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
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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.
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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
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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. 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. 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. There is, however, a lack of strategy that brings all these objectives and targets under one integrated framework to address visitor use management from myriad perspectives. As it is written, the visitor use management targets are scattered throughout the plan, thus it is unclear how the data collection will inform 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 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. Subsidiary plans 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; all subsidiary plans should define the plan’s goal, contain a bulleted list of what data and information sources will be included
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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 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 fit within the context of the Bow Valley Human-Wildlife Coexistence Technical Working Group plan. CPAWS is a part of that working group and would appreciate being involved in updating the human-wildlife coexistence plan.
Strategy 1: Conserving Natural and Cultural Heritage Summary of recommendations: 1. The strategy needs to reflect the diversity of Indigenous communities and voices that have interest in park management. 2. Caribou recovery, in collaboration with Jasper National Park, needs to be included. 3. More details regarding human-wildlife coexistence management are required. 4. Intermediate targets are required to gauge program success mid-way through the management plan life cycle.
The opening paragraph of this strategy contains a statement that acknowledges the inherent uncertainty in management of BNP ecosystems and cultural resources. We are supportive and pleased to see Parks Canada’s approach to addressing this uncertainty requires basing management decisions on the “best available science and Indigenous Knowledge in support of a precautionary, adaptive approach…”. In the Appendix, we identify some targets that could contain more measurable outcomes to put this sentiment into action. The preamble to this strategy should consider the multiple Indigenous groups names, songs, and cultural perspectives of this place. There isn’t one song or story or even group of people that know Banff’s history, there are many and this historical diversity should be reflected in the cultural assessment. This sets the stage for the current diversity of Canadians who enjoy this park and value the ecological goods and services it provides. BNP is what it has always been – a place of travel, diversity, exploration, appreciation, spiritual connection.
Over the past decade, Parks Canada has been a leader in transboundary management of threats to aquatic systems through their management of whirling disease and aquatic species management. Parks Canada has also made significant improvements in aquatic connectivity with the restoration of Cascade Creek and the removal of the 40-mile creek dam. We are concerned that targets associated with Objective 1.2 may not go far enough in addressing new concerns stemming from more recent research. For example, Parks Canada should commit to measuring micro-plastics and measuring endocrine disruption of aquatic species in their data collection of water quality.
Objective 1.3 defines management direction regarding keystone species. In terms of restoring and enhancing ecological integrity, this is a critical objective. We are highly supportive of the
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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 management target to reduce linear density of informal trails around the town of Banff by 10% by 2029. Without knowing the current extent of user-created trails, it is difficult to know whether this target is sufficient or if more concerned efforts need to be made. The proliferation of user-created trails around communities in the Bow Valley is problematic for multiple wildlife species. We are pleased to see Parks Canada committed to addressing this issue with a measurable management target. Similarly, we appreciate seeing the target to reduce human-wildlife conflict from 2019 levels. We are concerned, however, that this management target does not describe a deadline for updating the coexistence plan. We would like to see this plan updated by 2022 so that there is at least one year of implementation to monitoring its success by the 2023 deadline of reduced conflict. Another target in this objective is to examine the long-term feasibility of the bison reintroduction in BNP. This target is weak and ineffective. The bison reintroduction has arguably been one of the most successful programs in Parks Canada’s recent history in BNP. Examining the feasibility of the pilot program will be completed in 2022, but there will still be nine years remaining in the life of this management plan. This target needs to go further to ensure the continued success of the bison reintroduction with an expanded range and in partnership with the Province of Alberta (see Appendix for proposed targets).
We are supportive of the bulk of management targets in Objective 1.4 that aim to reduce invasive species throughout the park. Given that this plan will expire in 2031, we would like to see more intermediate targets to assess management plan success by 2026 rather than towards the end of the management plan in 2029. The last target addresses prescribed fire and increasing the extent to 50% of the annual burned area. The Resource Conservation Technical State of Parks Report contains several more specific and supporting management targets that should also be included. The prescribed fire program should aim to: improve stakeholder engagement and understanding, weave Indigenous Knowledge in burning plans, and be supported by multi-agency collaboration. In addition, it is not only the extent of burning that is important but where prescribed burns are implemented. We would like to see a target describing how much habitat prescribed burning will restore for grizzly bears, migratory birds, and other species, as well as a target associated with how much prescribed burning will improve the wildfire risk adjacent to communities.
The last objective in this strategy addresses the management of species at risk. While the multi- species action plan contains an abundance of information and management direction, there is still benefit from including more specific management targets in the management plan. For example, it is extremely disappointing to see that examining the feasibility of woodland caribou reintroduction and the need to improve caribou habitat for eventual reintroduction are not included as management targets. We strongly urge you to continue to include this in the plan. In addition, a target requiring collaboration with the Province of Alberta to address cutthroat trout populations is required. The BNP management plan should also list the species at risk that Parks Canada will allocate resources towards recovering over the next ten years.
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Strategy 2: True-To-Place Experiences Summary of recommendations: 1. Some terminology, like “sustainable” and “site-specific physical capacity” need to be defined to increase clarity. We support the addition of a glossary at the end of the plan that defines key terms. 2. Commit to increasing BNP social science capacity at Regional and National levels. 3. Describe how new recreational activities will be assessed and managed; define targets to increase consistency in how rock climbing and road cycling are managed.
