What we heard summary

Nahanni National Park Reserve

Public Consultation for the Let’s Talk About Commercial Guided River Outfitting in Nahanni
(July 29, 2024 - September 30, 2024)

What we Heard Summary

Nahanni National Park Reserve is conducting a public review of licence quotas and the Náįlįcho Allocation to determine the future 5-year allocation. In January 2019, Nahanni and Nááts’įhch’oh National Park Reserves adopted the Guidelines for Licensing Guided River Outfitting in Nahanni and Nááts’įhch’oh National Park Reserves (the Guidelines). The Guidelines were developed with Indigenous cooperative management partners and included input from stakeholders, and the public. This was the first of its kind for Nahanni and Nááts’įhch’oh and the Guidelines were aimed at securing long term tourism sustainability, as well as integrating principles of adaptive management for commercial guided river outfitting.

Public consultation in the form of a written email feedback commenced July 29, 2024. The deadline to submit feedback was September 30th, 2024. Feedback was summarized into four categories 1) Proposed Selection Criteria for a New Operator; 2) Business Licence Quota; 3) Náįlįcho Allocation; and 4) Other.

Several members of the public expressed support for issuing the vacant Type B business license to make full use of the environmental carrying capacity, encourage healthy competition between operators, and boost the local economy. Others expressed their concerns that an additional license may threaten the sustainability of existing operators. Additionally, comments expressed that the selection criteria for a new operator should prioritize the local economy, Indigenous practices, hiring youth, and respect for the land. A wide range of comments were shared regarding the Náįlįcho Allocation, with some supporting the existing allocations and others supporting significant changes.

 

  • For ease of review, each public comment includes the corresponding Parks Canada response in the adjacent row of the table below. Identical comments are included only once in the table below. All comments will be considered in the review process.

 

Public Comments Parks Canada’s Response

 

Proposed Selection Criteria for a New Operator

 
1. Ensuring safe paddling on remote rivers and providing access for others who could not manage such trips on their own is integral. Parks Canada will only consider licensing competent and proven operators. Safety standards are a key consideration for a new operator, and this is built into licence screening criteria.
2. Supporting youth, local development and businesses, and Indigenous practices are part of what makes an operator desirable. Demonstrating support for local businesses and whether Indigenous practices are incorporated into trips is directly listed as part of the selection criteria for operators. There is also an opportunity to provide supplemental information which would be of relevant interest. Overall business practices are an important part of the selection criteria.
3. Respect for the land and respect for the environment are important selection criteria. Nahanni National Park Reserves are required under the Canada National Parks Act to ensure that visitation does not significantly impact ecological integrity.
4. Parks Canada should consider providing an opportunity for a local NWT business to operate in the park. Under the Canada National Parks Act and National Parks of Canada Business Regulations there are no directives that provide preferential treatment for applicants based on residency. An exception exists regarding a local Indigenous operator who may wish to activate an Indigenous licence. If a notification for new licenses is issued, Parks Canada will consider all applications made including NWT owned businesses.
5. Hiring local, northern staff should be part of the licence considerations. See comment # 2 and #4.
6. Park licenced businesses operating in the NWT should focus on how they can best support and contribute to the local economy first and foremost, not add to the problem of fly-over business that is already prevalent in this Territory. National Parks contribute to sustainable tourism development in the NWT. See comment #2.

 

Other

 
7. How is Parks accounting for trips that were cancelled in 2023? Trips booked but cancelled due to fire closures in 2023 were included in the allocation statistics.

