A letter from Grant Potter to Greg Fenton
Comment by George Mercer, Owner/Author of Write Nature
The real question is who is responsible. In a self-described flat organization in which park superintendents report to Parks Canada’s CEO and he it turn reports to the Minister who reports to the PM, there are only four possible answers. And it’s very unlikely that the bottom rung on this short ladder has much say in the matter.
Comment by Kevin Van Tighem, retired superintendent of Banff National Park
Brilliant bit of policy analysis by Grant Potter. I concur with him completely and you can quote me on that.
We are on the verge of losing twenty years worth of hard and principled work by public servants to respond to broad public concern by establishing firm limits on commercial development. There is absolutely no public support or demand for these developments – they serve only the commercial interests of private companies who have access to senior politicians. The management plan consultations, despite the nearly-desperate efforts by some senior park people to smoke out the ” silent majority” who would want new attractions in the parks, found that well more than 90% of commenters want parks to be natural, nature-focused, and providing only basic support services. Not one Canadian asked for, or supported, zip lines or more hotel rooms (at least in Banff’s case). I know; I read them all. Social research done in Kananaskis Country showed that new Canadians are among the most unequivocal in their view that parks are primarily for the protection of nature. The public interest, in short, is being sold out in spite of clear messages from Canadians that they don’t want more development and diversions in their treasured national parks.
I don’t know what can save our national parks from the current political pressure to grant new commercial privileges to party donors, short of one or two high-profile Parks Canada executives committing career suicide by standing up for the public interest. It could happen, I suppose. The only other hope is widespread public outrage – but the deliberately-fostered cynicism now infecting the body politic leads pretty directly to apathy. Which is what the beneficiaries of the privatization of our national parks are likely counting on.
Grant Potter’s reply to Superintendent Greg Fenton’s letter of September 11, 2013Grant PotterBox 1877Jasper, ABT0E 1E0
September 22, 2013Greg Fenton Superintendent,Jasper National Park of CanadaBox 10Jasper, ABT0E 1E0
Re: Your Response to My September 9 Letter
I have received your response dated September 11 to my letter and found it entirely indadequate. You did not respond to the very specific points in my letter. I will boil it down to two questions for which I want a written direct answer.
1. How could you approve and issue a building permit for the Glacier Discovery Walk in contravention of the following policy direction?
a. The 1994 Parks Canada Guiding Principles and Operational Guidelines (GPOP) (4.1.3) directs that only activites that promote appreciation of a park’s purpose and objective will be considered and require a minimum of built facilities, and
b. the 2010 Jasper National Park of Canada Management Plan (JNP Management Plan) 4.7.1 – 3. directs that Brewsters will be held to the development limits in their existing land documents.
2. How can a proposal for a hotel at Maligne Lake even be considered in contravention of the following policy direction?
a. GPOP directs that preference will be given to basic visitor accommodation (4.5.1) and, camping will be the principal form of accommodation (4.5.2);
b. the JNP Management Plan 4.7.1 – 1. directs Parks Canada to follow the 2007 Redevelopment Guidelines for Outlying Commercial Accommodations and Hostels in the Mountain National Parks (OCA Guidelines) which contain the direction that no new OCAs will be considered; and
c. the JNP Management Plan 4.7.1 – 3. directs that Maligne Tours will be held to the development limits in their existing land agreements.
Please don’t patronise me by giving me the “enhancing visitor experience” line. We both know that a miniscule percentage of visitors will take advantage of either of these opportunities: the Brewster walk because it offers little the old viewpoint did not and hotel accommodation at Maligne because it will be too expensive for all but a few. For the vast majority of visitors these developments will negatively impact on their experience in the park.
Both these projects fly in the face of Parks Canada policy that has been represented to the public as Parks’ direction. To contravene these policies constitutes a breach of the public trust for which someone needs to be held accountable.
Leona Aglukkaq, Minister of the Environment
Alan Latourelle, CEO Parks Canada
Jasper Environmental Association
Superintendent Greg Fenton’s reply to Grant Potter’s letterOffice of the SuperintendentJasper National Park of CanadaBox 10Jasper, ABT0E 1E0
September 11, 2013Grant PotterBox 1877Jasper, ABT0E 1E0
Thank you for your recent and thoughtful letter regarding plans by Maligne Tours to redevelop their visitor offer at Maligne Lake to include overnight accommodations.
As you know, the Maligne Lake and the Maligne Valley are iconic symbols of the Canadian Rockies. Parks Canada is committed to maintaining ecological integrity in the Maligne Valley area, while continuing to provide opportunities for Canadians to enjoy and experience their national parks. Wilderness-based tourism plays an important role in iconic Canadian destinations, as it allows visitors to form lasting bonds to natural areas and can promote understanding and encourage respect for the natural environment.
