Honorable Jason Nixon
Minister of Environment and Parks
208 Legislature Building, 10800 – 97 Avenue, Edmonton, AB
T5K 2B6

May 10, 2021

Dear Minister Nixon,

I am writing on behalf of the membership of Alberta Backcountry Hunters and Anglers (ABHA) regarding the announcement of a fee schedule for Kananaskis Parks.

We recognize that the increased activity in the Kananaskis Provincial Parks, crown lands and Public Land Use Zones (PLUZ)’s has been substantial since the beginning of the pandemic. People are looking for ways to spend time together safely and our parks and public lands offer incredible opportunities to support health and well-being. Many of our members spend time in the Kananaskis and also noticed the increased volume of visitors. We are aware of the extra impact visitation will have on the natural environment including fish and wildlife populations, movements, and human encounters; trail erosion; infrastructure maintenance; and park enforcement.

As a conservation organization, we care deeply about access to and the sustainability of these unique areas. We understand that a fee for use program can be part of a comprehensive management plan that supports these priorities, and we are in favour of carefully developed conservation management plans that use a regional approach where cumulative impacts are measured from all activities on the landscape.

We are concerned that the fee schedule has specifically excluded the McLean Creek Public Land Use Zone (PLUZ), an area known for high amounts of OHV use, despite the high environmental impacts felt in the area. McLean Creek is also home to Silvester Creek, one of the few remaining pure strain westslope cutthroat trout populations in the province, and is susceptible to habitat degradation. While we understand that McLean Creek may be covered under the Trails Act, which has not been introduced as of May 2021, we believe the disproportionate impact of OHV use in this PLUZ warrants the inclusion of this PLUZ into the fee schedule, until the Trails Act is passed.  This will avoid the scenario of stacking fees, while still achieving the conservation goals of the Kananaskis management plan.

ABHA is also curious how enforcement of the two recent fee announcements will be reconciled. The resources necessary to enforce a fee in Kananaskis are relatively low compared to the vast efforts necessary to enforce the recently announced public land camping fee given the difference of area and the impacts of random camping on public lands. This approach, thus, seems to inequitably distribute the fees among users based on their impacts (i.e., random camping in PLUZ vs. day-hikes on established trails).

ABHA members would appreciate a commitment, similar to the one that was made for the Public Lands Camping pass, as proposed in Bill 64, that any fees instituted for accessing Kananaskis parks are distributed to targeted conservation efforts, infrastructure maintenance, and conservation enforcement necessary to sustain the area. We would like to be certain there is a comprehensive plan beyond user fees to manage park usage, garbage collection, highway safety, reduction of human-animal conflicts, and similar impacts caused by increased use. We ask that you provide us with a better understanding of what other management strategies will be used to ensure the sustainability of the area including the proposed fee schedule for McLean Creek and other neighbouring areas, given they are adjacent to Kananaskis and, therefore, part of the same ecosystem.

Finally, we are concerned regarding access to Albertans and Indigenous populations who may already be systemically disadvantaged by these fees. We ask that you clarify how the fee exemptions will be determined to ensure there are no unnecessary barriers for Albertans to enjoy Kananaskis as it is such an important part of the culture of this province; an element that was fought hard for by Peter Lougheed and his colleagues, who wanted to ensure access for all Albertans in perpetuity.

Thank you for your consideration.  We look forward to continuing to develop a productive relationship with your office for the betterment of our wild lands and waters and their inhabitants for the enjoyment of all Albertans.

Thank you for your consideration, and I look forward to your response.

Sincerely,

Neil Keown
Chair
Alberta Backcountry Hunters & Anglers