November 30, 2009
Superintendent Kevin Van Tighem
Banff Field Unit
Superintendent Pam Veinotte
Kootenay, Yoho, Lake Louise Field Unit
Parks Canada, Banff National Park
RE: Comments on the Draft Management Plan for Banff National Park
The Bow Valley Naturalists hereby submit the following comments as part of this public review process. We will begin with some general observations about the Draft then add a number of more detailed points tied to page references.
We are a volunteer organization of approximately 120 people most of whom live in the Banff-Canmore area of Alberta. We have actively pursued our interests in natural history and conservation since our formation in 1967 with Banff National Park and the Bow Valley east of the park to the Kananaskis River receiving most of our attention.
The Bow Valley Naturalists have found our review of this Draft Park Management Plan to be a frustrating experience. The Draft wanders off into new, wrong, unwarranted directions; it lacks clarity and fosters uncertainty; where we wish to offer enthusiastic support, we hesitate, unsure if our interpretation of its language is the same as that intended by Parks Canada. We are aware some of this frustration has spilled onto the pages of our comments but we will not apologize for this. We care deeply about Banff National Park and constantly worry about its future. This place deserves a far better plan to guide its management than the Draft we have reviewed.
At the outset, we must declare our strong objection to the change in the way management planning is conducted by Parks Canada. The shift away from prescriptive direction to strategic vagueness is not helpful if the purpose of planning is to create the best possible future for national parks. We see it as a device to provide the greatest flexibility to decision makers with the least commitment and, consequently, the least amount of accountability – the very antitheses of sound planning.
National park management plans should offer clarity and certainty; they should mean the same thing to everyone who reads them regardless of background, interests, or values. This Draft fails to do so. It broadens the potential range for interpretation of direction or intent and sets the stage for conflict. In terms of the history of national park planning it represents a backwards leap. And we find it disturbing that while this review process is public – to some degree – the very character of national park plans has been quietly altered by new Management Planning Guidelines developed internally by the Parks Canada Agency.
We also object to the fact the Draft has been thrust in front of the public so hurriedly some crucial sections are completely blank or woefully incomplete. One important section of the current plan that the Draft of the new plan has left behind is: A Place for Open Management. Perhaps it is no coincidence Performance Measurements, an integral part of any plan, are only "in development". And assuming Parks Canada might be interested in the public’s thoughts about priorities, it seems bizarre the Summary of Priority Actions will not be completed – or even begun? – until after the plan is finalized.
Far too often, the Bow Valley Naturalists find ourselves having to remind Parks Canada about the role and purpose of environmental assessment (EA). EA is an essential planning tool designed to inform and improve decisionmaking. To exploit it in order to bestow post-decision blessings is to fundamentally abuse it. Yet the Strategic Environmental Assessment of this Draft will not be completed – or even begun? – until after the plan is finalized. So much for informing and improving that decision.
The current park plan lists a number of Key Components of the Park’s Vision one of which states "Environmental assessment practices will be of the highest standard". (p. 10). How may the public hold Parks Canada to account under its own plan after this clear, unambiguous statement is buried in the same grave as so many other straightforward directions in the current plan plowed under by the generalities of the new plan?
The life-span of the new plan should be clarified. According to the Draft, it will stand for 10 or 15 years. Not very precise. The current plan was approved as "a fifteen year plan" yet it is being replaced on the occasion of its 10 year review. And instead of accepting the euphemistic disguise of this as a "re-written" plan we think it more accurate to acknowledge it as a new plan. After all, a series of previously determined limits including the prohibition of increased commercial use of rivers and lakes, new horseback riding concessions, new alpine huts, and the release of new land for commercial or other development have been forsaken. These all should be reinstated. Growth targets have been advanced with no consideration for potential effects on ecological integrity or the quality of visitor experience. It’s definitely a new plan, but definitely not a better one.
