CPAWS-BC #241-312 Main Street Vancouver, BC V6A 2T2 604-685-7445 Rick Kubian Kootenay and Yoho National Parks Superintendent Yoho National Park Box 99 Field, BC T0L 0C0

July 7, 2021

Re: CPAWS’ Comments on the Yoho National Park Draft Management Plan

Dear Mr. Kubian,

The Canadian Parks and Wilderness Society (CPAWS) is pleased to provide our comments and perspectives on the draft 2021 Yoho National Park (YNP) Management Plan. We recognize and appreciate the hard work and commitment on behalf of many Parks Canada staff to draft these plans. We know this is no small feat. Overall, we find this management plan to be a significant positive step forward in the management of Yoho National Park. We understand that the YNP draft management plan is meant to provide overarching, strategic direction, but we are concerned about the lack of detail in some areas. There is room to ensure that long-term strategic direction includes definitions of potentially ambiguous terms, and to provide measurable targets and timelines by which to measure success. We would like to see Parks Canada recommit to a five-year project management cycle, as promised by the previous Minister of Environment and Climate Change, Catherine McKenna.

We have three overarching recommendations: 1. All targets should be measurable, even if they are accomplished over the long term. 2. The visitor use data collection and management objectives would be better suited as part of an overarching Visitor Use Management Strategy or Framework. 3. Yoho National Parks needs to demonstrate greater climate change leadership in both objectives and targets associated with this plan. Climate change should be central to the plan’s management intent, objectives, and targets.

We appreciate that Parks Canada starts this management plan by recognizing the hard history of displacement of Indigenous Peoples from their traditional lands to create and manage Yoho National Park. This recognition is pervasive throughout the plan, which is an essential component of Truth and Reconciliation. YNP has a long and diverse history, which truly starts millennia before the creation of the park and the colonization of what is now western Canada. We are buoyed to see Parks Canada’s commitment to weaving Indigenous Knowledge with western science to support more meaningful interdisciplinary, cross-cultural management of Yoho National Park.

Section 8.2 of the Canada National Parks Act states: “Maintenance or restoration of ecological integrity, through the protection of natural resources and natural processes, shall be the first priority of the Minister when considering all aspects of the management of parks”. This is an incredibly powerful statement that should be reflected in the vision for YNP in the draft management plan.

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Vision Statement We encourage Parks Canada to embrace an Indigenous perspective in the park vision by “thinking seven generations into the future”. This thinking and will enable Parks Canada to implement effective programs to address the climate change and biodiversity crises facing our World over and beyond the life of the management plan. The current vision statement integrates the human experience with wildlife needs for YNP and we appreciate the diversity of programs and perspective reflected in this vision statement. The vision statement should also include language about the habitats of YNP being critical to a functioning, resilient, productive large landscape ecosystem in the face of climate change and the global biodiversity crisis. YNP is a place where the global biodiversity crisis is stemmed through proactive, intentional management practices that recognize the unique role YNP plays in conserving an array of ecosystems and species in the face of the climate and biodiversity crises. To fully address these crises, the vision statement should discuss how the management of YNP will be “nature positive” whereby all management decisions benefit nature in some way. In addition to climate change and biodiversity, the vision statement should speak to YNP’s role in other big issues, including Truth and Reconciliation, being a world class destination, and being a leader in the innovative and effective management of Protected Areas globally.

The need for measurable outcomes We understand the targets are meant to be outcome and results-based, which is valuable. However, results-based, strategic outcomes can also be measurable. We are pleased to see the repeated reference to Parks Canada’s commitment to prioritize ecological integrity in management planning and decision making. We would, however, like to see this intention more directly reflected in management objectives and targets through measurable outcomes by which we can measure success throughout the term of the management plan. Measurable outcomes assist park staff in guiding day to day decisions, as well as developing work plans for the year. These outcomes are also critical for Canadians to hold Parks Canada accountable as the management plan is implemented over the next ten years.

The success of this management plan is in big part associated with the development and implementation of several subsidiary plans. While creating these plans is great, the management plan does not consistently state what kinds of data or information will be addressed in the plans and on what timelines these plans will be drafted. This needs to be rectified; this management plan should define the goal of all subsidiary plans, contain a bulleted list of what data and information sources will be included or sought, and a target defining if and how public consultation and engagement will be involved. There is little mention of involving stakeholders in drafting these plans, yet stakeholders could be essential in providing visitor use data for some subsidiary plans and implementing plans effectively. For example, the human-wildlife coexistence plan should be developed in conjunction with Banff National Park’s update to their coexistence plan. CPAWS has been engaged in planning human-wildlife coexistence in various capacities and would appreciate the opportunity to contribute to drafting this plan. CPAWS-BC #241-312 Main Street Vancouver, BC V6A 2T2 604-685-7445 Key strategies The key strategies in the plan are good and well connected. We appreciate how several strategies are common between the parks in the Rocky Mountain Parks complex. These common strategies clearly identify ways in which the parks will need to collaborate on issues that span boundaries. We propose a few changes to the naming and intention of a couple of strategies.

