Dear Minister Phillips:
I recently had an opportunity to interact with a group of people who have been on a working group regarding trails for motorized recreation in the Porcupine/Livingstone areas. I live in the area, and have a strong interest in having all land uses in the area done well. I believe you should know the feelings of at least one concerned resident.
The first impression from looking at the maps was it is a good, but not yet adequate, start. The numbers of trails that may be authorized is substantially below the current plethora of formal and informal trails.
On that last note, one of the participants pointed out an area in the north Porcupine map where off roaders simply stop beside the highway and drive their machines straight up a very steep ridge. The erosion is terrible, but that trail does not even exist on the map. It will be essential that there be explicit language in the enabling legislation/regulation that states no trail may be used unless it is specifically authorized in the Plan.
To return to the number of trails. In most areas, the number of permitted trails will still leave the amount of trail far above the levels that are necessary if sensitive wildlife are to prosper. There have been multiple reports from various bodies within and outside government detailing which species are impacted at which road/trail densities. Your Ministry should utilize the existing knowledge base to ensure that the trail density that is ultimately permitted can be supported by scientific data.
Additionally, there were maps showing the areas that are impacted by noise from even a small number of loud motors. Almost all of the Porcupine area is well within the areas that will be negatively impacted by any high noise source on those trails. The negative impacts extend far beyond the boundaries of the Crown Land that is being planned for. The potential noise levels are far above those that would be permitted in the vicinity of an industrial site. Your planning team should take those existing restrictions/guidelines into consideration when deciding what noise levels will be permitted, and where.
At the same time, they should also consult with their wildlife counterparts to understand what the impacts on wildlife may be. For example, many bird songs are much quieter than a motorcycle even a few hundred metres away. Some birds simply will not tolerate frequent loud noise, and abandon an area. There are data going back more than 50 years that show very strong negative physiologic effects on deer and such when they are exposed to noise. Those impacts are not obvious, but they might be critical for animals that are under energy stress at the end of winter or in a drought year.
Turning to specific trails, it was easy to find multiple examples of marked trails that made no sense. Many trails just appeared at the Crowsnest Municipal boundary, with no indication of how users might get to or from the indicated trail head. A plan that has no interface with the Municipality is an invitation to problems. At the other end, many trails simply stopped at the boundary of a Park or other protected area. Too many riders will not notice or respect closures of that nature, and will continue into restricted space out of ignorance or even malice. Much better to turn the trail into a circuit that does not invite boundary transgressions.
There are obvious contradictions, such as the one at the Allison site, which is designated for quiet recreation. But the small block is completely hemmed in by motorized recreation trails. Anybody trying to partake in quiet recreation is going to do so with the din of motorcycles hardly out of visual range.
A general overview showed the vast majority of trails and other activities are concentrated in the valley bottoms. In many locations, notably along Racehorse, Dutch and Oldman streams the activity is so concentrated that it constitutes a barrier to wildlife movement. Moreover, the random camping is immediately adjacent to the streams, well within the riparian zone. I suggest, again, that your planners interact with their counterparts in the Cows and Fish program. The aim of that program is specifically to exclude disruptive activities from the riparian areas which are both the most productive areas, and also those that are easiest to damage with thoughtless activities. All trails and other permitted activities should be moved back from the riparian areas as well as being above the flood zone from events like the 2013 storms.
In summary, I suggest that the plan go back for another look to minimize noise pollution, that wherever possible the reduced number of trails be relocated away from valley bottoms and streams. Random camping areas need to be outside the riparian and flood zones. Trails should not dead end at the edge of restricted areas.
There needs to be serious consideration to establishing limits on the numbers of users that are permitted. Natural areas can absorb a certain amount of disturbance, but when the limit is passed the deterioration is quick and difficult to repair. This may require that the Ministry set quotas on numbers of random campers and other users that can be permitted in an area. It may be necessary to put seasonal restrictions on some activities in some areas. If that is the case, it is important that the restrictions (whether numerical or seasonal) can not be changed without high level approval.
Additionally, it will be very important to adequately fund the enforcement of any rules. If there is no enforcement, there are no rules. This funding might well come from a user pay system. In that system, I envisage there being a fee for users in the area, with all money going to enforcement and habitat protection/reclamation. The details of what the fees should be and how they should be collected can be debated after the principal is established.
Finally, I recognize that this is an Interim Plan. However, the Province has a history of many decades in which Interim became final by default. It is important that something like that does not happen here. To prevent that, I suggest that the Interim Plan be issued with an expiry date. If there is not a Final Plan by the expiry date, all motorized activities would be prohibited away from the official roads, such as Highway 40 and accesses to the current campgrounds.
Allan Garbutt, B.Sc, M.Sc, Ph.D, LMCC, MD, CCFP. FCFP. FRRM