Wildsight's Comments on Retallack Proposal

Approval of Retallack’s present proposal for an all-season use adventure tenure in the South Purcell Mountains would have a significant impact on wildlife in the Purcell system and reduce the amount of suitable and secure core habitat for sensitive species, limit connectivity, and threaten already stressed, struggling, and fragmented wildlife populations.

Key issues with the proposal include:

  • The Cranbrook West Recreation Management Strategy prohibits helicopter-based recreation in almost the entire tenure, except the portion on Kootenay Lake side of the mountains, which was outside the strategy’s scope.
  • The Southern Purcells is a crucial connectivity link and core habitat for grizzly bears, including many areas with dense huckleberries that are important for grizzlies, especially females. Intense all-season use, including helicopter traffic and thousands of heli-bikers, will displace grizzlies from important habitat and threaten connectivity. The Southern Purcells are an important linkage for grizzly populations to the south, north and into the Selkirks and Rockies, making connectivity and secure habitat in this area crucial.
  • Year-round helicopter and human traffic threaten wolverines. With dens hidden under the snow during the winter and wolverines difficult to spot even in the best of circumstances, avoid when seen strategies won’t be effective to avoid disturbing wolverines.
    Mountain goats are extremely sensitive to disturbance from helicopter traffic. With highly-used goat habitat in many parts of the proposed tenure, the impact on goats would be high.
  • While designated mountain caribou habitat is largely outside the proposed tenure, it includes many areas that were historically used by caribou. With current caribou populations spending much of their time near the southwest corner of the tenure, the potential is high for helicopter disturbance from travel to and from the tenure from the planned LaFrance Creek lodge.
  • Endangered whitebark pine, found at high elevations in many areas of the tenure, would be at risk for the extensive alpine and sub-alpine trail building proposed. It would not be possible to build some of the proposed trails without cutting whitebark pine.
  • Thirty-three mountain bike trails are proposed across the tenure, covering 161 km. Adding thousands of downhill and cross-country mountain biker days annually is ecologically dangerous, especially in sensitive alpine and sub-alpine ecosystems.

Cranbrook West Recreation Management Strategy

The province of British Columbia convened the Cranbrook West Recreation Management Committee with representatives from across the recreational spectrum to resolve ongoing recreational conflicts. The proposed tenure area is within the C05, C06, and C07 landscape units. These landscape units are designated as all season RH1, which does not permit aerial based recreational access. Helicopter landings within areas designated as RH1 area are not allowed. RH1 areas are designated because they have very high environmental or social sensitivity to aerial landings. The areas were also designated RM1, which means they are managed to maintain low development and usage. The RM1 designation calls for low incidence of managed trails, routes or sites, low acceptance of recreational changes in the landscape and low incidence of human contact or managerial presence.

This proposal is in direct conflict with the RH1 and RM1 designations. This strategy was the result of a multi-year process facilitated by the province. Ignoring the strategy, which is government-endorsed policy, without full reference back to the stakeholder groups undermines public confidence in stakeholder processes.

Please reference this document (pages 21 and 23).

As one of the last significant areas in the Columbia Mountains (outside of protected areas) that remains only lighty tenured, the intact South Purcell Mountains are highly valuable.

Impacts On Species Of Management Concern

Grizzly Bears

The long term viability and persistence of grizzly bear populations in their southern range is directly linked to the amount and type of human activity on the landscape (Herrero 2005). The proposed tenure area occupies much of the high value habitat for the South Purcell grizzly population. Female grizzly bears in particular select habitats within their home range that provide abundant food forage and minimize human disturbance and they avoid disturbed areas and slopes that have high human activity during daylight hours (Martin et al 2010).

Both the scale and use intensity of this project will result in displacement of grizzly bears (particularly females) from suitable habitat and substantially reduce habitat availability for the South Purcell grizzly bear population. This 71,000 ha. proposal is extremely intensive with tens of thousands of uses projected every year. It will threaten connectivity and high value habitat for grizzly bears in the Purcell region.

The Purcell Wilderness Conservancy acts as a source population for grizzly bears in the Purcell system (Proctor et al 2007). For the persistence of grizzly bear populations to the south, vital connectivity between the PWC, the South Purcells, and the Yahk Grizzly bear population units must not be hindered by heavy recreational use. The proposed project area is in the heart of this area. Moreover, the Southern Purcell region is thought to be a vital link to provide connectivity and genetic interchange between the South Purcell and the South Selkirk grizzly bear populations (Proctor et al 2015). Given its scale and scope, this project could threaten that connectivity and significantly reduce the amount of available high value habitat in the Southern Purcells. It is critical that this region of the South Purcells maintains its low recreational usage if we want healthy grizzly bear populations and connectivity in the South Purcells and South Selkirks.

