Castle Provincial Park and Wildland Provincial Park Management Planning

September 22, 2015

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The Honourable Rachel Notley
Premier of Alberta
By email: premier@gov.ab.ca

The Honourable Shannon Phillips
Minister, Alberta Environment and Parks
By email: AEP.Minister@gov.ab.ca

September 22, 2015

Dear Premier Notley and Minister Phillips,

Re: Castle Provincial Park and Wildland Provincial Park Management Planning

Thank you for the long-awaited designation of protected areas in the Castle. Alberta Wilderness Association (AWA) believes the designation is the first, vital step in a process to restore this significant wilderness area and secure our headwaters.

We know that truly protecting the Castle as a keystone piece of Alberta’s biodiversity mosaic requires comprehensive management plans and regulatory enforcement. AWA is seriously concerned that with the initial information we have from Alberta Environment and Parks, the designation exemplifies when a park is not a park. The protection outlined in early September is more symbolic than substantive.

Throughout the past several decades, activities including oil and gas exploration and development, livestock grazing, clear-cut logging, and high-impact recreation, including motorized recreation, have caused substantial disturbance to portions of the Castle. AWA firmly believes that now is the time to begin restoring this area from the damage of those disturbances. We also know that restoration cannot occur while the activities that caused the initial damage continue largely unabated.

AWA respectfully provides the following points of emphasis to include in the management plans for Castle Wildland Provincial Park and Castle Provincial Park. We look forward to an opportunity to review this document with you and your staff.

Restoration Wilderness

Restoration of this keystone area must be a primary goal to achieve full protection as promised on September 4, 2015.

AWA has long held that the Castle is an area of restoration wilderness rather than the original pristine wilderness it once was. Restoring natural function and ecosystem processes means making some difficult decisions about allowed activities and initiating natural plant driven recovery processes that support the natural forces of nature.

AWA believes wilderness exists where large areas are characterized by the dominance of natural processes, the presence of the full complement of plant and animal communities characteristic of the region, and the absence of human constraints on nature. Alberta’s wild lands provide habitat for the wildlife that call them home and provide a setting for healthy headwaters, wetlands, and aquatic ecosystems. They regulate the climate, filter the air, and absorb, purify, and slowly release water to benefit all living things. The Castle wilderness is worthy of protection, restoration and firmly and unambiguously establishing long-term management principles that are consistently enforced.

Headwaters Security

Headwater protection within the Castle is a crucial component of securing clean and clear water for downstream communities.

The Castle contains important watershed areas, and comprises a significant source of the water in the Oldman river system. These headwaters form vital habitat for many wild species and provide the clean water that many Albertans and other Canadians living downstream depend on. To play this vital role these headwaters need meaningful protection from excessive linear access and from motorized recreation. Government policy papers have stated, time and again, that protection is the primary intent for land management policies in the Castle. For example, the 1977 Eastern Slopes Policy stated: “The highest priority in the overall management of the Eastern Slopes is placed on watershed management” (emphasis added). Even earlier, the Rocky Mountain Forest Reserve was established in 1964 for “the maintenance of conditions favourable to optimal water supply.”

Today the importance of these objectives is, if anything, more important than it was then. It is imperative that these foresighted management principles not be forgotten, and that the security of a sustainable clean fresh water supply be enshrined in the management plans for the Provincial and Wildland Provincial Parks.

Roadless Areas

Roadless areas are an intrinsic requirement for wilderness areas and are vital for the protection of native ecosystems. Linear disturbance in the Castle must be reduced and recovered.

Linear disturbance in both the Castle Wildland and Castle Provincial Park is well documented and exceeds targets for the successful functioning of this ecosystem. Stephen Trombulak and Christopher Frissell in Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities, their comprehensive scientific literature review, identified seven general “negative effects [of roads and trails] on biotic integrity in both terrestrial and aquatic ecosystems:”

• Mortality from road construction;
• Mortality from collision with vehicles;
• Modification of animal behaviour;
• Alteration of the physical environment;
• Alteration of the chemical environment;
• Spread of exotics; and
• Increased use of areas by humans.

In the case of the Castle our concern is that since remote areas are made more accessible by roads and trails they reduce the wilderness value of the area. As roads and linear disturbance necessarily accompany human development, road density is appropriately viewed as a proxy for development density. Thus a Castle that contains high incidence of roads and trails cannot be considered wilderness.

