Protecting Wilderness and National Parks

No Mountain Bike Park for the Illawarra Escarpment SCA - make a submission

Exhibition has ended

Use the webform to make a your email submission objecting to the conversion of this small rainforest reserve into a bike park with many constructed bike tracks. Submission Deadline extened till Friday 21 December.

    Proposed maze of Bike Tracks at Mt Kiera - from the Bike Concept Plan

Read the Colong Foundation submission as an objection  converting a rainforest reserve into a bike park.

You may use following guide to make a submission, if you don't wish not to use the webform.

The Manager
National Parks and Wildlife Service Highlands – Illawarra Area
PO Box 5436
Wollongong NSW 2520
email: :

Dear Sir/Madam,

I oppose the draft Mountain Bike Strategy and associated Bike Concept Plan because these documents will enable sensitive vegetation to be cleared in the Illawarra Escarpment State Conservation Area.  The degree of proposed clearing is incompatible with the management principles for this reserve, and also the objects of the National Parks and Wildlife Act, 1974 that protect nature.  If adopted, the bike track proposals outlined in these documents will turn this reserve into a bike park.

On 11 March 2013 the Wollongong City Council resolved to commission a Feasibility Study for a ‘Bike Park’, that was “to ensure no additional damage to native flora, fauna and ecosystems in the Illawarra escarpment and foothills. [1]”  By a succession of interventions the mountain bike lobby has inverted the intent of this resolution.  Proposals for up to 82 kilometres of constructed bike tracks in the Illawarra Escarpment State Conservation Area will clear up to 16 hectares of sensitive park vegetation.

The downhill bike strategy and plan were written by a bike track development company and if approved subsequent track construction will financially benefit such a company.  The track proposals appear to maximise construction opportunities, and do not seek to protect the public interest in this conservation reserve.

Grounds for Objection

If these bike track proposals are approved, the Illawarra Escarpment State Conservation Area will be cleared and highly fragmented by the proposed tracks, especially at Mt Keira.  This clearing for downhill bike sports is incompatible with the effective conservation management of the significant heritage values of this reserve as required by the National Parks and Wildlife Act (see s. 30G(2)(e)).  The development of an intensive network of downhill single bike tracks in this small and sensitive state conservation cannot be justified legally or ecologically.

The clearing on the scale proposed of rainforest and other ecologically sensitive communities in a State Conservation Area is not Ecologically Sustainable Development, a key criterion specified in the 2011 NPWS bike policy.  The draft bike strategy is incompatible with this policy.

Downhill mountain bike tracks construction is no more appropriate in a state conservation area than building ovals or golf courses in them.  The experience of downhill mountain bike riding overwhelmingly relates to “technical challenges”, not nature.  In accordance with Council’s 2013 resolution a bike park should be provided in a place that is not set aside for the protection of nature. 

Many illegal tracks have been built in this reserve. There is a pattern of bike track development and advocacy in other NPWS protected areas.  Illegal bike trails are established and then these tracks are used by a bike track development company to justify bike track construction in that protected area.  This advocacy approach has happened at Royal and Garigal National Parks and now is being used to justify construction of tracks in the Illawarra Escarpment and Mt Canobolas State Conservation Areas.

The funds spent on making tens of kilometres of new tracks and widening existing illegal tracks will involve machinery to destroy reserve bushland, including rainforest, and will disturb soil and wildlife. 

The perversion of Council’s resolution and good reserve governance

The 2011 draft management plan specified no downhill tracks were to be constructed[2].  In a final review of the plan a concession was made for one or two short single track sections to be considered if these significantly enhanced mountain biking opportunities by linking with off-reserve trails in an ecologically appropriate manner.  There was just one submission to the draft Plan of Management that supported mountain bike riding in the reserve, and it made suggestions seeking to minimise illegal riding. 

Then a decision was made in 2016 to delay the draft management plan to enable input from a mountain bike track working group for the Illawarra Escarpment. 

A Feasibility Study was commissioned by Council in 2017 from Dirt Art (a bike track consulting and construction company). The Study identified many mountain biking track development opportunities in the State Conservation Area. 

The NPWS then commissioned Dirt Art to undertake a Concept Plan that was published in July 2018. It defined specific bike track routes through the reserve.  The Concept Plan proposes construction of 82 kilometres of tracks through the reserve, with up to 37 kilometres proposed for short-term construction plus retention of most of the illegally constructed tracks.

The September 2018 the Plan of Management for Illawarra Escarpment State Conservation Area was published after an unusual drafting review process where a “whole of government” decision inserted the bike strategy into it. 

This draft Bike Strategy seeks to pervert Council’s resolution, NPWS management plan making processes and sovereignty of the park’s plan of management to regulate visitor use.  It has resulted in proposed bike track construction that will be highly damaging to this reserve.

The draft bike strategy and plan must be rejected by Council and the “whole of government” because these proposed works will significantly damage the reserve’s conservation values.  

Note: The Draft Illawarra Escarpment Mountain Bike Track Strategy and Concept Plan are on public exhibition until Frdiay December 21, 2018.  Please defend our parks and object to these destructive proposals in your submission.

Keith Muir
The Colong Foundation for Wilderness Ltd


[2] There are no locations in the park where sustainable singletrack cycling could be provided. Pg 23 dPoM, 2011,