We are supportive of the language in this strategy that emphasized authentic and quality visitor experiences. We struggle with the frequency that the word “sustainable” is used in this strategy, however. “Sustainable” has been used to define all kinds of economic, ecological, cultural, and social objectives, thus rendering it essentially meaningless. In addition, the word sustainable implies to maintain the status quo, but we would like to see visitor management strategies that move the park forward in terms of providing high quality visitor experiences while allowing for ecosystems and wildlife to flourish.
We are pleased to see that this objective includes the need for a detailed understanding of the demographics of Banff’s visitors, including patterns of use and visitor expectations. We would like to see visitor motivations added to this description. Understanding these aspects of Banff’s visitation is a significant data gap, which will require substantial effort to address. In light of that, we would like to see a management objective that demonstrates commitment to increase Parks Canada’s social science research capacity at both the National and Regional levels. These monitoring results need to be tied to criteria and indicators that will lead to a management response; this is what will directly link the data collection to management action and provide direction for Parks Canada staff in daily operations. We are also supportive of the collaborative effort between the Rocky Mountain Parks to review and assess the commercial guiding licensing process and confirm consistent standards. We think this target needs additional information about the criteria that will be used to assess guiding proposals.
There are several things missing from this objective, in particular there is no mention of how new activities will be managed. Outdoor recreation is a rapidly evolving industry and there are likely activities that will become popular in the next decade that we are currently unaware of. New activities need to be measured against a set of clear criteria that are defined in the management plan that prioritize ecological integrity and include authentic visitor experiences, working collaboratively with existing operators, and are based in a defined visitor need.
Some existing activities are experiencing rapid growth and popularity. In particular, we are concerned that long distance trail running, sport rock climbing, and road cycling are not mentioned in the management plan. Trail running presents unique challenges to park management as people get farther into the backcountry on day trips. These recreationists still use backcountry
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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 infrastructure (e.g., trails, outhouses) but are not counted in the wilderness passes. In addition, their higher speeds and quiet movement may lead to surprise encounters with carnivores. Parks Canada should include a target to identify the most appropriate trails for long distance trail running, in collaboration with recreation groups, and then ensure appropriate facilities are available for this use.
Rock climbing is a sport with a long history in BNP. There are many different kinds of rock climbing, but we are concerned with sport climbing where bolts are drilled into a cliff face. As climbing grows in popularity, more and more independent climbers are “route setting” on new rock faces in BNP. These routes range from 10m to over 30m long and can contain anywhere from three to more than 12 bolts and an anchor drilled into the rock face. The placement of bolts may appear to be an innocuous impact, but it can lead to increased rock fall hazard and disturb cliffside vegetation and/or cliff nesting birds and other wildlife. The indirect impacts associated with the proliferation of bolting are more substantial. Once a rock face is bolted, it becomes an attraction for sport climbers. These new sport climbing “crags” can become popular very quickly leading to an array of impacts including wildlife habitat displacement, the creation of new user-created trails, denuding of vegetation at the base of the cliff to create belay ledges and picnic spots, and erosion at the base of the cliff and on the trail. The management plan needs to commit to working with local climbing groups to create a permitting system for sport climbing to give the climbing community some direction regarding where crag development is or is not appropriate.
Road cycling in the park is also growing in popularity, partly due to Parks Canada’s experimental vehicle restrictions on the Bow Valley Parkway and the Lake Minnewanka loop road. These vehicle restrictions have created a new and highly enjoyable visitor experience. The management plan should explicitly contain targets that investigate the feasibility of making these seasonal vehicle restrictions permanent. Consulting and engaging with recreation group and park visitors will be an essential part of defining management details and implementation, but the intention to do so should be a target in the management plan. In addition, the management plan should also commit to monitoring the impacts of rock-climbing and road cycling on wildlife and ecosystems, both before and after management tools are applied.
Objective 2.2 says that visitor experiences will fit within site-specific physical capacity and will not harm the park’s ecological integrity. This term needs to be defined so that we can understand how it will be measured and monitored. In addition, this objective should be strengthened to include site- specific ecological capacity, which should also be defined. For priority sites, Parks Canada should work with stakeholders to define a “desired condition” of these sites that describes the visitor experience and associated ecological impacts. It is critical that park managers, park users, and stakeholders have something to aim for when considering “sound planning” and site use.
Similarly, visitor experiences in wilderness settings (Objective 2.3) should also be planned within the ecological capacity of sites, not just the physical capacity. We support limiting the group size to ten
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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 people and would also be supportive of Parks Canada including more limits of human use such as this in other locations in the park.
Strategy 3: Strengthening Indigenous Relations Summary of recommendations: 1. Weave Indigenous Ways of Knowing with park management whenever possible. 2. Diversify participation in the Indigenous Advisory Circle. 3. Use Indigenous languages on signage and other communication materials. 4. Support Indigenous-led cultural monitoring and other projects that can improve park management effectiveness from different perspectives.
Parks and protected areas in Canada would benefit enormously from the skills, knowledge and perspectives that Indigenous Peoples could bring to park management and programs. CPAWS has been working to support increased engagement of Indigenous Peoples in park management and to support Indigenous-led protected areas and conservation initiatives across Canada for decades. We remain sensitive to the need to support Indigenous involvement in park management as per their needs and requests. We appreciate Parks Canada’s efforts to include Indigenous Peoples more effectively and meaningfully in the management of BNP. A significant move forward in this regard is the discussion throughout the management plan regarding weaving Indigenous Knowledge with western science in management planning and conservation programs. While working with Indigenous Peoples to share their stories through education programs is valuable, engaging Indigenous groups as partners in the full suite of park management strategies, including prescribed burning, human-wildlife coexistence, climate change resiliency and other conservation programs will help operationalize Truth and Reconciliation in BNP management.