 

Business Licence Quota

 
8. Current licence holders are not fully utilizing their permitted spots, especially in shoulder seasons like June and late August. This indicates that it should be possible for a new operator to attain a licence and contribute to visitor use. Limiting the number of licences and trips is aimed to balance sustainable business operations with ecological integrity, wilderness visitor experience, and respect commitments made with Indigenous partners. Parks Canada will visit the possibility of accepting applications for the fourth Type B licence, with particular views of allocations during the shoulder seasons where allocation usage is currently low.
9. The current allocation data suggests that the environmental carrying capacity of the park has not been reached, meaning that there is room to responsibly grow visitor numbers without harming the park’s ecological integrity. Adding new operators in a controlled way can ensure the park’s sustainability while maximizing its potential. The Guidelines were developed to maintain high standards for quality wilderness experiences.
10. Adding another outfitter would not only harm the existing outfitters but also not necessarily result in increased visitation. See comment #9.
11. Preference that there not be any additional outfitters added to Nahanni National Park at this time. See comment #8.
12 The introduction of new operators could help meet the demand more effectively, improve the visitor experience by offering more diversity in services, and create healthier competition. Limiting the number of licences and trips is aimed to balance sustainable business operations with ecological integrity, wilderness visitor experience, and respect commitments made with Indigenous partners.
13. A more competitive marketplace would offer better trip availability, more flexibility in scheduling, and potentially lower costs for visitors, ultimately leading to a more satisfying experience for those looking to enjoy the wilderness of Nahanni. See comment #12.
14. Guidelines call for four type B licences, but currently, only three are active. Limiting the number of licences increases their value, benefitting existing licence holders, which may not align with the public interest or the interests of Dehcho Communities. In the description of type B licences from the guidelines, existing commercial allocation was serviced by three licences during the first allocation review period. Issuance of the fourth licence is being considered for the next review period.
15. Adding a new outfitter may reduce sustainability for existing outfitters. See comment #12.
16. A new outfitter may distribute visitors between more trip offerings, this could make trips less viable for each outfitter and result in reduced visitation. More but smaller departures would result in less business efficiency, decrease the sustainability of all businesses operating in the region and result in decreased capacity in the organizations that both Parks and the outfitters depend on. Sound business practice and sustainable visitation are the goals of the allocation distribution. Parks Canada will only consider licensing competent and proven operators. Safety standards are a key consideration for a new operator, and this is built into licence screening criteria.
17. It is more and more difficult to run smaller group trips profitably See comment #12.
18. Reduced profitability could impact the ability of outfitters to support local business community, partners, and cultural programming investments. See comment #12.
19. Present outfitters have had a monopoly See comment #12.

 

