•McCRORY WILDLIFE SERVICES LTD. RESPONSE TO 2011 TERRESTRIAL/WILDLIFE COMPONENT OF THE ENVIRONMENTAL IMPACT STATEMENT (EIS) & ASSOCIATED DOCUMENTS REGARDING THE PROPOSED NEW PROSPERITY GOLD-COPPER MINE PROJECT AT TETZAN BINY (FISH LAKE) WITH SPECIFIC REFERENCE TO THE GRIZZLY BEAR •[With added comments on other Carnivores, Wild horses & Northwestern Toad ] Wayne McCrory, RPBio. Summary of Report to CEAA Panel for Friends of Nemaiah Valley (FONV): July 30, 2013

RELEVANT QUALIFICAITONS

• Registered professional biologist, BC

• Expertise includes 40 years of research and conservation programs related to wildlife and bears. 80 technical reports including waterfowl, mammal inventory, Impact studies, grizzly bear habitat mapping, etc.

• BC govt. Grizzly Bear Scientific Advisory Committee for four years.

Relevant experience

• North Cascades grizzly bear recovery program. BC Parks –grizzly bear habitat mapping, conflict reduction plan and effectiveness of road closures & gating.

• Report on ungulate hunter/grizzly bear conflicts in the Muskwa-Kechika for BC Wildlife Branch.

• Report on preservation and management for grizzly bears in BC provincial park system

Other

• Environmental Impact Studies: Syncrude tar sands, Gas Arctic pipeline(Yukon), Chief Mountain Pipeline, Mackenzie Valley Pipeline, coastal logging & bears, etc.

• Bear-people conflict prevention plans for Whistler, Britannia Beach development, Vancouver North Shore, Metro Vancouver Parks, Upper Slocan Valley, BC Parks – West Kootenay District.

Cariboo-Chilcotin

• Environmental impact studies related to wildlife: Proposed Moran Dam on Fraser River, EIS of Chilcotin Military Block for Toosey Indian Band. • Aboriginal Funds for Species at Risk Study (AFSAR) for Williams Lake Indian Band & Xeni Gwet’in • Access Management, Tourism/Wildlife &Climate change studies for Xeni Gwet’in Study approach for my second Response document to a Prosperity & New Prosperity EIS

• Added to my 2010 grizzly bear submission that was accepted by the previous Panel. Now took a second look with more substantive ecological yardsticks. More baseline information including:

• 1). Conservation review of the Chilcotin grizzly bear

• 2). Grizzly bear habitat, movement corridor and DNA hair analysis at Tetzan Biny (Fish Lake) MDA.

• 3). Looked at importance of Fish Lake for grizzlies feeding on spawning rainbow trout.

• 4). Grizzly bear numbers using Tetzan Biny (Fish Lake) MDA seasonally & annually

• 5). More in-depth review of population numbers, mortality and conservation status of South Chilcotin Ranges grizzly bears.

• 6). Developed a human-caused mortality baseline from 2001-2012 data sources for the South Chilcotin GBPU.

• 7). Developed an estimate of New Prosperity human-caused mortality for grizzly bears in the GBPU, even with proposed mitigation.

McCrory Wildlife Service Response to BC Env. Ass. Office Letter to Panel. July 19, 2013

• Re. A.N. Hamilton, Carnivore Specialist. Comments on Grizzly Bears: a)I agree with his criticism that New Prosperity EIS undervalues the MDA habitat, etc. b). I seriously question his support for the project when he was unable to even provide electronic data on grizzly mortality & has been involved two published reports that identify road mortality as affecting grizzly bears including his estimate of 4 grizzlies killed annually on the proposed Kincolith Highway (Demarchi report) and the fact that up-grading the Duffy Highway to the south of the Chilcotin Ranges GBPU has caused female grizzlies to be extirpated north of the highway. c) I will be submitting a letter to the Panel on this.

PART 1. ADDITIONAL GRIZZLY BEAR BASELINE INVENTORY FOR THE NEW PROSPERITY MINE DEVELOPMENT AREA (MDA), REGIONAL STUDY AREA (RSA) AND THE SOUTH CHILCOTIN GRIZZLY BEAR POPULATION UNIT (GBPU). GROUND-TRUTHING NEW PROSPERITY 2011 EIS.

