AWA Comments on the Proposed Multi-species Action Plan for Banff National Park of Canada

May 11, 2026

On May 11, 2026, AWA provided comments to Parks Canada on the Proposed Multi-species Action Plan for Banff National Park of Canada, which includes management guidelines for 20 species at risk in the park.

The full letter can be read below, or at the PDF link: Comments on the Proposed Multi-species Action Plan for Banff National Park of Canada.

To Whom It May Concern,

Alberta Wilderness Association (AWA) appreciates the opportunity to provide comments on the Multi-species Action Plan for Banff National Park of Canada, which includes management guidelines for 20 species at risk in the park.

Founded in 1965, AWA strives to help Albertans understand the intrinsic values that wildlife and wilderness provide, and encourage ecosystem-based land-use planning decisions that will ensure a legacy for future generations. With over 10,000 members and supporters in Alberta and across Canada, AWA is dedicated to conserving Alberta’s wilderness and advocating for conservation strategies that protect Canada’s biodiversity.

AWA appreciates the opportunity to engage in this Multi-species Plan, as well as the time and effort that has gone into developing it. We support the measurable and tangible suggestions made in the plan, however, we find the management or recovery plans to be lacking for some species, and request stronger actions to protect all at-risk species. Please see the following for AWA’s detailed comments regarding the proposed Multi-species Action Plan for Banff National Park of Canada, hereby referred to as the Plan.

Detailed Comments

It must be the first priority of the Park to maintain ecological integrity and species preservation. Human influences and activities, such as recreational opportunities and access, must be managed appropriately in order to achieve that goal.

Compared to the 2017 Multi-species Action Plan for Banff National Park of Canada, we are glad to see more measurable actions, deadlines, and firm targets for recovery in the Plan. We also appreciate the timeline of accountability included in this Plan, which details a requirement for annual monitoring and a publicly available progress report to be completed after five years. AWA is also glad to see the implementation of specified timeframes listed for each action item listed, which we had previously advocated for during consultation for the 2017 draft plan. We are also supportive of the tangible strategies included to protect species at risk, such as the barbless hook regulations.

As multi-species action plans for other parks, such as Kootenay and Yoho, are also being developed at this time, alongside action plans for species such as native trout outside of the parks, coordination between action items in these plans should be a priority. AWA is glad to see that these are being developed together and all with some urgency attached. It should be stressed that all stakeholders and jurisdictions should be thinking about the big-picture conservation of these species, and how actions inside and outside the arbitrary borders of these parks will shape the landscape in the coming years, impacting these species’ survival.

Based on this goal, all action plans currently in development should incorporate discussions of how they will function together for the protection of these species. For instance, the Plan notes that for some species, setting site-specific population and distribution objectives is not appropriate because only a small portion of the species’ range is within the site, and therefore, the impact of management actions cannot be measured. It is stated that in such cases, conservation efforts may be limited to protection measures already in place under federal legislation. However, these progress measures could still be developed in collaboration with these other plans, if Parks Canada took a broader approach and merged some action items between the various plans in development. Making sure that management strategies and connectivity are coordinated between parks is imperative for maintaining and recovering these species at risk.

Banff National Park is a strategic location to take a more action-centric approach to recovery, since there is more room for conservation initiatives to work in protected areas where development is scarce. Parks Canada has an excellent opportunity to take on a leadership role and collaborate with other jurisdictions outside of the park boundaries to ensure that species at risk are protected on both sides of the boundary. The Plan notes that “Conservation Standards is increasingly being used by Parks Canada to support action planning, particularly with species for which implementing a shared adaptive management framework at a regional scale will improve conservation outcomes.” This goal should be implemented for more species at risk, and should include collaborative planning between jurisdictions such as the provincial government, Indigenous Nations, and municipalities when developing these upcoming finalized action plans.

