Ghost Position Paper V4

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Ghost Position Paper V4 Powered By Docstoc
					                                                                                    September 30, 2005
Mr. Craig Quintilio
Assistant Deputy Minister
Public Lands and Forest Division
Alberta Sustainable Resource Development

Dear Mr. Quintilio

RE: Draft Ghost-Waiparous Operational Access Plan (“the Plan”)

The climbing and soft impact recreational user communities are surprised and dismayed by the
unprecedented access restrictions that have been proposed as part of the Plan. We are of the
opinion that these restrictions are excessive, premature, unwarranted and will likely add very little in
terms of addressing the identified issues.

We are very concerned about the methodology used to substantiate the extent of the problems to be
addressed by the Plan. We also found the consultative process to be frustrating and at times,
seemingly driven by the desire to justify pre-determined outcomes. The apparent lack of empirical
baseline data is very disturbing and really calls into the question the validity of the command and
control provisions of the Plan.

We recommend:
       - immediate implementation of the Monitoring components of the Plan. We suggest that
         this work focus both on the general question of the sustainability of the Forest Reserve
         ecosystem, and also on the specific locales that are perceived to be high priority
         problem areas. This detailed work will then provide the badly needed baseline data
         which must form the justification for any access restrictions.
       - the Enforcement priorities of the Plan focus on the already available authority of law
         provided by the criminal code and the Public Lands Act and the Forests Act. It is our
         opinion that an increased „uniformed‟ presence in the form of „Forest Rangers‟ would
         mitigate many of the issues. It seems to us to be premature to create a Forest Land
         Use Zone or to add any new layer of laws, regulations or restrictions until sufficient
         resources have been allocated to enforce the existing law.

We strongly recommend that:
       - any further work on the draft trail map be suspended until the results of the Monitoring
           work is complete. The current draft map is clearly the „cart going before the horse‟.
       - any future drafts of the map be based solely on a comprehensive analysis and
           quantification of the problems as well as an assessment of the effects of any proposed

Please accept this letter as a request to meet with you as soon as possible to review our
recommendations and your responses to the specific areas where we require clarification as outlined
in our attached position paper. We are particularly interested in your views on the establishment of
Responsible User Zones (RUZ) to acknowledge areas of little risk because of the precedents set
by historical usage.

If you have any questions please contact Bill Marriott (403 239 2516) as he is coordinating our

Yours sincerely,

William D. Marriott
The Ghost Climbers Coalition

cc Mr. Rick Blackwood
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                                     1
September 30, 2005

The signatories below endorse the positions expressed in this paper on behalf of their
organizations. The combined membership lists in the Ghost Climbers Coalition contain
nearly 10,000 people.

Cameron Roe                                                   Eric Hoogstraten
President, Alpine Club of Canada                              President, Calgary Mountain Club

Sandy Walker                                                  Jon Jones
Chair, Calgary Section,                                       President, TABVAR
Alpine Club of Canada                                         The Association of Bow Valley Rock Climbers

Allan Derbyshire
Program Director,
Ecotourism and Outdoor Leadership
Mount Royal College

Karl Klassen
Executive Director,
Association of Canadian Mountain Guides

The Ghost Climbers Coalition
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                          2
September 30, 2005

Who are we?

The signatories to this document represent outdoor recreation organizations whose primary
purpose is to facilitate the meeting of their members to participate in backcountry trips (see
a description of the individual groups contained in the appendix). These trips include hiking,
backpacking, scrambling, mountaineering, rock climbing, and ice climbing. We have come
together because it appears our concerns with aspects of the Plan have been ignored
despite our being identified as one of the largest cohort of users in the area. We believe
that we speak on behalf of all back-country hikers and climbers in the Calgary region.

The individual members of our organizations are all very avid outdoor enthusiasts but come
from varied professional and employment backgrounds. This includes professionals
working in public policy analysis and development, government relations consulting, public
opinion surveys, environmental impact assessment, lawyers, and biologists to name but a
few. As a group we have serious concerns over:
     the loose definition of the issues
     the inadequate quantification of specific problems
     the absence of baseline data on which to set priorities
     the consultative process heavily dependent on opinion rather than fact
     the unsupported „command and control‟ solutions

Even though our members do not participate heavily in recreational ATV or motorcycle use,
the above is actually a very broad based concern affecting all user groups. However, our
sole use of the roads and vehicle trails is to obtain access to the areas where we engage in
our primary recreational pursuits and as such, we are limiting our comments only to those
areas where we have a direct stake in maintaining unencumbered access.

