The Peking Face - Destroyed vegetation on informal access trail (within last 12 months) –

Remote and Natural Area ............................................................................................................................ 34

Figure 35: The Peking Face - Destroyed vegetation on informal access trail (within last 12 months) –

Remote and Natural Area ............................................................................................................................ 34

Figure 36: Denuded surface at base of Taipan Wall substantial pedestrian impact (width 4m) registered

Aboriginal place ........................................................................................................................................... 35

Figure 37: Denuded vegetation - The Bundaleer .......................................................................................................... 35

Figure 38: Informal access trail showing vegetation impacts - Epsilon Wall ................................................................. 35

Figure 39: Possible Cinnamon Fungus case – Valley of the Giants ................................................................................ 35

Figure 40: Intact vegetation - between the Citadel and Van Diemen's Land ................................................................ 35

Figure 41: Faint graffiti – Mackay’s Peak ...................................................................................................................... 37

Figure 42: Graffiti, enhanced with D-Stretch – Mackay’s Peak ..................................................................................... 37

Figure 43: Fake rock art made with goat poo – The Chimney Pots .............................................................................. 37

Figure 44: Historic graffiti - Socrophiliac Buttress ........................................................................................................ 37

Figure 45: Historic graffiti treatment – Venus Baths .................................................................................................... 37

Figure 46: Quarry (Aboriginal Place) and fake rock art in chalk – Red Wall .................................................................. 37

Figure 47: Climbing route marker – angle grinder - Bundaleer ..................................................................................... 38

Figure 48: Fake rock art - Bellerophon Wall ................................................................................................................. 38

Figure 49: Graffiti – elevated position - Andersens ...................................................................................................... 39

Figure 50: Graffiti – detail of Figure 47- Andersens ...................................................................................................... 39

file:///E:/PV%20CURRENT/PVM0161%20-%20Gariwerd%20document/Redesigned_Public%20Report%20of%20Archaeological%20Field%20Survey%20of%20Climbing%20Areas%20Grampians%20Gariwerd%20National%20Park.docx%23_Toc55566552file:///E:/PV%20CURRENT/PVM0161%20-%20Gariwerd%20document/Redesigned_Public%20Report%20of%20Archaeological%20Field%20Survey%20of%20Climbing%20Areas%20Grampians%20Gariwerd%20National%20Park.docx%23_Toc55566552


Figure 51: Graffiti - Giant’s Staircase ............................................................................................................................ 39

Figure 52: Historic graffiti – West Flank ....................................................................................................................... 39

Figure 53: Painted climbing markers – Mt Rosea ......................................................................................................... 39

Figure 54: Painted climbing marker - The Peking Face ................................................................................................. 39

Figure 55: Fire - Taipan Wall ........................................................................................................................................ 40

Figure 56: Fire - Bundaleer ........................................................................................................................................... 40

Figure 57: Fire - Bundaleer ........................................................................................................................................... 41

Figure 58: Fire – Bundaleer – beneath The Ogive ......................................................................................................... 41

Figure 59: Interpretative panel at Bundaleer trail head ............................................................................................... 43

Figure 60: Ineffective mitigation at registered Aboriginal place ................................................................................... 43

Figure 61: Damage to registered Aboriginal place - Facebook Post: 29 January 2020 - Bundaleer................................ 43

Figure 62: Bouldering impacts – Valley of the Giants ................................................................................................... 45

Figure 63: Bouldering impact - Trackside Boulders...................................................................................................... 45

Figure 64: Bouldering impacts – Venus Baths .............................................................................................................. 45

Figure 65: Bouldering impacts - Trackside Boulders ..................................................................................................... 45

Figure 66: Impacts at uncatalogued bouldering location - Sundial Peak....................................................................... 46

Figure 67: Bouldering impacts - Sundial Peak .............................................................................................................. 46

Figure 68: Bouldering impacts at Andersens ................................................................................................................ 46

Figure 69: Bouldering impacts - Valley of the Giants .................................................................................................... 46

Tables Table 1: Traditional Owner Corporations ....................................................................................................................... 7

Table 2: Types of Harm - Aboriginal Cultural Heritage ................................................................................................. 17

Table 3: Survey Areas .................................................................................................................................................. 57

Table 4: Showing Results of Transect; Ground Surface Visibility and Effective Survey Coverage .................................. 58

Table 5: Assessment and Participation Schedule ......................................................................................................... 59

Table 6: Aboriginal Places Rediscovered as Part of this Archaeological Field Survey .................................................... 60

Table 7: Observed Compliance Issues within Climbing Areas with Rediscovered Aboriginal Cultural Heritage ............ 62

Table 8: Climbing Areas Assessed ................................................................................................................................ 63

Table 9: Protected Areas .............................................................................................................................................. 64

Table 10: Registered Aboriginal Places within Grampians (Gariwerd) National Park April 2019 .................................. 68

Maps Map 1: Assessment Areas ............................................................................................................................................ 10

file:///E:/PV%20CURRENT/PVM0161%20-%20Gariwerd%20document/Redesigned_Public%20Report%20of%20Archaeological%20Field%20Survey%20of%20Climbing%20Areas%20Grampians%20Gariwerd%20National%20Park.docx%23_Toc55566592file:///E:/PV%20CURRENT/PVM0161%20-%20Gariwerd%20document/Redesigned_Public%20Report%20of%20Archaeological%20Field%20Survey%20of%20Climbing%20Areas%20Grampians%20Gariwerd%20National%20Park.docx%23_Toc55566592


1. Assessment of Climbing Areas within and outside Special Protection Areas

This report presents the results of an Aboriginal cultural heritage desktop and archaeological survey completed within the Grampians National Park (the Park), which sits inside the Greater Gariwerd Cultural Landscape (Gariwerd Landscape).

This assessment was undertaken by Parks Victoria with the principal objectives of collating existing data on Aboriginal cultural heritage located within the park, identifying previously unrecorded values and documenting any visitor impact that may have occurred on those values. The report identifies opportunities for mitigating any potential impacts to Aboriginal cultural heritage and areas of archaeological sensitivity.

The full version of this report, Archaeological Field Survey of Climbing Areas, Grampians (Gariwerd) National Park, can be found via the Victorian Aboriginal Heritage Register. This version was created for the public and contains the same information as the full report, however with sensitive Aboriginal cultural information removed.

The field survey was supervised by Andrew Martin of Parks Victoria’s Managing Country Directorate between June 2019 and February 2020.

1.1 Assessment Aims and Methodology

Ordinarily, a field survey to ascertain what impact may occur to Aboriginal cultural heritage is conducted before any activity associated with the proposal occurs. In this instance the assessment is in the context of an established activity for which the impact or assessment of Aboriginal cultural heritage values was not previously considered; its impact only recently recognised.

