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Politics

Banff-Bow Valley Study

This section of the analysis will examine in more detail the impact of the spiritual or ideological dimension of the wilderness preservation, or restoration movement, on the policy agenda of Parks Canada. Following the 1990 incorporation of Banff as a town under the laws of Alberta, the gulf between environmentalists and those favouring community development grew wider and deeper. Formal incorporation transferred some municipal powers from the federal bureaucracy to an elected Town Council. The federal government, however, retained final authority on planning, land use, development, and environmental issues. With the triennial general assembly of the International Union for the Conservation of Nature—the World Conservation Union—scheduled to meet in Montreal in October 1996, environmental groups took the opportunity to bring their arguments about a "development crisis" in Banff before an international audience and the international media. Complaisant journalists responded to the alarming allegations of environmentalists with headlines more alarming still: Banff might be removed from a list of "World Heritage Sites." There was next to no explanation of the genesis of this list nor what, if anything, de-listing might entail. It was, in fact, symbolic politics at its very best: large headlines, deep anxieties, no substance. The result, however, was that the federal Heritage Minister launched the two year, $2.4 million Banff-Bow Valley Study.¹³⁵

The Banff-Bow Valley Study was run by a federally appointed, five-member task force commissioned to examine the state of the Banff-Bow Valley and provide recommendations for a revised management approach. The geographic area of study was 3,504 kilometres (53 percent of the total area of Banff National Park) of the park's Bow River watershed from the headwaters near Bow Lake to the East Gate of the park. Its conclusions would establish benchmarks for the future interpretation of the mandate of Parks Canada, and of regulations governing land use in the park. A great deal of emphasis was placed on stakeholder/public participation in the study. Fourteen interest sectors were represented at the initial round table: national environment; local environment; municipal government; federal government; Siksika First Nations and Wesley First Nations; park users; infrastructure/transportation; social/health/education; commercial outdoor recreation; commercial visitor services; tourism/marketing; culture/heritage; and the Banff Bow Valley Study Task Force itself.¹³⁶

Despite the apparent effort to involve all stakeholders throughout the round table process, many participants objected to being limited to discussing broad strategic goals, rather than interpreting the results of any technical studies. These studies included a historical analysis, management framework review, visitor behaviour research project, ecological and tourism outlook projects, and a study on appropriate activities for the park. Among these technical studies, the ecological outlook project stands out as having produced both the raw data, and predictive models that informed the bottom-line conclusion of BBVS Task Force. In keeping with the origin of the entire exercise, they were appropriately alarming: "if we continue along our present road, Banff cannot remain a national park."¹³⁷ A close analysis of the argument, assumptions, concepts, and data that led up to this conclusion, however, casts doubt on its reasonableness.

We have already indicated the questionable scientific assumptions employed in the creation of predictive models. They were, nevertheless, a major element in the creation of the Ecological Outlook Project (EOP), used to "evaluate the cumulative environmental effect of the forces at work in the Banff-Bow Valley and to predict how current behaviour, trends and decisions will shape its future."¹³⁸ The other major component of the EOP was the Futures Outlook Project (FOP), designed to provide an analysis, model, and prediction of human geographical impact. The FOP used specially customized computer software to simulate several future scenarios for land use and development. In any such modelling process, however, the assumptions of the simulation model underwrite its results.

The problem is indicated clearly enough with an examination of the procedures used to model future numbers of visitors to the park. A number of different rates of increase were used, from -0.5 to 6.0 percent, but only the high-end estimators appeared in the Summary Report and only they were reflected in the final conclusions to the efforts of the Task Force. One again, the rhetoric was alarming: "Past trends of human influence in the Valley cannot be sustained if ecological integrity is to be maintained in the park."¹³⁹ The mean increase in the rate of visitation was 5.46 percent. Using this rate compounded to 2020, a whopping 19 million visitors were expected. Using a 3 percent rate, estimates were for 10 million visitors by that time.

