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Nature Alberta (Federation of Alberta Naturalists) Comments on the Draft Banff Management Plan

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On behalf of the people of Canada, we protect and present nationally significant examples of Canada’s natural and cultural heritage, and foster public understanding, appreciation and enjoyment in ways that ensure their ecological and commemorative integrity for present and future generations.

Nature Alberta (Federation of Alberta Naturalists) Comments on the Draft Banff Management Plan
(NOTE: Federation of Alberta Naturalists is changing its name to Nature Alberta)

To:Mike Murtha, Planner, Banff Field Unit
     Parks Canada
     mike.murtha@pc.gc.ca

The policy of Nature Alberta towards Banff and other national parks is in tandem with the Parks Canada mandate, which states:

On behalf of the people of Canada, we protect and present nationally significant examples of Canada’s natural and cultural heritage, and foster public understanding, appreciation and enjoyment in ways that ensure their ecological and commemorative integrity for present and future generations.

Much of the environmental and naturalists community (as well as most other Canadians) agrees with your mandate.  We are realistic enough to understand that to carry it out requires broad-based and active public support.  Such support can only truly be realized through “understanding, appreciation and enjoyment” of our Parks – which requires promotion of our Parks and attracting visitors for first-hand experience.

The draft Banff Management Plan is ambitious and a management statement focused on the ecological and cultural heritage of the Park.  When and as initiated, it should result in an even greater fulfillment of the Parks Canada mandate generally and in Banff National Park (BNP) specifically.  Nature Alberta is very supportive of the Plan generally.  However, there is a critical asterisk to note:

The results and Nature Alberta’s support assumes that all the objectives and actions in the Plan adhere strictly to the mandate and the “first priority to the maintenance or restoration of ecological integrity” (pg 5). 

Without a doubt, this is the most important point to be made, because it is not unusual for visions and mandates to be fudged, glossed over or relegated to a lower priority in the carrying out of actions.

INCREASED VISITATION
For example, the overall objectives of increasing visitation are justified for the acceptable – one might say vital – goals of increased awareness, understanding and natural/cultural experiences.  Nature Alberta recognizes the many potential short, medium and long term benefits to our Parks system and Parks Canada itself through increasing visitation.  Without people actually experiencing our Parks, it is difficult to find public support for them, or for more Parks.  Visitation is certainly one of the best ways to educate the public about nature and the reason for National Parks.  Programming designed for awareness, education and understanding, and that promotes the natural splendour of BNP regardless of the season, is the way to go in seeking increased visitation, whether the target visitor is youth, new Canadians, tourists or the Canadian general population.  But again, as long as it is guided and controlled first and foremost by the Parks Canada mandate and does not compromise the ecological integrity of the Park.
 
As you are aware, the continual increase in the number of visitors, along with development, was cited by the Banff-Bow Valley Study (1996) as an activity that,

 “threatens the mountain environment. If allowed to continue, it will cause serious and irreversible harm to Banff National Park’s ecological integrity and its value as a national park” (pg 4). 

In our opinion, the problems usually arise for two main reasons:

a) When the actions – in this case, increases in visitation – become the priority under the subtle smokescreen that impacts can be mitigated.  It must be remembered that mitigation only reduces impact or makes it acceptable (though “acceptable” is an illusory term: to whom is it acceptable, and why?). 

b) Lessening of the will and determination on Parks Canada’s part to adhere to their mandate. We realize that you walk a fine line between those (a majority) that want BNP to reflect ecological and cultural heritage and those (a minority, but who generally have considerable influence) that wish to exploit the Park’s attributes for commercial or personal gain. Your Plan does not say that directly but certainly alludes to it with suggestions such as concentrated development and increased visitation.

Thus, will and determination are perhaps the keys to this Management Plan: is the will there to stick to the mandate and goals, regardless of other pressures?

Anyone visiting BNP knows that overcrowding is already a problem.  More people means more vehicular traffic, including on already somewhat congested roads like the Icefield Parkway. There are definitely many methods of addressing or decreasing overcrowding and vehicular congestion, even while increasing the number of visitors, and the Plan alludes to that.  However, given the pressures that can arise, it will take steadfast determination on the part of Parks management and staff – which, of course, should receive full support from all levels of Parks Canada. 

CYCLING
You mention cycling several times.  Cycling is certainly an excellent method of seeing BNP up close and personal, and Nature Alberta supports increased leisure cycling (as opposed to racing and backcountry cycling events and mountain biking).  Of course, more cyclists mean more opportunity for vehicle-bicycle confrontation, but that is not an insurmountable problem. 

VIRTUAL BANFF
“Virtual” opportunities, as you mention often, are an excellent method to increase “attendance,” and they have a certain amount of educational and information value.  However, it is extremely important to keep in mind that such methods are not anywhere near a substitute for the real thing.  “Nature deficit disorder” comes to mind.  Virtual visitation may also aggravate the apathy common towards real nature.

RESOURCES
The Plan says nothing about the resources needed to carry out the objectives, which rely heavily on interpretation (personal and non-personal), science and physical improvements (those in keeping with the Parks Canada mandate).  Considering past and on-going reductions of staff and funds for these segments, our concerns may be well-founded that, regardless of good intentions, the results will be more promotion, more people, more development, more recreation, more commercialism – but less of those things that the park is suppose to provide as a priority.  Perhaps you could let us know why “Resources” were not included in the Plan.

NET LOSS
Much like mitigation, we also have a bit of a problem with the rather deceiving theory of “no net loss”: develop at Site A, but restore an equal amount at Site B.  More often than not, B never comes close to matching what is lost at A.  A ratio of at least 3:1 is more appropriate than 1:1.