Xeni Gwet’in have created Aboriginal Preserve & B.C.’s first Wild Horse Preserve. Near- intact ecosystem including grizzlies, wolves, cougars, wild salmon but where people can still survive on the land. A unique people and culture and landscape. A world-class aboriginal protection model as big as Banff National Park 1989 Nemiah Aboriginal Preserve Declaration You actually see this sign on the Taseko/Whitewater road before the 4500 turn-off to Fish Lake

1989 Xeni Gwet’in Nendduwh Jid Guzit’in or Aboriginal Wilderness Declaration. 2002 Elegesi Qiyus Wild Horse Preserve or Eagle Lake Henry Cayuse Wild Horse Preserve

• Declared that no industrial logging, mining and hydro- electric development • 770,000 ha, approximate size of Banff National Park Despite hardships people who live in this unique area wish to keep the Xeni Caretaker Area, aboriginal preserve & wild horse preserve pristine CONSERVATION CONTEXT: What is the Coastal Mountains Dryland Grizzly Bear? [Sam Zirnehlt Photo]

• A unique ecotype that Lives on the dry east side of the coast mountains where there are grasslands & dry climate.

• Eats salmon & cosmpolitan diet includes whitebark pine nuts and wild potatoes, salmon & in the spring spawning trout at Fish Lake.

• Dens in the high country.

CHILCOTIN DRY LANDS GRIZZLY BEAR. Extinct in most BC grasslands. Not just a grizzly bear, but a special ecotype that is continentally important • Extirpated in grasslands north-east of Fish Lake towards Fraser River. Conflicts with settlers and cattle. • A few may wander into Junction Sheep Park. Some still shot by ranchers in Chilcotin

Dryland grizzly can be very large and travel over very large areas. Home ranges 3x size of coastal cousins This makes it more vulnerable to conflicts with humans than coastal bears Taseko-run salmon in Elkin Creek Significant salmon areas for grizzly bears in Taseko-Chilko systems

Ground truthing grizzly habitat in Xeni Gwet’in Caretaker Area Found West Chilcotin & South Chilcotin mountains & foothills core grizzly refugium larger that Greater Yellowstone Ecosystem in US Study recommends a grizzly recovery plan and to retain remaining grizzly habitat intact. Salmon an important value

• Some 1,239,761 hectares or 46% of the total proposed Chilcotin grizzly bear conservation area is protected • Xeni aboriginal/wild horse preserve provide greatest protected area of 777,290 hectares, includes within it 4 provincial protected areas

Continentally Important

• 2010 grizzly bear conservation study headed by Craighead Institute showed Chilcotin the last large refugium left in North America for the Coastal Mountains Dryland Grizzly that once ranged as far south as California. Now extinct in the U.S.

• Chilcotin Ranges last viable enclave of the threatened & endangered coastal foothills-dryland grizzly bear left in North America. Arrow points to mine at Fish Lake . Proposed New Prosperity mine is within this large core dry land grizzly bear conservation area

Stating the obvious: Eastside Forest Scientific Society Panel (1994): Concluded that existing roadless regions have enormous ecological value.

• A panel of eight scientists representing the American Fisheries Society, American Ornithologists Union, Ecological Society of America, Sierra Biodiversity Institute, Society for Conservation Biology, and the Wildlife Society. They were addressing the coastal rainforests on National Forests in Oregon and Washington. These forests have experienced a long history of human impacts; the science team recognized the scale of importance relative to availability.

Another study in 2005 said Chilcotin has one of last best intact habitat areas left in North America to preserve 8 species of carnivores, especially wolves • Used 8 species: wolf, wolverine, cougar, grizzly, black bear, coyote, pine marten, fisher • Best area for conservation is an arc from Tweedsmuir south through Itcha Ilgachuz Park, Nunsti Park to the Churn Creek Protected Area Recent DNA study of South Coastal Ranges (Apps et al. 2009) identified 9 genetically discrete population clusters. North Cascades (23 bears) is isolated