The overall aim of the project was to better understand the impacts of park use on Aboriginal cultural heritage values at rock climbing areas in the Grampians National Park. This was done by:

• completing a comprehensive desktop assessment to understand past land use, research into Aboriginal cultural heritage and survey effort in the park

• creating a predictive model to understand where different types of Aboriginal cultural heritage (artefact scatter, rock art, scarred trees, etc) are likely to exist within the park

• completing a field survey to identify previously unrecorded Aboriginal heritage values and document any visitor impacts on those and recorded values

• assessing whether observed impacts are in contravention of park regulations and require a management response


1.1.1 Traditional Owners

There is currently no Registered Aboriginal Party (RAP) appointed under the Aboriginal Heritage Act 2006 (Vic) (AHA) or RAP applicants for the assessment area discussed in this survey.

There is also no RAP appointed for the Gariwerd Landscape as a whole. However, some parts of the Gariwerd Landscape fall within the boundaries of three RAPs: the Black Range State Park and an area along the north‐west edge of the Gariwerd Landscape lie within the Barengi Gadjin Land Council Aboriginal Corporation (BGLCAC) RAP area; land adjoining the south-western border of the Grampians National Park are part of the Gunditj Mirring Traditional Owners Aboriginal Corporation (GMTOAC) RAP area and a narrow band of land inside the south‐eastern border of the Gariwerd Landscape and adjoining the Grampians National Park lies within the Eastern Maar Aboriginal Corporation (EMAC) RAP area (appointed 6 February 2020) as shown in Map 1.

Initially, the recognised interests of Martang Pty Ltd (MPL) extended into the assessment area. Under section 156(2)(a) of the AHA, registration was revoked on 1 August 2019 and this group’s participation was not included in the assessments after this point in time.

There are no native title holders for the Grampians National Park under the Native Title Act 1993 (Cwlth) and we are not aware of any negotiations currently underway under the Traditional Owner Settlement Act 2010 (Vic.).

An Indigenous Land Use Agreement (ILUA) was signed between the State of Victoria and three Traditional Owner corporations – BGLCAC, EMAC and GMTOAC. Collectively, these corporations represent the Gariwerd Traditional Owners. The ILUA means that any future acts by the State of Victoria (from the agreement date of 3/12/2018) will not extinguish the rights to native title by the claimants.

BGLCAC, EMAC and GMTOAC are project partners for this survey and this relationship is maintained through the Greater Gariwerd Landscape Management Plan Project Steering Committee (PSC).

Table 1: Traditional Owner Corporations

Group Name ICUN Contact Information

Barengi Gadjin Land Council Aboriginal Corporation

4395 https://www.aboriginalheritagecouncil.vic.gov.au/barengi-gadjin-land-council-aboriginal-corporation

Eastern Maar Aboriginal Corporation

7585 https://www.aboriginalheritagecouncil.vic.gov.au/eastern-maar-aboriginal-corporation

Gunditj Mirring Traditional Owners Aboriginal Corporation

4672 https://www.aboriginalheritagecouncil.vic.gov.au/gunditj-mirring-traditional-owners-aboriginal-corporation

https://www.aboriginalheritagecouncil.vic.gov.au/barengi-gadjin-land-council-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/barengi-gadjin-land-council-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/barengi-gadjin-land-council-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/barengi-gadjin-land-council-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/eastern-maar-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/eastern-maar-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/eastern-maar-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/eastern-maar-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/gunditj-mirring-traditional-owners-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/gunditj-mirring-traditional-owners-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/gunditj-mirring-traditional-owners-aboriginal-corporationhttps://www.aboriginalheritagecouncil.vic.gov.au/gunditj-mirring-traditional-owners-aboriginal-corporation


1.1.2 Notifications

Surveying for Aboriginal cultural heritage is regulated by section 34A of the Aboriginal Heritage Act 2006 (AHA). As there is no registered Aboriginal party, Parks Victoria is the occupier for the purpose of this survey.

As required, a notice in the approved form was submitted and the Secretary, Department of Premier and Cabinet provided confirmation on 23 May 2019 that the delegate had received a Notice of Intent to carry out a survey for land parcels at the following locations: Bundaleer [1/PP2204; 19F/PP3822]; Halls Gap [19/PP3822;25A/PP2208; 41E/PP2208]; Hollow Mountain [92A\PP2955]; Mt Stapylton Campground [98G/PP2955; 2/LP931198; 98E/PP2955; 72\PP3767; 98D/PP2955; 98C/PP2955] and Hollow Mountain South [92A\PP2955]. The received survey notification has been allocated the AV Survey Number: 41.

Relevant documentation, any Aboriginal place records, photographs, maps and plans relating to the survey for Aboriginal cultural heritage, were submitted to the Victorian Aboriginal Heritage Register between November 2019 and May 2020.

1.1.3 Aim of Field Survey

A key component of this project was to complete an archaeological survey consistent with the requirements of a “standard assessment” pursuant to regulation 59 of the Aboriginal Heritage Regulations 2018 (Vic.).

The aim of the field survey was to:

• Assess the integrity of the landforms;

• Identify any disturbance to the landforms;

• Identify any surface evidence of Aboriginal cultural heritage; and

• Identify areas of potential sensitivity for Aboriginal cultural heritage including the presence of caves, cave entrances or rock shelters.

The field survey was undertaken in accordance with proper archaeological practice and will generally locate evidence of surface sites but will not necessarily find buried archaeological deposits. The methodology for the standard assessment is informed by the results of the desktop assessment and the site prediction model.

The standard assessment involved a visual inspection of the activity areas following a judgement sample model outlined in Burke and Smith (2004). This methodology included the review of existing climbing and bouldering guidebooks and websites to determine the optimal access routes to and between each climbing area so that team members could:

• Walk into and inspect informal access trails

• Identify locations where climbing equipment (bolts and hangers etc) could be observed

• Assess any vertical surface at ground height to check for rock art or quarries

• Observe ground surface exposures and areas of erosion which could reveal eroding Aboriginal cultural heritage

• Record the general percentage (%) of ground surface visibility

• Record evidence of surface disturbance (Table 4)

• Examine all mature trees encountered within the activity areas for the presence of scars, though locating a scarred tree within a climbing area, according to the desktop, would be anomalous.

• Examine each climbing location for the presence of caves, cave entrances or rock shelters.


Where Aboriginal cultural heritage was located during the field survey, the following was undertaken:

• Completion of a standard recording form.

• Photography of the general location of the site and cultural material. All Photographs “geotagged’ with GPS position in the image’s EXIF metadata.

• Drawing a plan of the site in relation to landmarks.

• Recording the location of the Aboriginal cultural material with a differential GPS to sub-metre positional accuracy.

• Digital collection of non-spatial attributes required by Aboriginal Victoria’s Standards for Recording Aboriginal Places 2008.

1.2 The Assessment Areas

The assessment area is the Grampians National Park, Victoria (Map 1). This is situated approximately 260 km west of the Melbourne CBD. Most of the assessment area is located on cuesta landscapes and the terrain ranges from a gentle slope to much steeper sections. The elevation of the assessment area ranges from approximately 360 meters Above Sea Level (ASL) at Mount Zero to 1167 meters ASL at Mount William. The ground surface is diverse and includes exposed rock platforms, rock/gravel scree and shallow soil deposits.