We are supportive of empowering the Indigenous Advisory Circle (IAC) and creating opportunities for Indigenous involvement in park management and conservation programs. The management plan acknowledges Treaty 6, 7, 8 but the IAC is only comprised of people from Treaty 7. This reduces the diversity of Indigenous representation in the discussion. The Indigenous Advisory Circle (IAC) could be strengthened by inviting other Nations from the other side of the Continental Divide who still have traditional territories within BNP to participate.
In reviewing this strategy, we identified several missing objectives and targets. We would support a target associated with including Indigenous languages on signage and other communication materials throughout the park. While place names have been a significant request of the Stoney First Nation, we also think other languages and First Nations could be highlighted in communications materials to help demonstrate the diversity of cultures that have a relationship with BNP prior to colonization. This strategy could also be strengthened with an objective stating support, both financial and in-kind, for Indigenous led projects that contribute directly to park management and conservation programs. For example, the Stoney Nation has led a monitoring
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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 project examining the cultural impacts associated with the bison reintroduction. This project could be the first of many that are Indigenous-led and provide an array of benefits for local communities, Indigenous groups, and park management. Parks Canada should also define a target to work with Indigenous researchers who have expertise in braiding knowledge and who are furthering the field of Indigenous led management.
This objective should also speak to Parks Canada’s support for and collaboration with intertribal management related projects, such as the Buffalo Treaty. This includes the need for a target to work with Indigenous Peoples on adjacent lands, both at the community and First Nation levels.
Strategy 4: Connecting with Canadians Summary of recommendations: 1. Rephrase targets to ensure they are measurable. 2. Develop a volunteer strategy. 3. Engagement programs should aim to address a management objective and desired outcome. Program success should be measured against the desired management outcome. 4. Staff should be empowered and encouraged to share their work in public forums and with partners. 5. List criteria for projects that will trigger public consultation to increase transparency.
Parks Canada partly exists to share the significance of Canada’s wild places with all visitors. BNP has global significance as part of the Rocky Mountain World Heritage Site, the headwaters of important Canadian watersheds, and a destination for visitors from all parts of the World. Although bringing the park to people where they are through various means is a great aspect of this strategy, it is surprising that there are only two objectives to operationalize this important work. Several of the targets associated with these objectives are not at all measurable, which makes it impossible to quantify Parks Canada’s success in this regard. For example, the first target under Objective 4.1 says Parks Canada will collaborate to “build public understanding for key scientific questions, findings, and conditions”. How can that be measured? Rephrasing targets like this to be more active and measurable would be a significant improvement. Additional detail is also required to define target audiences for targets; “Canadians” is much too broad to be effective.
Similar to Objective 4.2, the last management plan also committed to increasing volunteering and citizen science opportunities, yet these programs were not fully explored or implemented. Programs such as this require more direct funding and support as they can be instrumental in building a constituency of park supporters. Defining measurable targets, such as a percent increase in program participation over time and the types and frequency of communication methods applied, can help to provide the additional detail required for Parks staff to incorporate these programs in their work and annual budgets. This section should state the value and impact of volunteering on
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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 park management and commit to providing various opportunities for volunteers to support all kinds of park management programs, including the management plan’s commitment to gather an abundance of visitor related data and use patterns. This strategy should include an objective to develop a volunteer strategy that will define goals, program opportunities, and overall engagement experience outcomes.
Targets to improve information access on the Parks Canada website should also include a commitment to providing some information in multiple languages, especially for social media posts. Messaging should also be reflective of peoples’ cultural background, meeting people “where they are” both in terms of access to knowledge and cultural relevance.
Additional targets should describe tangible connections between management challenges and the outcomes of educational programming. For example, a target can be created to reduce and/or eliminate litter in high human use areas using “Leave No Trace” communications; one potential measure of success would be the amount of human capacity associated with litter clean-up over time. This strategy should also include targets describing programs that share the hard truths of high levels of visitation to the park (e.g., human-wildlife conflict, wildlife habitat displacement, disruption to alpine vegetation) in an effort to reduce impacts.
Connecting with Canadians is about more than education programs. Targets that empower and enable Parks Canada staff to share more information with the public increase transparency and are important for Canadians to feel connected to the great work being conducted by Parks Canada staff every day. For example, authors and co-authors of peer-reviewed scientific papers should be able to share and discuss that work when invited to speaker events, webinars, or media more freely. Parks Canada staff should be rewarded and encouraged to share their work more broadly. This also includes publicly releasing and posting technical documents, such as the Resource Conservation Technical Monitoring Report and the complete Environmental Impact Assessment associated with this plan, on the Parks Canada website. Having to email the superintendent’s office to get documents like this is unnecessary and does not contribute to transparency.
Part of the essence of this strategy centers around transparency, which Parks Canada repeatedly says it values. There is much work to be done to increase transparency and accountability in the objectives and targets defined in this management plan. We would like to see objectives regarding public consultation and engagement, including a list of criteria for what kinds of redevelopment or park management decisions will trigger public consultation and a requirement of Parks Canada to report back to Canadians detailing how consultation results were used in decision making.
Strategy 5: Managing Development Summary of recommendations: 1. Provide a definition of “development footprint” and how it will be measured.
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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
2. Consider types and intensities of recreational use when determining how to make facilities more inclusive and removing barriers. 3. Redevelopment projects should be held to a higher standard and be nature positive.
