April 28, 2000
Matt Austin
Large Carnivore Specialist,
Wildlife Branch,
Ministry of Environment, Lands & Parks
Executive Summary
Based on my review of the documentation it is my opinion that the Melvin Creek/Cayoosh Project, including the mitigative measures that the proponent has committed to implementing, has the potential for substantial direct and cumulative impacts to the Stein-Nahatlatch grizzly bear population and to the potential to recover this threatened population in the future. I believe, however, that these impacts could be substantially addressed through a number of additional mitigative measures and, provided that a comprehensive mitigation package was implemented, may result in no net impact to the population.
It is important to note that the most substantial of the mitigative measures discussed are within the prerogative of the provincial government as opposed to that of the proponent. All of the mitigative measures that are adopted should be clearly established and binding prior to the construction and operation of the project and should be complemented by an adaptive management approach in which the results of an effective monitoring program influence the implementation of these measures.
Purpose
This analysis of the potential impacts of the proposed Melvin Creek/Cayoosh Project (“the project”) on the local grizzly bear population has been prepared in response to a request from Fisheries and Oceans Canada as part of its responsibilities under the Canadian Environmental Assessment Act. This report is based on the opinion of the author following my review of the available documentation on the project and after discussing the issue with relevant staff of the Ministry of Environment, Lands & Parks.
Background
The project is located within the 7 515 km2 Stein-Nahatlatch Grizzly Bear Population Unit (GBPU). Although the Melvin Creek drainage itself is only approximately 30 km2 the project has the potential to have impacts over a much larger surrounding area unless effective mitigative measures are implemented.
The Stein-Nahatlatch is one of nine GBPUs in the province that have been designated as “threatened” under the Grizzly Bear Conservation Strategy (GBCS) (Figure 1). This population was identified as being threatened during the summer of 1998.
[Figure 1. The Conservation Status of Grizzly Bear Population Units in British Columbia (to be provided later)]
The process for designating GBPUs as threatened under the GBCS involves comparing the currently estimated population against the minimum capability of the GBPU to support grizzly bears. Any GBPU where the population is estimated to be less than 50% of the minimum current habitat capability is considered threatened. This process has been reviewed by the Grizzly Bear Scientific Advisory Committee which is appointed by the Minister or Environment, Lands & Parks and is comprised of grizzly bear experts both within and outside of the provincial government. Recovering threatened populations is a critical part of achieving the first goal of the GBCS which is “To maintain in perpetuity the diversity and abundance of grizzly bears and the ecosystems they depend upon throughout British Columbia.”
It is estimated that the habitat capability of the Stein-Nahatlatch GBPU is 189-318 grizzly bears. The current population estimate for the GBPU is 67 or 36% of the minimum habitat capability. Although a detailed review of the reasons for the current status of this GBPU has not yet been undertaken, the most significant forces that have resulted in the population being threatened are habitat alteration, human-caused mortality and the loss of habitat effectiveness (the ability and/or willingness of grizzly bears to use habitat) due to human disturbance.
Threatened GBPUs are closed to grizzly bear hunting, will each have a recovery plan prepared and implemented (the launching of the first pilot recovery plan for the North Cascades GBPU was announced by the Minister of Environment, Lands & Parks in July, 1999 and is nearing completion) and are a focus for any other conservation actions under the GBCS.
The designation of a grizzly bear population as “threatened” also has implications for forestry and land use planning. Within the Identified Wildlife Management Strategy (IWMS), under the Forest Practices Code Act, Wildlife Habitat Areas can be created to protect critical habitats within threatened GBPUs. The IWMS also includes Higher Level Plan Recommendations for grizzly bears (grizzly bears are one of only three species that have been formally recognized as requiring consideration through strategic land use plans) that clearly state that government will only present options to a planning table that will ensure that populations do not become, or remain, threatened. The following quote is excerpted from the Higher Level Planning Recommendations:
“…government will develop a series of options for the management of grizzly bear habitat for the planning table’s consideration… These options will not include a scenario that results in a population becoming or remaining threatened throughout the population unit.”While this direction does not apply specifically to environmental assessments, it illustrates that the provincial government has recognized the need to ensure the conservation of threatened grizzly bear populations.
The proponent has acknowledged that the Melvin Creek drainage contains highly suitable habitat that is currently subject to relatively little human disturbance. This represents an ideal combination of circumstances for grizzly bears and, in fact, grizzly bears and grizzly bear sign have been documented in this area including an adult female with cubs in 1997. The sighting of an adult female with cubs so recently is particularly noteworthy as the survival and reproductive success of the small number of adult females present in threatened populations such as the Stein-Nahatlatch are critical to their maintenance and recovery.