Additional species of consideration have been added since the 2017 Action Plan, moving from 7 to 20 species with the addition of the Bank Swallow, Barn Swallow, Black Swift, Bull Trout, Eastern Red Bat, Grizzy Bear, Hoary Bat, Limber Pine, Northern Myosis, Plains Bison, Silver-Haired Bat, Vivid Dancer, Western Bumblebee, Western Toad, and Wolverine. These additions are a promising step towards incorporating more protections for species at risk in the park.

However, no population and distribution objectives or recovery approaches are identified in the Plan for Bank Swallow, Barn Swallow, Black Swift, Eastern Red Bat, Hoary Bat, Little Brown Myotis, Northern Myotis, Silver-Haired Bat, Vivid Dancer, Western Bumble Bee, Western Toad, or Woodland Caribou, despite some being threatened or endangered as well as listed under the Species at Risk Act (SARA). This feels like a critical gap in species recovery within the park. The Plan notes that these species are not included for reasons such as no known threats being present in the park or a limited population of each species existing in the park. However, with threats such as climate change and the displacement of animal populations from rapidly changing landscapes, it is uncertain whether that will remain the case for these species in the coming years. Additionally, these species should be considered at a broader scale, with approaches being developed for conservation that work between jurisdictional boundaries, as noted above. The limited conservation and recovery measures noted for these species, which in the draft Plan consist mainly of monitoring programs, should be expanded.

Additionally, the Plan should outline why the Common Nighthawk and Olive-Sided Flycatcher were removed from the updated Plan. These species have been downgraded on Schedule 1 from Threatened to Special Concern; however, removing these species from the action plan is inconsistent with the goal of ensuring that populations continue to grow and stabilize in the coming years, as well as ensuring that long-term monitoring programs are maintained. The 2017 Plan notes that the causal factors responsible for the decline of Olive-Sided Flycatcher and Common Nighthawk are poorly understood, and it would therefore be wise to continue assessing these species going forward.

The What We Heard: Summary of Comments on the Draft Banff National Park Management Plan from Phase 2 of the Public and Indigenous Engagement Program report from 2021, used to inform the Banff National Park of Canada Management Plan in 2022, revealed some key ideas from stakeholders. Themes from this engagement should be more robustly incorporated into this Plan, including that:

There should be no further loss of habitat or habitat effectiveness as a result of commercial development or other human-caused disturbances such as recreational activity, light, and noise.
Protection objectives and targets should be more comprehensive and measurable, and key terms such as “sustainability” and “improved wildlife corridor effectiveness” should be defined in detail.
The Grizzly Bear Habitat Security Model should be refined to address seasonality, degrees of disturbance, and other species of concern, as this is important for science-based planning for resource protection and visitor use management.

Urgency must be stressed within the Plan, and some objectives could be made stronger to reflect this requirement. For instance, the goal “To protect, maintain and recover Bull Trout to self-sustaining populations where recovery is likely, within the Recovery Area” should be modified to say where recovery is “possible,” as allowing populations to further decline outside of the likely recovery areas will contribute to further declines in the species overall. Some action items could also be implemented more quickly than the stated timelines. For example, the goal that “Bull trout are reintroduced to at least one priority water body within the species’ historic range by 2035” could be strengthened to include an additional water body and a faster turnaround.

The action items within this Plan could be more effectively implemented by utilizing the outreach and communications initiatives mentioned. Since Parks Canada is partnering with some digital influencers and content creators to promote conservation knowledge to a new demographic[1], this is an opportunity for increased public involvement in species at risk recovery.

Financial priorities for Parks Canada, including the specific programs and projects and personnel resources that are allocated towards the action items in the Plan, should also be clearly detailed.

AWA supports this Multi-species Action Plan and looks forward to receiving updates once the final Plan has been released. Thank you for considering these comments.

Sincerely,

ALBERTA WILDERNESS ASSOCIATION

Sara Heerema

Conservation Outreach Specialist

References

[1] McCann, M. April 14, 2026. Parks Canada works with social media influencers to shape visitor behaviour in Banff. CBC News.