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Banff National Park Box 900 Banff, Alberta T0L 0C0

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Banff National Park Box 900 Banff, Alberta T0L 0C0 c/o Canada Olympic Park 88 Canada Olympic Road SW Calgary AB T3B 5R5 Phone: (403) 232-6686 Fax: (403) 232-6988 www.cpaws-southernalberta.org Dave McDonough Banff Field Unit Superintendent Banff National Park Box 900 Banff, Alberta T0L 0C0 July 7, 2021 Re: CPAWS’ Recommendations for Banff National Park Draft Management Plan 2021 Dear Mr. McDonough, The Canadian Parks and Wilderness Society (CPAWS) is pleased to provide our comments and perspectives on the draft 2021 Banff National Park (BNP) 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 Banff National Park. We understand that the BNP 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. Banff 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. This document details our overall comments and specific areas for improvement. For clarity, we have followed the same structure as the management plan by reviewing the overall management plan vision and context, then each key strategy, and finally the management areas of focus. An appendix is included at the end with our detailed recommendations pertaining to the wording used in individual objectives and targets. We look forward to working with the many dedicated Parks Canada staff to implement this management plan over the next 10 years. Please feel free to contact us to discuss any of our input further. Yours in conservation, Katie Morrison Sarah Elmeligi Anna Pidgorna Conservation Director National Parks Coordinator CPAWS National Senior CPAWS Southern Alberta CPAWS Southern Alberta Conservation Coordinator CPAWS Comments re: Banff National Park Draft Management Plan 2021 1 c/o Canada Olympic Park 88 Canada Olympic Road SW Calgary AB T3B 5R5 Phone: (403) 232-6686 Fax: (403) 232-6988 www.cpaws-southernalberta.org Overarching Comments 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 Banff National Park. This recognition is pervasive throughout the plan, which is an essential component of Truth and Reconciliation. Banff National Parks 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 Banff National Park. We note that the introduction of the Parks refers to Treaty 6, 7, and 8 Nations but neglects to include Metis Region 3. This omission needs to be corrected. In addition, we believe that all Nations need to be listed upfront to increase recognition of the individual Nations and cultures that form the history and current expanse of Nations that have an interest in this landscape. 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 BNP in the draft management plan. In the Indigenous Relations strategy, the first objective starts by “thinking seven generations into the future”. This thinking and language should also be reflected in the vision statement as it is what will enable Parks Canada to implement effective programs to address the climate change and biodiversity crises facing our World. Vision statement As it is currently written, the vision statement prioritizes the human experience associated with the landscape of BNP. The vision statement does not reflect the need to restore ecological integrity, nor does it reflect how the maintenance and restoration of ecological integrity is the first priority of the Minister when considering all aspects of park management. This language needs to be included in the opening paragraph describing the vision. The vision statement should also include language about the habitats of BNP being critical to a functioning, resilient, productive large landscape ecosystem in the face of climate change and the global biodiversity crisis. BNP is a place where the global biodiversity crisis is stemmed through proactive, intentional management practices that recognize the unique role BNP 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 BNP 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 BNP’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. CPAWS Comments re: Banff National Park Draft Management Plan 2021 2 c/o Canada Olympic Park 88 Canada Olympic Road SW Calgary AB T3B 5R5 Phone: (403) 232-6686 Fax: (403) 232-6988 www.cpaws-southernalberta.org 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 the Stoney First Nation 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 BNP 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 Banff National Park is a unique park in the world, particularly given the high level of visitation and ecological significance of the landscape. 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. While the management plan repeatedly attests that Parks Canada is a leader, we do not see that leadership CPAWS Comments re: Banff National Park Draft Management Plan 2021 3 c/o Canada Olympic Park 88 Canada Olympic Road SW Calgary AB T3B 5R5 Phone: (403) 232-6686 Fax: (403) 232-6988 www.cpaws-southernalberta.org reflected in the management objectives and targets. This is more than a suite of management goals and objectives; it is a critical component of the plan’s foundation. Following the 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. A potential opportunity to demonstrate leadership in this regard is for BNP to partner with Jasper National Park to designate the Icefields Parkway as Canada’s first carbon-neutral highway by 2025.
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