Backcountry Hunters and Anglers
P.O. Box 10294
Airdrie, AB
T4A 0H6

April 12, 2017

Julie MacDougall
Senior Parks Planner
Alberta Environment and Parks
Parks Division
South Region

Re: Management Plan for Castle Provincial Park and Castle Wildland Park

Dear Ms. MacDougall:

The Alberta Backcountry Hunters and Anglers welcome the opportunity to provide written
comments on the draft management plan for the newly established parks in the Castle area,
southwest of Pincher Creek. Further to our meeting with you and your team last week, we
have some specific wording changes to suggest for the management plan. Those are appended
to this letter.

The thousands of North Americans who belong to Backcountry Hunters and Anglers are united
in the belief that our freedom to hunt and fish depends on habitat. While many of us enjoy
hunting and fishing on a range of landscapes, including farm fields and reservoirs, there is
something special – even magical – about hunting deep in the backcountry or fishing on a
remote river. Wilderness hunting and fishing deliver a sense of freedom, challenge and solitude
that is increasingly threatened by the twin pressures of growing population and increasing
technology. Many treasured fish and wildlife species – such as cutthroat and bull trout, grizzly
bear, bighorn sheep and mountain goat – thrive in wilderness. Others, like elk and mule deer,
benefit from wilderness. We take the advice of Theodore Roosevelt: "Preserve large tracts of
wilderness ... for the exercise of the skill of the hunter, whether or not he is a man of means.”
As hunters and anglers who value quality habitats and wildness, we offer the following
recommendations with regard to off-highway vehicle use, facility development and roads, and
hunting and angling:

1. Off-highway Vehicle Use:

Our members strongly support the phase-out of off-highway vehicle use in the parks. In our
view this will conserve wildland habitat and help restore the kinds of high quality angling and
hunting experiences that have become increasingly rare in our province. We would support an
immediate phase-out, but if this is not practical then at a minimum we request that motorized
use be prohibited immediately on any designated trails that ford or run within 100 meters of
streams occupied by westslope cutthroat trout or bull trout. Regardless of the timing of any
park-related management decisions, the Habitat Protection Order for westslope cutthroat trout
is in effect right now, and bull trout populations are threatened right now. There is no excuse
for delay.

The decision to phase out the recreational use of OHVs will increase habitat security for species
like elk, bighorn sheep, mountain goat and grizzly bear, protect trout habitat by reducing
siltation and storm runoff spikes, and improve the quality of experience for the many
conservation-oriented anglers and hunters who prefer foot access, woods skills and fair chase
traditions over technology and speed.

Alberta’s wealth of public lands has long been the foundation of some of our finest angling and
hunting opportunities. Unfortunately, public lands in the green zone (historically, the forest
reserves) of the province have been badly impaired by intensive resource development
activities and the widespread use and abuse of OHVs. By virtue of their weight, power, width
and speed, OHVs cause vegetation damage, soil compaction, erosion, stream habitat
degradation, noise disturbance and displacement of both wildlife and other recreational land
users. The speed and range of OHVs has the effect of eliminating remoteness and quiet, both
treasured land attributes for the many hunters and anglers who value wildness and healthy
natural environments.

We note that private conservation organizations in Alberta such as the Nature Conservancy of
Canada, Alberta Conservation Association, Alberta Fish and Game Association and Ducks
Unlimited Canada already prohibit the use of motorized OHVs on their private land holdings,
specifically to prevent landscape damage and protect fish and wildlife habitats. Prohibiting
their use in the new parks is consistent with this established practice. For the same reasons, we
would support substantial reductions in the overall footprint of motorized recreation elsewhere
on Alberta’s public land, coupled with careful trail planning and enforcement to keep OHVs out
of sensitive wildlife habitats, riparian areas and wilderness-quality hunting areas.
Once OHV use has been eliminated, we believe that our members, and many other hunters and
anglers who had abandoned the Castle area because of declining fish populations, widespread
habitat damage and the loss of wilderness qualities, will at last be able to return to the Castle
parks and enjoy the kind of high quality hunting and angling experiences that used to be
available there and elsewhere along the eastern slopes of the Rockies, but have now become
rare.