Much of the proposal area overlaps critical huckleberry patches for grizzlies in the South Purcells. Dr. Michael Proctor has provided maps of the critical huckleberry patches and high value habitat in the South Purcells. The importance of these huckleberry patches has been verified by ground truthing and grizzly bear collar data. Huckleberry patches drive grizzly bear habitat use, home range selection, reproductive output and density (Proctor, personal communications). High recreational use in these areas for heli-biking, heli-hiking, and other spring, summer, and fall based activities would significantly reduce the amount of secure and suitable habitat for grizzly bears in the South Purcells.

Wolverines

Although wolverines remain understudied outside of protected areas, numerous studies do show negative impacts from commercial recreation on wolverine populations. Female wolverines presence in particular has been found to be negatively associated with heli-skiing and backcountry skiing (Krebs et al 2007). Habitat use by male wolverines in winter was also negatively associated with heli-skiing areas in the Columbia Mountains (Krebs et al 2007). It is clear that pressures from commercial backcountry use, industrial use, and human recreation activities like heli-skiing may erode the capacity of an area to support wolverine populations, especially reproductive females (Krebs 2000).

The proponent’s proposal to avoid wolverines “once seen” or “avoiding wolverine dens once discovered” is an insufficient mitigation measure. Wolverine dens are difficult to identify and it is not easy to spot wolverines. One can’t rely on seeing them to avoid them, given their very large ranges and solitary behavior. By the time you see a female wolverine going into a den from a helicopter or on foot there is a strong likelihood of displacement from that denning site. Wolverines are known to abandon dens from what are typically thought to be low impact activities like a backcountry skier getting within 200m of a den. The inadequate proposed 500m buffer between wolverines and helicopter traffic combined with proposed intensive and high use recreation will result in disturbance, abandonment of habitat, and will threaten connectivity for wolverine populations in the Purcell Mountains.

Wolverines in the South Purcells are believed to exist at low density and exhibit low genetic connectivity with other populations in Southeastern BC (Hausleitner and Kortello 2014). The latest unpublished research from the South Purcell region suggests that wolverine presence is negatively correlated with human disturbance and forest service road density but positively correlated with protected areas such as provincial parks and the Purcell Wilderness Conservancy (Kortello, personal communication). Wolverines in the South Purcells are struggling to interchange DNA because of our human footprint on the landscape (Hausleitner and Kortello 2014). Wolverines may be avoiding areas of intense use and forest service roads because of disturbance from snow machine and helicopter usage and selecting for protected areas because of a lack of disturbance (Kortello as per comms). This means that reducing human impact on unprotected crown land is critical to ensuring wolverine persistence and connectivity in the Purcell Mountains. This project’s proposed human footprint combined with existing pressure from recreation, industry, and trapping could erode the South Purcell Mountains’ capacity to support a wolverine population and further fracture connectivity with other populations in southeast BC.

Mountain Goats

Mountain goats are extremely sensitive to human activity and mechanized disturbance. Mountains goats disturbed by helicopter traffic within 2000 meters will exhibit a predator response. They have evolved to escape predators by always having escape terrain nearby (i.e. cliffy, rocky, mountainous terrain) where they can out-climb and avoid predators. However, when a helicopter flies close to mountain goats, they cannot escape the predator represented by the sound and their heart rates and stress levels increase dramatically. Their elevated heart rates and stress levels decrease within minutes of the helicopter leaving, but mountain goats who are repeatedly exposed to helicopter activity will abandon critical habitat or at least expend significant energy in avoidance behaviours (Festa Bianchet and Côté 2008).

The proponent’s proposed “avoid when seen” mountain goat mitigation procedure is insufficient. Avoiding goats is extremely difficult due to the fact that they are often in smaller groups, are difficult to see at distance, and they move around a lot. Mountain goats are difficult to spot from the air in winter and it is nearly impossible to spot them from the proposed “avoid when seen” distance of 1500-2000m. This proposed management strategy will be ineffective at mitigating negative effects of helicopter-based recreation.