Each one of these above effects are at play in the Castle and at odds with restoring wilderness values. Current designated trail networks within the two proposed Castle parks total more than 500 km. In 2011, overall linear disturbance in the Castle Special Management Area Forest Land Use Zone totalled 1,283 km, for an average density of 1.3 km/km². This is more than double the scientifically-established thresholds of 0.6 km/km² as recommended in the grizzly bear and westslope cutthroat trout recovery strategies for the survival of those species. The Castle has a history of being over-roaded and over-developed. This has led to the landscape damage we see today which is in dire need of restoration. This restoration must be a primary focus of management planning.

Random camping

Random camping can be an appropriate and a supportive recreational use of a wilderness landscape, however it must be managed carefully with enforcement to prevent abuse of this provision.

AWA generally approves of random camping. However, random camping is a privilege often abused. Consistent management and enforcement must be in place. Fourteen day limits on random camping are appropriate and offer ample opportunity to hikers and campers to explore and enjoy the surrounding wilderness areas. In the Castle and elsewhere on the Eastern Slopes these limits are being ignored; some campers are simply squatters, setting up semi-permanent camps that last over the course of the season and often over several years. Random camping, if unchecked, often places particular pressure on riparian habitat which is by far the most important for most forms of wildlife. This must be dealt with through consistent enforcement.

Abuses of random camping opportunities include:

• garbage dumping,
• damage being done to campsites (for example, vegetation cutting and streambank damage),
• squatters asserting “ownership” or tenancy over campsite areas,
• severe soil compaction,
• noise,
• heavier fishing pressure.

These abuses must be dealt with.

Hunting

Hunting should not be allowed in the Castle Provincial Park.

There is no good reason for hunting to be allowed in the proposed Provincial Park. The only hunting currently allowed in an Alberta Provincial Park is the Elk management hunt in Cypress Hills Provincial Park. This is an exception that exists for a specific documented reason; no analogous situation exists in the Castle. AWA is concerned about the reasoning for allowing this hunt, to say nothing of the precedent it may set for future parks.

Livestock Grazing

Livestock grazing needs to be curtailed throughout the Castle, and eliminated from the upland sub-alpine and alpine areas. Reduced stocking rates may be required and should be disallowed in the Provincial Park.

Wherever intensive livestock grazing has occurred in the Castle over the past several decades, plant communities have been converted from native species to a combination of non-native grasses, native forbs and shrubs, and non-native weedy species. By removing competing herbaceous species, grazing may also have contributed to the invasion of woody plant species. In the 2002 paper Bringing it Back: A Restoration Framework for the Castle Wilderness, Dave Sheppard, Gary Parkstrom et. al. note that grasslands in the overgrazed meadows of the South Castle River valley, “presumably once dominated by rough fescue and other native grasses, had been largely taken over by introduced Kentucky blue grass and timothy, as well as introduced weeds such as Canada thistle and tall buttercup.”

In a 2000 survey, botanist Reg Ernst also determined that over grazing has served to diminish the canyons’ natural values, suppressing native flora and replacing them with a host of invasive plants placing a heavy burden on the crucial watersheds they support.

Livestock grazing diminishes the quality of the area as a site for recreation. Hikers, fishers, campers and other self-propelled recreationists end up needing to pick their way around manure piles. In some areas, finding an undisturbed site to set up a tent can be a challenge.

In an October 13, 2014 letter to the Government of Alberta, AWA passed on the concerns expressed to us by our supporters who have visited the Castle’s front range canyons. These concerns included:

• The trampling of tree and plant life on the valley floor.
  “This was so bad that the historic trail in many places in the upper part of the valley is now indistinguishable from dozens of other ‘trails’ through the trees created by cattle.”
• The presence of large amounts of cow dung throughout the valley.
  “Although having some dung is undoubtedly a natural part of the ecosystem the problem seems to be that large numbers of cattle are returning to the same area year after year and are adding to the deposits faster than they can decompose.”
• The trampling of the banks and stream bed of the main creek and some of its tributaries; and the pollution of this vital water source.

Livestock grazing does not belong in the upper alpine areas of the Castle. It is questionable, at best, in the lower canyon bottoms. In any case, careful management of grazing is an absolute necessity. Only non-native forage species should be provided for grazing. This may mean reducing the stocking rate in some areas. It is essential to avoid grazing where competition with wildlife will occur.

Off-Highway Vehicle Use

Off-highway vehicle use is damaging to the environment and is damaging to nearly all wildlife species including, sensitive and threatened species. It disrupts the wilderness experience for other park-goers and should not be allowed in either of the Castle parks.

