Date: 5th August 2016
Attention Alberta Environment and Sustainable Resource Development Ministry (ESRD) firstname.lastname@example.org
The Honourable Rachel Notley, Premier
The Honourable Shannon Phillips
Minister of Environment and Parks
Deputy Minister Bill Werry
Environment and Sustainable Resource Development
Executive Director Fish and Wildlife Policy Branch Environment and Parks
Sue Cotterill, Section Head
Species at Risk, Non-Game and Wildlife Disease Policy Environment and Parks
August 4, 2016
Re: Alberta Draft Little Smoky and A La Peche Caribou Range Plan
Dear Ministry of Alberta Environment and Sustainable Resource Development,
As a broad coalition of conservation and animal protection organizations from across Canada, we are extremely concerned with the proposed Little Smoky and A La Peche Caribou Range Plan for the province of Alberta. Our comments are submitted here for your review during the 60-day feedback period.
Clearly, if implemented, the experimental plan would seriously endanger the ecological integrity of already severely degraded environments and the natural communities therein. The proposed experiment to recover subpopulations of mountain caribou would disrupt ecosystem functions and processes, compromise the quality of life for innumerable wildlife species, and threaten a diversity of plants and animals. Accordingly, the draft Little Smoky and A La Peche Caribou Range Plan contravenes the very meaning and purpose of ecological conservation, and if implemented would further adversely affect the natural environment. Collectively, we urge the Province to discard the Draft Little Smoky and A La Peche Caribou Range Plan or amend it in the following ways:
Below we have outlined our major concerns with the plan, provided references to support these arguments, and proposed changes that satisfy our requested amendments:
The province has knowingly allowed industry to destroy, fragment, and disturb caribou habitat for decades despite concerns raised by scientists since the late 1970s. Why a caribou conservation plan would allow for the continued destruction, fragmentation, and overall impoverishment of remaining critical caribou habitat is unclear.
According to the federal 2012 Recovery Strategy for Caribou, 95% of critical caribou habitat in the Little Smoky range has already been disturbed by industrial development and infrastructure. Numerous scientists, conservation organizations, and concerned citizens across Canada contend that industry should be immediately and entirely prohibited within identified critical caribou ranges. To continue enabling industry at a significant cost to caribou and other wildlife species is unacceptable on moral and ecological grounds. The unrelenting accommodation of industries that exacerbate climate change also makes a mockery of Canada’s commitment to reduce greenhouse gas emissions in line with the Paris Climate Agreement.
Although previous governments were responsible for widespread habitat destruction and lethal predator control programs, the current government continues to allow industry to destroy remaining caribou rangeland while concurrently employing wide-scale killing programs of large carnivores and other species.
Extensive research has shown that habitat change due to human activities is the ultimate cause of caribou decline; see Witnessing Extinction – Cumulative impacts across landscapes and the future loss of an evolutionary significant unit of woodland caribou in Canada (Johnson et al. 2015). The limited quantity and quality of habitat currently available for caribou requires increased and immediate restoration and protection. Discussion about self-sustaining populations is futile in the context of continuous resource exploitation in the region. Habitat restoration and management on the landscape scale cannot be confined only to specific areas. A permanent moratorium on human activity within these caribou ranges is required.
The proposed plan fails to address the complexity of threats that the caribou face. For example, the plan does not mention adverse effects of climate change on the caribou population or potential vulnerability due to the genetic implications of penned caribou herds that may prevent them from adapting to a changing environment; see Genetic diversity in caribou linked to past and future climate change, published in Nature Climate Change (2014). Most scientists agree that the best chance for caribou recovery is a committed long-term effort to restore the severely damaged forests that caribou co-evolved with and depend on for sustenance and security. We need to recognize, however, that climate change combined with the magnitude of habitat destruction and impoverishment that has already occurred might preclude that opportunity. Accordingly, the recovery the plan should outline an alternative strategy that could be implemented if the initial plan fails.