Map 1: Assessment Areas


1.2.1 Aboriginal Cultural Heritage within the Grampians National Park

Before the survey commenced, the Grampians National Park contained over 237 registered Aboriginal places, all of which have cultural heritage significance in accordance with Aboriginal tradition and, for the most part, also have archaeological significance which is of importance when considering the objectives of the National Parks Act 1975 and the Parks Victoria Act 2018.

A robust and contemporary summary of Aboriginal archaeology of Gariwerd is provided in Professor David Frankel’s Between the Murray and the sea: Aboriginal Archaeology in south-eastern Australia (2017) which examines the complex interplay between social, cultural and physical landscapes. Frankel’s selection of sites is but a smattering of those present, many of which are associated with rock art of the Northern Grampians. It provides no direct observations of the survey areas, but tangentially at Mugadgadjin in the Black Range State Park suggests that there is something distinct occurring in relation to materials imported into the Grampians, where at this site at least 12 different stone sources have been used to create stone tools retrieved from a secure archaeological context. Frankel’s observations are that imported materials occur more frequently in the northern parts of the Grampians and Black Range, which appear more connected to exploited source locations to the north within the Mallee, a hint at a complex web of human behaviour that governs exchange, strategy and movement within this landscape.

Parks Victoria’s Aboriginal Cultural Heritage Identification Guide (2019) contains further information and images about Aboriginal cultural heritage found throughout Victoria.

https://www.parks.vic.gov.au/-/media/project/pv/main/parks/documents/managing-country-together/aboriginal-heritage-identification-guide.pdf

1.2.1.1 Artefact Scatter and Low Density Artefact Distribution

Artefact scatter allows for the description and recording of both lithic (stone) and non-lithic cultural artefacts (brick, tin, ceramics, glass, faunal remains) found on the ground surface. Glass and ceramic materials that have been flaked are recorded as Lithic Artefacts, while those that have not been flaked are recorded as non-lithic material. Surface scatters of flaked stone artefacts may be represented by one or a range of raw material types and the artefacts themselves should be identifiable using technological and typological characteristics associated with manufacture.

A Low Density Artefact Distribution (LDAD) is the occurrence of stone artefacts at densities of up to 10 counted artefacts in any area of approximately 10m x 10m, or 100m2, including within a single test pit of ≤1m2. This density distinction has been adopted to facilitate a streamlined recording process for lower densities of artefacts. As a distribution, the LDAD does not have an extent but each individual artefact is accorded an area of Aboriginal cultural heritage sensitivity. Therefore, there is no assumption made that additional artefacts might not be found between those included in a registration. Unlike Artefact Scatters, LDADs do not require there to be an assumption of association between artefacts recorded in the same LDAD registration and do not need to be grouped or separated by landform or material type. In the Grampians National Park there have been 104 artefact scatters and 32 LDADs previously recorded within most geological units; indicating that within the Grampians National Park there are locally desirable raw resources for the manufacture of stone tools which suggests that artefact scatters and LDADs will very likely be rediscovered within the survey areas.

1.2.1.2 Quarry

A quarry can be defined as the ‘location of an exploited stone source’ (Hiscock and Mitchell 1993: 23). A quarry may reflect minimal exploitation of the source or form part of a broad range of complex intersecting activities. The most easily recognised aspect of a quarry is where materials have already been extracted from the source material and there is a visible colour contrast between newly exposed surfaces and weathered surfaces. The early stages of a reductive process take place to manufacture portable items (Hiscock and Mitchell 1993: 11-12). Activities that take place in a quarry include procurement or extraction, transport and

https://www.parks.vic.gov.au/-/media/project/pv/main/parks/documents/managing-country-together/aboriginal-heritage-identification-guide.pdfhttps://www.parks.vic.gov.au/-/media/project/pv/main/parks/documents/managing-country-together/aboriginal-heritage-identification-guide.pdf


reduction (Hiscock and Mitchell 1993: 12). Quarry Places should provide evidence for one or all of these activities, though some quarries may be hard to identify where loose rock is collected from the surface and is transported out of the area without modification. Extraction activities involving exposed or buried bedrock, exposed boulders, clasts or cobbles, transport activities involving the movement of materials to various locations within the Place, and reduction areas where manufacturing takes place to reduce the extracted material and process it to form transportable objects may all take place within the site. Frequently quarried stone types include greenstone, silcrete, quartz, quartzite, basalt, chert and sandstone. Other quarried resources include ochre and mineral pigments. In the Grampians National Park, twenty-one quarries have been previously recorded within the Wartook Sandstone, Kalymna Falls Sandstone, Serra Sandstone and Major Mitchell Sandstone geological units; indicating that within the Grampians National Park there are locations of desirable raw resources which suggests that additional quarries, possibly with in-situ instances of reduction will be rediscovered.

1.2.1.3 Scarred Tree

Scars on trees are created when the sapwood is exposed on the trunk or branch following the removal of bark for producing items such as canoes, shields, bowls or building materials. Other scar types include toe-holds, where notches were cut into the bark to make the tree easier to climb, or resource extraction holes. Although there are no known surviving carved or decorated trees in Victoria, there are historical accounts of trees being carved or decorated at several locations in Victoria. There have been ten Aboriginal scarred trees previously recorded within the Grampians National Park; for the most part these are away from areas with cliffs, bluffs and caves, and generally associated with either waterbodies or waterways where the candidate trees are located; which suggests that Aboriginal scarred trees will be unlikely to be rediscovered within the survey areas.

1.2.1.4 Shell Midden

Shell middens consist of either stratified or scattered shell resulting from human activities. Be aware that there are natural processes that can produce shell deposits. Cultural deposits can be distinguished from natural shell deposits by the range of shell species represented, the context of the shell, and by the presence of other material, most often charcoal, but also chipped stone artefacts, burnt stone, animal bone, human burials and other cultural material. In the Grampians National Park there have been two Aboriginal shell middens previously recorded within the Grampians National Park away from areas with cliff, bluffs and caves.

1.2.1.5 Rock Art

Rock art is images on rock surfaces that can be produced either by the adding of pigment (pictograms: painting, drawing, stencilling, printing, etc) to the rock surface, or by breaking through or extracting the rock surface (petroglyphs: pecking, pounding, abrading, scratching etc). Pictograms are generally found in locations sheltered from the weather such as rock shelters or caves, while petroglyphs generally occur on open rock pavements or on the walls of caves. In the Grampians National Park there have been 104 examples of rock art previously recorded within the Wartook Sandstone, Kalymna Falls Sandstone, Serra Sandstone and Major Mitchell Sandstone geological units; indicating that within the Grampians National Park there are desirable locations including rock shelters, caves, overhangs that provide for suitable for preservation of motifs and panels. The presence of ochre quarries of various colours in the immediate vicinity of the National Park also suggests it is likely that additional rock art could be rediscovered. Aiding this rediscovery is the use of digital augmentation to detect faded panels of rock art using a digital tool known D-Stretch, which is based on the decorrelation stretch algorithm. The decorrelation stretch is a process that is used to enhance (stretch) the colour differences found in a colour image the algorithm was originally developed by NASA’s Jet Propulsion Laboratory to process ASTER satellite multispectral sensor data (Campbell 1996; Alley 1996) and now applied to the rediscovery and analysis of rock art (Harman 2005; Harman 2014; Quesada and Harman 2019; Gunn et al. 2014; González et al. 2019).


