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1996 November Report of the Auditor General of Canada

Assistant Auditor General: Robert R. Lalonde
Responsible Auditor: Harry A. Ruthnum

Main Points

31.1 Parks Canada administers 38 national parks, including two recently established ones, four national marine conservation areas and 131 national historic sites, including nine heritage canals. The system of 38 national parks covers approximately 225,000 square kilometres. In 1994-95, there were over 25 million visitors to the national parks, historic sites and heritage canals. The budget for 1996-97 is $368 million.

31.2 The March 1996 federal Budget announced the government's intention to create a separate service agency to manage the Parks program. The new agency will manage, and preserve for future generations, a system of national parks, national historic sites and canals and related protected areas for the use and enjoyment of Canadians.

31.3 Overall, there is a need for Parks Canada to improve its knowledge about the state of the natural resources within national parks in order to implement a sound ecosystem-based management approach. This would help ensure that national parks remain or become unimpaired for the enjoyment of future generations, as required by the National Parks Act . We noted that:

  • in the six national parks we reviewed, Parks Canada's biophysical information was out-of-date or incomplete except for La Mauricie; and
  • although monitoring the ecological integrity of the ecosystems in national parks is a high priority according to Parks Canada policies and guidelines, in many national parks the Department has not monitored ecological conditions on a regular, continuing basis.
31.4 We are concerned that initiatives to increase visitation, if not carefully managed, could compromise the ecological integrity of national parks. Furthermore, adding new parks to the national system will put significant pressure on the resources that Parks Canada can allocate to each park to maintain and improve ecological integrity.

31.5 Of the 39 natural regions, 24 are currently represented by a national park. Since 1990, four new national parks have been established, all of which were under way before 1990. Given the rate of progress to date in creating new parks, the national parks system may not be completed as planned by the year 2000.

31.6 A number of candidate sites for national parks remain open to industrial development activities. We are concerned that these activities could harm the ecosystems and wildlife habitat that national parks are trying to protect, and impair their value as wilderness reserves.

31.7 Parks Canada has neither developed an action plan nor established a target date for completing the National Marine Conservation Areas System.

Introduction

The role of Parks Canada
31.8 Parks Canada is a program of the Department of Canadian Heritage. Its objective is "to commemorate, protect and present those places which are significant examples of Canada's natural and cultural heritage for the benefit, understanding and enjoyment of the people of Canada, in ways which ensure the ecological and commemorative integrity of this heritage for the benefit of present and future generations."

31.9 Parks Canada administers 38 national parks, including two recently established ones, five Canadian heritage rivers, four national marine conservation areas and 131 national historic sites, including nine heritage canals. The system of 38 national parks covers approximately 225,000 square kilometres. In 1994-95, there were over 25 million visitors to the national parks, historic sites and heritage canals. The budget for 1996-97 is $368 million.

31.10 The 1988 National Parks Act states that "the National Parks of Canada are hereby dedicated to the people of Canada for their benefit, education and enjoyment...and shall be maintained and made use of so as to leave them unimpaired for the enjoyment of future generations." In essence, the Act calls for the sustainable use of national parks. It also states that "maintenance of ecological integrity through the protection of natural resources shall be the first priority when considering park zoning and visitor use in a management plan."

31.11 Parks Canada has divided Canada into 39 natural regions, each with distinctive physical and biological characteristics. The 1990 Green Plan sets out the federal government's goal of completing the national park system by the year 2000 by having a national park in each of the 39 regions. Parks Canada proposes to complete the system by achieving a negotiated national park agreement for each of the unrepresented natural regions or a permanent withdrawal of proposed national parklands from industrial development.

31.12 National parks help sustain wildlife populations and protect critical habitat, watersheds and rivers, and endangered species. They also assist in monitoring the health of the Canadian landscape by providing natural benchmarks against which to measure changes in natural ecosystems. National parks contribute to sustainable development by protecting representative ecosystems that define the Canadian landscape. Finally, when development of adjacent lands is proposed, the parks can help to keep it within sustainable limits because of the potential for transboundary impact.

31.13 In 1990, the Green Plan enunciated Canada's long-term goal of setting aside 12 percent of its total territory as protected space. Also included in the Plan were the following specific measures relating directly to national parks:

  • establish five new national parks by 1996;
  • conclude agreements for 13 additional parks to complete the terrestrial system by the year 2000; and
  • establish three new national marine parks by 1996 and a further three by the year 2000.
31.14 In 1986, the National Marine Parks Policy was approved, which committed Canada to protecting important examples of its marine environment. In 1987, Fathom Five National Marine Park was established in Georgian Bay, by federal-provincial agreement with Ontario, as Canada's first national marine park. The 1986 policy was subsequently updated in 1994 by the National Marine Conservation Areas Policy to reflect more adequately the challenges of sustaining marine ecosystems and species.

31.15 The March 1996 federal Budget announced the government's intention to create Parks Canada as a separate service agency. The agency will have a mandate to manage, and preserve for future generations, a system of national parks, national historic sites and canals and related protected areas for the use and enjoyment of Canadians. Legislation to create the agency will be prepared.