• “Ancestral landscapes with little human access now separated by human activity and physiographic features that are likely to inhibit grizzly bear survival and movement”. Mine & new paved highway to Fish Lake will fragment continentally important dryland grizzly bear ecosystem on east side Pink/orange areas show units where grizzly bears are considered threatened in BC, including the Chilcotin Ranges GBPU. Population down to about 100, but Xeni have a protected core BASELINE INVENTORY: 2012 FIELD SURVEYS AT FISH LAKE MDA GROUNG-TRUTHING NEW PROSPERITY 2011 EIS • DNA from grizzly hair from rub trees between Little Fish-Fish Lakes shows grizzlies here travel to Chilko Lake and Chilko River salmon area. • Mine area on major grizzly wildlife travel corridor. Hair from 3 diff. grizzlies and 2 black bears Baseline Inventory: 2012 Ground-truthing. High spring & moderate summer/fall grizzly habitat values in Fish Lake MDA High Value spring grizzly habitat Example of Chilcotin grizzly on spring grassland range Chilcotin grizzly in typical riparian spring feeding & travel corridor 2012:DNA hair collection in Fish Lake MDA showed 4 male grizzlies but some samples spoiled. DNA hair-snagging study in 2007 showed 36 grizzlies in mid-upper Taseko. Most or all of these would come in contact with the mine site annually, meaning 1/6- 1/3 of GBPU population would be effected by the mine. BASELINE INVENTORY: 17 grizzly bear mark trees in 8.5 km between Little Fish & Fish Lakes & & Mid Fish Creek indicates not only local but regionally important movement corridor

. 2 mark trees/km indicates high value for bear travel (McCrory et al. 2004).

. From a study in Banff Park McTavish and Gibeau {2010) caution against the potential loss of these critical communication trees, which may have immeasurable value to many animals.

New Prosperity MDA found to be on major grizzly/wildlife travel corridor. Highest cluster of mark tree that I have observed in the Xeni Gwet’in Caretaker Area

BASELINE INVENTORY: Fish Lake has a high biomass of spawning rainbow trout in May-June that would attract a minimum of 15- 20 grizzly bears. Available spawning trout biomass at Fish Lake to be 78,143 kilograms or 171,915 pounds, only a portion would be catchable to grizzly bears Yellowstone National Park Study: This late-spring and early-summer food source is believed to be one of the highest sources of net digestible energy available in the spring and help bears regain body mass after emerging from their winter dens and also helps female grizzlies with young meet the energetic needs of lactation. THEREFORE EXTREMELY IMPORTANT TO CHILCOTIN GBPU GRIZZLY BEARS. NO OTHER SIMILAR AREA IDENTIFIED.

BASELINE INVENTORY:HUMAN-CAUSED GRIZZLY BEAR MORTALITY FOR CHILCOTIN RANGES GBPU

• Baseline human-caused mortality to grizzly bears between 2001-2013 from known and unreported causes was estimated to be 3.3- 3.7 bears per year. Approximately one half of the kill was estimated to be females. NEW PROSPERITY-CAUSED GRIZZLY BEAR MORTALITY = 4 – 7 grizzly bears/year

• Total mine-caused mortality was estimated to be 4-7 grizzly bears annually from all causes over the 35-year life of the mine (1-2 at mine site, 2-3 reported/unreported collision kills of grizzly bears on the highway to the mine, and 1-2 along the transmission line from hunters and other).

• Case in Point: In 2010 was an unconfirmed report of a mother grizzly and young being killed on the Taseko Road by a logging truck (Len Butler, Conservation Officer. Pers. Comm.)

PART 2: REVIEW OF NEW PROSPERITY 2011 ENVIRONMENTAL IMPACT STATEMENT (EIS) & ASSOCIATED DOCUMENTS CONCERNING NON-DETRIMENT FINDINGS RE- SOUTH CHILCOTIN RANGES GRIZZLY BEAR POPULATION

New Prosperity 2011 EIS, Sections 2.6 and 2.7, Terrestrial Component. Attempting to understand this lengthy, complex, detailed document and some of its deficiencies some times felt like this! For example, it weighs some mitigation on a Grizzly Bear Mortality Risk Reduction Plan but one find there is no such “Plan” as yet. ASSUMPTION: Since Taseko Mines remains technically unclear as to what industrial standards the current bush road will be up- graded to I am assuming it will eventually be a paved highway

• Explicit standards for the up-grade and re-routing of of the Taseko/Whitewater/4500 road to Fish Lake would be important to any EIS assessment of mortality risk to grizzly bears and other wildlife from traffic collisions. For example I cite evidence from Apps,, Hamilton et al. (2009) that the Duffy Lake Road (which is in the next GBPU south of the New Prosperity location) started as a logging road about 1970 and was upgraded/paved in 1991 to become an extension of Highway 99. This transportation improvement is believed to have caused the extirpation of resident female grizzly bears north of the road.

• Certainly whatever standards Taseko might eventually provide, it remains clear that the mine will result in significant access improvement to accommodate the projected 3-fold increase in traffic; with associated increased capability for accelerated speeds over current bush conditions.

