McCrory Wildlife Services Ltd.
P.O. Box 146, New Denver, British Columbia, V0G 1S0
Phone: 250-358-7796 (Van. 604-709-0801); FAX: 250-358-7950
e-mail: waynem@vws.org
November 19, 1999
Mr. Raymond L. Crook
Melvin Creek/Cayoosh Project Committee Chair
Environmental Assessment Office
Box 9426 Stn. Prov. Govt.
Victoria, B.C. V8W 9V1
(FAX: 250-387-2208)
Re: Cayoosh/Melvin Creek Resort Proposal:
Environmental Impact Assessment (Hatler et al. 1999) and Cumulative
Environmental Effects Assessment (CEA)
Dear Mr. Crook:
I was recently informed by a member of SPEC that the public response period for reviewing the Cayoosh Creek "Resort" EIS has passed, but that there was some opportunity provided comments were in no later than Nov. 22/99. I therefore appreciate the opportunity for my professional review to become part of the public process.
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 member of the B.C. Minister of the Environment's
Grizzly Bear Scientific Advisory Committee.
In reality, the ecological footprint of the proposed Cayoosh All-Season
Development (14,186 beds, 12,000-27,900 skiers/day) will be permanent,
large-scale and irreversible. To use the title "Cayoosh Resort" in itself
is misleading when visitation levels will be the daily equivalent of a
small city, larger than the size of Banff (population 8,000).
I have carefully reviewed the above-mentioned biological report (Hatler et al, 1999) and CEA as part of the environmental impact assessment (EIS) of the proposed Cayoosh Resort Development. As a professional biologist it is my opinion that these documents are seriously deficient.
A development of this size directly threatens extinction of the surviving grizzly bear population in the region, as well as will seriously impact, if not impair, the long-term persistence of wolves, mountain goats, wolverine and other species. Inadequate preparation of the environmental impact assessment and absence of a full-scale cumulative effects analysis does not address the public's interests and seriously underestimates the needs of wildlife populations.
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.
With the extremely high all-season human visitation, plus associated heli-skiing/hiking and many activities radiating outward for a predictable range of 10 km from the resort city, one would anticipate the entire Cayoosh Range to eventually be one vast recreational playground. The CEM claims that the area will not have the "impacts known at much larger resorts like Whistler, Vail, Banff..." because it is smaller (CEM, p. 20). This is highly misleading. Unlike Banff, Cayoosh would be built in a high-elevation, pristine mountainous area within core, pristine habitats and travel corridors for grizzly bears, mountain goats, wolverine, and other species. This alone indicates that there will be extensive ecological effects perhaps different from but of equal or greater magnitude to those of population centres such as Banff or the town of Lillooet which are located in valley bottoms with less productive grizzly and other habitats
Given the current scientific knowledge regarding the significant environmental
impacts to caused by large town sites/recreational developments (admitted
by the proponents' CEM, p.20), I cannot conceive how the Hatler EIS report
could conclude that the town site/ski development
will have only "minor impacts" and "no demographic (population-level)
effects on any species." Similarly, it is difficult to accept
the conclusion of the Cumulative Environment Effects Assessment that: "the
cumulative impacts of the resort development and the region are predicted
to remain at low levels." I strongly disagree; furthermore,
a review by other objective and independent biologists would support my
position.
There is sufficient evidence that the conclusions reached by both the Hatler EIS and the CEM are erroneous and misleading and should be rejected. Only by ignoring:
Although the Hatler report makes some attempt to document basic biological information and identify mitigative measures for the proposed development, the report's credibility is limited by its narrow scope, limited focus, incomplete literature review, somewhat outdated approach, and weak interpretation of cumulative impacts. One major shortcoming is the failure to address the magnitude of the impacts in a broader ecosystem or population survival context, such as for grizzly bears within the realm of an already fragmented ecosystem. In fact, many of these potential cumulative impacts are referred to in the CEM document under the term: "...the magnitude of these impacts is unavailable". If the magnitude of many of the potential cumulative effects are unavailable, how could both the Hatler EIS and CEM have arrived at the conclusions as they did?
Many of these unanswered but critical impact "magnitude" questions could
have been systematically addressed and measured by a GIS (Geographic Information
System) analysis of road densities, loss of habitat effectiveness, road/facility
zone of influence, corridor values (based on slope analysis, etc.) and
by an analysis of core female grizzly bear security habitats. A similar
systematic approach could have been used for wolverine, mountain goats
and other species. Such GIS mapping analysis and other readily available
quantifiable tools of the trade have been curiously ignored in the Hatler
report and thus many important questions have gone
unanswered.
