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A Summary of Public Comments on the Brewster’s Proposed Glacier Discovery Walk in Jasper National Park and Parks Canada’s Response

February 16, 2012


In 2010, Brewster Travel Canada (Brewster) approached Parks Canada with a proposal to develop a new visitor attraction at the Sunwapta Canyon viewpoint along the Icefields Parkway. Parks Canada reviewed the proposal and determined that it was consistent with the Agency’s legislation and policies, and could advance to the environmental assessment and development review processes.
Parks Canada determined early on that an environmental assessment would be required at the screening level under the Canadian Environmental Assessment Act (CEAA) for Brewster’s project. Under the CEAA, a range of actions can be taken to engage the public in an environmental assessment, from providing information to actively soliciting comments.

Public participation can strengthen the quality and credibility of an environmental assessment; the public is an important source of local and traditional knowledge about a project’s location and likely environmental effects. Public participation also informs decision-making by helping Parks Canada to understand the range of public concerns related to a project, including concerns not directly related to environmental matters.

Parks Canada was also interested in the views of Aboriginal communities with documented historic connections to the park and sought to engage those communities in identifying interests in the proposal and providing feedback on the environmental assessment.

Public Participation Process

Parks Canada directed Brewster to engage stakeholders, Aboriginal communities and the public early in the environmental assessment process—to raise awareness of the proposal and obtain feedback on the concept and design in support of the environmental assessment. Brewster held five open houses, provided a website, phone line and email address for more information, and met with organizations and Aboriginal communities.

Canadians provided feedback through letters, e-mails to Parks Canada, websites, Facebook pages, blogs, on-line petitions, postcards and articles and letters in local, regional and national media outlets.

A total of 4,474 written submissions were received by the Superintendent of Jasper National Park between January, 1st, 2010 and February 6, 2012. During the three-week formal public comment period on the environmental assessment from November 23 to December 16, 2011, 2116 submissions were received.

Comments came from across the country and internationally; from individuals and organizations. Some comments were detailed and technical; others were a simple postcard submission, or a name on a petition. In some submissions it was clear that the authors misunderstood, or were misinformed about the project. Although the majority of comments came from individuals, some were submitted from organizations with hundreds of members.

Although the majority of comments reflected a lack of support for the proposal, numbers for or against were not the only factor that Parks Canada considered when evaluating public response. All comments were taken into account when making the determination, but in the end, the consultation process is not a plebiscite. Parks Canada considered the validity, scope and new information presented relevant to the assessment. The following pages summarize the public comment received on the proposal and Parks Canada’s response.

Aboriginal Engagement

Initially, some Aboriginal groups expressed concern about the location and nature of the project and the consultation process. Discussion at the Jasper Aboriginal Forum focused on access to the site, interpretation of Aboriginal stories, and potential traditional use of the area by Aboriginal peoples.

Subsequent site visits with Elders from communities that expressed an interest in the project either confirmed that there were no concerns with the project or that no follow-up was required. Several communities were interested in pursuing economic opportunities.

Summary of Public Comments and Parks Canada’s Response

The major themes from the submissions fell into the following categories:
1. Policy
2. Visitor experience
3. Project justification and need
4. Environmental effects
5. Public participation process

1. Policy

What we heard:
Most respondents opposed the ‘principle’ of the project and felt that this kind of new commercial development does not belong in a national park. Concerns were raised about the privatization of land within the national park, and the precedent for further development in Jasper National Park and other parks.

In contrast, some respondents pointed to the proposed Glacier Discovery Walk as meeting one of Parks Canada’s objectives to enhance visitor experience and strengthen the connection to Jasper National Park while balancing protection. Additionally, some felt the area of policy relative to visitor appreciation and enjoyment had been neglected in the past and welcomed the proposal to innovate in this area.

Parks Canada’s response
The proposal is consistent with the Icefields Parkway Strategy, and respects the approved management plans for both Banff and Jasper national parks. Jasper’s management plan sets out specific limits to commercial growth and development, and provides direction to enhance visitor experience while ensuring ecological integrity is maintained or restored. The proposal is acceptable under existing land use zoning for the park, and will not intrude into the 97% of park lands managed as wilderness. Brewster will use an existing underutilized viewpoint; no additional development such as new staff accommodation, transportation nodes, or maintenance facilities, is required.

Parks Canada allows private operators to deliver services and programs that help visitors appreciate, understand and enjoy the park. Visitors have the option to access services from business providers, and have been doing so in the mountain national parks for 126 years.

2. Visitor experience

What we heard
Supporters of the proposal saw this as a unique and new visitor experience within Jasper National Park. They felt the proposal would create a unique, barrier-free, opportunity with appeal for a broad section of visitors; educational opportunities that will entice visitors out of their vehicles; and could result in enhancements to traffic safety and congestion for all visitors.
Concerns included limited access to the viewpoint, the negative impacts of increased traffic, congestion and parking pressures at Tangle Falls, and the visual impacts on the natural view.

Parks Canada’s response
Parks Canada believes that the proposed new walkway will ultimately improve the visitor experience of the area. There are two other public viewpoints in the immediate area (Stutfield Glacier and Tangle Falls), and more than 20 other viewpoints along the parkway for visitors to enjoy on their own. Free public access at this viewpoint will still exist, albeit in a modified form.