McCrory Wildlife Services found EIS data base on grizzly bears to be seriously deficient and thus conclusions of no significant adverse residual impacts to grizzly bears confusing

• Emphasis on physical footprint conceptual habitat losses without sufficient ground-truthing of grizzly suitability maps for RSA and more site specific habitats for MDA such as importance of sites where grizzly bears feed on spawning rainbow trout. • Lack of quantification of baseline pre-mine and mine-caused mortality estimates for the Grizzly Bear Population Unit (GBPU) to accompany RSA mortality risk maps (core secure areas and road density). • An over reliance on proposed mitigation measures that have not been proven to be effective with respect to identified significant adverse cumulative environmental effects. • A general absence of integration from the scientific literature of some relevant information and case history studies to assess mine impacts on grizzly bears.

1. McCrory Wildlife Services Response to New Prosperity 2011 EIS findings that there would be a non-significant loss of wetland and riparian habitats and grizzly bear habitat values in the MDA and RSA • Any measure of habitat loss of a small development area against a much larger study area is typically going to show non-significance but this can be a misleading ecological yardstick. • Studies show grizzly bears make very high use of wetland habitats disproportionate to their small availability on the landscape in comparison to other habitat types • As noted, Fish Lake was found to be highly significant for grizzly bears to feed in May-June on a high biomass of spawning rainbow trout making this a high value nutritional supplement for at least 15-20 grizzly bears. In my professional opinion, the loss will be a significant adverse impact on the threatened GBPU grizzly population. Taseko’s 400 ha of wetland removal would cumulatively be the equivalent of removing twice the protected wetlands pictured in this valley area from the Xeni Gwet’in ecosystem-which is sparce in wetlands for wildlife. Their EIS claims grizzly bears can we afford such losses? But can they, when private ranchlands take away so much and when wetlands provide incredible biodiversity & will be diminished through global warming? 2. McCrory Wildlife Services Response to New Prosperity 2011 EIS findings of non significant effects of logging on wetland ecosystems in the mine RSA

• I would generally concur although drying effects may occur in some situations.

• In terms of forested habitats, EIS does not take into account climate change and wildfire impacts to grizzly bear habitat values. For example, 3 large wildfires in Brittany Triangle since 2003 has significantly improved grizzly and other wildlife habitat Wildfires will change forested habitats in mine area and improve already good habitat for grizzly bears [Ministry of Forests photos - 2003 Brittany burn] Xeni Climate change adaptation study (Ecolibro2010) shows some major concerns for global warming impacts on the XGCA. New Prosperity 2011 EIS looks at logging but does not factor in effects of climate change on bear habitats in MDA & RSA Climate change adapation Douglas fir - bunchgrass areas today In next 70 years, grasslands will increase & move north, & treeline will move higher up the mountains Upward shift in treeline will reduce meadow habitats for bears, less wild potatoes, whitebark pine nuts, etc. Reduced salmon & wetlands. Overall net loss for grizzlies from climate change 3. McCrory Wildlife Services Response to New Prosperity EIS of no net loss of grizzly habitat, & TEM- based habitat suitability maps • New Prosperity TEM-based habitat suitability maps generally show the RSA and MDA as overall low-very low habitat for grizzlies, with some small areas of higher value. These maps were not ground-truthed & tend to down-play real habitat values & do not factor in salmon values • Craighead & McCrory (2010) ground-truthed grizzly bear suitability maps that include salmon show moderate-high values in RSA and MDA, as does 2012 ground-truthing of habitats in MDA.

4. McCrory Wildlife Services Response to the New Prosperity 2011 EIS findings that there would be significance loss of fish and fish habitat ( but no significant loss of grizzly bear habitats)

• I estimate from EIS data (section 2.6) that the spawning biomass for grizzly bears at Fish Lake to be 78,143.4 kg or 171,915 pounds! While only a portion of this biomass would be available to grizzly bears in specialized, catchable habitat.

• The EIS calculates about 40+ % of Fish Lake spawning habitat will be left but it is unlikely that most grizzly bears will be able to still use their ancestral trout feeding sites due to the large industrial disturbance regime. Those bears that do will be exposed to high mortality risk from mine traffic conditions, uncontrolled attractants, accidents and so on. After all this will be the largest open pit mine in Canada.

Continued

• The trout compensation plan will do little if anything for the significant loss of Fish Lake trout as a major food resource for grizzly bears since it won’t involve replacing the trout spawning habitat and unique local situation at Fish Lake.