By limiting the analysis to a simplistic approach and isolating most
of the potential impacts to the immediate area of the proposed facility,
the reader could get the impression that most of the cumulative impacts
of what will, in fact, be a small city, will have only a localized effect
on
wildlife, and can be easily minimized by improved site design
and management. Given the weight of evidence from studies on the impacts
of developments of such a grand scale, nothing could be further from the
truth.
I also recognize that the Hatler report may have been constrained by the limited and inadequate EIS specifications required by the government's EAO, including the narrow scope of the cumulative environmental effects assessment. These are systematic deficiencies that encourage poor quality.
My professional opinion for recommending that the current EIS and CEM be considered deficient is based on the following:
1. The scale of the all-season proposed development is
enormous by any standards (up to 27,900 skiers per day and high use year
round). The "Resort" is, in fact, much larger than the Banff "town site"
and would by any standard be considered a small city. It is well known
that the impacts of such large human and facility concentrations, when
built in prime wildlife habitats, have far-ranging and irreversible effects
on wildlife populations, ecosystem function and biological diversity by
contributing to local extirpation and even eventual extinction of more
sensitive species. The recent loss of the last Bow Valley wolf pack
due to excessive human
development within the protective umbrella of Banff National
Park should be instructive in this regard.
The Cayoosh cumulative impact study fails to adequately address such
aspects as the magnitude of the impact of highway improvements and escalating
traffic volumes on increasing wildlife road kills and blocking movements
for some wildlife populations not only in the immediate area, but
along all major transportation corridors to the Cayoosh town site/city.
These are impacts which can readily be quantified and supplemented by numerous
studies readily available in the scientific literature. For example, highway
mortality rates for wildlife could be predicted from existing highway kill
data and projected traffic volumes. Projected traffic volumes could also
have been used to ascertain how seasonal animal movements might be blocked
(e.g. for female grizzly bears and wolverines). The degree of habitat
displacement could also have be quantified.
Also, we know that the cumulative effects of human activities have appreciably
altered grizzly bear habitat in much of the surrounding ecosystem. The
physical and ecological impacts of clearcut logging and of road building
and associated human activity have already affected the
majority of the surrounding valleys including important riparian, glacier
lily corm, avalanche chute, meadow and forested habitats. This could have
been measured through a road density/loss of habitat effectiveness model,
then the Cayoosh Development could have been measured against this baseline.
This was not done.
The region already appears to have concentrated road densities that likely far exceed the 0.4 kilometers of road per square kilometer of habitat considered minimal to maintain long-term grizzly persistence. This places the surviving larger and smaller roadless wilderness areas with good grizzly habitat in the region, such as the Cayoosh Range, at a premium value for protection for ecosystem functioning. This issue is also not addressed.
2. The impacts of the ski lifts and other developments on mountain goat winter range, movement corridors and population survival would be considerably greater than the Hatler report acknowledges. I see no map of winter range and established travel trails and route in this report. Additionally, the proposed mitigation measures may have limited effect. Also not addressed are the cumulative impacts of random, uncontrollable all-season backcountry use by helicopters, all terrain vehicles, snowmobiles hikers and skiers from the Cayoosh Town site as an access point. These would radiate far and wide.
3. The area is part of a large South Coastal Grizzly Bear Recovery Zone proposed by the B.C. government under the B.C. Grizzly Bear Conservation Strategy to "reverse the losses" of bears and their habitat. These animals and other carnivore species require large home ranges and wide vegetative habitat diversity, as well as corridors (connectivity) to travel between habitats.
The proposed development would be located in the exceptional and still
intact grizzly bear and other productive wildlife habitats in Melvin Creek
and the surrounding Cayoosh Range. Left intact, the large roadless
area of the Cayoosh Range would contribute significantly to a regional
recovery program for grizzly bears, wolves, mountain goats and other species.
My study of fragmentation, wildlife corridors and core grizzly habitat
zones for the ecosystem (see attached map) leads me to believe that the
fragmented carnivore populations still have a moderate chance of recovery.
A recent sign-on letter to Lillooet Land & Resources Management Plan
table
members (letter attached) by 10 independent bear biologists 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". Yet none of the inherent values of retaining
the Melvin-Cayoosh Range as a core wildlife area for recovery of mountain
goat, grizzly and other species is at all addressed by Hatler et al.
Although the Hatler study mentions that Cayoosh Development could act
as a population sink, there is no detailed analysis. This is a major short-coming.
