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Rideau Canal Management Plan
A legislated requirement for Parks Canada is to create a management plan for each of its sites on a 10-year cycle (originally a 5 year cycle - changed in 2012 to a 10-year cycle) or when a significant change to the management system of the site is made. UNESCO's requirement is for an up to date management plan for any World Heritage Site.
In December 2022, Parks Canada released a new management plan, replacing the last plan which was done in 2005. A new plan for the Rideau should have been done in 2010 (based on the then 5-year cycle), in 2012 after the massive management and policy direction change or, for sure in 2015 to meet the then 10 year legislated requirement. But Parks Canada did nothing. The bottom of this page documents that sad tale.
Outside of the fact that it's not actually a management plan (in structure) and that Parks Canada doesn't actually follow its management plans (detailed below), the 2022 plan has some very significant issues. Three of those are:
In 2021, I made an extensive 100 page submission regarding the then draft plan, focussed primarily on the legislative requirements under the Parks Canada Agency Act for Parks Canada to protect and present the cultural and natural heritage of the site - legal requirements that Parks Canada is not following on the Rideau Canal. Parks Canada received 49 other written submissions - most focussed on cultural heritage and environmental issues (my submission covered both those aspects). Parks Canada has simply ignored most of that input, which confirmed by original belief that they were doing the management plan as simply a pro-forma process.
- No commitment to do heritage interpretation which is a mandated requirement for a National Historic Site of Canada run by Parks Canada (part of maintaining the "commemorative integrity" of the site). UNESCO also has a similar requirement for World Heritage Sites. Parks Canada does not provide heritage interpretation resourcing for the Rideau Canal.
- No commitment to maintain the built heritage fabric of the Rideau Canal - again, this is a legislative requirement (also part of maintaining the "commemorative integrity" of the site). In the plan, Parks Canada states "By 2032, at least 70 percent of engineering works of national significance are maintained in fair or good condition." So, right off the bat Parks Canada is saying that having up to 30% of the engineering structures in poor or worse condition is okay. And, significant in its omission, is a commitment to maintaining non-engineering heritage structures (i.e. blockhouses, lockmaster houses, etc.).
- No commitment to meet any UNESCO World Heritage Site Requirements - UNESCO requirements are notable by their complete absence in this plan. I was told by Parks Canada back in 2018 that the new plan would be a combined NHS and WHS plan. The current WHS plan dates to 2006 and is obsolete (way out of date and Parks doesn't follow it anyway). In 2019, UNESCO wrote a letter of concern to the Government of Canada, stating in part that "the management system for the property does not currently provide adequate protection to the OUV [outstanding universal value] or the setting thereof". The 2022 plan does not address that concern or other World Heritage Site requirements (I've detailed UNESCO requirements in my submission to the draft plan).
Also very troubling is that it shows that Parks Canada lied to UNESCO in their response to UNESCO's 2019 letter of complaint. In Parks Canada's response (letter dated February 5, 2020) they stated "With respect to ICOMOS’s recommendations for updated management planning, I am pleased to confirm that Parks Canada is in the process of renewing the Rideau Canal National Historic Site Management Plan (completed in 1996, updated in 2005, and slated for renewal by December 2020)." So, here we are with a new plan in December 2022, with none of UNESCO's issues addressed in it. Parks Canada is well known for having a poor track record when it comes to managing its WHS sites, but this is in the extreme.
I am not going to analyse the new plan to the depth I did for the draft plan since 95% of my comments still stand (not addressed in the new plan). I've left the draft plan comments on this page (below) since it shows the discussions and timelines that went into the losing battle to have Parks Canada operate the Rideau Canal as a heritage site.