Both a high biomass of spawning rainbow trout and Taseko-run salmon play an important nutritional role in the ecology of the Dryland Grizzly Bear, trout in the spring at Fish Lake and salmon in the fall elsewhere. The mine development will virtually eliminate grizzly bear use of the Fish Lake ecosystem wetlands and trout. The mine highway will block access of of some eastern grizzlies to Taseko sockeye and cause significant mortality to and blockages of some grizzlies moving back and forth to access salmon. 5. McCrory Wildlife Services Response to New Prosperity EIS of no significance with respect to mortality risk as determined from GIS modeling of core grizzly bear secure areas & road density • Appear to be using logging road densities to down play real impacts of mine. Mortality risk from paved highway to mine will be much higher and can’t be measured just in terms of “road density”.

• Residual losses after mitigation are greatly under-played since much of the proposed mitigation has been shown to be ineffective.

• The extinction/extant “front,” where bears are already gone from the landscape, abuts the GBPU to the north and east, putting the MDA and some of the RSA on the extremely high risk “edge” of advancing decline / extermination,

Brittany Triangle core grizzly area Fish Lake still a significant core grizzly area

The kinds of impacts flowing from New Prosperity are precisely those that have forced grizzly bears out of a major portion of the province.

• There exists no evidence that the province (MOE) has the regulatory mandate, tools, or funding to meet the “collaborative” monitoring and mitigation agenda that New Prosperity is off-loading to the public agency, and,

• The science and conflict history across North America clearly demonstrates that human activity such as Taseko’s New Prosperity project will increase mortality and alienate habitat for grizzly bears.

6. McCrory Wildlife Response to New Prosperity 2011 EIS claim of finding “no concern” on interruption of the mine development on wildlife/grizzly bear movement patterns

• The MDA overlaps a highly significant regional movement corridor for grizzly bears between Big Creek Park and the Taseko that would be used annually by up to 36 grizzly bears based on Apps et al. DNA study. The mine development will cause significant disruption. • Some grizzly bears will divert their movement patterns from the mine MDA to the RSA to north of the mine where the main highway where they will be exposed to traffic collisions. • The mine highway in the RSA will cross a significant cross valley movement corridor for grizzly bears from Big Creek Park and elsewhere on the east side of the GBPU to access salmon in the Chilko-Taseko systems.

McCrory Wildlife Services Conclusion: • Disruptions of normal and ancestral movement patterns caused by the mine development, including increased mortality and habitat fragmentation will have a significant, adverse impact on grizzly bears in the GBPU, particularly causing nutritional stress and reduced survivability due to blockages to high value habitats including fish.

7. McCrory Wildlife Services Response of New Prosperity EIS concerning residual non-significance & human-caused mortality (hunter kills, livestock conflict, and human-bear conflict) to grizzly bears

• I estimate 1-2 grizzly bears will be killed annually within the MDA from a variety of sources including conflicts with mine workers, conflicts related to uncontrolled garbage, accidents.

• I estimate another 1-2 will be killed annually from increased hunter and other access created by the mine highway and transmission corridor. Defence of life kills, mistaken identify by black bear hunters, and others – generally go unreported Effects of 50 km Transmission line & access • Width (500 m?) will make for easier hunting, increased hunting opportunities.

• This long roaded corridor will effectively improve access for motorized access into a mosaic of intact grizzly habitats and areas already impacted by logging and roads. Nonetheless, despite gating and other restrictions, increased motorized 4-wheel drive and ATV use are expected to causing displacement and increased illegal mortality to grizzly bears.

• E.g. In endangered international Selkirk grizzly ecosystem with 50 bears, 4 of the 18 mortalities over a 14 year period were associated with closed (gated) roads (Wakkinen 1993, Wakkinen and Johnson 1996).

8. McCrory Wildlife Services response to Taseko’s EIS of non- significant effects on mortality of grizzly bears from mine- generated traffic mortality

• As noted, I project an estimated about 2-3 reported/unreported collision kills of grizzly bears annually on the mine highway due to it crossing a migratory corridor for grizzly bears to access salmon, etc. • in 2010 there was one reported but unconfirmed mortality of a female grizzly with cub as a result of a collision with a logging truck on the Taseko Road. This is a bad loss to the threatened population. • Mine road mortality will far exceed the high magnitude effect of significance where more than one grizzly bear is killed during the life of the Project as a result of collisions with Project-related traffic (March 2009 EIS/Application, Volume 5, Section 6.3.4.5).