Our most important characteristic is derived from our actual experience in the areas. We
have been users of these areas for decades covering literally thousands of trips. So
collectively, by virtue of our intimate and extensive use, and our professional and academic
backgrounds, we are expert witnesses to observe the extent of the declared issues in those

Finally, all the members of these clubs or associations have traditionally adhered to the
concept of Wilderness Code of Ethics which holds minimum impact as one of its highest
values. As well, many of these organizations provide educational opportunities to their
members to provide extensive safety training in order to minimize the human risks of our
recreational activities.

Where do we play?

The peaks, valleys and cliffs accessible in a few hours from a substantial road constitute
the areas where we pursue our activities. In the Plan area this is primarily at the end of the
Trans Alta road beyond the „big hill‟ in an area that we call the Ghost, and along the upper
reaches of the Waiparous Creek road which we call Waiparous. These areas offer some of
the finest rock climbing and back-country hiking in the Rockies. The Ghost also contains a
high concentration of some of the finest ice climbing routes in the Rockies and is world
renowned because of this. Nearly 100 ice routes are readily accessible in a 1-2 hour hike

The Ghost Climbers Coalition
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                            3
September 30, 2005

from the end of the roads. The importance of this area to climbing enthusiasts and the
tourist revenue that is generated by visiting climbers should not be underestimated.

What do we want?

In order that we may pursue our activities unencumbered by largely unenforceable and
unjustified restrictions we request that the government establish a Responsible Users
Zone. We request that this area, described below, be excluded from the Plan area. In
keeping with existing and traditional climber and hiker usage this would mean that there
would be no new restrictions on vehicular traffic nor would there be any new restrictions on
random camping in this area; the status quo would be preserved

Further, we request that any and all future access reviews that may be undertaken by any
Alberta governmental agency, including the Stewardship Monitoring Group, exclude the
proposed Responsible Users Zone.

We propose that the entire area (“the RUZ area) encompassed in the 3 Townships 26, 27,
28 in Range 9 be designated a Responsible Users Zone.

Why do we want it?

The reasons for our request are outlined below and are based on our long term empirical
observations in the RUZ area:

    1. Usage in the area is very low. We estimate that no more that 40 vehicles access
       this area on any summer weekend. In winter these numbers drop to less than 5.
       This constitutes less than 1% of all the users visiting the Plan area. Further,
       although climbing is becoming a more popular sport we do not anticipate that this
       usage level will even double in the next 20 years. This extremely low level of current
       and anticipated usage dictates that access restrictions are not required.

    2. The majority of users are zero impact. We estimate that 80% of the users in the
       RUZ area are engaged in hiking or climbing and only 20% are ATV users. Hiking
       and climbing users drive their vehicles to a staging area where they park until it is
       time to go home. These users engage in no recreational driving in the area.
       Further, hiking and climbing activities have zero impact on the environment.

    3. Virtually all users stay on existing roads. It is our experience that virtually all
       users, including ATV users, stay on the established roads and trails. Over the past
       twenty years there have been no new trails created by ATV users in RUZ area and
       driving in open areas is virtually unheard of.

    4. Virtually all camping is in specific areas. It is our experience that virtually all
       camping is done by climbers and is restricted to specific areas that give ready
       access to the climbing crags and ice.

    5. Campsites are kept free of garbage. All of the campsites are very clean and all
       users pack out their garbage. Climbers recognize the risks in abusing these areas
       so we routinely check the sites for trash and if we find it we remove it. Since

The Ghost Climbers Coalition
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                                4
September 30, 2005

        climbers and other responsible users are present most weekends the sites utilized
        by us have always left very clean.

    6. All climber frequented campsites show virtually no signs of human waste.
       For years on our club sponsored events we have adhered to a policy that requires
       the collection and removal of any human waste. As you are aware, the ACC
       Calgary Section has at its own expense established an outhouse at the bottom of
       the big hill. The location of this outhouse is well known and it is utilized by all types
       of users in the Ghost area.