We support and echo the comments from First Nations that the “Strengthening Indigenous Relations” strategy is not comprehensive enough. This strategy shouldn’t only aim to strengthen relations, it should aim to improve effective engagement of Indigenous groups with traditional territories in YNP in park management. If Indigenous Peoples are better and more meaningfully engaged, relationships will naturally be strengthened. In addition, broadening this key strategy will also create space for Parks Canada to work with First Nations to address specific issues that may not be covered in other strategies or objectives.

Given the global climate and biodiversity crises, we believe the climate change and adaptive management strategy should be a central strategy to this plan. These concepts should be mentioned in the plan vision statement and be reflected in all park management actions. The climate and biodiversity crises are the overarching challenges facing all aspects of park management for the next decade and beyond. We propose this strategy be listed as one of the first strategies in the plan and be entitled “Addressing Climate Change and Biodiversity Loss”. Listing this strategy first sets the stage for a true landscape scale, long-term, solutions-based approach to park management that puts ecological integrity first. The entire management plan should be framed under the idea of an equitable, carbon-neutral, nature positive plan. Every activity and proposed management action should be measured against whether and how it improves ecological integrity, addresses the climate crisis, addresses reconciliation, and how they will make nature better and not only mitigate loss.

Adaptive management should not be a part of the climate change strategy as it applies to all aspects of park management. Adaptive management is not a strategy, it is a principle by which strategies and park management practices adhere. The principle of adaptive management should be stated in the park vision as an integral part of the management approach; subsequent strategies and objectives should reflect adaptive management. The management plan must demonstrate that applying adaptive management is more than monitoring and collecting data, it is a process whereby monitoring informs management practices and decisions.

Climate change leadership YNP is a unique park in the world and in the Rocky Mountain National Park system. As the manager of this park, Parks Canada is naturally poised to be a leader globally in Parks and Protected Areas management. The importance of this leadership is even more critical now as we face global climate and biodiversity crises. With its diversity in habitats across elevations, YNP has a critical role to play in terms of ensuring ecosystem resiliency in the face of climate change. This is more than a suite of management goals and objectives; it is a critical component of the plan’s foundation. Following the

3 lead of the federal government, Parks Canada should aim to transition to carbon neutral by 2035 and targets to move in that direction should be included in this management plan.

We appreciate the target in Objective 7.1 that speaks to monitoring the extent of alpine ecosystems and monitoring small mammal populations. We encourage Parks Canada to take this one step further, however, and to partner with Banff and Kootenay park staff to model and identify climate refugia for wildlife. These refugia should be managed now to directly promote habitat quality and security so that when species’ range shifts, the habitat is available. While it is helpful to collaborate with scientists investigating the effects of climate change, Parks Canada can be a leader in facilitating and creating multi-disciplinary research programs that identify best management practices to address the impacts of climate change.

We would like to see some targets that tie climate change research to visitor use management more directly. For example, limiting human use in areas identified as climate refugia or considering recreational management tools on the Wapta and Yoho Traverses to reduce impacts to glaciers at sensitive times of winter.

Collaboration across boundaries is particularly important when it comes to addressing climate change and ensuring ecosystem resiliency across the landscape. We appreciate how climate change is addressed as a part of regional collaborations in Key Strategy 6. As a leader in large landscape management in one of Canada’s premier National Parks, Parks Canada should lead collaborative efforts. It is not sufficient to expect other agencies to put these efforts together and for Parks Canada to join. Parks Canada has more capacity to create and facilitate these collaborative efforts than other adjacent jurisdictions. While Objective 6.1 speaks to these collaborative efforts, there is no specific commitment to any particular collaborative effort that will address multi- jurisdictional challenges with aquatic invasive species, species at risk, or wildlife connectivity. More detail in this regard will enable adjacent jurisdictions to plan for capacity to contribute to transboundary programs, thus increasing their effectiveness.

Visitor use data collection and management This draft management plan is the first one to directly address the impacts of high human use on the park’s natural and cultural resources. We are pleased with several management objectives and targets that are designed to address these impacts from both ecological and social perspectives. While Objective 2.2 speaks to the development of Visitor Use Management strategies for high use areas, we encourage Parks Canada to consider this effort more broadly and strategically. Visitor Use Management strategies are required at the landscape scale for several reasons and to ensure that management of one high use area does not displace users to other less appropriate areas. A park-level strategy that brings all these objectives and targets under one integrated framework can address visitor use management from myriad perspectives. As it is written, it is unclear how the data collection from one strategy will inform visitor management and what the overarching visitor management goals are. While it is good that visitor use data and management are a part of each strategy, these targets and objectives would be more effective if they were framed within one CPAWS-BC #241-312 Main Street Vancouver, BC V6A 2T2 604-685-7445 strategy or framework. As it is, we are concerned that visitor management will end up being disconnected across the park because plans from site to site or from the front country to the backcountry will not align under one framework. As visitation is a factor that impacts most aspects of park management, including them all in one strategic framework will create efficiencies of scale, and inform day to day management of the park by on-the-ground staff.