Náįlįcho Allocation

 
20. Current licence holders would like to see an increased share of allocation. Current allocations were based on historic usage. Parks Canada allocated 50% of arrival days to outfitters and 50% to private users. Parks Canada intends to review the allocations and may choose to reorganize to better accommodate sustainable tourism practices. Parks Canada may reallocate assigned dates to accommodate a fourth license. However, Parks Canada recognizes there are challenges for business sustainability, and outfitters need to plan for the season ahead. Parks Canada recognizes that an increased allocation will potentially benefit a business and a decrease in allocation has potential to negatively impact a business.
21. A decrease in current allocation will negatively impact business and operations and the ability to bring visitors, negatively impacting overall visitation and benefits to the communities. See comment #20.
22. Maintain allocation as is for the next 5-years. See comment #20.
23. Industry “full capacity” is not the literal mathematical maximum but a percentage of industry norms. An operator needs full flexibility in dates to offer in order to meet "full capacity". See comment #27.
24. A more equitable Náįlįcho Allocation Framework- that distributes prime dates more equitably across companies would even the playing field for companies to compete more fairly. Not giving more dates, but more evenly distributed dates would be better. Fully restructuring the allocation framework is not being considered at this time. Current allocations are based on historical usage. Parks Canada intends to review the allocations and may choose to reorganize to better accommodate sustainable tourism practices.
25. Allocation calculations only use the best 3 years, rather than using every year. It would be more appropriate to look at the allocation data from every year. Using the three best years allows for fluctuations outside of a business owners control to not effect their overall allocation statistics. Within the last 5 years the pandemic greatly effected visitation rates the world over.
26. With the 2025 booking cycle already partially complete and 2026 dates shared with clients, changes should not take place until 2026 at the earliest to allow the incumbent businesses time to adjust their business models and to ensure a new operator does the same. Sustainable tourism is a priority. Any significant changes will not take place until 2026 at the earliest.
27. A 50% utilization target seems low. If total allocation is designed to represent the level of long-term tourism sustainability, it is unclear why any usage below 100% would not trigger consideration for an additional licence. A higher utilization threshold would provide a clearer signal that current operators are fully leveraging their allocations, and that the market could support another entrant. We propose that the Nahʔą Dehé Consensus Team consider establishing a more ambitious target, such as 80-90%. Such a target would encourage current outfitters to maximize their allocations and would signal when the market is ready for additional capacity, aligning more closely with sustainable tourism goals. If an 80-90% target had been in place during the current allocation review, the underutilization of existing allocations would be even more evident, strengthening the case for issuing call of proposals on a new licence. It was never the intention that outfitters are required to obtain full capacity on allocation, there is recognition that there is a degree of vacancy that will occur. A threshold of < 50% use of arrival dates is one signal that Parks Canada may carefully review and consider reallocation. The goal of the Guidelines is not necessarily growth in visitation, but a recognition that outfitting accounts for a large part of our visitation and we want that level of visitation to be maintained and sustainable.
28. Allocation segments should be revised to better reflect visitation time periods and natural phenomena like high water at the end of June. Parks Canada recognizes that high water events are more likely in June, however, restructuring the allocation system is not being considered.
29. Efforts to bring visitors to the park outside of the typical season should be rewarded as it helps boost the sustainability of many local businesses (airlines, hotels, boat shuttles). Trips falling before June 15 or after August 30 should be counted towards the June 15 or August 15 allocation usage. Parks Canada recognizes that operating outside of the peak periods can improve overall tourism sustainability. Parks Canada will consider acknowledgement of these trips in allocation statistics, however, fully restructuring the allocation system is not being considered at this time.
30. We should maximize the number of people that have the opportunity to experience Nái̖li̖cho. We should allow more people the honour and privilege of seeing this remarkably unspoiled and uniquely awesome part of the world. See comment #12.
31. Better management of and/or a reduction in the numbers of private trips should become a top priority for Parks Canada. A more formal lottery system or permit system for self guided groups to access to the park is likely necessary moving forward to preserve the wilderness character of Nahanni. Similar to the one for the Grand Canyon (weighted lottery) & other multi-day river trips ensure that not everyone is able to travel at the exact same time, and that the coveted mid-season dates are fairly distributed. Self-guided groups are subject to an allocation and a formal permitting and booking system is in place. A lottery system is not being considered. Parks Canada is working to improve scheduling and booking to reduce any congestion, while acknowledging that visitors require some flexibility due to environmental factors affecting float plane schedules.
32. Currently the split of Nái̖li̖cho departures/allocation is 50-50 between guided and self guided. If another outfitter was offered the chance to guide in Nahanni, this split should be changed to ~60% outfitters-~40% self guided, with the intent that this additional outfitter will replace some of the self guided trips on the river. Parks Canada is considering the allocation use for both guided and private trips.
33. The current statistics do not account for the actual group size on each trip. Trips with minimal participants are counted the same as fully booked trips, potentially overstating the impact on the environment and visitor experience, and ability of existing outfitters to utilize licence allocation. Incentivizing outfitters to run smaller trips with fewer guides/support resources will lead to lower quality experiences and safety issues. See comment #16.
34. It is important for the Consensus Team and Parks Canada to maintain an objective, data-driven process that serves the broader public interest rather than the commercial interests of current licence holders. Parks Canada is following a data-driven process outlined in the Guidelines. The Guidelines were developed with Indigenous cooperative management partners and are aimed at securing long term tourism sustainability and integrating principles of adaptive management.

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