Also conveniently absent from the draft is mention of research showing that logging, oil and gas development and motorized recreational use cause physiological and nutritional stress to caribou, which in turn may affect their reproductive behaviour see The influences of wolf predation, habitat loss, and human activity on caribou and moose in the Alberta oil sands (Wasser et al. 2011).
On the pretense of preventing extirpation of a subpopulation of mountain caribou, the range plans allowing the uninterrupted industrial exploitation of already degraded caribou habitat, would effectively reduce complex natural ecosystems to maladaptive ranches for caribou. This is unacceptable and defaces the intent of the Species At Risk Act (2002).
Many experts strongly question the efficacy of predator kill programs, yet this critical input is being ignored by decision makers who continue to scapegoat wolves for caribou declines.
Killing wolves and other large carnivores will likely not save endangered caribou, yet the continuation of predator control is still being proposed on an “experimental” basis. After more than 80 years of predator control efforts throughout North America, no evidence supports the assumption that widespread wolf kill programs will increase ungulate populations in the long term (Vucetich and Nelson 2014). It is of particular interest that over the past 11 years, more than 1,000 wolves have been killed in an attempt to protect the Little Smoky Caribou with no significant increase in caribou numbers (Hervieux et al. 2015). Even if the killing and removal of predators could positively affect the population growth of their prey, the Little Smoky population is limited by the carrying capacity of their severely diminished and impoverished habitat. Consequently, even a temporary population response is unlikely.
As summit predators, wolves are an influential species that help maintain biodiversity and influence large-scale ecological processes (Beschta and Ripple 2016, Beschta et al. 2016). Removing an apex predator and keystone species can trigger changes is food webs that result in decreased species diversity and distortion of established ecological processes (Ripple et al. 2014, Callan et al. 2013, Ripple and Beschta 2011, Beschta and Ripple 2009).
The ranges targeted are dynamic ecosystems characterized by uncertainty, surprise and complexity. No ecological models take into account all possible variables and predict a clear outcome. Indeed, researchers from Isle Royale, where the simplest predator-prey, wolf-moose system has been studied for well over 50 years, emphasize the inability of models to predict outcomes for periods of more than 5 years (Vucetich et al. 2012, Vucetich et al. 2010, Peterson 2007, Mech and Peterson 2003). We can no longer allow for long-term experiments that involve killing of large predators only to learn it does not bring about the desired results.
Such mass killing – spanning decades and under the guise of conservation – is nothing short of absurd and shameful. Causing harm to hundreds of intelligent and sensitive animals in a vain attempt to maintain small herds of caribou in degraded habitat is simply unacceptable from an animal welfare and conservation perspective (Brook et al. 2015).
Public attitudes toward wildlife continue to change as research on animal cognition increasingly shows how similar other animals are to humans in their awareness of self and ability to reason. As society’s values of empathy and compassion evolve, governments have a responsibility to acknowledge the moral drivers that underlie these shifts. Killing experiments that defy people’s growing compassion for animals and the wealth of available scientific research are unacceptable as a conservation policy.
Public policy is always a matter of facts and values being considered through a political process. We need science to keep our empirical facts transparent and accountable. We need ethics to keep our policy transparent and accountable to society’s changing values. Experiments that involve the intentional killing of animals violate the fundamental principles of ethical science. It is time to take into account ethics while making decisions about wildlife. Decisions should reflect the views of the public in its entirety and not just selected special interest groups. Applying an adaptive management approach to managing our environment should not be about applying a ‘killing’ strategy and testing it. We must think more creatively about the complexity of our ecosystems, and entertain strategies that seek to build resilience instead of reducing complexity into zoo-like models.
The Government of Alberta’s Draft Little Smoky and A La Peche Caribou Range Plan includes a fencing experiment that would enclose a large tract of former wilderness for caribou and then slaughter many other species. Natural predators such as wolves, as well as deer, elk, and moose would be killed for up to 50 years.