Figure 1: Pre DStretch image – RGB – The Promised Land registered Aboriginal place

Figure 2: Post DStretch – CRGB – The Promised Land registered Aboriginal place

1.2.2 Selection of Survey Locations

Of those listed on the Crag website, there are 279 climbing areas within the Grampians mapped with an extent of less than 300,000 square metres. Within these 279 areas there are 8300+ catalogued climbing routes. Prior to this survey there were six (6) registered Aboriginal places consisting of eight (8) components spatially intersected within five (5) mapped climbing areas. Further spatial analysis shows that a further fourteen (14) registered Aboriginal places are spatially located within 50 metres of the 279 climbing areas, including seven (7) registered Aboriginal places containing rock art. The large number of climbing areas in this location required consideration of how to identify criteria by which to prioritise survey locations. It was determined that to select areas, there needed to be both substantial numbers of climbing routes catalogued and a level of visitation that indicated popularity. In addition, several climbing areas were nominated by Licensed Tour Operators (LTOs) and local Parks Victoria staff. A suitable proxy for visitation was determined to be the number of ‘ticks’ a climbing route received on the Crag website as an indicator of its popularity. Through this survey, 125 climbing areas were selected for assessment with approximately 4300+ individual climbing routes or 56% of the catalogued climbing routes in the Grampians. Names of climbing areas assessed are tabulated in Table 8. Sets of climbing areas were organised into 12 assessment areas as shown in Map 1 and Table 3.

1.2.3 Constraints; Area Surveyed and Ground Surface Visibility

The field survey was undertaken by Parks Victoria between October 2019 and February 2020. They were assisted by representatives from the three Traditional Owner organisations that claim traditional ownership over the Grampians. Survey accessibility was reasonable, accounting for the difficult terrain and requirement to venture off formal access tracks over the seven field rotations.

Given the remoteness of the activity and the ruggedness of the landscape, care was taken in the planning to minimise the effort required to access these areas by ensuring route planning was undertaken in the most efficient way possible. On the whole, the terrain did not constrain the conduct of the standard assessment. The exceptions to this were two climbing areas, Ground Control Caves and Cut Lunch Walls at Gunigalg (Mt


Stapylton), which were not attempted by the survey team as the access descriptions in the published guide books posed an unacceptable risk to the safety of the team. In several locations such as Left Side at Mt Rosea, there was very dense vegetation which prevented access to the ground surface but did not prohibit movement thought the area or identification of climbing related activity. GNSS signal shadow in this terrain is a real challenge; however this was adequately resolved to less than 1m accuracy by postprocessing field data with correction data from the GPSnet CORs Network.

1.3 Rediscovered Aboriginal places

This section of the report has been omitted from the public version of the report. The full archaeological report of these assessments contains sensitive information about Aboriginal cultural heritage now stored on the Victorian Aboriginal Heritage Register (VAHR). Access to the full reports may be sought via the VAHR.

Further Information: https://www.aboriginalvictoria.vic.gov.au/victorian-aboriginal-heritage-register

https://secure.vicpos.com.au/https://www.aboriginalvictoria.vic.gov.au/victorian-aboriginal-heritage-register


1.4 Discussion

There is sometimes a perception that a “site” or Aboriginal place is limited spatially to exact dimensions of a component, being the singular rock art motif or quarry section, and that harm can only occur this exact “site”. This is contrary Section 5 of the AHA which states:

(1) For the purposes of this Act, an Aboriginal place is an area in Victoria or the coastal waters of Victoria that is of cultural heritage significance to Aboriginal people generally or of a particular community or group of Aboriginal people in Victoria .

(2) For the purposes of subsection (1), "area" includes any one or more of the following—

(a) an area of land;

(b) an expanse of water;

(c) a natural feature, formation or landscape;

(d) an archaeological site, feature or deposit;

(e) the area immediately surrounding any thing referred to in paragraphs (c) and (d), to the extent that it cannot be separated from the thing without diminishing or destroying the cultural heritage significance attached to the thing by Aboriginal people;

(f) land set aside for the purpose of enabling Aboriginal ancestral remains to be re-interred or otherwise deposited on a permanent basis;

(g) a building or structure.

The extent of a “site” is thus inclusive of the area sympathetic to the situation in which Aboriginal cultural heritage is rediscovered and is respectful of the natural features and formations that are contributory to the archaeological site formation processes that accumulated and preserved the Aboriginal place and its associated cultural heritage significance is rediscovered. Protecting the full site extent is necessary for preservation of the Aboriginal place.

"cultural heritage significance" includes—

(a) archaeological, anthropological, contemporary, historical, scientific, social or spiritual significance; and

(b) significance in accordance with Aboriginal tradition;

"Aboriginal tradition" means—

(a) the body of traditions, knowledge, observances, customs and beliefs of Aboriginal people generally or of a particular community or group of Aboriginal people; and

(b) any such traditions, knowledge, observances, customs or beliefs relating to particular persons, areas, objects or relationships;

Any ‘harm’ to the site applies not only to a component of the Aboriginal place but the same protections within the Act apply to the whole of the Aboriginal place also. Hence, the existence of one component of Aboriginal heritage can trigger the exclusion of an activity that may cause harm anywhere within its context or setting. When formulating the boundaries of Aboriginal places, the most relevant consideration of the context of a place is the density of Aboriginal archaeological materials or the landform. When considering the context of a place in the Grampians, where rock shelters and boulders are common, the situation of these

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features become a key consideration when determining the nature, extent and cultural heritage significance of the Aboriginal place. When there are areas of quarrying in a rock shelter or on a wall, then the extent of the Aboriginal place reflected in the description on the Victorian Aboriginal Heritage Register is inclusive of the whole shelter or defined with future management or protection requirements in mind.

1.4.1 Legal Requirements at Aboriginal Places

Rock climbing and abseiling are popular pursuits within the Grampians National Park. Over time it has emerged that these and other recreational activities are having both cumulative and observable adverse impacts on both Aboriginal cultural heritage and vegetation within the park.

All climbers, as individuals, and Parks Victoria, as a body corporate, have a legal obligation to comply with the requirements of the AHA. Parks Victoria as a land manager also maintains partnerships with Traditional Owner groups, who are recognised as the primary guardians, keepers and knowledge holders of Aboriginal cultural heritage, and has a responsibility to recognise, protect and conserve Aboriginal cultural heritage in Victoria in ways that are based on respect for Aboriginal knowledge and cultural and traditional practices. The AHA provides blanket legal protection for all Aboriginal cultural heritage in the State of Victoria. Aboriginal cultural heritage is an ‘umbrella’ concept consisting of three main sub-categories: Aboriginal places, Aboriginal objects and Ancestral remains (being the whole or part of the bodily remains of an Aboriginal person).