As we have prepared our response to the Draft we have wanted to be as constructive as possible but this part of the task is very difficult when the overall approach to planning is so flawed. The failure of the Draft to rigorously follow through from objectives or directions to actions and indicators is a major weakness that appears throughout the document as does the failure to identify measures of success for delivering quality experiences. Parks Canada’s obsession with visitor experience seems confined to promoting more visitation with little concern for whether people are gaining understanding and appreciation through direct, meaningful contact with their natural heritage. The fallback position of the Draft in this regard is to measure "visitor satisfaction". But if this assessment takes place outside of any context recognizing the special nature of national parks and associated experiences, it becomes simply a numbers game – a game on display throughout the Draft.
And numbers are at the core of one of the worst, most bewildering components of this Draft: Parks Canada’s aggressive push to increase visitation. The faint consolation we derive from the way this is presented is that at least Parks Canada does not attempt to fabricate any justification for it. There is no pretense that a 2% annual increase in visitation is desirable because it will improve ecological integrity or enhance the quality of visitor experience. Clearly it will not! Nor is there any suggestion that the Canadian public is clamouring for more visitors to Banff. The one and only justification is that Parks Canada has identified growth as one of its "corporate priorities" in its Corporate Plan. This is hardly sufficient in terms of the public interest.
The Draft even acknowledges that the public appreciates the park just the way it is, although with growing concerns about congestion in places. It also notes a long-standing upward trend in visitation anyway. And the biggest problem identified by visitors who have been surveyed has nothing to do with their experience of the park, it has to do with not receiving value for money from businesses. Boldly and absurdly in the face of this, Parks Canada pushes for more visitors. A big part of that push will involve the contrivance of special events and new recreational activities. Again, there is no hint that dressing up the park with these frills is a response to the wishes of the Canadian public.
The move in the direction of national parks as playgrounds reflects Parks Canada’s misguided efforts to accommodate the ambitions of the tourism industry that, in Banff, already occupies a position of privilege. Nowhere is this more apparent than in Parks Canada’s adoption of the jargon of industrial tourism to guide much of its planning. The Draft is tainted by references to such things as "refreshing the product offer" and measures of success such as "market uptake". In our view, not only is this completely inappropriate for a public agency responsible for managing national parks, it is repugnant and should be discarded. We strongly encourage Parks Canada to put a halt to its travels down this particular road of growth and exploitation and return to the kinds of values and ideals it knows are warmly embraced by the people of Canada.
The remainder of our comments will focus primarily on issues of concern. It is worth noting that while there are quite a few objectives or directions we agree with and support, the absence of clearly articulated goals, or outcomes, or timelines does not engender confidence of their implementation.
p. 8 Common Mountain National Park Vision This needs to be strengthened to clearly recognize that the foundation of these parks is the landscape itself, the ecosystems and their diverse components and processes. Then the material about their utility in human terms may be added.
Importance of Banff National Park This section, like the common vision preceding it, is overwhelmingly humancentric, as if the land, the natural world, held no intrinsic value. It completely fails to identify the place and role of this national park in the larger mountain ecosystem of which it is a vital part. And it fails to situate national parks in general, and Banff in particular, in the context of a changed and changing world. It is a world increasingly dominated by one species – humans – in which the tiny remnants of intact nature represented by national parks continue to grow in significance as does the imperative to properly protect them.
p. 11 Global Warming We were pleased to see the reality and pressing challenge of global warming identified by: "the need to anticipate and plan proactively for the impacts of global climate change on ecosystems, tourism and hydrology". However, our pleasure turned to chagrin when we realized this was the one and only reference to the subject; the Draft has absolutely nothing to contribute in the form of objectives or actions although Parks Canada knows full well that significant changes to the mountain landscape are and will be occurring. This is a serious planning deficiency that must be corrected. We propose that Parks Canada determine the current carbon footprint related to all human use of the park; then actions should be identified with timelines for aggressively reducing it, followed by measured indicators of success. Relevant research objectives and actions also should be stated.
A Vision for the Future of Banff National Park We appreciate the first paragraph for drawing attention first and foremost to the natural foundation of this place, the very element that is missing from the common mountain national park vision.
p. 12 Showcases of Conservation Innovation The first bullet in this strategy does not lead to any direction or indicators of success. Yet it highlights some real needs. It should be fleshed-out with real substance.