Focus of the audit
31.16 Our audit focussed on the systems and processes that Parks Canada has in place to maintain, enhance and report on the ecological integrity in national parks. We also assessed the completion of the national parks system. Further details on the audit objective, scope and criteria are found at the end of the chapter in the section About the Audit .

Observations and Recommendations

Maintaining and Improving Ecological Integrity in National Parks

31.17 Parks Canada defines ecological integrity as "a condition where the structure and function of an ecosystem are unimpaired by stresses induced by human activity and are likely to persist."

31.18 Parks Canada carries out a wide variety of activities that are intended to contribute to maintaining and improving the ecological integrity of national parks. These include investigations into poaching; monitoring environmental factors such as acid precipitation and water quality; and carrying out environmental impact assessments of proposed capital works. Attaining ecological integrity in national parks involves a long-term commitment by Parks Canada. The results of its efforts often occur over long periods and may not be immediately apparent.

31.19 Parks Canada has adopted the concept of ecosystem-based management. This implies pursuing goals of ecological integrity using a comprehensive approach to protecting an ecosystem that may be greater than the size of the park. This approach is based on knowledge of the human and naturally induced stresses that affect these ecosystems, and a recognition that such ecosystems are constantly changing. Ecosystem-based management therefore demands actions based on appropriate information and coherent plans to reduce stresses so that ecosystems can evolve naturally over time.

31.20 This contrasts with earlier approaches, which usually focussed on protecting individual species or analyzing the linear relationships of specific food chains or cycles. Ecosystem-based management relies heavily on monitoring changes and assessing the impacts of stress on an entire ecosystem.

Managing to achieve ecological integrity
31.21 In our opinion, Exhibit 31.1 represents prerequisites that relate directly to managing with a view to achieving ecological integrity.

31.22 To the extent that these prerequisites or "building blocks" are in place, it will be possible to manage in a way that will allow Parks Canada to maintain and improve the ecological integrity of national parks. Conversely, if any of these building blocks are lacking or weak, there is a risk that some or all ecological objectives will be compromised to some degree.

31.23 This section of the chapter presents our findings in relation to these prerequisites. Our findings on accountability appear under "Accountability to Parliament", paragraphs 31.81 to 31.90. We have also included observations on Parks Canada's efforts to communicate information on ecology to visitors to national parks and to the public in general (paragraphs 31.47 and 31.48).

31.24 Exhibit 31.2 displays basic facts about conditions affecting the six parks we reviewed as part of the audit. The concepts and terms included in the exhibit are explained in this section.

Planning does not always provide a clear link between ecological integrity objectives and initiatives
31.25 The park management plans provide strategic direction for the protection of park ecosystems. However, we noted that the management plans for 18 parks were more than five years old; the average age was about 12 years, even though the National Parks Act and policy require that management plans be reviewed every five years. Moreover, in 9 parks the ecosystem conservation plans, which provide more precise direction on the protection of ecological integrity in each park, are more than five years old. Parks Canada's Guide to Management Planning suggests that these plans be updated within five years.

31.26 These plans were developed before Parks Canada had articulated its current ecosystem-based guidelines and policies. Delays in preparing management plans and ecosystem conservation plans reduce Parks Canada's ability to preserve the ecological integrity of national parks. For example, they complicate the incorporation of stronger ecosystem conservation goals and practices, which are required by the 1988 revisions to the National Parks Act and Parks Canada's subsequent ecosystem-based guidelines and policies. Furthermore, 13 parks reported that they did not have a fully completed ecosystem conservation plan.

31.27 Except for Pacific Rim National Park Reserve, the management plans of the six parks that we reviewed did not provide a clear link between ecological integrity objectives and initiatives. Nor were the business plans linked clearly to the management plans. Business plans are intended to define how management plan initiatives will be implemented. Consequently, it is difficult to assess how ecological integrity initiatives will be implemented to achieve strategic objectives and whether Parks Canada plans to allocate its resources according to those objectives. Parks Canada also has no formal process for monitoring the implementation of management plans or reviewing previous initiatives.

31.28 We are concerned that in some instances, management plans emphasize social and economic factors over ecological factors. This may be reflected in decisions relating to the development of park facilities and the extension of commercial leases. Our concern applies particularly to Banff and Jasper national parks, which have experienced substantial commercial development in recent years.

31.29 Parks Canada should ensure that park management plans are updated in accordance with the requirements of the National Parks Act and policy, and business plans should be clearly linked to those management plans. Parks Canada should also introduce a formal process for monitoring the implementation of management plans.

Department's response: Agreed. Parks Canada is currently assessing the links between the management planning process and business planning process to ensure that key accountabilities such as ecological integrity are respected in both planning and plan implementation. Mechanisms to assess the implementation of management plans do exist through the annual cycle of business plans and work plans. These will be reviewed and strengthened as necessary.

Parks Canada lacks key information necessary for park management
31.30 Good information is a cornerstone of managing parks in an ecologically responsive manner. However, we found that Parks Canada's information base was weak in two key areas, as discussed below. Because it lacks essential information, Parks Canada risks making decisions on park management that may not be sound in terms of maintaining and improving ecological integrity.

