victorian national parks camping and accommodation fees
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victorian national parks camping and accommodation fees
OCTOBER 2013 VICTORIAN NATIONAL PARKS CAMPING AND ACCOMMODATION FEES REGULATORY IMPACT STATEMENT Authorised and published by the Victorian Government, Department of Environment and Primary Industries, 8 Nicholson Street, East Melbourne, October 2013 © The State of Victoria Department of Environment and Primary Industries 2013 This publication is copyright. No part may be reproduced by any process except in accordance with the provisions of the Copyright Act 1968. Print managed by Finsbury Green October 2013 ISBN 978-1-74287-863-8 (pdf) Accessibility If you would like to receive this publication in an alternative format, please telephone DEPI Customer Service Centre 136186, email customer.service@depi. vic.gov.au via the National Relay Service on 133 677 www.relayservice.com.au. This document is also available in on the internet at www.depi.vic.gov.au Disclaimer This publication may be of assistance to you but the State of 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. Victorian National Parks Camping and Accommodation Fees RIS Contents Executive Summary....................................................................................................................... vi 1 2 3 4 5 6 7 8 Introduction ......................................................................................................................... 1 1.1 Purpose of the report............................................................................................................. 1 1.2 Background to the project ..................................................................................................... 1 1.3 Structure of report ................................................................................................................. 2 Problem to be addressed .................................................................................................... 4 2.1 Definition of regulatory problem and rationale for government intervention ...................... 4 2.2 Objectives of government intervention ................................................................................. 5 Context ................................................................................................................................ 6 3.1 Legislative framework ............................................................................................................ 6 3.2 Victorian camping and accommodation ................................................................................ 9 3.3 Policy context ....................................................................................................................... 12 3.4 Role of key stakeholders ...................................................................................................... 15 3.5 Alternative providers ........................................................................................................... 17 Financial analysis ............................................................................................................... 22 4.1 Methodology ........................................................................................................................ 22 4.2 Delivery costs ....................................................................................................................... 27 4.3 Current usage ....................................................................................................................... 28 4.4 Forecast cost base ................................................................................................................ 35 4.5 Efficiency of costs ................................................................................................................. 36 Framework for options analysis ........................................................................................ 39 5.1 The pricing framework ......................................................................................................... 39 5.2 Approach for assessing the options ..................................................................................... 39 5.3 Identified options ................................................................................................................. 41 Assessment of regulatory options ..................................................................................... 45 6.1 The base case ....................................................................................................................... 46 6.2 Option 1 ............................................................................................................................... 49 6.3 Option 2 ............................................................................................................................... 52 6.4 Option 3 ............................................................................................................................... 55 The preferred option ......................................................................................................... 58 7.1 Determining the preferred option ....................................................................................... 58 7.2 Fees and financial implications ............................................................................................ 59 Statements on compliance ................................................................................................ 62 8.1 Impacts on small business .................................................................................................... 62 8.2 Competition assessment ...................................................................................................... 62 8.3 Implementation ................................................................................................................... 63 8.4 Enforcement......................................................................................................................... 63 8.5 Evaluation strategy .............................................................................................................. 63 Victorian National Parks Camping and Accommodation Fees RIS 9 Consultation ...................................................................................................................... 65 9.1 Consultation undertaken to-date......................................................................................... 65 9.2 Further Consultation ............................................................................................................ 66 References ................................................................................................................................... 67 Appendix A - Detailed costings .................................................................................................... 69 Appendix B - Pricing framework .................................................................................................. 72 Appendix C - Level of Service ....................................................................................................... 80 Appendix D - Visitor attitudes towards camping ......................................................................... 84 Appendix E - Benchmarking ......................................................................................................... 86 Appendix F - The proposed determination.................................................................................. 90 Appendix G - Proposed fee structure .......................................................................................... 95 Charts Chart 4.1 Number of separate trips to Victoria’s Parks (last three years)................................... 29 Chart 4.2 Usual camping accommodation ................................................................................... 30 Chart 4.3 Location of last Victorian camping visit ....................................................................... 30 Tables Table 1 Outline of Level of Service Standard for camping and roofed accommodation categories..................................................................................................................................... vii Table 2 Options for camping fees (average fee for each category, prices per night) ................... x Table 3 Options for roofed accommodation fees (average fees per night) .................................. x Table 4 Financial analysis of Options (annual average over ten years, 2013-14 prices) .............. xi Table 5 Summary of MCA results.................................................................................................. xi Table 6 Proposed fees for permit camping (2013-14 peak rates) ............................................... xii Table 7 Proposed fees for camping pass (2013-14 rates)........................................................... xiii Table 8 Proposed fees for special camping sites (2013-14 rates) .............................................. xiii Table 9 Proposed fees for overnight hiker permits (2013-14 rates) .......................................... xiii Table 10 Proposed fees for roofed accommodation (2013-14 rates) ........................................ xiv Table 11 Proposed average fees (peak rates) - current and proposed ...................................... xv Table 12 Camping cost in National Parks by level of service (based on one family of two adults and two children including one night’s park entry where applicable) ............................ xvi Table 13 Estimated annual revenue yield under preferred option ($ million) .......................... xvii Victorian National Parks Camping and Accommodation Fees RIS Table 3.1 : 2013-2014 camping fees as set under the National Parks Act 1975 (average prices per campsite night for each category)1,2,3 ........................................................................... 8 Table 3.2 : Camping service level categories ............................................................................... 11 Table 3.3 : Historical camping fees (peak) by service level category (per campsite night) ......... 12 Table 3.4 New South Wales camping fees on public land ........................................................... 18 Table 3.5 : South Australian park entry and camping fees .......................................................... 18 Table 3.6 : Benchmarking select private provider's fees (prices per campsite night) ................. 19 Table 3.7 : Summary of fees charged by alternative providers (Peak rates, average prices per campsite night for each category) ......................................................................................... 20 Table 4.1 : Assumed inflation rates from 2008-09 to 2012-13 and ongoing to adjust 2007-08 cost baseline* .............................................................................................................................. 22 Table 4.2 Camping and Accommodation important visitor attributes/attitudes: ....................... 31 Table 4.3 : Visitation by service level category ............................................................................ 32 Table 4.4 : Estimated cost of camping and accommodation facilities in parks and reserves managed by Parks Victoria (2011-12, $million)1.......................................................................... 32 Table 4.5 : Description of costs .................................................................................................... 33 Table 4.6 : Revenue from camping and accommodation facilities managed by Parks Victoria (2009-10 to 2011-12) ................................................................................................................... 34 Table 4.7 : Ten Year Average annual cost of camping and accommodation facilities managed by Parks Victoria ($ million)1 ........................................................................................................ 35 Table 4.8 : Summary of the estimated cost of providing camping facilities in parks/reserves managed by Parks Victoria (2013-14) .......................................................................................... 37 Table 5.1 Weighting of assessment criteria ................................................................................. 40 Table 5.2 : MCA scale ................................................................................................................... 41 Table 6.1 : Current 2013-14 fees (average fee per night for each category)1 ............................. 47 Table 6.2 : Financial analysis of the base case (current fees annual average over ten years, 2013-14 prices) ............................................................................................................................ 47 Table 6.3 : Scoring of the base case ............................................................................................. 48 Table 6.4 : Option 1 fees (average fee per night for each category)1.......................................... 49 Table 6.5 : Financial analysis of Option 1 (annual average over ten years, 2013-14 prices) ....... 50 Table 6.6 : Scoring of Option 1..................................................................................................... 52 Table 6.7 : Option 2 fees (average fee per night for each category)1.......................................... 52 Table 6.8 : Financial analysis of Option 2 (annual average over ten years, 2013-14 prices) ....... 53 Table 6.9 : Scoring of Option 2..................................................................................................... 54 Table 6.10 : Option 3 fees (average fee per night for each category)1........................................ 55 Table 6.11 : Financial analysis of Option 3 (annual average over ten years, 2013-14 prices) ..... 56 Table 6.12 : Scoring of Option 3 .................................................................................................. 57 Victorian National Parks Camping and Accommodation Fees RIS Table 7.1 : Summary of MCA results............................................................................................ 58 Table 7.2 : Proposed fees (peak rates)1 ....................................................................................... 59 Table 7.3 : Estimated annual revenue yield under preferred option ($ million)1........................ 60 Table 8.1 : Impacts of new camping pricing structures on competition ..................................... 62 Table A.1: Estimated costs of camping facilities in national parks and reserves operated by Parks Victoria (2013-14)............................................................................................................... 69 Table B.2 : Methods of collecting payment ................................................................................. 76 Table B.3 : Pricing structure options ............................................................................................ 77 Table C.1 : Level of service categories for campgrounds under the National Parks Act ............. 80 Table D. 1: Community attitudes towards camping .................................................................... 84 Table E.1 : Benchmarking of private provider prices (select, prices per campsite night) ........... 86 SCHEDULE 1 ................................................................................................................................. 92 Camping fees peak season (fee units per night).......................................................................... 92 SCHEDULE 2 ................................................................................................................................. 92 Fees for special camping sites year round (fee units per night) .................................................. 92 SCHEDULE 3 ................................................................................................................................. 93 Fees for overnight hiker permits year round (fee units per night) .............................................. 93 SCHEDULE 4 ................................................................................................................................. 94 Fees for roofed accommodation (fee units per night) ................................................................ 94 Table G.1 : Proposed fees for permit camping (2013-14 peak rates).......................................... 95 Table G.2 : Proposed fees for camping pass (2013-14 rates) ...................................................... 95 Table G.3 : Proposed fees for special camping sites (2013-14 rates) .......................................... 96 Table G.4 : Proposed fees for overnight hiker permits (2013-14 rates) ...................................... 96 Table G.5 : Proposed fees for roofed accommodation (2013-14 rates per accommodation) .... 97 Figures Box 3.1: Objectives of the National Parks Act 1975 ...................................................................... 6 Figure 3.1 Nature and extent of forest, parks and reserves in Victoria....................................... 10 Figure 3.2 DEPI’s Pricing Framework for public land ................................................................... 15 Figure B.1 : DEPI’s pricing framework for public land ................................................................. 72 Victorian National Parks Camping and Accommodation Fees RIS Glossary DEPI Department of Environment and Primary Industries DEWNR Department of Environment, Water and Natural Resources (SA) DPI Department of Primary Industries DSE Department of Sustainability and Environment DTF Department of Treasury and Finance HPHP Healthy Parks Healthy People MCA Multi Criteria Analysis NPWS National Parks and Wildlife Service (NSW) RIS Regulatory Impact Statement Victorian National Parks Camping and Accommodation Fees RIS Executive Summary Introduction Victoria’s parks and forests provide fantastic nature-based recreation experiences, supported by some of the most accessible campgrounds in the world. From the Alps to the Grampians, the Otways to the Prom, our parks and forests are places people go to escape, rejuvenate and get in touch with nature. Victorian parks and forests offer a range of great camping experiences to suit any visitor. To continue to protect and enhance these special places for the community, the Victorian Government intends to introduce a more sustainable user pays system for camping and accommodation. This will also ensure that future generations can continue to enjoy our parks and forests. Currently, fees are applied inconsistently across the state leading to confusion for visitors, and sometimes fee evasion. The new fees and charges will ensure that users of campgrounds and roofed accommodation in parks contribute toward the cost of providing these facilities and services. Costs associated with delivering camping and accommodation include: • • • • • • Campground/accommodation maintenance Asset maintenance – i.e. shelters, toilets, barbeques Environmental management of surrounding areas impacted on by visitation Ranger patrols and staff presence associated with delivering the services Refuse and recycling, revegetation and site protection Operation and maintenance of wastewater, water treatment, underground gas/electricity supply and power generation infrastructure • Bookings, ballots, issuing of permits, visitor information and interpretation • Risk and emergency management, emergency response. The user pays model will also be consistent with Government’s broader policies for cost recovery and will assist Parks Victoria with the management and protection of the surrounding environment and ensure ongoing access and enjoyment of these special places. The model is also consistent with other Australian states, for example New South Wales where a user pays system is in place. Camping and accommodation fees have not increased significantly in the ten years from 2004 to 2013 with fees increasing in most years by the Treasurer’s rate. The proposed fees are expected to be introduced on 1 March 2014 to all parks where a camping permit may be issued under the National Parks Act 1975.1 This Regulatory Impact Statement (RIS) outlines the implications of changes on sectors of the Victorian community. The Department of Environment and Primary Industries (DEPI) and Parks Victoria have prepared this RIS with assistance from Deloitte Access Economics in drafting key chapters and undertaking the cost recovery and financial impact analysis. 1 Camping fees for other public land will be addressed in a separate process. However to ensure a consistent pricing framework across public land, total costs and revenue estimates relate to all land tenures managed by Parks Victoria. vi Victorian National Parks Camping and Accommodation Fees RIS This RIS is released for public consultation to assess the impact of the proposed fees and ensure camping will continue to be affordable, accessible and enjoyable for all members of the community. Importance of camping and accommodation in parks Victoria’s national and other parks play a vital role in protecting the natural environment and cultural heritage, providing opportunities for recreation, and bringing social benefits in terms of the health and wellbeing of individuals and the community. Parks also bring economic benefits to local, regional, state and national economies. Campgrounds and roofed accommodation in parks allow visitors to access and enjoy Victoria’s natural environment and cultural heritage and enhance the social and economic benefits provided by parks. These benefits contribute to prosperous, cohesive, socially active and healthy communities. Provision of campgrounds, roofed accommodation and associated facilities such as walking tracks not only enable people to enjoy the benefits of parks, but they also protect the natural and cultural values that make parks such wonderful places to visit. Management of camping and accommodation in Victoria’s national and state parks Parks Victoria, on behalf of the Secretary, Department of Environment and Primary Industries, manages Victoria’s parks and reserves. Camping and accommodation is provided in 133 parks and reserves across Victoria and includes approximately 680 campgrounds together with many dispersed camping sites. It is estimated that there are more than 2.2 million overnight stays in Victoria’s national park each year. This represents nearly 7% of all visits to national parks annually. Table 1 outlines the different service categories for camping and roofed accommodation in Victoria’s parks and reserves. This table also includes a categorisation for different roofed accommodation types available in parks across Victoria. Table 1 Outline of Level of Service Standard for camping and roofed accommodation categories Service level/type Description Examples Very high Hot showers, fully serviced, full time ranger presence, sewer toilets, designated campsites, booking service, treated drinking water, laundry facilities, unique location Tidal River, Wilsons Promontory NP High Some showers, Partially serviced, regular ranger patrols, mostly septic/sewer toilets, mostly designated sites, booking service, some drinking water, unique location Cape Conran CP, Grampians NP, Lake Eildon NP Mid No showers, partially serviced, infrequent ranger patrols, booking service, pit/composting toilet, mostly undesignated sites Brisbane Ranges NP, Great Otway NP, Cape Liptrap CP, Cathedral Range SP vii Victorian National Parks Camping and Accommodation Fees RIS Basic and very basic permit Unserviced, minimal ranger patrols, typically no booking service, pit or no pit toilets Mornington Peninsula NP, Bunyip SP, Lerderderg SP Special Select campgrounds with unique characteristics that give rise to the need for a special fee Grampians NP, Great Otway NP, Mount Buffalo NP, Wilsons Promontory NP, Croajingolong NP Group lodges 12, 24 & 30 bed, bunk style Group Lodges accommodation Wilson’s Promontory NP, Cape Conran CP Huts 4 & 6 bed single room bunk style Huts selfcontained no ensuite Wilson’s Promontory NP Cabins 6 & 8 bed self-contained Cabins Wilson’s Promontory NP, Cape Conran CP, Buchan Caves Reserve Wilderness retreat Sole use or twin share tent style accommodation with or without ensuite Wilson’s Promontory NP, Cape Conran CP, Buchan Caves Reserve Lightstation Self-contained Cottage style accommodation Wilson’s Promontory NP, Gabo Island Source: Parks Victoria Camping and accommodation charges on public land in Victoria have been applied to selected areas (such as Tidal River, Wilsons Promontory National Park) for many decades. Currently camping and accommodation fees are charged at only 24 of the 133 parks and reserves (18 per cent), with 109 camping grounds requiring a camping permit. Six parks offer roofed accommodation facilities and services, including cabins, cottages, huts, lodges and wilderness retreats. The Problem At present, the total annual cost of delivering camping and accommodation facilities and services within Victoria’s national and other parks is estimated to average $17.8 million over the next ten years. However, only $6.5 million is currently collected in revenue from user fees and charges. The estimated shortfall of $11.3 million is neither fair nor sustainable. The current pricing framework for camping and roofed accommodation in national and state parks does not provide for financially sustainable delivery of these services. Campgrounds and roofed accommodation offered in parks are currently provided at significant cost to taxpayers and do not align with the Government’s cost recovery principles. The Government’s objective is to encourage the use of parks by making them accessible to the broader community. However, unless the users of our magnificent public land estate and natural assets contribute a fair share of the cost of providing and managing these camping and accommodation sites, providing for these facilities and services will become more difficult. Without investment campgrounds and roofed accommodation facilities and services offered in parks will degrade, requiring either costly maintenance or providing a substandard visitor experience for those who choose to use our parks. viii Victorian National Parks Camping and Accommodation Fees RIS These issues were highlighted by a 2010 Deakin University research report, 2 which identified the following issues with the current camping and accommodation pricing structure: • Fees vary across and within parks. There are currently twelve pricing levels for camping, with site fees ranging from $5.60 to $48.00 per night • Current camping fees have an inconsistent and unstructured relationship with the level of service provided and are generally only applied at high visitation sites or where collection is easiest • There are inconsistencies in the camping fees charged for peak, shoulder and off peak season Objective of fee determination The Victorian Government is seeking to establish a fee structure that addresses the issues outlined above and provides for ongoing, financially sustainable provision of camping and accommodation facilities and services in Victoria’s national and state parks. The National Parks Act 1975 requires that the Minister sets camping fees in national and state parks through a determination. This determination will apply to all camping places and facilities provided in national and state parks. In the future, the Government will also consider a camping pass for dispersed camping and some basic/very basic campgrounds. This will ensure users pay for the ongoing management of these areas, including the associated access tracks. Similarly, camping fees will be considered for forests and other areas of public land to ensure camping across all public land is sustainable. Just as for parks and reserves, managing camping areas in forests and other public land incurs significant costs to the state, for such things as maintenance, waste management and ranger patrols, and it is important to recover these costs in order to continue to ensure campgrounds are accessible to those wishing to enjoy Victoria’s wonderful forests and parks. Pricing options considered The pricing options considered in this RIS were: • Current Fees (Base Case): Current fees for camping and accommodation facilities and services provided in national and state parks are shown in Tables 2 and 3 • Option 1: Fees are based on achieving full cost recovery with the assumption of 100% compliance, and set according to the level of service of the facility provided. Fees between different service levels differ due to the different costs per visitation night (i.e. no cross subsidies between different service levels or accommodation types) Deakin University, 2010, Research report for Parks Victoria: Camping and Accommodation Product & Pricing. 