Some grizzly bears habituate to roads and are more suspeptible to mortality In the old days, gravel roads & travel were much easier on wildlife [Photo: D. Williams] Proposed new road to Kincolith, BC (Demarchi 2001) • According to wildlife biologist A. Hamilton (pers. comm. 1999) concerns about potential impacts of the Greenville to Kincolith project on grizzly bear habitat were superceded by concerns about mortality risk posed by construction and operation of the road.

• Biologists projected that of the 175-270 grizzly bears estimated to be within the Stewart Meziadin GBPU, the road could negatively affect 40-60. Most effects would be in the form of disturbance and displacement, but based on regional data, an annual mortality rate of 4-6 individuals was forecast as a result of the road.

Projected cumulative impacts of mine access & development-roads

• Many studies show that access & roads have a negative impact on grizzly bears including loss of habitat, displacement from quality habitats within a Zone of Influence (ZOI) up to 3 or more km, blockage of movements. Most human- caused grizzly bear mortality occurs near roads (Horejsi 1999).

• In a Montana ecosystem somewhat similar to the West Chilcotin, grizzly bears showed strong avoidance of roads with 11-60 vehicle per day [vpd] (Mace et al. 1996). 60 vpd appeared to be a possible threshold for high avoidance, which we used to analyze the impacts of the Prosperity Mine.

• Less dominant bears (adult females, subadults) will also habituate to road sides, even with high traffic volumes, as “security” from male bears and become more susceptible to collisions with traffic and illegal killing.

• Roads cause habitat fragmentation and decreased habitat values from avoidance can cause population declines once the amount of roading and impacts passes a certain ecological threshold.

Taseko’s mitigation program will have limited results & largely be ineffective in reducing any grizzly mortality

• Food-garbage control at mine site important but overall projected mortality to grizzlies from cumulative effects of mine development cannot be effectively mitigated.

• Taseko proposes as mitigation as GRIZZLY BEAR MORTALITY MONITORING PROGRAM. With highway collisions, if one reported, 4 others not, so 4 may die or be injured before problem detected.

• Monitoring will do little or nothing to prevent mortalities and will not address illegal kills from increased motorized use of the transmission line roads or increased backcountry use (motorized) in XGCA as a result of human population influx into area from mine development

• Road closures, speed limits and other administrative attempts to mitigate access problems has limited effectiveness in reducing human-induced grizzly bear mortality (Horejsi 1999).

Increased backcountry motorized and non-motorized recreational/hunting/fishing use will lead to increased grizzly bear-people conflicts with increased defense-of-life kills as firearms are allowed.It only takes a few trigger-happy people to damage the population. Defence of life kills are often close to roads CONCLUSION: Mine-caused mortality and displacement from key habitats will push the Chilcotin grizzly bears over the extinction threshold • 4 % human-induced mortality the outside limited for small threatened populations (Horejsi 1999). E.g. 4 if accept current numbers at 100 and 8 if accept at 203. • Baseline mortality in GBPU is already 3.3.-3.7 killed annually and population likely already at the edge if not over. • Mine-caused mortality will add 4-7 annually, worse in years of poor salmon or berry crop and whitebark pine nut failures.

In the Journal of Animal Ecology, Bascompte and Sole (1996) refer to an “extinction threshold”

• Because grizzly bear populations are highly sensitive to human-caused mortality, habitat losses and displacement, critical thresholds are reached that should not be exceeded if the population is to be expected to survive or recover over the long term. New Prosperity will push the already threatened grizzly bear over the edge to extinction. Prognosis for any recovery not good. Case History: Schoen and Beier (1990) - grizzly bears & mine in S.e. Alaska

• Six radio-collared grizzly bears denned significantly further from mine in the 2nd year • Significant decrease in use of grizzly bear day-beds along new road • One female bear was monitored from before the mine (1982) to the spring of 1989. Prior to 1986 she successfully weaned two litters of 2 cubs each. After that she lost two consecutive litters. The researchers had no direct evidence that development activities were implicated in her reproductive failure, but suggested the possibility that displacement from her familiar feeding area along lower Zinc creek in 1987 may have reduced her reproductive effectiveness.

Other case histories

• Johnson et al (2005). Collared grizzly bears in arctic showed mineral exploration sites had a moderate influence in use of summer habitats up to 23 km.

