AWA Letter RE: Updated Castle Parks Management Plan

April 19, 2017

Premier of Alberta
Honorable Rachel Notley
Email: premier@gov.ab.ca
Minister of Alberta Environment and Parks
The Honorable Shannon Phillips
Email: aep.minister@gov.ab.ca

RE: Updated Castle Parks Management Plan

Dear Premier Notley and Minister Phillips:

We would like to thank you for your prompt response on our submission regarding the Castle Provincial Park and Castle Wildland Provincial Park Draft Management Plan. As your letter indicates, the Alberta Government has made a number of substantive changes to the draft management plan on March 1. The following letter is an addition to our March 9^th submission and primarily surrounds the suggested changes to the management plan made on March 1.

Alberta Wilderness Association (AWA) is concerned with many of the proposed revisions to the draft plan, because most of the revisions propose increasing access, use and development with the parks. AWA believes these promises, made without any comprehensive reviews or studies may place competing land uses as a priority over the primary conservation and protection purposes of the park. We firmly believe that any land uses should be carefully reviewed to ensure they are consistent with the primary conservation, protection, and restoration goals for the parks. Only if these land uses are consistent with a wilderness in need of restoration should they be permitted within the Castle Parks.
Grazing

AWA is supportive of reviewing grazing and range management practices to ensure they are managed in a manner that prioritizes conservation and are consistent with protected areas. We reiterate that the establishment of the Castle Parks provides an opportunity to rectify past management practices for cattle grazing and to restrain the invasion of non-native species.

AWA has concerns with the proposed changes in the draft plan to have a dedicated Rangeland Agrologist as the only responsible authority on grazing management within the Castle Parks. While it may be appropriate for Rangeland Agrologists to be the primary point of contact for daily operations, we do not necessarily believe that it is appropriate for them to be solely responsible for the assessment, allocation, and permitting of sustainable forage use within each grazing allotment. AWA suggests that it is more appropriate for the Government of Alberta to be responsible for appointing Agrologists to perform routine assessments of allotment holders. Additionally, the assessment, allocation and permitting of sustainable forage use should be completed in consultation with plant biologists and parks staff to ensure that parks values and the array of native plant communities and species at risk are being sustainably managed and adequately protected. Currently, the focus of assessments and allocations currently revolves around the state of the land from a purely grazing perspective; environmental considerations such as the state of vegetation not used for grazing, the protection of rare or at risk species, or the state of water courses are not considered. This focus on only grazing issues can be counter to the conservation intent of protected areas.

AWA has voiced concerns for many years that the sole focus of grazing management in the foothills of the Eastern Slopes appears to be the provision of grazing to allotment holders. AWA does not oppose cattle grazing on public lands, however a more holistic approach where due attention is also paid to environmental and wildlife concerns is required. Within parks, where the primary purpose is protection, conservation and restoration must be at the forefront of all management decisions.

New Park Facilities and Infrastructure

Provide accessible infrastructure to facilitate experiences for all park users (67) *NEW*
Ensure access to the Castle Parks from the north (Crowsnest Pass) and from the east (Beaver Mines and Pincher Creek) (67) *NEW*
Maintain key road access into the Castle Parks along the Adanac and Sartoris Roads *NEW*
Explore opportunities to develop access for persons with limited mobility, including the elderly, to reach select back country locations in Castle Provincial Parks, using trails or roads specified for that purpose

AWA is concerned with many of the proposed increases in access, use and development with the parks. Promises made without any comprehensive reviews or studies, may place competing land uses as a priority over the primary conservation and protection purposes of the park. AWA is supportive of providing wilderness experiences for persons with limited mobility; however, the cumulative effects of all land uses must be considered and any excessive road building or use of off-highway vehicles is inappropriate. The Oldman Watershed Council estimates that the existing road network in the Castle Provincial Park has an overall density of approximately 0.47 km/km²– this figure is significantly high and only considers the existing road network; it does not take into consideration the additional human footprint of any future development in the parks (including camping), allowing motorized access for trappers, and the new proposal to allow for motorized retrieval of game. AWA requests that at minimum, a review be conducted to determine the amount of linear disturbance within the Castle Parks including the current proposed level of infrastructure within the parks. We believe that linear disturbance thresholds (Objective 2.2.1) should be developed taking into consideration the need for restoring this landscape and the species at risk that reside within these parks. This will require more stringent restrictions on use and development within riparian areas and rare plant and wildlife areas such as grasslands.

