February 15, 2010
Hon. Barry Penner Minister of Environment
Dear Minister: “The caribou feeds the wolf, but it is the wolf who keeps the caribou strong” Inuit Proverb
For many centuries, the wolf, caribou, and Inuit lived in harmony. The caribou provided sustenance to both the wolf and Inuit people. The wolf kept the caribou strong by killing the weak, old, injured and caribou calves, thereby eliminating the weak caribou, reducing disease to the herd and allowing the caribou herd to flourish. The Inuit people who depended on the caribou watched this interaction for centuries and kept it in balance.
What has gone so terribly wrong? Why has the caribou in BC been so decimated that it ended up on the endangered species list? Do not look to canis lupus as the problem because the wolf kept the caribou strong for centuries. Michael Bloomington, head of Alberta’s Caribou Management Plan from 1978-83 stated, “the wolf is being made to pay the price for what is really the consequence of human activity in the area.” This human activity in BC which has caused the mountain caribou herds to be placed on the endangered species list is:
- Extensive logging of old growth forests which the mountain caribou depend on
- Disruption and fragmentation of the mountain caribou habitat by logging, mining and other resource extraction
- Disruption of the winter mountain caribou environment by heli-skiing and snowmobiling
- Human caused over hunting of the mountain caribou
These human activities cause many more mountain caribou deaths than any predation by wolves.
Your ministry along with all British Columbians must be better stewards of the environment because the environment and the wildlife belong to all British Columbians, not the Ministry of Environment. You are just the Trustee!
Many wolf biologists in their studies have concluded that wildlife managers must carefully and continuously monitor prey populations so that wolf predation is not additive but merely compensatory.
The Ministry’s proposed wolf cull is yet another response by the anti-wolf faction in your ministry and the contractors you employ. Stephen F. Wilson’s report “Recommendations for Predator-Prey Management to benefit Mountain Caribou Recovery” is an example of the anti-wolf bias.
There is no evidence in his report or the reports of the Mountain Caribou Recovery Team that wolves are heavily preying on mountain caribou calves. Evidence would include conclusive evidence of wolf kills of caribou calves and caribou found in wolf scats.
Wilson relies on the vague statement of Bergerud that wolf predation is considered the major factor limiting the growth of caribou populations in North America.
L. David Mech and Rolf O. Peterson dispute Bergerud’s analysis. They state, “while Bergerud’s analysis provides evidence that predation by both wolves and bears can be strongly limiting, his claim that wolf predation is generally regulatory is based more on reasoning that on actual evidence.” (Mech & Peterson 2003)
Wilson admits in his report that grizzly and black bears are major predators on mountain caribou calves but due to public pressure on conserving grizzly bears and reductions of bear populations would have to be large because it is difficult to identify and remove problem bears. No where in his report does Wilson admit that removing problem wolves would be difficult or against public perception. No he justs recommends removing whole packs!
In fact studies have shown that grizzly and black bears can be a very high source of ungulate calf death (91%) (Ballard 1979 & 81)
Ministry of Environment again recommends further wolf control even though many prominent wolf biologists (Mech, Haber, Theberge) state that wolf control programs do not work. Mech and Peterson (2003) state, “during the 1980’s & 1990’s there were extensive efforts, primarily through wolf control in Alaska and Yukon, to induce prey populations to increase to a high stable equilibrium, but none was successful.”
Wilson states in his report that Mountain Caribou Science Team and MOE biologists consulted in the drafting of the report strongly recommended that wolves targeted for removal should be shot from helicopters. Are your staff not aware of Section 27(2) of the Wildlife Act (BC) which states, (2) A person commits an offence if the person (a) hunts wildlife from an aircraft?
The Minister does not have the authority to authorize predator control programs by shooting from aircraft including helicopters because this activity is regulated by the Federal Government. Is the Minister aware of the Canadian Aviation Security Regulations?
The Canadian Aviation Security Regulations prohibit any carrying of loaded firearms or shooting from an aircraft. Under subsection 27(1) there is a provision to allow a federal or provincial department or agency that is engaged in wildlife control to have an unloaded firearm on the plane. Transport Canada officials have assured me that no firearms can be loaded on an aircraft nor can any shooting from an aircraft occur.
Can the Minister assure me that no hunting of wolves by ministry staff, or staff contracted by the ministry or any other sanctioned wolf control activities by the ministry, is being conducted or considered from helicopters or any other aircraft?
In the Caribou Progress Report of April 29,2008 it states that there has been extensive radio-collaring of wolves. 22 packs or 70% of wolves between Williams Lake and Revelstoke are now collared. MOE staff in the past have used these radio collars to locate wolf dens and have killed the pups and adult wolves. This is by way of their own admission that I obtained this info. Can the Minister assure me that these radio-collared wolves are being studied for research purposes and not a means for wolf control?
This same report stated that 6 male wolves and 6 female wolves have been sterilized in the Quesnel Highlands. Is this unethical practice of sterilization of wolves continuing? Who is performing this sterilization?
How many wolves have been killed in BC as a direct result of managing the Mountain Caribou Recovery?
There is a fundamental principle of human justice which is equal treatment for all under the law. As a society we have advanced minority rights, women’s rights, and rights of oppressed religious groups to have equal treatment under the law. I submit that this same principle applies to how we treat wildlife. Under your ministry care, wolves have always experienced unequal treatment as compared to other species. The MOE has promoted bounties on wolves, poisoning of wolves, and recently harsh wolf culls like the 1980’s Muskawa/Kechika wolf slaughter. This harsh, unequal treatment continues under the guise of predator control to augment the mountain caribou herds.
Wolf control is always the default position of the MOE. There has to be a paradigm shift from this thinking to wolf control as the very last measure after extensive research and consultation by a panel of prominent wolf biologists.
I ask the Minister to give canis lupus in BC the treatment it deserves as stated by L. David Mech, “I hope I can help other people to see the wolf for what it is: one more magnificent species, superbly adapted to contend with its harsh environment, and highly deserving of our understanding and acceptance.”
I look forward to your response.
Sincerely, Gary R. Allan, JD