One of only 3 indicators of success that is identified is: "minimal restrictions on use" (p. 13). We believe this carries the very real danger of offering perverse incentives to park managers who may wish to earn success points rather than fulfill their obligations to protect. We also think that a central message all park visitors should be exposed to and learn from, is that in a finite world, if we are serious about providing havens "where nature flourishes and evolves for all time" (A Vision for the Future of Banff National Park) we must be willing to demonstrate restraint. We look forward to the day Parks Canada will stop pussy-footing around this issue. A far more enlightened indicator of success would be: "the acceptance of necessary restrictions".
p. 19 Sharing the Excitement of Science and Stewardship We are very disappointed that the Draft displays no firm commitment to science. There is no direction; not even mention of developing a science strategy that is long overdue. And there are no indicators of success for science or for stewardship.
p. 22 Bringing the Mountains to People Where they Live We are delighted to see Parks Canada finally endorse the concept of outreach. The Bow Valley Naturalists have been encouraging Parks Canada to extend itself this way for several decades and have always been puzzled by its resistance to the idea. The big question for us, of course, is whether there will be any actual follow through and real steps taken. Some of the links we hope will be explored are between people and the Earth as home so visitors better understand the intimacy and continuity of the human-nature relationship. There must be more specific direction and relevant indicators of success. Otherwise, we suspect the true essence of the park will be passed over in what the Draft, with its indicators of success for this strategy focused on understanding, appreciation, and communication related to Parks Canada as an entity rather than to the park, clearly implies is more of an Agency branding exercise.
We like the approach of working with other agencies, the education system etc. but must stress that while "collaborate with" sounds good, it gives no sense at all of the level of effort that will be employed – a perfect example of how strategic generality renders this document almost meaningless at times. Our worry about this is heightened by the absence of any indicators of success tied to the proposed collaboration.
p. 24 Managing Development to Enhance the Park Environment The Draft should clearly state that "the central challenge to manage growth" for the Town of Banff and the Village of Lake Louise will be replaced, before long, by the far more difficult challenge of having to learn to manage without growth. The opportunities for leadership and to export lessons learned to other communities and jurisdictions should be celebrated.
p. 25 One of the best ways Parks Canada could support the Town of Canmore’s effort to maintain wildlife corridors and effective habitat for wary species, is by setting good, consistent examples in the way it manages the national park. This has not always been done so it is well worth affirming this responsibility through direction and indicators of success.
p. 26 New Development We see no justification for new development or new recreational facilities. And we regret having to say this, but having witnessed the cynical "gain game" senior park managers indulged in recently to facilitate expansion of Marmot Basin Ski Area in Jasper National Park, we simply do not trust Parks Canada officials to manage trade-offs involving new developments or facilities in the best interests of national park values. The suggestion in the Draft that any such trade-offs would match newly disturbed land with reclamation of previously disturbed land in a quantitative rather than qualitative manner heightens our concern.
It was astonishing to read that limits to commercial activities in Zone 1 areas, Environmentally Sensitive Sites, and other areas crucial for their ecological or visitor experience attributes would only be "considered". If such limits are not in place now they should be imposed immediately and where inappropriate kinds or levels of commercial activity already exist it should be removed.
p. 27 Gravel Extraction We welcome the direction for active, ongoing restoration of gravel extraction sites and the inclusion of these costs at the front end of the budgeting process.
Alternative Energy The Draft should more fully account for the risks inherent in tampering with Declared Wilderness boundaries, even for the development of alternative energy sources. (Note: we are not necessarily opposed to this.) It must be very clear that if alternative energy sources are utilized, there must be no increase in capacities.