Both climbers and Parks Victoria have a duty to act in a certain way, including not harming Aboriginal cultural heritage and complying with requirements of the AHA. If Parks Victoria has failed to act to prevent harm occurring, then the omission of action could constitute an offence under section 27 of the AHA, especially since there are lawful mechanisms within the AHA that permit ‘harm’ to happen. ‘Harm’ is a term defined by s. 4 of the AHA:

"harm", in relation to Aboriginal cultural heritage includes to damage, deface, desecrate, destroy, disturb, injure or interfere with.

These individual sub terms are not defined in the AHA so they are interpreted to have their common dictionary meanings as shown in Table 2.

Meeting requirements to avoid ‘harm’ in the Grampians National Park is multi-dimensional, with the large numbers of catalogued climbing locations which lack an accurate locational or spatial information; the size and nature of the park; the lack of previous assessments for Aboriginal cultural heritage in the park; and consequently the incomplete cultural heritage assessment coverage in areas known to be climbing areas. The core management questions are whether rock climbing can occur within the Grampians National Park as a permitted use, and what is the required process for this to occur in a way that protects to the existing environment and the Aboriginal cultural heritage present and complements the legal protection afforded Aboriginal cultural heritage.

The consequences of harm to any Aboriginal place under the management of Parks Victoria could have significant legal, reputational and financial consequences. Where harm occurs it undermines trust and erodes the partnerships with Traditional Owner communities that Parks Victoria needs to complete the duties of a land manager. The erosion of trust is not geographically limited to one group but can be observed to have implications beyond group boundaries. Incidences of harm to Aboriginal places locally are noticed regionally and beyond, and if the harm is allowed to continue without resolution, can do further damage to Parks Victoria’s reputation as an effective land manager. Protecting Aboriginal cultural heritage is therefore not only a legal requirement under the AHA, but also an organisational commitment and a required to maintain a social licence to operate.

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Table 2: Types of Harm - Aboriginal Cultural Heritage

damage inflict physical harm on (something) so as to impair its value, usefulness, or normal function

deface spoil the surface or appearance of (something), for example by drawing or writing on it

desecrate treat (a sacred place or thing) with violent disrespect

destroy end the existence of (something) by damaging or attacking it

disturb disturb with the normal arrangement or functioning of (something)

injure harm or impair [weaken or lessen] (something)

interfere prevent something from operating or existing in the correct way

Within the context of the AHA, the protection and preservation of Aboriginal cultural heritage (values) are an object of the National Parks Act 1975 where Aboriginal places part of their cultural heritage significance is considered archaeological: s.4(a)(ii) for the protection and preservation of indigenous flora and fauna and of features of scenic or archaeological, ecological, geological, historic or other scientific interest in those parks. The objectives of the 2013 Regulations of the National Parks Act 1975 allow Parks Victoria:

1(a) to provide for the management and control of parks and to regulate or prohibit certain conduct in relation to parks, so as to promote—

(i) the preservation and protection of parks, flora, fauna and indigenous fish in parks and various other features of, and facilities in, parks;

(ii) the protection of designated water supply catchment areas and other water supply catchment areas;

(iii) the safety, enjoyment, recreation and education of visitors to parks;

Similarly, interfering with archaeological or historical remains prohibited and is a possible offence per regulation 54 of the National Parks Regulations 2013

A person must not excavate, remove, damage, deface, or otherwise interfere with any archaeological or historical remains or relics in a park. Penalty: 20 penalty units.

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1.5 Results

125 climbing areas and a total of 163 kilometres of tracks both to and in-between climbing areas were inspected during the survey. In addition to the five previously registered places located within these areas, 42 Aboriginal places were rediscovered within 26 climbing areas (see Table 7).

Further to the results, and of importance to future land management decision-making, is that:

• 30 Aboriginal Places were rediscovered in locations within current set asides

• 12 Aboriginal Places were rediscovered outside set asides

Of these 42 Aboriginal places, there were 74 individual components, noting that an Aboriginal place may include more than one component (see Table 6).

• Quarries: 39

• Stone Feature (rock shelters 6 and rock wells 6)

• Earth Feature – (Hearth): 1

• Artefact Scatters: 12

• LDAD: 10

The survey rediscovered up to nine components within a single Aboriginal place, and up to five Aboriginal places located within a single climbing area. The result of this survey has yielded an increase of 16% in the number of Aboriginal places and 26% in the number of individual components recorded within the Grampians National Park. All Aboriginal places rediscovered or inspected have been, or are in the process of being, added to the Victorian Aboriginal Heritage Register, as required by s.24 of the Act.

Additionally, 8 Aboriginal places already on the register before 1 April 2019 were opportunistically inspected as part of the survey, due to their proximity to climbing areas.

1.5.1 Aboriginal Cultural Heritage

Based on the results discussed above, the following additional information has been added to the Victorian Aboriginal Heritage Register to describe the archaeological signature of the geographic region:

• Previously, Aboriginal cultural heritage places were predominantly isolated stone artefacts and small artefact scatters with occasional scarred trees, quarries and rock shelters with associated cultural deposits and/or art. However, the specific geology of the Northern Grampians provides suitable raw materials for stone artefact manufacturing, and quarries dominate the visible evidence in this locality.

• Quarries have been observed most frequently within the Serra Sandstone and Kalymna Falls Sandstone geological units and within the ecological vegetation class (EVC) boundaries called ‘Rocky Outcrop Herbland’. These locations can be at significant elevations above the natural land surface and away from water sources.

• Quarries for stone tool manufacture are yet to be identified within the central Grampians but are expected to occur as the geology is favourable.

• Quarries for stone tool manufacture are found in concentrated locations in the Billawin Range, with considerable potential for further rediscoveries in this area.

• The overwhelming number of rediscoveries occurred in the Northern Grampians and most of these sites were rediscovered quarries and their associated reduction areas recorded as artefact scatters, per current recording standards.


• There is considerable scope for research into the presence of quarried material in the landscape surrounding Gariwerd; of note is research into the distribution of the distinctive source materials located at Spurt Wall, Red Wall, The Plaza Strip and Summerday Valley.

• The rediscovery of an ochre source at Bundaleer also lends itself to an avenue of further research, especially x-ray fluorescence analysis (XRF) to establish if there is any link between this source material and known and rediscovered rock art sites with red motifs in Gariwerd.

• Rock art is located within the Rocky Outcrop Herbland or the Heathy Dry Forest EVC; typically, these locations are close to drainage lines and ephemeral waterways. The geological intersection is rather diverse, with rock art found predominantly in the Serra Sandstone (60%+) with minor frequencies in the Wartook Sandstone, Moora Moora Sandstone and Kalymna Falls Sandstone.

• It is expected that future rock art discoveries will be faded motifs in locations with less secure preservation contexts; discovery will be facilitated by use of digital decorrelation stretch analysis.

• Other types of Aboriginal places are predominantly located on sandy soil on flat or gently undulating ground in open forest or woodland.

• Most types of Aboriginal places are generally situated near sources of fresh water with pools and natural springs above headwater locations. Larger artefact scatters are found in the vicinity of waterbodies.