31.31 Increasing visitor traffic in national parks could compromise ecological integrity. Parks Canada's marketing strategy is expected to attract more Canadian and international visitors for longer stays in national parks. This strategy is also expected to increase the number of visitors in off-peak seasons. We are concerned that Parks Canada's ability to preserve ecological integrity in national parks and ensure sustainable park use will be seriously challenged. Furthermore, adding new parks to the national system will put significant pressure on the resources that Parks Canada can allocate to each park to maintain and improve ecological integrity. This financial pressure is likely to increase as government resources become even more constrained over time.

31.32 Given Parks Canada's intention to promote national parks extensively, and given the significant risk to ecological integrity associated with increased visitation, comprehensive information on the ecologically acceptable level of visitor use in national parks is important. We noted a lack of such information in the parks that we reviewed. Furthermore, determining the acceptable level of visitor use is complicated by the absence of measurable objectives for ecological integrity. The lack of such information reduces Parks Canada's ability to ensure the sustainable use of national parks and may result in the degradation of ecologically sensitive areas that are most accessible to the public.

31.33 The risk to ecological integrity posed by high numbers of visitors is real, and has been recognized in existing parks. The ecological sustainability of the "Four Mountain Parks" area (Banff, Jasper, Kootenay and Yoho national parks) is of particular concern. The number of visitors in these parks increased by 25.7 percent between 1988-89 and 1994-95. In 1994-95, there were 8,650,000 visits to this area. By comparison, the number of visitors to other national parks during the same period increased by 13.7 percent.

31.34 The ecologically sensitive Bow Valley accommodates a large proportion of the visitors to the Four Mountain Parks area, and Parks Canada recognizes that it has already been significantly impaired by human activity and development. The terms of reference of the Banff Bow Valley Study, commissioned by the Minister for Canadian Heritage, highlighted the need to provide for sustainable use of the Bow Valley and to protect the natural values of Banff National Park. Nevertheless, a recent initiative of the Department of Canadian Heritage (Roads to Canada's Great Drives) heavily promoted the Bow Valley as an attraction.

31.35 On-site staff in national parks were consulted to determine their views on the extent to which the parks are used. According to staff, two thirds of national parks are experiencing some degree of "overuse or crowding". As well, the consultations revealed that increased visitation is beginning to cause environmental problems in some northern parks.

31.36 Parks Canada should determine the acceptable level of visitor use for each park in order to preserve ecological integrity in national parks.

Department's response: We agree with the observation that Parks Canada should determine the acceptable level of visitor use for each park in order to preserve its ecological integrity. The recently released Banff-Bow Valley Study is an excellent example.

31.37 Baseline biophysical information needs to be improved. Preserving the integrity of ecological systems in national parks requires collecting data on park resources and maintaining and updating biological, ecological and physical information. It also requires doing scientific research on the status of ecosystems and monitoring their condition over time in order to detect changes and take corrective measures.

31.38 Parks Canada has not systematically collected scientific data on natural resources and monitored changes in their condition over time for all the national parks. We found that the biophysical information Parks Canada did have for the six parks we reviewed, other than La Mauricie, was frequently out-of-date or incomplete. Without this critical information, Parks Canada will have difficulty assessing the condition and trend of natural resources in these national parks, including species at risk. This increases the risk that Parks Canada will be unable to protect ecological integrity in these parks.

31.39 In response to our survey of the national parks, 14 parks reported that they had no scientific research strategy for gathering data to address ecosystem-based management questions. Of the 22 parks that did report having such a strategy, 11 said that it was not part of the scientific research framework for the park's administrative region. This reduces Parks Canada's assurance that research is effectively responding to park and regional management needs for information related to ecological integrity.

31.40 Despite these weaknesses, Parks Canada has had some positive results in maintaining and improving the ecological integrity of national parks. For example, it is working with other government agencies, industry, Aboriginal people and adjacent landowners to encourage compatible management practices in national parklands and adjacent areas. The intent is to minimize the impact on national park ecosystems of activities taking place outside park boundaries. For example, in La Mauricie and Point Pelee national parks, a number of joint research projects and other collaborative initiatives have had a positive impact on ecological integrity. As a result of one such initiative, the stocking of lakes that lie outside the boundaries of La Mauricie National Park but are connected to water bodies inside the park has been stopped. In Point Pelee National Park, local commercial nurseries have reduced the marketing of non-native plants. As a result of both changes, the modification of the natural processes in both parks has been reduced.

31.41 Parks Canada's partnership arrangements continue to play a significant role in its efforts to maintain the ecological integrity of national parks. For example, its involvement in the Fundy Model Forest Program has permitted Fundy National Park management to gather and analyze a significant amount of data in a relatively short period of time at less cost than if it had tried to do so on its own. One of the goals of this program is to ensure the environmental sustainability of the greater park ecosystem.

31.42 Parks Canada should improve the quantity and quality of its baseline biophysical data in order to respond to ecosystem-based management questions with a view to preserving ecological integrity in national parks.