We suggest an additional direction that requires Parks Canada to prepare a proper system with coherent criteria for evaluating this type of proposal.
p. 29 Connectivity The directions for maintaining or restoring ecological connectivity are hopelessly vague. Again we question what is meant by "collaborate". One phone call? And a statement such as "restoring connectivity of streams, wetlands and lakes” gives no sense whatsoever of the number or scale of projects envisioned. This deliberate vagueness echoes loudly and hollowly in the sole, all-encompassing ecological indicator of success: "restored ecological connectivity" another excellent example of how meaningless this exercise can be when such generalities reign supreme. The direction sounds good but leads nowhere.
We urge caution as Parks Canada explores the potential of electronic gadgetry for communicating. It must not lose sight of the fact that virtual experience is no substitute for the real thing.
p. 30 It All Started Here The thumbnail sketch of the beginning of Canada’s national park system ("a dream emerged from the steam") is a loose interpretation of history to put it politely. We see no value in obscuring facts behind steamy language. The original impetus behind the establishment of what became Banff National Park was purely exploitive. Indeed, Parks Canada’s recent emphasis on the growth of tourism through promotions and marketing harkens back to those early days.
p. 32. From Exceptions to Exceptional We repeat our earlier criticism that "new recreational activities and special events" are responses to demands from the tourism industry not the public. It is no surprise however, when the "number of new visitor opportunities" appears as the only indicator of success.
The railway is a serious cause of wildlife mortality in the park but it is not the only one. Highways are another; Parks Canada should be pointing at itself as well as at CPR. Wildlife deaths continue to occur on unfenced portions of the Trans Canada Highway or the Parkways, but some have been on fenced sections of the TCH where inadequate maintenance is to blame. This requires clear direction, specific actions, and indicators that actually track change.
p. 33 World Heritage Site Surely it is not "a premiere scenic drive" along the Icefields Parkway that "defines" the Canadian Rocky Mountain Parks World Heritage Site (p. 31). We argue it is the landscape that provides the definition. This is not a subtle, semantic distinction. It separates the human constructed idea of place from the real.
Again, the Draft puts forward "increased number of visitors" on the Icefields Parkway as an inappropriate indicator of success with no attempt to measure quality of national park experience. We detect the signals of current priorities for Parks Canada all too clearly.
We support the extension of the Canadian Rocky Mountain Parks World Heritage Site by adding provincial parks in Alberta and B.C. and encourage Parks Canada’s partnership with the neighbouring provincial governments to accomplish this.
p. 34 Setting Ecosystem Priorities A serious deficiency in this section is the failure to recognize the protection of biological diversity as a priority. Parks Canada’s policy is very clear about the important role national parks play in this regard. (Guiding Principles and Operational Policies. p. 9, p. 33) The new plan should contain direction and actions to inventory biodiversity, determine status, and provide protection. The Banff Springs Snail and the mountain pine beetle are not the only small creatures worthy of discovery. Nor are fish the only members of aquatic ecosystems. Education should be used to broaden public understanding and appreciation of biodiversity as a means to improving the quality of visitor experience.
Indicators of success should include progress in the inventory and status determinations along with evidence that native biodiversity is flourishing in the park and will continue to do so.
p. 35 Grizzly Bears So far, we have had time for only a brief perusal of draft plans for the other mountain parks but we did notice discrepancies between the way grizzly bears are discussed in the Banff document compared to those for Kootenay and Yoho. Considering the fact that bears in all 3 parks are part of the same regional population the need for consistency is obvious. It is our view that the sections on grizzlies in the drafts for the other parks are clearer and stronger and should be carried into the Banff Draft.
We understand that at this stage the most important tool for grizzly bear protection is to manage on the basis of Habitat Security - determined primarily by human activity. In this context alone, we cannot see how Parks Canada could possibly entertain the notion of increasing levels of visitation and use.
We support the proposal to relocate trails out of high-quality grizzly habitat and into settings that offer improved human experiences. However we have to question the likelihood that this might actually be implemented since there are no corresponding actions proposed for any areas in the park. Another good idea with no effort to follow through.