• “habitat loss for grizzly bears was most extreme during late summer and autumn, where we measured 12 and 11% reduction in the total availability of high and good-quality habitats, respectively”. Note: This is a critical time for pre- denning weight gain

Case Study: High black bear mortality at Syncrude Mine • I worked on wildlife impact studies here in 1970s including mitigation recommendations. • Study of wildlife mortalities 2000-2008. Syncrude was responsible for the majority of mortalities, including 43 deer, 20 red fox and eight black bears. Possible causes of mortality include euthanasia of problem wildlife, drowning or oiling from tailings, animals hitting infrastructure (e.g., buildings), or vehicles and electrocution. Numbers of dead animals reported to government underestimated true mortality because they were derived from ad hoc reporting by companies. Also:Huge investment by Society in protecting this ecological system. Proposed Prosperity Mine, jeopardizes ecological integrity of world-class protected areas that anchor the grizzly bear and other vulnerable carnivores

. Xeni Gwet’in aboriginal/wild horse preserve - 770,000 ha • Tsylos Provincial Park - 233,340 ha • Big Creek Provincial Park - 65,982 • Spruce Lake Protected Area - 71,347 ha

INDUSTRIAL EXAMPLE: Although the Waneta construction site is in a busy industrial corridor, it borders on a large rural wild area. Bears likely gathered here in the distant past to catch salmon. Some bears “habituate” to such areas if food sources, denning habitat and other habitats are available.

OTHER CONCERNS-Listed Western Toad breeds at Fish & Little Fish Lake

• Western Toad is federally listed - Species of Concern. Adults migrate from mountains to lakes/ponds in spring. Baby toads migrate from ponds in late summer. Lots die where cross roads

New Prosperity EIS does not adequately address issue of high traffic kills of the listed toad at Fish Lake. Taseko Mine Highway will cause considerable wild horse mortality as horses regularly cross current bush road to access habitats on both side.

Much of north end of GBPU has very high overlap of private and public cattle lands with prime spring and fall (salmon) grizzly habitat

My conclusion: Strongly disagree with Taseko EIS that no significant effects on wildlife, incl. grizzly bears. There will be adverse effects on grizzly bears in an already stressed ecosystem – with virtually no government ability for mitigation

• Taseko’s EIS was based largely on species habitat assessments that were used in a limited area-type assessment, comparing amount of habitats lost by the mine development versus availability in regional study area.This does not take into account degree of concentrated use of some habitats such as wetlands by grizzly bears. • Did not adequately address conservation status and cumulative threats of species at risk such as the grizzly bear or other indicator species. Less wary bears don’t always avoid at construction sites or [Photos: Get Bear Smart Society files]

Taseko’s mine will triple the vehicle traffic on the Taseko/Whitewater Road from about 100 vpd to about 300 vpd.Where did the numbers come from for current use? Seem far too high. Evidence does not support New Prosperity 2011 EIS claims that no grizzly bear mortality or significant adverse effects from 50 km up-graded & industrial paved mine highway to mine with 3 x today’s traffic volume. • Summer traffic levels of two transprovincial highways through Granby grizzly area in s. BC about 90 - 100 vpd. 1989-1997, 1/3 of what Taseko road will be if mine developed: At least one Granby grizzly mortality on hwy (Horejsi 1999). • Population of 50 Granby grizzlies cannot sustain one highway induced mortality per year if female (Horejsi 1999). • For every bear reported killed on a highway, 5 more die but go unreported (MOE map: 1990-1999). • MOE Map: 1990-1999. 3 bears (likely black bears) reported killed on highway between Wms. Lake and Hanceville. between = 15 if add in unreported. • Ministry of Transportation does not keep mortality data for Taseko Road from Hanceville to Nemiah. • In 2010, COs had unconfirmed report of a mother grizzly and young being killed by logging truck on Taseko Road.

Road improvements & tripling of traffic volumes from Hanceville to New Prosperity proposed mine will increase impact on large carnivores including grizzly bears from low-moderate to high-very high (Evink et al. 1996)

Impacts on grizzly bears - Taseko/Whitewater Road & “4500 road”

• If current use of Taseko/Whitewater road is >60 vpd then much of grizzly habitat within 0.5 + km of the road already reduced in value from traffic for about 40 km across the plateau. • However, core grizzly habitat mapping shows some smaller core roadless areas on the plateau, despite logging & fragmentation. • Significant increase in traffic from mine will still have an impact on habitats along the Taseko/Whitewater Road by closing off reduced movements of warier grizzlies across the plateau and causing mortality to subdominants that habituate to roadsides. • 4500 road is 10

“The practice, now common, of identifying “critical habitat” and classifying it into management situation categories is an approach that may help a few individual bears over the short-term, but, over the long-term, will surely violate the totality of resources and space necessary for population viability” (Dr. J. Craighead 1995).

