Affidavit #2 of Petr Komers by sagelegal

JAN 31 ZQW

Peoinv Affirmed/Sworn the 30th day of January, 2018

Affidavit #2 of Petr Komers No.: 18 0247 Victoria Registry

IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: WEST MOBERLY FIRST NATIONS, and ROLAND WILLSON ON HIS OWN BEHALF AND ON BEHALF OF ALL OTHER WEST MOBERLY FIRST NATIONS BENEFICIARIES OF TREATY NO. 8 PLAINTIFFS AND: HER MAJESTY THE QUEEN IN RIGHT OF THE PROVINCE OF BRITISH COLUMBIA, THE ATTORNEY GENERAL OF CANADA, and BRITISH COLUMBIA HYDRO AND POWER AUTHORITY DEFENDANTS AFFIDAVIT OF PETR KOMERS I, Petr Komers, with a business address of 207 Edgebrook Close NW, Calgary, Alberta, ecologist, AFFIRM/MAKE OATH AND SAY AS FOLLOWS: 1.

I have personal knowledge of the things I say in this affidavit, except where stated to be based on information and belief and where so stated I verily believe the same to be true.

I am an ecologist with over 20 years of experience conducting and supervising university research, and publishing in peer-reviewed journals. My specialization includes the assessment of ecological impacts, regional habitat use, population ecology, and the assessment of disturbances on a wide range of wildlife species including species at risk listed under the Species at Risk Act. I received my Doctor of Philosophy from the University of Saskatchewan in 1992. Since 2002, I have been the President and Principal Consultant at Management and Solutions in Environmental Sciences (MSES) Inc. A copy of my curriculum vitae is attached to this Affidavit as Exhibit "A".

Attached to this Affidavit as Exhibit "B" is a copy of a report dated November 25, 2013 by Dr. Scott McNay (the "McNay Report"). This Report is a technical review of the Site C Page I of 3

Environmental Impact Statement ("EIS") and related materials concerning wildlife resources,

specifically furbearers, ungulates and large carnivores including (but not limited to) EIS guidelines, baseline studies, response to information requests and amendments, and to provide advice regarding significant residual adverse environmental effects of the proposed Site C project.

I reviewed the McNay Report and I found no issues in the report that would be contrary to my knowledge or opinion save the following:

On page 16, the author states: "The fact does remain however, that the proposed

Project will have a significant effect on these species populations at the local level by a permanent, irreparable loss of habitat that will eventually translate to loss of the local population. .

I agree with this statement subject to how "local population" is defined.

We are not aware of any quantitative assessment of the viability of the local population as identified by West Moberly First Nations or other Aboriginal groups.

On page 18, the author states: "It is our opinion that mortality risk for displaced

animals is difficult to assess without consulting results of previous projects of a similar nature." I agree with this statement, and have identified similar data gaps in a number of environmental assessment processes for previous projects.

I hereby adopt the McNay Report, subject to paragraph 4, as my expert evidence in this proceeding, and certify that I hold as my expert opinion the opinions, conclusions and recommendations

made

therein.

The

factual

assumptions,

research

conducted,

and

documents forming the basis for these opinions, conclusions, and recommendations, as well as applicable limitations thereto, are set out in that Report.

I certify that I am aware of my duty as an expert witness to assist the court and not be an advocate for any party. This duty prevails over any obligation that I may owe to any party, including West Moberly First Nations on whose behalf I have been engaged.

I further certify that I have made this affidavit in conformity with this duty and will, if called on to give oral or written testimony, give that testimony in conformity with this duty.

Page 2 of 3

In particular, in preparing this affidavit, I acknowledge that it is my duty to provide: evidence that is fair, objective and non-partisan; evidence that is only related to my area of expertise; and, such additional assistance as may reasonably be required to determine a matter at issue.