Although it is unclear at this time how much of the Stein-Nahatlatch GBPU is in core area condition (defined as any area >500 m from an open road), over 99% of the Melvin Creek drainage is currently core area which grizzly bears, and in particular adult females, have been found to use disproportionately to their occurrence on the landscape.
In considering the potential impacts of the project it is important to recognize that recreational use of the area surrounding the project is already increasing. Given the profile of summer visitors to the proposed resort provided by the proponent, a minority of guests are expected to participate in backcountry recreational activities outside the Melvin Creek drainage. It is reasonable to expect, however, that recreational use of the surrounding area will expand incrementally as a result of the project in the absence of additional mitigation on the part of the provincial government. The extent of this incremental increase is difficult to predict. It is also important that the potential for increased recreational use of the surrounding area by staff and residents is also acknowledged.
The Stein-Nahatlatch GBPU is surrounded by three other threatened populations: South Chilcotin Ranges to the north, Garibaldi-Pitt to the west and North Cascades to the southeast. The North Cascades GBPU is the British Columbia portion of the cross-border North Cascades grizzly bear population which is listed as “threatened” under the Endangered Species Act in the United States. The only potential linkages between the very small (approximately 20) grizzly bear population remaining in the North Cascades and any other grizzly bear population is with the Stein-Nahatlatch GBPU.
Potential Project Impacts and Mitigation/Compensation Options
Mortality Risk Within the Melvin Creek Drainage
Potential Impact Without Additional Mitigation/Compensation
This project has the potential to result in direct human-caused mortality
of grizzly bears due to actual or potential bear-human conflicts within
the Melvin Creek drainage. As acknowledged by the proponent, this
project has the potential to serve as a “population sink” if grizzly
bears are attracted, and able to gain access, to non-natural foods such
as garbage. Under those circumstances bears would be expected to
quickly become food-conditioned and the most likely result would be conflicts
with people and a very high risk of these animals being destroyed in order
to protect property and public safety. This is of particular concern
because the loss of individual animals will have a greater conservation
impact on a small, threatened population such as the Stein-Nahatlatch as
opposed to a large, healthy population.
Options for Additional Mitigation/Compensation
Proponent
Given the considerable information available on the measures to reduce
bear-human conflicts, it is my opinion that the implementation of a comprehensive
bear management plan by the proponent could substantially address this
issue, resulting in a small residual increase in grizzly bear mortality
risk in the Melvin Creek drainage. The proponent has already committed
to preparing a bear management plan acceptable to the Regional Fish, Wildlife
& Habitat Manager, however, further discussions are required with the
proponent regarding a commitment to the scope and content of this plan.
Most of the elements of a suitable bear management plan are mentioned elsewhere
in this document.
Government
Mitigation of this impact should be the responsibility of the proponent.
Potential Impact With Additional Mitigation/Compensation
In order to potentially achieve no net impact to the Stein-Nahatlatch
grizzly bear population as a result of increased mortality risk in the
Melvin Creek drainage the bear management plan would need to be sufficiently
comprehensive (e.g. addressing infrastructure issues such as garbage collection
and storage) and would need to be implemented effectively. In addition,
efforts to reduce mortality risk would need to be taken elsewhere in the
GBPU to offset the remaining residual mortality risk (see below).
Mortality Risk Outside the Melvin Creek Drainage
Potential Impact Without Additional Mitigation/Compensation
Increased recreational activity in the surrounding area has the potential
to increase the risk of human-caused mortality for grizzly bears in these
areas by increasing the potential for encounters between people and grizzly
bears as well as opportunities for grizzly bears to become conditioned
to human foods or garbage.
Options for Additional Mitigation/Compensation
Proponent
It is largely beyond the direct control of the proponent to address
bear-human conflicts and other causes of human-caused mortality outside
the Melvin Creek drainage, however, the proponent could contribute towards
efforts to reduce bear-human conflicts in the surrounding area (e.g. educating
visitors to the area and providing bear-proofing garbage cans etc.).
Government
If steps are taken to address the deterioration of habitat effectiveness
in areas outside of Melvin Creek (see below) this impact could also be
reduced.
Potential Impact With Additional Mitigation/Compensation
In order to potentially achieve no net impact to the Stein-Nahatlatch
grizzly bear population as a result of increased mortality risk outside
the Melvin Creek drainage efforts to reduce bear-human conflicts through
education and improvements in infrastructure would need to be increased
and measures to limit human activity in these areas would need to be adopted.
Habitat Loss and the Deterioration of Habitat Effectiveness Within the Melvin Creek Drainage
Potential Impact Without Additional Mitigation/Compensation
The project will result in the direct loss of grizzly bear habitat
as well as a dramatic deterioration in the effectiveness of the remaining,
currently highly effective, grizzly bear habitat in the Melvin Creek drainage.