We are surprised to see the Draft use 1 independent female grizzly bear as the threshold for human-caused mortality. The consensus recommendation from the Interdisciplinary Problem Solving Group that was accepted by Parks Canada was 1.2. This may seem like a very minor difference but the IPS recommendation was scientifically based and therefore defensible.
p. 36 Species at Risk It is important for Parks Canada to clarify that while Plains Bison and Woodland Caribou both have been assessed as "Threatened" by the Committee on the Status of Endangered Wildlife in Canada, only the Woodland Caribou is listed under the Species at Risk Act that carries legislated obligations. This should facilitate the selection of a priority for restoration.
p. 37 Fire The target for all parts of the park to be "within at least 20% of their long term fire cycle" is a radical departure from the 50% target for the fire cycle in the current plan. We wonder whether the new figure has a substantial basis or if it was simply pulled out of the air. And we wonder whether achieving 80% of the fire cycle everywhere is realistic or even remotely feasible.
Alluvial fans and riparian areas Another example of the frustrating vagueness that afflicts the Draft: What does "reduced disturbance footprint" mean as an indicator of success? We strongly support it in principle but will it be measured in centimetres or hectares? The new plan must be far more forthright in its portrayal of Parks Canada’s commitment to take action.
Aquatics As we mentioned earlier, there is much more to aquatic systems and processes than fish - native or non-native. The new plan should expand its aquatic horizons.
p. 39 Lower Bow Valley Some of the messages provided at the East Gate should describe appropriate behaviour for park visitors. This would include information about speed limits. Respect for speed limits should be an objective; strict enforcement, an action; and a very high degree of compliance, an indicator of success.
p. 41 Restoration of the Montane The first objective for the Lands Adjacent to the Town of Banff is to actively restore a variety of crucial elements of the montane ecoregion. But no actions are identified and only a partial indicator of success so no responsibility has been assumed by Parks Canada. This oversight must be rectified.
p. 42 Cascade Pits We fully support restoration of the Cascade Pits. However, we fully oppose the action to "develop the remainder as a day use area for staging special events.". This area is part of the Cascade Wildlife Corridor! Here is a case where Parks Canada must lead by example. Its expressed concern about maintaining the viability of wildlife corridors in areas outside the park will have no credibility if it persists in violating standards it helped develop for protection of corridors, inside the park. A number of years ago this site was proposed for the elk handling facility, now located on Tunnel Mountain. It was rejected because of the blatant conflict with wildlife corridor protection. A large day use area exists already, a few hundred metres away at Cascade Ponds. The entire Cascade Pits area should be restored.
Airstrip We realize the previous Environment Minister in the current government made a bad decision on the future of the airstrip, even to the extent of ignoring advice from Transport Canada, and that Parks Canada is required to maintain it for emergency and diversionary purposes rather than close it. However, the Key Action for the private aircraft and associated facilities to be removed must be accompanied by a tight, strictly enforced timeline. Otherwise, the small handful of pilots who have been abusing this situation for years will continue to do so indefinitely while the restoration of this part of the Cascade Wildlife Corridor languishes.
p. 43 Bow River More vague actions and indicators. What does it mean to "ensure that use of the Bow River is managed conservatively"? How are "uncrowded" conditions and opportunities defined? We would like to support these statements because we feel strongly that not only should riparian values be protected, so should "uncrowded opportunities for quiet enjoyment and reflection", particularly in light of Parks Canada’s current push for more crowds and more fun and games. But we can’t support what we cannot clearly understand. There is no guidance in these generalities.
We also are puzzled by the limiting reference to breeding waterfowl along the Bow River. The Bow River is important to waterfowl as a staging area outside of the breeding season and associated wetlands such as the Vermilion Lakes or the Rainy Bay complex are extremely important to waterfowl throughout the ice-free season. And of course, the river, its riparian areas, and the wetlands are crucial habitat for a myriad of species other than waterfowl. The Draft fails completely to encompass Parks Canada’s ecological integrity responsibilities in this area, and many others.
p. 46 Town of Banff The Bow Valley Naturalists strongly support the Objectives and Key Actions designed to retain and enforce limits. Parks Canada must provide steadfast defence of these. Unfortunately, we worry that its promotion of increased visitation will undermine this position and will be exploited by some people and groups in the Town to push hard against the limits with the hope of reopening them. It is important to emphasize that commercial and residential caps should not be treated as targets; they are, in fact, maximum levels not minimum.