AFFIRMED/SWORN BEFORE ME in Calgary, Alberta on January 30, 2018

) ) ) ) ) ) )

A commissioner for taking affidavits for Alberta

) )

Petr KOMERS

TERRY E GILHOLME Barrister & Solicitor

Commissioner for Oaths/Notary Public In and for Alberta

Page 3 of 3

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Petr E. Komers, Ph.D. Wildlife, Land-use, and Environmental Impact Assessment Overview Dr. Komers specializes in the assessment of ecological impacts, regional habitat use and population

ecology.

He integrates this expertise with community,

municipal, and regional land-use plans.

routinely acts as an expert witness, a referee of scientific manuscripts, and as an examiner at university thesis defenses. For over 20 years, Dr. Komers conducted and supervised university research and

published in peer-reviewed journals with his students and colleagues. Dr. Komers applies his expertise when advising review boards, legal teams, and other decision makers regarding project impacts on

communities and people. He leads multidisciplinary teams in reviews of impact assessments, advising on completeness and deficiencies, and recommends actions to ensure that environmental management plans are thorough, practical and relevant regarding the identification and management of environmental

change. Dr. Komers has led ecological assessments in Canada, USA, Europe, Asia and Africa. His experience includes multimillion dollar industry and research projects in wildlife ecology, leading of

international scientific teams, and the development of environmental standards. Dr. Komers has been selected by the Government of Alberta to join the roster of Albertans who may be called upon to serve on review panels of regional plans under the Alberta Land and Stewardship Act. He resided in six countries

and is fluent in six languages. Dr. Komers works with proponents, Indigenous communities, governments, and NGOs.

Areas of specialization Conservation biology, ecosystem change, wildlife ecology, environmental impact assessment, third-party review, community engagement.

Key Experience •

Designed,

managed, and written

America, Asia and Africa.

multi-disciplinary environmental impact assessments

North

Since the early 1990s, led teams of science practitioners in assessments

ranging from local assessments of environmental applications to multimillion dollar projects of international significance.

•

Designed,

managed,

and

written

multi-disciplinary third-party reviews

industry

regulatory

applications and environmental management and monitoring plans. This was done on behalf of Indigenous communities as well as Review Boards at the provincial and federal levels throughout

Canada starting in the late 1 990s. •

Served as an

expert witness and advisor in

well over

1000 hours of hearings and technical

workshops in presence of legal teams.

•

Authored over 50 peer-reviewed or international papers, presentations and invited speaker lectures with a focus on wildlife ecology and conservation, impact assessment and the engagement of

indigenous peoples. •

Supervised graduate students conducting university research in wildlife ecology and conservation at the University of Calgary, Canada, and the University of Uppsala, Sweden.

THIS IS EXHIBIT "

referred to in the 'Affidavit of

yffir TE R R Y E G ! L H O L M b Barrister & Solicitor

Sworn before me this ... Jsf

Commissioner for Oaths/Notary Pubfffev °f- -

D. 20

In and for Alberta *<-?7mmissj<)ni:r for oaths IN -IN/) FOR Al.maiTA

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Key Projects Scientific Advisor to the Environmental Impact Review Board, Inuvialuit Settlement Region, NWT, for the Inuvik to Tuktoyuktuk Road development. Scientific Advisor (wildlife) to the Mackenzie Valley Environmental Impact Review Board, the Gahcho Kue mine project and the Taltson Hydroelectric Project, NWT.

Scientific Advisor to the Environmental Monitoring Advisory Board, Diavik Diamond Mine, NWT. Lead on the wildlife impact assessment for the Mackenzie Gas Project, NWT. Regional Land Use planning and mapping analyses for First Nations in Northern Alberta. Third party reviews of ElAs on behalf of Aboriginal communities: projects in the Alberta Oil Sands,

Diamond Mines in the NWT, and Hydroelectric Projects in Manitoba and British Columbia.

Great Sand Hills Regional Environmental Study - Third party review on behalf of the File Hills Qu'Appelle Tribal Council

Scientific Advisor to the Energy Resources Conservation Board, Encana Suffield project. Ecosystem Goods and Services Assessment by Alberta Environment, third party review and PowerPoint presentations on the strategy.

