Obstacles to the development and sustainability of the nature-based guiding industry in Australia

To whom it may concern,

Wildiaries has been working with Diverse Travel Australia developing a network of nature-based experiences and operators in Australia. As weʼve progressed, itʼs become increasingly obvious that there are some escalating regulatory problems. We would like to request consideration and support, to voice a concern and table solutions.

Onerous regulations are closing down aspiring small businesses and making it difficult for well-established operators to continue working in key areas of Australia. Weʼve experienced the loss of two out of four wildlife guides for Kakadu in the last year or so and all such guides in Central Australia. With many established business owners nearing retirement and youngsters quitting to work in the environmental consultancy sector, weʼre concerned the industry wonʼt survive to meet Tourism 2020 targets.

The positive news is that everyone within this important niche agrees that accreditation and permitting are both policies that can and should help secure better quality in the Australian market. Implementing some fairly simple solutions to the current problems is all that is needed (see Attachment 4).

Despite nature being a specialised niche, it is an important sector. Nature is a universal brand value with appeal across all countries and demographics. One associate of ours is the only specialist with Japanese guides. Last week, a major Indian nature-based operator visited and there is increasing demand from China and other new destinations.

Two thirds of all visitors to Australia partake in a nature-based activity. The companies we work with, will respond to the changing market place and with an increasing number of foreign travelers wanting an in-country point of contact, some of them are reporting their biggest seasons ever. The message is similar from other operators, at a time when overall visitor figures in some of the most popular Australian landscapes are down by up to 50%.

Nevertheless, there are some worrying hidden trends. Some businesses can no longer meet demand for visits to important landscapes of Australia e.g. Kakadu & the Red Centre. Increasingly, they have become effectively limited to one state and canʼt often casually employ reliable interstate guides theyʼve been using for years. The same guides can however, work for larger European and US companies, some of whom have negotiated exemption from regulations.

Australiaʼs best nature guides are hand-picked by the top ambassadors for nature travel and wildlife interest overseas - some are even used by David Attenboroughʼs documentary teams - but are becoming unavailable for home-grown Australian tour operators to use. Yet every year, more and more visitors to our shores are demanding the kind of unique and intimate travel experience are delivered by these businesses.

The financial constraints and limitations on Australian nature-based companies and emerging businesses have not been adequately considered before implementation of

Wildiaries 39 The Crescent, Belgrave Heights, Victoria 3160

Tel: +61 (0) 405 220 830 | e-mail: [email protected] | Skype simonmustoe

Responses from our associates

... the letter is fantastic! It clearly puts into words so many of the issues that have been troubling me and others for years

... those that put this together need to be congratulated on "getting it right"

Thank you. I would be honoured to have my name added to such a thoughtful submission.

... thanks for including me ... I couldnʼt agree more.

Thanks for the email and attachment, it is all very true...

mailto:[email protected]?subject=


regulations. There is not much financial flexibility (see Attachment 3) and there are peculiarities of the industry that need to be taken into account, if it is to thrive (Attachment 1).

Many businesses are losing out to overseas competitors by not being able to work Australia-wide. Plus, over the last few years, the pool of qualified guides around Australia has dropped substantially. The recent regulation changes are despite existing businesses having built an international reputation long before they came into force. This quote from one of our associates sums it up beautifully:

“In 1993 I was advised by the the Western Australian tourist commission representative that I was wasting my time setting up a nature-based tour company. We proved him wrong. Now, 20 years later, I am having to prove to them that I am qualified and even produce a business plan for something that helped shape the industry. It’s madness!”

Please note, the states have been very helpful when it comes to processing their own permits and our associates wholly support accreditation in principle. It is just that in their current form, the regulations are undermining potential and no-one appears to be in a position to address the main problems.

This is where the nature-based tourism industry is asking for urgent support. These are issues that donʼt just affect nature-based or wildlife guides. Our hope is that the information attached will be of use to the government and non-government sectors, in finding a way to reverse the current trends and that we may be able to help government and industry reach its targets and realise objectives for a more sustainable and better quality tourism experience.

