c/o Olympic Park 88 Canada Olympic Road S.W. Calgary, AB T3B 5R5 Phone: 403-232-6686 Fax: 403-232-6988 Email: [email protected]

Senior Parks Planner Environment and Parks Parks Division Castle Provincial Park and Castle Wildland Provincial Park Draft Management Plan 4th Floor Administration Building 909 - 3 Avenue North Lethbridge, AB T1H 0H5

10 April 2017

Dear Ms. MacDougall,

CPAWS appreciates the opportunity to comment on the Revised Draft Castle Management Plan.

The Canadian Parks and Wilderness Society (CPAWS) envisages a healthy ecosphere where people experience and respect natural ecosystems. CPAWS is the only nation-wide conservation organization dedicated to the protection and sustainability of public lands across the country. For over half a century, our 13 chapters across Canada have helped to create over two-thirds of all protected areas in Canada. Since 1967, the Southern Alberta Chapter of CPAWS has been dedicated to protecting the ecological integrity and connectivity of the Alberta landscape, as well as increasing conservation awareness and engagement among Albertans.

For 50 years, CPAWS Southern Alberta has been involved in many different conservation issues in our province. Without CPAWS, our Rocky Mountain National Parks would look very different than they do today and we would not have areas like Kananaskis and the Whaleback to name a few. Our particular role as a conservation organization in Alberta is to provide landscape scale, science-based support and advice for the conservation and protection of Alberta’s protected areas and wild lands. We have a positive public profile and pride ourselves on working cooperatively with government, First Nations, businesses, non-government organizations and individuals to achieve practical conservation solutions on the landscape.

Overview of draft Castle Management Plan

CPAWS Southern Alberta commends the government for protecting the Castle Parks and for using science-based decision making in the draft management plan. We support this government’s effort towards reaching International targets for protected areas and see the Castle as an excellent start in this process.

In Wildland and Provincial Parks, the conservation of nature should be the top priority. The IUCN defines a protected area as “a clearly defined geographical space, recognised, dedicated and managed, through legal or other effective means, to achieve the long term conservation of nature with associated ecosystem services and cultural values” (IUCN Definition 2008).

The draft Castle Management Plan for the Wildland and Provincial Parks has an overall positive direction and focus on conservation. CPAWS Southern Alberta strongly supports the stated primary purpose of “conservation of nature, the respect of Indigenous rights, and the provision of recreational and tourism experiences. All management decisions will be consistent with the protection of biodiversity, water resources, ecological integrity and connectivity.”

CPAWS Southern Alberta commends the government for a draft management plan that prioritizes conservation and encourages all management to remain consistent with the international definition of a protected area.

The elimination of forestry, mining, new oil and gas leases and motorized recreation are all important actions to meet these objectives. We commend the government for these tough decisions to meaningfully protect a legally designated protected area.

Research and monitoring, and associated adequate budget and resources, will be a key component to ensure that management activities are meeting these conservation objectives and the precautionary principle and adaptive management is used to adjust management actions to better protect or reduce potential harm of any infrastructure or activities in the parks.

CPAWS largely supports the strategies for conservation and protection of the Castle Parks (Section 2). Further recommendations on how to strengthen these strategies are outlined in the sections below.

There are five key areas that CPAWS Southern Alberta has focussed our recommendations for the draft Castle Management Plan:

 Management of all land-uses in the new Castle Parks should prioritize conservation.  Phase-out of off-highway vehicle use from the Castle should be completed within two years including the immediate closure of all motorized trails within 100m of native trout streams.  Focus of quiet-low impact, nature-based recreation and tourism with minimal infrastructure and footprint.  The focus on cooperation with First Nations and Métis and the education of cultural and traditional land use and rights should be maintained as a priority.

Management of all land uses in the new Castle Parks should prioritize conservation. CPAWS Southern Alberta believes that the management of all land uses in the parks should prioritize conservation. We support the statement that “existing recreation activities will be evaluated and managed for their compatibility with the conservation objectives and, where required, use and access will be modified to ensure protection of natural and cultural values.” (Section 1.1). We encourage the government to apply this principle to all land-use decisions in the parks. While most of the management plan is in line with the stated conservation goals, there are a few areas of the plan that need more clarity to ensure conservation is prioritized. Specifically:

 Section 2 notes that “land uses such as grazing, recreation and access by Indigenous peoples will be managed to achieve a balance between these demands and the conservation intent.” CPAWS Southern Alberta recommends that rather than attempt to “balance” all land uses, all uses in the parks should be managed within ecological limits and using the stated conservation objectives of protection of biodiversity, water resources, ecological integrity and connectivity as the top priorities.  CPAWS strongly supports the direction of Section 2.2.2 to ensure connectivity between the Castle Parks, the adjacent public lands and across Highway 3. Adjacent public land management should also be consistent with the objective of ensuring connectivity across the landscape.  The government should expand on the strategies in 2.7 to work with adjacent private land holders and land trusts to ensure park management supports and facilitates connectivity and conservation efforts with adjacent private lands. Any infrastructure developed within the parks should not compromise conservation efforts either within the park or on adjacent private lands.  While the strategies in Section 2.4.1 on invasive species management are positive, this section should also acknowledge the human disturbance element of invasive species after fire and should read “The impacts of the Lost Creek Fire are partially located within Castle Provincial Park; this disturbance and associated human intervention by salvage logging and motorized access, allowed a significant infestation of noxious and prohibited noxious weeds.”  Section 2.4.2 states that “There is growing concern that low fire frequency is having profound effects on ecosystems and linked social-ecological systems.” While fire cycles and maintaining natural age structures are an important consideration in forest management, recent analyses by the Southern Eastern Slopes Collaborative shows very little lodgepole pine-white spruce forests older than 116 years in the C5 management area and Castle (see attached figure). This needs to be considered in any management decisions on forest age structure.  It should be clarified in the plan that while grazing and quiet recreation will continue, it will only continue where it supports conservation objectives and within limits. Parks do not have the same management objectives as “multi-use” landscapes. CPAWS is encouraged by the statement in Section 2.4.3 that “Further, range management activities that improve natural biodiversity, minimize or eliminate disturbance of habitat, minimize or eliminate cattle from the Alpine Subregion, reduce cattle access to sensitive riparian areas and water sources, and reduce conflicts with recreational users are essential to sustaining cattle grazing in the protected areas.” While CPAWS Southern Alberta does not object to some cattle grazing in the Castle, it should be acknowledged that depending on the ecosystem (e.g. alpine, riparian), grazing does not always enhance biodiversity and the government should work with lease holders and other stakeholders to ensure it is carefully monitored and managed to maintain ecosystem health.  CPAWS Southern Alberta supports the creation of a Wildland Parks to protect headwaters, biodiversity, species at risk and wild places. To maintain the character and protection of the Wildland Park, no additional roads should be built within the park boundaries. Such roads would impact the wild character of these area, have potential effects on water, fish and wildlife and set a dangerous precedent for Wildland Parks in Alberta. For example, the non-designated portion of the South Castle Road in the Wildland Park should be closed and reclaimed.  The cumulative impacts of all developments need to be considered in any infrastructure or facility development.

Phase-out of off-highway vehicle use from the Castle should be completed within two years including the immediate closure of all motorized trails within 100m of native trout streams.

CPAWS Southern Alberta strongly supports the removal of off-highway vehicle use from the parks. The science is clear that off-highway vehicle trails and trail use, even in controlled circumstances, causes increased erosion, changes in runoff patterns, damage to streams and waterbodies, damage to fish and wildlife habitat, harm to vegetation and rare plant communities and noise and visual disturbance to wildlife, among other environmental impacts (examples in the references below)12. Motorized use also increases the permeability of backcountry areas to humans, increasing mortality risk for species such as grizzly bear3.

Off-highway vehicle use also displaces non-motorized users. Protected areas are places for people to connect with and learn about nature through low-impact and quiet recreation. The new Castle Parks will allow these recreational activities to thrive.

While CPAWS Southern Alberta supports this action, we have a number of recommendations to strengthen this part of the plan:

 The phase-out of OHVs should be expedited to two-years to begin the restoration process and ensure ecological damages to the Castle do not continue to impact this protected area.  Section 6.10 of the Addendum should be revised to indicate that in the first year along with enforcement of use of illegal trails, all designated trails within 100m of threatened westslope cutthroat trout and bull trout streams will be closed immediately. Not closing these trails immediately continues harm to these threatened species, is contrary to the management objectives, strategies outlined in Section 2.2.3 and 2.3 and to the fulfillment of the Federal Westslope Cutthroat Trout Critical Habitat Order.  Addendum Section 6.7, special consideration should not be granted for hunters retrieving game. This negates the strong actions to restore OHV trails and to eliminate impacts to water and wildlife from OHVs (e.g. Strategies from Sections 2.2, 2.3 and 2.4). Such measure would be difficult to maintain, regulate and enforce. Likewise, without OHV use, the Castle would be an attraction for world-class backcountry hunting without motorized vehicles and support local equestrian outfitters, which would be compromised by OHV use.  CPAWS has concerns about Addendum Section 6.10.2 to “explore the potential for limited winter recreational OHV use on designated trails.” While snowmobiles do not have the exact same impacts on soil, they still have the potential to impact fish habitat and affect movement of small mammals, key ungulate winter habitat, predator-prey access relationships and noise disturbances to wildlife. They are also disruptive to quiet recreationalists looking escape noise and busy landscapes. Snowmobiles should be considered a motorized use and phased out of the Castle