• Aboriginal places in climbing areas are generally situated within a zone 5m in height from the ground surface; quarries are typically linear features that follow the natural alignment of the source material.

• Aboriginal places in the rockier and steeper areas are expected to comprise isolated artefacts, quarries and their production areas, and possible sub surface deposits in rock shelters which may or may not have rock art.

• Stone artefact assemblages and quarries are dominated by silicified sandstone and quartzite but may include minor amounts of quartz, silcrete and rarely volcanic glass. The proportion of silicified sandstone and quartzite tends to be higher in sites in the Northern Grampians, however this is not exclusive as there are known silicified sandstone and quartzite quarries in the south-western Victoria Range.

• This survey merely scratches the surface. There is a co-locational relationship based on geological presence that has brought the current usage into conflict with the past usage.

• The Northern Grampians portion of this cultural landscape is now better understood. It is a location with embedded Aboriginal places names and tangible evidence of extensive yet selective resource exploitation.

• At Halls Gap, tangible evidence of the Aboriginal cultural heritage can be identified even after 170 years of European agriculture, forestry and tourism.

• The southern Victoria Range is a yet to be understood part of the story of the Western Grampians; the cultural heritage values of this area will need to be investigated in the future.

Whilst there have been numerous investigations over decades, these apply in area to only a fraction of a percentage of the park area, and largely include assessments for proposed assets (now built) or post-fire impacts constrained to burnt assets. From this survey it is observed that the Grampians National Park has not been systematically surveyed for Aboriginal cultural heritage. Notwithstanding the large number of Aboriginal places with rock art, most of which have been identified by reports from the public, known information has been mostly gathered through a few localised surveys or in the course of routine management of known Aboriginal cultural heritage rather than activities aimed at identifying Aboriginal cultural heritage. As such, the currently known distribution of places within the park is the result of a biased sampling history that is aligned with a euro-centric prioritisation of rock art over other values. It therefore


cannot be assumed to give a full understanding of Aboriginal land-use within the Grampians National Park, nor of what types of places occur in what types of settings within the park. It is notable that there is an absence of any substantive archaeological sub-surface testing of the park. The richness and diversity of resources within the landscape highlights the potential for the widespread presence of significant archaeological sites throughout the park that may also be rediscovered within unassessed climbing areas as part of future assessments. This means that, while it is known that Gariwerd was an attractive area for Aboriginal people to live, it is nevertheless not possible from the existing archaeological literature to predict the location of Aboriginal archaeology without further field assessment.

1.5.2 Observed Compliance Issues within Climbing Areas

In recent years, the impact of rock climbing in the Grampians National Park has increased and contemporary rock climbing activities, such as bouldering, have emerged, creating risk to environmental and cultural values. The survey has demonstrated that the activity has a direct and observable impact signature that poses a risk to Aboriginal places and would likely constitute harm under the AHA - specifically interference, defacement and damage. If this risk is not managed appropriately, Parks Victoria and the recreational users of the park risk becoming the subject of compliance and enforcement scrutiny from the regulator.

Many of the impacts of climbing are interconnected, being both core and ancillary to the activity of climbing. The act of exploring and establishing new climbing routes necessitates leaving designated paths, removing vegetation, installing bolts for safety, and leading others to newly identified crags. From a small initial impact, a more defined path will emerge and erode over time as an area’s popularity increases. The trails require waypoints leading to the creation of cairns which in turn facilitate easier access into the climbing area. Incrementally new routes are established, more bolts are installed, the impacts accumulate and the cycle repeats. Each step in this is conceivably an offence under the current regulations.

Of the 125 climbing areas inspected during this project, 26 had Aboriginal cultural values present. In 10 of the 42 Aboriginal places rediscovered, one or more forms of harm, as defined by the AHA were identified, and a further six Aboriginal places exhibited impacts characterised as non-compliance with the National Parks Regulations 2013, as shown in Table 7, including:

• Bolting (5 Aboriginal places)

• Informal Access Trails (8 Aboriginal places)

• Chalking (7 Aboriginal places)

• Fire (2 Aboriginal places)

• Rock breakage (1 Aboriginal places)

• Vegetation removal (10 Aboriginal places)

• Graffiti (2 Aboriginal places)

• Erosion (10 Aboriginal places)

• Bouldering (2 Aboriginal places)

The next section describes penalties for a range of offences that may occur in this context. In 2020-2021 a penalty unit is $165.22. The value of a penalty unit is set annually by the Department of Treasury and Finance and is updated on 1 July each year.


1.5.2.1 Bolting

National Parks Regulations 2013 - Regulation 62: Hazardous behaviour in caves prohibited

(1) A person must not smoke in any cave in a park.

Penalty: 10 penalty units.

(2) A person must not perform any act in a cave in a park that may be hazardous to any person or to the preservation of the cave.

Penalty: 10 penalty units

Regulation 53: Interfering with rocks or similar natural objects prohibited

(1) A person must not damage, deface, remove or otherwise interfere with any rock or similar natural object in a park.


Aboriginal Heritage Act 2006 - Section 28: A person must not harm Aboriginal cultural heritage. A person must not do an act that harms or is likely to harm Aboriginal cultural heritage.

Penalty: In the case of a natural person, 60 penalty units. In the case of a body corporate, 300 penalty units.

Note: Section 187A applies to an offence against this section.

There is no comprehensive and verified dataset of bolts in climbing routes, and no known instances where bolts have been installed or managed officially by Parks Victoria. However, assuming between five and seven bolts per climbing route in the Grampians National Park (and accounting for variation in climbing styles), it is estimated that there is possibly at least 10,000 to 15,000 bolts in catalogued climbs. Installation of bolts is widespread practice, except for bouldering locations. Bolts of various types with and without hangers were observed at each climbing location visited, frequently in the ceiling of larger caves or rock shelters that are now registered Aboriginal places. Bundaleer is an interesting case study, with its long history of tourist visitation due to the rock shelters and views. This Aboriginal place has been extensively damaged by tourism with pedestrians walking through and camping within the rock shelters over more than one hundred years. It is notable here that impacts from tourist recreation are distinguishable from impacts that are specifically climber-related, such as the observable modern, abandoned, vintage and broken climbing bolts that perforate the walls and ceilings. This indicates that climbing has, in a cumulative fashion and over the long term since the late 1950s, damaged the cultural heritage of the Aboriginal place (see Error! Reference source not found.).

The initial threat posed by bolting is observed to be the placement of the first bolt, which generally occurs within the first five metres of the ground surface. This roughly correlates with the zone in which any physical evidence of tangible Aboriginal cultural heritage will likely be faded or visible on the ground surface. The installation of bolts is a possible offence against the National Parks Regulations because interfering with rocks or similar natural objects is prohibited, as is doing any act that is hazardous to the preservation of the cave.