The actual numbers of visitors to the park since the time of the study tell a different story (figure 2). An increase in attendance in 1994-95, from 4.3 million to almost 4.9 million, was followed by a steady decrease: from 4,892,551 person visits in 1994-95 to 4,257,218 person visits in 1998-99—a cumulative drop of almost one percent. If one discounts the anomolous surge in attendance in 1994-95, the drop amounts to over 13 percent. The discrepancy between the rhetoric of crisis and less dramatic fluctuations in the number of visitors both illustrates the need for caution when interpreting data generated by computer models, particularly when they amount to little more than linear estimations, and indicates how otherwise competent statisticians can allow their "biases," as Steve Herrero called them, to overwhelm their scientific integrity.

The scope and depth of the Banff-Bow Valley Study was unprecedented. Notwithstanding the efforts made by the Task Force to include a wide variety of interests, at the end of the day, the study's conclusions reflected the growing orthodoxy of conservation biology. The BBVS had no independent research arm but relied on outside and "independent" work by client groups such as the Eastern Slopes Grizzly Bear Project (ESGBP), or the Central Rockies Wolf Project (CRWP). Accordingly, the data and, in general, the scientific discourse generated from these sources became the primary source of data and analysis; it was openly acknowledged by the Task Force, however, that major data gaps existed concerning the human use and economic activity in the area. The gaps related to trend data, to information on visitor activities, and to statistically valid information on the use of backcountry facilities.¹⁴⁰ Former Task Force member Brent Ritchie (Professor of Tourism Management at the University of Calgary), noted that the perspective on park use supplied by tourism and tourist services was underrepresented in terms of the database, and the research and analysis of what data was there was itself inadequate and out-of-date.¹⁴¹ In contrast, the environmentalists had mobilized an impressive network of organizational, scientific, and financial resources prior to the study, along with a large number of sympathetic wildlife biologists, all of whom were focused on the effort to rewrite parks policy. Their success is eloquent testimony to the organizational strength of the environmental movement that, by forming alliances within a sympathetic scientific community, was able to turn a discussion on land management and use decisions into a mandate for reducing and phasing out human use and economic development from the park. It meant, as well, that the interests of the tourist industry as well as commercial and transportation interests were left to react to an already established agenda with considerable momentum behind it.

Panel on Outlying Commercial Accommodation

Following the release of the BBVS, the Task Force's recommendations for centralized ecological management were given considerable publicity as well as political currency. Environmental groups claimed their views had been (once again) vindicated by science. Many voices called upon the Heritage Minister to act quickly and end "Disneyfication" of Banff. She responded with a development moratorium, announcing that no new land would be available for commercial development in Banff. Once again, tensions between Banff council and Ottawa heightened as the federal government established strict new guidelines for park management and a community plan for the townsite.

Four months after the one-year development moratorium was announced, the Heritage Minister established a five-member Panel to review the redevelopment guidelines for outlying commercial accommodations (OCAs), and the draft ski area guidelines that had been tabled for discussion by Parks Canada and ski area operators. The ski area operators—Banff Mount Norquay, Marmot Basin in Jasper, Skiing Louise and Sunshine Village—all participated. The collaborative drafting of the guidelines was intended to provide direction for future planning and operation of the ski areas located within the mountain parks. This "work in progress," was designed to provide a basis for discussion between the various stakeholders. Once again, the round table format was adopted in an effort to involve a wide range of interested stakeholders. Individual consultations were also held prior to the public workshops. Even though a wide range of interests were involved in the drafting of operational guidelines for the management of their businesses, the ecological assumptions built into the BBVS set the parameters for discussion. The consequence was that a reasonable compromise, let alone a meeting of minds, proved impossible to achieve.

