AWA Letter: Jasper Icefields Trail (North)
April 7, 2017
April 7, 2017
Hon. Catherine McKenna
Minister of Environment and Climate Change Canada
House of Commons, Parliament Buildings
Ottawa, ON K1A 0A6
RE: Jasper Icefields Trail (North)
Dear Minister McKenna:
Thank you for the opportunity for Alberta Wilderness Association (AWA) to provide input on the Icefields Trail (North) during both the Let’s Talk Parks Canada Roundtable and the March 16 Icefields Trail consultation in Calgary.
AWA, founded in 1965, works throughout Alberta towards more representative and connected protection of the unique and vital landscapes that are the source of our clean water, clean air and wildlife habitat. With over 7,000 members and supporters in Alberta and across Canada, AWA remains committed to ensuring protection of wildlife and wild places in Alberta for all Canadians.
AWA believes the Jasper Icefields Trail (North) project as currently proposed is incompatible with ecological integrity in Jasper National Park. AWA is respectfully requesting that your ministry carefully re-evaluate the merit of this project, given the substantial investment it would require. We recommend these funds be allocated to other projects that will restore and maintain ecological integrity while providing opportunities for outstanding interpretive services by Parks Canada staff.
Commitment to Uphold Ecological Integrity
On March 10, 2017, you presented a speech at the Canadian Parks Conference in Banff, stating:
“I want to make sure that protecting ecological integrity is front and centre in every decision I make about our national parks.” We also note that your Mandate letter states: “We have committed to an open, honest government that is accountable to Canadians, lives up to the highest ethical standards, and applies the utmost care and prudence in the handling of public funds.”
AWA believes the Icefields Trail is neither protective of ecological integrity nor applying the utmost care and prudence in handling public funds. AWA urges you to uphold your commitments to ecological integrity.
Public involvement and process
We believe the statement that “the concept for the project is also part of the management plans for both Jasper National Park Management Plan (2010) and Banff National Park Management Plan (2010)” is a misleading assertion. The most applicable direction in the Jasper Management Plan reads, on page 116, “Review the needs of cyclists and develop options. Explore options to enhance opportunities.” Has a review of cyclists’ needs been undertaken? If so, AWA requests that review be publicly available and if the review has not been completed, AWA believes a needs assessment for cyclists, including statistics on cyclist injuries and current and projected statistics on cyclist use, type of cycling, and purpose of cycling in Jasper National Park, must be completed prior to any further advancement of this project. As well, AWA would like to receive a copy of any socio-economic study that has been done regarding this project.
We are greatly concerned that the concept for the trail seems to be in direct contradiction to some of the key directions of the Jasper Management Plan (2010). See Appendix 1 for an outline of actions and provisions in that Management Plan that AWA believes are in direct contradiction to the Icefields Trail (North) proposal.
AWA was taken by surprise when this project was announced in the media in May 2016. We wondered how a $66 million project that had undergone no public consultation would be credible. AWA was further surprised in January 2017 to see another $20.5 million contributed to the project, for a total of $87 million. Now, in March 2017, freedom of information documents reported by the Canadian Press reveal that the total project cost was estimated at $170 million as early as August 2016. Such a major expenditure of public funds should require public awareness and approval long before the funds are allocated. During the consultation in Calgary, the presenter stated that the project is in a very early stage, however, the vast majority of data collection needed for the Detailed Impact Assessment (DIA) had already been completed, using significant tax-payer dollars before any public consultation was held. While AWA commends the federal government for finally including public consultations as part of the decision-making process, we remain skeptical that the process is truly reflective of what Canadians want to see in this National Park.
The Report of the Standing Committee on Environment and Sustainable Development released March 2017, Taking Action Today: Establishing Protected Areas for Canada’s Future, notes, “despite repeated questions to numerous witnesses, the Committee was unable to determine what process led up to the announcement in Budget 2016 of a $65.9 million investment for a new biking and walking trail in Jasper National Park. More transparency in decision making is required.” [emphasis added] AWA expects that the directions in your mandate letter – “We have also committed to set a higher bar for openness and transparency in government” and “We have committed to a responsible, transparent fiscal plan for challenging economic times” [emphasis added] – will be implemented, and provide the necessary openness, transparency and fiscal responsibility required of this proposal.
Of major concern is the intrusion of this project into the endangered Brazeau mountain caribou range. The proposal indicates winter use may be allowed and this is concerning, as the Brazeau herd, already reduced to only a dozen individuals, are known to pass through the Icefields Parkway in winter. These caribou need much more stringent protection within a National Park than the plan appears to recognize. A major focus on habitat protection and strict access management for caribou is not apparent in the proposal documents and AWA believes the project has the potential to directly undermine caribou protection.
Parks Canada is required by law under the federal Species at Risk Act to recover southern mountain caribou through conservation strategies. The proposed trail does not contribute to – and likely inhibits – fulfillment of the 2014 recovery goals for southern mountain caribou to “achieve self-sustaining populations in all population units within their current distribution” and “stop the decline in both size and distribution of all population units.” The 2014 recovery strategy states that the threat of unnaturally high predation rates as a result of human-caused and natural habitat loss, degradation, and fragmentation can be mitigated “through coordinated land and/or resource planning, and habitat restoration and management…” [emphasis added].