Finding ways to manage development to preserve ecological integrity while simultaneously addressing other parts of the Parks Canada mandate has always been a challenge in BNP. We are supportive of the focus for development to facilitate greater awareness and connection to the natural and cultural spaces BNP has to offer. We are very supportive of the management plan target in Objective 5.1 that states “the developed footprint at the park level is maintained or reduced from 2021 levels”. This is a great step forward for Parks Canada to consider the broader landscape and manage development within the context of the entire park landscape. While there will be some resistance to this management target, we feel that is one of the most meaningful in the draft management plan and will stimulate creativity and innovation. We think some additional language that defines how development footprint is defined and measured is important. There needs to be consistent understanding of what this means amongst all stakeholders and potential developers. This target should include existing leases as well as any new leases. This objective should also include a target that no new parking lots will be built or expanded in the park. Bigger parking lots take up habitat, disrupt connectivity, and do not address parking and traffic congestion issues. We also appreciate the language in this objective that protects viewscapes to ensures that all aspects of the park experience, from the view to the ecological functionality, are considered in re-development plans.
We are also supportive of efforts in Objectives 5.2 that aim to ensure the park’s facilities are more inclusive and that barriers are identified and removed. We encourage Parks Canada to not only consider the facilities and infrastructure that may increase accessibility but to also consider the types of recreational activities. Data collection regarding visitor expectations should specifically aim to understand what kinds of recreational activities all visitors expect to see when they arrive to BNP. That data should be cross-referenced to recreation ecology research that defines impacts of activities. Then Parks Canada staff can work with stakeholders to identify appropriate locations for facility upgrades that will improve the visitor experience without negatively impacting ecological integrity. For activities that are not appropriate or possible within the ecological limitations of the landscape, Parks Canada should develop educational materials explaining their decision.
Objective 5.3 focuses on how new development will be assessed. First, this management objective appears to contradict the target to not increase the park’s development footprint. There should be no additional new developments in Canada’s busiest and most developed National Park. In addition, to say that a development should not have significant adverse impacts on park resources is a minimum standard that applies to all developments inside and outside of protected areas. This language needs to be stronger. Redevelopment projects will enhance ecological integrity and contribute positively to the local environment. This target should be phrased in a way that prevents land-swaps in the name of “net environmental gain”, which some commercial developments have
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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 used to justify expansion or a larger development footprint. Swapping land parcels with different attributes and different levels of ecological significance does not create an environmental gain. Parks Canada should drive for improvements not mitigations. All proposals should also be measured against their nature-positive contribution to the park and the development’s ability to address carbon footprint and overall climate impact. Redevelopment should include decarbonizing visitor facilities and services.
This management target should explicitly state that if a development does not meet all of the criteria, Parks Canada staff are able to reject the proposal. In addition, this target should include that all proposals will be expected to conduct monitoring activities to assess any impacts and the success of mitigative efforts. Where mitigation is not successful, Parks Canada should reserve the right to cancel the development or request significant changes to development plans to ensure impacts are mitigated successfully.
Strategy 6: Regional Connectivity and Landscapes Summary of recommendations: 1. More objectives and targets are required to demonstrate how Parks Canada will improve regional connectivity and collaborate across the landscape. 2. Parks Canada should lead collaborative efforts, particularly associated with the bison reintroduction, Bow Valley wildlife management, and visitor use management across its boundaries.
Banff National Park is at the heart of the Rocky Mountain National Park ecoregion. Collaborating across boundaries with other National Parks, with provincial land management agencies, and other landowners/disposition holders is essential. We are pleased to see this as a stand-alone strategy in the management plan but are disappointed in the one objective and target that does little to provide concrete direction to operationalize this strategy. The preamble suggests that Parks Canada should actively seek, encourage, and participate in the “development of regional resource management, tourism, and transportation and tourism/recreational plans”. We suggest Parks Canada take this further. As a leader in large landscape management in one of Canada’s premier National Parks, Parks Canada should be leading collaborative efforts. It is not sufficient to expect other agencies to put these efforts together and for Parks Canada to join. We are also aware of at least two instances in the past year where Parks Canada staff have not been granted permission to participate in cumulative effects assessment projects in the Bow Valley or to share their peer-reviewed research regarding wildlife movement to inform land use decision making processes outside of the Park boundaries. In the past, Parks Canada was more directly involved in land management decisions beyond its boundaries as evidenced by its participation in the Three Sisters Mountain Village hearings in 1992 and the contribution of scientific research to the Eastern Slopes Study that led to the Bow Valley Corridor Guidelines that are still applied today. Parks Canada need to reconnect to
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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 this previous role in the Bow Valley and more broadly. This strategy appears meaningless because it is not followed up with tangible actions that demonstrate collaboration across borders.
Strategy 7: Climate Change and Adaptive Management Summary of recommendations: 1. Involve stakeholders in the development of the Climate Change Action Plan. 2. Model and identify climate change refugia for wildlife. 3. Support the Town of Banff’s Environmental Master Plan. 4. Require and incentivize businesses to reduce emissions. 5. Define nature-based solutions that will help address climate change as a scale broader than the park itself.
We appreciate that BNP is going to develop a Climate Change Action Plan and the list of things that this action plan will contain. We look forward to working with Parks Canada on the development of this action plan and believe that a target is required to commit Parks Canada to convening a process whereby all interested stakeholders are invited to participate in action plan development. In addition to the bullets listed, we think this action plan should include the modeling and identification of 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. The Town of Banff has more tangible outcomes in their Environmental Master Plan, which should also be supported by Parks Canada’s climate change action plan. The BNP management plan should include an objective to become carbon neutral by 2030, which would include targets such as defining the current carbon sequestration potential and the current carbon emissions across the Park.