Individuals representing environmental groups were unanimous in rejecting the draft guidelines in their entirety. Ben Gadd of the Alberta Wilderness Association (AWA), for example, considered downhill skiing to be entirely inappropriate for parks. His recommendation: "When a ski-area's lease runs out, shut the things down, yank the equipment, raze the buildings and reclaim the access road." He argued that caps on the number of skiers and moratoria on further developments and improvements would have the positive effect of making the ski areas less attractive to skiers, less profitable, and thus easier to close. His hard-headed understanding of ski hill economics was coupled to the striking rhetoric of cliché. Downhill skiing, he said, is "the crack cocaine of recreational economics: dirty, damaging and addictive as hell."¹⁴² Jill Seaton of the Jasper Environmental Association (JEA) summarized her perspective on park use with the observation that it is "totally out of keeping with the philosophy of a national park to manipulate the elements by means of technology."¹⁴³ This view, if it means anything intelligible at all, if implemented, would presumably shut down a lot more activities than downhill skiing. Even the Canadian Parks and Wilderness Society (CPAWS), which claims to represent a moderate view in conservation policy, suggested that "there are precedents for removing ski-hills and restoring these lands to their full potential as wildlife habitat."¹⁴⁴ About the only difference between CPAWS and the AWA or the JEA is the sophistication of their rhetoric. Scientific discourse at least looks intelligible beside the unfocused opinions of technophobes.

One of the many paradoxes of ideological or spiritual opposition to the dual mandate of the parks is that the activities that the environmental movement most derides appear to cause the least damage on a per visitor basis.¹⁴⁵ Once again, as with so many other questions, the issue becomes one of interpretation. The Heritage Minister had established apparently clear parameters within which recommendations were to be made: development guidelines for both OCAs and ski hills were to follow the principles of "appropriate use," clear limits to development, management practices reflecting their location within a national park, and "no net negative impact." Nobody denies the need for controlled development in Banff; and certainly no businessperson would be running commercial operations in or around the park without fully recognizing the sensitivities of their environment. But whose criteria will determine "appropriateness?" And is "net negative impact" to be determined on purely biological grounds, or is there room for cost-benefit analysis that accounts for other social and economic interests as well? While the objective of the OCA Panel was to let commercial operators and the public be heard in an open and effective manner, the federal government did not release the report until over a year after its completion. The government then announced that the findings of the report would be interpreted in context of the report of the concurrent Panel on Ecological Integrity. When the rhetorical sledgehammer of "ecological integrity" is capable of overwhelming its practical application, commercial activities continue to be deemed inappropriate and human use and enjoyment of the park becomes further restricted.

Ecological Integrity Panel

The extended review of Canada's park policy, which began with the Banff-Bow Valley Study in 1994, culminated on March 23, 2000, with the release of the report of the Panel on Ecological Integrity. Appointed in 1998, the eleven-member panel had been mandated to review the management and organization of the entire national park system. If the BBVS had recommended a new management philosophy for Banff, the EI Panel advocated a new environmental paradigm for Parks Canada as a whole. This essentially became a task of organizational design, as the Panel debated how to "heal" the bureaucratic agency responsible for overseeing Canada's national parks.¹⁴⁶

This conclusion, reiterated throughout the Panel's 127 recommendations, raises questions concerning the relative influence of competing interests over the course of the 16 months of consultation in 9 national parks and 9 cities. Since interested individuals were invited on the basis of their perceived ability to contribute to the ecological integrity mandate of the Panel, a review of the participants reveals just whose contributions were perceived valuable. In order to determine the relative influence of various interest sectors, a database was compiled listing all the workshop participants as supplied by Parks Canada.¹⁴⁷ Three of the 11 Panel members were affiliated with an environmental group (CPAWS);¹⁴⁸ five others were experts in environmental science and wildlife management. Of the workshop participants, over 19 percent were affiliated with environmental groups, over 27 percent represented parks and protected areas, and 9 percent were in the environmental science sector. In contrast, less than 6 percent of the participants were from either the industry or tourism sectors (figure 3).

The overall conclusions of the panel clearly reflect the different levels of influence the several sectors had in the policy review process. The main themes of the preservationist and restorationist approach to the environment, analyzed above in the "Ideology" and "Policy" sections of this Public Policy Source, echo throughout the report. The recommended upgrade of the "science" capacity of Parks Canada is estimated to cost $28 million per year in additional funding.¹⁴⁹ The purposes to be served by vastly increasing the production of scientific discourse by Parks Canada are clear enough. Given the apparently regrettable fact that "the ecological function and the ecological ethic are compartmentalized within the organization, effecting in a sense a 'green ceiling,'" one series of recommendations calls for the transformation of the new Parks Canada Agency into an advocacy organization.¹⁵⁰ Here the "social animation" programs of the 1970s and 1980s analyzed by Pal would no doubt form the models to be emulated.