Department's response: Agreed.

Determination of indicator species of ecological integrity is not completed
31.43 Many monitoring projects focus on determining the state of health of particular species. Some of this information can then be used as an indication of the general health of an ecosystem. For example, Parks Canada uses the condition of the loon population as one of a number of indicators of ecological health in La Mauricie National Park. Similarly, it uses the condition of the pine marten as an indicator of ecological health in Fundy National Park. However, our survey of the national parks showed that 15 parks have not established indicator species of ecological integrity, and 11 others have only incomplete sets of indicators. Indicators such as these, if available, could be used to detect changes in ecosystems. The lack of indicators of ecological integrity also complicates the identification of the ecological aspects on which Parks Canada needs to focus its monitoring. This reduces its assurance that monitoring will yield useful information for park management.

Monitoring of the ecological conditions in national parks is incomplete
31.44 Monitoring the ecological condition of the ecosystems in national parks is a high priority, according to Parks Canada policies and guidelines. However, in many national parks, the ecological conditions are not monitored on a regular, continuing basis. In response to our survey of the national parks, 16 parks reported that they had no program for monitoring ecological integrity. Another nine reported that they had one, but that it was only partly developed.

31.45 Without an effective monitoring program based on valid indicators, the risk increases that Parks Canada will not be able to detect problems that may be affecting ecological integrity and take remedial action. To illustrate the risk associated with shortcomings in monitoring, effluent from a settlement pond is being drained into an adjacent wetland at the Wasagaming town site in Riding Mountain National Park, to reduce the amount of toxic residue polluting a lake. However, Parks Canada does not monitor the wetland area to determine whether, or to what extent, the effluent is causing damage to the area and the wildlife species associated with it.

31.46 Parks Canada should develop an effective system for monitoring the ecological conditions in all national parks.

Department's response: Agreed. Parks Canada's current work has placed it in a leadership role in the development of this field. Parks Canada is regarded as an important partner in Canada's Environmental Monitoring and Assessment Network.

Interpretation and public education programs could contribute more to preserving ecological integrity in national parks
31.47 Information and interpretation are identified in Parks Canada's policies as "principal means of achieving its protection and presentation objectives". Information and interpretation programs provide information to park visitors and the public in general to help them understand, appreciate, enjoy and protect Canada's national parks. These programs are also aimed at providing opportunities for members of the public to acquire knowledge and skills that will help them to make environmentally responsible decisions on a day-to-day basis.

31.48 Our survey of the national parks showed that of the 28 most accessible, 19 have not developed a strategy to communicate information about ecological integrity. As well, the level and content of information on ecological integrity provided in the different parks is inconsistent, as in some instances the linkage between communication and protection of natural resources needs to be strengthened. Consequently, assurance that ecological integrity information is delivered effectively is reduced. The information presented in the visitor centres at Riding Mountain, Fundy and Pacific Rim national parks tended not to relate to broader environmental issues and thus did not convey a message of ecosystem protection. In our opinion, Parks Canada could do more to communicate information that would help it explain and protect the ecological features of national parks.

31.49 Given the potential for benefiting ecological integrity, Parks Canada should strengthen public education programs to better communicate ecological information to park visitors and Canadians in general.

Department's response: Agreed. Among current initiatives, Parks Canada is a sponsor of both the Discovery Channel's Great Canadian Parks series and an educational video series by noted ecologist Dr. Stan Rowe.

New Park Establishment

31.50 The federal government's goal is to complete the national park system by representing each of the 39 terrestrial natural regions in the system of national parks by the year 2000. Each national park is to represent the biological and physical characteristics found in its natural region, and contribute to maintaining the area's ecosystems in as healthy a state as possible.

The national parks system may not be completed by the year 2000
31.51 Of the 39 natural regions, 24 are currently represented by a national park ( Exhibit 31.3 ). Since 1990, four new national parks have been established, all of which were under way before 1990 (Aulavik, Vuntut, Wapusk and Tuktut Nogait). The latter two were established in 1996. One national park, Vuntut, was established in the Northern Yukon region, which was already partially represented by Ivvavik National Park. Also, land acquisition is currently under way to establish the Gulf Islands National Park in southern British Columbia.

31.52 Given the rate of progress in creating new national parks to date, the low activity in over half of the natural regions still unrepresented and the number of unconfirmed potential park sites, the national parks system may not be completed as planned by the year 2000. Today, less than five years before the deadline, Parks Canada is negotiating with provincial and territorial governments, Aboriginal people and local communities to establish parks in 7 of the 15 remaining natural regions. Our audit noted that in three inactive regions, there are no negotiations due to a lack of support from other governments and local communities. The other five regions lack specific proposals for negotiation, making them inactive natural regions as well.

31.53 Failure to represent each of Parks Canada's terrestrial regions could undermine the federal government's protected-area commitments originally made in Canada's Green Plan (1990) and the Tri-Council Statement of Commitment to Complete Canada's Networks of Protected Areas (1992). It could also indicate a failure to meet Canada's international commitment to establish a network of protected areas to conserve biological diversity, as stated in the Biodiversity Convention (1992).