2 ix Victorian National Parks Camping and Accommodation Fees RIS • Option 2: Fees are based on rates charged by private operators (for accommodation only) or public providers in other jurisdictions (for both camping and accommodation). These are referred to as market rates • Option 3: Fees are based on improved revenue yield for camping and accommodation facilities and services. All fees achieve improved revenue generation, reflect differences in quality between the levels of service and are mindful of market rates. Roofed accommodation fees were also set in consideration of scarcity rents (Preferred Option) The proposed fees and financial implications of each option are outlined below. Note that fees are set by Parks Victoria to apply from 1 September to 31 August each year. The proposed 2013-14 prices shown in this document are the new fees proposed for introduction from 1 March 2014 and would apply to 31 August 2014. Table 2 Options for camping fees (average fee for each category, prices per night) Current fees (Base Case) Option 1 Option 2 Option 3 Service level Peak Off peak Peak Off peak Peak Off peak Peak Off peak Very high (pwrd) (per site) $55 $49 $45 $40 $55 $50 $66 $59 Very high (non-pwrd) (per site) $33 $30 $49 $44 $50 $45 $59 $53 High (per site) $32 $29 $38 $34 $42 $38 $50 $45 Mid (per site) $22 $19 $46 $42 $25 $23 $38 $34 Basic and very basic (per vehicle) $0 $0 $13 $13 $13 $13 $13 $13 Special (per site or per person) $14 $13 $34 $31 $15 $13 $18 $18 Source: Deloitte analysis Table 3 Options for roofed accommodation fees (average fees per night) Current fees (Base Case) Option 1 Option 2 Option 3 Accommodation type Peak Off peak Peak Off peak Peak Off peak Peak Off peak Group lodges $557 $501 $729 $656 $516 $465 $648 $547 Huts $89 $80 $175 $157 $125 $113 $131 $111 Cabins $195 $176 $155 $140 $197 $177 $236 $202 Wilderness retreat $245 $245 $241 $216 $247 $222 $245 $245 Lightstation $133 $121 $97 $87 $119 $108 $135 $122 x Victorian National Parks Camping and Accommodation Fees RIS Source: Deloitte analysis Table 4 Financial analysis of Options (annual average over ten years, 2013-14 prices) Current fees Total cost Option 1 Option 2 Option 3 $17.8 $17.8 $17.8 $17.8 Max potential revenue $7.3 $17.8 $16.5 $18.4 Estimated yield $6.5 $14.7 $13.6 $15.3 $11.3 $3.1 $4.2 $2.5 Shortfall per year ($million) Source: Deloitte analysis Estimated yield is lower than the maximum potential yield due to estimated levels of non-compliance. Accommodation fees for option 3 were set using the principles of: • Scarcity rent: Where there is excess demand for a good or service, due to scarcity or a restriction on supply, prices should capture private benefits that exceed cost recovery • Considerations over quality differences and consumer willingness to pay Fees were also set with consideration of DEPI’s Pricing Framework for public land outlined in Appendix B. Determining the preferred option A Multi Criteria Analysis (MCA) was used to determine the preferred option to ensure sustainable camping and accommodation facilities and services are provided in parks and reserves. MCA was chosen as it utilises qualitative and quantitative techniques to assess policy options against decision criteria. A MCA was used to test which of the three options would best meet both the Government’s objective of encouraging the use of national and state parks while delivering increased revenue for camping and accommodation facilities and services. The results of the MCA are shown in Table 5. Table 5 Summary of MCA results Criteria Weighting Option 1 Option 2 Option 3 Efficiency 40 per cent +7 +6 +8 Equity 30 per cent -3 +5 +8 Effectiveness 30 per cent -10 +3 +3 Weighted total 100 per cent -1.1 4.8 6.5 It is foreseeable that, under the base case, camping facilities would become degraded resulting in a situation that is counter Government’s objective of encouraging the use of national and state parks, particularly if some campgrounds xi Victorian National Parks Camping and Accommodation Fees RIS need to be closed for health and/or safety reasons. Option 1 achieved a score that indicates it is worse than the base case, primarily driven by equity and effectiveness implications. Options 2 and 3 both receive scores indicating that they are better than the base case for generating increased revenue. These options significantly reduce the funding shortfall of providing camping and accommodation facilities and services, providing a more sustainable funding approach relative to the base case. In particular, revenue generation is highest under option 3. While options 2 and 3 may be argued to be counter to the Government’s objective of encouraging the use of parks, as increasing fees may reduce visitation rates, options 2 and 3 generate the necessary funds to maintain campgrounds and roofed accommodation sustainably into the future. Without the increased revenue, as in the base case, Parks Victoria will not be able to maintain campgrounds and roofed accommodation to the current levels leading to closures and reduced services which would be further at odds with the Government’s objective of encouraging the use of national and state parks. On balance, option 3 scores the highest as the fees achieve the most sustainable revenue stream (i.e. it best addresses the efficiency criterion) and most accurately reflect differences in quality (i.e. it best addresses the equity criterion). As such, option 3 is the preferred option. Details of the Preferred Option The preferred camping and accommodation fees are outlined in further detail below. The proposed fees reflect differences within each category, such as for size of groups, school groups and types of vehicle. Table 6 Proposed fees for permit camping (2013-14 peak rates) Site up to 8 persons Site up to 6 persons Per person School groups site up to 6 persons School groups per person Additional vehicle Very High Non powered $59.20 N/A N/A $53.30 $8.90 $9.20 Very High Powered $65.90 N/A N/A N/A N/A $9.20 High - Non powered N/A $48.70 N/A $43.80 $8.80 $9.20 High Powered N/A $54.10 N/A $48.70 $9.70 $9.20 Mid N/A $37.80 $18.90 $34.00 $6.80 $9.20 Basic & Very Basic N/A $19.30 $9.70 N/A N/A N/A Category Notes: A 10 per cent discount applies during off-peak periods (May to October each year). xii Victorian National Parks Camping and Accommodation Fees RIS Table 7 Proposed fees for camping pass (2013-14 rates) Category Per Vehicle/Boat Annual $121.70 $347.70 $608.50 $43.50 $43.50 Monthly $81.10 $231.70 $405.50 $29.00 $29.00 7 Day $46.40 $132.60 $232.00 $16.60 $16.60 Overnight $17.40 $49.70 $87.00 $6.20 $6.20 Small bus Large bus Motorcycle Hiker/Cyclists Table 8 Proposed fees for special camping sites (2013-14 rates) Category Exclusive School Groups per person Per person Boat / Canoe / Kayak per person Booking administration (per booking) Lower Glenelg NP Canoe Camp N/A $9.00 N/A $10.00 Individuals $10.00 Groups $15.00 Mt Arapiles N/A N/A $5.00 N/A N/A Plenty Gorge Parklands Nioka Bush camp $360 ($420 with kitchen & hall) N/A N/A N/A N/A Yarra Valley Parklands $315.00 N/A N/A N/A N/A Table 9 Proposed fees for overnight hiker permits (2013-14 rates) Category Per person School groups per person Site 1-3 persons Group exclusive Group site 13 Booking administration (per booking) Great Ocean Walk, Falls to Hotham Alpine Crossing N/A N/A $30.00 $216.00 $27.00 Individuals $10.00 Groups $15.00 Wilsons Prom, Mt Buffalo $12.50 $11.30 N/A N/A N/A Individuals $10.00 Groups $15.00 xiii Victorian National Parks Camping and Accommodation Fees RIS Croajingolong (Wilderness Coast Walk), Grampians National Park, Alpine National Park, Baw Baw National Park, Cobboboonee National Park, Discovery Bay Coastal Park, Lower Glenelg National Park (Great South West Walk) $10.00 $9.00 N/A N/A N/A Individuals $10.00 Groups $15.00 Table 10 Proposed fees for roofed accommodation (2013-14 rates) Category Peak season Shoulder season Off peak season Extra person Booking fee ballot/ booked period Administration fee – applies to phone assisted amendments and changes to bookings 34 Bed Bunkhouse Plenty Gorge Nioka Bush camp $510.00 N/A $510.00 N/A N/A $20 6 Bed Cabins - Wilsons Prom $304.30 $243.40 $222.70 N/A $10.00 $20 8 Bed Cabins - Cape Conran $224.80 $179.80 $161.90 N/A $10.00 $20 5 Bed Cabin - Buchan Caves $95.60 N/A $86.10 N/A N/A $20 4 Bed Huts - Wilsons Prom $132.70 $106.10 $95.50 N/A $10.00 $20 6 Bed Huts - Wilsons Prom $202.20 $161.70 $145.50 N/A $10.00 $20 12 Bed Lodges Wilsons Prom $495.50 $396.40 $356.80 N/A $10.00 $20 24 Bed Lodge Wilsons Prom $997.70 $798.10 $718.30 N/A $10.00 $20 30 Bed Lodge Wilsons Prom $1,247.20 $997.70 $898.00 N/A $10.00 $20 17 Bed Lodge - Cape Conran $756.10 $604.90 $544.50 N/A $10.00 $20 Lightstation - Wilsons Prom Standard Plus 133.80 N/A $120.50 N/A N/A $20 Lightstation - Wilsons Prom Standard 100.50 N/A $90.50 N/A N/A $20 Lightstation - Gabo Island $350.00 N/A $315.00 N/A N/A $20 14 Bed Shearers Quarters - Murray Sunset $374.10 N/A N/A N/A N/A $20 xiv Victorian National Parks Camping and Accommodation Fees RIS Wilderness Retreat Wilsons Prom (Sole use or twin share, with ensuites) $302.50 N/A $302.50 $24.80 N/A $20 Wilderness Retreat Cape Conran & Buchan Caves (Sole use or twin share, no ensuites) $181.50 N/A $181.50 $21.80 $10.00 $20 Fees and financial impacts under the preferred option Fees (peak rates only) under the preferred option are outlined in Table 11. The proposed fees for camping facilities are an increase on the current fees, in particular where fees are being introduced for the basic and very basic campsites for the first time. This reflects the current modest fee structure, where patrons are being subsidised by tax payers and camping sites are not being adequately maintained. Table 11 Proposed average fees (peak rates) - current and proposed Base case (current) Camping Fees $55 $33 $31 $22 $0 $14 $66 $59 $50 $38 $13 $18 $3.7 -$10.9 $11.5 -$3.1 $557 $89 $195 $245 $133 $648 $131 $236 $245 $135 Estimated revenue yield Estimated shortfall/surplus $3.2 $0.0 $3.8 $0.6 Estimated revenue yield Estimated shortfall/surplus $6.5 -$11.3 $15.3 -$2.5 Very High (pwrd) Very High (non-pwrd) High (non-pwrd) Mid Basic & Very Basic Special Financials Estimated revenue yield ($m) Estimated shortfall/surplus Accommodation Fees Group Lodges Huts Cabins Wilderness Retreats Lightstation Financials ($m) Total Financials ($m) Option 3 (proposed) Source: Deloitte analysis In comparison with other jurisdictions, the proposed fee structure compares favourably with other states that apply variable fees on the basis of the level of service (see Table 12). When combined with the applicable entry fees in other states, the proposed fees are comparable for the Basic, Mid and High service categories. xv Victorian National Parks Camping and Accommodation Fees RIS In Victoria, the majority of camping occurs is in the Basic service level category and the proposed fees are either below or comparable with all other states. While the fees proposed for the Very High service level are slightly higher than other states in Table 12, few states offer equivalent facilities in national parks. The proposed fees for the Very High service category remains comparable with private sector offerings (eg. caravan parks and tourist parks). Table 12 Camping cost in National Parks by level of service (based on one family of two adults and two children including one night’s park entry where applicable) State/Territory VIC (preferred option) TAS NSW SA WA QLD ACT NT Basic Mid High Very high $13 $38 $50 $59 $37 $28 $20 $31 $21 $12 $7 $37 $28 $23 n/a $21 $12 $7 $46 $41 $28 $46 $21 n/a $15 $52 $46 $41 n/a n/a n/a $15 Note: Figures obtained from each state’s website September 2013 Nightly camping fee and daily park entry fee are combined in the figures shown Figures are indicative only and based on selected sites with equivalent service level Fee structure, levels of service and other fee components are not always directly comparable. Overall, the estimated revenue yield from camping and accommodation facilities under the proposed fees is $15.3 million, in comparison to the revenue yield under the current fees, which is estimated at $6.5 million. However, the proposed fees will not achieve full cost recovery due to the expected level of compliance which was included in this assessment. When accounting for the assumed levels of payment compliance, the estimated budget shortfall under the proposed camping and accommodation fees will be reduced from $11.3 million to $2.5 million. This may be further reduced by compliance measures taken during the implementation of these changes. Estimated revenue yield from the proposed camping and accommodation fees are shown below in Table 13. Revenue from camping and accommodation facilities and services is expected to increase from $13.5 million in 2013-14 to $16.9 million in 2022-23, with a net present value of $126 million assuming a real discount rate of 3.5 per cent. These revenue estimates are modelled on full implementation of the proposed fees across all parks and reserves managed by Parks Victoria. In practice, a staged implementation is proposed, with permit camping within national parks being implemented during 2013/14. Fees associated with dispersed camping, such as a ‘camping pass’ and other tenures such as other Crown land and forests will be implemented in subsequent years once legislative and/or regulatory processes are completed. As such, the actual revenue yield will be less than modelled here in the early years. xvi Victorian National Parks Camping and Accommodation Fees RIS Fees outlined in this RIS are for the year 2013-14. Fees in subsequent years will be adjusted to maintain the financially sustainable provision of camping and accommodation facilities and services. In general, fees will be increased on an annual basis in accordance with Treasury guidelines to ensure fees are consistent with general price inflation. Table 13 Estimated annual revenue yield under preferred option ($ million) Year Revenue yield 2013-14 2014-15 2015-16 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 $13.5 $13.7 $13.9 $14.2 $14.4 $16.3 $16.5 $16.6 $16.8 $16.9 Source: Deloitte analysis Conclusion The increased revenue generated under the preferred option will allow campgrounds and roofed accommodation in parks to be managed sustainably so that future generations can continue to access and enjoy Victoria’s magnificent parks. Assets associated with these facilities and services will be revitalised, rejuvenated and renewed and better facilities and services will be provided. Visitors will enjoy a better experience and land managers will be able to appropriately manage the natural assets that underpin these areas. The benefits of the proposed fees will therefore outweigh the costs to society. Public Consultation Public release of the RIS will provide an opportunity for members of the public to comment on the proposed changes to camping and accommodation fees. DEPI and Parks Victoria therefore encourage feedback regarding the impact of the proposed fees. In particular, stakeholders may wish to provide comment on the proposed rates for each camping and accommodation type as well as the extent of the proposed changes. Submissions must be received by 5pm on 22 November 2013. All submissions received are public documents and may be made available as requested. xvii Victorian National Parks Camping and Accommodation Fees RIS 1 Introduction This chapter explains the purpose of this report, provides background to the project and outlines the structure of the Regulatory Impact Statement. 1.1 Purpose of the report The opportunity to camp or stay in accommodation in parks was first introduced over 100 years ago at Wilsons Promontory National Park and Mount Buffalo National Park. These opportunities have grown so that now visitors can immerse themselves year round in parks by pitching a tent, parking a caravan or camper trailer, or relaxing in a cabin or wilderness retreat. Staying in parks has grown significantly in popularity over the years, now attracting over 2 million overnight stays at over 680 campsites and a range of accommodation types such as cabins, huts, lodges, wilderness retreats and lightstation cottages. The experience of staying overnight in a park is complemented by the provision of quality services and facilities including visitor information, walking trails, toilets, water, picnic and barbeques facilities as well as the presence of rangers. In recent years, a range of influences such as increases in costs, fire and flood events, maintenance to keep infrastructure/facilities at acceptable standards and inconsistent fee structures have all affected the nature of camping and accommodation in our parks. The total cost of providing camping and accommodation opportunities within Victoria’s national and other parks is estimated to be $17.8 million per annum. Currently only $6.5 million is collected in revenue from user fees and charges. The estimated annual shortfall of $11.3 million is neither fair nor sustainable. To continue to protect and enhance these special places for future generations, the Victorian Government intends to introduce a sustainable user pays system for camping and accommodation. 1.2 Background to the project Victoria’s national parks and reserves attract approximately 30.1 million visitors per annum. Of these it is estimated that nearly 2.26 million (7.5%) are overnight visitors utilising the camping and accommodation opportunities available throughout the state. Parks bring direct and flow-on economic benefits to local, regional, state and national economies. They are also central to the health of communities. Camping and staying in roofed accommodation is a valuable way of enjoying the benefits provided by our parks. Parks Victoria is the statutory authority responsible for the management of Victoria’s parks, reserves, and other land and water. Camping and accommodation is provided in 133 parks and reserves across Victoria. This encompasses almost 680 camping grounds together with many dispersed camping sites. Camping and accommodation charges on public land in Victoria have been applied to selected areas (such as Tidal River, Wilson’s Promontory National Park) for several decades. 1 Victorian National Parks Camping and Accommodation Fees RIS Camping and accommodation fees have not increased significantly in the ten years from 2004 to 2013 with fees increasing in most years by the Treasurer’s rate. Currently 24 (18 per cent) of the 133 parks and reserves are fee for service, encompassing 109 camping grounds which require fees. Six parks offer roofed accommodation, including cabins, cottages, huts, lodges and wilderness retreats. A 2008 review by Parks Victoria and Deloitte, identified that Parks Victoria was subsidising both camping and roofed accommodation. It was determined that the current financial model for the provision of the camping and accommodation was unsustainable. The Government is therefore seeking to increase revenue from camping and accommodation services and facilities provided on public land to ensure they can be provided into the future. Increased fees, consistent with the Cost Recovery Guidelines 3 and market rates are needed to achieve this increased revenue. Section 21 (2) of the National Parks Act 1975 (the Act) provides the necessary head of power to set camping and accommodation fees and charges (and associated terms and conditions) for land governed by the Act. The attached ministerial determination (Appendix F) sets the new fees for all land managed under the Act. Terms and conditions associated with these fees are included in the determination. An RIS was prepared to assess the impact of the proposed changes on the Victorian community. This RIS was prepared by the Department of Environment and Primary Industries (DEPI) and Parks Victoria. Deloitte Access Economics assisted in drafting key chapters and undertaking the cost recovery and financial impact analysis. 1.3 Structure of report The report is structured as follows: • Chapter Two sets out the regulatory problem being addressed and the objective of government intervention • Chapter Three provides context for the determination, including the current legislative framework, the current fee structure for Victorian camping and accommodation, the policy context, the roles of key stakeholders and inter-jurisdictional approaches • Chapter Four outlines the financial analysis underpinning the RIS, including current usage and forecasts, assumptions made and an overview of the cost calculations • Chapter Five outlines the framework for options analysis and identifies several feasible options. Criteria for assessment are also developed. Options have been developed to address the cost recovery problems identified in Chapter Four • Chapter Six contains an assessment of regulatory options, including a financial analysis of each identified option and a ranking of each option against the criteria for assessment developed in Chapter Five 3 Department of Treasury and Finance (DTF), 2010, Cost Recovery Guidelines, State of Victoria 2 Victorian National Parks Camping and Accommodation Fees RIS • Chapter Seven provides an overview of the preferred option and how implementation of this option will take place • Chapter Eight contains the statements of compliance, namely: the impact on small business; assessment of competitions impacts; implementation and enforcement considerations and the evaluation strategy • Chapter Nine outlines the consultations undertaken during the RIS development process thus far and the consultation strategy going forward. 3 Victorian National Parks Camping and Accommodation Fees RIS 2 Problem to be addressed This chapter provides an overview of the problems inherent in the current camping fee pricing structure and establishes why regulatory change is necessary. 2.1 Definition of regulatory problem and rationale for government intervention There is currently a significant shortfall in the revenue generated from camping and accommodation facilities and services provided in parks. The current financial model is unsustainable and current facilities and services will not be able to be provided to the standards expected by the community. In 2011-12 the estimated cost to Parks Victoria of the camping and accommodation facilities in parks and reserves under its management was around $12 million. In the same year, the revenue earned from these facilities was around $4.2 million, falling from the previous year’s $4.4 million. Assuming costs were much the same in the previous year, this suggests that the current overall level of cost recovery is around 35 per cent. The estimated shortfall is expected to grow to a ten year average of $11.3 million per annum. A research report conducted by Deakin University for Parks Victoria identified that the camping and roofed accommodation product was an underperforming area and that key management issues with the camping products were: • Under performing financially with only partial cost recovery achieved in existing pay for use parks • Complex pricing and terms & conditions that are not standardised across the park estate • Inconsistent pricing in relation to services and facilities offered in the park • Inconsistent quality and service delivery across the park estate • Structured in a way that does not easily facilitate high quality and effective marketing to maximise yield 4 Furthering this, the key issues with the current pricing regime were found to be the following: • The majority of campsites are available to be accessed at no cost by the public, with only 24 out of the 133 parks that offer camping operating on a fee for service basis • Fees vary across and within parks. There are currently twelve pricing levels for camping, with site fees ranging from $5.60 to $48.00 per night • Existing fee structures with a base rate plus additional persons are difficult to enforce and administer leading to fee evasion, non-compliance and revenue leakage 4 Deakin University, 2010, op. cit. 4 Victorian National Parks Camping and Accommodation Fees RIS • Current camping fees have an inconsistent and unstructured relationship with the level of service provided and are generally applied at high visitation sites or where collection is easiest • There are inconsistencies in the camping fees charged for peak, shoulder and off peak season5 The camping fees pricing structure currently employed in Victoria’s parks does not align with the Government’s cost recovery principles, cost neutrality principles or DEPI’s pricing policy for public land. By providing camping facilities at costs much lower than market prices Parks Victoria is at risk of distorting the market. Additionally, Parks Victoria is operating at a significant deficit through the provision of camping product below cost recovery levels. Due to specific provisions in the Act, camping fees in national and state parks can only be set or changed through a ministerial determination. For this reason, intervention through some form of regulation is necessary in the case of any fee changes. 2.1.1 Increased revenue for regulatory activities If the determination to raise and extend the level and application of camping fees was not made, Parks Victoria would be unable to sustainably provide camping and accommodation facilities, services and associated assets in parks. The current financial model is inconsistent with the principle of cost recovery and creates a need for government funding, resulting in the subsidisation of camping product by non-users of the facilities. 2.2 Objectives of government intervention The Government’s objective is to encourage the use of our parks by a wide spectrum of the community by providing safe and accessible camping and accommodation facilities and services expected by the community. The objective of the proposed determination is to prescribe fees which implement the user pays principle to ensure the sustainable provision of camping and accommodation facilities and services in all national and state parks. The determination is consistent with cost recovery principles. Government intervention provides a consistent, fair and transparent user pays approach to for service activities on the public land estate. 5 Ibid. 5 Victorian National Parks Camping and Accommodation Fees RIS 3 Context This chapter sets out the context for the determination, including the current legislative framework, the current fee structure for Victorian camping and accommodation, the policy context, the roles of key stakeholders and inter-jurisdictional approaches. 3.1 Legislative framework The proposed fee determination to be made by the Minister will come under Section 21 (2) of the Act. The determination applies to permits issued under Section 21 (1)(a) of the Act and is supported by subordinate legislation, the National Parks Regulations 2013 (the Regulations), which have been made under the authority of Section 32AA, 37 and 48 of the Act. 3.1.1 Legislation The purpose of the Act is to establish the statutory basis for the protection, use and management of Victorian national and other parks, covering nearly 3.45 million hectares. The objectives of the Act are listed in the box below. Box 3.1: Objectives of the National Parks Act 1975 The objectives of the National Parks Act 1975 are: a) To make provision, in respect of national parks, state parks, marine national parks and marine sanctuaries: i. For the preservation and protection of the natural environment including wilderness areas and remote and natural areas in those parks; 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; iii. For the study of ecology, geology, botany, zoology and other sciences relating to the conservation of the natural environment in those parks; and iv. For the responsible management of the land in those parks; aa) To make further provision in respect of designated water supply catchment areas in national parks: i. For the protection of those areas; ii. For the maintenance of the water quality and otherwise for the protection of the water resources in those areas; and iii. For the restriction of human activity in those areas for the purposes of subparagraphs i and ii. ab) To make provision in respect of wilderness parks : 6 Victorian National Parks Camping and Accommodation Fees RIS i. For the protection, enhancement and management of those parks as wilderness so as to maximise the extent to which those parks are undisturbed by the influences of the European settlement of Australia; ii. For the protection, preservation and evolution of the natural environment including indigenous flora and fauna and of features of ecological, geological, scenic, archaeological and other scientific significance; iii. For the use and enjoyment of those parks by the public for inspiration, solitude and appropriate self-reliant recreation; and iv. For the study of ecology, geology, botany, zoology, archaeology and other sciences relating to the environment in those parks; b) In respect of ‘other parks’: i. To make provision, insofar as is appropriate to each such park, for the protection and preservation of indigenous flora and fauna and of features of scenic or archaeological, ecological, historical or other scientific interest; and ii. Subject to such provision as is made under subparagraph (i), to make provision for the public to observe, experience or otherwise become acquainted in those parks with the countryside and rural skills activities and pursuits and for carrying on, in those parks and for those purposes, agricultural, horticultural, or other agrarian projects and botanical, biological, ecological, geological, zoological, or other scientific studies or projects; and c) To make provision in accordance with the foregoing for the use of parks by the public for the purposes of enjoyment, recreation or education and for the encouragement and control of that use. Section 21 (2) of the Act prescribes that the Minister may determine from time to time the terms, conditions, charges and fees to which permits granted or that may be granted under subsection (1) are or are to be subject. Subsection (1) refers to granting a person a permit to occupy a building, camping place or other facility erected in the park for a period not exceeding six weeks. In addition, traditional owners who have recognised native title rights under the Native Title Act 1993 (Cth) or recognised traditional owner rights under the Traditional Owner Settlement Act 2010 (Vic), which include the right to camp, are exempt from paying camping fees in national and state parks located within their respective agreement areas. 3.1.2 The National Parks Regulations 2013 The National Parks Regulations 2013 (the Regulations) provide for offences in any parks within the meaning of the Act. The objectives of the Regulations are outlined in Box 3.2. 7 Victorian National Parks Camping and Accommodation Fees RIS Box 3.2: Objectives of the National Parks Regulations 2013 The objectives of the National Parks Regulations 2013 are— 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; b) to prescribe penalties for contravention of requirements in relation to occupation sites; c) to prescribe travelling allowances for members of the National Parks Advisory Council and advisory committees; d) to prescribe an area in Cape Howe Marine National Park in which a prescribed class of boat is prohibited; e) to prescribe the conditions for Ministerial approvals under section 45B of the Act; f) to prescribe other matters necessary or required to be prescribed under the Act. Division 2 of Part 9 of the National Park Regulations 2013 specifies that a person must not occupy an occupation site (building, camping place or other facility for which a permit under section 21(1)(a) of the Act may be issued) without a permit. 