The two mountain goat survey population units in the South Purcell Mountains have suffered major declines in goat populations in the last 10 years. The Kamma-Meachen population in the south has declined by 44% and the upper St Mary’s population has declined by 17% (Poole and Klafki 2015). Both populations would be significantly affected by this project. There is a high likelihood of displacement of these declining mountain goat populations given the scale and intensity of helicopter traffic outlined within this application.

Much of the proposal overlaps with critical goat areas: Baribeau, Hungry Creek, upper Tower Creek, upper Hall Lake Creek, upper Meachen, upper Redding, upper Crawford, Pyramid, Boulder, and much of White Creek are critical mountain goat habitat. The high winter snowpack in the South Purcells already significantly limits availability of high-quality winter habitat where forage is available (Klafki, personal communication). During a high snow year mountain goat survival is already difficult in the South Purcells. Adding additional stress from helicopter-based recreation to these already declining populations would make their long term viability and persistence in the South Purcells precarious.

Mountain Caribou

The project has the potential to disturb the South Purcell mountain caribou population. Mountain caribou are federally listed and protected as an endangered species under the Canadian Species at Risk Act.  There is also a provincial Mountain Caribou Recovery Implementation Management Plan that has protected significant habitat under provincial Government Action Regulation and Ungulate Winter Range orders. Retallack’s proposal avoids much of the provincial GAR order areas, but there is occupied caribou habitat which is outside of the GAR order areas, within and in close proximity to the proposed tenure area. Mountain caribou can be found in the high subalpine during the late winter as deep snowpacks allow them access to abundant arboreal lichen. This makes mountain caribou particularly likely to experience disturbance from heli-skiing as it takes place in similar high alpine and subalpine habitat. Disturbance from heli-skiing and backcountry activity is widely recognized as a contributing factor to the decline of mountain caribou in BC (MCTAC 2002). The proposed 500 metre buffer from helicopter traffic and 100m from skiers and non mechanized traffic is inadequate and will result in displacement and disturbance of mountain caribou from both helitraffic and skiers.

The South Purcell herd can often be found in upper and middle parts of Redding and upper LaFrance and Lockhart Creeks, as evidenced by government telemetry data and historic sightings. Although the proponent has mainly avoided the current usage areas for the South Purcell herd, the proponent’s proposed flyover routes may conflict with future and current caribou usage, especially in the middle Redding Creek area, near the proposed primary flight route. Current and future flyover routes will heavily utilize Redding Creek resulting in potential displacement, increased energy costs, and increased predation risk to the South Purcell herd. Access to the Meachen Creek areas of the tenure is proposed via a very long, circular route that appears unrealistic; in the future or in cases of bad weather the proponent may wish to access that area directly via LaFrance and upper Redding Creeks from their lodge at the base of the LaFrance drainage, potentially overflying very heavily used core summer and winter caribou habitat. The upper Meachen Creek area is also historically an area with many caribou sightings. Caribou are very sensitive in the late winter and rely heavily on fat stores to get them through the winter. Disturbance can result in displacement from critical habitat, increased energetic costs, and increased predation risk, resulting in potentially lower winter survival rates (Kinley 2003, Seip 2007).

Moose

The little research that exists on moose reaction to helicopter disturbance suggests that moose are particularly sensitive to it. Moose respond to heli disturbance by increasing movement rates for up to two hours and will seek escape cover in rugged terrain and taller vegetation after being disturbed (Stoen et al 2010). This could mean that moose will be limited in their forage availability and suffer increased energetic costs following helicopter disturbance.

The St. Mary’s area and mid-elevation tributaries provide excellent and important wintering ground for moose (Poole, K. 2006. Moose inventory of Management Units 4-22 (Bull River) and 4-20 . Areas like the Redding riparian, lower Baribeau Creek, lower Pyramid Creek, the middle and upper St Mary’s River valley provide important wintering ground for moose in the South Purcells. With constant helicopter traffic, moose in the South Purcells will suffer from increased disturbance and increased energetic costs from disturbance.

Whitebark Pine

Whitebark pine is an endangered and federally protected species under Canada’s Species at Risk Act. It is a long lived, five-needle pine that is restricted in Canada to high elevations in the mountains of British Columbia and Alberta (SARA 2017). Due to factors that include climate change, diseases (mountain pine beetle and white-pine blister rust), fire suppression and logging, this species has a high risk of extirpation in Canada (SARA 2017).