Over decades, these areas have been purposefully converted from wilderness into industrial landscapes, despite numerous scientific warnings that this would lead to the demise of caribou. Although restoring and protecting critical caribou habitat are essential steps to ensuring that caribou have somewhere to live now and in the future, widespread killing programs and fenced enclosures are not conservation tools and should not be disguised as such. They are merely attempts to preserve tiny island-like farms of caribou on a carved-up and impoverished landscape. Killing programs and fences have no place in conservation strategy that has long-term vision and takes into account complex species interactions and the stochasticity inherent to ecological systems.
The plan contains information about managing caribou and other species, but not about how these animals will be conserved as part of a functioning ecosystem. The plan does not acknowledge other management alternatives, but instead gambles on the success of this inflexible, over-simplified fencing experiment.
Creating caribou farms, while continuously culling wolves and liberalizing hunting of deer, elk and moose is an expensive mega-experiment based on flawed assumptions and small scale experiments that have failed to restore caribou populations and caribou range.
Our strong recommendation is that this plan be abandoned for a more comprehensive and all-inclusive approach to wildlife management in Alberta. As all components of Alberta’s ecosystem are part of a public trust, which our organizations collectively represent, we urge you to recognize and consider this joint submission as representation of the many thousands of Albertan and Canadian citizens, who support the signatories below. We look forward to learning about how you will make important changes to the range plan before its implementation, based upon the above recommendations.
Finally, we trust that our input, and all other comments submitted during this period, will be considered as public input on Alberta’s Wolf Management Plan, which is expected to be completed in draft form at the end of this fiscal year. We will continue to engage an informed public in the government’s decision-making processes involving the management and policies of wildlife as a public trust.
Beschta, R. and W.J. Ripple. 2016. Riparian vegetation recovery in Yellowstone: The first two decades after wolf reintroduction. Biological Conservation 198: 93-103.
Beschta, R.L., L.E. Painter, T. Levi and W.J. Ripple. 2016. Long-term aspen dynamics, trophic cascades, and climate in northern Yellowstone National Park Canadian. Journal of Forest Research 46: 548-556.
Beschta, R.L. and W.J. Ripple. 2009. Large predators and trophic cascades in terrestrial ecosystems of the western United States. Biological Conservation 142: 2401 – 2414.
Brook, R.K., Cattet, M., Darimont, C.T. Paquet, P.C. and G. Proulx. 2015. Maintaining ethical standards during conservation crises. Canadian Wildlife Biology and Management 4: 72-79.
Callan, R., Nibbelink, N.P. Rooney, T.P., Wiedenhoeft, J.E. and A.P. Wydeven. 2013. Recolonizing wolves trigger a trophic cascade in Wisconsin (USA). Journal of Ecology 101: 837–845. doi: 10.1111/1365-2745.12095
Hervieux, D., Hebblewhite, M., Stepnisky, Bacon, M. and S. Boutin. 2015. Managing wolves (Canis lupus) to recover threatened woodland caribou (Rangifer tarandus caribou) in Alberta. Canadian Journal of Zoology 92:1029 – 1037.
Johnson, C.. J., Libby, C.J., Ehlers, P.W. and D.R. Seip. 2015. Witnessing Extinction – Cumulative impacts across landscapes and the future loss of an evolutionary significant unit of woodland caribou in Canada. Biological Conservation 186: 176 – 186.
Mech, L.D. and Peterson, R.O. 2003. Wolf Prey Relations in Wolves: Behaviour, Ecology and Conservation. Eds. Mech, L.D. and Boitani, L. University of Chicago Press 447p.
Peterson, R.O.. 2007. The Wolves of Isle Royale: A Broken Balance. University of Michigan Press.