NEW THINGS!
Re: Pg 17: “Create promotions, products and special events to provoke visitation to activity nodes designed for intensive use and in seasons and locations that have available capacity and sufficient ecological resilience”.

That’s a bit vague, even for a Management Plan.  You can understand our apprehension at the suggestions in the Plan of offering new activities, product improvements, new developments, alteration of zone boundaries, etc without any indication of what these actually are. 

The results depend on just what kind of promotions, products and special events are envisioned – or actually initiated.  One of the greatest experiences of national parks is that you cannot experience it anywhere else.  Promotions, products and events that take advantage of that uniqueness – that pass the “is it compatible with our mandate and first priority?” test – are great.  Obviously, to cite one example, that does not include things like golf tournaments, which can be held in roughly 20,000 other non-park locations in North America.  Though they may add profit to the commercial sector, they add nothing to the park experience. 

The same can be said for other events such as races.  One particular activity that has caused innumerable problems in sensitive environments everywhere is mountain biking.  Mountain bike trails have no place whatsoever in National Parks, since that activity can be held virtually anywhere and adds nothing to the park experience.  In fact, activities and events such as these degrade both the Park itself and the park experience for the vast majority of those who do not take part in golf, racing, mountain biking or similar non-compatible activities. 

It should be noted that many who read the quoted statement on page 17 will see it as an opportunity for things that are not compatible with the Park mandate, so this segment of the Plan may cause considerable pain for Parks managers!  It would also cause considerable pain for organizations like Nature Alberta – in fact, for that great majority of Canadians that agree with your mandate and priority.  The bottom line is that there are recreational, sporting and commercial activities that do not belong in BNP and should not be allowed in an effort to increase total numbers and commercial growth. We would also be opposed to any further commercial licenses outside of the townsites’ boundaries.
Nature Alberta would like to see the non-compatible concept declared explicitly in all the relevant sections of the Management Plan.  

BISON AND CARIBOU
Nature Alberta supports, in principle, the idea of reintroducing Caribou to BNP.  Plains Bison is a different story.  In a perfect world, having Bison once again roaming BNP would be wonderful.  But the world is not perfect.

You are certainly aware of the many problems that would arise with a reintroduction of Plains Bison: management and containment difficulties; disease possibilities; year-round food availability; population control; political opposition; to name just a few. We’re not really sure what the point would be, considering the problems, headaches and potential expense.  Would it not be far better to focus on grizzlies, large carnivores and other more immediate concerns?  To quote one of our Directors: “Manage what you have, as best you can, and do not further complicate matters.”

Thus, Nature Alberta does NOT support a Bison reintroduction at this time.  Perhaps bring the idea back in 10 years, when all your other priorities have been successfully initiated.

RAILWAY TRACKS
We realize that Management Plans are “the big picture” and as our comments so far indicate, many of our concerns are associated with the actual carrying out of the proposed ideas in the Plan.  One example of that is the problem with wildlife mortality, in particular, grizzlies, on the rail lines.  Your Plan continually refers to this problem and states (pg 59):

“Work with Canadian Pacific Railway to implement effective measures to minimize wildlife mortality along the railway tracks.”

That is an excellent idea, but the problem is already decades old and increasing.  The CPR should not be exempt from rules that guide national parks.  Perhaps it’s time for a more forceful statement indicating that the problem will be solved by 2014.  Thus, notwithstanding that broad statement, we’re mostly interested in what actions you intend to “minimize wildlife mortality along the railway tracks” and how quickly you can accomplish it. 

COSTS
Your Plan mentions several times that many visitors feel they are not getting good value: e.g., pg 44: “Visitors report a low level of satisfaction with value for money”. One of the limitations for increased visitation is the high cost that visitors are faced with in BNP.  The “Action” associated with this seems even vaguer than most actions:

“Work with the Town of Banff and the business community to improve visitors’ level of satisfaction and perceptions of value” (pg 45). 

Perhaps this is because no one has any idea how to apply that action!  However, to attract youth, new Canadians and the average wage-earner, high cost is definitely one problem that must be tackled. 

Related to high costs (though not necessarily of any value for the problem of Banff townsite economics), we would suggest three reasonable methods which may allow you to reduce general entrance fees, which in turn may increase visitation and maybe even provide increased revenue:

a) Raising Park entry fees for busloads of visitors, which presently are unreasonably low;

c) Increase entry fees for foreign visitors (who do not pay Canadian taxes that support Canada’s National Parks);

b) A gate charge – or more appropriately, a toll – for drive-throughs.  Considering that drive-throughs, including big trucks, are using the roads as much as anyone and cause extra work and headaches for Parks staff, it seems very odd and patently unfair that they do not have to pay to do so. After all, the Park was there long before the TransCanada Highway.

IN SUMMARY
Thus, our summary comment is that should Parks Canada and BNP managers view all the sections and actions of the Management Plan through the overriding lens of your mandate, then the Plan has great merit and will allow Parks Canada to live up to the all-encompassing statement on page 5:

The Parks Canada Agency is accountable for ensuring that management of each national park gives first priority to the maintenance or restoration of ecological integrity. This ensures that national parks will remain unimpaired for the benefit, education and enjoyment of future generations.

Your mandate is supported by a huge majority of Canadians, including the forty-two Alberta groups in Nature Alberta and their 5,000 members whom we represent. Nature Alberta would strongly support the Plan if, and it bears repeating:

All the objectives and actions in the Plan adhere strictly to the mandate and the “first priority to the maintenance or restoration of ecological integrity”. 

Sincerely,

Dennis Baresco, President
Nature Alberta (Federation of Alberta Naturalists)

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