Retallack’s trail proposals significantly overlaps with healthy whitebark pine dense stands and areas. Many of their proposed ridgetop and sub-alpine trails could not be built without cutting whitebark pine, which grows in dense stands in subalpine areas where proposed biking trails would be located. In addition, glading for skiing operations could pose a threat to whitebark pine as trees could be cut, particularly in the mid seral stage (60-100 year old) when taller whitebark pine is very difficult to identify. Whitebark can be difficult to identify and can be falsely identified as lodgepole pine due to the tree bark and the tree looking similar when needles and cones are not visible.

The Southern Purcells have a very high concentration of whitebark pine at upper elevations (Moody personal communications). Areas like Pyramid Creek, Tower Creek, Coppery Creek, Calamity Creek, Fiddler Creek, and Mallandaine Pass have high-density whitebark pine stands. Trail building or upgrading in these areas at elevations above 1800m almost certainly could not be done without cutting or harming this federally-protected species.

Impact On Quiet Recreation

The South Purcells are a renowned area for quiet, low-impact recreation. Tourists and visitors from Alberta, Montana, and elsewhere visit the South Purcells for opportunities to enjoy wilderness and low-impact, quiet recreation. Areas like Mallendaine Pass, Hourglass Lake (Meachen Creek), Whiteboar Lake (Meachen Creek), Mt Evans (Meachen Creek, Mt Manson and Patrick (St Mary’s), Mortar and Pestle Lake (East Dewar/St Mary’s Alpine Park), Pyramid and Alki Creek, Mt. Loki (Loki Creek), Plaid Lake (Crawford Creek) provide easy and world class access to wilderness and quiet recreation experiences. The South Purcells offer recreation opportunities that are valued by locals, hunters, anglers, guide outfitters, trappers, visitors, skiers, climbers and hikers and are huge assets to local economies. Low impact quiet recreation takes place in much of the South Purcells in all seasons. The impact of this proposal on quiet recreation will be significant. Many visitors and locals come to these locations because of their remoteness and because they appreciate the serenity and wilderness values within these locations. Tens of thousands of annual all season users and constant helicopter traffic could deplete much of the South Purcell Mountains of quiet recreation opportunities.

Mountain Biking Concerns

While heli-access mountain biking is becoming increasingly common in BC, formal tenures for this activity are relatively new. Because of the summer/fall use in wildlife habitat, the high travel speed of downhill mountain bikers and the erosion associated with trail building and use, the potential environmental and wildlife impacts of high intensity heli-biking use are very significant. The proposal includes 161 km of mountain bike trails (33 different trails), covering most of the tenure. With many of these trails located on ridgetops, in alpine and sub-alpine terrain, this would be a very significant change in the South Purcells, where there are few alpine or sub-alpine recreational trails and no known alpine or sub-alpine mountain bike trails.

Most of the biking would be accessed by helicopter. Aerial landings are not allowed in any of the landscape units (C05, C06, and C07) under the Cranbrook West Recreation Management Strategy (page 21, 23). The areas are managed to maintain low development and usage, with a low incidence of managed trails and low acceptance of recreational changes in the landscape (all season RM1 designation) by agreement among stakeholders involved in the Cranbrook West Recreation Management Strategy.

Mountain bike impacts remain relatively understudied. Generally, trail building is believed to have a substantial impact on erosion and sedimentation, with the potential for negative impacts from sedimentation on aquatic life, including fish, downstream. While the management plan addresses impacts on wet areas, erosion in dry trail areas and resulting sedimentation is not addressed. Heavily utilized steep downhill biking trails can essentially act like streams, increasing surface water flow and erosion risk on steep slopes. The impacts on sensitive alpine and sub-alpine plant communities of downhill mountain bike trails will be significant. Trail building and downhill bike usage will leave a major impact on intact drainages that contain rare and endangered old growth, including species at risk like Whitebark Pine and at risk plant communities in areas such as Tower Creek, Calamity Creek, and Pyramid Creek.

Retallack’s mountain bike proposal will have a substantial impact on wildlife, local residents, and backcountry users due to helicopter disturbance. Sensitive species like mountain goats, wolverines, and mountain caribou are negatively affected by constant helicopter usage (MCTAC 2002, Festa Bianchet and Côté 2008, Krebs et al 2007). Both the scale and intensity of use in the project area will result in displacement of grizzly bears, wolverines, mountain goats, and moose from suitable habitat, reduced and fragmented connectivity, and substantially reduced habitat availability for these sensitive species.