We seriously question why a national park agency would suggest "visitors spend longer periods of time in the town" (p. 47) except to pander to its tourism industry partners. We maintain the town has a vital role to play for many visitors as the beginning point for their explorations of the park. But the park not the town should be the destination.
p. 48 Spray Area The current plan indicates there is a seasonal closure in the Middle Spray to provide security for grizzly bears. The Draft of the new plan does not. Parks Canada should be straightforward about whether it intends to retain this closure or do away with it. We believe it should be retained.
We are pleased that concerns related to motorized access near national park boundary areas and helicopter over-flights impairing the wilderness experience of park visitors are identified. It is very important that boundary area concerns – including the killing of predators that travel in and out of the park – also be identified for the East Slopes area. For both areas a much clearer display of the level of commitment Parks Canada is prepared to devote to these matters is required. It is worth noting that direction to deal with the problem of over-flights has been a feature of the current management plan for Banff for the past 12 years, with no apparent progress to report. Actions involving statements such as "collaborate with" adjacent land managers and "work towards minimizing helicopter over-flights " offer no guidance to the public or to those Parks Canada officials charged with implementing the management plan. Indicators of success should be included as well as timelines.
p. 50 East Slopes There is an obvious contradiction between the current situation in which grizzly bear habitat security is "lower where there are well used day use trails" (p.50) and the indicator of success (p. 52) pointing to "sustained or increased use levels for day use trails". It is almost as if Parks Canada thinks it can have it both ways even though it knows it can’t. The contradiction must be resolved on the side of ecological integrity.
The current plan allows mountain bike use on the old Cascade Fire Road only as far as Stony Creek. The Draft is not clear about this and should be.
We are unsure what to make of the statement: "maintain low levels of human use and minimal infrastructure in historic caribou range until it is determined whether the species can successfully be reintroduced" (p. 52). Then what? Will these constraints be lifted?
Our nomination for the silliest proposal in the entire Draft goes to the Key Action for the Fairholme Environmentally Sensitive Site (ESS). It states: "visitors will be invited to share in stewardship of this area by voluntarily limiting their use to one visit or less per year." But later in the document, the Draft notes this area is "the largest remaining intact block of secure montane wildlife habitat in the park" and that "human use in this areacan restrict wildlife movement." So why would Parks Canada want to encourage even a limited amount of use? It is not completely ridiculous to observe that this invitation is extended to 3.2 million potential visitors to the E.S.S.. As we suggested earlier, Parks Canada will earn far more respect by presenting good, solid reasons for restrictions and backing them firmly than it will by being wishy-washy on park protection.
p. 54 Middle Bow Valley The Draft makes no attempt to contend that ecological integrity and quality of visitor experience will benefit from "increased numbers of visitors" on the Bow Valley Parkway. There is no justification to include it as an indicator of success.
With the seasonal temporal restriction remaining in place for now for the eastern portion of the Bow Valley Parkway we strongly encourage Parks Canada not to continue to treat it like a secret. Prominent signs should be posted on the Trans Canada Highway so all visitors are aware of the circumstances.
p. 56 Main Ranges We believe Simpson Pass should be added to Healy Creek – Ball Pass as an area that is important for regional wildlife movement. We endorse the objective for functionality (p. 57) but actions to support it are absent as are indicators of success. Both should be presented in the new plan.
