In mid-December, 2022, a new management plan for the Rideau Canal was tabled in Parliament, eight years after an updated plan was legally required to be produced. Despite receiving 50 written submissions during the spring 2021 "consultation" process, more than any Parks Canada site has ever received, Parks Canada chose to ignore most of those informed comments, making the management plan into a pro-forma process. The resulting plan not only does not reflect public input, it also overlooks many of Parks Canada's legislated requirements for heritage protection and presentation of the Rideau Canal. Four issues stand out:
No commitment to heritage interpretation which is a mandated requirement for a National Historic Site of Canada (NHS) run by Parks Canada (part of maintaining the "commemorative integrity" of the site). UNESCO also has a similar requirement for World Heritage Sites (WHS). 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. We were told by Parks Canada 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 The current WHS plan dates to 2006 and is obsolete (way out of date and Parks doesn't follow it anyway).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.
No commitment to Environment Protection - environmental protection, including the ecological intergrity of the Rideau Canal, is a responsibility of Parks Canada since the Rideau Canal is a federally owned waterway. The environmental protection of the Rideau Canal is a jurisdictional mess, which a group of academic researchers, in trying to graph those jurisdictions, called a "horrendogram". The management plan does not provide any clarity or detail Parks Canada's specific responsibilities, many of which they simply ignore.
There are many other issues, including the fact that it's not a management plan by any definition of what a real management plan should look like. Their last plan (2005 - abandoned in 2012) was far better done, it was an actual management plan.
Parks Canada 2022 Management Plan for the Rideau Canal:
The following are comments regarding the draft plan written in 2021. Most of those comments remain valid for the final plan which failed to incoporate
Parks Canada's conducted consultations on a new Rideau Canal management plan from January 26 to May 14, 2021.
Our review of the plan shows that it has deep and substantive issues including a complete failure to meet Parks Canada's heritage and ecological mandates on the Rideau Canal. In addition, it does not address UNESCO's concerns, which were that the management system of the site did not protect the outstanding universal value of the site and requested a new management plan. The following is our submission plus several others, including an extensive submission by Ken Watson and a critique of Parks Canada's management plan format and system by Manuel Stevens, former (retired) Parks Canada planner for the Rideau Canal:
Of note, outside of a requirement for the management plan to address all of Parks Canada's legislated requirements (which it does not), another purpose of the plan is to provide public clarity benchmarks and accountability of how Parks Canada will manage the Rideau Canal on behalf of all Canadians. Does this plan provide you with that required clarity and accountability?
Although the official consultation period has ended, you can still make your views known to the Director of Ontario Waterways, David Britton - david.britton@canada.ca
Parks Canada Management Plans
A management plan is a legislated requirement for Parks Canada. Section 32 of the Parks Canada Agency Act states that Parks Canada will "provide the Minister
with a management plan for that national historic site or other protected heritage area in respect of any matter that the Minister deems appropriate, including, but not
limited to, commemorative and ecological integrity, resource protection or visitor use, and that plan shall be tabled in each House of Parliament."
The timing for updating the plan used to be 5 years but was changed in 2012 to 10 years "The Minister shall review the management plan for each national historic site or other protected heritage
area at least every 10 years and shall cause any amendments to the plan to be tabled in each House of Parliament." The last Rideau Canal management plan was done in 2005, so 2005 + 10 = 2015. We should in fact have had a new plan earlier with the massive management changes done in 2012 (the change to a new Waterways division should have required a new plan), and for sure in 2015 if Parks Canada actually followed its own legislation. But that never happened.
In general terms, the purpose of the plan is to ensure the commemorative integrity of the Rideau Canal National Historic Site, guide appropriate public use, ensure the application of cultural resource management principles and practices in decision-making and conserve the natural values of the Canal. Two of the submissions shown above, those by Ken Watson (submission) and Manuel Stevens (submission), discuss and review the purposes of a Parks Canada management plan.
Bottom line is that it's not supposed to be just a document to be written, it's supposed to be a document that guides management direction and provides for public clarity and accountability for how Parks Canada is managing the Rideau Canal on behalf of all Canadians. The draft plan, first released to the public in late 2020, does not meet any of those requirements.
