Honorable Jason Nixon,
Minister of Environment and Parks

Dear Minister Nixon;

The Alberta Hiking Association (AHA) has reviewed Bill 79 (Trails Act) and have the following comments. Any further comments that we gather from members or the hiking public will also be passed on to you. We trust that these will be addressed during subsequent readings of the Bill or the preparation of associated Policies and Regulations.

Firstly, we reiterate our support for this Bill in principle, as it appears to recognize the importance of trails and the significant benefits they can provide on Public Lands in Alberta. However, as other commentators have noted the Bill is “framework” legislation that contains few specifics, instead leaving the creation and implementation of policy to the discretion of the Minister of Environment. Therefore, the AHA’s ongoing support for the Bill will depend on whether some key fundamentals are put in place. These include:

– maintaining or improving measures that protect important natural values (e.g., watershed, wildlife, endangered species etc.);
– ensuring that trail development and use is consistent with the various land, water and recreation management plans in a given area;
– establishment of a permanent role for stakeholders such as the AHA to provide meaningful input to the development and implementation of policies under the Trails Act; and
– ensuring that the provincial government is committed to being an active, true and committed trail partner into the future.

We note that as the owner of public lands in the Province, the Government of Alberta is also the owner of trails on those public lands. As ultimate owner of these assets, the Province should be primarily responsible for providing financial support for the construction and maintenance of these public resources. Further, trails on public lands will need to be formally recognized and adequately protected from damage or misuse. A truly sustainable trail system will require that all of these characteristics be put in place.

It is critical that all existing or new trails on public lands be assessed by government staff in conjunction with knowledgeable trail groups for environmental and stakeholder acceptability before they are designated. Adherence to all existing plans (e.g., regional plans and sub-regional integrated resource plans) and relevant standards should be maintained which in turn must based on the best available science. Where such plans do not exist, a priority should be put on developing them.

Trails need to be managed as significant public recreation facilities that are compatible with other approved land uses in the area. They need to be protected from damage from unauthorized uses, misuse or unmet commitments. Further, the government is and must remain responsible for enforcement, where such unauthorized uses or misuse occurs. Finally, the government needs to ensure that good information about trails is easily available to recreationists, other stakeholders or permittees.

The AHA has long recognized that while some of the best hiking in the province is provided in protected areas, provincial public lands also have much high-quality potential. These lands are often close to where many Albertans live, have high scenic and natural values and are open to public access. While these lands are typically managed for a variety of uses (e.g., logging, recreation, cattle grazing, petroleum, etc.) we are hopeful that, especially with the long overdue recognition and protection for trails which Bill 79 promises, more successful partnerships like in West Bragg Creek will be possible through effective shared use management. Appropriate policies and protocols need to be developed to guide ongoing shared use management. These should minimize impacts and conflicts as well as maximize the potential synergies between stakeholders. If and when damage to trails occurs, enforceable measures need to be in place to ensure repairs, relocation and/or compensation.

Trail partnerships require a variety of supports from government to ensure their ongoing viability and effectiveness. These should include but not be limited to support for the formation and effective functioning of community-level trails volunteer groups. Lasting partnerships require that both parties are able to bring a more or less equal amount to the table and that together they provide valued public recreation opportunities at a reasonable cost and risk.

The province needs to develop and approve standards for facility design (e.g., parking lots, trails, signage, etc.) as well as support for effective safety operations by volunteers. This could include training and certification to operate required equipment and machinery (e.g., chain saw operators training and certification, etc.). Also, the Province should provide up to half of the required resources for implementation of approved trail plans for both capital costs and ongoing maintenance. Trail group partners would raise the balance through fund raising, donations or other sources available to them. This funding should be coordinated and long term. Trails should be designated and approved using the most up to date trail planning, design, construction, maintenance and management standards provided by the province. These would be intended to minimize environmental impacts and maintenance requirements and provide the best quality user experiences.

The AHA will be inviting further comments and feedback from members and the hiking public and will therefore likely provide further input on the Bill. We believe that we have an important role to play in implementing the provisions of the proposed Trails Act. While we have always been the voice for hikers, if the new Act is passed and comes into force, we plan to significantly increase our encouragement and support of our members to become actively engaged in trail projects and partnerships. As well we will be doing more to inform and educate our members and the public about how to enjoy hiking, snowshoeing etc. safely. To this end, we intend to continue to expand and improve our working relationships with government staff as well as other related organizations.

Don Cockerton
Chair, Alberta Hiking Association

Cc: Jamie Bruha, Director, Public Lands Division
AHA Board of Directors