The Draft makes clear that each of the Landscape Management Units in the Main Ranges except for the Upper Bow is below the target for grizzly bear habitat security. Yet even though improvement is desired as an indicator of success, not a single action to accomplish this is presented. On the contrary, an action is proposed to investigate "additional hut development" that could very well have the opposite effect. We urge that all such thoughts be banished. There is no need for Parks Canada to recreate the European Alps experience in the Canadian Rockies. And many of the provincial mountain areas, especially on the B.C. side, are riddled with facilities for those seeking them. We think it is much better that national parks allow visitors to find deep meaning and pleasure from experiencing the backcountry landscape on its own terms. And with ecological integrity as first priority there is a mandate to provide space, freedom of movement, and security for grizzly bears, for all other forms of wildlife, and for the ecological processes in which they are participants.
It would be useful for Parks Canada to include in the new plan its working definitions of "hut", "shelter", and "lodge" along with capacities for each so the public may better understand the full extent of these facilities in the park.
p. 59 Lake Louise Area We appreciate the objective that "effectiveness of the Whitehorn corridors is maintained or improved" and "the Fairview corridor effectiveness is improved" but as part of one of the most prevalent recurring weaknesses in the draft, no actions are identified.
We want to propose that the Lake Louise area and the Icefields Parkway offer some of the most visual and pertinent opportunities to interpret the unfolding reality of global warming.
p. 63 Icefields Parkway We welcome the objective that key elements of ecological health "include maintaining or restoring ecological (e.g. fire), aquatic ecosystem health, viable wildlife populations, key habitats and habitat connectivity, and ensuring that human-caused mortality and disturbance does not increase". Unfortunately, the key actions with the exception of one token reference to reducing environmental impact "when building or modifying infrastructure" are directed exclusively towards human use. Many of these are worthwhile but it certainly is not possible to tell that ecological values are the core of Parks Canada’s management responsibilities. The only relevant indicator of success looking back to the good, broad objective, is reduced wildlife mortality.
We were pleased to read an objective that "planning will focus on the quality of visitor opportunities" but disappointed to find no indicators of success – except, of course, the ubiquitous "visitor numbers increase" (p. 65) that is irrelevant to this objective.
A similar situation arises with another objective we strongly support: "Discovery and learning will be fundamental" (p. 64). Here is something central to the education component of Parks Canada’s mandate but the only indicator of success that might apply is a vague, general statement that "new interpretive stories are provided". It’s as if Parks Canada either doesn’t particularly care about the quality of education and visitor experience – we certainly trust this is not the case – or doesn’t know how to deliver, evaluate, and celebrate it.
p. 66 North Saskatchewan It is our impression this area is not very well known from an ecological perspective. The new plan should identify steps to address this, beginning with the segment of montane ecoregion centred around Saskatchewan Crossing. Results from research would assist management and could inform educational programs.
We note the same peculiar statement as in the East Slopes section about holding the line on low levels of human use and minimal infrastructure "until" the feasibility of re-introducing caribou is determined. This requires clarification.
p. 70 Zoning It is our understanding that the Valleyview-Middle Springs Wetland has been added to the Middle Springs Environmentally Sensitive Site. The new plan should acknowledge this.
Wilderness Area Declaration We are very disturbed by the door the Draft wants to leave open for amending declared wilderness boundaries to accommodate "limited future development of new facilities, renewable energy and communications towers". Slight adjustments to boundaries to allow gravel extraction adjacent to highways may make sense in some places after alternatives have been thoroughly investigated, and it is possible the same is true for potential renewable energy sites. But legislated wilderness is precious; its boundaries should not be vulnerable to tinkering, especially not in the interests of commercial/recreational developments. Far better, we think, to leave this door tightly closed than to risk unspecified intrusions.
In concluding, the Bow Valley Naturalists have wrestled hard with the difficulties posed by this Draft. We have been motivated by an abiding appreciation for Banff National Park. We encourage Parks Canada to go back to the drawing board, re-think current direction, and write the new plan in a way that will reflect planning principles and affirm genuine commitment to the first priority and core values for national parks.
Mike McIvor, President
cc. Hon. Jim Prentice, Minister, Environment Canada
Hon. David McGuinty, Liberal Environment Critic
Hon. Linda Duncan, NDP Environment Critic
Hon. Bernard Bigras, BQ Environment Critic
Alan Latourelle, CEO Parks Canada Agency