Regards,

Simon Mustoe, WildiariesCc. Caroline Densley, Diverse Travel Australia

Endorsed by:

Sue Gregory, Sicklebill Safaris and Cassowary House (N. Qld)Alan Gillanders, Alanʼs Wildlife Tours (N. Qld)Carol Probets, Blue Mountains Birding (NSW)Denise Goodfellow, Denise Goodfellow Nature Guide (NT) Tonia Cochran, INALA Birding and Wildlife Tours (Tas)Peter Waanders, SA Birding (SA)George Swann, Kimberley Birdwatching (N. WA)Dave ʻChookʼ Crawford, Close Up Birding (N. Qld)Simon Clayton Birdrangers (N. NSW)Karen Garth EcoAdventures (Vic)Chris Doughty, Peregrine Bird Tours (Vic)

Encl.Attachment 1: What characterises nature-based tourism? Attachment 2: What characterises a great nature guide? Attachment 3: What are the financial impacts to small business of the current regulations?Attachment 4: Case examples of problems in the industry.Attachment 5: Simple solutions.





Attachment 1: What characterises nature-based tourism?Like any industry, nature-based tourism has its own financial and other endemic characteristics, that determine how it can operate within the broader market. This is a response to common suppositions about the industry. Understanding how it behaves puts us in better stead to address regulatory impacts and ultimately, to achieve objectives. Reading these responses will also help interpret the Attachments to this letter.

Supposition Response

If costs rise, operators should charge more.

The businesses are supplying guides for very small group sizes and it is generally agreed amongst operators that current prices are at a market maximum. The strong Australian dollar and high fuel prices are both key influences.

Nature-based operators are only a small ʻnicheʼ

We know already that nature is a huge brand value. Some of these ʻnicheʼ companies are experiencing unprecedented demand for services at a time when other areas of Australia are suffering decline. This is hardly surprising, when we know that nature-based tourism is growing by 20% p.a. worldwide, compared to 7% for other sectors and that there is always consistent demand for nature experiences. These companies may be small but they are also the best quality and most heavily sought-after. They appear to have the potential to grow faster than any other company during periods of economic hardship. Arguably, it is these companies that should be supported so that they can grow quick-enough to meet future demand. This is especially if we believe (as we do) that they are exactly the type of company we need to compete with countries like the US, South African and Canada.

Permit fees are only a small cost, whatʼs the problem?

Operators are not that concerned about permit fees as such. The cost is more in the administration. Note, it is not just about permits. Requirements for insurance, permits and accreditation are increasingly inter-dependent. Often it means having all or none of the above. As set out in Attachment 1, a well-established company cannot make enough money to afford to pay a part-time administrator, which would be needed to both manage clients and the paperwork necessary to maintain permits, accreditation and other requirements in numerous states. Itʼs already very difficult for small businesses to manage - they are subject to the same level of cost, reporting and control as much bigger companies, such as bus tours. In small companies, all the admin work is usually done by a director. There would be no way to increase income to cover additional staff, other than to increase tour group size but then these companies would not be providing the service their clients need.

Surely accreditation and permits are a good thing?

Absolutely. There is no disagreement. Operators have long been waiting for recognition of the fact that they are the highly qualified go to people. However, now that the regulations have arrived, the economic constraints are causing them to lose business to overseas companies (who are not accredited) and they canʼt compete with non-specialised large-group nature tours.






Casual or ʻpart-timeʼ operators arenʼt that important. They are unreliable and negatively affect the image of Australian tourism

This is an obvious concern and on face value, would seem to have merit. Why would the Australian tourism industry, wish to rely on part-time or casual guides? There are a number of very good reasons. Not least, because some of these guides go onto become fully-fledged tour operators. There is conceivably no way to start a guiding business without beginning part-time (see financials in Attachment 1). There are also few who really connect with nature and whose knowledge is infectious and compelling. There are even fewer who match this with the interpersonal skills and organisation needed to run a business. Our experience suggests that the type of person who chooses to do this, is unique and rare. The industry cannot afford to jump to rapid conclusions and potentially lose a critical support component for the whole industry. Itʼs also about the nature of the business. Australia is a very big country and when it comes to nature and wildlife, local knowledge is everything. Some of the best guides are local nature experts (conservationists, birdwatchers, consultants) and make themselves available as guides because they enjoy showing people nature, at an affordable price.