Parks Canada 2022 Management Plan for the Rideau Canal:
Rideau Canal Management Plan (2022)
For comparison, here is the far better done 2005 plan, a plan that was mostly abandoned by Parks Canada in 2012: 2005 Rideau Canal Management Plan
Information regarding input in 2021 into the
It's a long and sad tale. Parks Canada received 50 written submissions regarding the draft plan, more than any other Parks Canada site has ever received (including other large sites such as Jasper and Banff national parks). Parks Canada chose to ignore most of that input, making the "consultation" process simply a pro-forma process. While the final plan does show some small tweaks in response to the huge input by the informed public and other government agencies (i.e. NCC), it remains highly flawed. That written input all said, in a nutshell, that Parks Canada's priorities should be cultural heritage protection and presentation, and environmental protection and presentation - both are legislated requirements of Parks Canada - requirements they are essentially ignoring on the Rideau Canal.
new "management plan" for the Rideau Canal
Another significant problem is that while Parks Canada has a legislated mandate to create a management plan, there is no legislative requirement that they follow one. We have a very well documented example on the Rideau Canal of the fact that Parks Canada does not follow its plans. Time will tell if the new plan is simply empty words on paper, or whether Parks Canada will follow the plan.
Official Submissions to Parks Canada:
Letters regarding the management plan:
Replies to Letters regarding the management plan:
- UNESCO - Reply on May 5, 2021 - short note to say the letter triggered "Paragraph 174 of the Operational Guidelines for the Implementation of the World Heritage Convention." This is the protocol that the state party (Canada) gets to respond to UNESCO regarding the complaint. We'll see if Parks Canada will be honest with UNESCO in their reply.
- PM Trudeau - Reply on May 10, 2021 - short letter from PMO to say it has been sent to the Minister of Environment and Climate Change to deal with.
- Hon. J. Wilkinson (Minister of Environment & Climate Change) - never received a reply. This is typical, the Minister (whoever at the time) generally never replies (not just my problem, Friends of the Rideau has that same issue).
- Ron Hallman (CEO of Parks Canada) - Reply on May 19, 2021 - Mr. Hallman, who controls the resourcing and policy direction of the Rideau Canal, clearly doesn't care about Canadian history or the environmental health of the Rideau Canal. His 1 page reply didn't address any of my issues of concern. You can read his letter here.
Management Plan Chronology - A Sad Tale of Ineptitude
This would almost be funny if you didn't consider the huge amount of public dollars wasted in this process which could have been done far more efficiently.
- 2010 - initial work starts on a new plan given the 5-year mandated cycle at that time (from the last 2005 plan). Parks abandons this effort as behind the scenes they are starting to re-design the management of the Rideau Canal, and other historic canals, into a new Waterways unit that will be focused on tourism and recreation, not on cultural heritage and environment.
- 2012 - the Rideau gets hit with the double whammy of a brand new management structure (being overseen by a Director of Ontario Waterway - no more Superintendent position) and a 40% cut to its operating budget as a result of a government mandated 5% cut to Parks Canada (canals got hit the hardest in the cuts). The change in management structure should have required a new management plan - nothing was done.
- 2012 - also in 2012, the Government of Canada changes the Parks Canada Agency Act to go from a 5-year management plan cycle to 10-years. This re-sets the legislated requirement for a new plan for the Rideau Canal NHS to 2015.
- 2015 - the 10-year legislated requirement for a management plan update comes and goes with nothing done.
- June 2016 - several open houses are held as preliminary consultations for a new management plan. Plan is scheduled to be completed in 2017.
- October 2016 - the management planning process has been extended for another year. The new deadline is March 2018.
- May 2017 - plans for pre-draft consultations in 2017 have been dropped by Parks Canada. A new deadline of March 2020 has been set.
- February 2018 - on short notice, small group consultations about the new management were held. These were well structured and provided a reasonable forum for input by the informed public and other government agencies (i.e. NCC, Ontario Parks). General public consultations are now scheduled for summer 2018 (within the prime navigation season to properly capture boater input)
- August 2018 - a letter from Director Jewel Cunningham noted that public consultations are now scheduled for "late summer 2018"
- September 2018 - an email from the heritage planner, Susan Millar, stated that public consultations are now delayed until 2019.
