June 12, 2000

Hon. David Anderson
Minister of Environment
Rm. 133, East Block
House of Commons,
Ottawa, ON.
K1AOA6

Hon. Harbansingh Dhaliwal
Minister of Fisheries & Oceans
Rm. 121
House of Commons,
Ottawa, ON.
K1AOA6
 

Re: Recent B.C. Minister of Environment Analysis of Proposed Cayoosh Ski-Townsite Development near Lillooet, B.C. By Matt Austin, Large Carnivore Specialist.

Dear Sirs:

I very much appreciate that some of the Federal Government's Cumulative Effects guidelines have been brought to bear on this mega-project. I am a professional bear biologist who has carried out an independent review of most of the relevant documents related to the very large Cayoosh townsite-ski development. My  review  is based on 35 years' experience as a professional biologist who has studied goat and bear biology, habitat and environmental impacts extensively.  My work includes two detailed grizzly/black bear habitat mapping projects in the same ecosystem as the proposed Cayoosh Resort Project, preliminary grizzly bear mapping of the Lillooet Planning Area Ecosystem (fragmentation, movement corridors and core wilderness areas), and my experience as a former member of the B.C. Minister of the Environment's Grizzly Bear Scientific Advisory Committee.

I have made a number of recent submissions to the B.C. Environmental Assessment Office on this development.  My conclusion has been that both the scale and scope of this project, to be built in prime grizzly habitat at higher elevations, would cause significant and irreversible cumulative effects on the regional grizzly bear population and other wildlife.

I was pleased to see that the B.C. Ministry of Environment's Grizzly Bear Review generally concurs with my major concerns that this development threatens this grizzly population and the grizzly bear recovery plan.  You should also note that a 1999 sign-on letter by 10 independent bear biologists to the Lillooet Land & Resources Management Plan Table recommended that 40-60% of the region will need to be protected if grizzlies are to be recovered, "otherwise extinction within the next several decades is a reasonable scenario".  The Cayoosh Range is one of the proposed protected areas that could help grizzly bears recovery in the region.  It is, however, my opinion and that of other independent biologists that the proposed Cayoosh mega-development will tip the scales towards final extinction and that opportunities for mitigation are extremely limited.

I therefore strongly disagree with the MOE-Matt Austin opinion that these impacts can be mitigated with no net impact to the grizzly population.  This is highly speculative since there is no development of this scale in North America that has been built within prime grizzly bear and other wildlife habitat that has an track record of not causing significant negative impacts and long-term cumulative effects.

I therefore recommend that a 2 - 5 year moratorium be instituted.  A more adequate and comprehensive cumulative effects analysis using the best available science should be completed encompassing all probable and potential impacts, including much more comprehensive field studies of the habitats, movements and population levels of mountain goats, wolverine, grizzly bear and other species.  This should be related to an in-depth impact/cumulative effects analysis for the whole Lillooet Ecosystem. This analysis should be coordinated and peer-reviewed by an independent panel of wildlife experts and be subject to full public hearings.

Until such research is done, any claims for no net loss of grizzly bears through mitigation has little basis in the established reality for the following reasons:

1.  Access control

Mr. Austin ignores that control of access on public lands in B.C. has a very poor track record.  B.C. legislation is weak and often unenforceable in this regards.  Mr. Austin also grossly underestimates the potential for recreation use that would be generated from such a large-scale development as Cayoosh. Backcountry recreation and commercial use could easily exceed that of the facility itself during the summer months.  Much of this would be uncontrollable.  Secondly, backcountry commercial operations are not adequately controlled or monitored in the province and there are numerous applications in that area and would be many more to follow once the large resort is built.

2.  Impacts of road improvements and increased traffic

A major flaw is that Mr. Austin fails to address the obvious impacts of improved highway access and associated increased traffic volumes on regional wildlife populations (grizzly bears, wolves, wolverine, etc.). This will be significant. including roadkill mortality, displacement, and a major fragmentation effect of the north-south linkage corridor between Coast Mountains and Cascades Recovery Areas for grizzly bears in s.w. British Columbia; as well as wolf/grizzly bear recovery  in the U.S. North Cascades. There are currently 6.3 million vehicles annually passing by Whistler (Van. Sun. June 1, 2000). Few, if any, female grizzly bears now  cross the Trans-Canada Highway in Banff National Park. Traffic mortality to grizzly bears that might try to cross the Cayhoosh-Whistler-Lillooet Highway could easily account for unacceptable losses to grizzly bears.

3.  Mitigation through bear management plan

Most large-scale townsite developments of the large size of Cayoosh, when built in prime grizzly habitat, have had a history of causing unacceptable levels of grizzly mortality and displacement  - no matter the level of enforcement - such in some of our national parks.  The historical and on-going grizzly bear mortality problems associated with the Lake Louise Ski Development and associated townsite are just one prime example of the limitations of mitigation.

There are, of course, other concerns that would add to the significant cumulative effects but these are the major ones.

I very much appreciate the Federal government taking a role in this matter and look forward to your office taking a strong stand on this matter of urgent public concern to national interests in protecting endangered grizzly bears, wolves and other species.

Sincerely, Wayne P. McCrory, RPBio., Bear biologist.