As the land manager, Parks Canada has a responsibility to set the tone and expectation of climate change and biodiversity related programs in its actions, which can promote similar behaviours and expectations of visitors’ responsibilities. One simple example would be to increase the number of publicly accessible recycling and composting bins at various locations throughout the park. Simple infrastructure such as a this is a strong visual reminder for visitors to see that BNP values minimizing human waste in a special place. Parks Canada should not encourage businesses operating in the park to take actions to reduce carbon emissions, it should require and incentivize them to do so. One way that Parks Canada can support this is to work with businesses to create a program that businesses can use to measure their estimated carbon footprint and a list of mitigations that range in implementation costs. A program such as this, for example, could help businesses measure carbon emissions for diesel buses and trucks, determine the cost of switching from internal combustions. Parks Canada could also investigate the feasibility of securing federal funding for businesses to retrofit their operations to reduce emissions, working with other federal departments and agencies.
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We appreciate Parks Canada’s targets in Objective 7.2 to reduce emissions and pollution, however, this objective should be split into two. One objective should address Parks Canada infrastructure assets, which is under the sole control of Parks Canada. A second objective should address pollution sources, which may or may not be the sole responsibility of Parks Canada since some commercial operators, including CP Rail, also run the risk of spills. The second objective should include a target to work with all potential commercial and industrial polluters to create the spill management protocol that clearly delineates roles and responsibilities in the event of a spill.
The climate change strategy should also include an objective around educating visitors and Canadians more broadly about the seriousness of the climate crisis. The Rocky Mountain National Parks represent the best place in Canada to understand the impacts of climate change from multiple scales from site specific to landscape scale. Models show that glaciers in BNP will be severely reduced through the life of this management plan, therefore, this strategy should include objectives and targets associated with carbon storage and mitigation, as well as defining other nature-based solutions. While some of this may be captured in the Climate Action Plan, they do stand alone as an independent objective.
Strategy 8: Moving People Sustainably Summary of recommendations: 1. Combine the expert panel advice with the transportation related objectives in this management plan to create a Visitor Use Management Framework.
The name of this strategy is confusing. The strategy preamble speaks to a system that goes beyond transportation and encompasses the whole experience of being in and enjoying a National Park, yet the name of the strategy does not convey that holistic perspective. In addition, the newly formed expert panel is also examining this aspect of park management. To increase clarity, we suggest the strategy in the management plan provide the overarching visitor use management objectives and strategies, and the expert panel focus on one aspect (i.e., the people-moving aspect) of that strategy. A transportation strategy is part of a Visitor Use Management Framework, but it does not effectively address what activities people engage in once they reach their destination. This management strategy needs to consider all aspects of the visitor experience from pre-trip planning to post-trip engagement feedback. Clearer language will help Canadians understand the difference between this key strategy, the advice and process associated with the expert panel, and the final sub-management plan. If this strategy is more comprehensive than the expert panel, space would be created for additional objectives and targets. This strategy is the piece that ties other targets in the plan together in one comprehensive visitor use strategy. This strategy should define what will happen to all of the visitor use data that will be gathered through other strategies’ objective and targets, what management objectives that data will address, what the visitor experience outcomes will be, and how ecological integrity will be enhanced through these efforts. This visitor use strategy should also define how Parks Canada will move BNP towards being carbon neutral. The only
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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 objective associated with this strategy is actually a target and would be strengthened if it was to create a visitor use management framework for BNP.
Additional objectives need to be associated with what people are doing when they get to their destination. Other objectives in the management plan speak to better understanding what activities visitors are engaging in, what their expectations are, and other human dimensions of the park experience. This strategy is the opportunity to bring those pieces under one objective that clearly defines:
• How Parks Canada will define thresholds and indicators that will require management action, and how those actions will tie together across the landscape. • The differences between backcountry and front country human use impacts, experiences, and management approaches and how these all work together to manage ecological integrity and visitor experience.
Area Strategies Town of Banff We appreciate that the Town of Banff faces its own unique management challenges and requires specific objectives and targets in this management plan. We are concerned that the language around the targets is not specific enough to clearly provide direction for development in the Town of Banff.
We would also like to see more explicit coordination and cooperation with the Town of Banff in terms of supporting their Environment Master Plan, addressing human-wildlife coexistence, and implementing Fire Smart programs. Parks Canada should also collaborate with the Town of Banff on visitor information and educational opportunities. Lake Louise Area Summary of recommendations: 1. Detail the order of events associated with the new wildlife underpasses on the Lake Louise ski hill road. 2. State how adaptive management principles will be applied to all new management actions aiming to reduce traffic flow to Lake Louise and Moraine Lake. 3. State that grizzly bear habitat security will be increased in Skoki LMU by managing human use levels in an adaptive management context. 4. Do not include the Paradise Valley trailhead as a bus stop.