Brewster will be responsible for conducting a traffic safety study along the entire length of Tangle Hill and or implementing actions to address safety issues.

An Interpretation Plan for the Glacier Discovery Walk, improvements to the Stutfield Glacier and Tangle Falls viewpoint; an area shuttle bus service; roving wildlife guardian interpretive program and upgrades to the Icefields Centre are planned to improve the visitor opportunities in the area.

3. Project Justification and Need

What we heard
Concerns in this category included a weak rationale and lack of social science to support the project. Respondents felt there are already ample visitor opportunities in the area, including better views. Some supporters cited the popularity and longevity of current attractions and the need to provide safe, accessible frontcountry experiences for those not able nor willing to travel on their own or in the backcountry.

Parks Canada’s response
Parks Canada seeks to offer experiences for different types of visitors who want to interact with nature in many different ways. Recent park survey results show that more than 90% of visitors come to the park for sightseeing and prefer a comfortable view from the edge, without venturing far from the road.

Parks Canada believes the proposal will improve visitor experiences in the area and offer a unique, barrier-free opportunity not currently available. Additionally, the project responds to the needs and priorities of the tourism sector to provide renewed sustainable visitor opportunities.

4. Environmental impacts

What we heard
Many people were concerned that the project’s long-term impact on wildlife cannot be predicted with confidence, due to a lack of data. Respondents most frequently cited mountain goats and sheep as species of concern. Questions were raised about mountain goat use of the project area and the impacts to local and park-wide goat population. People were concerned that increased traffic and people on the site will disrupt goats and sheep and that the construction may have a greater effect on goats, sheep and other wildlife than predicted in the environmental assessment. The impacts of construction and operations on wolverine, bears, other carnivores and raptors were also raised.

Other adverse environmental effects of concern included slope stability, the effect of a proposed trail connecting Tangle Falls parking lot and the GDW site, increased emissions associated with new bus traffic, increased litter and noise, the impact of road salt on area watercourses, and the cumulative effects of the project.

Some respondents supporting the proposal pointed to the minimal environmental impact of building infrastructure on a previously disturbed site, and using existing infrastructure at the Icefield Centre. Some noted that the impact to wildlife will be negligible and short term.

Respondents fear that the structure will detract from the natural beauty of the area. Although there may be no visual impact from some locations adjacent to the highway, there may be impacts from other locations.

Parks Canada’s response
Brewster will be required to invest in specific mitigations to address environmental impacts identified through the EA process. The impacts on wildlife and future needs for additional scientific knowledge will be addressed through careful mitigation and a follow-up monitoring program. For example, the walkway will be designed to minimize disturbance to animals on the cliffs below; construction will not occur during kidding or lambing season; and the hours of operation will be shortened to provide for early and late day animal movement. A monitoring program during construction and operations will assess and adapt all activities at the site to ensure that impacts on wildlife are minimized and populations remain secure.

Mitigations related to public access, traffic safety and increased visitor numbers at the site will include upgrading nearby viewpoints. A free shuttle bus to transport visitors to other opportunities in the area will provide alternatives for visitors not wishing to pay for access and could reduce traffic congestion, increase public safety and reduce carbon emissions.

5. Public participation process

What we heard
Many respondents commented that the public review period for such a large environmental assessment and complex project was too short. Other comments included concerns about transparency, given that Brewster conducted a significant share of the public participation program for its proposal and its consultant was responsible for preparing the environmental assessment report.

Parks Canada’s response
The public information and involvement activities aimed at engaging the general public and aboriginal communities began early on in the process. Information about the project—public open houses, website information, an e-mail and toll free information line, and regular e-mail updates—was available for close to a year before the formal environmental assessment public consultation period.
More information concerning the results of stakeholder meetings and open houses hosted by Brewster and correspondence with Brewster can be obtained in the Glacier Discovery Walk Project Consultation and Aboriginal Engagement Report (October 28, 2011).

The project description was posted on the Canadian Environmental Assessment Internet Registry and the environmental assessment screening was available on the Brewster website, through Parks Canada and the Brewster Office in Banff. As per the CEAA, and as a standard practice, Parks Canada (as the Regulatory Authority), may delegate the preparation of the environmental assessment to the proponent; however Parks Canada reviews the assessment and makes a determination regarding the significance of adverse environmental effects.


Overall, the Aboriginal engagement and public information and involvement process was robust, transparent, timely and national in scope. It demonstrated a significant passion and interest in Canada’s national parks and protected areas.
The largest number of comments received and the central public debate in the petitions and media against the proposal related primarily to the interpretation of Parks Canada Agency policy and appropriateness. While these comments were well meaning, caring and passionate, they were philosophically in opposition to the interpretation of policy and the determination of appropriateness by the Parks Canada Agency.
To address the concerns related to environmental and social effects (and visitor experience), the project environmental assessment screening report describes prescriptive undertakings for Brewster to mitigate adverse effects and to implement related follow up programs. Parks Canada has identified “desired end results” to guide mitigation and provide additional direction on the intended outcomes. The process and the nature of the concerns have helped to shape, clarify and justify the desired end results.
The analysis of public comment has concluded that there was no nature of concern or new information presented that would prevent the proposal from moving forward.