Plans to allow off-highway vehicle (OHV) use in the Provincial Park and Wildland Provincial Park constitute a significant concern. The Castle encompasses a network of trails used for OHV recreation – some designated and some not – that far exceeds linear disturbance density tolerances recommended in the recovery plans for species at risk that are found in the area, such as those for the grizzly bear and the westslope cutthroat trout. For these species populations to persist in the Castle, the extent of the trail network needs to be drastically reduced or eliminated. These trails have multiple effects on the forest ecology and the resident plant and wildlife species. Trails disrupt and fragment habitat, provide a vector for the introduction of invasive plant species, and bring greatly increased human use deep into the backcountry where it conflicts with existing wildlife populations. Disturbances related to both trail construction and maintenance, as well as their use by OHVs, erodes the land; they ultimately accelerate siltation into headwaters streams where native fish species are threatened. In short, OHV use is incompatible with native plants, wildlife, fish and non-motorized recreation activities in the park.

In similar areas elsewhere along the Eastern Slopes, such as the Bighorn Backcountry, AWA monitoring and research projects (reports online at: http://albertawilderness.ca/issues/wildlands/areas-of-concern/bighorn/#parentHorizontalTab5) have revealed that the establishment of a designated trail network is insufficient to prevent motorized recreation from damaging watersheds. Years of monitoring have shown that users regularly go off-trail and damage vegetation and riparian areas. This kind of damage takes decades to recover. This damage occurs despite the presence of signs banning this practice. Trail closure periods, established to protect wildlife and sensitive water-logged ground during vulnerable times of the year, are often ignored. Even conscientious riders who stay on-trail and adhere to the regulations end up causing untenable amounts of erosion and damage to the valley bottoms, just by virtue of their numbers and regularity of use. The alpine and sub-alpine headwaters along the Eastern Slopes, with their soft soils, frequent rainfall, and carefully balanced ecosystems, cannot support this type of activity on the land.

In the Castle parks, we need to ask what really is being protected. With motorized recreation in place, native plants are not protected from invasive species, native fish populations are not protected from watercourse disruption, and native terrestrial populations are not protected from habitat fragmentation. Perversely, these parks protect the very activities that have compromised so severely the ecological health of the area. Unless these activities are prohibited and restricted seriously the government’s September 4, 2015 announcement delivers symbolic, not substantive, protection.

Native Species Protection

A focus on native species protection is of paramount importance for these new parks. Native species habitat is highly negatively impacted by dense networks of trails and other linear disturbances, such as which exists in the Castle currently. These networks must be clawed back.

It is well-documented that the livelihood of several species at risk inhabiting the Castle, such as grizzly bears, wolves and wolverines, is negatively impacted by linear developments such as OHV trails and other areas where motorized activity takes place. For example:

• In her 2015 MSc thesis Complex Effects of Human-Impacted Landscapes on the Spatial Patterns of Mammalian Carnivores, Nicole Heim notes that “wolverines negatively respond to spatially extensive and increasing density of linear features, such as road networks and seismic lines.”
• In the 1997 Southern East Slopes Cumulative Effects Assessment, Michael Sawyer et. al. investigate the change in habitat for wolves over the previous century. They find that “the most notable change over time was the significant reduction of very high and high quality […] habitat, concurrent with increases in very low quality habitat.” This continues: “Most of the reduction in habitat effectiveness was attributable to adverse effects of increased linear developments such as roads.”
• For many threatened species, such as the grizzly bear, OHV trails constitute “sink” habitat – bears are attracted to the trails because they offer easy travel and because of the food found along the trails’ edges, but suffer elevated rates of mortality (noted particularly by John Boulanger and Gordon Stenhouse in The Impact of Roads on the Demography of Grizzly Bears in Alberta).

The Alberta Government’s Alberta Grizzly Bear Recovery Plan 2008-2013 recommends no more than 0.6km/km² of open routes in any grizzly bear core conservation area – which includes the entire area proposed for inclusion in the two Castle parks. (“Open routes” are defined as roads or trails that receive motorized use, and on which motorized use is not controlled for the purposes of grizzly bear conservation.) Similar recommendations on limits to the density of linear disturbance are found in recovery and management strategies for threatened fish species, such as the bull trout and westslope cutthroat trout.

Map 1: Designated westslope cutthroat trout critical habitat inside the proposed Castle parks.