As noted in my bear study of Duffey Lake Park (McCrory, 1998), which is
near the Cayoosh Development, the area has a very high
capability to support grizzly bears and "mortality from ongoing
legal hunting and poaching, especially involving breeding-age females,
is a likely factor in delayed population recovery".
The Hatler study talks about steps that will be taken to minimize mortality
and bear/human encounters such as food/garbage management, but is highly
deficient when considering the overall long-term detrimental impacts the
Cayoosh Development will have on the grizzly population in the entire region.
Grizzlies are a sensitive species; the loss of even one breeding
female will affect the chances of population recovery.
Food/garbage management of large human centres/recreational developments in grizzly bear ranges have often proven largely ineffective, even in town sites in National Parks which are highly regulated and patrolled. The high grizzly bear feeding/movement corridor habitat of the Cayoosh Range means that the Ski Development will create a permanent mortality sink for grizzly bears by attracting a constant stream of less wary bears from the entire ecosystem. These will end up being killed through various food-conditioned and human-bear encounter problems leading to predictable incremental mortality that will tip the scales away from potential recovery toward decline and eventual extinction.
While the Hatler study acknowledges the possibility of a population
sink for grizzlies, it ignores the obvious implications that are readily
documented in the published literature. In the Yellowstone ecosystem for
example, mortality of grizzly bears within 6 km of a development was up
to 11 times greater than bears in the backcountry (Mattson and Knight 1991).
At the Fishing Bridge Recreational Development in Yellowstone, the mortality
sink was as large as 8713 km2 - the area ranged over by bears that died
because of problems at the Development. The Fishing Bridge Facility with
staff accommodations, a trailer court, campsites, visitor food services,
livestock, and sewage treatment facilities was in prime grizzly habitat
and a travel corridor. It accounted for 28% of all grizzly bears
killed or removed from the ecosystem between 1968 and 1983; of the 67 bears
reported removed from the park in the same period, 46% (n = 31) were associated
with problems or behavior that began at the Fishing Bridge
development.
In my opinion, the mortality sink for grizzly bears created by the Cayoosh Development will effectively erode any chances for population recovery. In fact, grizzly extinction would be predictable in about 10-20 years of project construction, despite the fact that a "source" population is recognized by the Wildlife Branch in a nearby coastal area.
4. Because of the proximity of the proposal to key existing and proposed protected areas as the Stein Park, the cumulative impacts of such a large scale development will effectively erode the protective goals of BC Parks and create "islands of extinction" for grizzly bears and other sensitive species. This is not addressed in the Hatler report.
5. Continentally, the Lillooet ecosystem is an integral part of the only remaining western movement corridor, linking more-secure grizzly populations to the north in Canada, to the Cascades grizzly bear recovery area in B.C. and the U.S. As grizzly bears are already extinct in much of the dry interior of B.C., it is also the only major north-south corridor left in western B.C. Not only will the Cayoosh Proposal be a major mortality sink for grizzly bears in the Lillooet ecosystem, but the development will eliminate any chances of restoring a major international connectivity corridor for grizzly bears and other wide-ranging species. This aspect was not considered by the Hatler report.
6. Although the possible logging of Melvin Creek is being
used as a rationale to justify development such as the Cayoosh Resort,
the two are not on the same scale of ecological impact. This argument ignores
the fact that the area is also being proposed as a protected wilderness,
and that logging roads can be deactivated as part of long-term ecosystem
restoration.
All of these factors put the credibility and integrity of the environmental
review of the Cayoosh Project under serious question. Added to this, the
Cayoosh Resort Proposal area of Melvin Creek was effectively removed by
cabinet approval from being part of a larger, government- identified protected
areas candidate (LUCO letter, May 4, 1995). This was done without
biological justification and apparently against the objections of the
Regional Protected Areas Team (RPAT). This suggests that the government
had already made up its mind to approve the project and raises serious
questions as to whether a fair consideration of all values can be expected.
Given the serious long-term ecological implications of this large-scale development, I recommend several immediate actions:
1. Acknowledge that the Cumulative Effects Assessment and the Hatler EIS report have serious deficiencies.
2. Place a 2-5 year moratorium on the Cayoosh Development until such time as an adequate and professionally responsible EIS and Cumulative Effects Analysis can be completed, using the best available science.
3. Conduct a comprehensive assessment that takes into account the impact of the proposed development on grizzly bears, mountain goats, wolverine and other sensitive wildlife in the entire ecosystem.
4. Appoint an independent review panel of wildlife experts from outside the province to peer review this assessment and make recommendations.
5. Hold full public hearings on the Cayoosh Resort Development.
Sincerely,
Wayne P. McCrory, RPBio.