Parks Canada released a draft action plan to save Wood Buffalo National Park from being deemed an endangered world heritage site by UNESCO, but activists and Indigenous rights-holders say the plan doesn’t have enough teeth.
One of the most important recommendations – that an environmental and social impact assessment of British Columbia's Site C dam be completed – has not been included in Parks Canada's plan.
The Slave River Coalition and Smith's Landing First Nation say a decision not to assess how Site C will impact the Peace Athabasca Delta would be of major concern.
The groups also believe the plan falls short in addressing needs for consultation, trans-boundary water agreements, and legislation.
Parks Canada released the 96-page draft plan on Monday for public feedback, but details were sparse. A related news release did not specify where the action plan can be found, the channels through which the public can provide feedback, or how long the public engagement period will last.
When Cabin Radio reached out to Parks Canada for clarification and further comment, Parks responded by emailing the same news release and backgrounder a second time.
The organization's website states the three-week comment period runs from November 19 to December 10. Members of the public who would like to receive a hard copy of the action plan, or who wish to submit feedback, must email firstname.lastname@example.org.
In full: Parks Canada's draft action plan
In June, the federal government announced $27.5 million in funding over the next five years to build capacity and develop a plan to secure the future of the park’s UNESCO World Heritage Site status.
The draft of the plan was originally due to UNESCO by December 1, 2018, but in late September the deadline was pushed to February 1, 2019.
Site C concerns
"[All of the recommendations are] important, but the Site C piece is really weighted very heavily if you had to look through and prioritize those things because of the potential for further drying in the delta,” said Amy Lusk, with the Slave River Coalition, pointing to one of main issues that led the Mikisew petition in 2014.
"So issues that affect the Peace Athabasca Delta, that impact water flow through the park, are also going to impact the whole watershed of the Mackenzie Basin and the potential impacts could be felt right to the Arctic Ocean," Lusk continued.
”The Government of Canada has said that the dam will not impact the delta because it's further downstream; it's not something that needs to be assessed.
"Our position is that's not sufficient. It certainly will affect the Peace Athabasca Delta, given what we've seen from previous dams on the Peace [River],” she added, pointing to the Bennett and Peace Canyon dams, which she said have been identified as causing two-thirds of the drying of the delta.
"I don't know how [they] can say that it's justified.”
Lusk also pointed to an article published by The Narwhal – an environmental journalism website – in which Vern Ruskin, a retired BC Hydro engineer, called for an independent safety review of the project and claimed there is no precedent for a dam like Site C, built as an L-shape in shale rock.
She echoes the need for an independent review, saying engineers do not know if the Site C dam will hold.
Becky Kostka, the lands coordinator for the Smith's Landing First Nation, told Cabin Radio: "A lot of our feedback has been ... our disappointment that Canada won't stand up to something like Site C and include the park at least in the environmental assessment. They're really saying that the environmental assessment which was conducted was done well enough … That's been really disappointing."
Kostka continued: "If you look at a map of watersheds that are moving north through the Mackenzie Basin area, they all really come to a pinpoint in Smith's Landing's traditional territory.
“That's concerning not just for us, but for everyone north of 60, because all that water coming off the Peace, coming off the Athabasca, coming out of the park, is all heading north.
"What we're trying to do in Wood Buffalo National Park is, if we can successfully restore the delta and successfully start to increase flows on the Peace and on the Slave River – and ensure contamination isn't coming from the oilsands or agriculture or pulp and paper – then not only are we protecting the park, we're protecting everything north of 60, because that whole watershed comes that way."
Plan has 'no real teeth'
Kostka and Lusk say trans-boundary water agreements are missing from the action plan.
Some provinces and territories have bilateral agreements, but federally managed waters – like those running in and out of the park – are excluded.
The two groups would like to see an agreement uniting provincial, territorial, and federal partners over water management, citing the effects dams in BC are already having on Alberta waters flowing north to the territory.
"We just need to make sure that water flowing between jurisdictions is protected as best as possible,” said Kostka.
"We feel that the action plan has no real teeth..
“Obviously we're trying to give it teeth by tapping into legislation, but it's hard when you're working with multiple jurisdictions.”
She listed numerous federal, provincial, territorial, and Indigenous bodies who would ideally come to agreement on draft legislation – but are currently limited by boundaries and existing legislation.
"The pieces [of the action plan] that were left to the provinces are weak, and we want to see more work done on that," she said, citing not only legislation but parts of the plan that address the tailing ponds framework and connectivity between different protected areas.
Kostka confirmed the Smith's Landing First Nation, along with 10 other rights-holders in the park, has been consulted over the last month and already provided feedback.
While she has not yet reviewed the updated draft to see how many suggestions were incorporated, she hopes Parks Canada is making a more sincere effort even though consultation over the past few years has “been pretty rocky.”
“I do think Parks Canada is trying but, at the end of the day, they're restricted by the bigger-picture need or desire for economic development. How can we truly protect the park if something like Teck Frontier is given final approval?” Kostka asked.
Spanning a proposed 292 square kilometres, Teck Resources’ Frontier mine would be one of the largest oilsands mines in the world, reports The Narwhal – and would be located just 30 km outside Wood Buffalo National Park.
Kostka said the First Nation’s remote location, bordering the northern Alberta border, often means it is forgotten about during consultation processes, such as with the Frontier mine, other oilsands projects, and the Site C dam.
With approximately 365 members and few staff able to dedicate time to conservation, Smith’s Landing hopes to partner with Parks Canada to amplify its voice.
"We see this as an opportunity to make Parks our biggest ally in trying to protect the watershed, which has been one of our priority areas,” Kostka said.
While Kostka said consultation is a positive step – one of UNESCO’s criticisms was the “longstanding and unresolved conflicts and tensions” between Indigenous peoples and the government – Smith's Landing wishes it had been consulted and involved in park governance and conservation from the start.
“Just recently, Parks Canada has given Indigenous partners the opportunity to enter into contribution agreements which will now allow [us] to bring together a technical working group of Smith's Landing knowledge holders and some kind of technical consultant to bring the western science piece in as well," said Kostka.
"Right now, I think there's a general sense within all of the Indigenous groups that Parks Canada still is not truly representative of the Indigenous groups, and we want to have more of a say and more representation."
Over the remaining two weeks, said Lusk, her community has a chance to see what’s in the plan and provide feedback.
The Slave River Coalition requested Parks Canada hold a community open house but the organization declined, citing lack of time to gather the necessary provincial, territorial, and federal representatives to attend the meeting; and saying Parks Canada would prefer to speak to groups rather than individuals.
But as Lusk points out, “They knew eventually they'd have a community feedback period.”
In response, the coalition held its own open house every day during the first week of the public engagement period to help people understand the action plan, raise awareness of the engagement period, and invite people to add their names to a feedback letter the group is drafting.
"When we're talking about the 'outstanding universal value' of this place, it's not just for local people or people in the watershed, it's really saying that globally this place is significant," said Lusk.
"It's right up there with the Great Barrier Reef or pyramids as they also share this UNESCO designation and they're really supposed to be viewed as treasures for the world.
“The fact that [Wood Buffalo National Park] is one of the world's largest freshwater inland deltas and a hugely important place for migrating birds – it's something people across Canada should be concerned with.
"It would be terribly embarrassing for Canada to lose our UNESCO World Heritage Site status."