Trail density in the Castle already far exceeds that recommended threshold. In Castle Area Forest Land Use Zone: Linear Disturbances, Access Densities and Grizzly Bear Habitat Security Areas, Peter Lee and Mathew Hanneman of Global Forest Watch Canada (GFWC) measured and ground-truthed the extent of linear disturbance within the Castle Special Management Area FLUZ (now PLUZ). This area is approximately co-extensive with the two Castle parks. They found that:

• The total length of linear human disturbances in the Castle area FLUZ is 1,283 km (1.3 km/km²);
• The linear disturbance density averages more than double the Grizzly Recovery Plan’s recommended threshold of 0.6 km/km² and more than triple the threshold in several watersheds and within several important grizzly bear areas; and
• The Castle Area FLUZ is not secure for grizzly bears according to thresholds for disturbances in core habitat.

Without significant reductions in the trail network, and close monitoring and enforcement of OHV activity, the mere designation of the Castle as either Provincial Park or Wildland Provincial Park does not offer sufficient meaningful protection on the ground. The elimination of logging, mineral extraction and new surface access to petroleum and natural gas commitments is a helpful step, but is not sufficient so long as the trail network remains in place. One without the other seriously limits the effectiveness of stopping the abuse.

While the GFWC study measured all linear disturbance in the Castle PLUZ (designated and not), even the designated motorized trail network as defined by the Castle Access Management Plan exceeds that threshold in much of the Castle. That designated trail network, for example, includes over 285 km in the proposed 299 km² Provincial Park. Thus the designated trail density will be 0.95 km/km² – well in excess of the scientifically recommended limits. Even in the proposed Wildland Provincial Park where the overall density is lower, the damaging effects of these trails are present. There are, for example, many specific watersheds within the Wildland Provincial Park (including the West and South Castle Rivers) where the density of the designated motorized trail network exceeds the recommended thresholds and where this occurs in the presence of federally-designated westslope cutthroat trout critical habitat (see map 2).

Concerning petroleum and natural gas commitments in the parks (both existing and new), it will be important to carefully develop a life-cycle plan regarding those developments. These plans will need to include agreements about the conclusion of operations by a certain date that will include restoration and reclamation commitments. The memorandum of understanding method used in the Hay-Zama Wildland park can serve as an excellent model for this approach.

AWA believes it is critical that the existing access management plan must not stand in the new parks. Re-examining the presence and extent of motorized recreation in the Castle as a whole and implementing the species-at-risk protection that the proposed parks are intended to provide is required. This is especially important considering that the entire proposed parks’ areas are within designated core habitat for grizzly bears and includes many streams designated as critical habitat for westslope cutthroat trout. Also directly impacted are streams that provide critical habitat for bull trout, which is already listed by the province under the Wildlife Act, recognized as threatened by COSEWIC, and currently under review for listing under SARA.

Map 2: Castle parks showing 135 km of designated motorized trail or road (in red) within 1200m of westslope cutthroat trout critical habitat streams.

The existing designated trail network outlined in the current access management plan is problematic for other reasons as well. The planning and siting for that network impacts all the westslope cutthroat trout (WSCT) critical habitat areas that are protected by law (see maps 2 and 3). The total length of this trail within the proposed park boundaries totals roughly 135 km. At least as important is the fact this network includes many uncontrolled and unbridged crossings of sensitive water bodies. The access management plan is a legal mechanism that de-facto overrides section 43 of the Alberta Public Lands Administration Regulation. That regulation would otherwise prohibit driving motorized vehicles through a water body and disturbing the habitat of provincially and federally threatened fish species, including WSCT. Further it is critical to remember that it is illegal under SARA to damage critical habitat. Trails and motorized activity in areas outside the designated critical habitat, such as hill slopes paralleling the stream outside the buffer, or upstream of the critical reaches, still cause siltation that flows downstream and becomes a threat to that habitat. Even in areas not flowing into designated WSCT critical habitat, streams still have the potential to provide good habitat for sensitive aquatic species, once properly recovered. This recovery cannot take place in the presence of ongoing motorized activity.

Map 3: Documented threats to bull trout and westslope cutthroat trout within proposed park boundaries.

In summary, motorized recreation is not compatible with ecosystem protection, let alone ecosystem restoration. This activity contributes to a negative experience for other human park visitors. The existing trail networks exert numerous documented negative pressures on the environment within the proposed parks and the trail density is far too high for the survival of threatened species. This is not an appropriate land use for either the Provincial Park or the Wildland Provincial Park in this sensitive ecosystem. For the Provincial Park, ministerial written authorization would be required to allow this land use. AWA strongly urges the Minister not to grant this exception.