Parks Canada has neither established nor publicized its priorities for each natural region
31.54 In our 1989 audit, we recommended that Parks Canada establish a target date and priorities for completing the system. In the 1990 Green Plan, the federal government made a commitment to complete the terrestrial national parks system by the year 2000. This goal was subsequently confirmed in 1994. To date, however, Parks Canada has neither established nor communicated clear priorities for establishing a park in each of the unrepresented natural regions. It has indicated only that its priority is to establish new national parks in the seven natural regions that already have active proposals.

31.55 Parks Canada updated its National Parks System Plan in 1990, and in 1992 prepared a Draft Action Plan for Completing the National Parks System Plan. The System Plan provides a general overview of the features Parks Canada wants to protect in each natural region. It also indicates the status of planning in each unrepresented natural region and describes the five-step approach to park establishment:

  • identifying representative natural areas;
  • selecting potential park areas;
  • assessing park feasibility;
  • negotiating a new park agreement; and
  • establishing a new national park in legislation.
31.56 The Draft Action Plan reviewed the steps to establishing new national parks and the status of planning in the unrepresented natural regions. It also set target dates for advancing work in unrepresented natural regions. However, most of these target dates have passed.

31.57 Parks Canada should update and release its National Parks System Plan and Action Plan for Completing the National Parks System.

Department's response: The system plan is in the process of being updated. The current action plan will continue.

Parks Canada has not been sufficiently proactive in getting support for new national parks
31.58 One challenge that Parks Canada must overcome to successfully negotiate new national park agreements is obtaining the support of provincial and territorial governments, Aboriginal people, and local communities. Securing such support can take years. In the case of a proposed national park in the Northwest Territories, it took 16 years before local communities were prepared to negotiate a park agreement. Such support still has not been secured for a proposed national park in southern British Columbia. Achieving local support, in particular, is a fundamental requirement of federal parks policy. Parks Canada's ability to achieve a national park agreement for six of the seven active national park proposals, and two of the three inactive national park proposals, will depend to a considerable extent on securing the support of local people.

31.59 Parks Canada needs to assign more priority to securing provincial and local support for new national parks in the eight inactive natural regions. Failure to do so leaves candidate sites open to industrial development, and other land-use decisions that could prevent the creation of a new national park. We noted the lack of a strategic approach, for example, infrequent use of outside professionals and community-based workshops to assist in bringing together Parks Canada, provincial and territorial governments, Aboriginal people, local communities and other interested parties to examine the challenges and potential opportunities for action, particularly in the inactive natural regions. By simply waiting for other governments and local communities to adopt favourable positions, Parks Canada is reducing the likelihood of achieving representation in several natural regions and maintaining ecological integrity.

31.60 Parks Canada should develop a more strategic and proactive approach to achieving provincial, territorial, Aboriginal and local support for candidate park sites, thus allowing it to complete the national parks system on a timely basis.

Department's response: The Department believes that Parks Canada has adopted a strategic and proactive approach. It is important to recognize that provincial and territorial, Aboriginal and local support must be earned through dialogue and consultation, always in conjunction with legitimate demands and desires for other land uses.

Some potential national parks remain open to industrial development activities
31.61 A number of candidate sites for national parks remain open to industrial development activities. We are concerned that these activities could harm the ecosystems and wildlife habitat that national parks are trying to protect, and impair their value as wilderness reserves. Interim measures are needed to protect these potential parks from development until negotiations on the feasibility of creating a new national park are concluded. Failure to do so could raise the cost of creating new parks in the future if Parks Canada has to compensate developers for stopping their work and losing their tenure or licenses. Giving developers access to potential national parklands could also jeopardize the public consultation process.

31.62 Mineral staking has already occurred in several potential national parks in the south. As well, areas of moderate to high mineral potential within the boundaries of several proposed northern national parks have been identified, which could result in mineral staking before Parks Canada has concluded negotiations for establishing these parks. The federal government cannot apply interim protection measures to the southern national park candidates because the land is provincial Crown land. However, it can do so in the Northwest Territories.

31.63 It is the policy of the federal government to ensure that an inventory of the non-renewable natural resource potential of areas in the territories be compiled prior to their formal establishment as new national parks. The government conducts mineral and energy resource assessments to ensure that the economic and strategic significance of mineral and energy resource potential is duly considered in the process of new park establishment. Until such assessments are complete, candidate sites remain legally open to mineral prospecting and staking activities. For example, we observed one instance where mineral prospecting permits were issued for areas proposed for inclusion in Tuktut Nogait national park before negotiations between Parks Canada and a northern Aboriginal community were concluded. As a result, negotiations to complete the park were delayed.

31.64 Parks Canada should continue to try to convince other jurisdictions and federal departments to use their legislative powers to withdraw candidate national park sites from development as early as possible to preserve their ecological integrity.

Department's response: Agreed. This is already being done, with demonstrated success.

