Comments on the 2025 Draft Alberta Plan for Parks
The Alberta government’s ‘Plan for Parks’ is a high-level policy document setting out the direction for parks management and priorities in the province. While it does not include any regulatory details, and as such does not have the enforceability of a regulation, it does set the tone for the provincial government’s treatment and attention towards parks.
In May 2025, the Government of Alberta released an updated draft version of the Plan for Parks (the “Plan”) after the previous version expired in 2019. This is an important step because parks and protected areas are an integral part of Alberta’s landscape, not only for recreation and access to nature but also for ecosystem functions, species at risk protections, and the adaptation to and mitigation of the effects of climate change.
The opportunity to comment on the Plan is open until July 26, 2025, and we encourage everyone to have their say on the direction of these critical spaces.
Below, we set out some of our comments on the Plan which may be useful when coming to your own conclusions in this regard. Specifically, we believe improvements can be made in four key areas: the stated purpose of parks; the balance of conservation goals versus recreation and access; the importance of clear Indigenous co-management; and a focus on climate change mitigation and adaptation. Each is discussed briefly below.
- The Purpose of Parks
The Plan identifies three core purposes: “conserve and effectively manage Alberta’s natural heritage; facilitate access and enjoyment of nature through recreation, education and nature appreciation experiences; and protect Alberta’s natural heritage for the benefit of current and future generations.” While these are important, there is no reference to “the conservation and management of flora and fauna” or “the preservation of specified areas, landscapes and natural features” both of which are set out in Section 3 of the Provincial Parks Act. Because purpose statements often guide the tone and priorities of a document, we recommend incorporating this statutory language into the Plan as a core purpose.
- Conservation vs Recreation
Throughout the Plan we believe there is an outsize focus on recreation without equal attention paid to conservation and to the wildlife and species at risk that rely on these protected areas for their life cycles. Notably, this was also a key theme in the Phase 1 Engagement Summary Document. This was the initial phase of engagement which was held in 2024. In the results from that work, many survey respondents focused on “the need to conserve natural environments and ecosystems” as priorities they felt were important for parks. Similarly, when asked ‘what do you value most about Alberta’s parks’ both “protection of biodiversity and representative landscapes” and “protection of ecosystem functions” were in the top 4 out of 11 possible answers from survey respondents, alongside “nature-based recreation.”[1] These results demonstrate that there is appetite from Albertans for an increased conservation focus that is not captured by the current Plan.
To advance conservation goals, we first recommend the timely completion of Alberta’s remaining regional plans. This step is necessary for several reasons:
- It would support the Plan’s stated commitment to landscape-level planning and align park management with the Land Use Framework and subregional planning;
- It would help to ensure cumulative effects management and landscape level planning for species at risk is done; and
- It would help manage parks for the purpose of “lasting protection for the benefit of present and future generations.”[2]
If we want to ensure that future generations have access to the same level of flora and fauna on the landscape, we must manage acute and cumulative effects including those effects that stem from recreation. Long-term sustainability justifies an increased level of scrutiny on both type and volume of recreation on the landscape. Regional plans will also help to ensure that biodiversity relevant features are present outside of parks and that there is alignment between park and non-park designations for the purposes of wildlife corridors and connectivity. Notably, this is an area in which collaborative species at risk management, including adoption of protections under the federal Species at Risk Act would be necessary.
The Plan also highlights the use of access fees. While access fees may be one tool to help manage unfettered access to these parks, the money raised by these fees should be reinvested back into the park system rather than going into general revenue. Any review of the access fee structure should include this as a requirement. Access fees should also be used to capture higher intensity uses such as off-highway vehicles (over and above vehicle registration fees). If access fees are tied to impacts to the park, they can be directly linked to mitigation and restoration of impaired areas, and to increased monitoring and enforcement of environmental laws as they relate to recreational impacts.[3]
Overall, the Plan for Parks should elevate conservation as its primary objective. The Plan states that park visitation is managed “with a dual mandate of conservation and recreation” and goes on to state that the core of parks management is welcoming visitors and allowing for nature-based recreation. While this is important, we respectfully submit that the core of parks management needs to be ecosystem management and the protection of wildlife and species at risk. Access and recreation are important, but secondary, functions and should focus on ecosystem appropriate recreation. This conservation focus is clearly echoed in several provisions of the Plan including section 2.1 which states that “parks conserve nature in-place to maintain biodiversity and ecological processes.” Similarly, section 2.4 which focuses on the protection of sensitive landscapes and the compliance with World Heritage Site and other designation standards sets a clear minimum for the protection of these important ecological spaces.
On the other hand, we are concerned that other focuses such as section 3.2 which includes enabled expansion of recreation activities; expanded access to water on ‘resilient waterbodies’; increased trail networks and connections; and new development in parks may undermine conservation goals without a proper decision-making framework for their implementation.
- Indigenous Co-Management
Throughout the Plan we were pleased to see a renewed focus on Indigenous participation and consultation; however, we also think that this presents an opportunity for the creation of Indigenous Protected and Conserved Areas (“IPCAs”). While neither the Provincial Parks Act, nor the associated regulations, provide an opportunity for delegating authority to another group or individual, thereby limiting the option of a true IPCA, and specifically full legal co-governance opportunities, the Plan does refer to updates coming to both the Act and regulations. This could provide an opportunity to incorporate better options for IPCAs.
In the meantime, Indigenous co-management, such as the process to create and manage the Kitaskino-Nuwenëné Wildland Provincial Park, is available under the Act’s provisions. We note that under section 2.3 “Parks enable collaboration with Indigenous communities and organizations to advance reconciliation and enhance conservation outcomes”, there is already reference to “cooperative management agreements”. While co-management does not necessarily mean co-governance, this represents an ideal opportunity for the establishment of the beginnings of a fulsome agreement, particularly if there will be changes to the Provincial Parks Act or a standalone IPCA Act enshrining the same in Alberta law.
- Climate Change Mitigation and Adaptation
Finally, we think it is important to highlight the risks of climate change on parks and park ecosystems. While section 2.2 sets out a goal for parks to be “resilient and responsive to environmental change” with references to varying weather and disasters, the only reference to a changing climate is with regards to new and updated park infrastructure under section 3.3. Managing climate change and its effects requires a dual focus on adaptation and mitigation. Parks management will need to be prepared for new and varied impacts on parks, whether that looks like drought, fires, or floods and should be working to mitigate these impacts alongside other provincial ministries. Specifically, this may represent an opportunity for “climate change appropriate recreation” which recognizes the impacts of managing recreation alongside extreme weather events. However, prior to the incorporation of this type of recreation, there must first be recognition of the impacts of climate change on parks.
As Alberta shapes its vision for the future of parks, it’s crucial that this Plan reflects not just where people want to go, but what the land and ecosystems need to thrive. By prioritizing conservation, strengthening Indigenous partnerships, and preparing for a changing climate, the province can ensure its parks remain resilient, inclusive, and ecologically rich for generations to come. Now is the time to speak up and help shape a Plan that truly protects what matters.
[1] See “What we heard Alberta’s Plan for Parks” at page 9.
[2] See Provincial Parks Act, RSA 2000, c P-35, s 3(e).
[3] To read more of our recommendations on access fees see: Rebecca Kauffman, Jason Unger & Kyra Leuschen “Accounting for Nature: Regulatory approaches to filling environmental budget gaps in Alberta” (Oct 2022) Environmental Law Centre at 51 online: https://elc.ab.ca/wp-content/uploads/2025/02/Accounting-for-Nature-November-2022.pdf.