1 Ouren et al. 2007. Environmental Effects of Off-Highway Vehicles on Bureau of Land Management Lands: A Literature Synthesis, Annotated Bibliographies, Extensive Bibliographies, and Internet Resources https://pubs.usgs.gov/of/2007/1353/report.pdf 2 Stokowski and LaPointe 2000. Environmental and Social Effects of ATVs and ORVs: An Annotated Bibliography and Research Assessment http://atfiles.org/files/pdf/ohvbibliogVT00.pdf 3 Northrup et al. 2012. Vehicle traffic shapes behaviour on a multiple-use landscape http://onlinelibrary.wiley.com/doi/10.1111/j.1365-2664.2012.02180.x/abstract

 CPAWS Southern Alberta strongly supports the creation and adaption of areas for mobility challenged Albertans and visitors (Addendum Section 4.1); however, these activities should not be OHV based. Research on access to nature and mobility advocates state that connection to nature is not facilitated by motorized recreation4.

Focus on quiet-low impact, nature-based recreation and tourism with minimal infrastructure and footprint.

CPAWS Southern Alberta strongly supports the focus on quiet, low-impact, nature-based recreation and tourism in the Castle Parks. Connection to nature is an important part of our Alberta identity and the Castle area is a great opportunity for Alberta families and visitors, from backcountry enthusiasts to weekend picnickers to learn about and experience wild Alberta. However, infrastructure developments associated with these activities should be minimal and retain the natural and wild character of the parks, making nature the main attraction.

A few recommendations to strengthen and support low-impact recreation and tourism in the parks:

 Nature-based recreation and tourism should support a conservation first management priority.  Low-impact nature-based recreation, visitor services, programming and tourism, should focus on nature and cultural education and stewardship engagement activities in the Castle Parks.  The plan should clearly state that nature-based tourism in the Castle Parks will not focus on infrastructure and should have a minimal footprint in the park. The tourism base should be centered in adjacent communities to reduce impacts in the park and to support local economies.  Elimination of automobile accessible random camping (as outlined in Section 6.2) is necessary to meet conservation objectives, however new rustic group camping sites need to be re-located to less sensitive areas and monitored to ensure ecological values are not impacted. Appropriate facilities need to be provided to ensure that damaging activities such as improper garbage and sewage disposal are eliminated. The success and ecological impact of this style of rustic group camping sites will need to be closely monitored.  Section 6.2 of the management plan does not mention tent-only camping sites. CPAWS supports the designation of tent-only front-country camping sites to provide tent campers with a quieter, more rustic experience.  Fixed-roof accommodation is not appropriate for the Wildland and Provincial Parks (Section 6.2). Any fixed-roof accommodations should be located in adjacent communities outside of the park boundaries.  Recreation and tourism activities should connect people to nature and the cultural history of the region.  Park zoning should be done using the precautionary principle and put conservation as the top priority. Zoning should be designated and adapted based on data to achieve conservation objective. Facility zones should be located outside of sensitive areas, including core grizzly bear habitat and threatened westslope cutthroat trout and bull trout habitat.

4 Jakubec: Connecting people to parks – at all stages of life – with people power http://calgaryherald.com/opinion/columnists/jakubec-connecting-people-to-parks-at-all-stages-of-life-with- people-power

The focus on cooperation with First Nations and Métis and the education of cultural and traditional land use and rights should be maintained as a priority.

CPAWS Southern Alberta strongly supports cooperation with Aboriginal communities in creation and management of the Castle Parks. Nature-based recreation and tourism activities should be low-impact and focus on education, awareness and respect for Aboriginal culture, communities and traditional land rights.

Thank you again for creating these special new parks in Alberta and for providing the opportunity to comment on the draft management plan and amendments. We look forward to supporting this government’s efforts towards increasing Alberta’s parks and protected areas networks. Establishing conservation as the priority in the Castle is a key element in this objective.

Sincerely,

Katie Morrison Conservation Director CPAWS Southern Alberta Chapter

Cc:

Hon. Shannon Phillips, Minister Environment and Parks [email protected] Andre Corbould, Deputy Minister, Environment and Parks [email protected] Steve Donelon, ADM Parks Division, Environment and Park [email protected] Alberta Environment and Parks Management Plan [email protected]