Parks Canada has not pursued alternative approaches to land ownership
31.65 The National Parks Act requires the federal government to administer and control surface and sub-surface rights within the legislated boundaries of newly created national parks. When a national park is created in southern Canada, the province must transfer provincial Crown lands to the federal government before they can be administered under the Act. In northern Canada, most lands are administered either by the federal Crown or by Aboriginal people. Recent land claims settlements such as the 1993 Nunavut Land Claims Agreement set out the terms and conditions under which new national parks can be established.

31.66 The goal of the federal government is to represent each of the 39 natural regions with a national park where the federal government owns the land. Ideally, provincial governments and the federal government would work together in completing the national park system. One impediment to their doing so is that in several natural regions, the provincial government that administers the land will not transfer candidate national parks to the federal government. The need for the federal government to own the land limits alternatives. It could also increase the cost of establishing new parks, particularly if such lands are allocated to development interests before a potential national park has been identified, negotiated and established. We believe that flexibility on the issue of ownership of specific sites is essential if all natural regions are to be represented on time and at reasonable cost. In fact, both the federal Task Force on Park Establishment (1987) and the Canadian Environmental Advisory Council (1992) suggested that Parks Canada consider recognizing protected areas managed to national park standards in those natural regions where federal ownership of national park lands is not possible.

31.67 Clearly, innovative approaches to federal ownership will be needed to negotiate the use of the land to represent some of Parks Canada's natural regions. In such cases, Parks Canada may seek government approval to change its goal and accept representation of a natural region by some means other than a national park, using legislation other than the National Parks Act to protect the lands and waters. For example, we noted that a limited application of this approach worked in the case of Grasslands National Park. In Grasslands, the Saskatchewan government maintains ownership of the park's major watercourses, while delegating authority under provincial parks legislation to Parks Canada to manage the watercourses to national park standards. Similarly, the British Columbia government passed provincial legislation allowing Parks Canada to administer Pacific Rim as a national park until the area is proclaimed under the National Parks Act .

31.68 If certain natural regions are to be represented by a protected area other than a national park, Parks Canada needs to analyze the impact and benefit of varying the traditional national park approach. It needs also to ensure that there is public support for such an approach, given that the goal to complete the national park system by the year 2000 through the creation of national parks administered under the National Parks Act was supported in two extensive national consultation programs between 1989 and 1994. A major benefit of such an approach is that the ecological integrity of nationally significant natural areas could be achieved more quickly, and not lost to potential development while jurisdictions discuss issues related to land transfer.

31.69 For those natural regions where the need to own the land becomes an impediment, Parks Canada needs to be more proactive in finding another approach. For example, it needs to work with the relevant provincial jurisdictions to jointly identify a potential park site that meets the federal and provincial goals for representation. Once the site has been confirmed, the provincial government needs to be encouraged to apply interim protection measures while the federal and provincial governments develop a joint conservation strategy for protecting the area to national park standards.

31.70 Parks Canada should continue to represent each natural region by a national park where federal ownership is possible. Where it is not possible, Parks Canada should study alternatives, and recommend that the government:

  • consider the implications of alternative approaches to represent those natural regions, on a case-by-case basis;
  • consider federal recognition of such protected areas where the provincial government agrees to protect and manage them to national park standards under provincial legislation; and
  • subject such alternative approaches to public consultation, to ensure public support for a change to the federal government's goal of representing several specific natural regions with a national park.
Department's response: Parks Canada, pursuant to government direction, will maintain the course that leads to national parks being owned by all Canadians and managed on behalf of all Canadians.

Not all natural regions are adequately represented
31.71 In the early 1970s, Parks Canada adopted the concept of "representation" to guide its selection of new national park sites. Its goal is to protect representative examples of the Canadian landscape in each of the 39 natural regions. Potential national parks must represent the geology, physiography, vegetation, wildlife and ecosystem diversity that are characteristic of the natural region in which they are situated. The degree to which a national park adequately represents a natural region depends on how well its final boundary captures, or represents, all of the natural features that define a natural region. Park boundaries must also be large enough to ensure that natural evolutionary processes continue.

31.72 We reported in 1989 that Parks Canada would conduct a region-by-region assessment of the adequacy of representation of the natural regions by existing parks. This review has not been done.

31.73 Such a review is important because parks in 12 of the 24 natural regions deemed represented by a national park were created before the system plan was adopted. Accordingly, the design of these parks was not based on the criterion of representation. As a result, the parks may not adequately represent their respective natural regions.

31.74 Parks Canada should assess the extent to which regions are represented by existing national parks and ensure that, where appropriate, park management plans address the need to improve representation.

Department's response: Agreed. The federal government's current priorities are the establishment of new national parks in unrepresented natural regions and creation of new national marine conservation areas.

Lack of clear objectives and priorities for completing the National Marine Conservation Areas System
31.75 Parks Canada released its first National Marine Conservation Areas System Plan in 1995. The Plan divides Canada's three oceans and the Great Lakes into 29 distinct marine regions. The goal is to represent each natural marine region in the system of national marine conservation areas. To date, there are four national marine conservation areas, Fathom Five and a marine component of Pacific Rim National Park Reserve. In addition, federal-provincial agreements have been signed to create the Gwaii Haanas National Marine Conservation Area in the Queen Charlotte Islands of British Columbia (1988) and Saguenay Marine Park in Quebec (1990).