Road building and road upgrading to allow clients to access trails and to be shuttled for mountain biking would be environmentally unacceptable. There are no details in the management plan about this type of road, but with 3600 proposed person-days per year in each zone, road use, maintenance, upgrading or even construction would need to be significant.

Some road densities in the region already exceed the 0.6km/km2 recommended road density threshold for grizzly bear viability. Areas like the Crawford Creek Grizzly Management Unit have a road density of 0.97km/km2 (Proctor et al 2008). However, it’s important to note that when these resource roads are not being used by humans they can actually help grizzly bear populations as they can be used for roadside forage and as travel corridors. If Retallack were to develop or upgrade roads and use them to shuttle mountain bikers this could easily change the impact of existing roads on grizzlies to be negative. High human use and increased effective road density could significantly reduce secure and high value habitat for grizzlies in this area, which could have significant implications on grizzly populations.

Impact On Core Areas

While the Southern Purcell Mountains are vast and rugged and still exhibit all of the wildlife populations that have been present for millennia, many of the drainages have been logged and/or heavily impacted by industry and recreational users. Although the landscape has some degree of fragmentation, there are many areas and drainages that offer wildlife enough room to roam due to their intactness and low road density. These areas are core or anchoring areas for wildlife in the South Purcell Mountains. Many of these intact or barely impacted areas have been included in this tenure application.

Retallack’s proposal could severely impact these wilderness and wildlife values and threaten wildlife connectivity and core habitat within the South Purcell system. The list below is organized in a mainly south to north gradient and features critical areas and examples of the values that are found within these drainages:

Mallandaine Pass and proposed tenured areas on the south side of Meachen Creek: Mallandaine Pass is an extremely heavily used mountain pass in the Purcell system for wildlife. The Mallandaine and upper Goat River (not included in this tenure) is one of the most wildlife rich and important areas in the Purcell system.

The proponent is proposing to use the Mallandaine Pass Trail for snowshoeing and hiking. However, the area is outside the proposed tenure area. This area is important wildlife habitat, especially for grizzlies and caribou. If this area will be used, it should be formally included in the tenure and the management plan, so that the environmental impacts can be evaluated.

This area is not only a corridor or connectivity area, areas around Mallandaine Pass, upper Fiddler, and the Whiteboar and Ailsa/Mayo Lake drainages are critical habitat for grizzly bears, mountain goats, moose, and possibly wolverines. Wildlife travel down Mallandaine Pass to get to critical habitat in Fiddler, Redding, and Meachen Creeks from the Goat watershed.

Goat disturbance is a major concern as the ridgelines between Whitegrouse Mountain, Mt Mckay, and Mt. Evans are identified mountain goat habitat areas. Aerial censuses have picked up groups of goats throughout this whole series of ridges (Poole and Klafki 2015). There would be no conceivable way to comply with the MoE recommendation of a 2000m helicopter buffer from mountain goats within this area.

Upper and mid Meachen Creek is core grizzly bear habitat. Huckleberry geospatial data and collar data show this is one of the core areas for grizzly bears in the South Purcells.

Pyramid Creek’s value lies in its intactness, its core grizzly bear habitat, caribou habitat, old growth forests (ICH and Western Larch) at low and mid elevations, and its high value, increasingly rare and high density Whitebark Pine at upper elevations (Utzig 2014). The proposal would also impact the current low-impact recreational usage of this drainage. The Pyramid Creek Trail is maintained by the Kimberley Trails Society and is part of the Pyramid-Alki Creek Loop Trail that is well-maintained and popular with locals. The upper basins of Pyramid, Alki, Matthew, and Murphy are also popular ski touring destinations in the winter months.

Loki Creek is one of the very few remaining intact, unroaded drainages on the eastern slopes of Kootenay Lake. It contains excellent mountain goat, wolverine, grizzly bear, and elk habitat. Disturbance from constant helicopter traffic would threaten the values within this drainage.