Furthermore, at Bundaleer there are observed impacts of the direct impacts of climbing-related activity within a known, signposted Aboriginal place. Whilst measures were put in place to mitigate harm caused by trampling and access, these appear to have been ineffective and harm to the place has continued. A further instance of observed harm included recent dislodgement of portions of the rock shelter, the responsibility for which was claimed on social media by a climber in January 2020 (see Figure 56). This may be an offence, as under the AHA, the whole setting of an Aboriginal places is protected from harm, not just the discrete


archaeological ‘components’ of the place. A 36(1)(f) permit to rehabilitate this Aboriginal place will be required to remove the failed protection measures and reduce the risk of further interference with the Aboriginal place. Generally, a 36(1)(c) permit to harm an Aboriginal place will be required to install or remove of bolts within the extent of the registered Aboriginal place.

Another observed instance of bolt impact within an Aboriginal place is a bolt and hanger located on a ground level boulder within a rock shelter at Gilham's Crag. It is possible this bolt and hanger is a belay, however its function is unclear. Aboriginal cultural heritage is readily identifiable here, with a quarry and possible subsurface deposit in a rock shelter (see Error! Reference source not found.). Authorisation would also be required to remove the bolt within this Aboriginal place.

VAHR ID Aboriginal place Name Climbing Area

Awaiting Registration Gilham’s Crag 5 Gilham’s Crag

7324-0746 Gariwerd North 20 The Plaza Strip

7323-0305 Bundaleer Complex Bundaleer

7324-0742 Gariwerd North 16 Gunn Buttress

7324-0743 Gariwerd North 17 Amnesty Wall


1.5.2.2 Informal Access Trails

National Parks Regulations 2013 - Regulation 64: Crossing area by way other than an identified track prohibited

A person must not, in a park, leave a track identified for walking or riding if Parks Victoria has erected a sign or notice on that track requiring persons to remain on the track, unless the person is authorised to do so by a permit issued under these Regulations.


Regulation 53: Interfering with rocks or similar natural objects prohibited



Aboriginal Heritage Act 2006 - Section 28: A person must not harm Aboriginal cultural heritage. A person must not do an act that harms or is likely to harm Aboriginal cultural heritage.



An ‘informal access trail’ in this report refers to an unsanctioned route created by park visitors to access parts of the park that lie off-track. Informal access trails are not official or identified walking tracks which have been planned, appropriately authorised and maintained by Parks Victoria. In considering the origin of these trails, it was noted that they were found to only lead to climbing areas and their presence is documented within climbing and bouldering guide books. They are therefore understood to be climbing-related. The trails are subtle and without the published references they would be difficult to detect. The incremental way these trails have developed has led to a complex network of paths that can be found throughout the park. In general, informal markers, a series of small cairns of stones, flagging tape or cuts made to a tree with a sharp implement like an axe or knife have been used to create a directional indicator. The construction of cairns within any National Park is an offence.

A typical trail is no more than 40 cm in width. They typically lead, via the most efficient route, to the base of a cliff and then branch in either direction along the cliff base to various starting points for individual climbs which are also marked. It is estimated that approximately 50% (81 km) of the distance walked in this survey followed informal access trails. The conduct of the survey was quickened by the presence of these informal access trails, which have interconnected climbing areas so that it is possible to loop through several climbing areas without having to retrace the route. A notable example is the connection between the Citadel and Sandinista Cliffs, making it possible to circumnavigate between Mt Zero Carpark and Hollow Mountain Carpark via the south-eastern flank of Gunigalg (Mt Stapylton). This network of informal access trails has come at considerable environmental cost with observed segmentation of the landscape, trampling of vegetation, compaction of soil, introduction of weed species and possible incursion of cinnamon fungus. The trails provide easier access for both humans and pests into the wilder portions of the National Park. Rubbish, toilet paper and faeces were often observed near informal access trails, sometimes hundreds of metres from official walking trails.


The ad hoc creation of these trails facilitates access into areas that have not been adequately formalised and will continue to contribute to erosion and disturbance of the surface soil profile. This threat is of most concern where there is bouldering and in climbing areas of medium to high popularity. In every instance where a climbing area is not adjacent to an official walking path, there was found to be an informal access trail. Damage to the land surface in informal access trails with even modest volumes of pedestrian foot traffic is exacerbated by slope of any significant degree.

Aboriginal Places are severely compromised directly and indirectly by informal access trails. Direct impacts through erosion were observed at Bundaleer, Mountain Lion, Sandinista Cliffs, Amnesty Walls and The Dungeon, and contact with quarry reduction floors was observed at The Plaza Strip, Gilhams Crag and Taipan Wall/Spurt Wall. At these places, there is a clear indication that damage and disturbance is caused by the continuation of access along the present alignments. Erosion and physical modification to the land surface associated with these access trails has contributed to the rediscovery of these Aboriginal places on the eroded surface. There is a real risk that, if protection measures are not put in place, the remaining soil profile will continue to erode, exposing further Aboriginal cultural heritage and compromising the integrity of the location. Erosion is also a considerable issue on formal tracks at The Watchtower climbing area, which is used by LTOs

Observations made through this survey indicate that the impact of informal access trails on natural and cultural values informal access appears to be greater in magnitude than the impact of climbing itself. Of concern is that the 20km of these informal access trails are located within areas defined under the National Parks Act 1975 as Remote and Natural Areas. Ordinarily, the establishment and maintenance of infrastructure, including walking paths, is heavily restricted in these areas and require ministerial consent. Rationalising and remediating the network of informal access trails would be required to reduce fragmentation of the environment and its current and potential future impacts.



7324-0730 Gunigalg Quarry 5 Taipan Wall/Spurt Wall



7324-0744 Gariwerd North 18 Sandinista Cliffs

7323-0742 Gariwerd North 16 Gunn Buttress


7323-0748 Gariwerd North 22 The Dungeon

7423-0811 Halls Gap LDAD Frenchman’s Beret

Awaiting Registration Mountain Lion LDAD Mountain Lion


Figure 3: Cairns marking informal access trail - Forrest Rock

Figure 4: Heavily eroded informal access trail - below Taipan Wall

Figure 5: Informal access trail leading to Mt Pleasant climbing area

Figure 6: Rubbish on informal access trail - Chatauqua Peak – 400m off Chatauqua Peak Loop Walk


Figure 7: Pink flagging tape used to mark informal trail - The Upper Goon

Figure 8: Cairn indicating start of climbing area (bolts pictured) - Western Wall

Figure 9: Cairn and informal access trail - Rosea Right Wing

Figure 10: Informal access trail - Mountain Lion - erosion registered Aboriginal place


Figure 11: Small cairn marking start of informal access trail - Gilhams's Crag

Figure 12: Worn informal access trail at ‘unpopular’ climbing location - River Road Rocks


1.5.2.3 Chalk

National Parks Regulations 2013 - Regulation 53: Interfering with rocks or similar natural objects prohibited



Regulation 54: A person must not excavate, remove, damage, deface, or otherwise interfere with any archaeological or historical remains or relics in a park.


Aboriginal Heritage Act 2006 - Section 28:

A person must not harm Aboriginal cultural heritage A person must not do an act that harms or is likely to harm Aboriginal cultural heritage.