Research on industrial disturbances in Southern Alberta and the Foothills Natural

Region;

supervision of Graduate Research Projects, University of Calgary. Research on wildlife population management in Alberta, NWT, Kenya and Sweden.

Lead for the wildlife impact assessment of two mining projects in Alaska.

•

Environmental impact assessment and environmental management plan in Kirthar National Park (Pakistan).

Employment Experience 2002 - present

MSES Inc.: President and Principal Consultant

(International

Project

Development,

Environmental

Evaluation

and

Planning,

Management of Environmental Science Teams) 2003-2007

AMEC Earth & Environmental Ltd., Calgary, Alberta: Casual Consultant

(Lead Wildlife Ecologist for the Mackenzie Pipeline Environmental Group, Project Planning, Implementation and Management; Environmental Assessment and Planning) 2001 -2002

Inuvialuit Environmental & Geotechnical Ltd.: Manager Biophysical Services (Project Planning

and

Implementation,

Senior Review,

Science Advisor,

Public

Consultation)

1997-2001

AMEC

Earth

Environmental

Ltd.,

Calgary,

(Environmental Assessment and Planning,

Alberta:

Project Planning,

Senior

Consultant

Implementation

Management, Public Consultation, Environmental Regulation) March 1998

University of Calgary, Alberta: Sessional Lecturer

(Preparation and Delivery of Lectures in Conservation Biology, Student Advisor) 1995- 1996

University of Uppsala, Sweden: Research Fellow

and

49 MSES r*j 'kMtra " trramwftt ScÂŤ<Âť

(Fundamental / Applied Research, Project Development and Management,

Student

Supervision, Public Consultation, International Team Leadership) 1993 - 1995

University of Cambridge, England: Research Fellow

(Fundamental

Research,

Project

Development

and

Management,

International

Collaboration)

1988 - 1992

University of Saskatchewan, Canada: Sessional Lecturer; Teaching Assistant

1985 - 1987

University of Alberta, Canada: Teaching Assistant

Education 1993 - 1997

Post-doctorate, University of Cambridge, UK, and University of Uppsala, Sweden

1988- 1992

Doctor of Philosophy, University of Saskatchewan, Canada (Thesis: Mating strategies of male wood bison)

1985 - 1987

Master of Science, University of Alberta, Canada (Thesis: Mate choice in black-billed magpies)

1981 - 1984

Bachelor of Science, University of Berne, Switzerland

Awards 1995 - 1997

Swiss National Science Foundation (SNSF) Post-doctoral Fellowship, Switzerland

1993 - 1995

Natural

Sciences

and

Engineering

Research

Council

( NSERC)

Post-doctoral

Fellowship, Canada 1993-1995

National Geographic Research Award, USA

1990-1992

University of Saskatchewan Graduate Award, Canada

1988 - 1990

Natural

Sciences

and

Engineering

Research

Council

{NSERC)

Post-graduate

Scholarship, Canada 1989-1991

World Wildlife Fund Canada Research Grant

Affiliations Member

Editorial/Advisory Board for the Journal of ETHOLOGY, ECOLOGY & EVOLUTION

Alberta Roster

to serve on review panels of regional plans under the Alberta Land and Stewardship Act

Advisor

University of Calgary Environmental Science Program, External Advisory Committee

Past-President

Alberta Society of Professional Biologists (ASPB)

Past-Adjunct

Adjunct Associate Professor, University of Calgary, Biological Sciences

Publications Presentations

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Komers, P.E. 2017. Science, Policy, and Indigenous Peoples. Environmental Science Program; invited speaker. Department of Biological Sciences, University of Calgary. March 2017

Komers, P.E. 2016

Who gives? On sharing land with bison, moose and wolves in a changing

landscape. Invited speaker. Department of Biology.

Universita di Firenze, Italy. August 2017

Komers, P.E. 2013. Rates of Land-cover Change in the Alberta Boreal Forest. Ecology and Evolution Seminar; invited speaker. Department of Biological Sciences, University of Calgary. November 2013

Komers,

P.E. and Kopach, B. 2013. Using ecological analysis to assess impacts on rights of indigenous peoples. Session chair and organizer. Presented at International Association for Impact Assessment, Calgary, Canada, May 2013.

