LETTER RE:
Scoping Exercise - Prince Albert National Park of Canada
Park Management Plan

August 17, 2004

Prince Albert National Park
Box 100,
Waskesiu Lake, SK
S0J 2Y0

Park Management and Staff,

On behalf of the Canadian Parks and Wilderness Society - Saskatchewan Chapter (CPAWS), this letter and accompanying documents constitute our Society’s submission to the scoping exercise for Prince Albert National Park’s (PANP) new management plan (please note that accompanying documents will be sent to PANP by Canada Post).

Over the last several years, CPAWS contributed extensively to the development of the Park’s management plan. We attended public meetings, met with park staff, surveyed the public, submitted written materials on issues, participated in the PANP Management Plan Round Table, and commented (in writing) on the March 2002 Draft Plan. The issues that we identified during those activities remain important. We submit them again so that they are registered in the scoping exercise and will be addressed in the new park management plan. The issues are:

1. Establish a science-based, representative network of protected aquatic ecosystems in the park that is closed to sport fishing. The network will support Parks Canada’s mandate to protect natural ecosystems, it will serve as sanctuaries for aquatic biodiversity, and it will ensure that there are healthy control sites for scientific research.
   
2. Ensure that Kingsmere Lake is part of the network of protected aquatic ecosystems. Kingsmere Lake is an important aquatic benchmark site because of its size, shoreline characteristics and healthy flora and fauna.
   
3. Enhance protection of water bodies in the park that have native Lake Trout populations. Lake Trout are in trouble throughout Western Canada’s boreal plain eco-region making the park’s local trout populations in Kingsmere, Crean and Wassegam Lakes extremely important to preserve.
   
4. Remove man-made water control structures in the park and disallow construction of new control structures. Water control structures impact natural ecosystems. Removal of the Waskesiu River dam and construction of a new control structure on the river (the Newberry Riffle) is an ecological integrity issue that must be clearly and meaningfully addressed in the park’s management plan (see below for further comment on this issue).
   
5. Disallow construction of new motorized roads or expansion of existing roads in Zones I , II and III in the park. Roads impact natural habitats.
   
6. Clarify boundaries and re-zone areas as they are identified in the 2001 Parks Canada discussion paper on zoning. Legislate all Zone II wilderness areas in the park.
   
7. Disallow aerial spraying of pesticides in all zones within the park.
   

With regard to the Waskesiu River Dam, during a recent meeting in the park, CPAWS learned that Parks Canada is proposing to expunge the Waskesiu River dam issue(s) from the new management plan. Given the well known and well-documented impacts of man-made water-control structures on natural ecosystems, we feel that building a new control structure in a National Park is an extremely important issue and should be part of the 20-year management plan. We understand that Parks Canada is preparing to undertake an environmental impact assessment for a Newberry Riffle on the Waskesiu River.

By way of this letter we request copies of:

• the documentation that is being used by Parks Canada in support of the proposal to install the Newberry Riffle. Specifically, we would like to review the scientific information that explains how the Newberry Riffle will not impact the ecosystems and will restore and preserve natural processes (not just fish data) downstream of the control structure. We would also like to see the information that confirms the effectiveness of the riffle in addressing water level issues as raised by recreational boat users in the park. Please send hard copies of this information to our office.
  
• the Terms of Reference for the environmental impact assessment that is being developed for the Newberry Riffle on the Waskesiu River. The assessment cannot adequately address environmental impacts of the riffle if it is limited only to impacts during the construction phase of the structure or if it focuses only on areas that lie within the immediate vicinity of the riffle site. The assessment must consider the varied ecological impacts that the structure may have on upstream, downstream and surrounding park lands. A meaningful assessment must consider cumulative impacts. It must look at impacts over time by considering short and long-term environmental impact scenarios.

In closing, I thank you for the information that we have requested herein. And thank you for this opportunity to contribute to the park management plan for Prince Albert National Park. We look forward to our continued participation in the Management Plan process.

Sincerely,

Colleen Rickard

c.c. Alan Appleby, Conservation Director, CPAWS-Saskatchewan
CPAWS-SK Board of Directors
Timothy Feher, Executive Director, CPAWS-National

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