There are loads of people out there who can show people animals.

Whilst itʼs true that anyone with a basic knowledge can get by with most visitors, itʼs also important to understand your market and deliver what people want. We regularly hear examples of visitors who have expectations for guiding and are disappointed. Often this is because the guideʼs (or their employerʼs) own opinion of their knowledge exceeds reality. According to market research:

A customer who is unhappy is likely to talk about it to 8 to 16 people ... More than 90% of the people who are unhappy never go back and purchase anything from the company or brand they are unhappy with. The network of an average customer is estimated to be about 250 people. While it is important that you do the math for your own company, a 5% increase in retention rates could up the profit by 25% to 100%. http://www.mineful.com/blog/category/customer-engagement

Itʼs not hard to imagine that tourists looking for a unique and engaging experience associated with their interest, will have some existing knowledge. They may ask difficult questions and may in fact, be more knowledgeable about some things than the guide themselves. These are “experience seekers” and Tourism Australiaʼs own marketing describes them as people who:

... investigate holiday options thoroughly and as such are knowledgeable consumers ... are tertiary educated ...

They are also

... opinion leaders within their peer and social groups. So they are likely to talk positively and negatively about experiences. If only one in 16 tourists is an experience seeker and they become dissatisfied, this could be enough to stem growth in tourism potential. Since it is the ʻexperience seekerʻ market that Australian tourism is looking to as a key factor in future growth, we cannot afford to assume that anything less than a great nature guide is best.

Most people who want a guide wonʼt know if the guide makes a mistake

As revealed by the Tourism Australia research (above), experience seekers are usually very well informed. Many of our associates guide overseas academics and medics (there is a whole industry around alumni travel). They are already very knowledgeable and expect a lot from their guides, increasingly in very specialist areas of natural history, that sometimes require the casual employment of specific skills: people who may not have tour guided before. These customers would not go on a mass market tour and demand high quality guiding skills.



http://www.mineful.com/blog/category/customer-engagement







If there arenʼt enough nature guides, we can train more through existing accreditation

The fact is, most nature guides have been interested since they were children. We know promising guides who are just 17 years old who already have over 10 years of experience. Being a nature guide is something you choose to do because you were born with the interest. There is no way to train someone with this knowledge. Training should be focused on the supporting skills to be a great guide.

If they want more marketing, they should join a tourism authority

Membership of tourism authorities is often cited as a means to an end, when it comes to marketing. There is no doubt that when it comes to destination marketing, regional and local tourism authorities do an incredible job. Nature-based and wildlife guiding however, is a specific market (hence whatʼs contained in this table). For reasons similar to why regulations are failing to assist such operators, tourism authority action doesnʼt always help these specific small businesses. Needless to say, these same businesses have for a long time developed their own market which they understand better than anyone. There is a case to say that the authorities would gain from paying for their knowledge as well. If there was a way to get more mutual benefit, most companies would happily pay the annual fee to get involved.





ATTACHMENT 2: What characterises a great nature guide?

This has been put together using submissions by the guides who endorsed this letter.

A great nature guide is someone who:

• is COMPETENT in a variety of aspects of the surrounding environment including flora and fauna and preferably geology and other relevant topics;

• is genuinely PASSIONATE about natural history and with a spirit of learning that never ceases;

• can IDENTIFY birds, mammals and more obscure animals quickly and accurately;

• has an AUTHENTIC KNOWLEDGE of different places where specific things can be found and how best to see them (this is quite a skill, that is developed over years of personal development, skill and practice);

• can CONVERT people to an interest in nature, with a solid, yet infectious and inspiring personality, that makes experiences sustainable, fun and memorable yet carry a subtle and compelling conservation message;

• has the SAFETY and care of clients in mind at all times.