Gavin, S., S. Hechtenthal, A. Stewart, T. Whidden, Z. Stanojevic and P.E. Komers. 2010. Maintaining wildlife movement: the need for regional planning. Presented at International Association for Impact Assessment, Geneva, Switzerland, April 2010. Best Poster Award. Kienzle S.W., J. Byrne, D. Schindler and P. Komers, 2005. Northern Watershed

Lead to an Impending

Do Massive Oil Sands Developments in a Crisis?

Results from a

Gap Analysis

Environmental Impacts Assessments. American Geophysical Union (AGU) Conference Poster, Section "Watershed resilience and sustainabiiity", 5-9 December 2005, San Francisco, California.

Gavin, S and Komers P.E. 2005. Pronghorn behaviour in response to roads in southern Alberta, Canada. Animal Behaviour Society, 42nd Annual Meeting, Snowbird, Utah, August 6-10, 2005. Komers P.E. and Clayton D. 2003. Reclamation Challenges North of 60 - Wildlife, Regulations and Traditional Knowledge, presented at the Canadian Land Reclamation Association, Calgary, Alberta.

Komers,

P.E.

2002.

Replacing

Opinion

with

Measurement

Environmental

Assessments.

Presented at the National Energy Board, June in Calgary, Canada. Komers, P.E. and Archie, B. 2001. Dealing with Traditional Land Use and Northern Heritage Issues in Development Projects. Conference for the Mackenzie Oil & Gas Development Strategies, October in Calgary, Canada.

Komers, P.E. 2000. Non-Linear Responses of Ecosystem Components to Provide Threshold Values for Cumulative Effects Management. Cumulative Effects Management Conference, November in Calgary, Canada.

Lectures, University of Calgary

Komers, P.E., Environmental Impact Assessment, Environmental Science Program ENSC 502; on regulatory underpinnings and practical approaches to measurement in Canada and internationally. Recurring in Winter Semester 2002 - 2009.

Komers,

P.E.

Impacts

Wildlife,

Environmental

Science

Program

ENSC 401;

the

measurement and analysis of disturbance effects, recurring, September 1998 - April 2015.

Peer-reviewed Publications

Belvederesi, C., Thompson, M.S., Komers, P.E. 2017. Canada's federal database is inadequate for the assessment of environmental consequences of oil and gas pipeline failures.

Environmental Reviews. Published on the web 25 May 2017, DOI: 10.1 1 39/er-201 7-0003

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Stewart, A., arid P.E. Komers. 2017. Conservation of wildlife populations: factoring in incremental

disturbance. Ecology and Evolution. 2017: 1-9. DOI: 10.1002/ece3.3015 Komers, P.E., Z. Stanojevic. 2013. Rates of Disturbance vary by data resolution: implications for conservation schedules using the Alberta Boreal Forest as a case study. Global Change Biology. 19:2916-2928. doi: 10.1 1 1 1/gcb.12266. A.,

Stewart,

and

P.E.

Komers.

2012.

Testing

the

Ideal

Free

Distribution

Hypothesis:

Moose

Response to Changes in Habitat Amount. International Scholarly Research Network (ISRN) Ecology. Volume 2012, Article ID 945209, 8 pages, doi:10. 5402/2012/945209. Komers,

P.E.,

Stewart,

S.D.

Gavin,

Hechtenthal,

Whidden,

and

Stanojevic.

2010.

Participatory Management In The Canadian Oil Sands. 'IAIA10 Conference Proceedings' Submission ID: 56; The Role of Impact Assessment in Transitioning to the Green Economy 30th Annual Meeting of the International Association for Impact Assessment 6-11 April 2010, International Conference Centre Geneva - Switzerland (www.iaia.org)

Stewart, A., P.E. Komers, and D.J. Bender. 2010. Assessing Landscape Relationships for Habitat Generalists. Ecoscience, 17: 28-36. Gavin, S.D. and P.E. Komers. 2006. Do pronghorn (Antilocapra americana) perceive roads as a predation risk? Canadian journal of Zoology, 84:1775-1780.