This habitat may be playing a role in supporting some of the limited number
of animals remaining in this population and, even if it is not, could help
to support grizzly bears in the future.
Options for Additional Mitigation/Compensation
Proponent
I believe that any foreseeable attempt to directly mitigate the impact
of habitat loss and the deterioration of habitat effectiveness within the
Melvin Creek drainage on grizzly bears has a low likelihood of success.
Even if steps could be taken to mitigate this impact, this would only be
meaningful if grizzly bears actually made use of this habitat, which could
be expected to result in an increased mortality risk for these animals
(see above).
Given that mitigation of this impact within the Melvin Creek drainage is not be desirable, an alternative is off-site habitat enhancement within the Stein-Nahatlatch (e.g. prescribed burning or access management). This off-site mitigation should be negotiated with the Ministry of Environment, Lands and Parks. A commitment from the proponent to undertake and/or fund off-site mitigation should be in place prior to project certification.
Government
Mitigation of this impact should be the responsibility of the proponent.
Potential Impact With Additional Mitigation/Compensation
In order to potentially achieve no net impact to the Stein-Nahatlatch
grizzly bear population as a result of habitat loss and the deterioration
of habitat effectiveness within the Melvin Creek drainage it would be necessary
for the impact within the drainage to be counter-balanced with off-site
mitigation as described above.
Deterioration of Habitat Effectiveness Outside the Melvin Creek Drainage
Potential Impact Without Additional Mitigation/Compensation
The project has the potential to result in the deterioration of habitat
effectiveness in a large area surrounding the project (i.e. the northern
portion of the Stein-Nahatlatch GBPU) due to increased human activity.
For example, the proponent has acknowledged that the project “will
contribute to an increase in new back country (sic) opportunities in the
Cayoosh Range where access has been previously limited by the lack of roads.”
Since that time the proponent has made commitments (see below) to measures
that will reduce the movement of people from the project directly to surrounding
drainages that partially address this issue.
The geographic scale of this impact is dictated by the areas that would be expected to receive increased use by visitors, residents and staff. For non-commercial recreational activity that would include areas within a reasonable driving distance for day trips (e.g. roads and trails accessed directly from Highway 99 between Mount Currie and Lillooet). For commercial recreational activity that would activities originating from locations within a reasonable driving distance from the project (see above) that occur within the northern portion of the Stein-Nahatlatch GBPU (e.g. the area north of the Stein River and Lizzie Creek to Seton Lake, Anderson Lake and the road from Mount Currie to D’Arcy).
It is my opinion that the potential deterioration of habitat effectiveness in the area surrounding the project resulting from increased human activity represents a significant impact to this threatened grizzly bear population. I believe that this effect has the potential to impact the likelihood of this population recovering in the future unless additional mitigative measures are adopted.
Options for Additional Mitigation/Compensation
Proponent
The proponent has committed to measures to reduce recreational activity
in areas outside of the Melvin Creek drainage that originate directly from
the proposed resort (i.e. people hiking, biking, riding horses or driving
motorized vehicles from the resort into neighbouring drainages) which,
if effectively implemented, will partially address the component of this
issue that is under the proponent’s control. To date the proponent
has committed to:
The proponent could also potentially contribute toward efforts by the provincial government to mitigate this impact (see below).
Government
The potential impacts to grizzly bears resulting from increased human
activity in the area surrounding the project that does not originate directly
from the proposed resort (i.e. guests and staff using the existing road
and trail network to access the surrounding area) is the responsibility
of the provincial government to address. Mitigative measures that
could be applied by the provincial government to reduce this impact include
placing a restriction on the issuance of commercial recreation tenures
and managing access in the area surrounding the project through road deactivation,
gating and/or legal restrictions under the Wildlife Act or the Forest Practices
Code Act.
Potential Impact with Additional Mitigation/Compensation
In order to potentially achieve no net impact to the Stein-Nahatlatch
grizzly bear population as a result of the deterioration of habitat effectiveness
outside the Melvin Creek drainage, it would be necessary to prevent, and
where prevention is not practical to offset, the incremental increase in
human activity as a result of the project in the surrounding area through
access management and a restriction on the issuance of commercial recreation
tenures.
Monitoring and Adaptive Management
Applying an adaptive management approach, consisting of monitoring as
well as an effective feedback mechanism that will allow the results of
this monitoring to influence the implementation of any mitigative measures
adopted, will be critical given the uncertainties and complexities involved
in mitigating the impacts of a project of this nature on grizzly bears.
A monitoring plan that includes these principles should be completed
prior to the construction and operation of the project.