• themes their tours so the trip is an experience and the tour a story rather than a string of facts and figures;

• has the ability to pitch information at all levels (from school kids to professional biologists);

• is aware of clientsʼ needs e.g. when they are tired or hungry or uncomfortable with the pace of the tour, and will act accordingly;

• has the ability to put people at ease, or handle difficult situations in an efficient and discrete manner with minimal impact on the tour;

• clients want to be with, especially if the tour is long (sometimes 1 month or more at a time);

• has good business sense;

• Is respectful of local cultures and of the opinions of customers.

“It's a rare individual who can combine all these talents in a way that gives the client a great and truly memorable nature experience”





ATTACHMENT 3: What are the financial impacts to small business of the current regulations?

To understand how current regulations affect small business, we first have to model typical businesses and understand their annual cash flow and overheads. Since many of these businesses are quite small, itʼs a relatively simple process. Nature-based tourism and guiding can be divided into three sectors that represent the natural progression from a start-up business to a larger niche tourism operator.

1. Sole trader nature guides / start up enterprise.

These are characterised by single operators, often family businesses that only do wildlife guiding and are not producing their own tours. The operator may do part-time work or be a second income-earner for the family. Some guides are casual and do only occasional jobs, whilst others seek full-time guiding and a few have aspirations to build their business further. These businesses may or may not be registered for GST. Despite the apparent casual nature of these small businesses, they are important both as a bolt-hole for larger businesses seeking guides in remote areas and as the first step towards growing a bigger business.

2. Sole trader / incorporated company

These are the natural next step in establishing a guiding business. To bring in additional income and respond to demand from return clients, the operator may start to run tours, building in additional margins. The operator exceeds the threshold for GST but the business owner / director still does the majority of the guiding work themselves.

3. Business or incorporated travel company

If the operator wants to grow further, this may mean taking on an additional guide for day to day work or subcontracting others to respond to demand for tours. The operator may begin to provide services to other companies and increase the number of tours and itineraries. The overheads associated with this step-up in business are considerable, mostly due to the need to employ staff.

Sole trader / startupSole trader / startup Sole trader / small businessSole trader / small business CompanyCompanyITEM $ % $ % $ %INCOME $29,750.00 $98,800.00 $196,000.00

OVERHEADS

Insurance $2,500.00 8.40% $2,500.00 2.53% $2,500.00 1.28%

Permits/vehicle/accreditation

$1,282.80 4.31% $2,322.80 2.35% $2,727.80 1.39%

Marketing $0.00 0.00% $1,000.00 1.01% $3,500.00 1.79%

Office overheads

$0.00 0.00% $12,000.00 12.15% $12,000.00 6.12%

Vehicle costs $11,550.00 38.82% $17,160.00 17.37% $23,100.00 11.79%

Staff $0.00 0.00% $0.00 0.00% $129,500.00 66.07%

GST $0.00 0.00% $9,880.00 10.00% $19,600.00 10.00%

Business operating ProfitBusiness operating Profit Business operating ProfitBusiness operating Profit Company profit (after salaries)Company profit (after salaries)

MARGIN $14,417.20 48.46% $53,937.20 54.59% $3,072.20 1.57%





The above table illustrates the income and profitability of average-sized businesses in each of the three categories. In the case of the sole trader start-up and businesses, the ʻmarginʼ is what the operator lives on. In the first instance, this may be casual only and often part-time. Most areas of Australia are seasonal, so there may be only 6 months of work per year for local guides (130 working days). For a healthy startup business, weʼve assumed they might get 70 days of guiding per year. These operators have no budget for marketing so they rely on word of mouth. At the outset, their income may be a lot lower. Despite their casual nature these operators are incredibly important to the industry for many reasons:

1. They are essential for local knowledge in remote areas and as casual guides for the larger companies;

2. They are generally less expensive. Some tourists will preferably go with them, as opposed to the more established companies;

3. Their clients can become hooked on Australian wildlife and want to come back and do tours (or know others who want to do tours); and

4. A proportion will become more established businesses.5. This is the entry point for most startup businesses.

The second ʻsole trader and small businessʼ category is a step up, where the operator has built trust and established return clients who want tours. They take a leap of faith and organise trips. Overheads immediately go up, with the need for an office, marketing, GST registration etc. If the operator can manage 6 trips a year and 80 days of guiding, there is potential for a modest annual salary of about $54,000.

