Club-level rallying in the lower Cotter catchment
This submission hopes to facilitate limited appropriately managed club-level rallying
in the lower Cotter catchment while supporting the Catchment Management Plan
mission of restoring the catchment to a stable condition that supports the delivery of
clean water and that also allows for a range of activities that are compatible with the
protection of water resources.
The submission has been endorsed by the two clubs involved in rallying in the ACT,
the Brindabella Motor Sport Club and the Light Car Club of Canberra1.
Summary
Those involved in local rallying, particularly the local event organisers and
community-based motor sport clubs, recognise that ensuring water quality from the
lower Cotter catchment is the highest priority land use for that area. Through the
adoption of a proposed rally-management plan, the local motor sport community
believes that limited, controlled access to the catchment is consistent with this land
use priority at the same time as providing ongoing opportunities for appropriate
community access and a commitment to an important part of Canberra’s sporting
heritage.
Excluding all rallying from the lower Cotter catchment has significant implications
for those directly involved as well as for other members of the community and for
managers of other areas of recreational land. Allowing limited appropriately managed
rallying in the catchment limits negative impacts on other recreational areas in the
ACT, provides positive social and environmental benefits for those involved and for
the wider community, and continues the long heritage of Canberra as the home of
Australian rallying.
Key issues:

Recognising the water resource management priority for the Lower Cotter
Catchment and acknowledging water quality as the highest priority land use;

Recognising that recreational activities, including some motor sport, are not
inconsistent with the water quality priority and with the proposed ecosystem and
risk management approaches to catchment management; and

