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Action Alert: LARP 10-Year Review

October 14, 2022

October 14, 2022

Dear valued AWA members,

I am reaching out to advise you about a public engagement opportunity to provide comments on the 10-Year Review of the Lower Athabasca Regional [Land Use] Plan (LARP). This is important because regional land-use plans (such as LARP) are developed with the intention that they will guide the direction of desired economic, environmental, and social objectives on a long-term basis in a manner that recognizes the cumulative impacts of human activities in a given region. These plans must convey a vision on the future direction of the region, and objectives that would help attain that vision.

This review is required under the Alberta Land Stewardship Act (ALSA) and intends “to assess the ongoing relevancy and effectiveness of the existing plan in supporting the long-term vision for social and environmental needs in the region.”

Survey link: https://www.alberta.ca/lower-athabasca-regional-plan-review-engagement.aspx

Alberta’s Regional Planning process (as set out in ALSA) contains a provision that allows for individuals or groups who are directly and adversely affected to request a review of a land-use plan. In 2015 a Report was published by a LARP Review Panel which was commissioned on behalf of six directly and adversely affected First Nations in the lower Athabasca Region – Athabasca Chipewyan First Nation (ACFN), Mikisew Cree First Nation (MCFN), Cold Lake First Nation (CLFN), Fort McKay First nation and Fort McKay Metis Community Association (FMFN), and Chipewyan Prairie Dene First Nation (CPDFN).

The primary findings of the 2015 LARP Review Panel Report highlighted that the cumulative effects of rapid industrial development in the lower Athabasca region were negatively impacting First Nations, and that the Government of Alberta did not adequately address the arguments put forward by First Nations, or the written evidence they provided. LARP is intended to balance the interests of all stakeholders within the region through a cumulative effects perspective, but the Review Panel Report found that the interest of First nations were not incorporated into LARP in any meaningful way. Cumulative effects of industrial development in the lower Athabasca region were found to be negatively impacting the Constitutional Rights of First Nations and their traditional land uses.

This Review Panel Report outlined three recommendations and suggested that the Government of Alberta revise LARP to incorporate these recommendations. The three recommendations were as follows:

  1. A traditional land use (TLU) management framework must be developed and included as an important component of LARP;
  2. To achieve cumulative effects management in the region – an equalization must be achieved to find a balance between industrial activities and the rights of First Nations in order for LARP to successfully attain its vision; and
  3. The province has a constitutional obligation to manage lands in a way that respects treaty rights regardless of division of powers or jurisdiction.

Alberta Wilderness Association (AWA) echoes the recommendations made by the 2015 Review Panel, and we are planning to complete the public engagement survey put out by Alberta’s Land Use Secretariat. Alongside the 2015 Review Panel Report, we are planning to highlight some of our other concerns for the lower Athabasca region which need to be incorporated into a revised LARP, which we have listed below to aid others in their attempts to complete the survey.

  • There is an urgent need to develop and implement a reclamation strategy for oil sands tailings effluent which is science-based, supported by Indigenous communities, and is paid for by oil sands corporations and not from public taxpayer money.
  • Recent evidence shows that in order to meet Canada’s global climate commitments and GHG emissions targets, we need to begin rapidly decommissioning existing fossil fuel infrastructure and put a halt to all new oil and gas projects – this means that LARP needs to be revised to ensure that economic activities in the region are diversified, that oil sands development is no longer prioritized, and that workers are supported in a just-transition into other forms of sustainable employment.
  • There has been a failure by the Government of Alberta to develop a Biodiversity Management Framework (BMF) to which the original (2012) LARP had committed, with evidence-based limits, short-term and medium-term objectives, and specific timelines and adequate enforcement to ensure Alberta meets its goals.
  • We support the implementation of new (or expansion of existing) protected areas within the lower Athabasca region, which would help to limit industrial activities in such places and thereby conserve healthy ecosystems and native biodiversity – this can include provincial parks, wildland provincial parks, or Indigenous Protected and Conserved Areas (IPCAs).
  • A revised LARP should include land disturbance limits such as those included in the February 2021 approved Moose Lake Access Management Plan (AMP) which sets a maximum limit of buffered industrial disturbance (by sector) and recognizes the edge effects to wildlife habitat which extent 50 to 200 metres beyond disturbance.
  • There needs to be an investigation into whether LARPs implementation (since 2012) has improved the prospects for species at-risk in the region, and what additional measures might be required to ensure their recovery?

The LARP survey is extremely lengthy, and we recognize that not everyone will have the time or capacity to complete any (or all) of the questions. However, we are encouraging our members and all concerned citizens to take part in the survey to at least some extent by providing feedback in support of First Nations and Alberta’s wilderness ecosystems in the lower Athabasca region. From the information available online the survey currently has no discernable end-date, but we would encourage interested parties to submit their feedback before the end of October.

Please contact AWA Conservation Specialist Phillip Meintzer with any questions or concerns about this request.

Phillip Meintzer
pmeintzer@abwild.ca

Thank you.

A healthy relationship to the wilderness is not in the least incompatible with civilized living. Indeed, I believe it to be an indispensable condition thereof; that no man is truly civilized unless he is involved in and cares for the wilderness.
- Ashley Montagu, 1969
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