MR. RAY CROOK
PROJECT COMMITTEE CHAIR
CAYOOSH RESORT PROPOSAL
ENVIRONMENTAL ASSESSMENT OFFICE
Dear Mr. Crook:
Thank-you for your letter of reply, dated December 13, 1999. Aside from the good points you have raised and your concerns, which I will respond to in the near future, I would like to update you on information specifically regarding grizzly bears which I have acquired subsequent to my November 22, 1999 submission to your office. The information pertains to a grizzly bear and mountain goat reconnaissance conducted by the Ministry of Environment, Lands, and Parks by Ted Antifeau in 1979, and to early 1990s correspondence by the same Ministry regarding grizzly bears, which is a blue listed species.
The reason I bring this to your attention, is because the proponent, NGR Resort Consultants Inc., has stated in section V of the July 6, 1999 Project Report:
* that "there is no clear evidence that a separate, fully viable population of grizzly bears has ever existed in the Cayoosh Range". (page 79)Ted Antifeau, who had been with the Kamloops Fish and Wildlife Branch, conducted intermittent surveys of grizzly bears and mountain goats in the Cayoosh Range from May 26 to August 20, 1979. As a result, he wrote the February 1980 draft report, Grizzly and Goat Survey: Portions of M.U. 3.16 & 3.33, Summer 1979. The Antifeau report is not referenced in the proponent's Project Report Wildlife Assessment, section V, although this report was made available to a private citizen through a freedom of information request in 1997. According to the report, there were a total of five sightings of grizzly bears in Management Unit 3-16, two of which were in the Melvin Creek drainage. On July 23, "a large, single grizzly bear grazing in the lower part of the head basin of Melvin Creek" was sighted. Between August 16-18, another adult grizzly was observed "traveling along and grazing along the alpine meadows on the south side of the upper main creek valley" of Melvin (page 11). Antifeau describes that:
* that grizzly "sightings have been particularly infrequent" (page 50);
* and from an interview from a local guide outfitter, Leo Ouelette, whose licence is currently suspended due to wildlife violations, the statement about grizzly bears that "sightings anywhere in the Cayoosh Range are rare" (page 50).
"the main Melvin Creek valley had, by far, the highest density of recent and fresh bear droppings of all the areas visited in our survey. In 9 km of hiking we found 21 bear droppings, including 10 recent and 2 fresh. All but one of these fresh and recent scats were in the subalpine and alpine zones." (Page 12)Like the proponent, Antifeau had also interviewed Leo Ouelette regarding Melvin Creek, who stated that "there were up to three grizzly bears in Melvin Creek as of the summer of 1977," and that "one of these was a sow". This information is contrary to the information presented by the proponent from Leo Ouelette.
Two days after the Application Proposal for commercial alpine ski development was initiated by Kamloops Crown Lands as a result of Al Raine's request, the Ministry of Environment responded on August 31, 1990 that it was "utterly opposed" to the proposal "because of the habitat importance for mountain goats, grizzly and other alpine fauna" (attached). According to a letter to Crown Lands, dated November 7, 1990, the proponent, Al Raine, was aware of the fact that the Ministry of Environment "had objected strongly", and that the proponent "understood" the objection. The Ministry of Environment's objections were based both upon Antifeau's survey of grizzly bears and goats, and from an earlier study of goats in the early 1970s, which, according to the biologist who conducted the study, observed that Melvin Creek "as being the center of the population with groups of greater than 100 goats" (telephone interview by Ministry of Environment, 1993).
In a April 13, 1993 Ministry of Environment memo (attached), is recognition of the Antifeau report, referring to the "siting of two grizzly in the valley" from the report. The same memo mentions that "helicopter assessment of Melvin Creek in company with Ainsworth Lumber staff showed good grizzly summer habitat with evidence of digs". In retrospect, it is not difficult to understand why the Cayoosh Range, with the undeveloped Melvin and Lost Valley Creeks and the high wildlife values were considered as an Area of Interest for the Protected Areas Strategy in the early 1990s.
In addition, the proponent has known about the Ministry of Environment's concerns about grizzly bears from the outset. Nevertheless there are a number of occasions after 1995 when these concerns are seemingly disregarded:
"The grizzly bear issue while it will need further monitoring over the next few years, it is not deemed to be a major issue at this time for Melvin Creek". "In addition, the valleys west of Melvin Creek are of greater interest for grizzly bear assessment and protection." (Al Raine letter to R.G. Anderson, B.C. Environment, April 23, 1996.)
"As a result of the strong objections of the Ministry of Environment's wildlife staff to the Cayoosh Resort proposal, Grizzly bear were considered to be of greatest concern. However, following summer site visits and subsequent research with others who had considerable summer experience in the area, it was concluded that while habitat would support Grizzly bear experience, Grizzly bear did not frequent the valley often and certainly had not in recent years." (NGR report to Ray Crook, November 7, 1996)Both the proponent's correspondence and the wildlife assessment in the project report base their conclusions about grizzly bears predominantly on the lack of sightings from aerial surveys. According to my conversations with biologists, this is an unreliable and poor method of rendering conclusions and general inferences about grizzly bear populations. For instance, on page 30 of the proponent's project report wildlife assessment, is a reference to a hunter who had observed a female grizzly with two cubs in the Melvin drainage in September 1997.
The concern that we have is that the proponent has not cited important and relevant information in the review of grizzly bear reports and history from the Ministry of Environment, Lands, and Parks files, and that this history is inconsistent with the proponent's conclusions about grizzly bears.
Sincerely, Will Koop.