Lake Louise Area has been presenting significant visitor experience and ecological integrity management challenges for over a decade. There is no doubt that Lake Louise requires focused attention to address an array of issues with an extremely high and continually increasing level of visitation. The strategy states that the most challenging aspect of this increased visitation is
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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 managing the volume of private vehicles. While we agree that this is a significant challenge, we suggest that the high volume of visitors themselves, not just their vehicles, presents the greatest challenge. Visitors to the park impact the ecological integrity, social and visitor experiences, and infrastructure assets in multiple ways; most of those impacts occur when the visitors are not in their vehicles. This is one of the principal reasons that CPAWS has so ardently encouraged Parks Canada to consider a holistic visitor use management framework – it is not only how people get around the Park, but what they do when they arrive at their destination that presents the greatest challenge to park management.
We are supportive of the strong foundation of this area strategy focused on improving ecological integrity and enhancing visitor experiences. Our biggest concern with this area strategy is the apparent conflict between efforts to improve functionality of the Whitehorn Corridor while also considering the Lake Louise ski area parking lot as the base for the shuttle service to Lake Louise and Moraine Lake. While using the Lake Louise ski area parking lot as the base for shuttles will address various safety and visitor experience concerns, it will also dramatically increase traffic on the Lake Louise ski area road. This will dramatically impact the effectiveness of the Whitehorn corridor from the Bow Valley Parkway to the Pipestone area. We understand that crossing locations have been identified based on wildlife movement data. The management plan needs to clearly define when an underpass and fencing will be built and at which location. This work needs to be completed before the ski hill parking lots is turned into the shuttle base.
In Objective 1.1, maintaining/improving the Fairview wildlife corridor, the targets speak to reducing traffic volumes on Lake Louise Drive and Moraine Lake road. Some of these measures are currently in place and have had minimal effect. More specific actions should be included that are measurable over time to define the most effective management approaches in reducing traffic volume. This is an essential component of adaptive management. The last target suggests that trails in the Fairview corridor will be evaluated and reconfigured to improve corridor effectiveness. We suggest the trails that will be evaluated be named here.
Objective 1.3 continues the work with CP rail to mitigate wildlife-rail mortality, which is great to see. There needs to be a specific target that defines when this objective is complete. We think a target that includes the need to monitor new technology applications and management approaches to refine management effectiveness over time needs to be included.
We are pleased to see an objective about increasing grizzly bear habitat security in this area strategy, since that is something that was missing in the main management plan. As the Skoki area is one of four LMUs in the park with a grizzly bear habitat security below the threshold of 68%, increasing habitat security in this area is essential. Grizzly bear habitat security is tied to two aspects of the landscape – the quality of grizzly bear habitat and the volume of visitors. The targets in this objective all centre on managing grizzly bear habitat quality through vegetation management. While this may reduce human-bear conflict risk, as a lone measure, it also reduces habitat quality.
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This can be problematic at a larger spatial scale. Food sources should not be removed without being replaced elsewhere. Therefore, this objective requires a target associated with habitat enhancement away from human use areas where either forest will be cleared or food source planted (i.e., shepherdia). There should also be targets, however, that target human use levels in important grizzly bear habitats. This involves:
• Understanding the location of high-quality grizzly bear habitat quality at least 400m from human use areas, and • Reducing or eliminating human use in these areas.
This may require implementing caps on the volume of visitors on certain trails during the berry season (July – September), and/or closing certain areas to human use during weeks of the year or hours of the day. Finding ways to reduce human use will be essential to effectively increase grizzly bear habitat security.
Objective 1.6 addresses the need to protect water quality and aquatic native species. The second target is to carefully manage water-based activities and access to waterways to reduce the risk of invasive species. Some additional detail on how water activities may be managed would be helpful. Are these mechanisms targeting the boats people use, human use levels, the kinds of activities people engage in, where people have come from, or all of the above?
The visitor experience portion of the strategy address several objectives that will improve the visitor experience and reduce congestion. We appreciate the pre-trip planning management actions as they will help ensure visitors have appropriate expectations for their Lake Louise experience, as well as giving people an opportunity to learn about the challenges facing this part of the park. An additional target should be added regarding educating park visitors prior to their arrival about the ecological importance of the Lake Louise area and the importance of being a good steward. We appreciate the visitor monitoring program to understand the patterns of visitor use as part of the actions to address Objective 2.2. We would also like to see trail intercept surveys to measure visitor expectations and motivations as part of this program.
Another in the list of management actions is to incorporate the Paradise Valley trailhead into the shuttle system or future transit plans. We are not supportive of this. The Paradise Valley is known to contain critical grizzly bear habitat and is essential to address grizzly bear habitat security. Over time, this trail has been rerouted to avoid the most sensitive grizzly bear habitat, the backcountry campground has been closed for certain times of the summer, and there is a group of four restriction in place for hikers in the summer. These measures were put in place to further protect grizzly bear habitat. In the larger landscape, the adjacent Larch Valley is one of the busiest trails in the Park. Even though Larch Valley still contains high quality grizzly bear habitat, it is less frequented by bears because of the volume of people. Maintaining a lower level of human use in Paradise Valley is essential to ensure grizzly bear habitat security is not further impeded and is
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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 currently managed through current parking lot size. Under no circumstances should Parks Canada increase visitor use of Paradise Valley trail or campground.
The last objective in this area strategy speaks to visitor education, which is great. We are concerned, however, that the actions listed are not outcome-based or measurable. For example, encouraging people to practice safe and ethical wildlife viewing is not an outcome. In addition, safe and ethical wildlife viewing should be defined. Educating hikers about the importance of using designated trails is similarly not an outcome. The outcome is that non-designated trails begin to see less human use over time. The actions listed are commendable and appropriate, but they need to be rephased to be focused on the outcomes that will be achieved through visitor education. Lake Minnewanka Reservoir Area Summary of recommendations: 1. Involve stakeholders in the development of a Minnewanka area plan. 2. Ensure multi-use trail development does not impede wildlife movement through the Minnewanka loop. 3. Place visitor management into the context of an overarching visitor management framework to address park-level objectives.