3.1.3 Regulated fees The fees for camping in national and state parks in Victoria are set by a Ministerial determination under Section 21 (2) of the Act. The published fees to be charged for the 2013-14 year are outlined in the table below. Note that, for ease of comparison, these fees are expressed as averages across various products within each service level category. For example, there are a number of fees for different products within the ‘Special’ category which, when averaged, amount to $16. Table 3.1: 2013-2014 camping fees as set under the National Parks Act 1975 (average prices per campsite night for each category)1,2,3 Service level Peak Rates Off Peak Rates Very high (powered) $55 $49 Very high (non-powered) $33 $30 High (powered) $34 $30 High (non-powered) $32 $29 Mid $22 $19 8 Victorian National Parks Camping and Accommodation Fees RIS Basic and very basic $0 $0 Special $16 $16 Source: Parks Victoria fee schedule, prices set on a per site per night basis 1 Note: Peak period rates apply from the Melbourne Cup Weekend to the last Sunday in April inclusive, and also 2 for the September school holidays. Special refers to site specific characteristics and special offerings such as the 3 Great Ocean Walk. For ease of comparison, these fees are expressed as averages across various products within each category of service level/type. 3.2 Victorian camping and accommodation Approximately 40 per cent of the State is public land, managed for the shared benefit of all Victorians (see Figure 3.1). This includes: • National Parks, State Parks and other parks – land managed and protected mainly for natural values under the Act • State forests – land protected and managed to balance a variety of uses and values under the Forests Act 1958 • Wildlife and Nature Reserves – land managed and protected under the Wildlife Act 1975 • other land reserved for a variety of public purposes, such as recreation, under the Crown Land (Reserves) Act 1978 • land owned or managed by the government, a local council, or other organisation and made available for public use • other land that is unreserved and which may in some cases be sold or occupied through the issue of various types of leases and licences under the Land Act 1958 About 4 million hectares of forests and parks are national parks and other conservation areas (wilderness, state and regional park and reserve areas) managed mainly for their natural values. Parks provide Victorians with opportunities for recreation, tourism and enjoyment of open space, while protecting significant environmental features, ecosystems and landscapes. Forests and parks are managed for the benefit of all Victorians. The sustainable management of forests and parks is central to protecting Victoria’s precious natural environment and biodiversity while providing opportunities for Victorians to enjoy the benefits. In managing this estate as one of our significant environmental and natural assets, the government responds to a wide range of community concerns and interests and balances the need for environmental protection with appropriate use. Management approaches for forests and parks vary with the purpose and use of that land. The management of pristine, natural areas and national parks which are managed mainly for conservation differs from the management of other areas, such as our forests and beaches, which are managed for a range of uses, including recreation and commercial uses. This means that land management practices aim to strike a balance to ensure that the use of that land always provides a net benefit to the public. This balance aims to ensure that public values are protected while community access is enhanced. 9 Victorian National Parks Camping and Accommodation Fees RIS Figure 3.1 Nature and extent of forest, parks and reserves in Victoria Source: DSE 2012 Parks Victoria operates camping and roofed accommodation sites across a range of land classifications including national parks, State parks, Crown land and coastal parks. This is broken down as follows: • 24 fee/permit parks, including 109 campgrounds • 109 non-fee for service parks, including 571 campgrounds • Six parks which offer different types of accommodation including cabins, huts, cottages, lodges and wilderness retreats In 2005, Parks Victoria adopted the Levels of Service Framework Policy which allocates a service level to each park based on the facilities and services available at the site. There are five service levels, ranging from ‘very basic’ to ‘very high’. The facilities associated with each service level were decided based on over 10,000 visitor surveys completed by Parks Victoria over a ten year period. The surveys gauged from visitors which particular facilities were deemed as important. A detailed outline of the facilities associated with each service level is provided in Appendix C. In applying the Levels of Service Framework Policy to camping product, the proposed facilities associated with each level of campsites were determined, as outlined in the table below. 10 Victorian National Parks Camping and Accommodation Fees RIS Table 3.2: Camping service level categories Category Very high-permit camping High-permit camping Mid-permit camping Basic & very basic Special fees Product Features • • • • • • • • • • • • • • • • • • • • • • • • • • • • Fully serviced Hot showers Full time ranger presence Sewer toilets Designated campsites Booking service Treated drinking water Unique location Laundry facilities Partially serviced Regular ranger patrols Mostly septic/sewered toilets Some showers Designated sites Booking service Unique location Some drinking water Partially serviced Infrequent ranger patrols Booking service Pit/composting toilets Mostly undesignated sites No showers Un-serviced Minimal ranger patrols Pit or no pit toilets Typically no booking service Distinct characteristics and product offer such as boat based camping or overnight walking Source: Deloitte 2011 3.2.2 Historical fees Table 3.3 shows the camping fees charged by Parks Victoria over the past four years. The fees have been allocated to campsite service levels in alignment with the fee groups represented in the current Parks Victoria fee schedule. Parks which fall into each service level are detailed in Appendix C. 11 Victorian National Parks Camping and Accommodation Fees RIS Table 3.3: Historical camping fees (peak) by service level category (per campsite night) Service Level 2008-09 2009-10 2010-11 2011-12 $22.30 $22.80 $23.30 $23.80 High-permit camping $16.00 $16.50 $17.00 $17.50 2 $13.00 $13.50 $14.00 $14.50 Very high-permit camping Mid-permit camping Basic & very basic 1 3 Special fees $0.00 $0.00 $0.00 $0.00 Varied Varied Varied Varied Source: Parks Victoria fee schedule 1 Notes: These prices are the average of Cape Conran, Wilsons Promontory and Mt Buffalo National Parks. 2 Fees are charge for many campsites in this category although there are a number where fees are not currently 3 charged Almost all campgrounds in the ‘basic and very basic’ service level category are currently provided free of charge. 3.2.3 Terms and conditions Under the current pricing system, there are numerous terms and conditions that influence the price charged to different groups of people at different times. The new pricing structure will seek to standardise these terms and conditions across the national and state parks. The current terms and conditions include: • Peak, off peak and shoulder periods are applied around the state. Currently these time periods differ by location and occasionally by service level offered • Standard booking terms vary across the state. Parks Victoria currently uses a mix of site based and per person based fee structures which are complex, difficult to enforce and administer leading to fee evasion, non-compliance and revenue leakage 3.3 Policy context The Government is determined to ensure the sustainability of providing camping and accommodation services and facilities on public land. To do so, it is intended that fees will be introduced for all camping and accommodation and increased as necessary in Victorian national and state parks through a ministerial determination, consistent with the principles of cost recovery. 3.3.1 Public land policy Victoria’s forests and parks provide enormous environmental, social, cultural and economic benefits to all Victorians. These include providing ecosystem services; providing recreational and health benefits to the public; offering opportunities for indigenous peoples to maintain connection to country; and supplying economic needs of the community reliant on public land resources such as apiary, grazing and tourism opportunities. 6 There are many flow-on economic benefits associated with these industries, particularly the tourism industry. Visitors often spend money on accommodation, transport, catering and related tourism infrastructure, providing significant benefits to surrounding local communities. 6 DSE, 2012, op. cit. 12 Victorian National Parks Camping and Accommodation Fees RIS Parks Victoria estimates that the Grampians, Port Campbell and Wilsons Promontory national parks alone contribute $487 million annually to the state’s economy. 7 Parks Victoria notes that there is also a strong correlation between the accessibility of parks, the physical and mental health of individuals, and the creation of a healthy and harmonious community. In this sense, camping facilities offer access to the national parks and the activities made available through this, including walking, fishing, mountain climbing, four wheel driving, caving, cycling and much more. Parks Victoria notes that the provision of this access to parks is vital in improving general community health as it allows individuals to experience ‘moments of respite in which to recharge’. 8 As a common community resource, the parts of the public land estate could be used excessively if government did not have a role in managing the use of activities, goods and services on the land through consents. The allocation of consents also seeks to ensure that those who receive private benefits from the use of, or access to, the land or natural assets, or who give rise to the need for regulation, pay an appropriate share of the cost. 9 3.3.2 Cost recovery Cost recovery through fees occurs on the basis of a user-pays system, whereby those who utilise services are obliged to pay for the cost of those services, rather than having them funded from general taxation revenues. Under full cost recovery through fees, the people who use the services are not being subsidised by the taxpayers who do not use the current services. The current Victorian Government policy is for fees and user charges to be set on a full cost recovery basis, consistent with the Victorian Government’s Cost Recovery Guidelines (summarised in the box below). Setting fees on a full cost recovery basis also aligns with DEPI’s Public Land Pricing Framework. Box 3.3: Cost recovery Cost recovery is the recuperation of the costs of government provided or funded products or services that, at least in part, provide private benefits to individuals, entities or groups, or reflect the costs their actions impose. The Victorian Department of Treasury and Finance has published Cost Recovery Guidelines that establish a framework to promote the development of appropriate cost recovery consistent with the Victorian Government’s vision of a best practice regulatory environment and transparent arrangements that promote efficient use of resources within the State. Victorian Government policy is for fees and user charges to be set on a full cost recovery basis as this ensures efficiency and equity objectives are met. 7 Parks Victoria 2003, The value of parks - the economic value of three of Victoria’s national parks: Port Campbell, Grampians, Wilsons Promontory, Parks Victoria, Melbourne 8 Parks Victoria, n.d., Camping in Victoria’s parks 9 DSE, 2012, op. cit. 13 Victorian National Parks Camping and Accommodation Fees RIS Appropriate cost recovery can improve the way that resources are allocated within the economy, thereby contributing to allocative efficiency (a situation where resources are allocated in a way that maximises the net benefit to society). Equity can have both horizontal and vertical dimensions. Horizontal equity refers to treating people in similar situations in similar ways. Vertical equity refers to those with greater means contributing proportionately more than those with lesser means. Allocative efficiency will be achieved when the value placed on the ability to camp in Victoria’s national and state parks by users equates to the cost of resources used up in production. By requiring payment for the camping product on the basis of cost recovery, Parks Victoria will be signalling to users the resources involved in its provision. If users are willing to pay the increased fees for camping, allocative efficiency would have improved. Applying the principles outlined in the box above, in the case of camping and accommodation fees, horizontal equity would imply that the fees to cover the services provided in Victoria’s parks are equivalent to fees charged for similar services. This means consistency in fees across all camp sites in Victoria’s parks and on other public land and similar services offered by private providers. Vertical equity may imply that individuals on low incomes would contribute less to the overall cost recovery than those with higher incomes, although DEPI does not, and is not planning to offer concessions for camping and roofed accommodation facilities in national parks. Vertical equity can be achieved by the provision of a range of camping and accommodation types in parks which offer accessible ways for all Victorians, regardless of income, to value, act and enjoy national and state parks. 3.3.3 Competition Benchmarking was undertaken by Deloitte in 2010 to determine if the provision of camping and accommodation facilities was consistent with similar services offered on private land. The results of the benchmarking suggested that some facilities are currently being offered at a lower rate than by some private providers, although comparable services were difficult to determine for the lower service level categories. Benchmarking is also useful to determine the market rate for particular services offered in parks and to identify if adjustments are needed to avoid any anti-competitive outcomes. 3.3.4 DEPI Pricing Framework DEPI has developed a Pricing Framework to be applied to all licence, lease, permit and fee for service activities which take place on public land within DEPI’s portfolio. The objective of this Framework is to provide a consistent, fair and transparent approach to pricing that complies with government policy of cost recovery, regardless of land tenure or management arrangements. 10 The Framework also aims to facilitate a more streamlined and simplified decision making process. The Pricing Framework is outlined in Figure 3.2 below and discussed in more detail in Appendix B. 10 Ibid. 14 Victorian National Parks Camping and Accommodation Fees RIS Figure 3.2 DEPI’s Pricing Framework for public land Source: DEPI 2013 3.4 Role of key stakeholders The Secretary of the Department of Environment and Primary Industries is responsible for the management of land under the Act. Parks Victoria is the key land management service provider for the parks and reserves estate. Victoria’s public land estate management agencies are seeking to achieve the following outcomes: • Deliver community benefits from Victoria’s public and private land assets 15 Victorian National Parks Camping and Accommodation Fees RIS • Effective social and environmental policy and regulation to deliver sustainable outcomes and protection for future generations • A reasonable return on the exclusive use of public land estate assets, conferred through a range of consents 11 3.4.1 Department of Environment and Primary Industries (DEPI) DEPI is Victoria’s lead environmental policy agency whose core purpose is to set the standard for the management of natural resource protection and use. One of their primary responsibilities is to enhance the value of Victoria’s parks and forests. In addition to this, key DEPI responsibilities include: • Efficiently managing water resources • Reducing the impact of major bushfires • Providing effective stewardship of the environment • Increasing community benefits from Victoria’s public land assets • Adapting effectively to the impacts of climate change • Providing high quality land and property information services 12 DEPI delivers the management of the State’s National and State parks in partnership with Parks Victoria. The delegation of responsibilities between the two bodies is set out in a management agreement. 3.4.2 Parks Victoria Parks Victoria is a statutory authority and was established under the Parks Victoria Act 1998. Under the Act, Parks Victoria is responsible to provide services to the State and its agencies for the management of parks, reserves and other public land. Subject to ministerial approval, it may also provide land management services to owners of private land used for public purposes. Parks Victoria is governed by a Board of up to nine members including the Chair. All board members are appointed by the Governor in Council on the recommendation of the Minister. The Board is accountable to the Minister for the performance of Parks Victoria and its operational direction. It is also accountable to the Secretary of DEPI and the Department of Transport for the delivery of services. The Board recommends to the Minister the appointment of a Chief Executive to whom it delegates the day to day management and administration of Parks Victoria. Parks Victoria is responsible for managing, protecting and enhancing the value of parks across a diverse estate of public land, covering more than four million hectares. The key principle, ‘Healthy Parks Healthy People’ (HPHP) is at the core of all Parks Victoria activities. This aligns community wellbeing with access and enjoyment of parks. Under the Health Parks Healthy People framework, all Victorians are encouraged to enjoy the free access to parks and reserves in order to improve their general wellbeing. 11 Ibid. 12 DSE website, 2012, What We Strive For 16 Victorian National Parks Camping and Accommodation Fees RIS Increased access to the parks and reserves, however, must be achieved in a sustainable manner in order to align with other Parks Victoria goals such as protecting the environmental values for current and future generations. 3.5 Alternative providers There are a variety of different approaches to fees charged for camping in parks and reserves in the States and Territories. Similarly, private providers also offer camping opportunities in many locations across Victoria. In addition to this, Victoria’s parks currently have a number of private operators who run camping and leased accommodation through lease and licence arrangements. These include lightstations (Point Hicks, Otway and Nelson) as well as Port Campbell Caravan Park and Princes Margaret Rose Caves. The average fees charged by inter-state governments and Victorian private providers are explored in the sections below. 3.5.1 Inter-jurisdictional comparison The following section outlines the approach taken to camping provision in national and state parks by New South Wales and South Australia. It is not known whether the current subsidy level received by these states to provide camping or weather the fees are set to achieve full cost recovery. New South Wales: Camping grounds in NSW national parks are managed by NSW National Parks and Wildlife Service (NPWS). NPWS is a part of the Office of Environment and Heritage within the NSW Department of Premier and Cabinet. The governing legislation for camping fees in NSW public parks is the National Parks and Wildlife Act 1974 and the National Parks and Wildlife Regulation 2009. While NPWS provides and operates the majority of visitor facilities and accommodation situated on public land, a selection of accommodation opportunities are established and run by the private sector in a landowner/lessee relationship 13. NPWS regulates this through legally enforceable leases, licences and contracts which align with the NPWS Visitor Accommodation Policy 14. NPWS sets their camping pricing structure for visitor facilities and services across parks has been established in alignment with several principles, including: • Achieving cost recovery • Ensuring a user pays system • Decentralised system of fee and price setting for many products • Local retention of revenue • Recognition of NPWS’s role in building awareness and understanding of conservation in the community 15 Currently NSW charges camping fees in 146 (out of 279) parks. The range of camping fees charged by NPWS is outlined in Table 3.4 below. 13 New South Wales Taskforce on Tourism and National Parks, 2008, Final Report 14 NSW National Parks and Wildlife Service, 2010, Visitor Accommodation Policy 15 New South Wales Taskforce on Tourism and National Parks, 2008, Final Report 17 Victorian National Parks Camping and Accommodation Fees RIS Table 3.4 New South Wales camping fees on public land Type of fee Fee range Adult fee (per night) $5-$10 Child fee (per night) $3-$5 Vehicle fee (per night)* $20-$40 Source: NSW Taskforce on Tourism and National Parks, 2008 Notes: Some camping fees are in addition to daily vehicle entry fee South Australia: Camping in South Australia’s parks and reserves is the responsibility of the Department of Environment, Water and Natural Resources (DEWNR). South Australian camping fees are set by the relevant Minister under the authority of Section 43 C of the National Parks and Wildlife Act 1972. Fees apply for camping in South Australia’s national parks and reserves. These fees are charged on a vehicle per night basis, with the charges reflecting the park’s maintenance costs and the level of services provided (Parks SA 2012). The camping fees also vary on the vehicle type, with different prices charged for cars, motorcycles and hikers/cyclists. There are over twenty types of camping service levels currently offered in South Australia, from campsites accessible by foot only to wilderness retreats. Current annual passes for South Australian camping is costed as follows: Table 3.5: South Australian park entry and camping fees Pass name Multi Park Pass with camping Pass entitlements 12 month unlimited entry and camping (for periods of up to five nights at a time in any one place in a designated campsite) in all parks excluding Desert Parks and Flinders Chase National Park Holiday Pass with camping Two months unlimited entry and camping( for periods of up to five nights at a time in any one place in a designated campsite) in all parks excluding Desert Parks and Flinders Chase National Park Desert Parks Passes 12 months unlimited entry and camping (where permitted) to a series of Desert Parks. Also a comprehensive 4WD handbook and maps, hints, tips and attractions Cost Vehicle: $165 Second vehicle: $80 Concession: $130 Vehicle: $70 Concession: $60 Vehicle: $150 Renewal: $90 18 Victorian National Parks Camping and Accommodation Fees RIS Single Park Pass 12 months unlimited entry and camping (for periods of up to five nights at a time in any one place in a designated campsite) in a single park of your choice Vehicle: $110 Second Vehicle: $55 Concession $85 Source: Parks SA, 2012 Inter-jurisdictional benchmarking In 2011 Deloitte undertook a benchmarking analysis of the fees charged for camping in national parks by Victoria compared to similar camping provision in other States and Territories. Product benchmarking of Victorian camping and accommodation prices against comparable public sector offerings across Australian states and territories suggested that the current Victorian pricing structure is comparatively lower than those in New South Wales, Queensland and Tasmania. Conversely, it is marginally higher than those of South Australia, the Northern Territory and Western Australia. 3.5.2 Private providers Desktop research was used to determine fee benchmarks for private providers. Camping facilities were randomly selected and data on fees for powered and non-powered sites during off peak, shoulder and peak season was collated based on information publically available through providers’ websites. The camping facilities selected and their fees are provided in more detail in Appendix E. Whilst public camping facilities are classified from very basic to very high, a review of the private provider’s facilities demonstrated they were all in the very high category. This is due primarily to the amenities, including hot showers and flushing toilets, laundry, on-site staff, booking capacity, barbeque and kitchen facilities, and available drinking water. Additional facilities often included activities for children, such as playgrounds, games rooms, swimming pool and information on activities to do in the area, whilst some also had a small kiosk to purchase food and supplies. There is also a high degree of difference in the resources needed to provide camping and accommodation on public land compared with the majority of private camping and accommodation products. As facilities on public land are often in remote locations, access to services such as electricity, water and rubbish/sewage collection is often not straightforward. In these cases, public sites must use expensive methods to provide the camping and accommodation facilities. Examples of this include generating power remotely or using a helicopter to remove rubbish and sewerage. These additional expenses may be an explanation for different fees between public and private providers. Table 3.6: Benchmarking select private provider's fees (prices per campsite night) Average per region Yarra Valley and Dandenong Ranges Peak powered Peak unpowered $36.00 $31.00 19 Victorian National Parks Camping and Accommodation Fees RIS Mornington Peninsula $39.75 $32.00 Goldfields, Daylesford & Macedon Ranges $38.67 $33.17 Phillip Island $57.50 $47.00 Great Ocean Road $48.50 $33.50 Grampians $35.33 $29.83 High Country $37.57 $32.33 Gippsland $38.00 $27.50 The Murray $38.38 $31.00 Wilson’s Promontory $51.67 $37.50 AVERAGE $40.55 $31.79 Source: Select private providers’ websites, 2012 prices An overview of Table 3.6 demonstrates that fees are, on average, higher for powered compared to unpowered camp sites, though both have access to the same level of other amenities and facilities. The regions with the highest fees include Phillip Island, Wilson’s Promontory and the Great Ocean Road at $57.50, $51.67 and $48.50 for a powered site in peak season respectively. A review of the facilities found that on average, there was no notable difference in facilities between those providers who charged higher than average and those who charged lower than average fees. The main difference in fees appeared to be based on location and proximity to points of interest, for instance beach access. In some instances, additional fees were charged for campsites with views. 3.5.3 Summary The following table demonstrates how current fees in Victoria’s parks compare to comparable inter-jurisdictional and private provider fees. The level of service categories have been used to allocate campgrounds to a particular category and ensure that they are compared on a like for like basis. Table 3.7: Summary of fees charged by alternative providers (Peak rates, average prices per campsite night for each category) Service Level Parks Victoria fees (2013-14) Inter-jurisdictional average fee (2013-14 estimate)1 Victorian private providers average fee (2012-13) Very high (nonpowered or powered) $33-$55 $50-$55 $32-41 $32 $43 NA $22 $25 NA High Mid 1 Notes: Estimate based on results of benchmarking analysis inflated to 2013-14 prices using CPI. As indicated, fees for a powered site in Victoria are consistent with fees charged in national parks in other jurisdictions, but higher than what is charged by private providers. As discussed earlier, this is influenced by the high levels of resources required to provide camping in remote locations. Fees for a non-powered site are broadly consistent with what is charged by private providers in Victoria but lower than what is charged in national parks 20 Victorian National Parks Camping and Accommodation Fees RIS in other jurisdictions. Fees for ‘High’ and ‘Mid’ standard sites are lower in Victoria relative to what is charged in national parks in other jurisdictions. 21 Victorian National Parks Camping and Accommodation Fees RIS 4 Financial analysis This chapter illustrates how the cost recovery calculations were undertaken to determine the fee levels charged for each service level offering. 4.1 Methodology 4.1.1 Determining costs In order to determine the costs associated with camping and accommodation facilities in parks and reserves, Parks Victoria, with assistance from Deloitte, undertook an analysis of camping and accommodation costs in 2008. The analysis was based on data from 200708. 16 Deloitte undertook further work in 2011 (2011 study) to update and extend the 2008 figures for the period 2013-14 to 2017-18, based on CPI and other known increases in expenses since then and projected into the future, as listed in Table 4.1. Note that some additional information has been added for 2012-13. Table 4.1: Assumed inflation rates from 2008-09 to 2012-13 and ongoing to adjust 2007-08 cost baseline* 2008-09 Motor vehicle expenses Employment expenses 5.0% 2009-10 5.0% 2010-11 2011-12 2012-13 2013-14 onwards 5.0% 5.0% N/A 5.0% 4.3% 4.3% 4.3% 3.5% N/A 2.3% Energy expenses 10.3% 20.3% 11.0% 8.3% N/A 7.0% Diesel fuel expenses 17.7% -19.7% 7.1% 9.9% N/A 3.4% ISR insurance premiums 21.1% 258.8% 15.0% 15.5% 20.0% 18.0% Motor vehicle insurance premiums 9.2% 11.0% -3.8% 44.2% N/A 15.0% Public liability insurance premiums 9% 73% 22% 22% 20.7% 29.0% Source: Deloitte (2011) Notes: *The energy and Diesel fuel expense inflation rates were based on Australian Bureau of Statistics Consumer Price Index data (discussed below). The other expense inflation rates were developed by Parks Victoria staff based on information from Parks Victoria systems and suppliers where necessary to best reflect the actual and expected changes in cost. Deloitte sought a view on potential price increases likely to arise from the carbon price and subsequently agreed with Parks Victoria some one-off cost increases for 2012/13 and 2015/16, i.e. energy fuel expenses (5%) and general expenses (1%). As the cost recovery model is calculated in real terms (2013-14 prices), the inflation rates for 2013-14 onwards were discounted by the projected Victorian Treasurer’s rate (2.25%). 16 A review of costs was required as costs associated with camping and accommodation facilities in National Parks managed by Parks Victoria are not easily identifiable from Parks Victoria’s financial systems and annual reporting. This is because the financial cost centres are at the park level only, and do not delineate between costs associated with day visitors, costs associated with general flora and fauna management and costs associated with camping and roofed accommodation facilities. The review was a very resource intensive exercise so has not been repeated since 2008. 22 Victorian National Parks Camping and Accommodation Fees RIS The assumed inflation rates for 2013-14 onwards were determined as follows: • Motor vehicle expenses – Parks Victoria typically budget for a 4-6 per cent increase in fleet costs per year. Fuel costs and maintenance are the main drivers of cost increases. As such, this analysis assumes an average increase in motor vehicle expenses of 5 per cent per annum • Employment expenses – Labour costs for Parks Victoria have increased over recent years (approximately 4.3 per cent per annum from 2008 to 2010) due to salary increases in the Parks Victoria Enterprise Bargaining Agreement (EBA) 2008. Labour costs are expected to further increase in line with the Parks Victoria Enterprise Bargaining Agreement (EBA) 2013. However, according to the Cost Recovery Guidelines ‘the Government’s wages policy … clearly states that EBAs must not result in reductions in services or increases in (cost recovery) charges’. 17 Rather, such cost increases should be funded through cost savings arising from sustainable productivity improvements or the implementation of good management practice. As such, this analysis assumes only a modest increase in employment expenses of 2.3 per cent per annum consistent with the Victorian Treasurer’s rate over recent years (i.e. no increase in ‘real’ terms after 2012-13) • Energy expenses – Based on the average price increase of electricity over the ten years to June 2012, the price of electricity is assumed to increase by 7.0 per cent per annum. 