Maintaining key road access into the Castle Parks from both the Adanac and Sartoris roads is redundant and may actually be counter to the conservation outcomes of the parks. The environmental impacts of the Sartoris road should be reviewed and seriously considered for decommission, as this gravel road parallels westslope cutthroat trout critical habitat in Lynx Creek for considerable portions and the road crosses many of its tributaries. The runoff and erosion from this road is contributing sediment to this stretch of critical habitat. We believe that keeping this road open may cause further declines in this population and will likely prevent its recovery. We respectfully request that that the Precautionary Principle is used and a comprehensive review is undertaken before the approval of any roads within the Castle Parks.

Hunting

Collaborate with fish and wildlife associated groups to determine best practices and develop guidelines to allow for limited use of Off Highway Vehicles for the purposes of game retrieval (99) *NEW*

As outlined in our earlier submission, AWA has outstanding concerns with permitting hunting in the Castle Provincial Park, but we support hunting within the Wildland Provincial Park as a compatible use. The science is clear that that the use of off-highway vehicles is not compatible with the conservation objectives of these parks, and we do not support the use of off-highway vehicles within these parks for game retrieval. Keeping motorized trails open explicitly for this use will not alleviate the soil compaction problems that the trails themselves cause and will not allow the parks to act as a wildlife refuge if motorized access in the backcountry is permitted. Additionally, there has been no scientific review conducted to determine what the linear density within the Castle Parks will be when these trails are left open. AWA believes that more traditional forms of game retrieval (by horsepack) are a more compatible use with parks values. This will have the additional benefit of supporting local outfitters and guides in the area.

Recreational OHV Use

The following points were removed from this version of the plan:

Recreational OHV use south of Highway 774 will be discontinued effective immediately
Prior to the beginning of the second year of the transition period, OHV use will be discontinued on all remaining trails within Castle Wildland Provincial Park, and on those trails within Castle Provincial Park that are determined to have high ecological value

As we stressed in our previous submission, winter use of off-highway vehicles also causes negative impacts on the environment, primarily on overwintering ungulate populations, and we do not believe that they are a compatible use within the Castle Parks. AWA supports the decision to remove OHVs from the Castle Parks, but we are disappointed in the ongoing delay, the decision to continue OHV use for up to five years in the area, and the removal of key actions in the short term. We believe that delaying OHV trail closures may prevent building a positive and loyal visitor base for many years, therefore delaying economic benefits to adjacent communities. We understand the phase out of off-highway vehicles has been proposed in order to allow time for the government to identify more suitable areas and to determine appropriate sites to allow OHV use on other public lands. This work by the government could be completed in much less time than the currently proposed 3-5 year window and AWA believes is not sufficient reasoning to delay sound decision making for our parks. We respectfully reiterate our support for an immediate ban of OHVs in the Castle Parks. At minimum, immediate trail closures are required for the most sensitive areas in need of restoration and trails likely to affect westslope cutthroat trout critical habitat and key bull trout spawning areas. At a minimum, we support suggestions made by other groups to immediately close all motorized trails within 100m of native trout streams – this would necessarily include the Sartoris Road and any other roads currently being considered.

Camping

A compatible activity we would request you consider is the provision of front country walk-in tenting opportunities and tent-only camping areas within the Provincial Park.

To conclude, motorized use and access in the Castle is counter to the wilderness experience that most Albertans are seeking. Many Albertans are seeking low-impact recreational opportunities and are looking forward to returning to this magnificent wilderness that they have been unable to enjoy for years. The Castle management plan must reflect the need of this landscape to restore so that Albertans may enjoy truly protected wilderness.

Thank you for your consideration of these additional comments.

Yours truly,

ALBERTA WILDERNESS ASSOCIATION

Joanna Skrajny, Conservation Specialist

cc:
Senior Parks Planner
Alberta Environment and Parks
ABParks.PlanComments@gov.ab.ca