At this point, it becomes very difficult to grow further. The only way to get more work is to take on staff. However, this introduces such significant overheads that thereʼs need to expand to a larger portfolio of trips. Many such people also outsource guides to overseas companies. There are only a very small handful of companies that manage to make the leap from small business to established company. The margins on these companies are very small indeed.

The figures above are based on a company holding permits and accreditation for one ʻaverageʼ state or region. If this is replicated across regions, there are two consequences:

1. The financial cost increases proportionally; and2. The amount of paperwork also increases proportionally.

It becomes difficult to manage without taking on an additional administrator. To service just four states using a part-time administration assistant, could increase overheads for permits, accreditation and associated costs from about 1.4% to over 20% of annual turn-over (see Figure 1).





Figure 1. Hypothetical business cost, where an additional four state accreditation permit and administration costs are factored in. This causes an increase in cost from about 1.4% to over 20% of annual turn-over needed to service regulatory requirements.

The key factors in this equation, that limit the scope small businesses have to adapt financially are:

1. Cost to consumer;2. Ability to run tours.

Whether a startup business of established tour operator, day trips form a significant part of any business. Unfortunately, many of these are loss-leaders, despite being an essential service for creating loyal clients and selling tours. A few years ago, these day trips would make some money but due mostly to the strong Australian dollar and increasing fuel prices, the margins these days are often negative.

Day guiding prices are inflexible. Niche nature travel businesses report that people will rarely spend more than about $425 a day, excluding food. The vast majority of bookings are couples. Day trips become profitable when groups book, as there is scope for passenger supplements but tends to be the exception to the rule. Most trips average about 150km a day and due to trade vehicle limitations, have to be done in a passenger vehicle with more than a certain number of seats. This usually means a 4WD. At $1.10 per litre (RACV vehicle fuel & wear and tear figures), this is $165. Companies that employ guides will usually provide a salary of about $325 a day, which amounts to a loss of about $65 for each day of guiding. Some of this loss is made up occasionally by additional passenger supplements, or one of the directors doing the guiding themselves.





“We have been advised that as of 1 January 2012 we have to have $20 million public liability insurance to use our Kakadu accreditation, which has increased our insurance bill by $500 from an already hefty bill of several thousand $$/year. “

Mostly however, this loss-leader is made up by running multiple day trips and developing tailor-made packages, where margins can be built into other guide fees, accommodation etc.

For larger companies, it is this part of the market this is being hardest hit by the current regulations. By removing the ability for companies to service the whole of Australia, significant swathes of the business are being undermined. This means:

a) Companies are starting to work more for overseas businesses, who have lower overheads and are not subject to Australian regulations;

b) Companies are starting to take people overseas;c) Companies are finding ways to avoid entering Australian National Parks; ord) Companies are having to tell clients they cannot run trips to preferred destinations (which

include some of Australiaʼs most important brand areas).

As for the smaller businesses, these are increasingly shutting down. Thatʼs not to say itʼs impossible to run a business in the current regulatory environment but compared to most businesses, its extremely hard to survive. Few have the necessary pre-existing financial comfort to survive the startup period e.g. a well-paid partner and no family. Now there is little scope for casual operators to provide basic guiding services either themselves, or under the auspices of an interstate company, the situation has worsened. Adding insult to injury, the permit and accreditation policies in some states include heavy fines for anyone flouting the rules.

These are the key messages for the industry:

1. The nature-based tourism industry is to some degree, already subsidising Australian tourism by providing an essential guiding service to travelers and before regulations, over the last 20 years, shaped this sector of the market.

2. Relatively small changes in regulation can have profound effect on the cost of administering companies that provide high quality experiences and visitor engagement.

3. The same problems are hampering the development of new businesses. With many of the current operators nearing retirement and new operators struggling.





ATTACHMENT 4: Case examples of problems in the industry

The following is a semi-anecdotal account of problems with the industry. We have deliberately stopped short of going into specific detail and instead, tried to reflect some of the stories and accounts weʼve heard. The significance of these issues varies from place to place but allows us to get an overall understanding of the breadth of issues raised.