18 Note that a ten year time horizon is used because price increases in recent years, which mostly reflect the cost of network upgrades, are not likely to be as high over the medium term • Diesel fuel expenses – Based on the average price increase of automotive fuel over the five years to June 2012, the price of diesel fuel is assumed to increase by 3.4 per cent per annum 19 • Insurance premiums – Based on average Parks Victoria insurance premium increases over the four-five years to June 2013, the price of ISR, motor vehicle and public liability insurance premiums are assumed to increase by 18 per cent, 14 per cent and 29 per cent per annum.20 According to Parks Victoria, it is reasonable to assume that these large annual increases will continue into the future due to increasing risks associated with fire and flood events 21 As the cost recovery model is calculated in real terms (2013-14 prices), the inflation rates for 2013-14 onwards were discounted by the projected Victorian Treasurer’s rate (2.25%). 17 Department of Treasury and Finance (DTF), 2010, op. cit., p. 34 Australian Bureau of Statistics, 2010, Consumer Price Index, Australia, Sep 2012, Cat no. 6401.0, Table 12, Melbourne, ABS website, accessed 6 December 2012, http://www.abs.gov.au/AUSSTATS/abs@.nsf/DetailsPage/6401.0Sep%202012?OpenDocument 18 19 Ibid. 20 Note that the calculation of the average for ISR insurance excludes the 2009-10 increase as this is regarded as anomalous. 21 It is important to note that the cost of insurance represents a relatively small share of the overall cost base. As such, the estimation of the cost base is not sensitive to assumptions over future insurance premium price increases. 23 Victorian National Parks Camping and Accommodation Fees RIS The 2011 study also involved the inclusion of additional costs identified by Parks Victoria as necessary to support the adoption of the proposed pricing framework and implementation of new pricing strategies. These additional costs included: • Service level improvement costs that will be incurred to ensure that service levels meet environmental, health, risk and market expectations • Incremental operating costs that will be bookings/payments • Reform implementation costs, such as signage and visitor information • Additional asset maintenance costs necessary to maintain existing and improved assets to a higher level of standard than they are currently maintained • Additional annual depreciation and capital asset charges • Capital spending on essential asset refurbishment and replacement to select campgrounds and a new online booking system to manage customer bookings and payments and improve compliance incurred in light of increased The cost estimates used for the purposes this RIS are based on those developed for the Deloitte 2011 study. 4.1.2 Cost recovery and fee analysis The methodology for the cost recovery analysis for this RIS was as follows: • Review Deloitte 2011 study report and accompanying financial model and make any necessary changes to ensure it is up to date with DEPI’s proposed pricing approach and requirements in the Cost Recovery Guidelines 22 • Estimate the cost base according to average annual costs over the ten year period 2013-14 to 2022-23, including direct costs, corporate costs, depreciation costs, the opportunity cost of capital (‘capital asset charge’ assumed to be 7 per cent) and capital investment costs. Calculate costs separately according to Parks Victoria’s proposed Level of Service Standard • Calculate fees under each of the options • Estimate maximum potential revenue, expected yield and expected revenue shortfall under each option • Compare proposed fees with existing fees 4.1.3 Scope of analysis The scope of the proposed fee determination is for camping and accommodation in all parks under the Act. Camping is also permitted in areas of public land which are governed by the Crown Land (Reserves) Act 1978 and the Forests Act 1958, and unreserved Crown land. While it is expected that fees for these camping grounds will also be brought into alignment with the pricing framework and cost recovery guidelines, this will be addressed through amendment to the relevant legislation and regulations in the future. 22 Ibid. 24 Victorian National Parks Camping and Accommodation Fees RIS Note, however, that the analysis of costs and revenues outlined in this RIS includes the costs of providing camping and accommodation facilities in parks/reserves governed by the Crown Land (Reserves) Act 1978 (as managed by Parks Victoria) as well as those governed by the Act, consistent with the study undertaken by Deloitte in 2011. Given that government’s broader objective is to charge consistent fees for camping and accommodation across the State – that is, regardless of whether the facilities are in parks/reserves governed by the Act, the Crown Land (Reserves) Act 1978, the Forests Act 1958 or unreserved Crown Land – it was necessary to include the costs of non-National Parks Act camping and accommodation facilities in the analysis. Including these costs as part of this RIS avoids the need to update the pricing framework in the future when fees for non-National Parks Act camping and accommodation are also brought into alignment with the new arrangements. 23 Note also that the proposed fee determination does not cover privately owned or operated caravan parks, public land managed under other Acts or any other private sector investment in tourism infrastructure on public land. Victoria’s parks currently have a number of private operators who run camping and leased accommodation through lease and licence arrangements. 4.1.4 Limitations Some limitations with the cost recovery and fee analysis are outlined as follows: • Due to limitations in data, the financial modelling does not reflect revenue from proposed booking fees (see Appendix A) or fees for select overnight hiker sites, namely Lower Glenelg NP Canoe Camp, Croajingolong Wilderness Coast Walk, Grampians, and Great South West Walk • The level of visitation in 2013-14 is based on data for 2012-13 where available (including forecast for the remainder of the year) and 2007-08 (most recent available for some campgrounds). This is regarded as being the best available data for projecting visitation over the next ten years. It is possible that visitation may change over that time due to factors such as population growth. However, it is also possible that visitation may not increase due to supply constraints. Given uncertainty on this question, and the lack of data to form the basis for any growth assumptions, there is no basis to assume any natural increase above these base levels. Note, however, that visitation is assumed to increase by 1 per cent per year (non-compounding) starting from 2013-14 to account for the planned infrastructure upgrades, which are designed to boost visitation. The modelling assumed that these upgrades will occur progressively over the ten year period as funds become available, rather than up-front • Costs associated with camping and accommodation facilities in parks/reserves managed by Parks Victoria are not easily identifiable from Parks Victoria’s financial systems and annual reporting. This is because the financial cost centres are at the park level only, and do not delineate between costs associated with day visitors, costs associated with general flora and fauna management and costs associated with camping and roofed accommodation facilities. In light of this, Parks Victoria, with assistance from Deloitte, undertook a detailed analysis of camping and accommodation 23 Note that the analysis of costs does not include camping and accommodation facilities managed by DEPI (includes some facilities in parks/reserves governed by the Crown Land (Reserves) Act 1978 and all facilities in parks/reserves governed by the Forests Act 1958) as these data were not available during the preparation of this RIS. 25 Victorian National Parks Camping and Accommodation Fees RIS costs in 2008, which was based on data from 2007-08. Data from the 2008 analysis was used as the basis for the cost recovery and fee analysis outlined in this RIS, but the 2008 cost data was inflated to provide cost estimates for the period 2013-14 to 2022-23. This was based on CPI and other known increases in expenses since 2007-08. As such, the cost information provided in this RIS may not reflect current costs • For camping facilities in the ‘high’, ‘mid’ and ‘basic and very basic’ service level categories, the analysis assumes a minimum payment compliance rate of 60 per cent reflecting the status quo and a maximum payment compliance rate of 80 per cent in those years where an electronic payments system is assumed to be in place. These estimates are based on advice from Parks Victoria and their accuracy has not been verified by Deloitte. As such, the revenue yield estimates provided in this RIS may not reflect actual yield over the period of the analysis • It is possible that increases in existing camping and accommodation fees, plus the introduction of fees for campgrounds that are currently free, would result in a reduction in visitation, particularly in relation to those facilities where demand is already low. However, evidence from a study conducted by Deakin suggests that 81 per cent of potential visitors would be happy to pay a reasonable fee to camp, if they knew that the fees were based on the cost of maintaining camping facilities and that the revenue earned would be used to maintain and improve the environment and the camping facilities and services (see Appendix G). Given uncertainty on this question, and the lack of data to form the basis for any demand elasticity assumptions, there is no basis for which to quantify the potential impacts on revenue yield from camping and accommodation facilities. However, this is discussed in qualitative terms as a potential impact of some of the options • The cost base includes costs associated with customer services officers who are necessary in the absence of an on-line customer booking and payment system. These costs are assumed to apply throughout the entire 10 year period of analysis. It is possible that fewer customer service officers will be required once the payment system is implemented, which is assumed to occur half way through the ten year period (i.e. July 2018). However, it is not clear whether this would be the case. As such, the cost estimates for 2018-19 onwards have not been adjusted accordingly. In the instance that costs are likely to deviate significantly to those included in the cost base outlined in this RIS, DEPI would amend fees accordingly • The fees outlined in this RIS are for camping and accommodation facilities located in parks governed by the Act. The government also intends to introduce similar fees for camping and accommodation facilities located in parks and reserves governed by the Crown Land (Reserves) Act 1978, the Forests Act 1958 or unreserved Crown Land. However, this will occur at a later stage. In the interim, therefore, facilities located in parks and reserves governed under these other legislative instruments will be cheaper and many campsites will still be free. This is likely to result in ‘leakage’ of visitation from facilities located in parks governed by the Act to facilities located in these other parks and reserves. In the absence of any information with which to predict the likely degree of visitation leakage, this has not been factored into the analysis for this RIS 26 Victorian National Parks Camping and Accommodation Fees RIS 4.2 Delivery costs The total cost of delivering the camping and accommodation product within Victoria’s national and other parks is estimated to be $17.8 million per annum. Currently only $6.5 million is collected in revenue from user fees and charges at 24 parks out the 133 parks providing camping. There is a high level of fee evasion/non-compliance of payment of fees at the majority of sites The estimated shortfall of $11.3 million is not sustainable. 4.2.1 Direct costs More than 80% of the costs incurred managing the camping and accommodation product within Victoria’s national and other parks are the on-ground cost of delivery. The largest proportion of direct costs are associated with the provision of staff. Park rangers, information officers and field services officers play a key role in delivering camping and accommodation. At high service sites, regular ranger patrols are undertaken on weekends; overnight through peak holiday periods. 4.2.2 Corporate costs 4.2.3 Servicing requirements Less than 7% of the total expenditure managing the camping and accommodation product is corporate overheads. These costs include staff directly involved in the delivery of camping and accommodation through bookings, support and general maintenance. Booking staff manage more than 47,000 booking and financial transactions for camping and accommodation products. The provision of camping and accommodation services and facilities improves the amenity of the site and minimises environmental impacts. Facilities and services include: • Provision of treated potable water • Provision of sewer/septic toilets, sullage pits, RV dump points, laundry facilities, baby change facilities. • Provision of waste refuse and recycling, litter management services, cleaning services • Provision of facilities for people with limited mobility • Campground access roads, trails, walking tracks, car and bus parking • Signage, visitor interpretative centres, campground maps, pre visit brochures and information • Picnic shelters and tables, children’s playgrounds, firewood, camp fire and BBQ facilities, horse yards, public telephones • Environmental management (pest plant and animal control), asset maintenance services, natural and cultural resource protection, management of tree risk Remote service delivery Many camping and accommodation sites are in remote locations and not connected to town grid utility services such as power, water, gas or sewerage services. As a result, major infrastructure services are needed to support these sites. These include remote power 27 Victorian National Parks Camping and Accommodation Fees RIS generation (for example Tidal River, Gabo Island, and Wilsons Promontory Lightstation), and water supply and treatment and waste water treatment services (for example Tidal River and Lake Catani campground in Mount Buffalo National Park). 4.2.4 Demand: Demand for camping is generally seasonal and with high occupancies correlating with the main holiday periods of Christmas, Easter, Labour Day and Melbourne Cup Day. Outside of the holiday seasons, high occupancy rates are also experienced on weekends during November, February and March. Camping annual occupancies vary between 1530% at its most popular locations, Lake Eildon National Park, Lower Glenelg National Park, Mount Buffalo National Park, Wilsons Promontory National Park, and Cape Conran Coastal Park. Accommodation occupancies vary with high annual occupancies at Tidal River (Wilsons Promontory National Park) and Cape Conran 60%-90% with higher occupancies during the off peak season when compared to camping. 4.2.5 Managing demand: Parks Victoria operates a ballot system to allocate campsites in four of the highest demand parks: Wilsons Promontory National Park, Croajingolong National Park, Great Otway National Park and Cape Conran Coastal Park. These systems ensure equity and access for all people who wish to stay at these high demand locations where demand exceeds supply over the peak holiday periods. Accommodation ballots are undertaken at Wilsons Promontory National Park and Cape Conran Coastal Park where demand far exceeds supply. 4.3 Current usage 4.3.1 Visitor profile A study conducted by Deakin University in collaboration with Parks Victoria found that the sample group of current visitors could be divided into four general clusters. These clusters are described as the following groups: • Regular ‘Prom’ camper: this group frequents Wilsons Promontory, usually sleeping in a large tent or in roofed accommodation. This group would be happy to pay a reasonable fee to camp, if they knew that the fees were based on the cost of maintaining camping facilities and would consider camping more frequently if camping facilities were upgraded • Older campers: are a group of pensioners and retirees who are generally on lower incomes but enjoy camping as it is thought of as a healthy activity. This group of campers feel that tax payers who do not use camping grounds in State and National parks should have to subsidise camping holidays for those that do. They are generally happy with the current camping facilities and do not compare prices between public and privately operated camping grounds 28 Victorian National Parks Camping and Accommodation Fees RIS • Middle class camping families: are wealthier than older campers and usually camp in groups of 3-6 people in large or medium sized tents. This group feels that some services and facilities in camping ground should be subsidised because State and National Parks are community goods. This group also strongly agrees with the need to charge camping fees to reinvest in camping ground and would not reduce the number of times they went camping if fees were introduced • Confirmed wilderness campers: enjoy camping in small or medium sized tents but are not prepared to pay very much to do so. They feel that camping should be subsidised because State and National Parks are community goods and that it is important to retain some free camping grounds The following graphs demonstrate some visitor profile trends found in the study. Chart 4.1 Number of separate trips to Victoria’s Parks (last three years) Source: Deakin University, 2010, Research report for Parks Victoria: Camping and Accommodation Product & Pricing, Figure 4.2.2 29 Victorian National Parks Camping and Accommodation Fees RIS Chart 4.2 Usual camping accommodation Source: Deakin University, 2010, Research report for Parks Victoria: Camping and Accommodation Product & Pricing, Figure 4.2.3 Chart 4.3 Location of last Victorian camping visit Source: Deakin University, 2010, Research report for Parks Victoria: Camping and Accommodation Product & Pricing, Figure 4.2.5 The study found the following visitor attitudes towards camping in national parks. 30 Victorian National Parks Camping and Accommodation Fees RIS Table 4.2 Camping and Accommodation important visitor attributes/attitudes: Most important attributes Attitudes towards fees Suggested areas for improvement • Litter management • The overall camping experience • A ranger available in an emergency • The actual campsite • Well marked walking tracks with signs giving directions. • Camping at a location that is unique • Reasonable campers should pay-user pays • Fees could escalate in proportion to facilities provided • Strong support towards fees being used for to upgrade and maintain facilities & environmental protection of areas close to camp sites • The number of visits would not be reduced if fees were increased or introduced • Provision of showers & toilets • Cleanliness of facilities • Safety • Better communication • Better cooking facilities & fireplaces • Provision of more cabins and a higher level of facilities • Refurbishment of park facilities to attract more campers 4.3.2 Importance of camping holiday attributes & motivation • Inexpensive holiday • To relax with family & friends • To get away from the city • To experience a unique part of the country • To provide a back to nature experience Visitation Information on visitation levels for camping and roofed accommodation facilities managed by Parks Victoria is provided in Table 4.3. The level of visitation is based on data for 2012-13 where available (including forecast for the remainder of the year) and 2007-08 (most recent available for some campgrounds). As indicated, campsite visitation is largely dominated by campsites in the Basic & Very Basic service level category, whereas roofed accommodation visitation is dominated by accommodation in the ‘Cabins’ and ‘Lightstations’ categories. Note that these figures reflect estimates of actual visitation so include patrons that may not have paid the required fee. The figures also reflect visitation for current non-fees-for-service facilities. Visitation is assumed to increase by 1 per cent per year (non-compounding) starting from 2013-14, and assuming the base visitation is consistent with the figures in Table 4.3. This is to account for the fact that the infrastructure repairs and replacements will occur slowly over the ten year period, rather than up-front. 31 Victorian National Parks Camping and Accommodation Fees RIS Table 4.3: Visitation by service level category Room/Campsite Nights Camping facilities Very High 53,738 High 31,545 Mid 40,858 Basic & Very Basic 567,819 Special 41,484 Roofed accommodation facilities Group Lodges 1,170 Huts 2,194 Cabins 8,081 Wilderness Retreats 1,556 Lightstation 4,677 Source: DEPI Notes: These figures reflect estimates of actual visitation so include patrons that may not have paid the required fee. The figures also reflect visitation for current non-fees-for-service facilities. The level of visitation in is based on data for 2012-13 where available (including forecast for the remainder of the year) and 2007-08 (most recent available for some campgrounds). Current costs 4.3.3 Figures on the estimated cost of providing camping and accommodation facilities in parks and reserves managed by Parks Victoria in 2011-12 are provided in Table 4.4. A description of the types of costs included in each of the cost categories is provided in Table 4.5. As indicated, the total cost is estimated to be $12.3 million ($9.7 million for camping facilities and $2.6 million for roofed accommodation facilities). Key drivers of the overall cost of camping facilities are direct costs associated with ‘Basic & Very Basic’ standard campsites (due to the large number of sites) and ‘Very High’ standard campsites (due to high visitation and a relatively high standard of service provided). Table 4.4: Estimated cost of camping and accommodation facilities in parks and reserves managed by Parks Victoria (2011-12, $million)1 Number of campgrounds Direct Costs Corporate Costs Depreciation Capital Asset Charge Total Very High 1 $1.56 $0.14 $0.09 $0.17 $1.96 High 13 $0.52 $0.09 $0.03 $0.04 $0.67 Mid 80 $0.90 $0.16 $0.02 $0.03 $1.10 Basic & Very Basic 521 $4.19 $0.29 $0.14 $0.28 $4.90 Special 65 $0.95 $0.07 $0.01 $0.02 $1.06 $8.11 $0.75 $0.29 $0.54 $9.69 Camping facilities Total Roofed accommodation facilities 32 Victorian National Parks Camping and Accommodation Fees RIS Group Lodges -7 $0.61 $0.04 $0.03 $0.08 $0.76 Huts -9 $0.22 $0.04 $0.01 $0.01 $0.28 Cabins -26 $0.72 $0.04 $0.07 $0.10 $0.94 Wilderness Retreats -14 $0.19 $0.01 $0.04 $0.05 $0.28 Lightstation -5 $0.27 $0.01 $0.02 $0.06 $0.36 $2.01 $0.14 $0.17 $0.30 $2.63 $10.12 $0.89 $0.46 $0.85 $12.32 Total Grand total Source: Deloitte, 2011, Parks Victoria: Camping and Accommodation Product Review – Update and extension of supplementary financial modelling for five years from 2013/14 to 2017/18; and accompanying Excel model. 1 Notes: These figures are estimates based on historic data from 2007-08. It is not possible to determine the costs of camping and roofed accommodation facilities on a regular basis as the cost centres in the financial reporting framework do not delineate between costs associated with day visitors, costs associated with general flora and fauna management and costs associated with camping and roofed accommodation facilities (i.e. cost centres are at the park level only). Parks Victoria, with assistance from Deloitte, undertook an analysis of camping and accommodation costs in 2008, which was based on data from 2007-08. This was a very resource intensive exercise so has not been repeated since 2008. However, Deloitte undertook a study in 2011 to update and extend the 2008 figures for 2013-14 to 2017-18, based on CPI and other known increases in costs since then and projected into the future. The cost estimates outlined in this table are based on the figures generated through that exercise. Table 4.5: Description of costs Cost category Direct Costs Description Base costs such as labour, lease expenses, water, energy, telecommunications and motor vehicle expenses and plant and equipment expenses Recurrent costs such as cleaning, administration, camp maintenance, emergency management, advertising and marketing, revegetation management, roads, rubbish, signage, park maintenance, visitor facility maintenance, toilet maintenance, tracks and trail maintenance (partial allocation to campers), transport services, visitor laundry, security and rd brochures, and commissions to 3 party distribution channels Corporate Costs Allocation of Commercial Services Division, general IT, public liability insurance, web access, 131963 Hotline, camping brochures, regional office costs, insurance premiums (ISR and vehicles), IT support calls, Summer Ranger Program, Camp Host Program Depreciation Annual depreciation charge which assumes a 30 year useful life for camping and accommodation assets based on advice from Parks Victoria Capital Asset Charge 7 per cent of the value of camping and accommodation assets Source: Deloitte, 2011, including related Excel model 4.3.4 Current revenues Figures on the revenue from camping and accommodation facilities in parks and reserves managed by Parks Victoria are provided in Table 4.6 for the three years to 2011-12. The total revenue from these facilities in 2011-12 was around $4.2 million, down from $4.4 million the year earlier due to the impact of severe floods. Around 58 per cent of the revenue in 2011-12 was earned from the camping product and the majority of the rest was earned from the accommodation product. Revenue from the various Wilsons Promontory product offerings accounted for 63 per cent of the total. 33 Victorian National Parks Camping and Accommodation Fees RIS Table 4.6: Revenue from camping and accommodation facilities managed by Parks Victoria (2009-10 to 2011-12) 2009-10 2010-11 2011-12 $1,608,038 $1,326,740 $1,381,394 $168,569 $201,450 $177,241 Mount Buffalo National Park $85,666 $83,320 $83,022 Grampians NP $41,350 $70,330 $94,307 Great Otway NP (Western) $3,913 $9,830 $9,295 Gippsland Lakes CP $4,904 $10,740 $6,465 Buchan Caves Reserve $72,020 $65,960 $71,538 Croajingolong National Park, Peachtree Reserve $13,524 $19,500 $20,054 $112,993 $113,920 $114,997 Lake Eldon National Park $75,534 $151,910 $143,666 Mount Arapiles-Tooan SP $38,149 $37,070 $22,810 $0 $34,420 $83,152 $18,260 $25,510 $24,505 $9,519 $14,470 $6,768 $46,360 $48,860 $53,775 Camping products Wilsons Promontory National Park Cape Conan CP Lower Glenelg NP, Mt Eccles, Discovery Bay Cathedral Range State Park Hattah Kulkyne NP Wyperfeld NP Upper Yarra Reservoir Little Desert NP $0 $0 $26,349 The Lakes National Park $16,705 $17,560 $12,950 Plenty Gorge Parklands $8,270 $12,310 $11,099 Ewing Morass W.R/Orbost $4,440 $9,120 $7,271 Yarra Valley Parklands $1,440 $14,540 $14,215 $0 $10,900 $14,668 $3,380 $11,000 $12,914 $0 $500 $12,637 $2,333,034 $2,289,960 $2,405,093 Great Ocean Walk $98,570 $99,230 $161,249 Total $98,570 $99,230 $161,249 Wilsons Prom $170,562 $127,230 $127,326 Cape Conran $63,926 $56,520 $62,973 Buchan Caves $24,800 $27,570 $28,171 $259,288 $211,320 $218,470 $1,816,284 $1,550,380 $1,119,285 $209,231 $212,400 $205,990 Buchan Caves Reserve $22,840 $23,380 $25,350 Gabo Island $22,630 $27,890 $22,439 $1,507 $1,370 $1,329 Kinglake NP Brisbane Ranges NP Other Total Walking Product Wilderness Retreats Total Accommodation product Wilsons Promontory National Park Cape Conan CP Murray Sunset NP 34 Victorian National Parks Camping and Accommodation Fees RIS Plenty Gorge $0 $0 $0 Total $2,072,492 $1,815,420 $1,374,394 Grand Total $4,763,384 $4,415,930 $4,159,206 Source: Parks Victoria 4.3.5 Current level of cost recovery As outlined above, the cost to Parks Victoria of the camping and accommodation facilities in parks and reserves under its management was estimated at $12.3 million in 2011-12. In the same year, the revenue earned from these facilities was $4.2 million, whereas in the previous year it was $4.4 million. Assuming costs were much the same in the previous year, this suggests that the current overall level of cost recovery is around 35 per cent. For camping facilities, total costs were around $9.5 million in 2011-12, whereas revenues were $2.6 million, suggesting that the current level of cost recovery for camping facilities is around 27 per cent. For accommodation facilities, total costs were around $2.7 million in 2011-12, whereas revenues were $1.6 million in 2011-12 and $2.0 million in 2010-11, suggesting that the level of cost recovery for accommodation facilities is around 60-75 per cent. It is important to note, however, that the analysis outlined in Chapter 7 suggests that, based on current scheduled accommodation fees for 2013-14 (which are higher than 2011-12 scheduled fees) and projected costs, the estimated revenue from the 2013-14 fees will be sufficient to recover the costs of accommodation facilities. 4.4 Forecast cost base Figures on the average annual cost of camping and accommodation facilities managed by Parks Victoria over the ten year period 2013-14 to 2022-23 are provided in Table 4.7. As indicated, the total annual average cost is $14.6 million for camping facilities and $3.2 million for roofed accommodation facilities. This gives a total cost base of $17.8 million per annum over the next ten years. Table 4.7: Ten Year Average annual cost of camping and accommodation facilities managed by Parks Victoria ($ million)1 Number of campgrounds Direct Costs Corporate Depreciation Costs Capital Asset Charge New Capital Spend Total Very High 1 $2.04 $0.23 $0.11 $0.17 $0.02 $2.58 High 13 $0.79 $0.15 $0.06 $0.06 $0.11 $1.18 Mid 80 $1.44 $0.20 $0.05 $0.06 $0.12 $1.87 Basic & Very Basic 521 $5.17 $1.00 $0.44 $0.39 $0.56 $7.57 Special 65 $1.22 $0.09 $0.03 $0.03 $0.02 $1.40 $10.67 $1.67 $0.70 $0.71 $0.84 $14.59 Camping facilities Total 35 Victorian National Parks Camping and Accommodation Fees RIS Roofed accommodation facilities Group Lodges -7 $0.67 $0.05 $0.03 $0.07 $0.00 $0.81 Huts -9 $0.27 $0.08 $0.01 $0.01 $0.00 $0.37 Cabins -26 $0.96 $0.06 $0.07 $0.10 $0.00 $1.20 Wilderness Retreats -14 $0.27 $0.01 $0.04 $0.05 $0.00 $0.37 Lightstation -5 $0.34 $0.02 $0.03 $0.06 $0.00 $0.45 Total $2.51 $0.22 $0.17 $0.29 $0.01 $3.19 Grand total $13.18 $1.89 $0.87 $1.00 $0.85 $17.78 Source: Deloitte analysis 1 Notes: Reflects the average annual cost of providing camping and accommodation facilities in parks and reserves managed by Parks Victoria over the ten year period 2013-14 to 2022-23. Figures are expressed in 2013-14 prices. These costs are higher than those listed above for 2011-12 for a number of reasons as follows: • Projected ‘real’ increases in prices (i.e. above inflation) relevant for certain cost items such as energy (due to network upgrades and the price on carbon), vehicle fuel and insurance premiums • Service level improvement costs that will be incurred to ensure that service levels meet environmental, health and risk standards, and become consistent with revised pricing framework, including additional site/facility maintenance, additional cleaning of facilities, asset maintenance, site orientation and protection works • Incremental operating costs that will be incurred in light of increased bookings/payments, including compliance, vehicles, uniforms, telephone and on-line bookings, third party commissions and camping guides • Reform implementation costs such as new signage, a camping information campaign and changes to meet environmental, health and risk standards • Additional asset maintenance costs, which covers the cost of maintaining existing assets Additional annual depreciation charge which assumes a 30 year useful life for upgrades to camping and accommodation assets and a five year useful life for the new online booking system • Additional capital asset charge of 7 per cent of the value of camping and accommodation assets and the new online booking system • Capital spending of $5 million for repairs and replacements for select campgrounds (Cape Conran Coastal Park, Gippsland Lakes Coastal Park, Great Otways National Park and Murray River Parks) over a ten year period, and $3.5 million for a new online booking system to manage customer bookings and payments. This capital expenditure is to be funded from increased fee revenue over the ten year period 2013-14 to 202223 and will occur incrementally over that period as revenue accrues to Parks Victoria 4.5 Efficiency of costs The efficiency of costs is discussed separately for camping and accommodation below. 