    7. In our assessment there has been insignificant user instigated environmental
       damage. It is our observation that environmental damage has remained at a
       constant and static level for several decades and that no eco-system or riparian
       area of environmental significance has been adversely affected. In fact, in the
       Ghost, it has been observed that many plant species have repopulated areas that
       were laid bare at the time of the river diversion.

    8. It is our view that safety issues are non existent. Climbers are constantly
       assessing risks and utilizing various systems and procedures to minimize personal
       risk as we engage in our recreational activities. The same goes for driving to and
       from the climbs. Since we are not driving for recreation we take great care to avoid
       situations where vehicles could become immovable.

    9. There are no user conflicts in the RUV area. This arises largely from the small
       number of users in the area. But also our experience is that all users are very
       friendly with each other and respect the rights that each of us have to be in this
       area. It far more common to find all users lending a „helping hand‟ to get a vehicle
       going or assist if there is some other problem.

    10. All of this happens without regulation. Why does the Plan propose almost
        punitive restrictions and regulations to seemingly force us to do what we are already
        doing out of a heightened sense of awareness and demonstrated responsibility?

We assert that the vast majority of users who frequent the RUZ area are „responsible users‟
as defined by the vision for users in the Draft Plan. We are already users who respect the
environment therefore we are self policing and thus do not need the additional threat of
laws and fines to re-shape our behavior. We are already exceeding the standard that
government is attempting to impose through additional regulation. Consequently, we
conclude that any legal restrictions are unnecessary and at a baser level almost offensive.

As we have indicated these observations and conclusions differ from the Department‟s
view. If there is valid scientific and demonstrable evidence to counter the above we have
yet to see it.

What do we need?

In order to obtain the Department‟s perspective on the issues we need additional
information that we have been unable to find in the documents released thus far. We have
structured our information requests as an observation followed by a specific question. We
have tried to be as definitive as possible so we would appreciate an answer in writing for
each question. We understand that we could make this request under the FOIP Act in

The Ghost Climbers Coalition
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                             5
September 30, 2005

order to access the Department‟s information but in a spirit of cooperation we hope that this
step will not be necessary. We will use the word „document‟ to refer to any written material
be it a study, a paper, a picture, a monograph, an essay, a memo in any medium that the
department may have used in the development of the Plan. If the information requested
does exist in a document we would appreciate a paper and/or an electronic copy of the
document for our review.

The Plan makes reference to two key documents, the 1999 Municipal District of Bighorn‟s
Forest Reserve Multi-User Dialogue Report (FRMUD) and the 1988 Ghost River Sub-
Regional Integrated Resource Plan (IRP), as giving legitimacy and direction for the
planning process. We respectfully submit that all the concerns, recommendations and
guidelines of these documents should be honored, not merely the ones used to justify the
actions in the Plan. In particular:

Scientific Information
The preface to the FRMUD report calls for “informed decision making based on leading-
edge information” (p.4) and advises that any management plan must “rely on good
science”(p.5). Further it warns that FRMUD itself “is not so much a scientific research
project as it is a tool of information gathering to foster dialogue” (p.9). The Plan Terms of
Reference states that “Scientific information … will be carefully considered in the
development of the plan.” (p.1) We have been unable to find a single scientific paper
confirming or analyzing the stated issues. We are hoping this work has been done.

Question 1: Is there a bibliography or reference list of the scientific documentation that has
been used to support the development of the Plan? If so, would it be possible to provide it
to us?

Public Opinion Surveys
Public opinion surveys are useful for assessing perceptions and opinions but less useful in
establishing scientific fact. Just because a survey of people think something is true does
not make it so. Further, if surveys are not done by credible polling organizations using
sound methodologies then the results can often be misleading. We respectfully submit
that public opinion surveys on matters of fact should not be used as a basis for public

Question 2: Are there any documents relating to the purpose and methodology of the
telephone survey and the Directions survey? If so, would it be possible to provide them to

Forest Reserve Usage Information
The FRMUD Conclusions/Recommendations indicated (p.45) “Alberta Forestry has been
conducting research on uses in the Forest Reserve”. And yet the Q&A summary from the
April 9,2005 session says “there are no statistics regarding the various users in the area”.
We sincerely hope that any access plan designed to manage recreational use is based on
a firm understanding of what is actually happening in the area.