The language used to describe the organization and operation of Parks Canada also had to be cleaned up. Indeed, a kind of Orwellian semantic overhaul was recommended because "the adoption of business language within Parks Canada (terms such as 'CEO,' 'clients,' 'business plans,' 'revenue')... clashes with the values of a conservation-based organization and symbolizes the importance of the revenue and development themes."¹⁵¹ On the other hand, the EI Panel was very concerned that the term "ecological integrity" was not used often enough in proposed action plans. We have seen, however, that EI is scientifically ambiguous. Nevertheless, extensive monitoring of the use of this highly symbolic but substantively empty term was called for. There must be "a content analysis of each park's interpretation program… to measure the degree to which ecological integrity is being communicated."¹⁵² Expenditures designed to produce more scientific discourse or to measure the number of times empty terms such as "Ecological Integrity" appear in Parks Canada pamphlets, other publications, and in the daily language of management, is some distance removed from the common sense purposes most Canadians understand to be the responsibility of Parks Canada. The endpoint of this bizarre bureaucratic initiative will come when the production of scientific discourse reaches the point that Canadians will be enjoined from enjoying the parks and wilderness they are paying so much to protect.

Parks Canada Agency

By the time the EI Panel reported, the Parks Canada Agency Act (Bill C-29) had turned the national parks service into an independent agency with greater human resources and financial flexibility. Responsible for overseeing Canada's 39 national parks and 3 marine conservation areas, the agency's budget for 1999-2000 was $388 million, $75 million of which came from internal revenues, the rest from taxpayers. The Agency currently employs approximately 5,000 employees, of whom more than a third are seasonal. While most operate outside the National Capital Region, they are still responsible to the CEO, and ultimately, the Minister of Canadian Heritage, both of whom operate from Ottawa.

The creation of a new Parks Canada Agency rests on the conviction that strategic reorganization can be a way of meeting specific policy problems.¹⁵³ The use of organizational design as a policy instrument was especially prevalent in the 1970s, for purposes of horizontal policy coordination (in areas such as transportation, science and technology, regional and economic development, and social development), but can also combine regional and coordinative responsibilities to attack specific policy problems.¹⁵⁴ For example, the Atlantic Canada Opportunities Agency (ACOA) in 1987 was an administrative reorganization of an existing complex of programs, agencies, and boards that, by intent at least, would deal with regional economic disparities in Canada. The point of such exercises is not to deliver on the promise held out by reorganization (and ACOA was as great a failure as other government programs directed at Atlantic Canada, for largely the same reasons),¹⁵⁵ but to build a specific set of assumptions into the mandate and policy agenda of the "new" agency. Accordingly, by turning the national parks service into a separate corporate entity, a new set of fundamental assumptions could be written into the bureaucratic structure of Parks Canada itself, with the consequence that thereafter anyone doing business with the new organization would, and could, do so only on the basis of the new and hereafter unquestioned assumptions. The experience of the OCA Panel, the findings of which were based on the EI assumptions of the BBVS, is a preview of things to come.

When the Act passed, CPAWS executives Gordon Nelson and Mary Granskou described their hopes for its effect, remarking that "CPAWS and others want to be a partner in guiding the direction of the entire national park system—dealing with systemic issues, instead of being consulted only on individual parks."¹⁵⁶ This new human resource potential was duly noted in the EI Report, which pointed to the approaching retirement of approximately 60 percent of the Parks Canada staff as an opportunity to improve the ideological compatibility of the Agency's work force.¹⁵⁷ In June, CPAWS executive director Mary Granskou was appointed to a senior national parks policy role. CPAWS' Melissa Slatkoff was given a federal appointment in August. CPAWS trustee and former EI Panel member Stephanie Cairns has recently been appointed to the ecological integrity advisory committee, as was the Canadian Nature Federation's Kevin McNamee. This is CPAWS "partnership" in action.

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Last Modified: August 23, 2000.