Tower Creek, unnamed drainage West of Tower Creek, Hall Lake Creek, and Parkers Creek: These four drainages make up a large area of de-facto wilderness between Meachen and Redding Creek. Tower, the unnamed drainage to the West of Tower, and Parkers Creek are intact drainages that provide excellent habitat for grizzly bears, wolverines, and mountain goats. Collar and huckleberry plant distribution data supports the all season (spring, summer, fall) use of these four drainages as important core areas for grizzly bears. Hall Lake Creek provides core habitat for grizzly bears and potentially a key connectivity route via an accessible mountain pass between all of these critical drainages. Mountain goat census data shows that these areas are occupied and important mountain goat habitat (Poole and Klafki 2015). This area would see high-impact, all-season use due to its proximity to the lodge, relatively high mountain relief (1000m vertical), and planned mountain bike trails. The project would not allow the current wilderness and wildlife values of this area to be maintained. Helicopter usage within these drainages will result in disturbance to wildlife, a decrease in suitable habitat and abandonment of habitat for sensitive species like mountain goats, grizzly bear, and wolverines.

There is also a strong likelihood of increased human-bear conflict, increased grizzly bear mortality, and abandonment of secure habitat for grizzly bears if the proposed mountain biking development is located in these drainages.

Redding Creek: Lower and mid Redding contain important grizzly and caribou linkage habitat (Utzig 2014). In the lower Redding riparian area there is an important goat lick that is used by goats, moose, and other species (Tembec 2010). Upper Redding Creek is core and excellent habitat for grizzly bears, mountain caribou, wolverines, and mountain goats. Constant helicopter traffic from La France Creek into Redding will severally impact the Redding drainage as it likely to be a key flight route given the location of the lodge, proposed flight routes, topography, and frequent bad weather in the winter. We understand that Retallack would retain the ability to change proposed flight routes within the application at will, so their flight routes could change on a day-to-day basis or could shift in the long term. Upper Redding and upper Meachen Creek would likely see helicopter traffic on a day to day basis, at any time of the year, causing disturbance and displacement for caribou, grizzly bears, and mountain goats in the area. If upper Redding and upper Meachen sees significant helicopter traffic it will result in increased energy output and the potential abandonment of suitable habitat by mountain caribou, mountain goats, and grizzly bears.

Baribeau Creek is core habitat for grizzly bears, mountain goats, mountain caribou, and moose. It is also an important linkage area for mountain caribou and grizzly bears (Utzig 2014). The drainage has a road in its lower reaches, but this road sees little use and the middle and upper drainage sees extremely limited human usage. Baribeau is core habitat for grizzly bears, mountain goats, mountain caribou, and moose. The drainage is mainly intact and high intensity recreation would threaten its connectivity function and reduce the amount of suitable core habitat for grizzly bears, mountain goats and moose populations that all occupy this drainage.

Mt Bonner area and Hungry Creek: The ridgelines between Mt. Bonner and Hungry Creek provide excellent and occupied mountain goat habitat (Poole and Klafki 2015). Mountain goat values here are exceptionally high.

Hungry Creek and the drainage near Mount Rice is core habitat for grizzly bears and mountain goats. Helicopter traffic and increased human presence will result in displacement from core habitat, increased energy costs, and increased risk of human-wildlife conflict. Proposed mountain biking trails would threaten critical and occupied mountain goat habitat.

Sawyer Creek is core grizzly bear habitat and the area has significant biodiversity value. A large portion of Sawyer Creek is managed to maintain the wilderness and biodiversity values found within this drainage under Canfor’s Forest Stewardship Council certification. The drainage has some of the largest western red cedar and western hemlock stands in the Southern Purcells (Tembec 2010). These old growth stands are increasingly rare and they provide significant biodiversity. These stands and much of the Sawyer Creek drainage provides critical core grizzly habitat as seen on Michael Proctor’s maps.

Lapointe Creek: Upper Lapointe Creek sees significant grizzly bear usage as evidenced by Michael Proctor’s all-season usage map. Huckleberry patches are found on the westside of the drainage near Rose Pass. Both Rose Pass and Sawyer Pass provide important north-south connectivity for wildlife. There is a strong likelihood of increased human-bear conflict, increased grizzly bear mortality, and abandonment of secure habitat for grizzly bears if the proposed mountain biking development is located in this drainage.

White Creek provides important connectivity linkage for wildlife, critical grizzly habitat, and has significant but scattered old growth stands throughout the drainage (Utzig 2014).

Upper Crawford Creek: The upper reaches of Crawford Creek are core grizzly bear habitat, caribou habitat, and an important wildlife linkage area because of the accessible mountain passes at the head of Crawford Creek. The upper reaches of Crawford Creek are extremely important for connectivity within the Purcell system.

