How much is a view worth? The Victorian public is asking itself that question after the state government announced on Monday that it would impose visitor fees on one of its most spectacular landmarks, the Twelve Apostles.

Bookings would be required and a fee payable for parking and access to the $126m Twelve Apostles Visitor Centre, the gateway to the main viewing decks for the famous sea stacks – columns of remnant rock from the eroded Victorian coastline, visible along the winding, 240km-long Great Ocean Road.

About 2.2 million people visit the Twelve Apostles every year, and the government expects that to increase to 3 million a year by 2032. But locals along the Great Ocean Road have long been concerned about overtourism.

The environment minister, Steve Dimopoulos, claims the imposition of “fair and reasonable” fees will help address crowding and protect the environment, and is in line with the management of other major Australian tourist attractions. The local council and the tourism board agree.

But just how common are these fee-for-access schemes, and how do people feel about them?

Grand Canyon and Stonehenge

While an entry fee to view an environmental landmark is a new step for Victoria, charging for similar experiences is common in other parts of the world.

In the United States, major national parks including Yosemite, Grand Canyon, Arches and Glacier national parks all have fee access schemes, although these have undergone some major changes in recent months.

US residents pay between about US$15 and $35 for entry to national parks. But Donald Trump signed an executive order last year to raise entrance fees for overseas visitors to US$100 per person per day, with annual passes costing $80 for residents but $250 for non-residents.

In the UK, when the government decided, not for the first time, to remove the view of Stonehenge from passing vehicles by diverting a nearby highway through a tunnel, the proposal was staunchly opposed by members of the public, environmental campaigners and Unesco, as well as planning inspectors who said the roadworks would cause “permanent, irreversible harm” to the world heritage site.

Access fees have been charged at Stonehenge since 1901 when the site was private land. More than a million people visit it every year, with adults paying between £27 and £70 each depending on whether they want to wander through the Neolithic stone circle or are content with simply having a good look from the official vantage points.

But millions also view it for free, from a distance, from the road. Guardian columnist Simon Jenkins suggested that they had a right to this, arguing that for passing motorists, “Stonehenge has long meant the thrill of the sudden glimpse”. The UK government eventually scrapped the plan, citing the need for austerity, and for now the road view remains intact.

Australian parks

Viewable from the road but with a lookout accessible for a fee, Stonehenge is perhaps a more direct comparison to the Twelve Apostles than the Australian examples listed by Dimopoulos on Monday.

Fees are payable to access Wineglass Bay and Cradle Mountain in Tasmania, Kosciuszko in New South Wales and Uluṟu-Kata Tjuṯa in the Northern Territory, but these differ in significant respects from the proposal at the Twelve Apostles.

A parks pass is required for entry to all national parks in Tasmania – including Freycinet, where Wineglass Bay is located. Only Cradle Mountain is paid for separately. Visitors in cars are covered by a vehicle pass and those travelling by bus, bicycle or on foot pay per person. Some multi-day hikes, such as the Overland Track, require booking in advance to limit foot traffic and ensure adequate available camping space.

Fees were first introduced at Uluṟu-Kata Tjuṯa national park in the Northern Territory in 1989, and 25% of revenue is paid as a lease to the Anangu traditional owners. Adults pay $38 for three days at the park, which also funds operations, ranger activities and preservation of the world heritage-listed site.

In NSW, vehicle entry fees are charged for 45 of the state’s national parks – usually $8 per vehicle per day, with Kosciuszko an exception ($29 per vehicle during winter peak) as it attracts a high number of visitors to resorts during the ski season. Most of the Blue Mountains national park is free. All NSW parks are accessible for free by foot, bicycle or public transport. In Victoria, visiting national parks is free but fees are paid for use of additional services such as campgrounds or access to guided tours.

Safety concerns

Unless you are an intrepid cyclist or hiker, there’s no way to access the Twelve Apostles except by motor vehicle. Guardian Australia understands there is a strong view within government that the fee should be under $20, and is considering charging per vehicle rather than per person.

Michelle Rowney, a Port Campbell resident and a community campaigner, says tourism to the area is so intense she has to “bunker down between November and March … It’s getting worse and worse.”

Rowney is concerned that charging a fee for the viewing platform may push visitors towards less safe vantage points along the notoriously treacherous road, or to parts of the park without adequate parking, environmental protection and safety infrastructure, or even toilet facilities.

She says locals have been campaigning for the restoration of nearby Gibson Steps, which was closed for many months last year after water runoff from the visitor centre development caused dangerous erosion to the cliffs and beach. Remediation work has begun and beach access opened. Nearby Loch Ard Gorge, however, is still closed indefinitely as the stairs are in need of repair.

Tourists have also been known to fall off the cliffs trying to take photos. A 23-year-old man fell 15 metres near Gibson Steps in October last year, requiring a large-scale rescue effort to bring him to safety.

Dimopoulos said on Monday that money raised by the fees would partly go towards safety infrastructure at other sites, so “people don’t make unsafe choices”. The opposition leader, Jess Wilson, said the government had to implement fees because it had “run out of money” to fund the park’s work itself.

Rowney says the proposed fee goes against what she believes is the ethos of national parks: that they should be available to everybody.

“I’m probably OK with people paying for services like car parking, maybe to use the toilets or access the visitor’s centre,” Rowney says. “But anybody should be able to see the Twelve Apostles, so I don’t think there should be a fee.”