Equating area-based habitat species model losses of the mine development as only a small % of regional area is presents a highly misleading impact picture of the mine footprint & cumulative effects

• E.g. 400 ha loss of wetlands = only 2 % loss of wetlands of the Prosperity Mines RSA (regional study area). • A grizzly bear radio-telemetry study in southeast British Columbia (McLellan and Hovey 1993) demonstrated that grizzly bears made a much higher proportionate use of wetlands than their distribution over the landscape. Although wetland/riparian habitat comprised only 8.5% of the study area, 40% of the transmitter locations of 46 radio-collared grizzly bears between May 15 – July 22 (and located 10 or more times) were in wetland habitats. Some bears were located 85% of the time in this type of habitat during this period. • Similarly I disagree with the approach used by the CWS on waterfowl that measured (as expected) small (402) breeding pairs in the Prosperity RSA (Breault 2008) as a small percentage of the much greater-sized Chilcotin Plateau. This does not address cumulative wetland losses in the overall region nor losses of wetlands predicted from global warming. Nor does it address total numbers of migrant waterfowl that pass through the RSA each season and might be subject to contaminants should the projected contaminant containment system fail, just as waterfowl have been subjected to at the tar sands.

Meadows - one km west of Fish Lake - Important trout & grizzly spring habitat/travel route; east end has mining damage

Suring et al (1998)

• Cumulative effects model of Chugach National Forest in AK. Mining operations, recreation sites accessible by motorized means, recreation trails, open roads and residential / townsite areas. • CONCLUSION: Simultaneous analysis of all known human activities resulted in a total cumulative reduction in habitat effectiveness (HE) of 71% for spring and 72% for summer.

Concluding remarks on grizzly bears

• Taseko Mines claims their development will have no significant impact on grizzly bears and other wildlife over the life-span of their gold-copper open pit mine. However, there are a number of species within the mine area and its large Zone of Influence (ZOI) that are already in various stages of federal and provincial listings as at risk from cumulative impacts that include excess roading and clearcutting, habitat losses and mortality from human settlement, extensive mining exploration activities (Upper Taseko), over-grazing (e.g. sharptailed grouse), illegal killing, climate change and other factors. The provincial listing of the Chilcotin grizzly bear as “threatened” is by definition a sound indicator of significant impacts, meaning that the species has already undergone significant adverse effects human development and associated activities. Climate change effects on wildlife are not even considered in Taseko’s EIS. Based on the evidence I have presented, I can only conclude that the Prosperity Mine will push vulnerable species like the dryland grizzly bear over the edge to extirpation.

Other important concerns: Main Industrial transportation corridor will pass through sector with highest Min. of For. Wild horse counts (Avg. 370 horses, 2006-2009. 42% of total average for region. A. Dobb data analysis

Currently little observed road impacts and horse road kills.Rough nature of road = slow traffic

• Note on wild horse map for the region that the majority of wild horses have their territories away from the main Williams Lake-Bella Coola Highway. • For the Taseko Road, some horse bands appear habituated to road traffic but will generally run off if the vehicle stops. Many other bands appear to avoid the road but will cross it. In winter, often see where a herd has crossed the road. • To cross the road, wild horses sometimes suddenly make a dash right out of the forest, en masse. This makes them vulnerable to traffic collisions. • Since horses generally stay in herds of up to 16 or more, I predict that with the significant improvements necessary to bring the current road up to industrial standards combined with a tripling of daily traffic volumes and speed that there is going to be a rapid escalation of wild horse- traffic collisions.

Other important concerns: Taseko road will cross major mule deer movement corridor • Improved road for mine will cause considerable mule deer road kills • Whole plateau an important subsistence mule deer hunting area for First Nations. Proposed mine will negatively impact ecological integrity of adjacent protected areas

Huge investment by society in protecting ecosystem. Mine will jeopardize ecological integrity. • Xeni Gwet’in aboriginal/wild horse preserve - 770,000 ha • Tsylos Provincial Park - 233,340 ha • Big Creek Provincial Park - 65,982 • Spruce Lake Protected Area - 71,347 ha