May 1996

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ARC REGULATORY IMPACT STATEMENT

The Alpine Resorts Commission (ARC) has released a Regulatory Impact Statement (RIS) in relation to proposed changes to ARC regulations covering amongst other things, resort entry charges, control over wheel chains, and issue of skidoo permits.

Resort Entry charges

The RIS proposes to maintain the current structure of resort entry charges by vehicle at the 1995 levels for cars and season passes. It also proposes an "off season" maximum fee of $6.50 per day per car outside the declared snow season, with corresponding rates for buses, motorcycles etc. There are a number of significant problems with these proposals and the supporting logic as documented.

There has been no serious attempt to look at alternatives to charging users twice in using a resort - once in charging the vehicle, and once in charging the activity (ski lift ticket, XC trail pass). Comparisons to interstate or overseas experience is dismissed out of hand with no examination of the comparative costs and benefits. Single point of payment seems to be the rule, not the exception in the USA and Canada at least. This also goes against the recommendation of the ARC Review Panel in regard to entry charges at Lake Mountain and Stirling.

There is no provision made for visitors to the area simply driving through resorts (Hotham and Falls) and hence not using resort facilities. The charge is simply to be levied on anyone ENTERING the resort.

The whole issue of cross subsidisation of summer use by winter users needs more examination. While some services(eg garbage, sewerage, power etc) are provided off-season, these services are minimal compared to winter, and would be very little used by summer visitors. The charge is set at 40% of winter costs - does a bushwalker parking at the start of the Razorback to walk to Feathertop really use nearly half the services of a Hotham skier ?

The cost of collecting this fee is not examined. Off Season costs are assumed to already be spent in the total winter costs - a supposition that cannot be supported. As there is no provision for an "off-season" season pass, it can only be assumed that staff will therefore need to be on duty to collect daily fees from visitors. This will mean additional staff resources, or staff being reallocated from other non-winter activities. Either option must mean either greater costs or reduced services in other areas.

A chart is used to attempt to demonstrate that resort entry charges are low compared to other recreation activities (including $224 Grand Prix tickets!?) but this is again a spurious comparison. To use an example familiar to me, 2 adults and 2 children pay $24 to go to the footy at the MCG, and only $ 16 to go to an ARC resort. However, the MCG charge is for the full entertainment for the day, not just for having someone point to where to park, keeping the grass mowed, and supplying electricity and toilets . The skiing family of four will actually pay $ 32 for cross country or $ 112 for half a day downhill skiing at Baw Baw.

In general the justification for the entry charges regime leave a lot to be desired, and the ARC should be required to undergo and publish much more detailed research before being able to proceed in this area.

Skidoo Permits

Until now the LCC recommendation to limit skidoo use to operational search and rescue purposes has been accepted by government. These regulations would allow the ARC to issue skidoo permits for a range of uses. Given that recreational snowmobile tours are being advertised for both Falls Creek and Hotham this year, one can only assume that recreational snowmobile would be a permitted usage. Australia has been (thankfully) free of the conflict of usage between recreational skiers and skidoos that would have been amply evident to any skiers who have visited the USA and Canada. If recreational use of snowmobiles is allowed here its introduction must be monitored most carefully.

Wheel Chains

An interesting aside is the new regulation making not carrying wheel chains an offence. I thought this was already the case (At least at Falls Creek and Hotham)

General

The RIS includes a list of bodies with whom it consulted on these issues, and it is most interesting for its omissions. The ARC appears not to have consulted with STAV, Federation of Walking Clubs, 4 wheel drive associations, Stirling Experience (ski hire & ski school at Stirling), or any summer user groups. Any claims to consultation must therefore be viewed as extremely suspect.