This fall, Parks Canada will launch a public engagement process for the Maligne Valley. The process will focus on developing a more detailed action plan for the area based on commitments in the Jasper National Park Management Plan (2010)
Concurrent with Parks Canada’s planning program for the Maligne Valley, Maligne Lake Tours is preparing a draft Sustainability Tourism Strategy and conceptual redevelopment proposals for their leasehold and operations. Parks Canada is prepared to consider a redevelopment proposal from Maligne Lake Tours, on the basis of its potential contribution to enhancing visitor experience and connections with the iconic Maligne Lake landscape. It is important to note that Parks Canada has not approved any redevelopment by Maligne Lake Tours.
More information will be available in the fall from both Parks Canada and Maligne Lake Tours. There will be a range of opportunities for the public and interested Aboriginal groups to learn more and to provide their comments to both Parks Canada and to Maligne Lake Tours. If Parks Canada approves elements of Maligne Tours’ proposals at a conceptual level, the proposals would be advanced into our development review process, including the preparation of an environmental assessment and additional opportunities for public consultation. I have requested my team to add you to the distribution list in order to be notified of opportunities to participate in these public engagement processes.
Thank you again for sharing your thoughts, and for your continued interest in Jasper National Park.
Jasper National Park of Canada
A letter from Grant Potter to Greg Fenton – Superintendent of Jasper National Park
Note: Grant was Parks Canada’s Business Liaison Officer in Jasper National Park 1995-2012Grant PotterBox 1877Jasper, ABT0E 1E0September 9, 2013 Greg FentonSuperintendent,Jasper National Park of CanadaBox 10Jasper, ABT0E 1E0
Re: Parks Canada Moving Backwards
I have been dismayed for some time at the direction Parks Canada has been moving. Long-standing policies and direction have and are being changed at an alarming rate. Now, I can and must speak out.
The 1988 Management Plan contained some very specific direction and, while a lot was not achievable during the 15 year life of the plan, there were some basic directions regarding activities going on and being proposed today. The 1988 Plan directed that no new lands would be released for commercial purposes. It also directed that the Maligne Valley would be managed as a day-use area and the Maligne Canyon Hostel would be removed and the beds replaced in a hostel located in the townsite.
In the 1990’s, during a management plan review, Parks Canada bowed to pressure and allowed that the Maligne Canyon Hostel could remain.
In 1994 the policy document Parks Canada Guiding Principles and Operational Guidelines (GPOP) was released. While many might say this document is dated, it is the policy document of record and is posted on the national website. Important directions in this document are, and I paraphrase:
- only activities that promote appreciation of a park’s purpose and objective will be considered and require a minimum of built facilities (4.1.3),
- preference will be given to basic visitor accommodation (4.5.1) and,
- camping will be the principal form of accommodation (4.5.2).
Then and now, hotel rooms outnumber frontcountry campsites and hostel beds.
In 2000, the mountain park management plans were re-written to be much vaguer and I don’t feel the public consultation or Parks’ communications adequately explained to the public the impacts of the lack of direction or the vagueness of direction. Lost was the statement about not releasing new lands for commercial purposes. It did direct that Parks would follow the 1998 Redevelopment Guidelines for Outlying Commercial Accommodations and Hostels in the Mountain National Parks (OCA Guidelines), even though it really was just a committee report at the time and had not been thoroughly reviewed by Parks Canada. It did contain the direction that there would be no new outlying commercial accommodations (OCAs) and the management plan clearly stated the same direction.
The 2010 management plan review modified the direction significantly as it related to OCAs (4.7.1 point 1.). It says Parks will follow the Redevelopment Guidelines for Outlying Commercial Accommodations and Hostels in the Mountain National Parks (2007) (OCA Guidelines). This is the Parks Canada reviewed and approved final version of the 1998 OCA panel report. One of the main tenets remains the same – no new OCAs. The 2010 management plan also says in 4.7.1 point 3. that “No new land will be released for overnight commercial accommodation outside the community” This might intimate new OCAs can be considered and conflicts with the former statement in this same bullet
In the 2010 plan it says in 4.7.1 point 3.: “Work with the Fairmont Jasper Park Lodge, Maligne Tours and Brewster Transportation and Tours to ensure consistency with the development and use limits that are set out in their leasehold agreements”
Impacts, Concerns and Comments
Before I get into Brewsters and Maligne, I would like to point out some new activities which have or are being considered that either conflict with current GPOP policy or stretch the meaning/intent of that direction.