Allowing appropriately managed motor sport in the catchment through application
of an agreed management plan.
Impacts of excluding all rallying from the lower Cotter catchment
A recent decision of the Lower Cotter Catchment Coordination Committee has meant
that all car rallying has been excluded from the lower Cotter catchment area. This
exclusion has significant adverse implications for those directly involved
(competitors, spectators, community groups supported by rallying, local businesses)
Please note the differences between club-level and international-level rallying – international events (like the
Rally of Canberra) need certainty of access and are not able to respond to changing circumstances like variable
roads availability. An international event would not be able to be cancelled or modified in case of extreme
weather events or high fire risk in the same way that a lower status event can.
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as well as for other members of the community and for managers of other areas of
recreational land.
For participants and spectators, the lower Cotter is an important area in terms of the
heritage value of the roads used for competition (international, national and local
rallies have been run there for over 40 years), the particular and unique challenges of
the roads in that area, the area's proximity to suburban Canberra, and the shortage of
similar quality areas for rallying in and close to the ACT. Loss of those particular
roads would be significant even if replaced by equivalent distance roads in another
area – the lower Cotter roads provide a unique experience in the ACT and region – the
particular surface material, the ‘flow’ of the roads, the nature of roads following
natural contours is different to roads in other areas in the ACT. The lower Cotter
catchment is the ‘spiritual’ home of rallying in the ACT, itself the centre of rallying in
Australia.
For the wider community, excluding rallying in the catchment increases pressure on
other areas that are still available to rallying in the ACT. Often these alternate areas
are much closer to residential areas (with attendant noise impacts) or have significant
groups of competing uses. The lower Cotter was an area that was much less utilised
for running, mountain biking, dog sledding in comparison to areas like Greenhills,
Stromlo and Kowen. With the loss of the lower Cotter, rallying is forced to use areas
that are less suitable and which have impacts on other forest users to a greater extent
than would be the case had the Cotter been available.
The loss of the Cotter catchment also means increasing pressure on the infrastructure
of other areas suitable for rallying. Limiting the available roads means other roads are
used more frequently, increasing the potential for road damage. Spreading the load
across a larger area reduces the cumulative impact on the entire system of recreational
areas. Allowing limited motor sport on roads identified for fire management access
purposes can be beneficial in keeping those roads in a state fit for their operational
purpose.
Removing the catchment for appropriate motor sport use also goes against the major
goal of the Lower Cotter Catchment Draft Strategic Management Plan of an involved
and supportive community. For example, the Uriarra Community Association and
other Canberra community groups uses local rallies for fundraising through service
provision, local rural fire brigades and SES units use events as training opportunities,
and local businesses provide specialist services and products to participants. Losing
the catchment would mean a loss of significant public goods to the non-rallying ACT
community. The rallying component of the community is actively engaged with these
wider-community activities, playing a role in the protection of the catchment from
fire, but also involved in restoring the catchment through participation in Greening
Australia planting activities and Landcare initiatives.
Existing management approaches
Organisers and competitors recognise that their sport has the potential for notinsignificant impacts to the local environment. However, unlike other unregulated
users and uses of the lower Cotter catchment, organisers take steps to ensure risks to
the resource are managed appropriately. Environmental risks are the subject of
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extensive risk identification and management activity undertaken by all organisers
prior to and during events.
Risks such as fires and toxic spills are managed in accordance with agreed
management plans. For example, risks associated with fire in forest areas are
managed through timing rallies outside periods of higher fire danger, having officials
and competitors trained and equipped to manage fires associated with an accident and
engaging specialist fire responders to deal with refuelling fires.
Potential risks to water quality are similarly managed. Potential toxic fluid spills
(from refuelling or servicing operations) are managed through tight controls on these
activities (including restricting refuelling operations to prepared areas, supervision by
marshals of refuelling and servicing), by adherence to strict vehicle construction
specifications and by a well designed emergency response.
The key issue regarding the use of the lower Cotter catchment area appears to be
sedimentation of waterways as a result of road damage and subsequent sediment runoff. This issue is currently managed through selection of the most suitable roads,
management of road use to limit passage of vehicles in the most sensitive areas,
rotating roads used in a roster to eliminate overuse, and very importantly, making
active decisions to not use particular roads or sections of roads in adverse conditions
(particularly rain).
[I would point out the potential for damage to the catchment from unregulated uses –
for example, four wheel drive enthusiasts and off-road motorcyclists cause significant
damage to forest roads and will continue to do so unless controlled.]
While recognising the importance of water quality within the lower Cotter catchment
area and the Draft Catchment Management Plan, I am proposing the adoption of
guidelines to facilitate the continued utilisation of these areas. These guidelines
extend the measures currently undertaken by organisers.
This approach follows the example set in Western Australia, where rallying is
permitted within surface water catchments according to the WA Department of
Environment’s Policy and Guidelines for Recreation within Public Drinking Water
Source Areas on Crown Land. That policy recognises rallying as an acceptable
activity with best management practices within a P1 water source area (that is, within
2km of the top water level of a storage reservoir). For comparison, off-road vehicle
use and hunting (both common activities in the lower Cotter catchment) are
unacceptable activities.
New management approaches to allow a return to the lower Cotter catchment
To enable a return to the catchment while recognising the new priority for the
catchment, I am proposing some additional management measures. These measures
would be in addition to existing compliance with the regulatory requirements of the
motorsport governing body (CAMS) and its insurers and the (erstwhile) Department
of Urban Services and ACT Forests, along with the Emergency Services Authority,
Australian Federal Police, ACT Workcover, and the ACT’s third party insurer. It may
be that these measures, and other aspects of the sport’s relationship with the ACT
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Government might best be described in a Memorandum of Understanding between
CAMS and the ACT Department of Territory and Municipal Services.
These additional measures have been designed to be consistent with the Draft
Catchment Management Plan major goal of access and use consistent with delivering
clean water and healthy landscapes. I propose:
a. Limiting road use to those roads identified in future catchment management plans
as essential for fire management and fire suppression. Rallying users recognise
that the current road network is inappropriate both for modern forestry methods
and for an ongoing role in fire management and for other operational purposes.
Roads can be the source of significant watercourse sedimentation. Limiting the
roads used allows the choice of the most appropriate roads to protect water quality
and for those chosen roads to be maintained appropriately;
b. Close cooperation with roading and soils officers in the relevant land management
agency to select roads in the best condition at the time of the event and rotating
roads used. Selecting roads not impinging on riparian, flora, fauna, or cultural
heritage exclusion zones. Determining an agreed ‘selection’ of roads for event
organisers to choose from;
c. Field inspection of roads to be used prior to events to ensure road condition is
appropriate and to allow comparison post-event to assess actual impact, if any;
d. Formalising a weather management plan to introduce key metrics for determining
when road conditions due to rain or extended dry conditions could have an
increased affect on sedimentation risk based on soil erodibility. Ensuring events
only run when conditions are appropriate. This approach extends that approach
used in the catchment at the moment for operational activities undertaken by
forest workers, and might include cessation of activity when passage of a test road
vehicle is causing any rutting or when there is run-off from the road surface or
water in table drains. Very High and Extremely erodible soils will require 2 –3
days of dry weather before operations commence;
e. Adoption of a roads credit system (similar to the existing noise credit regime)
recognising that certain levels of competition and categories of competing
vehicles carry different levels of sedimentation risk. Such a system would restrict
the number of vehicles of particular types allowed on catchment roads over any
period of time, weighted in favour of those times when rain and road moisture
conditions are most appropriate.
For example, the system might allocate 120 credits for Autumn and Spring, 80
credits for winter, and 100 credits for summer. A two-wheel-drive competing
vehicle in one rally using the catchment would use one credit for one pass over a
road. An all-wheel-drive vehicle would use one and a half credits, recognising the
additional pressure those additional driven wheels place on the infrastructure. A
vehicle in an international rally would use two credits, recognising the heightened
performance of such vehicles and their latest specification tyres. Such an
approach would effectively limit rallying to one event at state championship level
in Autumn or Spring, one small club level event in winter, and a mid-level event
in summer. International events are unlikely to pursue using the catchment due to
the possibility of adverse weather and the need to prevent catchment access at
short notice. Use under this example would mean a net reduction in use of over
50 per cent from the pre-bushfires situation.