- June 2019 - the management plan has been delayed yet again. Public consultation is now set for spring/summer 2020.
- April 2020 - the management plan is now delayed due to COVID-19.
- December 2020 - Parks Canada sends an incomplete plan (section 7 not included*) to several groups on the Rideau Canal - the covering letter contained no information about the planning process itself other than consultations will take place from January to March, 2021.
- January 26, 2021 - the "rideauplan.ca" site is opened to the public. It contains a fluff visitor survey and has no background information about the plan (reasons for the plan, structure, etc.). It appears designed simply to collect metrics rather than real information.
- March 30, 2021 - Parks Canada extends "consultations" to April 30, 2021 (their Rideau Canal website continues to show a March 31, 2021 deadline).
- April 29, 2021 - Parks Canada extends "consultations" to May 14, 2021 (their Rideau Canal website continues to show a March 31, 2021 deadline).
- January, 2022 - In late January, Parks Canada releases a "What We Heard" report regarding their spring 2021 "consultations". It was a PR document (Parks essentially admitted this) which relied heavily on their fluff on-line surveys, rather than the 50 written submissions (it was not representational of the input they received). At other large Parks Canada sites (i.e. the mountain parks), a What We Heard report is released between initial round table consultations and the consultations on an actual draft plan, since those initial round table consultations are supposed to be reflected in the draft plan. On the Rideau, there were initial round table consultations (see Feb 2018 above), but none of that ended up in the draft plan (one of our major complaints about the plan). So here, Parks Canada put a large amount of their limited resources into doing a What We Heard report which had no use other than to put a PR spin on their public consultations to make them reflected the result they want.
- December 14, 2022 - Steven Guibeault, the Minister of Environment and Climate Change Canada, who is in charge of Parks Canada, rubber stamped the plan and tabled it in Parliament (as required for all Parks Canada management plans). It was one of 5 management plans that Mr. Guibeault tabled that day.
* Section 7.0, which is the Summary of Strategic Environmental Assessment, is a requirement for any federal plan (essentially a mini environment assessment of the plan). Parks Canada forgot to put this into the original draft plan that was distributed in December 2020. It's unclear when they added it, since they didn't bother to inform those who received the original draft plan that didn't have Section 7.0. I found out about it by chance in a video meeting in early March when they happened to mention it. In Section 7.0 they state "Indigenous partners, stakeholders and the public will be consulted on the draft management plan, including a summary of the draft strategic environmental assessment." As I noted to Parks Canada in my review, they failed to meet that requirement. It's just one example of how badly they've mishandled this process.
A FEW MAJOR PROBLEMS
Outside of the actual content of the plan, there are a few significant problems:
It's not an Actual Management Plan
The current "high level" plan is not a management plan by anyone's definition outside of the Parks Canada Agency. The plan format was stripped down, staring in 2008, by then CEO Alan Latourelle who didn't want Parks Canada to be bound by detailed plans. This started a downward spiral of the plan. It ended up in 2014 as the format we see today - designed not for management guidance, but as a simplified document to meet the minimum requirements to create a plan.
It doesn't meet any international standards for a protected site management plan. It doesn't provide the required public clarity and accountability for how Parks Canada will manage the Rideau Canal on behalf of all Canadians, a fundamental requirement of any Parks Canada management plan. I have that detailed in my critique of the plan and Mr. Manuel Stevens, retire Parks Canada planner for the Rideau Canal wrote an extensive critique of the plan format itself.
Parks Canada Does Not Follow Its Management Plans
A significant problem outside of the format and content of the new management plan is that Parks Canada does not actually follow their management plans. We have a very well documented example of that on the Rideau Canal when significant portions of the existing 2005 plan were simply abandoned in 2012 with no accountability. The massive management changes, including a large shift in policy direction (to operating the canal as a simple recreational waterway - abandoning their heritage mandates) was done with no (zero) public consultation and it threw out much of the 2005 plan.