36 Victorian National Parks Camping and Accommodation Fees RIS 4.5.1 Camping facilities Detailed figures on the estimated cost of providing camping facilities in parks and reserves managed by Parks Victoria for the 2013-14 financial year are provided in Appendix A. The table provided gives an indication of the different types of costs included in the analysis. As indicated, key drivers of the cost of providing camping facilities are labour, motor vehicle expenses, track maintenance, general recurrent costs, commissions to third parties, compliance, additional signage, information campaign, additional camping guides, additional maintenance, upfront implementation costs, general corporate costs, customer service costs, depreciation and the capital asset charge. A summary of the cost estimates for the 2013-14 year is provided in Table 4.8, separately for facilities in each of the different service categories. In general, costs are largely driven by base costs (such as labour, utilities, vehicles and track maintenance) and recurrent costs (such as general administration, cleaning and camp maintenance). However, for the ‘Mid’ and ‘Basic & Very Basic’ facilities, the cost estimates also include significant incremental operating costs projected to be incurred in light of increased bookings and payments for these facilities. This includes the costs of compliance, vehicles, booking services, commissions to third parties, signage, camping guides, maintenance (to bring facilities up to a fee-for-service standard) and upfront implementation expenses (e.g. costs associated with the marketing campaign and changes to meet environmental, health and risk standards). For the ‘Basic & Very Basic’ facilities, overhead costs are also relatively high due to additional customer service and corporate costs. Costs per campground are highest for facilities in the ‘Very High’ category due to the higher standard of service and the relatively high number of sites in the Tidal River campground. Costs per campground are lowest for facilities in the ‘Mid’ category due to the lower standard of service. Counter to what one would expect, costs per campground are not lowest for facilities in the Basic & Very Basic category due to the fact that these campgrounds tend to cover a much larger, more dispersed, area and have a larger number of sites per campground (e.g. Murray River Parks). Table 4.8: Summary of the estimated cost of providing camping facilities in parks/reserves managed by Parks Victoria (2013-14) Very High High Mid Basic & Very Basic Special Total % total Total cost Base costs $1.13 $0.24 $0.40 $1.19 $0.74 $3.70 30% Recurrent costs $0.43 $0.24 $0.41 $0.16 $0.18 $1.42 11% Incremental costs $0.17 $0.09 $0.37 $3.49 $0.14 $4.27 34% Overheads $0.14 $0.07 $0.15 $1.27 $0.07 $1.71 14% Depreciation and capital asset charge $0.26 $0.06 $0.05 $0.65 $0.04 $1.05 8% Other costs $0.00 $0.08 $0.15 $0.01 $0.04 $0.28 2% 1 11 113 337 71 533 Number of campgrounds 37 Victorian National Parks Camping and Accommodation Fees RIS Cost per campground Base costs $1,129,307 $21,427 $3,577 $3,530 $10,382 Recurrent costs $428,246 $21,682 $3,670 $461 $2,535 Incremental costs $172,792 $8,090 $3,310 $10,359 $1,959 General overheads $144,681 $6,722 $1,324 $3,777 $920 Other overheads $257,852 $5,708 $411 $1,917 $536 $1,339 $7,144 $1,304 $41 $513 $2,134,217 $70,772 $13,596 $20,084 $16,845 Other costs Total Source: Deloitte analysis As indicated in Chapter 7, in order for Parks Victoria to fully recover all of the projected costs of providing camping facilities in parks/reserves under its management (not accounting for lost revenues from a lack of payment compliance), fees must be set at a level higher than the average of what is charged for similar facilities on public land in other jurisdictions (referred to as the ‘market’ rate). In particular, most fees must be set at around 20 per cent higher (50 per cent higher for facilities in the ‘Mid’ category) in order to fully recover costs. This suggests that the level of costs of providing camping facilities in Victoria is high relative to the average of other jurisdictions. However, it is not clear whether the camping fees charged in other jurisdictions are set so as to fully recover all costs and, therefore, whether this is the most appropriate benchmark for efficient costs of providing camping facilities. Note that it is difficult to compare costs of providing facilities in the ‘Basic & Very Basic’ category as many jurisdictions do not charge fees for this type of service. 4.5.2 Accommodation facilities As indicated in Chapter 7, it would be possible for Parks Victoria to fully recover all of the projected costs of providing camping facilities in parks and reserves under its management if it were to charge fees consistent with the rate charged by private providers and public providers in other states (i.e. the ‘market’ rate). Using the ‘market’ rate as a benchmark for efficient costs of providing roofed accommodation facilities, this suggests that the costs of providing these facilities in Victoria are reasonably efficient. 38 Victorian National Parks Camping and Accommodation Fees RIS 5 Framework for options analysis This chapter introduces the framework for the analysis of options available to Parks Victoria in regards to revising the fee schedule for camping product in national parks managed by Parks Victoria. 5.1 The pricing framework The DEPI pricing framework provides a process for developing pricing structures compliant with government cost recovery policy in the public land context. The details of the pricing framework are outlined in Appendix B. 5.2 Approach for assessing the options Consistent with standard practice, options for the fees are assessed using multi criteria analysis (MCA). This allows for objectives other than efficiency (such as equity) to be assessed as part of the options analysis 24. Box 5.1: Multi criteria analysis MCA refers to a range of techniques to assess policy options against decision criteria. MCA enables options to be compared in a way that utilises quantitative and qualitative evidence fully. The approach enables the inclusion of a wider range of criteria — including social and environmental considerations for example — than used in a typical financial analysis. In addition, the approach is transparent — necessarily subjective judgements and assumptions made to determine options and criteria, and to assign scores and weights are made explicitly. The preferences of the decision maker reflected in these judgements and assumptions can be readily changed in a sensitivity analysis or to incorporate more robust indicators of community preferences. 5.2.1 Criteria Consistent with the objectives of encouraging the use of national and state parks while delivering increased revenue from camping and accommodation facilities and services, the following criteria will be used to assess the options: • 24 Efficiency: Assesses the degree to which the option is consistent with the efficiency objective of cost recovery. Includes consideration of: • The level of cost recovery • Whether the fees send the right signals to the public regarding the resources used to provide camping and accommodation facilities in national parks Victorian Competition and Efficiency Commission, 2011, Multi-criteria analysis (MCA) Guidance note 39 Victorian National Parks Camping and Accommodation Fees RIS • Equity: Assesses the degree to which the option is consistent with the equity objective of cost recovery. This criterion includes consideration of horizontal equity which in this case is interpreted in two key ways: • The degree to which the fees are aligned to services of a like quality. When fees do not accurately reflect the level of service provided, the degree of horizontal equity is low • The degree to which the fees reflect the user pays principle. When fees are set at a level that requires a significant taxpayer subsidy, the degree of horizontal equity is low • Effectiveness: Assesses the degree to which the option addresses other cost recovery issues. Includes consideration of: • Compliance and implementation issues (e.g. the fee structure is cost effective, simple, easy to implement and reduces levels of evasion etc.) • Consistency with other policy objectives – importantly those around encouraging the use of parks and reserves for all community members In analysing the effectiveness of an option, the data gathered through the Deakin research report for Parks Victoria will be used as a basis to predict compliance and the level of visitor drop off if fees were increased. This data is provided in detail in Appendix D. 5.2.2 Weightings In alignment with Victorian Competition and Efficiency Commission’s MCA Guidelines, weightings have been determined for each criterion to reflect their relative importance. The weights allocated to each assessment criterion are outlined in Table 5.1 below. Efficiency is weighted more heavily reflecting the importance of achieving cost recovery and a sustainable funding approach for Parks Victoria. Table 5.1 Weighting of assessment criteria 5.2.3 Criteria Weighting Efficiency 40 per cent Equity 30 per cent Effectiveness 30 per cent Scale The criterion rating scale has a range of –10 to +10, where a score of zero represents no change from the base case. The scale is outlined in Table 5.2 below. 40 Victorian National Parks Camping and Accommodation Fees RIS Table 5.2: MCA scale Score -10 -5 0 +5 +10 Description Much worse than the base case Somewhat worse than the base case No change from the base case Somewhat better than the base case Much better than the base case 5.3 Identified options The options assessed in this RIS are outlined as follows: • Current Fees (Base Case): Current fees for camping and accommodation facilities and services provided in national and state parks. • Option 1: Fees are based on achieving full cost recovery with the assumption of 100% compliance, and set according to the level of service of the facility provided. Fees between different service levels differ due to the different costs per visitation night (i.e. no cross subsidies between different service levels or accommodation types) • Option 2: Fees are based on rates charged by private operators (for accommodation only) or public providers in other jurisdictions (for both camping and accommodation). These are referred to as market rates • Option 3: Fees are based on improved revenue yield for camping and accommodation facilities and services. All fees achieve improved revenue generation, reflect differences in quality between the levels of service and are mindful of market rates. Roofed accommodation fees were also set in consideration of scarcity rents (Preferred Option) Cost recovery as a policy position was chosen for Option 1 to address the identified revenue shortfall in providing camping and roofed accommodation in parks. Cost recovery was chosen as it is encouraged in the Cost Recovery Guidelines. As this option was not expected to sufficiently reflect differences in quality, a market option (Option 2) was also included in the analysis. The market option was chosen as it was thought to reflect differences in quality better than the cost recovery option. The market price is important as users of roofed accommodation and campgrounds in the higher level of service are likely to consider alternative options provided by the private sector, and also to other campers who may consider camping on public land in other states, particular New South Wales and South Australia. A market approach using the benchmarking of similar offerings was also considered less arbitrary than other pricing options that could have been chosen. A mixed approach was also included as an option as it was expected that it may also balance the government’s objective of introducing a user pays principle to generate sufficient revenue from camping and accommodation in parks while reflecting differences in quality and minimizing potential changes to visitation levels in response to pricing. Other options such as a fixed subsidy below cost recovery or a voluntary system were not chosen 41 Victorian National Parks Camping and Accommodation Fees RIS due to their expected failure to meet the government’s objective and/or difficulties in enforcement. In addition, three key aspects were considered, as follows: • The degree to which the overall level fees reflects full cost recovery (referred to as full revenue yield recovery in the context of suboptimal payment compliance) • The degree to which relativities in fees reflect relativities in cost and/or quality between different levels of service • The degree to which the structure of fees is consistent across the State These aspects are discussed below. 5.3.1 Degree to which fees reflect full revenue yield recovery Option 1 achieves full revenue yield recovery, Option 2 achieves less than full revenue yield recovery and Option 3 achieves greater than full revenue yield recovery for accommodation. Under all of these options, the costs of non-payment compliance are not covered (i.e. those that pay the necessary fees are not subsidising those that don’t). The concept of full revenue yield recovery is discussed in more detail at the beginning of Chapter 6. The fees proposed under Option 3 which exceed cost recovery levels in some cases were set by Parks Victoria to align with DEPI’s pricing framework for public land which states that, under certain circumstances, it is possible for the Government to set prices at a level that is higher than cost recovery. In particular, Principle 2 of the policy states that scarcity rent, Where there is excess demand for a good or service, due to scarcity or a restriction on supply, prices should capture private benefits that exceed cost recovery. Scarcity rents – along with considerations over quality differences and consumer willingness to pay – were considered when setting fees across the 16 different roofed accommodation products. Where this principle was deemed relevant by Parks Victoria, fees for roofed accommodation were set at a level higher than the theoretical level of cost recovery. 5.3.2 Degree to which relativities in fees reflect cost and/or quality differences Under Option 1, relativities in fees reflect relativities in average cost per visitor night, i.e. fees are set so that cross subsidies between visitors who demand differing levels of service or products are minimised. Although this approach appears reasonable, fees are set according to average costs per visitor night, rather than marginal costs per visitor night. As such, for campsites with relatively low levels of visitation throughout much of the year, campers utilising these sites would be required to cover the costs of maintaining the sites throughout much of the year when they are mostly vacant. Under Option 2, relativities in fees are based on those implied by ‘market’ rates. Market rates were developed by Deloitte as an input to a camping and accommodation product analysis for Parks Victoria in 2010 and have been indexed by inflation for the purposes of this RIS. For the camping product, the ‘market’ rates were based on benchmarks for similar 42 Victorian National Parks Camping and Accommodation Fees RIS products around Australia, with a focus solely on camping facilities offered by the public sector. 25 For the accommodation product, the ‘market’ rates were also based on benchmarks for similar products around Australia, but the benchmarking included both public and private sector providers. All rates applied in the analysis were reviewed by Parks Victoria. It is not possible to determine whether relativities in the ‘market’ rates reflect relativities in the cost of providing these facilities by private providers and public providers in other jurisdictions. Under Option 3, relativities in fees reflect relativities in quality between different camping and accommodation products and, to some degree, the existence of scarcity issues. This was based on quality differences, what the market is willing to pay and the existence of scarcity issues. Although Options 2 and 3 may be inconsistent with cost recovery principles as they imply a level of cross subsidisation between visitors who demand differing levels of service or products, it was thought appropriate to develop alternative approaches to Option 1 given the risk under that option of campers cross subsidising the cost of maintaining these sites for much of the year when they are vacant. 5.3.3 Degree to which the structure of fees is consistent across the State Across all the options outlined above, the fees are based on a pricing structure developed by DEPI and Parks Victoria. This is outlined below, separately for camping and roofed accommodation. Pricing structure for camping Under the proposed pricing structure, permits will be required for camping at all sites which have a level of service categorised as ‘Very High’, ‘High’, ‘Mid’, ‘Basic and Very Basic’ or ‘Special’. The fees will be standardised across all campsites with the same category of service level. These permits will be charged on a nightly basis, mostly per site. A number of individual (or ‘Special’) fees will be charged for unique location specific characteristics or product offerings such as the Great Ocean Walk. This includes fees for overnight hiker permits. Off-peak rates will apply for most permit camping sites. Peak period rates will apply from the Melbourne Cup Weekend to the last Sunday in April inclusive, and also for the September school holidays. For some ‘Basic and Very Basic’ service level sites, it is proposed to implement a camping pass in the future. The camping pass is proposed to apply on a per vehicle basis (dependent on type) with passes linked to vehicle registration to ensure that single passes are not shared among users. A camping pass will be required where there is not a defined campsite that attracts rates consistent with the ‘Mid’ or higher service categories. Camping passes 25 The inter-jurisdictional prices for camping in national parks was deemed a more appropriate point of comparison than Victorian private providers, whose camping product offerings are quite different. 43 Victorian National Parks Camping and Accommodation Fees RIS will be obtainable from the Parks Victoria website, phone service and other channels. Camping passes will apply for different time periods, as follows: • Overnight camping pass • 7 Day camping pass • Monthly camping pass • Annual camping pass Pricing structure for roofed accommodation Roofed accommodation will continue to be charged on a per room per night basis and individual fees will apply based on the unique characteristics of roofed accommodation products across the different parks and reserves. The fees for most accommodation products will vary depending on the season, where three distinct seasons will apply: peak season, shoulder season and off-peak season. 44 Victorian National Parks Camping and Accommodation Fees RIS 6 Assessment of regulatory options This chapter provides the multi-criteria analysis of each regulatory option using the framework established in Chapter Five. The following section provides an overview of the base case and how the current fee structure meets the criteria outlined in Chapter 5. Each of the options is then assessed against the base case, with scores allocated to reflect whether the criterion is met to a higher or lower standard under each option. Before outlining the regulatory options considered in this RIS, a few points should be considered: • For campsites classified in the ‘high’, ‘mid’ and ‘basic and very basic’ service level categories, it is not cost-effective for park Parks Victoria to provide the facilities and/or resources necessary to collect payments in every instance that campers choose to use these facilities. This is due to the geographically dispersed nature of these facilities and the irregular attendance patterns throughout much of the year. As such, not all campers comply with the requirement to pay a fee when using these facilities. This results in revenue yield being lower than maximum potential revenue. Advice from Parks Victoria is that payment compliance for current fee-for-service campsites (other than those in the ‘very high’ category) is approximately 60 per cent, and that this could be increased to 80 per cent if a payments system (Online Booking System) and other measures were put in place 26 • In light of the fact that revenue yield from campsites in the ‘high’, ‘mid’ and ‘basic and very basic’ categories is generally lower than it would be if 100 per cent payment compliance was achieved, it is not possible to achieve full cost recovery unless fees are increased to a point where campers that comply with payment requirements are subsidising those that do not comply with these requirements. Therefore, 100 per cent cost recovery is not regarded as appropriate on the grounds of horizontal equity. As such, the objective under many of the options is 100 per cent revenue yield recovery, rather than 100 per cent cost recovery • The cost recovery and fee analysis conducted for this RIS categorises costs and visitation according to Parks Victoria’s Level of Service Standard for camping, and accommodation type for roofed accommodation. The analysis also estimates fees (or cost per visitation night) separately for each of these categories. It is important to note that the approach to charging fees will ultimately involve a number of separate fee amounts for different products in some of these categories, namely: ‘high’ 26 The cost recovery analysis conducted for this RIS assumes that the level of payment compliance for campsites classified in the ‘high’, ‘mid’ and ‘basic and very basic’ service level categories is 60 per cent in year 1, increasing to 64 per cent in year five due to improved marketing and information activities, and then jumping to 80 per cent in year 6 and onwards when the Online Booking System is assumed to be in place. For roofed accommodation and campsites classed in the ‘very high’ category, 100 per cent payment compliance is assumed. 45 Victorian National Parks Camping and Accommodation Fees RIS (powered and non-powered sites), ‘basic and very basic’ campsites (a system of camping passes are proposed), ‘special’ campsites (unique fees for different products will apply) and roofed accommodation (unique fees for different products within the different accommodation types will apply). However, for ease of comparison between the options, average fees are provided for the products in these categories, noting that the preferred option will include a more detailed outline of specific fees for products within each of these categories. Note also that fees under the preferred option will include charges for extra people/vehicles, school groups and to cover booking costs etc. A longer list of detailed fees is provided in Appendix G for the preferred option • The cost base used in the cost recovery analysis includes a number of expenses that are additional to expenses currently incurred by Parks Victoria. These additional expenses have been identified by Parks Victoria as necessary to support the adoption of a new pricing framework/strategy and include service level improvement costs, incremental operating costs, reform implementation costs, additional asset maintenance costs and capital spending for repairs and replacements. It is assumed that these costs would be incurred gradually over the ten year period. In reality, these additional expenses may vary depending on the option that is ultimately implemented (i.e. it will not be possible to fund these costs under those options where fees are set at a level lower than full revenue yield recovery). However, for ease of comparison between the options, the financial analysis assumes that the same cost base will apply under all options, including the scenario that reflects the current fees • The cost base does not include some costs that may be incurred by similar operators in the private sector, such as land tax and municipal rates, as these are not applicable to public land. These costs are difficult to quantify for public land and relevant only for the high and very high camping categories which may have comparable offerings in the private sector. However, these only comprise a small percentage of the total sites covered by the RIS. • The cost base and revenue estimates outlined in this RIS include costs and visitation associated with parks and reserves managed by Parks Victoria that are not governed by the Act. Including these costs as part of this RIS avoids the need to update the pricing framework in the future when fees for non-National Parks Act camping and accommodation are also brought into alignment with the new arrangements 6.1 The base case The base case represents a continuation of the current fee structure for camping and accommodation fees in Victoria’s parks. In this case, Parks Victoria would continue to operate at a level far below cost recovery, with camping costs subsidised by Victorian taxpayers. The base case pricing structure is described in more detail in Chapter 2. The table below outlines the fees published for 2013-14 under the current pricing structure. 46 Victorian National Parks Camping and Accommodation Fees RIS Table 6.1: Current 2013-14 fees (average fee per night for each category)1 Service level and accommodation type Peak fee Off peak fee Very high (pwrd) (per site) $55 $49 Very high (non-pwrd) (per site) $33 $30 High (per site) $32 $29 Mid (per site) $22 $19 $0 $0 $14 $13 $557 $501 $89 $80 Cabins (per cabin) $195 $176 Wilderness retreat (per dwelling) $245 $245 Lightstation (per dwelling) $133 $121 Basic and very basic (per vehicle) Special (per site) Group lodges (per lodge) Huts (per hut) Source: Parks Victoria Fee Schedule 2012 1 Notes: The analysis expresses average fees (or cost per visitation night) separately for each service level and accommodation type. It is important to note, that the approach to charging fees will ultimately involve a number of separate fee amounts for different products in some of these categories, namely: ‘basic and very basic’ campsites (a system of camping passes are proposed), special campsites (unique fees for different products will apply) and roofed accommodation (unique fees for different products within the different accommodation types will apply). However, for ease of comparison between the options, average fees are provided for the products in these categories, noting that the preferred option will include a more detailed outline of specific fees for products within each of these categories. Efficiency 6.1.2 Under the base case, camping and accommodation services are estimated to cost Parks Victoria $17.8 million per annum on average over the period 2013-14 to 2022-23. The funding impact of such the base case pricing approach is an $11.3 million per annum shortfall. This approach is inconsistent with the principles of cost recovery. In order to maintain financial viability Parks Victoria would need to make up this funding shortfall either through increased Government funding, resulting in the subsidisation of camping and accommodation service users by non-users, or they would be required to reduce the provision of camping and accommodation services. Increased dependence on Government grants or lessees would concentrate Parks Victoria’s revenue sources and would likely lead to decreased predictability in funding. The following table outlines the financial analysis conducted on the base case. Table 6.2: Financial analysis of the base case (current fees annual average over ten years, 2013-14 prices) Value Total cost 1 Max potential revenue Estimated yield Shortfall per annum $17,784,597 $7,253,358 $6,539,745 $11,244,852 47 Victorian National Parks Camping and Accommodation Fees RIS Source: Deloitte analysis 1 Notes: The cost base used in the cost recovery analysis includes a number of expenses that are additional to expenses currently incurred by Parks Victoria. These additional expenses have been identified by Parks Victoria as necessary to support the adoption of a new pricing framework/strategy. In reality, these additional expenses may vary depending on the option that is ultimately implemented (i.e. it will not be possible to fund these costs under those options where fees are set at a level lower than full cost recovery). However, for ease of comparison between the options, the financial analysis assumes that the same cost base will apply under all options, including the base case. 6.1.3 Equity The current fee levels do not reflect the costs associated with providing camping and accommodation services overall, which is counter to the user pays principle. Moreover, the relativities in fees do not reflect cost differences between the different service level categories, nor do they reflect differences in quality. As a result, there is a low degree of compliance under the base case with the principle of horizontal equity. 6.1.4 Effectiveness There are currently difficulties inherent in the enforcement of camping fee payments. The ‘reasonable opportunity to pay’ clause means that in some cases, enforcement is more expensive than the revenue that specific sites may receive. In these cases, an honesty system or free camping is currently provided by Parks Victoria. The non-compliance rates under the current system are expected to be quite high considering the small number of sites that actually require payment. By offering camping options that are free of charge, the Government is supporting the easy access of parks to all Victorians. This is broadly aligned with the government objectives of encouraging use of Victoria’s parks and reserves. However, while the fees under this option would be considerably less than under other proposed options (hence making camping and accommodation services more financially accessible to visitors), it is considered that with such low fee revenue, there is a risk that service levels could not be maintained and that damage to the environment might also occur. This would result in a decline in accessibility over time, and hence a misalignment with the Government’s policy objectives in the longterm. 