Jasper Environmental Association
Box 2198, Jasper, AB T0E 1E0
October 29, 2014
Re: Draft Discussion Paper on the Maligne Valley Implementation Strategy
We thank you for the opportunity to comment on the Draft Maligne Valley Implementation Strategy Discussion Paper.
The JEA understands the aim of this Discussion Paper is the improvement of visitor experience, protection of the endangered woodland caribou and increased habitat security for the grizzly bear.
We note that, according to Parks Canada’s own survey, visitors already seem well satisfied with their visits to the valley. However, some improvements such as additional Animal Guardians, updated interpretive panels and more picnic tables and toilets would be welcome.
The JEA has some concerns about the following proposals:
- P5 Providing new short walks or hikes.
- The Maligne Valley is narrow with several pinch points but serves as an important seasonal wildlife corridor between the alpine and montane ecoregions. Has Parks Canada enough data on wildlife movement to provide new walks and hikes in the vicinity of the road that would not adversely affect the animals or increase the danger of human/wildlife encounters?
- It seems unwise to spend money on the boat launch area at the north end of Medicine Lake if it is going to be wiped out by the fairly regular flooding in that corner of the lake.
- Could brushing along the road have the effect of making the area more attractive to bears and create additional bear jams?
- P6 If you are going to ‘involve commercial operators’ public input should be allowed on each separate operation
- There is some reference to ‘behind the scenes’ tours. Could we please have more information on this idea?
- Dark Sky Programs. These should not be organized at Maligne Lake. Night-time traffic must not be encouraged on that road.
The Jasper National Park Management Plan 3.2.1 acknowledges that two of the most important ecological challenges facing the park are the status of woodland caribou and the regional grizzly bear
If Parks Canada is truly committed to preserving these two iconic species then their protection must be given a higher priority than ‘visitor experience’ which already seems to be satisfactory according the Park surveys.
- P9 “Developing some new opportunities in areas outside of caribou habitat…” what is ‘outside’ caribou habitat in the Maligne Valley when you are talking of re-introducing caribou to augment the remnants of the Maligne herd? For example, the area at the north end of Medicine Lake was definitely caribou habitat 12 years ago.
- P10 “The future of woodland caribou is the most pressing resource conservation issue in the Maligne Valley”…“Parks Canada now has a legal obligation to implement critical habitat protection”(Discussion Paper) “Losing even one caribou out of the Maligne herd could be critical to their long-term persistence”(Situation Analysis). Strong words … but there still appears to be no planned trail closures for the 2014-2015 winter in the Maligne area even though the Situation Analysis points out that the area between the Watchtower and Hardisty Pass is important habitat for the remnant herd and that “continued recreational use of a number of areas, such as Bald Hills and Jeffery Creek provides wolves with an unnatural advantage in accessing caribou habitat…” Presumably this should mean closing all trails in the Jeffrey Creek, Evelyn Creek and Trapper Creek drainages. It should also mean closing the Maligne road.
- P12 “intact habitat” for introduced population of caribou must be “intact”. Parks should not be whittling away bits of it to placate local recreationists.
- P11 Parks recognizes that displacement and habituation are the main threats to grizzly bears in the Maligne Valley but then points out that at busy times during the summer, “bears can use high quality habitat at quieter times of the year and in more remote areas of the valley.” It is hard to know what is meant by “quieter times of the year” as bears usually hibernate from November to late April. Research has also shown that bears habitually use valley bottoms as travel corridors and if this is the location of the best food supply this is where they will look for it.
- We are assured on p13 that “Several actions are proposed to improve the situation for grizzly bears, by lessening displacement of bears from important habitats, making wildlife movements through pinch points easier and reducing habituation and the risk of surprise encounters between bears and people.”
- P13 Actions to adjust trails and wilderness campgrounds, placing permanent bear warnings on the Opal Hills and removing obsolete facilities from pinch points are good first steps. However, the Skyline Trail could pose a problem for bears if the growing September/October shoulder season attracts more than 100 users per month – the threshold beyond which research has shown grizzlies are adversely affected. This is an important time for them for digging out ground-squirrels and locating den sites.
- P17 Parks Canada will “explore ways to make human activity more predictable for bears in and around the Maligne Day Use Area.”
There are encouraging statements here that may lead readers to believe that definite steps will be taken to give these hard-pressed species the protection they deserve in a national park. That is, until we come to the final pages of the document when we are faced with the proposal by Maligne Tours for overnight commercial accommodation.
If Maligne Tours is allowed to construct tent cabins in a pinch point at the north end of Maligne Lake it will effectively negate all Parks Canada’s proposals to improve grizzly habitat security and movement corridors and adversely affect future attempts to protect intact habitat for re-introduced caribou. It will also adversely affect the thousands of day-use visitors who travel to this iconic lake for a once-in-a-lifetime experience.
Parks Canada assures us it will “(W)ork with Maligne Tours to update their visitor facilities and operations at Maligne Lake, while ensuring all facilities, activities and services are consistent with Parks Canada’s legislative and policy framework, meet objectives or criteria set out in the management plan….” But they are not “consistent with Parks Canada’s legislative and policy framework” and do not “meet the objectives or criteria set out in the management plan”.
The management plan is the result of many years of research and months of public input. It is accepted by the Minister and tabled in Parliament. To amend it to satisfy the demands of a business interest could devalue the whole concept of management plans throughout the national parks system. Presumably the ‘wildlife-themed children’s maze’ will require another licence-of-occupation, resulting in Maligne Tours taking up a large part of the north shore of the lake. Incidentally the open area south of the boathouse that has been referenced as possibly being the location for this ‘maze’ is an important feeding and rutting area for moose.
For many years Parks Canada has stressed the importance of the environmental assessment as a determining factor in whether projects will be approved or not. An environmental assessment, paid for by the proponent, inevitably ensures it cannot be objective and, as far as we can ascertain, has never stopped any project yet. An environmental assessment virtually oils the way for development and at best leads to minor mitigations many of which should already have been carried out by any conscientious business operating in a national park. It is time for Parks Canada to stop citing the environmental assessment as being a defining element in the decision-making process.
Original signed by
Jill Seaton (Chair)
Jasper Environmental Association