31.76 Parks Canada has neither developed an action plan nor established a target date for completing the National Marine Conservation Areas System. For example, the year 2010 has been recommended as one target date by the Canadian Environmental Advisory Council and the Endangered Spaces Campaign.

31.77 Studies to identify possible sites have been completed in 12 marine regions and feasibility studies are under active discussion in another three. But Parks Canada has not assigned priorities for carrying out work in each of the 29 regions. Potential biological and economic disruptions underline the need to protect our marine resources as a priority.

31.78 Parks Canada should develop a strategic plan, including a target date, for completing the national marine conservation area system.

Department's response: Parks Canada intends to prepare an action plan for establishing National Marine Conservation Areas (NMCA). Until further experience has been gained in establishing and managing national marine conservation areas, it would be premature and unrealistic to set a target date for completing the national marine conservation area system. Consultations on appropriate NMCA legislation have been authorized very recently.

The process for adding new parks is cumbersome
31.79 Parks Canada can add new national parks and national marine conservation areas to the National Parks Act only if new legislation is passed . This requirement has become an impediment to bringing new national parklands into the system. For example, Aulavik National Park, created almost five years ago in 1992, will not be protected under the Act until Parliament amends it. Similarly, Parks Canada cannot add lands to existing national parks without returning to Parliament. However, the fact that existing national parks cannot be deleted or reduced in size without Parliament's approval does ensure that such areas are retained for the benefit of future generations. Parks Canada realizes that the present legislative process is cumbersome and is studying options to streamline the process.

31.80 Parks Canada should continue to seek amendments to the National Parks Act that would allow the federal government to add new national parks or enlarge existing ones through a streamlined legislative process, without having to introduce legislation in Parliament.

Department's response: Agreed. We underline though, that legislation is currently required.

Accountability to Parliament

31.81 The 1988 National Parks Act requires Parks Canada to report to Parliament on the state of the ecological conditions in national parks, and on progress made toward establishing new national parks. This information is to be reported at least once every two years through the State of the Parks report. The Act also requires the Minister to review each park's management plan once every five years.

31.82 The first State of the Parks report was tabled in 1990, and the next one was published in 1994. Parks Canada did not meet its statutory requirement to table a Report in 1992. It is proposing amendments to the National Parks Act to change the reporting requirement from every two years to at least every five years. While we recognize that this is a legislative issue, we are worried that increasing the time interval between reports by too much would dilute Parks Canada's accountability to Parliament.

31.83 Parks Canada should table a State of the Parks report in Parliament within the time requirement stated in the National Parks Act .

Department's response: Agreed. Should Parliament agree to changing the cycle to align the State of the Parks report with the Sustainable Development Strategy reports, Parks Canada would adopt that cycle.

Improvements to the State of the Parks report are needed
31.84 In our 1989 audit of Parks Canada, we indicated the lack of reliable program performance information for management and Parliament. In our current audit we found that the problem persists, and that the 1994 State of the Parks report did not provide a complete and reliable assessment of the ecological condition of national parks, based on a national set of ecological integrity indicators.

31.85 The primary tool used to assess the state of ecosystems for the 1994 State of the Parks report was a questionnaire on 29 predetermined "stresses" (causes of impairment) affecting national parks. Stresses were, for example, visitor and tourism facilities and forestry operations occurring near parks. However, this approach fails to provide certain key information needed to draw fair conclusions about the ecological conditions in national parks. For example:

  • it does not indicate the extent of impairment of the natural resources and processes in the parks; and
  • it does not indicate how particular stresses affect the natural resources.
31.86 The 1994 State of the Parks report also provided information on the status of the national park system and ongoing work in some of the unrepresented natural regions. The benchmark for measuring progress in completing the system is a map of the 39 natural regions. The map indicates which regions are represented and which are not ( Exhibit 31.3 ). It also includes a bar graph indicating progress in carrying out the five steps required to achieve a new national park ( Exhibit 31.4 ).

31.87 We found that parliamentarians do not have enough information to assess Parks Canada's progress in establishing new parks because the 1994 State of the Parks report omits certain information and includes other information that is incomplete. We also found that the report overstated progress in several national parks and national marine conservation areas. For example, the report stated that Parks Canada had acquired all of the land for Grasslands and Bruce Peninsula. However, we noted that this information was incorrect and that the land acquisition programs for both national parks remain incomplete.

31.88 We also found that the 1994 State of the Parks report does provide some sense of progress toward completing the various steps, but it does not estimate the time that will be needed to progress to the next step. For example, the step involving the negotiation of an agreement appears to take a long time - years in many cases. Furthermore, the State of the Parks report does not clearly indicate:

  • priority sites for work;
  • whether any proposal is inactive; and
  • information on the challenges facing Parks Canada in all of the natural regions.
31.89 We also noted that the 1994 State of the Parks report did not report on the status of planning in each of the 29 marine regions. The System Plan therefore remains the sole source of information on national marine conservation areas. Finally, the State of the Parks report provides little information on the likelihood that Parks Canada will meet its goal of completing the national park system by the year 2000.