AWA believes a “world-class” recreational trail is certainly not necessary and if built will cause unnecessary disturbance to this endangered species that Parks Canada has responsibility to protect.
The project proposes to intrude into Zone II Wilderness, intended to “be maintained in a wilderness state” and reclassify those areas as Zone IV Outdoor Recreation. Incrementally changing the zoning of Declared Wilderness is against the purpose of the zoning and adds cumulative disturbance effects to the landscape. The extent of the new disturbance will also require removal of critical valley bottom habitat for bears and caribou, and create a new linear feature that further fragments Declared Wilderness. Our National Park must maintain areas that are Declared Wilderness. Despite much of the project being within the Parkway right-of-way, it is well known that a variety of wildlife do use habitat right to the pavement.
Human and wildlife safety
AWA has serious concerns about human and wildlife safety. In particular, we believe bear-human interaction and bear habituation to humans will result if this trail is built. The current proposal indicates that the trail will be on average 20-30m from the existing road. This means that there will be a vegetated buffer 20-30m in between the Parkway and the Trail. What does Parks Canada predict bear behavior to be when a bear is ‘trapped’ between the Parkway and the Trail? Cyclists have no vehicles to use as protection. From a visitor and wildlife safety perspective, this appears to be a disaster in waiting. “Mitigating” this impact by removing buffalo berries is a preposterous notion, as Jasper National Park is known for its viable bear population and abundant bear habitat and food. Indeed, the Parks Canada website reads, “…the continued existence of the grizzly depends upon the preservation of large areas of undisturbed wilderness.”
Inappropriate use of funds
The current federal government intends to allow Heritage Resources Conservation program spending to fall to 13.8 per cent of total spending in 2019/20 from 23.4 per cent in 2011/2012. In Parks Canada’s 2016-17 Report on Plans and Priorities, spending on National Park Conservation will drop from $92.3 million in 2016-17 to $88.9 million in 2018-19, while expenditures on Visitor Experience total $320.8 million in 2016-17 and $322.9 in 2018-19. Visitor Experience spending is over three times as much as Conservation. AWA believes the $87 million allocated to this project from Parks Canada’s already inadequate conservation and education budget is an inappropriate use of funds.
The Jasper National Park Management Plan (2010) states, “Parks Canada does not have the resources to maintain the park’s extensive network of trails and facilities.”Crumbling backcountry infrastructure in Jasper has been described by the Jasper Fitzhugh as “appalling.” Parks Canada should not proceed with massive infrastructure projects when current infrastructure does not have adequate resources to be maintained.
Opaque use of funds
AWA believes the true future costs have not been clearly communicated to the public. We assume the project is intended to continue from the “end of trail” at Wilcox Campground at the Jasper-Banff border through to connect with the Legacy Trail in Banff. However, the addition of another approximately 180km trail from the Jasper-Banff border to the Banff townsite has not been clearly articulated by Parks Canada, thereby leaving the public to wonder about the actual total cost of this project. The true cost of the project would be the cost for the entire length of trail from Jasper to Banff plus the cost of ongoing maintenance and repair; these estimated future costs must be communicated clearly to the public.
On June and July 2016, AWA and five other organizations called for the federal government to immediately stop this proposal, and asked for the funds to be reallocated to invest in wildlife conservation and monitoring programs. AWA is again requesting that cheaper, more ecologically-friendly alternatives be proposed for the Icefields Trail (North), including the option of refusal. For example, has Parks Canada assessed how much it would cost to repair and widen the shoulder of the Icefields Parkway to accommodate road cyclists?
Impact of construction
The project is extensive at 109km, and as noted previously AWA expects an extra 180km to Banff will be proposed in the future. Not only are the site impacts during construction a concern, but the sourcing of sand/gravel and construction materials for the trail also adds to its environmental impacts. For example, floodplain gravel mining is not prohibited in Alberta and Parks Canada should not trigger further river corridor degradation from its aggregate sourcing practices. AWA has raised concerns about the impact of this industry on water quality in Alberta [Refer to AWA Background Document: https://albertawilderness.ca/wp-content/uploads/2016/05/20160517_bg_awa_gravel_mining-1.pdf].
AWA respectfully requests that this project be denied and we further urge you to commit to the priorities set out in Canada’s National Parks Act and to fully comply with the Parks’ Management Plans.
Thank you for considering our input on the Icefields Trail proposal. We look forward to your response.
ALBERTA WILDERNESS ASSOCIATION
Andrea Johancsik, Conservation Specialist
Salman Rasheed, Acting Jasper National Park Superintendent: Jasper.Superintendent@pc.gc.ca
Dave McDonough, Banff National Park Superintendent: Banff.Superintendent@pc.gc.ca
Wayne Stetski, NDP National Parks Critic: Wayne.Stetski@parl.gc.ca
Robert Sopuck, Conservative National Parks Critic: Robert.Sopuck@parl.gc.ca
Jim Eglinski, MP Yellowhead: Jim.Eglinski@parl.gc.ca