Honourable Shannon Phillips
Minister of Environment and Parks
208 Legislature Building
10800 – 97th Ave
January 22, 2019
Dear Minister Phillips,
Trout Unlimited Canada (TUC) is a national conservation charity that is science-based and volunteer-driven. Our work protects and enhances water quality, water flow, and community health. TUC is proud of the critical role our organization has played in the protection of Canada’s natural resources for over 40 years. TUC was pleased to learn of the provincial government’s announcement of the Bighorn Country proposal in late 2018. The Bighorn covers a large portion of the headwaters of the North Saskatchewan River which over 1 million people rely on for drinking water. The importance of source water protection cannot be understated. TUC is supportive of this proposal and its general intent, particularly with respect to protecting headwaters, watershed integrity, and biodiversity. In addition, we appreciate the value and importance of providing high quality, sustainable outdoor recreation opportunities to allow people to explore this region and connect with nature.
For decades, we have seen native trout populations and range shrinking all along the eastern slopes of the Rockies. For example, Bull Trout, which are found within Bighorn Country, are provincially listed as Threatened under Alberta’s Wildlife Act and anticipated to be listed under the federal Species at Risk Act. This should be considered a warning signal that land management has failed. After all, watershed integrity produces the elements these fish need to survive and thrive: clean, cold, complex, and connected habitat. As Alberta’s population grows, we can expect land use pressures from industrial, agricultural, and recreational impacts to increase, while the effects of climate change are expected to intensify. Effective land management which includes protected areas is essential to ensure the value of these landscapes is maintained and watersheds continue to function well into the future. Enhanced protection and management of the lands within the Bighorn is a step in the right direction towards our shared commitment of protecting and recovering Bull Trout and the landscapes that support them and all Albertans.
TUC is supportive of the protection of the Bighorn and the proper management of these public lands and waters that support fish, wildlife, and communities. This proposal is the first step and we offer the following comments for your consideration:
- West Country Public Land Use Zone: Creation of the West Country PLUZ is a significant positive step that will ensure the provincial government has the regulatory tools to more effectively manage and enforce impacts on this landscape. In 2017 and 2018, TUC and our volunteers partnered with AEP to rehabilitate 90 illegal off-highway vehicle (OHV) stream crossings along 29 km of stream at Fall Creek and Rocky Creek within the proposed PLUZ. We have seen first-handthe damage that decades of unmanaged recreation has on the landscape, damaging fish habitat and water quality. Land use and recreation management planning of the West Country is essential and must consider science-based thresholds for linear disturbance with consideration to existing and new forestry and industrial development to manage cumulative effects. Ad-hoc or unsustainable OHV trails that are not designated should be reclaimed, prioritizing trail reclamation in sensitive areas including those adjacent to waterbodies. As such, a portion of the $40 million committed to Bighorn Country should be dedicated to reclamation and enforcement to achieve positive outcomes. The PLUZ designation would also allow enforcement officers to issue specified penalties for public lands violations, avoiding the administrative delays of the current system. We believe this will help stop the damage and destruction of fish and wildlife habitat, and impacts to water quality in this region. Without a PLUZ, the investments and advances in habitat rehabilitation mentioned above, are at risk of being undone.
- Provincial Parks and Wildland Provincial Park: TUC is supportive of the creation of a Bighorn Wildland Provincial Park to conserve nature and provide recreation and tourism opportunities. However, we caution against developing too much built infrastructure and tourism facilities within the Parks, particularly the Wildland Park. The priority should be conservation and wilderness protection whereas tourism facilities may be better suited closer to or within gateway communities. We acknowledge the need for basic facilities to manage human use but these amenities must not be located in ecologically sensitive areas.
We applaud this government for taking steps toward enhanced and long term protection of the Bighorn. This is absolutely necessary to ensure conservation and wilderness values are maintained for the future of all Albertans. The details of management plans, development, and habitat rehabilitation will require thoughtful and careful consideration and consultation. We ask that the maintenance of wilderness areas be a top priority and that habitat rehabilitation and the protection and recovery of species at risk such as Bull Trout are prioritized as well.
Thank you for the opportunity to provide feedback on this important initiative. We look forward to your response.
Silvia D’Amelio, Chief Executive Officer
Trout Unlimited Canada