31.90 Parks Canada should improve the quality of information in the State of the Parks report. The report should provide information that is complete and reliable enough to present a fair picture of the ecological integrity of national parks and the progress achieved in completing the system. It should also include information on the status of the national marine conservation areas.

Department's response: Agreed. Work in this area is already under way.

Overall departmental response: The Department of Canadian Heritage is pleased to note the Auditor General's support for refining and improving our programs in support of ecological integrity. The need for better science, improved technology and growth in knowledge are challenges that face not only this generation but future generations of park managers. The Auditor General's findings are consistent with the foundations that we have already built into the 1994 State of the Parks (SOP) report.

The Auditor General has suggested means to improve the State of the Parks report as an accountability instrument. The Department supports this and, as scientific knowledge and data become available, we will implement improvements. The SOP report could, if Parliament agrees, be aligned with the new three-year reporting cycle for the Sustainable Development Strategy. As much of the data will be identical, this would avoid duplication, overlap and waste.

Parks Canada works hard to develop and communicate clear priorities for establishing new national parks in unrepresented natural regions. Every one of our partners, be they provincial governments, Aboriginal peoples, or non-governmental organizations, are aware of our priorities and kept up-to-date on their status. The audit does not give adequate recognition to the progress that has been made in establishing new national parks and protecting lands for proposed national parks. Recent progress includes: the acquisition of lands for a new national park in the Gulf Islands; the establishment of Wapusk and Tuktuk Nogait; land withdrawals for Wager Bay and Bathurst Island; and progress toward federal-provincial agreements on the Interlake area in Manitoba and the Torngat Mountains in Labrador. These results reflect the effort of many years of focussed, priorized work. In the last six months the federal government has protected, through two new park establishment agreements and through land withdrawals, more than 60,000 square kilometres of land - an area larger than the province of Nova Scotia.

Parks Canada continues to work with other jurisdictions and federal departments to utilize their legislative powers to withdraw park sites from development. In the last two years successful land withdrawals have been accomplished for three areas in the Northwest Territories by Indian and Northern Affairs Canada and one in Manitoba (Wapusk) in response to Parks Canada initiatives.

The Auditor General suggest that Parks Canada pursue alternatives that would permit natural regions to be represented by something other than a national park. The Department follows explicit government direction in its goal to complete the system, based on establishing national parks owned by all Canadians and managed on behalf of all Canadians. Parks Canada will continue in this direction.

Parks Canada intends to prepare an action plan for establishing national marine conservation areas (NMCA). On October 14, 1996, the Prime Minister announced the start of federal/provincial/public consultations aimed at introducing an NMCA Act in Parliament during 1997. It is considered premature to set a target date for completing the national marine conservation area system. We maintain that our current goal of establishing six areas by the year 2000 is realistic and attainable.

About the Audit

Objective

The objective of our audit was to review and assess whether Parks Canada is effectively managing two components of the program for which it is accountable-protection of ecological integrity and new park establishment- and to make recommendations to the Department.

Scope

Our audit focussed on the systems and processes Parks Canada has in place to maintain, enhance and report on ecological integrity; and to complete the national parks systems.

Criteria

Natural Heritage Protection (Ecological Integrity)

National parks should be maintained and used so as to leave them unimpaired.

The Department of Canadian Heritage should have and provide to Parliament relevant, reliable and timely information on the state of the natural heritage within national parks.

The Department of Canadian Heritage should have developed ways to measure the effectiveness of protective measures put in place.

New Park Establishment

The establishment of new national parks should be based primarily on their natural relevance and take into account opportunities to enhance Canadians' understanding and enjoyment of their natural heritage and the future operating costs to the government.

The Department of Canadian Heritage should have and provide to Parliament adequate information on the completion of the park system.

The establishment of new parks should be pursued with due regard to economy and efficiency.

Approach

The ecological integrity review focussed on a sample of six national parks (see Exhibit 31.2 ) out of the 36 established ones, including one park in each administrative region. The two newly established parks were excluded from our sample. The sample was selected to reflect as wide a diversity of Parks Canada's activities and management conditions as possible. The audit included the review of various Parks Canada documentation, and interviews at headquarters, regional and district offices. A survey on key ecological integrity issues was sent to the 36 national parks. We also met with stakeholders to understand their needs in regard to Parks Canada activities.

We examined documentation on progress and activities in establishing new parks, and met with staff who are directly involved in new park establishment at headquarters and the regions. We also reviewed documentation on three proposed national parks, including sites in southern Canada, the near north and northern Canada. We selected a successful national park, one still being negotiated and one where attempts to date have failed to produce a national park.

We consulted with the Department's Corporate Review Branch on all aspects of the audit. As the Branch had not yet started on an examination of either the protection of ecological integrity in national parks or new park establishment, it could not supply additional data.

Audit Team

Louis Bisson
Denis Robert
Katherine Rossetti

For information, please contact Harry A. Ruthnum, the responsible auditor.