"%#%(!'!#(&%(#!'&#'%(!" '(""'(&"#&#(&% !'!'&#"%(&%('#''%(%'('%'!(&%( &("&(&(((( The BC government should not sacrifice our priceless wildlife habitat and public recreation land to be exploited by large-scale tourism de- velopment. In the past, many of BC’s most su- perb scenic, wilderness and wildlife areas were put on a tragic path of luxury development to draw hordes of people and money for devel- opers. Today, our remaining wildlands are more valuable than areas overrun by tourists; they have a crucial role to play in stemming the loss of species, and preserving opportuni- ties for enjoying nature without destroying it. $ $$($ ( 1 $ $$($ ( Box 329, New Denver, British Columbia, Canada V0G 1S0 Phone: (250) 358-2333, E-mail: [email protected], www.vws.org June 4, 2020 Kelly Northcott Mountain Resorts Branch Min. of Forests, Lands, Natural Resource Operations #510-175 Second Avenue Kamloops, BC, V2C 5W1 Phone: (250) 312 7235 REVIEW OF ZINCTON RESORT EXPRESSION OF INTEREST I. SUMMARY Mr. David Harley seeks to build a resort town on 1,000 hectares of private land at Three Forks, with an additional 4,500 hectares of Crown land for skiing and mountain biking development. The total resort area would follow Highway 31A for 12 kilometres between Three Forks and Retallack, and be adjacent to the southernmost boundary of Goat Range Provincial Park. It is said to be bigger than Whistler and Blackcomb combined. The resort town on the private land would have a resort capacity for 1,750 people, which is three times the population of New Denver. The private land portion covers an area a little larger than Nelson, BC; by population it would be the largest town within a 75-kilometre radius, and be populated with “bunkhouses, private cabins, restaurants, bars, spas, general store, and other resort-related businesses”. The Crown land portion of the resort would be developed with a “luxury” backcountry lodge for 24 peo- ple in the Goat Creek watershed, and a network of trails for mountain biking and glading for ski runs on London and Whitewater Ridges, with visitors carried to the top by at least two gondolas. A “highway con- nector” (ATV track or road) between the lodge and the highway would service the lodge. Highway 31A from New Denver to Kaslo, and particularly the segment from Three Forks to Retallack, C. Pettitt London Ridge — Whitewater Ridge can be seen on the far right in the background. The far left end of London Ridge is descending to Three Forks. The proponent’s application covers both sides of London Ridge. 2 traverses some of the highest quality, unprotected wildlife, scenic, recreation and tourism lands in the West Kootenays. Although it has been logged and is still being logged, the high natural values are integral to the lives of many residents, who use it for hiking, skiing, backroad travel, berry-picking, fishing, biking and many other activities. In these days of biodiversity crisis, climate change and wildland fires, the whole idea of plunking a popu- lation centre for 1,750 people in the midst of a wildland area inhabited by grizzly bears and many other species of wildlife is inappropriate and shocking. This was expressed in the massive public opposition to the now failed Jumbo Glacier Resort, which cost BC decades of social and legal conflict. Logging, which can be ecologically destructive, is far less so than a resort for 1,750 people. After logging is done, those species that can still use it will eventually have habitat on the cutblocks. This includes the grizzly bears and moose in this proposal area. But a permanent human population centre is a permanent blow to all the more sensitive species — and one that inevitably expands over time. Whitewater Ski Resort is only a little over an hour from Zincton. It offers backcountry touring and has no need to degrade the environment with massive infrastructure, as it is only 20 minutes away from Nelson with acres of accommodations, restaurants and shops. Why would the government want to try to replicate all that along a scenic highway and mountain ridges that provide a wilderness home to grizzly bears and mountain goats? According to professional wildlife biologist and Grizzly Bear expert Wayne McCrory — based on his ex- tensive research experience, including with other human population centres and ski developments such as Whistler-Blackcomb and the proposed Cayoosh ski development — the Zincton development would add to cumulative impacts of past development such as logging roads and Highway 31A, causing serious di- minishment of some species, including three provincially blue-listed species known to occur in the pro- posal area: Grizzly Bears, Wolverines and Mountain Goats. It will also cause increased mortalities of Western Toads (a SARA-listed Species of Concern) and undermine a $165,000 conservation project car- ried out by the Valhalla Wilderness