Adventure Experiences

Urbanization of wilderness must be avoided. Fixed roof structures of any kind, or associated “adventure tourism experiences” are not appropriate within the Wildland Provincial Park.

Many of the types of adventure recreation development have similar impacts on the landscape and on the watershed as those documented for OHV trails. This includes, but is not restricted to, the concepts of hut-to-hut backcountry travel or via ferrata. In addition to their contribution to the urbanization of wilderness areas, a concern specific to hut-to-hut travel is that where it has been implemented elsewhere, the buildings often end up being misused, occupied for long periods of time (including an entire season), and rendered unavailable for the travellers and kinds of activity for which they were originally intended.

There may be scope in the Provincial Park for low-impact adventure tourism opportunities. They also could occur within the Castle Mountain Resort, but outside the park boundaries, where the landscape is already significantly impacted and is perhaps not a good candidate for reclamation. However, within the Wildland Provincial Park especially, these activities are not compatible with the wilderness experience that we believe most visitors would be seeking. And they are especially incompatible with the ecosystem protection and restoration that should be a hallmark of the park. Careful protection is the highest and best use of these lands, given their extremely high ecological, scientific and natural history value and cultural significance to Alberta.

Highway-side and other Retail Services

Highway-side regions inside the park boundaries are best left undeveloped and gateway community development encouraged.

There are many excellent opportunities for highway-side and other retail services (gas stations, hotels, etc.) in the hamlet of Beaver Mines and along highways 774 and 507, outside the park boundaries. These can build on existing services in the area and will be positive additions to the economy of the region. Beaver Mines and towns further afield such as Pincher Creek or the Crowsnest Pass are ideally situated to become gateway communities for the parks, and to service park visitors.

Transition Zone

For parks to be effective at providing ecological protection from impacts of industry there needs to be an effective transition zone between the areas intended to provide that protection, and those where industry is allowed to continue.

Restoration cannot occur when the impacts that caused the disturbance continue. Industrial scale activities allowed to occur immediately adjacent to the park boundary including the Shell natural gas plant, and the Southern Rockies Watershed Project (see map 4) are existing disturbances that must be reconsidered and life cycle plans implemented with buffers targeted for any new disturbance.

Map 4: Cut areas in the Southern Rockies Watershed Project immediately abutting and encroaching within the proposed Wildland Provincial Park boundary

AWA proposes that a scientifically determined transition zone be established around the park boundaries where reduced impacts are allowed to occur, in order to facilitate full protection and restoration within the park.

Enforcement

All activities and land uses in the Castle parks will need monitoring and consistent empowered enforcement.

We have often seen well-designed policies and regulations fall through on implementation or rendered moot by a lack of enforcement.

• Currently in the Castle, grazers are required to follow a Grazing Lease Stewardship Code of Practice; however, repeated documentation and concerns expressed to public lands managers about damage being caused by grazing in sensitive areas have not been addressed with changes in practices.
• Motorized and off-highway vehicles are currently prohibited from driving through or along water bodies under the Public Lands Administration Regulations; however AWA research on various sites along the Eastern Slopes has demonstrated regular and repeated violations of this principle, leading to declining population of threatened fish species and damaged riparian habitat.
• Fish species are further jeopardized by a failure to enforce habitat protection provisions of the federal Fisheries Act on the part of the Department of Fisheries and Oceans. In a forthcoming paper From ‘Badly Wrong’ to Worse: An Empirical Analysis of Canada’s New Approach to Fish Habitat Protection Laws, University of Calgary professor Martin Olszynski documents a 60 percent reduction in DFO authorization activity from 2012 to 2014, which he concludes has led to “the near-total abdication of responsibility for the protection of fish habitat by the federal government.” Where the federal government does not act to protect assets of critical value to Alberta, it is even more important for the province to intervene.

The ability of the Castle’s ecosystem to be restored hinges on strong, scientifically based management plans with appropriate implementation and enforcement. We look forward to your response and an opportunity to meet and discuss our concerns and ideas in the coming weeks.

Sincerely,

ALBERTA WILDERNESS ASSOCIATION

Sean Nichols,
Conservation Specialist

Hikers on Prairie Bluff in the Castle – an excellent activity in the planned parks. Photo credit: N. Douglas