6.1.5 Score The base case is allocated a score of zero against each criterion. This allows for the analysis of all other options against the base case, where a negative score will indicate a situation worse than the base case and a positive score will indicate a situation better than the base case. Table 6.3: Scoring of the base case Criteria Weighting Score Efficiency 40 per cent 0 Equity 30 per cent 0 Effectiveness 30 per cent 0 Total 0 48 Victorian National Parks Camping and Accommodation Fees RIS 6.2 Option 1 Under this option, fees are based on full revenue yield recovery and set according to service level, where relativities in fees between different service levels are based on relativities in cost per visitation night (i.e. no cross subsidies between different service levels or accommodation types). The fees were not adjusted further. The table below outlines the fees under Option 1. Table 6.4: Option 1 fees (average fee per night for each category)1 Service level Peak fee Off peak fee Very high (pwrd) (per site) $45 $40 Very high (non-pwrd) (per site) $49 $44 High (per site) $38 $34 Mid (per site) $46 $42 Basic and very basic (per vehicle) $13 $13 Special (per site) $34 $31 Group lodges (per lodge) $729 $656 Huts (per hut) $175 $157 Cabins (per cabin) $155 $140 Wilderness retreat (per dwelling) $241 $216 $97 $87 Lightstation (per dwelling) Source: Deloitte analysis 1 Notes: The analysis expresses fees (or cost per visitation night) separately for each service level and accommodation type. It is important to note, that the approach to charging fees will ultimately involve a number of separate fee amounts for different products in some of these categories, namely: ‘basic and very basic’ campsites (a system of camping passes are proposed), special campsites (unique fees for different products will apply) and roofed accommodation (unique fees for different products within the different accommodation types will apply). However, for ease of comparison between the options, average fees are provided for the products in these categories, noting that the preferred option will include a more detailed outline of specific fees for products within each of these categories. 6.2.1 Efficiency By setting the fee level on the basis of full revenue yield recovery Option 1 meets the efficiency criterion at a higher level than the base case. As demonstrated in Table 6.5 below, the maximum potential revenue received over the next ten years under this option equates to the total costs of providing camping and accommodation facilities. In this situation, Parks Victoria would increase their revenue level but would still require a small amount of subsidisation from central Government due to the estimated level of non-compliance. Parks Victoria would be able to deliver camping and accommodation product largely independently of government funding. The fees charged between the different products would accurately reflect the costs associated with providing the different products. 49 Victorian National Parks Camping and Accommodation Fees RIS The following table provides an overview of the financial estimates of this option. Table 6.5: Financial analysis of Option 1 (annual average over ten years, 2013-14 prices) Value Total cost $17,784,597 Max potential revenue $17,784,597 Estimated yield $14,730,889 Shortfall $3,053,708 Source: Deloitte analysis As full revenue yield recovery will be achieved and costs of different products would be accurately reflected in the fees, this option is deemed to be far better than the base case in terms of efficiency. However, revenue could be improved further under this option if the customer payment system was implemented at the outset (i.e. July 2013), rather than half way through the ten year period (i.e. July 2018) as is assumed under all three options. As such, this option is regarded as far better than the base case with a score of +7 for efficiency. 6.2.2 Equity Under Option 1, each fee fully reflects the costs associated with providing camping or accommodation at that particular service level. This minimises the level of crosssubsidisation between service levels. However, a key limitation of this approach is that the fees for the ‘Mid’, ‘High’ and ‘Very High’ standard campsites are much the same regardless of the fact that the level of service is different between each. This is counter to what one would generally expect (i.e. that campgrounds with a higher level of service should be priced at a higher rate). This difficulty arises because these prices are set according to average costs per campsite night and the fact that the majority of costs are fixed. For the ‘Very High’ standard campground (Tidal River Wilson’s Promontory), visitation is relatively high such that its full capacity is utilised for most of the year. In contrast, despite there being many more campgrounds in the ‘Mid’ category (77 in total), visitation is lower such that the full capacity is not utilised for most of the year. So even though the costs are higher for the ‘Very High’ standard campground, these costs can be spread over a larger number of campers due to the high utilisation. On the other hand, costs are lower for the ‘High’ and ‘Mid’ standard campgrounds, but these are less well utilised. The end result is that the costs per campsite night will work out to be much the same despite the differing levels of service. Key issues with pricing ‘Mid’, ‘High’ and ‘Very High’ standard campsites at the same rate are as follows: • Fees for the ‘Mid’ and ‘High’ standard campsites would be set above the marginal costs that visitors to these sites give rise to (i.e. under such a situation, visitors would be covering the cost of fixed expenses that are incurred throughout much of the year when the campground is mostly empty), thus giving rise to equity concerns 50 Victorian National Parks Camping and Accommodation Fees RIS • Fees for the ‘Very High’ standard campsites would be set at a level such that no premium would be paid by visitors to reflect the higher level of service provided and scarcity of campsites in this category, thus giving rise to a significant increase in excess demand for these sites and further equity concerns (particularly equity between campers who visit sites of a lower service level relative to those that visit sites of a higher service level) While the fees under this option accurately reflect the costs associated with different camping and accommodation products, the fees are inconsistent with broader horizontal equity principles for the reasons outlined above. As such, this option is regarded as worse than the base case with a score of -3 for equity. 6.2.3 Effectiveness The increased fee levels of Option 1 may result in a reduced level of visitation which is counter to the Government’s objective of encouraging the use of parks. The Deakin research suggests that 53 per cent of potential visitors would consider visiting an alternative destination if a fee was introduced to a campsite that is currently free. 27 However, 81 per cent of potential visitors also stated they would be happy to pay a reasonable fee to camp, if they knew that the fees were based on the cost of maintaining camping facilities and that the revenue earned would be used to maintain and improve the environment and the camping facilities and services. As some of the fees in Option 1 are higher than ‘market’ rates, particularly for ‘high’ and ‘mid’ level sites, it is predicted that the fees would be deemed ‘unreasonable’ by some visitors. This would be exacerbated by the fact that under a ‘no cross subsidy’ fee structure, the fees charged do not align with the service level provided. Any form of reduced visitation as a result of the fee increase would be counter the Government objective of increasing visitors to parks and reserves (see discussion of limitations in Chapter 1). Enforcement is also made more difficult with the introduction of fees for all campsites in Option 1. Currently only a small number of campsites attract fees, and therefore enforcement can be easily localised to those campsites. The introduction of fees for basic and very basic campsites will result in a large amount of campsites, often remote campsites, for which fees have never been collected before. However, while the fees under the base case are considerably less than under Option 1 (hence making camping and accommodation services more financially accessible to visitors), it is considered that, with such low fee revenue, there is a risk that service levels could not be maintained. This would result in a decline in accessibility over time, and hence a misalignment with the Government’s policy objectives in the long-term. In this regard, Option 1 offers a more effective long term situation than the base case. This argument only holds, however, if visitation remains high enough to sustain heightened revenue levels. In sum, the increased revenue received under Option 1 will increase the sustainability of camping product provision in the long term. However, fees based on pure revenue yield recovery levels results in a situation where fees are significantly higher than market rates for ‘high’ and ‘mid’ level sites and prices are not strongly aligned to the service level provided. In this context, it is predicted that visitors will find the fees charged for campsites 27 Deakin University, 2010, op. cit. 51 Victorian National Parks Camping and Accommodation Fees RIS ‘unreasonable’ which will result in reduced visitation and reduced compliance levels. This compromises the long term sustainability of the camping product provision and is a situation deemed worse than the base case. As such, this option is regarded as far worse than the base case with a score of -10 for effectiveness. Summary 6.2.4 The following table provides a summary of MCA scores under Option 1. Table 6.6: Scoring of Option 1 Criteria Weighting Score Efficiency 40 per cent +7 Equity 30 per cent -3 Effectiveness 30 per cent -10 Total -1.1 6.3 Option 2 Under this option, fees are based on average ‘market’ rates and set according to service level. For the camping product, the ‘market’ rates are based on benchmarks for similar products around Australia, with a focus on camping facilities offered by the public sector. This is because there are few comparable camping experiences offered by the private sector in Victoria for the lower service levels, whereas similar camping experiences are offered on public land in other states, particularly New South Wales and South Australia. For the accommodation product, the ‘market’ rates are also based on benchmarks for similar products in Victoria and around Australia, but the benchmarking includes both public and private sector providers as comparable experiences are offered in both sectors. The table below outlines the fees under Option 2. Table 6.7: Option 2 fees (average fee per night for each category)1 Service level Peak fee Off peak fee Very high (pwrd) (per site) $55 $50 Very high (non-pwrd) (per site) $50 $45 High (per site) $42 $38 Mid (per site) $25 $23 Basic and very basic (per vehicle) $13 $13 Special (per site) $15 $13 Group lodges (per lodge) $516 $465 Huts (per hut) $125 $113 Cabins (per cabin) $197 $177 Wilderness retreat (per dwelling) $247 $222 Lightstation (per dwelling) $119 $108 Source: Deloitte analysis 52 Victorian National Parks Camping and Accommodation Fees RIS 1 Notes: The analysis expresses fees (or cost per visitation night) separately for each service level and accommodation type. It is important to note, that the approach to charging fees will ultimately involve a number of separate fee amounts for different products in some of these categories, namely: ‘basic and very basic’ campsites (a system of camping passes are proposed), special campsites (unique fees for different products will apply) and roofed accommodation (unique fees for different products within the different accommodation types will apply). However, for ease of comparison between the options, average fees are provided for the products in these categories, noting that the preferred option will include a more detailed outline of specific fees for products within each of these categories. 6.3.1 Efficiency As demonstrated in Table 6.8 below, the maximum potential revenue received over the next ten years under this option is $1.3 million less than the total costs of providing camping and accommodation facilities. In this situation, Parks Victoria would increase their revenue level but would still require subsidisation from central Government due to fees being set at a level lower than revenue yield recovery and also due to the estimated level of non-compliance. The following table provides an overview of the financial estimates of this option. Table 6.8: Financial analysis of Option 2 (annual average over ten years, 2013-14 prices) Value Total cost $17,784,597 Max potential revenue $16,454,673 Estimated yield $13,603,472 Shortfall $4,181,124 Despite the fact that full revenue yield recovery is not achieved under this option, the level of revenue is still well above the level under the base case. As such, this option is deemed to be far better than the base case in terms of efficiency, but rates slightly lower than Option 1 and Option 3 which achieve higher revenue levels. Moreover, revenue could be improved further under this option if the customer payment system was implemented at the outset (i.e. July 2013), rather than half way through the ten year period (i.e. July 2018) as is assumed under all three options. As such, this option is regarded as better than the base case with a score of +6 for efficiency. 6.3.2 Equity Under Option 2, relativities between fees for different service levels are based on relativities implied by ‘market’ rates. As these relativities are not based on differences in costs, these fees result in a certain degree of cross-subsidisation between different camping and accommodation products. This gives rise to horizontal equity concerns. Setting fees according to market rates resolves the issue that cost recovery pricing does not adequately reflect differences in the level of services offered. The resulting fees for ‘Mid’ and ‘High’ standard campsites better approximate the level that does not reflect full fixed costs and the resulting fees for ‘Very High’ standard campsites better approximate the premium necessary to capture scarcity and the higher standard of service of these sites. 53 Victorian National Parks Camping and Accommodation Fees RIS As the horizontal equity issues prevalent in Option 1 are somewhat resolved in Option 2, this option is regarded as being more equitable relative to Option 1. It is also regarded as being more equitable than the base case as the level of cost recovery is much higher which gives rise to a lower taxpayer subsidy. However, equity could be improved further by addressing vertical equity considerations, such as through the introduction of concessions for students and other low income groups. Overall, this option is regarded as better than the base case with a score of +5 for equity. 6.3.3 Effectiveness As with the other options, enforcement remains difficult with the introduction of fees for all campsites. The increased fee levels may also result in a reduced level of visitation, although the evidence isn’t clear on this (as discussed above). However, it is considered that with such low fee revenue under the base case, there is a risk that service levels could not be maintained. This would result in a decline in accessibility over time, and hence a misalignment with the Government’s policy objectives in the longterm. In this regard, Option 2 offers a more effective and sustainable long term situation relative to the base case. Under this option, prices paid would be broadly consistent with many visitors’ expectations of relativities between different camping and roofed accommodation fees as they are based on ‘market’ rates. Therefore, relative to Option 1, fees under this option will be more reasonable and less likely to result in reduced visitation and reduced compliance levels. Relative to the base case, this option would be more effective at raising additional revenue through increased fees, but would still be associated with a number of implementation and compliance issues, particularly given that the customer payment system would not be implemented until half way through the ten year period (i.e. July 2018) as is assumed under all three options. Overall, this option is regarded as better than the base case with a score of +3 for effectiveness. 6.3.4 Summary The following table provides a summary of MCA scores under Option 2. Table 6.9: Scoring of Option 2 Criteria Weighting Score Efficiency 40 per cent +6 Equity 30 per cent +5 Effectiveness 30 per cent +3 Total 4.8 54 Victorian National Parks Camping and Accommodation Fees RIS 6.4 Option 3 Under this option, fees are based on full revenue yield recovery for camping and higher than full revenue yield recovery for accommodation, and then adjusted considering market pricing and differences in quality between the various camping and roofed accommodation products. In developing the fees, the existence of scarcity issues were also considered (as discussed in Chapter 5) and to avoid potential negative impacts on private operators. Table 6.10 explains how each category was adjusted in option 3. The table below outlines the fees under Option 3. Table 6.10: Option 3 fees (average fee per night for each category)1 Service level Peak fee Off peak fee Adjusted to: Very high (pwrd) (per site) $66 $59 Reflect differences in quality and scarcity Very high (non-pwrd) (per site) $59 $53 Reflect differences in quality and scarcity High (per site) $50 $45 Reflect differences in quality and scarcity Mid (per site) $38 $34 Above market but below cost recovery to avoid reduced visitation Basic and very basic (per vehicle) $13 $13 - Special (per site) $18 $18 Above market and below cost recovery avoid reduced visitation Group lodges (per lodge) $648 $547 Above market and below cost recovery avoid reduced visitation Huts (per hut) $131 $111 Above market and below cost recovery avoid reduced visitation Cabins (per cabin) $236 $202 To reflect differences in quality and scarcity Wilderness retreat (per dwelling) $245 $245 Above cost recovery and similar to market to address scarcity and impacts on private operators Lightstation (per dwelling) $135 $122 To reflect differences in quality and scarcity Source: Deloitte analysis 1 Notes: The analysis expresses fees (or cost per visitation night) separately for each service level and accommodation type. It is important to note, that the approach to charging fees will ultimately involve a number of separate fee amounts for different products in some of these categories, namely: ‘basic and very basic’ campsites (a system of camping passes are proposed), special campsites (unique fees for different products will apply) and roofed accommodation (unique fees for different products within the different accommodation types will apply). However, for ease of comparison between the options, average fees are provided for the products in these categories, noting that the preferred option will include a more detailed outline of specific fees for products within each of these categories. 55 Victorian National Parks Camping and Accommodation Fees RIS 6.4.1 Efficiency As demonstrated in Table 6.11 below, the maximum potential revenue received over the next ten years under this option is $0.6 million more than the total costs of providing camping and accommodation facilities. In this situation, Parks Victoria would increase their revenue to a level above full revenue yield recovery but would still require subsidisation from central Government due to the estimated level of non-compliance. The following table provides an overview of the financial estimates of this option. Table 6.11: Financial analysis of Option 3 (annual average over ten years, 201314 prices) Value Total cost $17,784,597 Max potential revenue $18,351,408 Estimated yield $15,282,614 Shortfall $2,501,983 Source: Deloitte analysis Given that the level of revenue collected under this option is above full revenue yield recovery it is deemed to be far better than the base case in terms of efficiency. It also rates slightly better than Options 1 and 2 where revenue is somewhat lower. However, revenue could be improved further under this option if the customer payment system was implemented at the outset (i.e. July 2013), rather than half way through the ten year period (i.e. July 2018) as is assumed under all three options. Overall, this option is regarded as better than the base case with a score of +8 for efficiency. 6.4.2 Equity Under Option 3 relativities between fees for different service levels are based on relativities in quality. As these relativities are not based on differences in costs, these fees result in a certain degree of cross-subsidisation between different camping and accommodation products. This gives rise to horizontal equity concerns. However, as discussed above, setting fees on the basis of cost relativities between different camping products is also associated with horizontal equity concerns because visitors of ‘Mid’ and ‘High’ standard campsites would be covering the cost of fixed expenses that are incurred throughout much of the year when the campground is mostly empty and visitors of ‘Very High’ standard campsites would not be paying a premium to reflect the higher level of service provided and scarcity of campsites in this category. Setting fees according to quality resolves these issues as the resulting fees for ‘Mid’ and ‘High’ standard campsites better approximate the level that does not reflect full fixed costs and the resulting fees for ‘Very High’ standard campsites better approximate the premium necessary to capture scarcity and the higher standard of service of these sites. 56 Victorian National Parks Camping and Accommodation Fees RIS As the horizontal equity issues prevalent in Option 1 are somewhat resolved in Option 2, this option is regarded as being more equitable relative to Option 1. It is also regarded as being more equitable than the base case as the level of cost recovery is much higher which gives rise to a lower taxpayer subsidy. In addition, it is regarded as being more equitable than Option 2 as fees are most accurately aligned with differences in quality under this option. However, equity could be improved further by addressing vertical equity considerations, such as through the introduction of concessions for students and other low income groups. Overall, this option is regarded as better than the base case with a score of +8 for equity. 6.4.3 Effectiveness As with the other options, enforcement is made more difficult with the introduction of fees for all campsites and there is a risk ofreduced levels of visitation However, it is considered that with such low fee revenue under the base case, there is a risk that service levels could not be maintained. This would result in a decline in accessibility over time, and hence a misalignment with the Government’s policy objectives in the long-term. In this regard, Option 3 offers a more effective and sustainable long term situation relative to the base case. Under this option, prices paid would be broadly consistent with many visitors’ expectations of relativities between different camping and roofed accommodation fees as they are based on differences in quality. Therefore, relative to Option 1, fees under this option will be more reasonable and less likely to result in reduced visitation and reduced compliance levels. This option is not regarded as being more effective relative to Option 2. Relative to the base case, this option would be more effective at raising additional revenue through increased fees, but would still be associated with a number of implementation and compliance issues. Overall, this option is regarded as better than the base case with a score of +3 for effectiveness. 6.4.4 Summary The following table provides a summary of MCA scores under Option 3. Table 6.12: Scoring of Option 3 Criteria Weighting Score Efficiency 40 per cent +8 Equity 30 per cent +8 Effectiveness 30 per cent +3 Total 6.5 57 Victorian National Parks Camping and Accommodation Fees RIS 7 The preferred option 7.1 Determining the preferred option The following table provides a summary of the results of the MCA across the three options. Table 7.1: Summary of MCA results Criteria Weighting Option 1 Option 2 Option 3 Efficiency 40 per cent +7 +6 +8 Equity 30 per cent -3 +5 +8 Effectiveness 30 per cent -10 +3 +3 Weighted total 100 per cent -1.1 4.8 6.5 As indicated in Table 7.1, Option 1 achieves a score that indicates it is worse than the base case. This is primarily driven by equity and effectiveness implications. While this option significantly increases the estimated revenue, the misalignment between fees charged and service level received causes a reduction in horizontal equity. This equity issue is directly linked to effectiveness implications as users are anticipated to find the format of fees under Option 1 unreasonable and this could reduce visitation and compliance. Any reduction in visitation is at odds with the Government’s objective of encouraging the use of national and state parks. Options 2 and 3 both receive scores indicating that they are better than the base case. As with Option 1, these options significantly increase the estimated revenue received for the provision of camping and accommodation products and, therefore, provide a more sustainable funding approach relative to the base case. In particular, revenue is highest under Option 3 so it achieves the highest score. Options 2 and 3 both significantly increase horizontal equity relative to the base case as the level of fees is more in line with the user pays principle (i.e. taxpayer subsidies are significantly reduced). In addition, fees are better aligned with differences in quality Effectiveness is also increased to some degree, but this is not clear cut. On the one hand, it could be argued that these two options rate worse than the base case as increasing existing fees and introducing new ones for sites that are currently free, may reduce visitation and therefore be at odds with the Government’s objective of encouraging the use of national and state parks. Moreover, enforcement is made more difficult under these options as the collection of fees is required across all campsites rather than just a select few as under the base case. On the other hand, it is foreseeable that, under the base case, camping facilities would become degraded resulting in a situation that is counter Government’s objective of encouraging the use of national and state parks, particularly if some campgrounds need to be closed for health and/or safety reasons. Under Options 2 and 3, this would not occur as the necessary funds would be available for upkeep and improvement of facilities. In addition, payment compliance issues would be addressed over the longer term through 58 Victorian National Parks Camping and Accommodation Fees RIS implementation of the customer booking system, which is assumed to occur half way through the ten year period (i.e. July 2018) under all three options. On balance, Option 3 scores the highest as the fees achieve the highest level of revenue (i.e. it best addresses the efficiency criterion) and most accurately reflect differences in quality (i.e. it best addresses the equity criterion). As such, Option 3 is the preferred option. 7.2 Fees and financial implications Fees (peak rates only) and financial impacts under the preferred option are outlined in Table 7.2. This table also provides a comparison with current fees (2013-14 scheduled) and ‘market’ rates (Option 2). A detailed outline of the proposed fee structure is provided in Appendix G. Table 7.2: Proposed fees (peak rates)1 Base case (current) Camping Fees Financials ($m) Total Financials ($m) Option 3 (proposed) $55 $33 $32 $22 $0 $14 $55 $50 $42 $25 $13 $15 $66 $59 $50 $38 $13 $18 $3.4 -$11.2 $10.3 -$4.3 $11.5 -$3.1 $557 $89 $195 $245 $133 $516 $125 $197 $247 $119 $648 $131 $236 $245 $135 Estimated revenue yield Estimated shortfall/surplus $3.2 $0.0 $3.3 $0.1 $3.8 $0.6 Estimated revenue yield Estimated shortfall/surplus $6.5 -$11.3 $13.6 -$4.2 $15.3 -$2.5 Very High (pwrd) Very High (non-pwrd) High Mid Basic & Very Basic Special Estimated revenue yield Estimated shortfall/surplus Accommodation Fees Group Lodges Huts Cabins Wilderness Retreats Lightstation Financials ($m) Option 2 (‘market’) Source: Deloitte analysis 1 Notes: The cost base and revenue estimates outlined in this RIS include costs and visitation associated with parks and reserves managed by Parks Victoria that are not governed by the National Parks Act 1975. Including these as part of this RIS avoids the need to update the pricing framework in the future when fees for non-National Parks Act camping and accommodation are also brought into alignment with the new arrangements. As indicated, the proposed fees for camping facilities represent a significant increase across all areas, particularly campgrounds in the ‘Very high (non-powered)’, ‘High’ and ‘Mid’ service level categories. Moreover, fees are being introduced for campgrounds in the ‘Basic and very basic’ service level category, for which fees do not current apply. These fees are 59 Victorian National Parks Camping and Accommodation Fees RIS also higher than what is charged by the ‘market’, particularly for campgrounds in the ‘High’ category. The estimated revenue yield from camping facilities under the proposed fees is $11.5 million, in comparison to the revenue yield under the current fees, which is estimated at $3.4 million. This represents an increase of over 240 per cent. When accounting for the assumed levels of payment compliance (which vary depending on the year in question), the estimated budget shortfall under the proposed camping fees is $3.1 million. The estimated revenue yield from accommodation facilities under the proposed fees is $3.8 million. When accounting for the assumed levels of payment compliance (which is 100 per cent for roofed accommodation), the estimated budget surplus under the proposed accommodation fees is $0.6 million. This indicates that the fees under the preferred option more than cover the estimated costs of roofed accommodation (as discussed above). Overall, the estimated revenue yield from camping and accommodation facilities under the proposed fees is $15.3 million, significantly higher than the revenue yield under the current fees, which is estimated at $6.5 million. This represents an increase of over 130 per cent. When accounting for the assumed levels of payment compliance, the estimated budget shortfall under the proposed camping and accommodation fees is $2.5 million. Annual revenues (including net present value) under the proposed fees are provided in Table 7.3. These revenue streams are calculated in real terms, so do not include the effects of nominal price inflation. As indicated, estimated revenue yield from the proposed camping and accommodation fees increases in real terms from $13.5 million in 2013-14 to $16.9 million in 2022-23, with a net present value of $126 million assuming a real discount rate of 3.5 per cent. Table 7.3: Estimated annual revenue yield under preferred option ($ million)1 Year Revenue yield 2013-14 2014-15 2015-16 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 $13.5 $13.7 $13.9 $14.2 $14.4 $16.3 $16.5 $16.6 $16.8 $16.9 Source: Deloitte analysis 1 Notes: The cost base and revenue estimates outlined in this RIS include costs and visitation associated with parks and reserves managed by Parks Victoria that are not governed by the National Parks Act 1975. Including these as part of this RIS avoids the need to update the pricing framework in the future when fees for nonNational Parks Act camping and accommodation are also brought into alignment with the new arrangements. It is important to note that the fees outlined in this RIS are for the year 2013-14. Fees in subsequent years would be higher. In particular, the Minister has the authority to increase fees on an annual basis in accordance with the Treasurer’s rate without undertaking 60 Victorian National Parks Camping and Accommodation Fees RIS another RIS. Increases higher than the Treasurer’s rate which are needed to ensure fees are consistent with general price inflation and continue to achieve full revenue yield recovery would require the Treasurer’s approval. 