2. Facility development and roads.

It is our view that the development footprint should be kept to an absolute minimum in both
parks. Parks protected for their biodiversity and watershed values, where visitors are invited to
enjoy high quality nature-based activities, cannot be improved by development – just the
opposite. We recommend that the parks’ capital budget be allocated primarily for ecosystem
restoration – for example remediating compacted soils and restoring native vegetation cover –
before spending money on new development. The sustainable and proper place for tourism
infrastructure is outside the parks in gateway communities and private land. The park should
anchor tourism businesses in the region, not house them. In taking this position we believe
that we are aligned with many others in the region adjacent to the park who have expressed
concerns that the provincial park, in particular, will be developed into something more like a
recreational resort than a natural place.

Commercial development should be minimized, or simply prohibited, in the parks to prevent
vested interests from becoming established and starting to push for mandate creep of the park
as has happened in some of Alberta’s mountain national parks in the past. The best way to
avoid Disneyfication is simply not to let it get started.

At our meeting with your team last week you asked specifically for our reaction to a request
you have had from other groups to develop a vehicle-accessible road up the South Castle valley.
We are unequivocally opposed to any new road development, especially into the Wildland
Park. With regard to the South Castle, the old road currently used for off-roader access into the
valley has an unbridged ford that is likely illegal under the Alberta Public Lands Act, the Alberta
Water Act and the Fisheries Act, as well as certainly contravening the Habitat Protection Order
for westslope cutthroat trout. This road should be closed immediately to motor vehicles at the
river and converted to a foot and horse access standard beyond it. No on-road or off-road
motorized routes should be allowed in the Wildland Park. The number of road kilometres
should be, if anything, reduced in the Provincial Park. Roads are not wildlife habitat, and roads
do not contribute to groundwater recharge and watershed protection.

We recommend that any new camping or day use areas be carefully selected so as to avoid
native grassland meadows, deciduous forests, riparian areas and other high-value habitat for
native ungulates, carnivores and fishes. In recent years, random campers have increasingly
occupied, and compromised, some of the area’s best wildlife habitat simply because it was
convenient to do so. It would be a mistake to designate those former random campsites as
formalized camping areas in the new provincial park at the expense of the wildlife and fish
whose habitat the park is meant to maintain.

3. Hunting and Angling

Please see our attached proposed wording changes for the Management Plan. We strongly
support your proposed policy to continue valuing hunting and angling as visitor activities in
both the Provincial Park and the Wildland Park. In our view these parks can and should become
showcases for traditional muscle-powered, fair-chase hunting and conservation-oriented
angling, while providing the highest quality of hunting and angling available in Alberta. Some of
our proposed wording changes are intended to change the language about hunting from what
comes across in the current draft as a sort of reluctant tolerance to wording that defines it as a
valued park experience opportunity.

Summary:

The Alberta government is to be commended for putting conservation principles, scientific
analysis and responsible land use first in their planning for the new Castle parks while also
restoring high-quality hunting and angling opportunities in the parks. Eliminating recreational
OHV use in the Castle is a solid first step toward getting our public lands right again for hunting,
angling and conservation. Minimizing the development footprint, including roads, and keeping
commercial facilities out of the parks will also help ensure that the enduring natural values of
these parks become what they are known for in the future, not our failures.
On behalf of Alberta’s Backcountry Hunters and Anglers, thank you for the opportunity to
contribute to what we believe will be an exceptional management plan for two exceptional
parks.

Yours truly,
Neil Keown
Chair, Alberta Backcountry Hunters and Anglers

cc. Peter Swain, Director, South Region Alberta Parks
Travis Sjovold, Area Manager, Alberta Parks
Brad Tucker, Partnership and Development Coordinator, Alberta Parks