Why do we need good nature guides and what does this mean?

Like fine wine, good food and aboriginal culture, there are few who have the skills and mindset to deliver an engaging and memorable experience with nature. Nature-based guiding requires the sort of skill and interest that one is born with and chooses to do for love not money. This is no different to any tourism venture. Itʼs an infectious passion that makes someone a good guide. Nature-based guiding is not something that can be taught through an accreditation process, so itʼs vitally important that people who are intrinsically well-qualified are supported by the industry.

“I once completed a diploma in tour guiding at Box Hill TAFE. The person who taught the course had only ever led one tour in his entire life and that was a sporting tour ... I more or less ended up teaching the course!”

Whilst itʼs possible to dress up any tourism experience in Australia as a ʻnatureʼ experience, itʼs also clear that national brands like Kakadu are seeing a drop in demand because such experiences arenʼt being delivered. The states are committed to addressing these problems and have begun to do a great deal to bolster these aspects of tourism.

Whilst tourism is suffering in places like Kakadu however, well-established businesses who offer nature-based tours are seeing no change in the demand for their products (in fact, some are getting increasing interest). The main difficulty they have now is supplying enough people to respond to demand. Overwhelming regulation is one of the more serious problems they cite.

1. Foreign companies avoid accreditation

In the Northern Territory, we know of three companies that have recently closed down. In one case, a company complained they could not afford local tourism accreditation, which meant they could not receive support (financial or marketing) from their regional body. The responsible authority may argue that the operator should have applied for accreditation but for reasons explained in Attachment 3, the ʻsmallʼ costs that are associated with these processes amount to a significant percentage of annual turnover. It was also pointed out that these same authorities fund famils to bring non-accredited foreign companies to Australia. These famils are Australian tax-payer-funded.

There is inequality in the tourism industry between local and foreign companies and this isnʼt limited to nature guides. For example, foreign travel agents recently lobbied for a reversal of regulations in Central Australia, that would have required them to accredit translators. Reality is, they have a fast turn over of staff and could not afford to keep up with the accreditation training - this was the right decision and necessary to protect foreign trade benefits. Itʼs not so different to the situation with Australian nature guides.





So there are numerous examples where overseas companies can operate without accreditation locally, whilst local companies are heavily regulated and donʼt appear to be able to negotiate the same exemptions. 2. Foreign Companies avoid need for permits

Local tourism operators are controlled to such a degree, that even small deviations from their permit requirements can result in heavy fines ($19,000 in Victoria). Yet, foreign-run companies are running trips within Australia all the time without such needs.

As in the foreign translator example above, itʼs right that the rules should be relaxed to protect an industry, when implementation of the policies achieves little added benefit.

Similarly, we know of instances where the rules seem to have been bent for foreign companies, allowing them casual ad hoc access to parks, where local operators have to go through months of accreditation and planning for the same outcome. Companies complain that, for instance, they canʼt take a client interstate because the authorities donʼt have any arrangements for casual / occasional tourism access to specific parks. Yet some of the same guides are working annually for foreign tour companies.

For reasons discussed in #5, this is now an almost impossible situation between some states. The regulations, combined with the closure of many startup businesses, are virtually prohibiting small companies to deliver Australia-wide tours.

3. Foreign Companies avoid need for Tourism Vehicle accreditation.

We believe that a foreign nature-based tour company has negotiated an exemption to the need for Tourism Vehicle accreditation across Australia and organised this state-by-state. Again, we support this relaxation of the regulations. It makes no sense that foreign companies should have to undertake several state accreditations each time they want to bring a new driver over to Australia - after all, their international licence applies wherever they go.

The issue is one of creating a level playing field. Some of our operators are required to have vehicles registered and inspected at their expense every 6 months. They have to have special drivers training but despite this, canʼt officially drive between states.

The need for tourism vehicle accreditation is another recent regulatory advance, that has made it even more difficult for small businesses to operate. For breach of conditions, the fines are potentially damaging and in some states, inspectors are specifically sent out to randomly check tour operator licences. One way to work around this, is to hire a vehicle. Unfortunately, demand for trade-vehicle plated 4WDs is now so huge, itʼs almost impossible to hire in states like NT. Some hire car companies are also reluctant to hire cars to go interstate but there are no ʻchange-overʼ points at the borders.