Ripple, W.J., Estes, J.A., Beschta, R.L., Wilmers, C.C., Ritchie, E.G., Hebblewhite, M., Berger, J., Elmhagen, B., Letnic, M., Nelson, M.P., Schmitz, O.J. Smith, D.O., Wallach, A.D. and A.J. Wirsing. 2014. Status and Ecological Effects of the World’s Largest Carnivores. Science 343.
Ripple, W.J. and R.L. Beschta. 2011. Trophic cascades in Yellowstone: The first 15 years after wolf reintroduction. Biological Conservation 145: 205–213.
Vucetich, John A; Nelson, Michael P; Peterson, Rolf O. 2012. Should Isle Royale Wolves be Reintroduced? A Case Study on Wilderness Management in a Changing World? The George Wright Forum29: 126-147.
Vucetich J.A. and Nelson. M.P. 2014. Wolf Hunting and the Ethics of Predator Control. Oxford Handbooks Online
Vucetich, J., Peterson, R.O., and Nelson, M.P. 2010. Will the Future of Wolves and Moose Always Differ from our Sense of their Past? In: The World of Wolves: New Perspectives on Ecology, Behaviour and Management. Eds.
Musiani, M., Paquet, P., and Boitani, L. University of Calgary Pres, Calgary, Alberta, Canada. 398 p.
Wasser, S.K., Keim, J.L., Taper, M.L. and S.R Lele. 2011. The influences of wolf predation, habitat loss, and human activity on caribou and moose in the Alberta oil sands. Frontiers in Ecology and the Environment.; doi: 10.1890/100071.
Yannic, G., Pellissier, L., Ortego, J., Lecomte, N., Couturier, S., Cuyler, C., Dussault, C. Hundertmark, K.R., Irvine, R.J., Jenkins, D.A., Kolpashikov, L., Mager, K., Musiani, M., Parker, K.L., Røed, K.H., Sipko, T., Þórisson, S.G., Weckworth, B.V., Guisan, A., Bernatchez, L. and S.D. Côté. 2014. Genetic diversity in caribou linked to past and future climate change. Nature Climate Change 4,132–137.; doi:10.1038/nclimate2074
Submitted on behalf of:
Animal Alliance Environment Voters Party of Canada – Stephen Best, Chief Agent
#101 – 221 Broadview Avenue Toronto, Ontario M4M 2G3
Animal Alliance of Canada – Liz White, Executive Director
#101 – 221 Broadview Avenue Toronto, Ontario M4M 2G3
Bear With Us Inc – Mike McIntosh, Executive Director
#3113, Hwy 518W, Sprucedale, Ontario P0A 1Y0
Born Free USA- Canada Representative Bary MacKay
P.O. Box 32160 Washington, DC 20007 USA
Cochrane Research Institute – Clio Smeeton, Executive Director
PO Box 484 Cochrane, Alberta T4C 1A7
Coyote Watch Canada – Lesley Sampson, Executive Director
P.O. Box 507 341 Creek Rd. St. Davids, Ontario L0S 1P0
Earthroots – Amber Ellis, Executive Director
401 Richmond Street West, Suite 410 Toronto, Ontario M5V 3A8
Association for the Protection of Fur-Bearing Animals – Lesley Fox, Executive Director
179 W. Broadway Vancouver, British Columbia V5Y 1P4
Humane Society International/Canada – Rebecca Aldworth, Executive Director
4035 Saint-Ambroise Street, Suite 320 Montreal, QC H4C 2E1
Raincoast Conservation Foundation – Chris Genovali, Executive Director
Physical: 216-2506 Beacon Ave, Sidney, British Columbia V8L 1Y2
Mail: P.O. Box 2429 Sidney, British Columbia V8L 3Y3
Valhalla Wilderness Society – Craig Pettitt, Director
Box 329, New Denver, British Columbia VOG 1S0
Wolf Awareness Inc – Sadie Parr, Executive Director
Western Office: 514 Anderson Rd. Golden, British Columbia V0A 1H1
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