Society in conjunction with several government departments, local volunteers, and other organizations. McCrory warns that: “The development will be a sinkhole for the Grizzly Bears of Goat Range Provincial Park, which range outside the park. Population decline will result from bear-human conflicts including mortality, displacement, and diminished reproduction due to stress. Over time the development would decimate, not only those grizzlies in the park, but also those that travel from a wide area, attracted by ex- tensive berry patches as well as garbage and lawns in the resort. The overall cumulative effect combined with existing logging, roading and Highway 31A traffic levels will fracture the grizzly bear connectivity corridor that exists between the Central Selkirks and struggling grizzly populations to the south into the U.S., breaking apart important gene flow needed for the viability of the smaller populations.” McCrory cites the example of Lake Louise in Banff National Park, which researchers found to have the highest grizzly bear death rate in the Rocky Mountains due to the overlap of extensive buffalo berries and very high numbers of people. The Zincton proposal plans to bring thousands of people by gondola onto London Ridge, which is also rated by McCrory as high quality habitat due to extensive huckleberry areas, alpine/subalpine Glacier Lily and Spring Beauty corm feeding areas, alpine denning habitat and travel corridors (Goat Pass). The Zincton EOI dangles a promise of greatly increased tourism, jobs and income that will cause New Denver to flourish economically. But most if not all ski resorts in BC, and many around the world, are concerned about their long-term economic viability right now, given that climate change is already forc- ing many to depend on artificial snow. This submission will show that New Denver and Kaslo still have a stunning array of attractions along Highway 31A, suitable for low-impact wilderness- and nature-based recreation and tourism, that would be harmed by high numbers of people drawn by the proposed resort. 3 II. ERRONEOUS OR MISLEADING ASPECTS OF THE EOI There are many important factors in the Zincton EOI that have either been exaggerated, omitted or mis- portrayed. Below we review some of these statements, which are presented in quotation marks: EOI: “Unaltered, natural landscapes” The scale of the development required to host 1,750 people would be very visible on the mountain slopes above Three Forks. There would have to be a major parking lot, the location and size of which is not specifically shown in the EOI. Staff housing will apparently be near the highway along Seaton Creek. Gondolas would have substantial visual impact, as would the “luxury” lodge in Goat Creek watershed. Then there would be the gladed ski runs that have powerful visual impact on ski hills, as well as a net- work of mountain bike trails. EOI: “1,600 metres of skiable vertical” Some claims about the ski attributes of the London and Whitewater Ridges may be exaggerated, which throws into doubt the reliability of the economic viability of the project. For instance, the claim of 1,600 m skiable vertical, making Zincton the second longest descent in the region, cannot be verified due to key figures that are missing from the EOI. It does not state the top and bottom elevations of the ski runs. There is reason to believe the total figure may be inaccurate. For instance, in some cases the proponent seems to state the top of Whitewater Mountain as part of the skiable vertical. But approximately the top 500 m of the mountain is accessible only to mountain goats and climbers with ropes. Similarly, the EOI is evasive about the location of the bottom of the ski runs. The claim that much of the ski terrain is north-facing is inconsistent with the proponent’s maps, which show the area dominated by southerly exposure. This might mean a short ski season as sunny days make a crust on the snow or turn it to slush with often accompanying high avalanche hazards. The EOI did not take into account climate change and does not acknowledge that having to make artificial snow is a com- mon practice at ski resorts today. That would entail huge consumption of water and energy. Where would it come from? What would it do to the three creeks? EOI: “The proposed area does not contain any at- risk terrestrial species, or any ungulates or ungu- late habitat.” • Goat Range Provincial Park, adjacent to the proposal, has a Master Plan that lists 41 provincial species at risk including 10 red- listed and 31 blue-listed species. • Some of the species at risk are charismatic megafauna known to occur in the proposal: Grizzly Bears, Mountain Goats and Wolver- ines are blue-listed in BC. G. Parker The proposal area is high-quality mountain goat habitat. Today • For ungulates, White-tailed Deer, Mule they are blue-listed in BC.