Ziplining and parasailing were considered among other activities. It is a real stretch to see how these would support the park’s purpose and objectives (GPOP 4.1.3) by providing a learning experience. Ziplining would also not fit with a “minimum of built facilities”. The Jasper review of these activities dictates no new land would be released for them. But, given the Brewsters’ precedent there will be pressure to release land for ziplining and, potentially other amusement rides.
Similarly special events are being proposed which would not be considered in the past because the activities involved really don’t require a national park setting or lend themselves to supporting the park purposes and objectives. Most are athletic events which don’t lend themselves well to learning experiences and actually pit “man against nature” rather than a communing with nature that would be more consistent with a national park experience. Most of these events, if kept small, don’t really hurt anything – they use existing facilities. However large events like Banff’s dragon boat races or triathlon jam up existing facilities to the point of excluding other visitors or degrading their experience. Happily, Banff seems to attract the huge events but it seems “improving visitor experience” is aimed at the participants without considering other visitors. Large events will be proposed for Jasper and proper policy needs to be in place.
Brewster’s Discovery Walk consists mainly of a manmade trail along the edge of an existing viewpoint and a suspended, plexiglass loop out over Sunwapta Canyon. The first part offers nothing that walking along the edge of the pre-existing viewpoint already provided. The second just offers a chance for visitors to scare themselves. If this is enhancing visitor experience, then why didn’t Parks just make the tread plexiglass at Sunwapta Falls bridge or the third bridge at Maligne Canyon. This creature flies in the face of GPOP 4.1.3: a minimum of built facilities.
It also violates management plan direction in 4.7.1, point 3. regarding complying with development and use limits in the existing lease/licence of occupation agreements. It can be argued that it is a new lease, not subject to this clause but the intent of this direction and the expectation of the public who read it are that Brewsters would be held to what they had.
The precedent of releasing land for commercial purposes ensures a constant stream of proposals.
The little change in wording from the 2000 to the 2010 management plans from “no new OCAs” to 4.7.1 point 1. “No new land will be released…” would seem to give Maligne Tours the leverage to establish a hotel that they have been seeking for 40+ years.
In 4.7.1 point 1. of the management plan there is a conflict. It directs Parks will follow the OCA Guidelines which contains the direction no new OCAs but then says no new land will be released for new OCAs. The latter would seem to give Maligne an opening if Parks is willing to forgo the OCA guidelines. However, accommodation at Maligne goes directly against the direction in 4.7.1 point 3. which directs consistency with existing development and use limits in the existing lease/licence documents. This proposal must be refused. Accepting it, not only would be in the face of existing direction, but by violating one of the main tenets the OCA Guidelines, it would undermine all of direction in that document including growth limits for the existing OCAs.
Any proposal for a hotel also violates GPOP. If accommodation is to be at Maligne, GPOP (4.5.1 and 4.5.2) dictates it should be a campground. Jasper does not need more high-priced hotel rooms. A campground is accessible to more visitors and more in keeping with a national park experience.
Maligne apparently is going to propose cabins around the Maligne Lake Chalet. Can the latter be done if, as the management plan directs, no new land would be released?
Other things to consider:
- more staff required and either a proposal to increase the number currently allowed at the lake or increased pressure on the housing shortage in town,
- the re-institution of horse rides at Maligne and a proposal to expand that offer to other trails,
- night boat cruises and,
- other activities to entertain guests such as ziplines.
I won’t get into environmental impacts or caribou as they are not my forte. But this decision must be a policy one. Do not lay it on the environmental assessment process that leads to a subjective decision as to whether impacts are sufficiently mitigated.
Parks Canada has diluted or excluded direction through the management planning process. Changing a few words here, deleting a phrase there, with the result that long standing policies have been changed significantly without the appropriate explanation to the public of the implications. It has not been a transparent process. Parks Canada has left itself open to having to review any proposal no matter how ludicrous regardless of what Canadians want in their national parks.
The new activities and projects proposed are all touted and justified by “improving visitor experience”. I cannot believe Parks Canada is really committed to this especially in light of recently laying off so many staff who were on-the-ground, directly delivering services to visitors. And, recent missives from our MP intimate more cuts are on the way.
The terms “thin edge of the wedge” and “slippery slope” have been used to describe Parks Canada’s trends in policy. I submit that releasing lands for commercial development and undermining the OCA guidelines are huge pry bars that will guarantee more and more pressure for development.
Someone once told me visitors come to national parks for what we don’t have: vendors hawking their wares on every corner and unrestricted commercial development. Let’s keep Jasper a national park, not an amusement park.
Please keep me informed of any public consultation or opportunities for input on these or other issues. My E-mail and phone info is below.
Leona Aglukkaq, Minister of the Environment
Alan Latourelle, CEO Parks Canada
Jasper Environmental Association