61 Victorian National Parks Camping and Accommodation Fees RIS 8 Statements on compliance 8.1 Impacts on small business It is Victorian Government policy to specifically consider the impact of proposed amendments to legislative proposals on small business in RISs. Where the costs of compliance with regulations comprise a significant proportion of business costs, small business may be affected disproportionately by such costs compared to large businesses. However, in this case, the proposed determination primarily imposes costs on individual visitors rather than on businesses. The businesses likely to be affected by the proposed fees are private providers of camping grounds and some licence tour operators who utilise camping and accommodation in parks. 8.2 Competition assessment It is Victorian Government policy that legislation which restricts competition will not be passed unless it can be demonstrated that: • The benefits of the restriction, as a whole, outweighs the costs • The objectives of the legislation can only be achieved by restricting competition In order to assess whether the proposed pricing structure will restrict competition, and if so, if the above principles have been met, the following ‘competition test’ has been applied. Table 8.1: Impacts of new camping pricing structures on competition Question Assessment Is the proposed measure likely to affect the market structure of the affected sector(s) – i.e. will it reduce the number of participants in the market, or increase the size of incumbent firms? No Will it be more difficult for new firms or individuals to enter the industry after the imposition of the proposed measure? No Will the costs/benefits associated with the proposed measure affect some firms or individuals substantially more than others (e.g. small firms, parttime participants in occupations etc.)? No Will the proposed measure restrict the ability of businesses to choose the price, quality, range or location of their products? No Will the proposed measure lead to higher ongoing costs for new entrants that existing firms do not have to meet? No Is the ability or incentive to innovate or develop new products or services likely to be affected by the proposed measure? No As mentioned earlier, the increased costs of camping fee impacts primarily on individual consumers of camping product. By bringing the cost of publically provided camping into alignment with market prices, the level of competition is expected to increase. 62 Victorian National Parks Camping and Accommodation Fees RIS 8.3 Implementation DEPI has acknowledged that the implementation of the proposed pricing structure will require the revenue raised from camping and accommodation services to be reinvested in the camping and accommodation services. To achieve a cost effective implementation of the pricing strategy, DEPI is proposing to introduce a new and streamlined booking and payment process. A single booking and payment system is proposed to apply to public land that covers both Parks Victoria and DEPI managed area. Mechanisms to distribute funding between the two agencies will be developed. The analysis conducted for this RIS assumes that the Online Booking System will be funded through increased fee revenue on the basis that the necessary capital to fund these costs upfront is not available, i.e. the Online Booking System is to be funded through saved revenue over the first five years, and therefore implemented in year six. The analysis includes an adjustment to expected revenue yield to account for improved payment compliance relative to the current level (80 per cent in year 6 and onwards when the Online Booking System is assumed to be in place). 8.4 Enforcement Division 2 of Part 9 of the National Park Regulations 2013 specifies that a person must not occupy an occupation site (building, camping place or other facility for which a permit under section 21(1)(a) of the Act may be issued) without a permit. The Regulations provide for a 10 penalty unit offence for this provision. Resourcing limitations for Parks Victoria means that it is not always possible for rangers to be present at each site. As a result, many sites are operated on the basis of an honesty system. This is estimated to result in some degree of non-compliance. The analysis conducted for this RIS includes an adjustment to expected revenue yield to account for improved payment compliance relative to the current level (60 per cent according to Parks Victoria) as a result of marketing campaign over the period and implementation of the Commercial Business System. The level of payment compliance is assumed to be 60 per cent in year 1, increasing to 64 per cent in year five and then jumping to 80 per cent in year 6 and onwards when the Online System is assumed to be in place. 8.5 Evaluation strategy DEPI and Parks Victoria will evaluate the effectiveness of the proposed changes to camping and accommodation fees by monitoring: • Revenue collection, • Visitation statistics 63 Victorian National Parks Camping and Accommodation Fees RIS • Enforcement data The National Parks Act Annual Report, which provides an annual update on the workings of the Act, as well as the Parks Victoria Annual Report, will be used to report on aspects of the proposed changes. 64 Victorian National Parks Camping and Accommodation Fees RIS 9 Consultation 9.1 Consultation undertaken to-date In 2009 Deakin University was engaged to conduct a research report for Parks Victoria. The purpose of the project was to conduct qualitative and quantitative research of visitors and potential visitors to parks managed by Parks Victoria from metropolitan and regional Victoria. The research included community expectations and perceptions on the quality; price; demand; user charges; and the concept of camping product as a public good. The research included conducting two focus groups with current and lapsed/potential campers and a quantitative survey with 488 valid responses from both parks visitors and non-visitors. Box 9.1: Deakin University Camping and Accommodation Product and Pricing Research Report – Key Insights Facilities and services A high level of satisfaction with the camping product was evident. Campers are generally very satisfied with the services and facilities that are provided. It is important that Parks Victoria recognise and address the critical improvements suggested by respondents. These relate to toilets, cleanliness, safety, communication and cooking facilities. It is also important that Parks Victoria consider strategies to increase the satisfaction of campers with regard to litter management, conservation programs and a ranger available in an emergency. Future pricing strategy It was regarded by respondents as being quite reasonable that campers should pay to use camping facilities, in a form of users pay system. There was strong support for fees being used to maintain and upgrade facilities and services and for environmental protection and support of the areas close to the camp sites. Within the community there is good support for the proposition that fees be introduced wherever Parks Victoria are supplying management services and that these charges should reflect the level of facilities and services provided at the particular campsite, in accordance with those suggested in this study. Price points for camping at parks with differentiated facilities have been developed as part of this study. 65 Victorian National Parks Camping and Accommodation Fees RIS It is important that PV rectify the inconsistent pricing that is currently instituted in relation to the camping services and facilities offered. The study identified that there was a perceived community good component related to camping which provides a variety of community benefits. In turn this translated into support for tax payers subsidizing some costs associated with camping. 9.2 Further Consultation It is anticipated that the proposed changes will generate significant interest from peak bodies and user groups. The RIS process will provide a mechanism for further consultation on the proposed changes. DEPI welcomes comments and feedback on the proposed changes and any impacts on the community. The DEPI website will provide basic information about the proposed reform and instructions for how to make a submission. Links to this page will also be provided on the Parks Victoria and Tourism Victoria websites. An email address will be established for all enquires relating to the proposed reform. There will also be notices on how to make a submission published in the Government Gazette and major newspapers. Submissions must be received by 5pm on 22 November 2013. 66 Victorian National Parks Camping and Accommodation Fees RIS References Deakin University, 2010, Research report for Parks Victoria: Camping and Accommodation Product & Pricing. Deloitte, 2011, Parks Victoria: Camping and Accommodation Product Review – Update and extension of supplementary financial modelling for five years from 2013/14 to 2017/18. Department of Human Services, 2011, State concessions and hardship programs 2010-2011, available at http://www.dhs.vic.gov.au/__data/assets/pdf_file/0013/701320/state_concessions_ and_hardship_programs_2010_11.pdf, accessed 29 October 2012. Department of Primary Industries (DPI), 2008, Public Land in Victoria, available at http://vro.dpi.vic.gov.au/dpi/vro/map_documents.nsf/pages/vic_pub_land, accessed 16 October 2012. Department of Sustainability and Environment () website, 2012, What We Strive For, available at http://www.dse.vic.gov.au/about-dse/department-overview/what-westrive-for, accessed 7 November 2012. Department of Sustainability and Environment (DSE), 2012, Pricing Framework, unpublished. Department of Sustainability and Environment (DSE), 2011, National Parks Act Annual Report 2011, available at http://www.dse.vic.gov.au/__data/assets/pdf_file/0009/127539/National-Parks-ActAnnual-Report-2011.pdf, accessed 16 October 2012. Department of Treasury and Finance (DTF), 2011, Victorian Guide to Regulation, Edition 2.1, State of Victoria, available at http://www.vcec.vic.gov.au/CA256EAF001C7B21/WebObj/VGR-incl/$File/VGR%20%20incl.%20SLA%20guidelines%20from%201%20July%202011.pdf, accessed 17 October 2012. Department of Treasury and Finance (DTF), 2010, Cost Recovery Guidelines, State of Victoria, available at http://www.dtf.vic.gov.au/CA25713E0002EF43/WebObj/CostRecoveryGuidelinesMa y2010/$File/CostRecoveryGuidelinesMay2010.pdf, accessed 16 October 2012. New South Wales National Parks and Wildlife Service, 2010, Visitor Accommodation Policy, NSW Government, available at http://www.environment.nsw.gov.au/resources/parks/policies/policyAccommodatio n.pdf, accessed 22 October 2012. New South Wales Taskforce on Tourism and National Parks, 2008, Final Report, available at http://www.environment.nsw.gov.au/resources/commercial/20080617Appendices.p df, accessed 22 October 2012. Parks Victoria 2003, The value of parks - the economic value of three of Victoria’s national parks: Port Campbell, Grampians, Wilsons Promontory, Parks Victoria, Melbourne 67 Victorian National Parks Camping and Accommodation Fees RIS Parks SA, 2012, Camping in South Australia’s National Parks, available at http://www.environment.sa.gov.au/files/6bd9f251-bb70-44a2-84719e4b009b127b/psa-gen-campingbrochure.pdf, accessed 17 October 2012. Parks Victoria, 2012, Legislative Framework, available at http://parkweb.vic.gov.au/parkmanagement/legislation, accessed 19 October 2012. Parks Victoria, n.d., Camping in Victoria’s parks Victorian Auditor-General, 2010, The Management of Concessions by the Department of Human Services, available at http://download.audit.vic.gov.au/files/240210_Concessions_full_report.pdf, accessed 29 October 2012. Victorian Competition and Efficiency Commission, 2011, Multi-criteria analysis (MCA) Guidance note, available at http://www.vcec.vic.gov.au/CA256EAF001C7B21/WebObj/Guidancenote-multicriteriaanalysis-PDF/$File/Guidance%20note%20-%20multi-criteria%20analysis%20%20PDF.pdf, accessed 25 October 2012. Victorian Government, 2011, 2011 Victorian Families Statement: Starting the discussion on what matters to families, available at http://www.premier.vic.gov.au/images/stories/documents/mediareleases/2011/Fa milies-Statement-pdf-document.pdf, accessed 29 October 2012. 2013 Camping Fees References Tasmania: http://www.tams.act.gov.au/parks recreation/recreational_activities/camping_in_the_act/namadgi_national_park NSW: http://www.nationalparks.nsw.gov.au/Stay and http://www.environment.nsw.gov.au/ South Australia: http://www.environment.sa.gov.au/parks/Visiting/Camping_accommodation Western Australia: http://www.dec.wa.gov.au/campgrounds/brochures.html Queensland: http://www.nprsr.qld.gov.au/experiences/camping/camping_fees.html Tasmania: http://www.parks.tas.gov.au/?base=412 Northern Territory: http://www.parksandwildlife.nt.gov.au/parks/parkfees 68 Victorian National Parks Camping and Accommodation Fees RIS Appendix A- Detailed costings Detailed figures on the estimated cost of providing camping facilities in parks and reserves managed by Parks Victoria for the 2013-14 financial year are provided in Table A.1. Note that estimated total cost of camping facilities in 2013-14 ($12.4 million) differs from the estimated cost base for camping (see Table 4.7 in the body of the report) as the cost base represents average costs over ten years. In particular, the cost base includes additional costs that occur in later years including real price inflation (i.e. above CPI price increases), upgrades to camping facilities (assumed to commence in 2014-15), and the depreciation and capital asset charge applicable to the upgraded facilities. Table A.1: Estimated costs of camping facilities in national parks and reserves operated by Parks Victoria (2013-14) Very High High Mid Basic & Very Basic Special Total $842,711 $153,289 $367,244 $973,258 $532,818 $2,869,320 Lease Expenses $13,374 $44 $0 $0 $2,439 $15,857 Water $61,207 $0 $0 $0 $0 $61,207 Energy $50,023 $12,890 $0 $0 $0 $62,913 Plant and equipment expenses $42,757 $17,792 $4,475 $0 $7,837 $72,861 Telephone $15,682 $5,496 $815 $0 $2,866 $24,859 Vehicle expenses $62,148 $23,498 $31,161 $216,185 $39,980 $372,972 Track Maintenance $41,405 $2,731 $0 $0 $151,154 $195,290 Contractors $0 $13,291 $297 $0 $0 $13,588 Insurance $0 $2,518 $99 $0 $0 $2,617 General Expenses $0 $4,143 $164 $0 $0 $4,307 $1,129,307 $235,692 $404,255 $1,189,443 $737,094 $3,695,791 $26,772 $22,159 $4,664 $0 $4,882 $58,477 $152,639 $0 $0 $0 $0 $152,639 $32,548 $0 $0 $0 $0 $32,548 $5,446 $16 $0 $0 $885 $6,347 $15,548 $0 $0 $0 $0 $15,548 $3,448 $15 $0 $0 $827 $4,290 Base costs Labour Total Recurrent costs Cleaning Admin Camp Main Customer Service Emergency Management II&E Marine Protection Area Marketing Outstation Management Revegetation Management $0 $59 $0 $0 $3,283 $3,342 $2,929 $52 $0 $0 $2,877 $5,858 $0 $310 $0 $0 $17,154 $17,464 $3,052 $9 $0 $0 $496 $3,557 69 Victorian National Parks Camping and Accommodation Fees RIS Roads $17,948 $53 $0 $0 $2,915 $20,916 Rubbish $53,890 $6,470 $0 $0 $0 $60,360 San & Sharps $5,441 $0 $0 $0 $0 $5,441 Security $0 $2,460 $0 $0 $0 $2,460 Signage $2,391 $50 $0 $0 $2,740 $5,181 $50,518 $0 $0 $0 $0 $50,518 Visitor Expenses $6,979 $124 $0 $0 $6,855 $13,958 Toilet Maintenance $5,719 $0 $0 $0 $0 $5,719 $0 $22,653 $668 $0 $0 $23,321 Track maintenance $6,387 $1,573 $961 $0 $7,320 $16,241 Transport Services $14,423 $42 $0 $0 $2,343 $16,808 Tree Main, surgery and risk management $8,292 $2,386 $0 $0 $5,430 $16,108 Visitor Facility Maintenance $0 $14,948 $10,136 $0 $0 $25,084 Visitor Laundry $2,903 $0 $0 $0 $0 $2,903 Security $9,809 $3 $0 $0 $161 $9,973 Track Maintenance $1,164 $78 $0 $0 $4,301 $5,543 Camping Fees Support $0 $470 $313 $0 $0 $783 Camping Fees Administration $0 $10,656 $7,104 $0 $0 $17,760 General recurrent costs $0 $153,912 $390,844 $155,387 $117,547 $817,690 $428,246 $238,498 $414,690 $155,387 $180,016 $1,416,837 $29,739 $0 $0 $0 $0 $29,739 Booking service costs – online $0 $1,278 $7,005 $99,818 $2,000 $110,101 Booking service costs – telephone $0 $1,597 $7,540 $59,891 $2,476 $71,504 $39,490 $12,459 $17,312 $234,196 $9,344 $312,801 Additional fee collection costs $0 $21,242 $0 $0 $0 $21,242 Additional Compliance costs $0 $0 $121,435 $956,804 $0 $1,078,239 Vehicle costs $0 $0 $11,386 $132,582 $0 $143,968 Signage $0 $0 $34,318 $418,687 $1,725 $454,730 Awareness campaign $0 $4,210 $34,370 $139,256 $12,495 $190,331 Training and uniforms $0 $0 $6,000 $52,966 $0 $58,966 Camping pass production and printing $0 $0 $0 $15,473 $0 $15,473 Camping guides $0 $7,636 $57,872 $154,729 $22,486 $242,723 Communications plan development $0 $1,527 $11,574 $77,365 $4,497 $94,963 Park Maintenance General maintenance and materials Total Incremental operating costs Service improvement costs Commissions to third parties 70 Victorian National Parks Camping and Accommodation Fees RIS Legal costs $0 $0 $0 $62,783 $0 $62,783 Additional Maintenance $55,879 $21,065 $35,170 $570,005 $45,352 $727,471 Upfront implementation costs $47,684 $17,975 $30,012 $516,280 $38,700 $650,651 $172,792 $88,989 $373,994 $3,490,835 $139,075 $4,265,685 Visitor Experiences Division $32,491 $23,857 $135,806 $445,091 $46,995 $684,240 General IT $55,020 $11,171 $2,017 $0 $8,954 $77,162 Public Liability Insurance $2,399 $511 $140 $0 $391 $3,441 Web $1,068 $217 $39 $0 $173 $1,497 131963 Hotline $2,250 $479 $132 $0 $367 $3,228 Camping brochures $2,971 $633 $174 $0 $484 $4,262 $22,216 $4,732 $1,300 $0 $3,620 $31,868 $2,692 $2,351 $488 $0 $444 $5,975 $180 $303 $145 $0 $30 $658 $4,577 $61 $21 $0 $743 $5,402 $16,716 $17,081 $5,414 $0 $2,715 $41,926 Total General overheads Regional Costs Insurance premium - ISR Insurance premium – Vehicles IT support calls Summer Ranger Program Camp Host Program $2,101 $11,232 $3,894 $0 $363 $17,590 131963 Hotline (Bookings) $0 $1,309 $0 $0 $9 $1,318 Customer service costs (incl. head office) $0 $0 $0 $827,809 $0 $827,809 $144,681 $73,937 $149,570 $1,272,900 $65,288 $1,706,376 $87,258 $29,091 $14,912 $216,291 $13,781 $361,333 $170,594 $33,694 $31,501 $429,703 $24,293 $689,785 Total $257,852 $62,785 $46,413 $645,994 $38,074 $1,051,118 Total $1,339 $78,587 $147,383 $13,662 $36,445 $277,416 $1,731,684 $641,766 $1,340,322 $4,849,327 $1,092,630 $9,655,729 Total Other overheads Depreciation Capital asset charge Costs of PV managed Reserves Summary Total direct costs Total indirect costs Grand total $402,533 $136,722 $195,983 $1,918,894 $103,362 $2,757,494 $2,134,217 $778,488 $1,536,305 $6,768,221 $1,195,992 $12,413,223 Source: Deloitte analysis 71 Victorian National Parks Camping and Accommodation Fees RIS Appendix B - Pricing framework The DEPI pricing framework provides a process for developing pricing structures compliant with government cost recovery policy in the public land context. The three stages of this process are: • Stage One: Establish costs • Stage Two: Decide how to recover costs • Stage Three: Implement costs Figure B.1: DEPI’s pricing framework for public land Source: DEPI 2012 72 Victorian National Parks Camping and Accommodation Fees RIS The following section demonstrates how the options for the proposed camping fees have been developed in this RIS using the framework. The options, discussed later in this chapter, were established in alignment with the following considerations. Establish costs There are four major undertakings in the process of establishing costs under the pricing framework. These are explored below. Define the activity The activities undertaken by Parks Victoria which need to be accounted for in the cost recovery process are those which are directly related to the provision of camping product in Victoria’s national and state parks. This includes the facilities and services used specifically for camping (i.e. campsite establishment, upgrades and maintenance, shower/toilet blocks, ranger checks, fee collection and booking systems). Activities associated with national park facilities and services that are not directly associated with the provision of camping, such as maintenance of walking tracks, vehicle entry or wildlife protection, are excluded from the pricing of camping fees. Define the costs The costs which need to be recovered through the camping fee pricing structure are those which are directly attributable to the provision of facilities and services used specifically for camping. These costs are described in detail in Section 4.3.3. Major costs include direct costs, corporate costs, depreciation and capital asset charges. Decide methodology For a detailed description of the methodology, please refer to Section 4.1. Collect cost data For a detailed description of the methodology, please refer to Section 4.1. Decide how to set prices There are several Government principles which underpin the decision making process for setting prices in alignment with the DEPI pricing framework. This section explores these underlying principles while focussing on three major decision points: • Who should pay for Government provided goods/services? • How much should be paid – when is it appropriate to charge below/above full cost recovery? • How should costs be recovered – what method of recovering costs is appropriate? 73 Victorian National Parks Camping and Accommodation Fees RIS Who should pay for the product? In alignment with the Government’s principle of cost recovery outlined in Section 2.3.1, the cost of providing camping facilities and services in Victoria’s national and state parks should be borne by those who use these services. Under this user-pays system, the costs of providing the camping product will be recovered through the fees charged for the services. Ideally, the different service levels of camping product provided (ie ‘very high’, ‘high’, ‘mid’ etc) will be reflected in their pricing so that users will pay an appropriate price for each service level. This will ensure there is no crosssubsidisation across product offerings. How much should the product be? In alignment with the pricing framework, there are three additional principles which should be considered when deciding what prices should be applied to the camping fee pricing structure. These are: • Scarcity rent • Competitive neutrality • Policy Outcomes Scarcity rent The principle of scarcity rent states that where scarcity or a restriction on supply causes excess demand for a good or service, prices should capture private benefits that exceed cost recovery. To capitalise on scarcity rent opportunities, peak and off peak prices will be applied. Fees outlined in Chapter 6 are based on a ten per cent spread between peak and off peak prices based on the spread applied to the majority of fees listed in the current fee schedule. DEPI has indicated that ‘special fees’ will be charged for unique location specific characteristics. These ‘special fees’ grant individual parks a degree of flexibility in allowing additional fees to be applied in situations of excess demand, utilising available scarcity rents. In these situations, the campsites would be operating above full cost recovery levels. Competitive neutrality The principle of competitive neutrality states that where the Government is providing a good or service in competition with private providers (or potential competition) prices may be set above direct cost recovery to compensate for public sector advantages. Essentially, this means applying ‘fully cost reflective’ pricing, considering factors such as: • The value of the land itself • The opportunity cost of any other capital • The corporate services that Parks Victoria and DEPI have access to • Any relevant taxes and charges. 74 Victorian National Parks Camping and Accommodation Fees RIS As the Government has rarely had to pay any land value costs for the camp sites, it should be considered whether the camping fees should be set at a rate above full cost recovery in order to fully reflect costs and remain competitively neutral. Policy outcomes Ideally, cost recovery arrangements should be consistent with overarching Government policy objectives. Under this framework, the greater educational, health, environmental and economic benefits of camping in Victoria’s national and state parks should be considered. These wider benefits have not been quantified in this analysis are understood as tangible positive impacts generated by the provision of camping and accommodation facilities in Victoria’s national parks. The Government promotes the accessibility and affordability of parks, encouraging increased use of park facilities by the public. In alignment with health and community development objectives, the Government may wish to subsidise camping fees. In addition, it could be argued that visitation to parks in regional areas provides a boost to regional economies. Reflecting with regional development strategies, the Government may wish to subsidise camping fees in specific regions. However, the level of subsidy provided should demonstrate a value proposition when compared against an alternative method of achieving the same policy objective. The policy objectives relating to increasing visitation to Victoria’s national and state parks must be balanced against the Government’s commitment to achieving cost recovery. Any situation which results in reduced park visitation over the longer term will not be aligned to broader policy objectives. How should payment be collected? Deciding in what form and under what method costs are recovered can influence the level of cost recovery achieved. Under the pricing framework, there are three principle considerations. These are: • Pricing structures should be legal and cost effective • Pricing structures should be simple and transparent • Allocation methods should enhance transparency, fairness and efficiency 75 Victorian National Parks Camping and Accommodation Fees RIS Legal and cost effective In principle, the costs of administering the camping fees should be as cost effective as possible. In addition the pricing structure must always be legal. As the introduction of camping fees across Victoria’s national and state parks will require a ministerial determination, which will also include revised terms and conditions, it is possible to introduce new legal requirements in the payment methods of camping fees. A range of options for the payment of fees, and influences on efficiency is provided below: Table B.2: Methods of collecting payment Collection method Online payment connected to booking confirmation Description Campsites must be pre-booked and paid online. Rangers conduct random checks at camp sites for compliance. Roofed accommodation is most commonly booked through online avenues. Efficiency impacts Medium level of compliance. Difficulties for spontaneous or manual payments (less relevant with rise of smartphones) Low costs of fee collection Supplementary phone contact where appropriate Purchase from a PV office, customer service centre or designated provider. Users purchase a permit prior to camping, Rangers conduct random checks at sited for compliance purposes. Honesty box Honesty box provided at each campsite with receipts to be attached to tents/vehicles. Random ranger checks to see if permits have been obtained. Lower level of compliance Lower costs of fee collection Some risk of theft and vandalism Difficulty collecting fees on a regular basis from remote locations Ranger collection Ranger collects fees from each tent each night. Higher level of compliance Higher costs of fee collection Difficulty collecting fees on a regular basis from remote locations Security risk for staff collection fees Other popular methods of booking campsites include phone bookings, booking at the park entrance and written applications. The cost effectiveness of each of these options needs to be considered. It is expected that the revenue generated by basic and very basic campsites would not be high enough to warrant constant ranger supervision. In these cases, payment collection models such as phone bookings may be a more cost effective option, despite 76 Victorian National Parks Camping and Accommodation Fees RIS lower expected compliance levels. It will be possible to utilise a range of payment options over the parks and reserves. Simple and transparent The pricing framework states that those using the public land estate should have a clear understanding as to what, when and how prices are charged. However, simplicity can sometimes compromise equity. It is important that the pricing structure is easy to understand, but also important that the pricing structure is equitable. In this case, some options in relation to pricing structures are established below, with simplicity and effectiveness outcomes estimated for each option. Table B.3: Pricing structure options Option Description Level of simplicity Level of equity Option 1: Straight camping fee A single camping fee charged for all camp grounds regardless of service level High Low Option 2: Camping fee by service level A straight camping fee for each service level i.e ‘very high’, ‘high’, ‘mid’ and ‘basic and very basic’ Medium Medium Option 3: Camping fee by service level with additional provisions There is a single camping fee for each service level, with fee differences for peak/off peak camping, and special service offerings Medium High Allocation methods As detailed in the above discussion on scarcity rent, the supply of some high demand camping products can be limited. In these cases, how this limited supply is allocated can impact on the overall benefits available to society through the provision of camping facilities and services. Ballot systems are currently used in some parks and reserves to ensure equitable allocation over periods of excess demand. Other parks operate on a ‘first in, first served’ basis. Parks which use ballot systems often reflect the higher administrative costs associated with this process into the prices charged for peak period camping and accommodation. Implementation The pricing framework is concerned with three key questions in the implementation phase of the pricing schedule. These are as follows: • Will targeted concessions be applied • How will stakeholder consultation be conducted • What is the review process for the cost recovery arrangements? 