The demand placed on small operators for management of vehicles is very significant. Although everyone is in agreement that vehicles should be road-worthy, treating small company private cars with the same regulations that apply to buses, may not be prudent. This situation would be improved if there was enough supply of good nature guides with their own trade vehicles interstate.





4. Total loss of nature-based tourism potential for some areas

A fledgling company that recently closed down, has taken internationally-significant visitors into the red centre. These include the editors of the biggest birdwatching magazines in Europe and some of the biggest international wildlife tour companies representatives. In this particular case, the person was the only wildlife operator and guide in that area. He was sought by name, by some of the biggest wildlife media people in Europe. This particular area now has no-one who can deliver a nature-based experience. Constraints on business development, local bureacracy in regards to permits, accreditation and land access, have all contributed to the loss.

5. Interstate Trips Impossible in Some Cases

Most companies at one point or another will be asked by a client to cross a border. Clients may, on a whim, ask to go to a particular spot. A lot of guided trips are not based on a set itinerary. Nature responds to changing weather conditions and what people learn on the way - this is the point of having a guide and a small group. Normal conditions for permitting are often incompatible with the demands of nature-based tourists.

Associates of ours have been asked to cost trips worth 10s of ʻ000s of dollars, covering most of Australia but are struggling to do so. The biggest problem is finding a guide who can take people interstate. One might think you can employ a second local guide but this is virtually impossible for these reasons:

1. Ten years ago, companies could call on any number of people locally who provide casual support for wildlife guiding. Casual employment is now a virtual impossibility because:

a. Casuals would need to have their own permit but they might only do ten days of guiding a year (often as a part time job). They simply canʼt afford to apply for permits. In order to do that, they have to have a business plan, brochures, their own insurance etc. To be a casual or part-time guide, you essentially have to already have a fully-functioning profitable business. Itʼs virtually impossible to get started.

b. Even if the contracting company applies, they then have to manage two sets of permits, one for their native state and another interstate. In the lifetime of most guiding businesses, they will be asked to travel interstate. Small businesses have not got capacity to maintain a full range of permits for all the administrative regions of Australia (see below, on how this can escalate to the need for 300 permits in one state).

c. Particularly in the current financial environment, clients are reluctant to pay two guides. Itʼs just too expensive to fork out an extra $425 a day.

d. Most clients on long trips want to be looked after by the same person throughout. It makes more sense to be able to deliver an ʻAustralianʼ experience with one guide. Some operators have specialist guides who speak languages like Japanese. They may be the only one in Australia.

Costly Permitting processes

Applying for permits may seem simple enough but the paperwork can be extraordinary. In one example, a small company in New South Wales decided to take it upon themselves to get blanket coverage. A year and a half later and they have the necessary 300 permits. In Victoria, the permit





is done by management region and can take 6-8 weeks to process. If an operator is suddenly asked to access an alternative area (maybe only kilometres away), they have no immediate entitlement and would have to disappoint the customer. Reapplication for the new area is more than a formality. It also takes weeks and costs money.

“ ... we operate Australia-wide tours and are finding the replication of permits in each state very frustrating and costly, both in terms of admin time and money.”

Interstate experiences are now part of a national tourism branding initiative: the National Landscape Program. Take Queensland and New South Wales for example. The Australian ʻGreen Cauldronʼ National Landscape Area crosses the Queensland and New South Wales border. To register as a bona fide tourism operator in these two states is a massive undertaking.

“We put one of our local Top End guides through the Kakadu guide course at our expense and pay the annual fee to access the Park (in addition to the $25 pp entry fee). In addition, this process only applies to one park and needs to be replicated at Uluru.

Each state requires almost park-by-park application. For NSW, one has to write an operations manual, predict which parks one might need to enter and give examples of itineraries. The documentation has to be accompanied by a company brochure, business plan and thereʼs a need to contact every Park Ranger. The process in most states takes 6-8 weeks (though usually much longer to prepare) and might require an interview. There is an annual fee and in most cases, a charge per entry to parks, plus regular paperwork.