With its proximity to the Town of Banff, several campgrounds, and a variety of recreational experiences available, it is not surprising that the Lake Minnewanka area is a popular destination for park visitors. We appreciate Parks Canada highlighting this area in this management plan and we support the development of an area plan. We hope that stakeholders will be invited to participate in the development of this area plan and not just invited to provide feedback once a draft plan is created. We are supportive that no overnight accommodations will be developed in this area. We also support the intention in the area plan to work with partners to collect data that describes the patterns, types, and demographics of visitor use. While this data will help the plan address visitor use levels, it will not address visitor expectations. If the area plan is to consider visitor expectations, we suggest that be added to the first target.
In terms of the area plan, any multi-use trail between Two Jack Lakeside and Two Jack Main campgrounds needs to consider current wildlife movement patterns and avoid further impact. Wildlife traveling along the front of the Fairholme range and on the north side of the Trans-Canada Highway are naturally funnelled into the Minnewanka loop road area, walking through the centre of the loop. Any human use trails should not be developed through the centre of the loop and should run parallel to the road to avoid displacing wildlife movement in this pinch point. This area plan should also examine the feasibility of designating specific weeks or days of the year where a vehicle restriction on the Minnewanka Loop Road will provide a safe walking/cycling route along the road.
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Appendix 1: Detailed Analysis and Recommendations Strategy 1: Conserving Natural and Cultural Heritage Objective 1.2: Aquatic Ecosystem Restoration Bullet #2: Mapping the park’s wetlands and clearly identifying high-priority areas where amphibian occupancy may be affected by park management is a good target. Remediation plans should be in place for any area that development has or will impact amphibian habitat, not only areas where development is occurring. The map of the park wetlands should also identify potential climate refugia for amphibians.
Objective 1.3: Keystone Species Bullet # 4: Working beyond boundaries to maintain and improve wildlife corridors. This target should contain the following:
• Mapping the extent of wildlife corridors and barriers to movement that cross the National Park boundary. • Identifying specific measurable outcomes that define “improved” wildlife corridors. Is improvement related to multiple species crossing in and out of the Park without incident? Is it tied to carnivore movement only? • Parks Canada will work with neighboring jurisdictions to identify areas of common ground where joint projects are required.
Bullet #5: Grizzly bear habitat security. Currently there are four Landscape Management Units (LMUs) that fall below the threshold of 68% secure habitat for grizzly bears: Banff Town, Lake Louise, Skoki, and Sunshine/Egypt. This management target should specify that grizzly bear habitat security will be increased to the 68% threshold for both Skoki and Sunshine/Egypt LMUs. These two LMUs are largely in the backcountry and should thus be easier to bring grizzly bear habitat security into alignment. To bring these LMUs closer to the 65% threshold will require focused human use management to reduce human use levels in critical grizzly bear habitat. Parks Canada will need to integrate several other management targets that discuss applying an array of management tools to address human use. In addition, both of these LMUs contain ski hills that are looking at options to increase their summer use, which will further compromise grizzly bear habitat security. It is imperative that prescriptive language in the management plan provide park managers direction to increase grizzly bear habitat security despite the pressure to continually increase human use.
Bullet #6: Bison reintroduction feasibility study. This target should be more specific and position Parks Canada as a leader in bringing bison back to the Alberta landscape. This target should include the following:
• If the feasibility study demonstrates favourable results, Parks Canada should implement a 5- year bison monitoring program that works with the province of Alberta and First Nations to
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examine the feasibility of extending the boundary of bison range into provincial lands. Given that there are no grazing lease holders or property owners on adjacent provincial land, there is an opportunity to provide more space for the growing bison herd. • A proactive education and engagement program in collaboration with the province of Alberta that works with communities closest to the current bison range to address concerns and implement solutions prior to bison expanding eastward. • Support of the Stoney First Nation’s cultural monitoring project aiming to examine the implications of bison reintroduction from a holistic, cultural perspective.
Missing target: Caribou recovery. A target committing Parks Canada to preparing for eventual reintroduction of caribou needs to include:
• Mapping the best available high quality caribou habitat and implementing management tools to ensure it remains secure. • Working with Jasper National Park to include reintroduction of caribou to BNP in their overall caribou recovery plans. • Working with the Stoney Nakoda Nation and other First Nations to conduct at least one ceremony to heal the land and prepare it to welcome caribou back to BNP (as was done with the bison reintroduction).
Objective 1.4: Restoration Activities Missing target: There should be a target that measures the extent of open meadow habitat and how that habitat was created (e.g., prescribed burning, bison grazing). Strategy 2: True-To-Place Experiences Objective 2.1 Rooted visitor experiences The objective discusses core components such campgrounds, trails, and scenic drives. We do not think that “scenic drives” should be included in this sentence as it is not a core component of the park experience. If there is a need to manage scenic drives, such as the Bow Valley Parkway, then there should be a specific management target associated with that.
Bullet #2: We are supportive that authenticity be a priority criterion when reviewing applications and proposals for businesses and visitor activities but think the word “attraction” should be removed from this target. There should be no attractions to BNP that are not the natural attractions of the mountains, lakes, and dramatic ecosystems that draw millions of people per year.