Question 3: Are there any documents that address any aspect of the multitude of
recreational uses of the Forest Reserve? If so, would you be able to provide them to us?

The Ghost Climbers Coalition
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                             6
September 30, 2005

OHV use is of particular importance and yet there seems to be a dearth of information
about the different types of OHV use, the location of different uses of OHVs and the
intensity of OHV use. Alberta is said to have the highest level of per capita OHV/ATV sales
and yet recreational use is not distinguished from commercial (e.g. ranching) use.

Question 4: Are there any documents that address any aspect of OHV usage that have
been utilized in the development of the Access Plan? If so, would you be able to provide
them to us?

Random Camping
Random Camping is another important issue and yet there is no information on its
distribution around the Reserve or its intensity at different locations or its impacts or any
mitigating actions now being provided by the government.

Question 5: Are there any documents that address any aspect of random camping that
have been utilized in the development of the Access Plan? If so, would you be able to
provide them to us?

The various documents available on the website refer to four ideas that are sometimes
issues, sometimes objectives, and sometimes priorities which has been sometimes
confusing. In the Terms of Reference these ideas are used to put a scope around the
review but in the Plan they mysteriously show up as “subject areas‟ and in the October 9,
2003 press release they are issues. The four; public safety, environmental protection, user
conflict, continued OHV opportunities, all share one thing in common – there is very little
description or quantification of the magnitude or seriousness of these issues. It is hard to
know if the Plan is good or not because we don‟t know what problem we are trying to solve.

Question 6: What evidence or data regarding public safety (or lack there of) has been
utilized in the development of the Access Plan? Were there any previous studies on this
topic that may have been used as a baseline?

Question 7: What evidence or data regarding user conflicts has been utilized in the
development of the Access Plan? Were there any previous studies on this topic that may
have been used as a baseline?

Question 8: Most importantly, what evidence or data regarding deleterious OHV usage in
the Ghost area has been utilized in the development of the Access Plan? Were there any
previous studies on this topic that may have been used as a baseline?

Watershed Integrity
Watershed integrity is indicated as a high priority in all the available documents. The IRP‟s
first Guideline on Watershed states that “Alberta Environment and Alberta Forest Service
will monitor water yield and quality to ensure the maintenance of a high-quality water

The Ghost Climbers Coalition
Position Paper on the Draft Ghost-Waiparous Operational Access Plan                            7
September 30, 2005

Question 9: What evidence or data regarding watershed integrity in the Reserve have
been utilized in the development of the Access Plan? Were there any previous studies on
this topic that may have been used as a baseline? How does the diversion project
reconcile itself with watershed integrity?

Fisheries and riparian habitat concerns are also held up as a reason for access restrictions.

Question 10: What evidence or data regarding fisheries and riparian habitat
endangerment in the Ghost has been utilized in the development of the Access Plan?
Were there any previous studies on this topic that may have been used as a baseline?
How does the diversion project reconcile itself with fishery and riparian habitat integrity?

The FRMUD report states (p.8) that “Between 1992 and 1998 staffing decreased from 28
full time seasonal personnel to none with the closing of the ranger station and the result
being the removal of a physical presence at the ranger station and a gross reduction in the
governmental presence in the area”. Documentation by Praxis et al indicates that many of
the perceived issues and concerns stem from a lack of government enforcement of existing
laws or regulations.

Question 11: Please provide any data regarding enforcement personnel present in the
Reserve over the last ten years.

Plainly, what we really need is simply to have some one in the Ministry recognize that our
cumulative and extensive experience in the Ghost is a valid resource from which
considered and practical access plans can be made. We clearly have demonstrated we
wish to be part of the process but feel that we have been essentially shut out of meaningful
consultations with SRD.

The Ghost is a unique climbing resource that we as Albertans cherish and want to preserve
while maintaining responsible and traditional accessibility.

The Ghost Climbers Coalition

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