The targets in Objective 2.2 speak to the development of a Visitor Experience Strategy and a Visitor Use Management Plan, but really the visitor experience is a part of the Visitor Use Management Plan. We recommend that Parks Canada reframe this objective so that the development of the Visitor Use Management Plan is the objective and an experience strategy is a target. Other targets should include defining the “desired condition” of the park, engaging stakeholders in the development of the visitor use management plan, and identifying visitor management options that may address ecological, social, and cultural objectives. Similarly, Objective 2.4 that aims to create a sustainable trail network, also contains targets that will be reflected in the Visitor Use Management Plan, such as trail improvements and relocated trailheads for visitor safety.

We appreciate the intention to continue to focus visitation in several high-demand areas of the park, although we are somewhat concerned that Emerald Lake and the Natural Bridge are not included as a management area of focus since they are the most highly visited places in the park. We appreciate the area management strategy for Upper and Little Yoho valleys. Upgrading visitor facilities and services in this area will improve the visitor experience and reduce ecological impacts associated with growing visitation. We encourage Parks Canada to specifically consider management of long-distance hikers and trail runners whose impact on backcountry areas is unknown. Parks Canada should put in place specific programs to monitor these impacts, as well as apply visitor surveys to better understand these users and their needs, motivations, and expectations. In addition, Parks Canada should commit to improving grizzly bear habitat security in this area, which will best be accomplished through appropriate visitor management strategies. In this vein, we also encourage Parks Canada to keep the Twin Falls Tea House as day-use only and not allow overnight visitors.

Improving efficiencies at Monarch and Kicking Horse campgrounds are welcomed partly because the development footprint already exists, as well as the infrastructure to accommodate an increase in human use. We are unclear what is intended by “investigating the potential of restoring a portion of the historic camping offer” but would like to ensure that any potential expansion of camping prioritizes potential impacts to wildlife movement and ecological integrity. YNP is currently in an excellent position in that visitation is already concentred in discrete areas. Parks Canada should not be looking to increase the footprint of development, or the extent of area designed for high human use in the park.

Wildlife Protection and Connectivity We appreciate Objective 6.2 that speaks to identifying wildlife corridors and working with neighbouring jurisdictions to conserve them. We are also supportive of decommissioning the Ice

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River and Amiskwi River trails to improve wildlife movement. We recommend that the bridge at the end of the Ice River trail that crosses on to BC public land be removed to reduce the risk of incursions on to the Ice River trail from the other end.

We appreciate the volume of work that has already been done to identify potential wildlife crossing structure locations associated with the twinning of the TransCanada Highway. We would like to see a commitment on behalf of the Federal Government to start construction on highway twinning within the first five years of this management plan. It is nice to see that YNP staff have proactively prepared for this project and we would like to ensure their work does not become outdated by the time construction begins.

Forest fire plays a significant role in the YNP ecosystem and we are pleased to see it as a focus in Objective 1.1. We also appreciate the involvement of Indigenous Knowledge in forest management and prescribed fire plans. Any additional details of how Indigenous Knowledge will be integrated is appreciated. Will Indigenous Knowledge holders provide input on a draft forest management plan, or will they be engaged in the development of the plan itself? We hope it is the latter and would appreciate that clarity being stated in the draft management plan. We would also like to see a target that described how the prescribed burn plan will address other species at risk objectives, such as habitat enhancement for grizzly bears and Olive-sided flycatchers.

Conclusion CPAWS is committed to working with Parks Canada to ensure the effective implementation of a management plan that prioritizes ecological integrity and ensures an array of high-quality visitor experiences. We appreciate the opportunity to comment on this draft management plan for one of Canada’s premier National Parks. As a national organization, we have examined all the Rocky Mountain National Parks draft management plans through a lens of national significance. However, as people who often recreate in Yoho and know its trails well, we are pleased to see the focus in this management plan on visitor use management and Indigenous engagement. We look forward to seeing many of the proposed changes implemented over the years and working with you and your team to ensure Yoho retains its special character in the larger system.

Yours in conservation,

Jessie Corey Sarah Elmeligi Anna Pidgorna Terrestrial Conservation National Parks Coordinator CPAWS National Senior Manager CPAWS Southern Alberta Conservation Coordinator CPAWS BC