Bullet #5: “Special Events” should be defined. What kinds of special events? Non-motorized, self- propelled recreation activities? In addition, this target should limit special events to start and end in highly developed areas, such as the Banff or Lake Louise town site, where there will be sufficient infrastructure to support spectators and participants. This target should also define a maximum number of participants for special events to be considered. The target says these events have to
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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 meet “high sustainability standards” but this term is ambiguous and provides no management direction in examining specific proposals.
Objective 2.2: Visitor experiences are sustainable Bullet #3: A variety of methods will be used to manage visitor use. We would like to see some examples of these methods that will be explored, such as daily or seasonal temporal visitor use restrictions, visitation quotas at certain sites, site design and infrastructure improvements. We also would like to see a commitment to work with stakeholder to test and refine these management tools so that a variety of perspectives are effectively considered.
Objective 2.3: Visitor experience in wilderness areas are sustainable Bullet #1: Allows for the development of new huts at or above treeline in cases where there are public safety issues. If there are examples of specific huts that fit this description, then they should be listed here. There is a risk that the language in this target creates the possibility for further hut development in the backcountry, which should not be permitted. Public safety issues are abundant in the backcountry and one could make an argument that huts are required for people to escape the safety risks associated with sudden, extreme weather. This target should not be so vague as to be misinterpreted.
Bullet #4: Commercial horse use will only occur in designated areas, which is already the case. It is unclear how it will be managed to allow impacted natural resources to recover and/or reduce impacts. How will recovery or reduced impacts be measured? Will they be monitored over a period of time before horse use will be permitted to continue? Strategy 4: Connecting with Canadians Objective 4.1: Building a constituency of park supporters. Bullet #1: Rephase to be more measurable and meaningful. For example, this could read: “… Parks Canada will measure an increase in public understanding of key scientific questions, findings, and conditions in BNP through a series of online survey conducted at annual intervals throughout the management plan”.
Bullet #2 is unclear. It currently says that visitor behaviour will be influenced positively through investments in promotional activities. Who is doing the investing? What are promotional activities? Are the activities promoting visitation in the park or promoting an expected visitor behaviour? Strategy 5: Managing Development Objective 5.2: Removing barriers This objective requires another bullet that describes the data that will be gathered to assess what kinds of activities and facilities visitors expect to see and how those expectations will inform site- specific planning and management. This target should also state that any new activities or facility upgrades will prioritize ecological integrity and meet visitor expectations.
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Objective 5.3: New development or redevelopment criteria The target associated with this objective lists several criteria that will be used to evaluate development and re-development proposals. We propose the following be added to this list:
• Define what positive impacts will be realized to the park’s natural resources and ecological integrity. • Define how the development will contribute to Canadians’ appreciation and understanding of the unique significance of Banff National Park. • Define how Indigenous groups will be consulted or engaged in the development process and operations.
Objective 5.4: Large-scale development proposals We are unclear what exactly defines “large-scale” and why BNP would even need to consider any large-scale development. There should not be any more large-scale developments in BNP. This objective should be removed and a statement that no more large-scale developments will be considered included in the strategy description. This will also align with the intent to maintain or reduce overall development footprint. Strategy 6: Regional Connectivity and Landscapes The one objective and target in this strategy list examples of subject areas where Parks Canada can participate in regional initiatives, we believe the Parks Canada team should define targets around each of those themes (e.g., fire planning and fuel management, coordinated response to human-wildlife conflict, etc). In particular, we also see the need for objectives and targets regarding the following:
• The bison reintroduction presents Parks Canada with an ideal project with which to create a multi-stakeholder, collaborative group to examine the long-term cultural and ecological implications of bison recovery on the broader landscape (including the Ya-Ha-Tinda). • Caribou recovery in BNP will require collaboration with Jasper National Park, as well as recreation groups (e.g., ski touring and hiking communities) to ensure that habitat quality and security are being built now for eventual reintroduction. • The creation of a Zone II Wilderness Management Plan that includes working with provincial jurisdictions to address incursions into the National Park from crown provincial land and species at risk movements beyond the National Park into crown land. • Coordinating regional land management strategies with Indigenous groups and other land managers to discuss strategies to contribute to the Federal objective of protecting 30% of Canadian lands and water 2030.
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Strategy 8: People-Moving Strategy Objective 8.1: Travel to and within the park Bullet #1: This objective should only include targets associated with travel in and around the park, yet the first target mentions attractions and patterns of visitor use. The first target should stick to transportation.
Additional targets should include:
• Completed recommendations of the expert panel being submitted to Parks Canada and incorporated into the overall strategy. • Demonstrated changes in visitor use patterns to reduce ecological impacts in the next State of Parks report. • Meaningful and thorough engagement of all stakeholders in the development of the Visitor Use Management Framework. • The final framework reflects Indigenous engagement in park management. • The people-moving strategy demonstrably reduces overall Park carbon emissions. Management Areas Town of Banff Objective 7.1.1: Achieves objectives in Town of Banff Incorporation Agreement Bullet #1, sub bullet #1: Development in the townsite does not interfere with viewscapes. The word interfere is subjective and should either be defined or changed. What one person thinks is interference, another may see as part of the view. Wording should include that no human-built infrastructure will exceed height limits defined in the Town of Banff building codes so as to not disrupt the viewscape in and around Town.
Bullet #1, sub bullet #3: There needs to be more detail regarding “respects natural processes to the highest degree possible”. It is difficult for development in a town site to adhere to the array of natural processes of the National Park. Which natural processes? Who defines the highest degree possible?
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