Parks Canada has no internal accountability when it comes to management plans and there is no external accountability. That's an extremely serious issue, one that the Government of Canada should pay attention to. Parks Canada appears to be exploiting a loophole in their legislation (Parks Canada Agency Act) which requires them to produce a management plan but doesn't actually say they have to follow the plan they create (it's implied and they used to follow their plans, but that changed in the mid-2000s).
A Pro-Forma Process
In January 2018, small group roundtable consultations were held on the scoping document (pre-cursor to a new management plan). These were in fact quite well done and a wide range of the engaged public and other government organizations participated in the process. But none of that ended up in the draft plan that showed up almost 3 years later - Parks Canada simply ignored those consultations and wrote the plan the way they internally wanted to.
The fact that they completely ignored this input doesn't bode well for the 2021 "consultations". It's a significant worry of myself and others that Parks Canada will produce a "What We Heard" document (simply done to produce a public perception that they listened to public input) and then write the final plan the way they want to. Since the new Rideau management plan is going to require a substantive re-write based on public input (plus of course adding all the UNESCO requirements), we will see how real this process is, or whether it's just a sop to the public.
A request by myself and many other people and organizations is to be able to see a Draft 2 of the plan that actually incorporates public input and the UNESCO requirements that are completely absent from the current draft plan. Parks Canada has refused to do this for the Rideau Canal. It's to be noted that the Mountain parks got this 2 stage process. A "What We Heard" document was produced from initial consultations and the draft management plan for each park can be measured against that public input. We got no such "What We Heard" from the January 2018 consultations. I'm not a fan of the Parks Canada "What We Heard" documents since they are self-serving cherry picked results, but still, it's better than having no documentation at all of those initial public consultations.
In 2010-11, Parks Canada made an internal decision (no public consultation) to dramatically change the management of its heritage canals, to operate them as simple recreational waterways, abandoning their heritage mandates to these sites, including their most significant heritage canal, the Rideau Canal (the only one with a World Heritage Site designation). This was rolled out in 2012, the same year that the Government of Canada imposed cuts on the operating budget of Parks Canada. Parks Canada chose to make those cuts to heritage (cultural and natural), purging the organization of most of its cultural heritage capacity (all sorts of heritage people were let go). As a percentage, the heritage canals took the biggest cuts in all of Parks Canada. This goes to the priority Parks Canada places on its heritage canals, which is right at the bottom, there are no heritage canal champions within Parks Canada today (essentially no heritage champions at all in Parks Canada these days).
The draft management plan that we first saw in December 2020, could have been written in 2012, in fact that's how I characterize it, it's a 2012 management plan. It would have received the same massive public push back on the Rideau Canal as the current draft plan is now receiving. But it reflects the management structure currently in place, a structure that will have to be dramatically changed if Parks Canada is to return to their legislated requirements on the Rideau Canal. Everyone in the cultural and natural heritage community of the Rideau Canal are of a common voice in telling Parks Canada to return to their legislated mandate on the Rideau Canal.
To return to its legislated mandate Parks Canada will have to change its current management structure for Rideau Canal and properly resource the canal to meet its legal heritage requirements. UNESCO characterizes resourcing of a site as human, financial and intellectual. The current management structure of the Rideau Canal falls far short on all three. So, even if a management plan is re-written to incorporate these, it will be moot unless Parks Canada makes those required management changes and provides sufficient resources; human, financial and intellectual, to the Rideau Canal.
This is not actually a battle with regards to a very poorly done management plan, it's a battle to have Parks Canada operate its heritage canals as exactly that, heritage canals. When Parks Canada was handed control of these canals from Transport Canada it came with a government directive for “a shift in emphasis in the management of the canal systems from "transportation" to historic restoration, preservation and interpretation; natural environment preservation and interpretation and the optimum use of federal lands.”
In 2012, Parks Canada rolled the canals back to the Department of Transport era - we need to be looking forward into the 21st century with the Rideau Canal, not backwards.
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