77 Victorian National Parks Camping and Accommodation Fees RIS Targeted concessions The camping fee pricing structure needs to consider whether specific groups in society will face access barriers as a result of the proposed fees. If this is the case, targeted concessions may be employed. DEPI currently has no concession policy for camping and accommodation on public land. As prices are charged per site, as opposed to on a per person basis, it would be difficult to determine whether a specific site purchase is eligible for concession pricing. DEPI is currently considering concession pricing options and this may impact camping and accommodation fees in the future. Consultation Extensive consultation with past visitors and potential visitors regarding potential fee increases to Victorian camping product was undertaken by Deakin University for the Parks Victoria ‘Camping and Accommodation Product and Pricing Research’ study 28. Over the course of this research, two focus groups were conducted: • One focus group (visitors) comprised of five males and five females who had been camping at a Parks Victoria campsite within the last three years • One focus group (non-visitors) comprised of four males and five females who were either lapsed campers (had not been camping at a Parks Victoria campsite within the last three years) or had never camped at a Parks Victoria campsite but would consider doing so These focus groups were designed to allow a detailed exploration of the perceptions of campers, lapsed campers and potential campers of aspects relating to the camping product, including the importance of various facilities and services, as well as pricing matters. In addition to the focus groups, an on-line survey which received 488 valid responses was also conducted. From these responses, two sub samples of respondents were obtained: • 116 individuals who had not camped in any of Parks Victoria’s parks over the last three years but who would consider camping • 372 respondents who had camped at Parks Victoria parks within the last three years The survey asked respondents a selection of classificatory and behavioural questions relating to various demographic questions and camping experience. Following this, respondents were asked to rate a series of scaled questions relating to the importance and satisfaction of the facilities and services associated with camping, as well as attitudes towards pricing matters. See Chapter Nine for further detail on the consultation undertaken to date and the post RIS consultation strategy. 28 Deakin University, 2010, op. cit. 78 Victorian National Parks Camping and Accommodation Fees RIS Review Parks Victoria will closely monitor expenditure on camping and campgrounds, including projects to increase service levels and upgrade locations. While endeavouring to keep prices stable and in line with market expectations, Parks Victoria may seek to increase camping fees above the Treasurer’s rate each year or every few years, in order to achieve cost recovery. 79 Victorian National Parks Camping and Accommodation Fees RIS Appendix C - Level of Service Information on the relevant level of service category for different campgrounds under the National Parks Act is provided in Table C.1. Table C.1: Level of service categories for campgrounds under the National Parks Act Park name Camping area Proposed Level of Service category Alpine National Park All camping areas including dispersed camping Camping Pass Alpine National Park Overnight walking Special Fee Barmah National Park All camping areas including dispersed camping Camping Pass Baw Baw National Park All camping areas including dispersed camping Camping Pass Baw Baw National Park Overnight walking Special Fee Black Range State Park All camping areas including dispersed camping Camping Pass Brisbane Ranges National Park All camping areas Mid Broken Boosey State Park All camping areas Basic/Very Basic Permit Bunyip State Park All camping areas Basic/Very Basic Permit Burrowa - Pine Mountain National Park All camping areas Camping Pass Cape Conran Coastal Park Banksia Bluff Campground High Cape Conran Coastal Park All other camping areas Basic/Very Basic Permit Cape Liptrap Coastal Park Bear Gully Mid Cape Liptrap Coastal Park All other camping areas Basic/Very Basic Permit Castlemaine Diggings National Heritage Park All camping areas Camping Pass Cathedral Range State Park All camping areas Mid Chiltern-Mt Pilot National Park All camping areas including dispersed camping Camping Pass Cobboboonee National Park All camping areas Special Fee Croajingolong National Park Shipwreck Creek Mid Croajingolong National Park Wingan Inlet Mid Croajingolong National Park All other camping areas Special Fee Dergholm State Park All camping areas Camping Pass Discovery Bay Coastal Park Lake Monibeong Mid Discovery Bay Coastal Park Swan Lake Public Camp Mid Discovery Bay Coastal Park All other camping areas Special Fee Enfield State Park All camping areas Camping Pass Errinundra National Park All camping areas Camping Pass French Island National Park Fairhaven Mid Gippsland Lakes Coastal Park Bunga Arm Mid Gippsland Lakes Coastal Park All other camping areas Mid Grampians National Park Bomjinna Campground Mid Grampians National Park Boreang Campground Mid Grampians National Park Borough Huts Campground Mid Grampians National Park Buandik Mid Grampians National Park First Wannon Remote Campground Basic/Very Basic Permit Grampians National Park Jimmy Creek Campground High Grampians National Park Plantation Campground High Grampians National Park Smiths Mill Campground High Grampians National Park Stapylton Campground High Grampians National Park Strachans Campground Mid 80 Victorian National Parks Camping and Accommodation Fees RIS Grampians National Park Troopers Creek Campground Mid Grampians National Park Wannan Crossing Campground Mid Grampians National Park Dispersed bush camping Basic/Very Basic Permit Grampians National Park Overnight walking Special Fee Great Otway National Park (East section) Allenvale Mid Great Otway National Park (East section) Big Hill Camping Area Mid Great Otway National Park (East section) Cora Lynn Basic/Very Basic Permit Great Otway National Park (East section) Hammond Road Mid Great Otway National Park (East section) Herberts (Wymbooliel Camp) Basic/Very Basic Permit Great Otway National Park (East section) Jamieson Basic/Very Basic Permit Great Otway National Park (East section) Sharps Camping Area Basic/Very Basic Permit Great Otway National Park (East section) Wye River Camping Area Basic/Very Basic Permit Great Otway National Park (West section) Aire Crossing Mid Great Otway National Park (West section) Aire River (east &west) Mid Great Otway National Park (West section) Blanket Bay Mid Great Otway National Park (West section) Fork Paddocks Basic/Very Basic Permit Great Otway National Park (West section) Great Ocean Walk Special Fee Great Otway National Park (West section) Johanna Beach Mid Great Otway National Park (West section) Lake Elizabeth Mid Great Otway National Park (West section) Parker Hill Mid Great Otway National Park (West section) Redwoods Mid Greater Bendigo National Park All camping areas Camping Pass Gunbower National Park All camping areas including dispersed camping Camping Pass Hattah - Kulkyne National Park Lake Hattah Mid Hattah - Kulkyne National Park Lake Mournpall Mid Hattah - Kulkyne National Park All camping areas including dispersed camping Camping Pass Heathcote - Graytown National Park All camping areas Camping Pass Kinglake National Park The Gums Camp Mid Kings Billabong WR All camping areas including dispersed camping Camping Pass Kooyoora State Park All camping areas Camping Pass Lake Albacutya Park All camping areas Camping Pass Lake Eildon National Park Candlebark High Lake Eildon National Park Devil Cove High Lake Eildon National Park Lakeside High Lake Eildon National Park Blue Gum Flat Basic/Very Basic Permit Lake Eildon National Park Brooks Cutting Camping Area Basic/Very Basic Permit Lake Eildon National Park Coopers Point Camping Area Basic/Very Basic Permit Lake Eildon National Park Jerusalem Creek Camping Area 1-8 Mid Lake Eildon National Park Mountaineer Creek Camping Area Basic/Very Basic Permit Lake Eildon National Park O'Toole Flat Basic/Very Basic Permit Lake Eildon National Park Taylors Creek Camping Area Basic/Very Basic Permit Langi Ghiran State Park Langi Ghiran Picnic and Camping Area Camping Pass Leaghur State Park South of Lake Meran Camping Pass Lerderderg State Park O'Briens Crossing Mid Lerderderg State Park Shaws Lake Mid Lerderderg State Park Upper Chadwick Basic/Very Basic Permit Little Desert National Park Ackle Bend Campground Mid Little Desert National Park Broughtons Waterhole Basic/Very Basic Permit Little Desert National Park Horseshoe Bend Campground Mid Little Desert National Park Kiata Campground Mid Little Desert National Park Mallee Walkers Camp Basic/Very Basic Permit Little Desert National Park Yellowgums Walkers Camp Basic/Very Basic Permit 81 Victorian National Parks Camping and Accommodation Fees RIS Lower Glenelg National Park Battersbys Mid Lower Glenelg National Park Bowds Special Fee Lower Glenelg National Park Forest Camp North Mid Lower Glenelg National Park Forest Camp South Mid Lower Glenelg National Park Georges Rest Special Fee Lower Glenelg National Park Hutchessons Mid Lower Glenelg National Park Lasletts Special Fee Lower Glenelg National Park McLennans Punt Mid Lower Glenelg National Park Moleside Special Fee Lower Glenelg National Park Moleside Canoe Camp Special Fee Lower Glenelg National Park Murrells Special Fee Lower Glenelg National Park Patterson Canoe Camp Special Fee Lower Glenelg National Park Patterson Walkers Camp Special Fee Lower Glenelg National Park Pines Landing Special Fee Lower Glenelg National Park Post and Rail Special Fee Lower Glenelg National Park Pritchards Mid Lower Glenelg National Park Red Gum Landing Mid Lower Glenelg National Park Simsons Special Fee Lower Glenelg National Park Skipworth Springs Special Fee Lower Glenelg National Park Wild Dog Bend Mid Lower Glenelg National Park Wilson Hall Mid Mitchell River National Park All camping areas including dispersed camping Camping Pass Moondarra State Park Seninis Visitor & Camping Area Camping Pass Mornington Peninsula National Park Lightwood Camp Basic/Very Basic Permit Mount Arapiles - Tooan State Park Centenary Park Special Fee Mount Buangor State Park All camping areas Mid Mount Buffalo National Park Lake Catani Camping Ground (Summer & Winter) High Mount Buffalo National Park Mount Mcleod Camping Area Special Fee Mount Buffalo National Park Rocky Creek Camping Area Special Fee Mount Eccles National Park Mt Eccles High Mount Granya State Park All camping areas Camping Pass Mount Lawson State Park All camping areas Camping Pass Mount Samaria State Park All camping areas Mid Murray - Kulkyne Park All camping areas including dispersed camping Camping Pass Murray - Sunset National Park All camping areas Camping Pass Nooramunga Marine & Coastal Park All camping areas Basic/Very Basic Permit Nyah-Vinifera Park All camping areas including dispersed camping Camping Pass Paddys Ranges State Park Camping Area (adjacent to Karri Track) Camping Pass Snowy River National Park All camping areas Camping Pass Kara Kara National Park All camping areas Camping Pass Terrick Terrick State Park Mt Terrick Terrick Camping Pass The Lakes National Park Emu Bight Mid The Lakes National Park Rotamah Island Mid Warby-Ovens National Park All camping areas Camping Pass Wilsons Promontory National Park Barry Creek Special Fee Wilsons Promontory National Park Five Mile Beach Special Fee Wilsons Promontory National Park Halfway Hut Special Fee Wilsons Promontory National Park Johnny Souey Cove Special Fee Wilsons Promontory National Park Little Waterloo Bay Special Fee Wilsons Promontory National Park Lower Barry Creek Special Fee Wilsons Promontory National Park Oberon Bay Special Fee Wilsons Promontory National Park Refuge Cove Boaters Camp Special Fee 82 Victorian National Parks Camping and Accommodation Fees RIS Wilsons Promontory National Park Refuge Cove Hikers Camp Special Fee Wilsons Promontory National Park Roaring Meg Special Fee Wilsons Promontory National Park Sealers Cove Special Fee Wilsons Promontory National Park Stockyard Camp High Wilsons Promontory National Park Tidal River / Norman Bay Very High Wilsons Promontory National Park Tin Mine Cove Boaters Camp Special Fee Wilsons Promontory National Park Tin Mine Cove Hikers Camp Special Fee Wyperfeld National Park Round Swamp Basic/Very Basic Permit Wyperfeld National Park All other camping areas Mid Source: Parks Victoria 83 Victorian National Parks Camping and Accommodation Fees RIS Appendix D - Visitor attitudes towards camping The following table demonstrates visitor attitudes towards camping as found in the Deakin report conducted for Parks Victoria. Table D. 1: Community attitudes towards camping Strongly disagree Strongly agree % agree I have gone camping in the past because it is a relatively cheap and affordable holiday 5% 32% 78% I have gone camping in the past because it is a break from my usual routine 4% 32% 80% I think of camping as a healthy activity 1% 34% 86% Even if some camping fees were to increase I think some services and facilities in camping grounds should be provided free of charge 1% 42% 87% Some services and facilities in camping ground should be subsidised because State and National Parks are community goods 1% 37% 81% Tax payers that do not use camping ground in state and National parks should not have to subsidise camping holidays for those that do 21% 14% 37% I would be unhappy to subsidize camping facilities that I do not use or receive any benefit from 18% 16% 42% If camping facilities were upgraded I would consider going camping more often 8% 14% 55% Before going camping I compare prices between public and privately operated camping ground in order to decide in which camping ground we will stay 18% 14% 46% Camping fees should be increased to reflect the cost of delivering and maintaining camping facilities and services 12% 9% 44% It is important to charge camping gees to maintain, reinvest and improve camp grounds 5% 16% 66% It is important to retain some free camping grounds 2% 41% 83% I am not concerned about the fact that sites that are currently free may have a camping fee introduced 15% 13% 43% If a camping fee were to be introduced to sites that are currently free I would consider visiting another destination 8% 17% 53% I would be happy to pay a reasonable fee to camp, if I knew that the fees were based on the cost of maintaining camping facilities 3% 32% 81% 84 Victorian National Parks Camping and Accommodation Fees RIS If camping fees were to be introduced to areas that are currently free to camp in, I would reduce the number of times that I would go camping. 12% 13% 45% Existing Parks Victoria’s camping grounds are tired and in need of upgrading and refurbishment 4% 11% 55% I would consider visiting Parks Victoria’s camping grounds if there were more cabins, safari tents or onsite vans 18% 14% 47% I have gone camping in the past because it allows me to get close to nature 4% 27% 73% Going camping allows me to be with my friends or my relatives 4% 28% 76% I would take the risk of being fined and not pay for the camping fee 40% 5% 19% Source: Deakin University, 2010, Research report for Parks Victoria: Camping and Accommodation Product & Pricing, Table A-14. 85 Victorian Parks Camping and Accommodation RIS Appendix E - Benchmarking Table E.1: Benchmarking of private provider prices (select, prices per campsite night) Region & provider Low season Powered Non powered Mid -season Powered Non powered Peak season Powered Non powered Yarra Valley & Dandenong Warburton Caravan Park $24.00 $20.00 $30.00 $26.00 Healesville Tourist Park $38.00 $32.00 $42.00 $36.00 Average for region $31.00 $26.00 $36.00 $31.00 Rosebud, Rye & Sorrento foreshore camping (council run) $30.00 $25.00 $45.00 $40.00 Dromana Tourist Park $30.00 Kangerong Holiday Park $27.00 Mornington Peninsula $35.00 $45.00 $24.00 $42.00 Western Port Caravan Park Average for region $29.00 $24.50 $35.00 $26.00 $21.00 $30.00 $27.00 $24.00 $39.75 $32.00 $42.00 $32.00 $36.00 $31.00 $38.00 $34.00 $47.00 $47.00 $29.00 $23.00 Goldfields, Daylesford & Macedon Ranges Jubilee Lake Holiday Park $21.00 Castlemaine Caravan Park Gold Nugget Tourist Park $33.00 $29.00 Windmill Holiday Park $34.00 $34.00 Shady Acres Caravan Park $26.00 $20.00 $43.00 $43.00 86 Victorian Parks Camping and Accommodation RIS Central City Caravan Park $34.00 $29.00 $40.00 $32.00 $40.00 $32.00 Average for region $30.60 $26.60 $37.67 $32.00 $38.67 $33.17 A Maze n Things Holiday Park $28.00 $28.00 $35.00 $35.00 $48.00 $48.00 Cowes Caravan and Camping Park $35.00 Amaroo Holiday Park* $40.00 Phillip Island Caravan Park* $32.00 $27.00 Average for region $33.75 $27.50 Southcombe Caravan Park $37.00 $34.00 Skenes Creek Beachfront Park (3 adults) $27.00 $22.00 Bimbi Park $25.00 $20.00 Cumberland River Holiday Park $27.00 River Vu Caravan Park, Nelson $23.00 Kywong Caravan Park $25.00 Philip Island $37.00 $52.00 $80.00 $50.00 $46.00 $57.50 $47.00 $43.00 $38.00 $65.00 $55.00 $40.00 $35.00 $60.00 $12.00 $16.00 $23.00 $16.00 $20.00 $32.00 $25.00 $36.00 $35.00 Great Ocean Road $30.00 $37.00 $25.00 $12.00 Big 4 Anglesea Holiday Park $45.00 Marengo Holiday Park $28.00 $24.00 $30.00 $24.00 $58.00 $40.00 Surfside Holiday park $39.00 $54.00 $47.00 Torquay Foreshore Caravan Park $31.00 Average for region $29.11 $22.67 $32.33 $20.33 $48.50 $33.50 Grampians Paradise camping and caravan Parkland $30.00 $25.00 $35.00 $30.00 $40.00 $35.00 Halls Gap Caravan Park $34.00 $27.00 $38.00 $32.00 Halls Gap Lakeside Tourist Park $28.00 $22.00 $37.00 $28.00 $65.00 Grampians $30.00 $25.00 87 Victorian Parks Camping and Accommodation RIS Grampians Gardens Tourist Park $28.00 $25.00 Emu Holiday Park $26.00 Acacia Caravan Park Average for region $32.00 $28.00 $35.00 $30.00 $24.00 $30.00 $28.00 $29.00 $26.00 $32.00 $26.00 $29.17 $24.83 $32.33 $27.67 $35.33 $29.83 Bright Holiday Park $35.00 $30.00 $42.00 $36.00 $50.00 $45.00 Mansfield Holiday Park $28.00 $25.00 $32.00 $28.00 $35.00 $32.00 Rutherglen Caravan and Tourist park $29.00 $22.00 $33.00 $26.00 Yackandandah Holiday Park $30.00 Mt Beauty Holiday Centre & Caravan Park $27.00 $22.00 High Country Holiday Park $30.00 $26.00 Omeo Caravan Park $30.00 $28.00 Jamieson Caravan Park $30.00 $25.00 Average for region $29.88 $25.43 Lakes Entrance Tourist Park $25.00 $22.00 Eagle Point Caravan Park $14.00 $10.00 Inverloch Surfside Caravan Park $35.00 Loch Sport Holiday Park $35.00 $29.00 $42.00 $33.00 Woodside Beach Caravan Park $30.00 $20.00 $35.00 $28.00 Mallacoota Foreshore Caravan Park (council) $20.00 $14.00 $26.00 $20.00 $35.00 $29.00 Cann River Rainforest Caravan Park (council) $20.00 $10.00 $20.00 $10.00 $20.00 $10.00 Average for region $25.57 $17.50 $28.25 $15.33 $38.00 $27.50 High Country $35.00 $33.00 $35.50 $40.00 $28.00 $30.67 $38.00 $33.00 $32.00 $28.00 $35.00 $30.00 $37.57 $32.33 $48.00 $43.00 $31.00 $22.00 Gippsland $22.00 $16.00 $45.00 $55.00 88 Victorian Parks Camping and Accommodation RIS The Murray Murray River Holiday Park $30.00 $48.00 Echuca Holiday Park $29.00 $25.00 Victoria Lake Holiday Park $30.00 $27.00 Cohuna Waterfront Holiday Park $28.00 $24.00 Big 4 Riverside Swan Hill $36.00 $31.00 River Road Caravan Park $23.00 Strayleaves Caravan Park $25.00 Moama Riverside Holiday and Tourist Park $30.00 Average for region $28.88 $35.00 $33.00 $32.00 $29.00 $25.00 $48.00 $44.00 $35.00 $30.00 $39.00 $35.00 $40.00 $31.00 $30.00 $15.00 $25.00 $15.00 $42.00 $24.40 $31.00 $30.50 $38.38 $31.00 Wilson's Promontory Toora Tourist Park $25.00 $35.00 Waratah Bay Caravan Park $30.00 $25.00 Yanakie Caravan Park $25.00 $20.00 Average for region $26.67 $22.50 $32.50 Average across sample $29.15 $23.81 $32.59 $30.00 $60.00 $25.00 $60* $50* $35.00 $25.00 $25.00 $51.67 $37.50 $26.57 $40.55 $31.79 Source: Provider websites, accessed 2 November, 2012. Notes: *Price is inclusive of four people 89 Victorian Parks Camping and Accommodation RIS Appendix F - The proposed determination National Parks Act 1975 DETERMINATION UNDER SECTION 21(2) FOR FEES AND CHARGES FOR OCCUPYING CAMPING PLACES AND BUILDINGS I, Ryan Smith MP, Minister for Environment and Climate Change, under section 21(2) of the National Parks Act 1975 determine that— (1) the following fees and charges are payable for permits granted under section 21(1)(a) of the National Parks Act 1975— (a) for permits to occupy camping places during the peak season, the fees specified in Schedule 1; (b) for permits to occupy special camping places in the parks specified in Schedule 2, the fees and charges specified for those parks in Schedule 2; (c) for overnight hiker permits to occupy camping places, the fees and charges specified in Schedule 3; (d) for permits to occupy a roofed building, the fees and charges specified in Schedule 4; and (2) despite clause (1)— (a) a 10 per cent discount applies to the fees and charges specified in Schedule 1 for permits to occupy camping places the period commencing on 1 May and ending on 31 October in each year except for the period between school terms 3 and 4; (b) the following are the non refundable fees and charges for the cancellation, alteration or reduction in duration of stay or occupants— i. 30 days’ or more notice, 50% of the applicable fees per night; ii. less than 30 days’ notice, 100% of the applicable fees per night; iii. school groups— 1 to 6 days’ notice, 50% of the applicable fees per night; 7 to 30 days’ notice, 25% of the applicable fees per night, and 90 Victorian Parks Camping and Accommodation RIS greater than 30 days’ notice, 20% of the applicable fees per night; and (3) in this determination— fee unit has the same meaning as in section 4 of the Monetary Units Act 2004 as if this determination were an Act or a statutory rule; off peak season means— (a) for Schedules 1, 2 and 3, the period commencing 1 May and finishing on 31 October in each year except for the period between school terms 3 and 4; (b) for Schedule 4, the period commencing 1 May and finishing on 31 August in each year except for the period between school terms 2 and 3; peak season means— (a) for Schedules 1, 2 and 3, the following periods— (i) commencing on 1 November and finishing on 30 April in each year; (ii) between school terms 3 and 4 in each year; (b) for Schedule 4, the period between the end of school term 4 and school term 1 in the following year; shoulder season means the period commencing 1 September and finishing on 30 April in addition to the period between school terms 2 and 3 and school terms 2 and 3 and 4 but does not include peak season; special camping places means the sites specified in Schedule 2. Dated RYAN SMITH Minister for Environment and Climate Change 91 Victorian Parks Camping and Accommodation RIS SCHEDULE 1 Camping fees peak season (fee units per night) Category Very High (Non powered) Very High (Powered) High (Non powered) High (Powered) Mid Basic or Very Basic Site up Site up to 8 to 6 persons persons Per person School groups site up to 6 persons School groups per person Additional vehicle 4.61 - - 4.15 0.69 0.72 Booking fee ballot/ booked period, per site 0.79 5.13 - - - - 0.72 0.79 - 3.79 - 3.41 0.69 0.72 0.79 - 4.21 - 3.79 0.76 0.72 0.79 - 2.94 1.50 1.47 0.76 2.65 - 0.53 - 0.72 - 0.79 - SCHEDULE 2 Fees for special camping places year round (fee units per night) Category Lower Glenelg NP (Canoe Camp) Mt Arapiles-Tooan SP School groups per person Per person 0.70 - Boat / Canoe / Kayak per person 0.79 - 0.39 - Booking administration (per booking) Individuals 0.79 Groups 1.17 - 92 Victorian Parks Camping and Accommodation RIS SCHEDULE 3 Fees for overnight hiker permits year round (fee units per night) Category Per person School groups per person Site 1-3 persons Group exclusive Group site 1-3 Booking administration (per booking) Alpine NP (Falls to Hotham Alpine Crossing) Great Otway NP (Great Ocean Walk) Wilsons Promontory NP, Mt Buffalo NP - - 2.34 16.82 2.10 Individuals 0.79 Groups 1.17 0.97 0.88 - - - 0.79 0.70 - - - Individuals 0.79 Groups 1.17 Individuals 0.79 Groups 1.17 Croajingolong NP (Wilderness Coast Walk), Grampians NP Alpine NP, Baw Baw NP, Cobboboonee NP, Discovery Bay CP, Lower Glenelg NP (Great South West Walk) 93 Victorian Parks Camping and Accommodation RIS SCHEDULE 4 Fees for roofed accommodation (fee units per night) Category Peak Shoulder season season Off peak season Booking fee ballot/ booked period per accommodation Administration fee – applies to phone assisted amendments and changes to bookings 6 Bed Cabins Wilsons Promontory NP 23.70 18.96 17.34 0.79 1.56 4 Bed Huts 10.34 8.26 7.44 0.79 1.56 6 Bed Huts 15.75 12.59 11.33 0.79 1.56 12 Bed Lodges 38.59 30.87 27.79 0.79 1.56 24 Bed Lodge 77.70 62.16 55.94 0.79 1.56 30 Bed Lodge 97.13 77.90 69.94 0.79 1.56 Lightstation - Standard Plus 10.42 - 9.38 - 1.56 Lightstation - Standard 8.83 - 7.05 - 1.56 Wilderness Retreat - (Single or twin share, with ensuites) 23.56 - 23.56 - 1.56 8 Bed Cabins 17.51 0.79 1.56 17 Bed Lodge 58.89 47.11 42.41 0.79 1.56 Wilderness (Single or twin share, no ensuites) 14.14 - 14.14 0.79 1.56 - 1.56 14 Bed Shearers Quarters 29.14 Cape Conran CP 14.00 12.61 Murray-Sunset NP - NOTES (1) The National Parks Act 1975 and its regulations must be observed and complied with by the permit holder and any person accompanying the permit holder within a Park. (2) A permit is not transferable to another person. (3) A permit is not valid until full payment is made. (4) Failure to comply with a permit, the National Parks Act 1975 or its regulations may result in any or all of the following occurring: the non-refundable cancellation of your permit; an offence being committed, or a request to leave the park. (5) School term dates are available on www.education.vic.gov.au. 94 Victorian Parks Camping and Accommodation RIS Appendix G- Proposed fee structure Detailed schedules of fees under the preferred option are provided below for permit camping, the camping pass system, special camping, overnight hiker permit camping and roofed accommodation. Note that the final fee schedules will also express fees in terms of fee units. A fee unit is a fixed quantum of dollars and cents that reflects one unit. This quantum changes each year with the Treasurer’s rate of inflation. Table G.1: Proposed fees for permit camping (2013-14 peak rates) Category Site up to 8 persons Very High - Non powered Very High - Powered Site up to 6 persons Per person School groups site up to 6 persons School groups per person Additional vehicle $59.20 $53.30 $8.90 $9.20 $65.90 N/A N/A $9.20 High - Non powered $48.70 $43.80 $8.80 $9.20 High - Powered $54.10 $48.70 $9.70 $9.20 Mid $37.80 $18.90 $34.00 $6.80 $9.20 $19.30 $9.70 N/A N/A N/A Basic & Very Basic 1 Notes: Peak period rates apply from the Melbourne Cup Weekend to the last Sunday in April inclusive, and also for the September school holidays. A 10 per cent discount applies during off-peak periods. For all parks conducting a ballot or expression of interest process for camping; a $10 ballot fee per campsite will apply for all successful applicants. Table G.2: Proposed fees for camping pass (2013-14 rates) Category Per Vehicle/Boat Small bus Large bus Motorcycle Hiker/Cyclists Additional vehicle Annual $121.70 $347.70 $608.50 $43.50 $43.50 TBD Monthly $81.10 $231.70 $405.50 $29.00 $29.00 TBD 7 Day $46.40 $132.60 $232.00 $16.60 $16.60 N/A Overnight $17.40 $49.70 $87.00 $6.20 $6.20 N/A 95 Victorian Parks Camping and Accommodation RIS Table G.3: Proposed fees for special camping sites (2013-14 rates) Exclusive School groups site up to 6 persons School Groups per person Site 1-4 persons Per person Boat / Canoe / Kayak per person Booking administration (per booking) Lower Glenelg NP Canoe Camp N/A N/A $9.00 N/A N/A $10.00 Individuals $10.00 Groups $15.00 Mt Arapiles- Tooan SP N/A N/A N/A N/A $5.00 N/A N/A Plenty Gorge Parklands Nioka Bush camp $360 ($420 with kitchen & hall) N/A N/A N/A N/A N/A N/A Yarra Valley Parklands $315.00 N/A N/A N/A N/A N/A N/A Category Table G.4: Proposed fees for overnight hiker permits (2013-14 rates) Category Overnight adult Per person School groups per person Site 1-3 persons Group exclusive Group site 1-3 Booking administration (per booking) Falls to Hotham Alpine Crossing, Great Ocean Walk N/A N/A N/A $30.00 $216.00 $27.00 Individuals $10.00 Groups $15.00 Wilsons Promontory NP, Mt Buffalo NP N/A $12.50 $11.30 N/A N/A N/A Individuals $10.00 Groups $15.00 96 Victorian Parks Camping and Accommodation RIS Croajingolong National Park (Wilderness Coast Walk), Grampians National Park, Alpine National Park, Baw Baw National Park, Cobboboonee National Park, Discovery Bay Coastal Park, Lower Glenelg National Park (Great South West Walk) N/A $10.00 $9.00 N/A N/A N/A Individuals $10.00 Groups $15.00 Table G.5: Proposed fees for roofed accommodation (2013-14 rates per accommodation) Category Peak season Shoulder season Off peak season Extra person Booking fee ballot/booked period 34 Bed Bunkhouse - Plenty Gorge Nioka Bush camp $510.00 6 Bed Cabins - Wilsons Prom $304.30 $243.40 $222.70 $10.00 $20 8 Bed Cabins - Cape Conran $224.80 $179.80 $161.90 $10.00 $20 5 Bed Cabin - Buchan Caves $95.60 N/A $86.10 4 Bed Huts - Wilsons Prom $132.70 $106.10 $95.50 $10.00 $20 6 Bed Huts - Wilsons Prom $202.20 $161.70 $145.50 $10.00 $20 12 Bed Lodges - Wilsons Prom $495.50 $396.40 $356.80 $10.00 $20 24 Bed Lodge - Wilsons Prom $997.70 $798.10 $718.30 $10.00 $20 30 Bed Lodge - Wilsons Prom $1,247.20 $997.70 $898.00 $10.00 $20 $756.10 $604.90 $544.50 $10.00 $20 Lightstation - Wilsons Prom Standard Plus 133.80 N/A $120.50 $20 Lightstation - Wilsons Prom Standard 100.50 N/A $90.50 $20 Lightstation - Gabo Island $350.00 N/A $315.00 $20 14 Bed Shearers Quarters - Murray Sunset $374.10 17 Bed Lodge - Cape Conran $510.00 Administration fee – applies to phone assisted b $20 $20 $20 97 Victorian Parks Camping and Accommodation RIS Wilderness Retreat - Wilsons Prom (Sole use or twin share, with ensuites) $302.50 N/A $302.50 $24.20 Wilderness Retreat - Cape Conran & Buchan Caves (Sole use or twin share, no ensuites) $181.50 N/A $181.50 $21.80 $20 $10.00 $20 98 Accessibility If you would like to receive this publication in an accessible format, such as large print or audio, please telephone 03 9651 5111 or email scb@dpc.vic.gov.au DSE 8302