Dear Premier Dosanjh,
On behalf of the organizations in our June 27, 2000 letter to the Hon. Premier Dosanjh, we acknowledge your August 4, 2000 letter of reply regarding our request that the provincial government honour and uphold the St'at'imc decision opposing the Melvin Creek ski proposal in the Cayoosh Mountain Range.
However, we are disappointed that after a period of five weeks the Premier's Office has not only failed to provide a reasoned response to the two concerns identified in our letter, but it then referred our letter for a reply from Deputy Minister Sheila Wynn, of the Environmental Assessment Office, a public body which just recommended Cabinet give certificate approval of the four season industrial ski development. The Environmental Assessment Office has already completed its business, and as such the matter of replying on the St'at'imc's decision should be in the hands of the Premier and his Cabinet, not otherwise.
The St'at'imc government, which has rights and title to the area in question, have said "no", a decision which is more than just a "relevant issue" for the ministers to consider on their August 14, 2000, determination. In addition, the Environmental Assessment Act policy process has been limited under the Melvin Creek Project Committee when it comes to meaningful consultation with the St'at'imc. A recent related example of this was publicized between the Environmental Assessment Office's Tulsequah Chief Project and the Taku River Tlingit First Nation, where the court quashed the final certificate approval for the mine because the review process was deficient under the Act as it "did not conform to legal requirements", a ruling which your government is appealing.
With regard to the Melvin Creek Project Committee's final report to the Ministers, there is an outstanding deficiency in the wildlife section regarding grizzly bears. Since November 1999, this issue was highlighted in SPEC's and a grizzly bear biologist's reports and letters to the Environmental Assessment Office (www.spec.bc.ca/melvin/). It is apparent, from government files and recent political manouevres by provincial administrators who negotiated with the federal government's Environment Ministry (May-June 2000), that they may have conveniently circumvented the federal process to conduct proper studies on grizzly bears by means of a recent provincial government biologist's report. Because of the controversial emphasis of this report, provincial ministries signed a Memorandum of Understanding, which advocates various forms of "mitigation" as the end-all buzz-word for grizzly bear management in the area. It is impossible to understand the mitigation of impacts to grizzly bears in the greater Cayoosh Range, because there were no studies conducted on grizzly bears. Considering the fact that the Enviro- mental Assessment Office conducted a lengthy grizzly bear study for a similar ski proposal in Jumbo Creek near Invermere, this makes us question why a grizzly study for the Cayoosh area was overlooked.
And it is equally impossible to understand the impacts over time to grizzlies, and other wildlife species, if the government has failed to conduct a cumulative impact assessment. Quite conveniently, and aside from federal legislation, there is no provincial legislation which mandates a cumulative impact assessment outside of the physical boundaries of the proposed industrial development in Melvin Creek. This is yet another critical deficiency in the present process for an area designated as a grizzly bear recovery zone.
Another concern we have is related to the recent development proposals in the proximity of the Melvin Creek drainage. Ten years ago the Kamloops Regional Ministry of Environment advocated against any and all commercial development referrals in the greater Duffey Lake area to the Ministry of Crown Lands (BCAL). We understand there are at least three or more recent snow cat and heli-ski/heli-hiking proposals before BCAL in the greater Cayoosh Range. The Melvin Creek resort is a trigger for other developments which will bring enormous stress and pressure on the greater Duffey Lake area.
From surveys recently conducted by the St'at'imc at their demonstration camp near Melvin Creek, they consistently indicate that many British Columbians, Canadian and international visitors are opposed to the ski development project. About 50% of those stopped on the roadside (July 27, 10:30 am - 5pm, approx. 600 vehicles; and August 3, 10:30 am - 3:30 pm, approx. 600 vehicles) signed a petition in support of the St'at'imc to oppose the four season ski proposal, and a strong remainder indicated that they would consider the information and would make up their mind later. European visitors also expressed concerns about the negative impacts of ski resorts in Europe, and were very supportive of keeping the Cayoosh corridor undeveloped. This survey is critical for the provincial Cabinet's imminent decision on this matter, and should indicate that the public have a separate position on this proposal from the recom- mendations presented to you by the Environmental Assessment Office, and related support by BCAL.
We recognize that you and your Cabinet are in a difficult position given the reckless support of this project by your predecessors. However, it is not too late to reconsider the serious cultural, ecological, and political implications associated with this ski proposal. The message is clear, and your opportunity is simple, since the proponent, NGR Resort Consultants Inc., has promised to withdraw from the proposal if the St'at'imc say "no".
We therefore urge you and your Cabinet to:
* recognize and support the St'at'imc decision against the project;Sincerely, Will Koop, SPEC researcher.
* acknowledge the fact that there is a deficiency in the Environmental Assessment process because there were no grizzly bear studies conducted in the area;
* acknowledge that there has been no scientific study on the cumulative impacts to wildlife and ecosystems in the greater Duffey Lake area as a result of the Melvin Creek ski resort proposal and related development applications;
* take advantage of the proponent's promise to withdraw his proposal.
cc. St'at'imc
Cabinet Ministers