East Dewar drainages including all ridges from the Mount Patrick drainage north to Irish Queen and Mortar Lake to the PWC boundary: This whole series of ridges is important and occupied mountain goat habitat. There would be no conceivable way to keep the MOE recommendation of a 2000m flying buffer from mountain goats in this area. Mountain goat aerial censuses have identified groups of goats throughout this series of ridges (Poole and Klafki 2015).

Coppery, Calamity, and Office Creek: These three drainages, which lie between the West Fork of the St Mary’s and Dewar Creek, make up a large area of de facto wilderness adjacent to the Purcell Wilderness Conservancy. This area’s value lies in its intactness, high-density huckleberry patches and high-value avalanche paths that provide forage for grizzly bears, elk and moose, core grizzly bear habitat, intact old growth forests at mid and lower elevations and endangered whitebark pine stands in the alpine (Utzig 2012). Huckleberry mapping data and collar data support this as one of the core areas for grizzly bear in the South Purcells.

Conclusion

Retallack’s proposal for intensive use over an entire portion of a mountain ecosystem could fragment wildlife habitat, decrease the amount of suitable and core habitat, and degrade wildlife connectivity and wilderness in the South Purcell Mountains.

References

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Klafki, Richard. Registered professional biologist. Personal communication cia email

Kinley, T.A. 2003. Snowmobile – Mountain caribou interactions: A summary of perceptions and an analysis of trends in caribou distribution. Unpublished report.

Kortello, A., D. Hausleitner 2014. Abundance and distribution of wolverine in the Kootenay Region: 2013 field season report: Purcell Mountains. Prepared for Ministry of Forests, Lands and Natural Resource Operations, Nelson, BC

Krebs, J., Lafroth, E., Parfitt, I. 2007. Multiscale Habitat Use by Wolverines in British Columbia, Canada. Journal Of Wildlife Management 71 (7).

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Proctor, M., Boulanger, S. Nielsen, C. Servheen, W. Kasworm, T. Radandt, and D. Paetkau. 2007. Abundance and density of Central Purcell, South Purcell, Yahk, and south Selkirk Grizzly Bear Population Units in southeast British Columbia. BC Ministry of Environment, Nelson, British Columbia, Canada.

Proctor, Michael. Nielsen, Scott Kasworm, Wayne, Servheen, Chris Thomas G. Radandt A. Grant Machutchon Mark S. Boyce. 2015. Grizzly bear connectivity mapping in the Canada-United States trans-border region. Journal of Wildlife Management 79(4):544-588.

Proctor, Michael. PhD grizzly bear biologist, Birchdale Ecological. Personal communications via email.

Poole, Kim. 2006. Moose inventory of Management Units 4-22 (Bull River) and 4-20 (St. Mary River), East Kootenay, January 2006. Unpublished report prepared for British Columbia. Ministry of Environment, Cranbrook BC.

Poole, Kim, and Klafki, Richard. 2015. Kootenay Region Mountain Goat Population Assessment 2013-2015. BC Ministry of Forests, Lands, and Natural Resources, December, 2015.

Seip, Dale, Johnson, Chris and Watts, Glen. 2007. Displacement of mountain caribou from winter habitat by snowmobiles. Journal of Wildlife Management 71(5):1539–1544; 2007.

Species At Risk Public Registry. 2017. Recovery Strategy for the Whitebark Pine (Pinus albicaulis) in Canada [Proposed] 2017. Environment And Climate Change Canada.

Stoen, O. Neumann, W. Ericsson, G. Swenson, J. Dettki, H. Kindberg, J. and Nellemann, C. 2010. Behavioural response of moose Alces alces and brown bears Ursus arctos to direct helicopter approach. Wildlife Biology 16:292-300.

Tembec. 2010. Management Strategies for High Conservation Value Forests
in Tembec’s Operating Area in the Cranbrook and Kootenay Lake TSAs. British Columbia.

Utzig, Greg. 2012. Draft Conservation Plan for a Portion of the Southern Rocky Mountain Trench Subregion: Regional Landscape Units 9 and 10: Columbia-Windermere Lakes and Horsethief-Skookumchuck from the West Kootenay Climate Vulnerability and Resilience Project. Kutenai Nature Investigations Ltd. Retrieved from Kootenay Resilience website: www.kootenayresilience.org.