The impact of chalking is in some cases more damaging than graffiti because it is inherently difficult to remove and visually obscures and stains the surface of the cliff face. This is recognised in the Summerday Valley LTO permit, where use of chalk is not permitted. Further, the use of steel brushes to clean chalk from climbing areas poses a considerable risk to Aboriginal places due to its potential to abrade and damage rock art. At The Promised Land climbing area, climbing chalk associated with an undocumented bouldering location was found within 5 metres of a rock art panel. Discouraging use of chalk will go some way to address this kind of impact. Climbing typically only occurs where bolts are present and, as such, the installation of bolts in the rock face above and in proximity to Aboriginal places leads to increased utilisation of the immediate vicinity and ancillary access areas. At The Snake Pit, a three-metre long quarry was observed to have impacts of chalk and further examples of impact were noted at Gunn Buttress and Spurt Wall. This is possibly evidence of a section 28 offence under the AHA, not committed by one single identifiable individual but by many over time. A further offence may be observed through the interference and defacement of archaeological or historical remains prohibited under regulation 54 of the National Parks Regulations 2013.

As the land manager, Parks Victoria is responsible not only for addressing and remediating harm but taking action to proactively prevent harm. Failing to prevent harm through omission is an offence under the AHA which is why Parks Victoria must act on these known areas.

Aboriginal cultural heritage must also be preserved in line with the objectives of the National Parks Act 1975 or lawful authorisation to allow the harm to continue must be sought. Within registered Aboriginal places the removal of chalk is not permissible without an approved permit, as it is considered interference with the Aboriginal place.

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7324-0730 Gunigalg Quarry 5 Taipan Wall/Spurt Wall

7324-0739 Gariwerd North 13 Tunnel Cliff

Awaiting Registration Wubjub-guyun 6 Hollow Mountain Cave



Figure 13: Quarry with chalk impact – Gunn Buttress registered Aboriginal place

Figure 14: Spurt Wall – quarry with chalk impact registered Aboriginal place

Figure 15: Chalk impacts within rockshelter - Green Olive Cave

Figure 16: The Snake Pit – extensive chalk visible

Figure 18: Chalk impact of quarry - Gunn Buttress

Figure 17: Quarry with chalk impact - The Snake Pit registered Aboriginal place


1.5.2.4 Vegetation Removal

National Parks Regulations 2013 - Regulation 48: The removal of vegetation is prohibited:

A person must not cut, fell, pick, remove, take, damage or destroy any vegetation in a park.



A person must not harm Aboriginal cultural heritage. A person must not do an act that harms or is likely to harm Aboriginal cultural heritage.



While this survey was not primarily concerned with impacts to vegetation, instances of damage to vegetation were logged and areas that had been denuded were noted within the assessment areas. Notable examples included climbing areas such as Sandinista Cliff, Amnesty Wall, The Dungeon,Taipan Wall, Valley of the Giants, Andersens, Venus Baths, The Peking Face - Bundaleer, The Upper Goon, Upper Wurzlegummage Wall - Wall of Fools, Barc Cliff, Citadel; Lookout Point Wall, Sundial Peak and others.

In these climbing areas, large areas of bare earth were observed which would ordinarily be covered with considerable surface vegetation. Figure 35: Intact vegetation - between the Citadel and Van Diemen's Land shows an example of intact vegetation comprising fern species at the intersection of the ground surface and a cliff base that contrasts with the dryer neighbouring rocky outcrop herb land/ rocky outcrop shrubland EVCs. This ecological community type appears to be disproportionately impacted by rock-climbing-related activity.

Sandinista Cliffs is a unique case as it is both a popular climbing area and location that receives considerable traffic from the Hollow Mountain walking trail; this is the only location where the source of impact was noted as being shared by multiple park users. A clear example of the impact of climbing-specific activity was noted at the Ravine climbing area where vegetation had been trampled to such an extent that an area extending between two and three metre from the cliff was bare and had compacted soil (see Figure 20). This compares to the level of impact observed at intensively used LTO locations such as Barc Cliff, Wall of Fools, Bundaleer and Lookout Point Wall (see Figure 28 and Figure 32).

Sawn trees and vegetation were also observed along informal access trails where the heaviest impact was found at the interface between the cliff and the ground surface. Typically, the larger areas were observed below individual climbing routes that interconnected with informal access trails along cliff lines in either direction. Dead and dying Xanthorrhoea australis at the Valley of the Giants and at Main Cliff – Mt Rosea were noted as possible cases of Cinnamon Fungus (see Figure 21 and Figure 34). Two instances of markers cut into trees with sharp implements were located at Upper Wurzlegummage Wall (a square marker) and the Giants Staircase, Mt Rosea (the word ‘Climbs’). These are both presumed to have been marked after the 2014 bushfires, given the burnt trunk of each tree and the proximity of the trees to each other (see Figure 25 and Figure 26).


VAHR ID Aboriginal place Name Climbing area

7324-0730 Gunigalg Quarry 5 Taipan Wall

7324-0748 Gariwerd North 22 The Dungeon


7423-0697 PLANTATION 1 The Promised Land

7324-0721 Gariwerd North 3 Barc Cliff


7324-0723 Gariwerd North 5 Walls of Fools

7324-0742 Gariwerd North 16 Andersens

7324-0744 Gariwerd North 18 Sandinista Cliffs

7323-0751 Gariwerd North 8 Flying Blind


Figure 19: Destroyed vegetation - The Upper Goon

Figure 20: Compromised vegetation along the cliff line - The Ravine

Figure 21: Dead Xanthorrhoea on informal access trail. Main Cliff – Mt Rosea

Figure 22: Faeces in association with an uncatalogued Bouldering location - Sundial Peak

Figure 23: Sandinista Cliffs – context of base of cliff

Figure 24: Sandinista Cliffs – no vegetation – registered Aboriginal place (width 5-6m)


Figure 25: ‘Climb’ marker cut into tree - Giant's Staircase

Figure 26: Marker cut into tree burnt in 2013 - informal access trail – Upper Wuzelgummage

Figure 27: Sawn vegetation – The Upper Goon

Figure 28: Pedestrian impacts (known LTO area) below Lookout Point Wall

Figure 29: The Peking Face - Destroyed vegetation on informal access trail (within last 12 months) – Remote and Natural Area

Figure 30: The Peking Face - Destroyed vegetation on informal access trail (within last 12 months) – Remote and Natural Area


Figure 31: Denuded surface at base of Taipan Wall substantial pedestrian impact (width 4m) registered Aboriginal place

Figure 32: Denuded vegetation - The Bundaleer

Figure 33: Informal access trail showing vegetation impacts - Epsilon Wall

Figure 34: Possible Cinnamon Fungus case – Valley of the Giants

Figure 35: Intact vegetation - between the Citadel and Van Diemen's Land


1.5.2.5 Graffiti

National Parks Regulations 2013 - Regulation 53: Interfering with rocks or similar natural objects prohibited

A person must not damage, deface, remove or otherwise interfere with any rock or similar natural object in a park.



A person must not harm Aboriginal cultural heritage. A person must not do an act that harms or is l

archaeological field survey of climbing areas...martin 2020. public report: archaeological field...

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