At the same time, parks are free for anyone else to enter. So what are permits achieving?

The New South Wales Ecopass scheme says it provides:

“ongoing certainty ... a vital consideration for operators planning to invest time and money in developing activities in national parks and reserves. The Parks Eco Pass licensing system provides this certainty in a number of ways including support to industry...”.

The permit requirements have:

1. Made interstate trade difficult / impossible;2. Made it difficult for any state company to take people anywhere within their own state (without

applying for 300 permits);3. Made it almost impossible for small startup companies or sole-traders to get a footing in the

industry;

The regulations neither provide any ʻongoing certaintyʼ or ʻsupport to industryʼ for the nature-based guiding sector. It goes on to say that operators can benefit from the Parks Eco Pass licensing system in the following ways:

• enter a partnership with NPWS that has a clear State Government mandate to increase visitation to national parks.





• receive advance notice of any road closures, major earth works, and improvements or changes to infrastructure via e-mails from NPWS.

• vehicle and personal identification that clearly indicates to the public that operators are required to be licensed.

• participation in forums to provide feedback and ideas to NPWS.• free marketing with contact details and ʻactivity offerʼ listed on http://

www.environment.nsw.gov.au/nationalparks/touroperators.aspx • the opportunity for your business to be promoted at consumer travel expos and events.• use of the NPWS Parks Eco Pass logo on your promotional material.• an official licensed operator certificate to display in the place of business.

None of the above provide any viable benefits to small business. In light of the apparently crippling constraints of the regulations on interstate and local trade, they do not support small business.

No accreditation required in other industries

The Environment Institute of Australia and New Zealand (EIANZ) is the peak professional body for environmental consultants. They are affiliated with the Certified Environmental Practitioner (CEnvP) scheme for ecologists working in Australia. To date and despite the fact the CEnvP scheme has been in place for many years, there is no formal recognition in statute or regulation, of any such certification or accreditation. This week, a bill to implement accreditation for environmental consultants in NSW was defeated in parliament.

This means that any qualified or unqualified person can lawfully advise governments, mining companies and other developers, on the likely impacts on wildlife in Australia.

Ironically, all the nature guides that have recently closed their nature-guiding businesses have taken jobs in the mining sector to work as consultants. There are no limits placed on their skills being used by developers in some of the most environmentally questionable activities in Australia. Yet the same individuals cannot be readily accredited to be paid to show someone a bird.

What is accreditation and permitting achieving?

What are the priorities for accreditation and permitting? If protection of national park ecosystems is the priority, there would be two simple ways to do this:

1) exclude people from national parks altogether; 2) make sure people are always accompanied.

Of course, neither are realistic options. The question remains however, if millions of people roam parks annually unaccompanied, what advantage is there to regulating the tiny proportion of small guided groups with a small handful of operators?

“I applied for a permit to access a park that they had done voluntary conservation work in most of my life. It was denied because the quota for permits had already been met. There were no bird or wildlife guides in that area and the places where he wanted to go, were away from the usual tourist tracks”



http://www.environment.nsw.gov.au/nationalparks/touroperators.aspx






Is it about protecting the quality of the tourism product? If it is, itʼs also unclear how this can be achieved, when the policies prohibit the establishment and growth of some of the best small operators. It favours large ʻbus toursʼ over small intimate experiences. This is not to say these tours arenʼt important but arguably, more diversity is needed to be compatible with major national strategies and to meet the demand that our associateʼs clients requests every day.





ATTACHMENT 5: Simple solutions

THE SOLUTION IS SIMPLE

• Ensure that the accreditation and vehicle licensing requirements are unified across all states so accredited

operators can work / employ casual guides, from anywhere in Australia.

• Implement a realistic volume threshold for companies accessing parks in every state, below which permits are a

basic formality or not required e.g. companies that do <200 visitor days per year (e.g. using a simple online register).

• Consider making accreditation a formality for any company that already meets equivalent requirements of a national professional standards body e.g. Ecotourism Australia or

Wildlife Tourism Australia.