Brotherton, P.N.M. and P.E. Komers . 2003. Mate Guarding and the Evolution of Social Monogamy in Mammals. In: Monogamy: Mating Strategies and Partnerships in Birds, Humans and other Mammals., U. Reichard and C. Boesch eds., University of Cambridge Press, Cambridge. Pp. 4258.

Komers, P.E. and G.P. Curman. 2000. The Effect of Demographic Characteristics on the Success of Ungulate Re-introductions. Biol. Cons. 93: 187-193.

Komers, P.E., B. Birgersson and K. Ekvall. 1999. Timing of Estrus Influenced by Male Age in Fallow Deer Am. Nat. 153: 431-436.

Do leks limit the frequency of aggressive 1999. Pelabon, C., P.E. Komers, and J. Hoglund. density and lek occurrence Can. J. Zool. male encounters in fallow deer? Linking local 77: 667-670.

Pelabon, C., P.E. Komers, B. Birgersson and K. Ekvall.

1999.

Social Interactions of Yearling Male

Fallow Deer during the Rut. Ethology 105: 247-258.

Komers, P.E. and P.N.M. Brotherton. 1997. Female Space Use Is the Best Predictor of Monogamy in Mammals. Proc. R. Soc. B. 264: 1261-1270.

Komers, P.E. 1997. Behavioral Plasticity in Variable Environments. Can. J. Zool. 75: 161-169. Brotherton,

P.N.M.,

J.M.

Pemberton,

P.E.

Komers and

Malarky.

1997.

Genetic

Evidence of

Monogamy in an Antelope, Kirk's Dik-Dik (Madoqua kirkii). Proc. R. Soc. B. 264: 675-681. Komers, P.E., C. Pelabon and D. Stenstrom. 1997. Age at First Reproduction in Male Fallow Deer: Age- Vs. Dominance-specific Behaviors. Behav. Ecol. 8: 456-462.

Komers, P.E. and P.N.M. Brotherton.

1997.

Dung Pellets Used to Identify the Distribution and

Density of Dik-Dik. Afr. J. Ecol. 35: 124-132.

Pelabon, C. and P.E. Komers.

1997.

Time-Budget Variations in Relation to Density-Dependent Can. J. Zool.

Social Interactions in Female and Yearling Male Fallow Deer During the Rut. 75: 971-977,

*9mses ÂŤ.** SAW TV

Komers,

Obligate

1996

P.E.

Monogamy Without

Paternal

Care

Kirk's

Dik-Dik.

Anim.

Behav. 51: 131-140. Komers, P.E.

1996,

Conflicting Territory Use in Males and Females of a Monogamous Ungulate,

the Kirk's Dik-Dik.

Ethology 102: 568-579. Plasticity of Reproductive Behavior in Wood Bison

1994.

Komers, P.E., F. Messier, and C.C. Gates.

Bulls: On Risks and Opportunities. Ethol. Ecol. Evol. 6: 481-495.

Plasticity of Reproductive Behavior in Wood Bison

1994.

Komers, P.E., F. Messier, and C.C. Gates.

Bulls: When Subadults Are Given a Chance. Ethol. Ecol. Evol. 6: 313-330. 1994.

Komers, P.E., F. Messier, P. Flood, and C.C. Gates.

Reproductive Behavior of Male Wood

Bison Related to Female Progesterone Level. J. Mammal. 75: 757-765. 1993.

Komers, P.E., F. Messier, and C.C. Gates.

Group Structure in Wood Bison: Nutritional and

Reproductive Determinants. Can. J. Zool. 71: 1367-1371. Komers, P.E, K

Roth, and R. Zimmerli.

1992.

Interpreting Social Behavior of Wood Bison Using

Tail Postures. Z. Saugetierk 57: 343-350.

Komers, P.E, F. Messier, and C.C. Gates.

1992.

Search or Relax: The Case of Bachelor Wood

Bison. Behav. Ecol. Sociobiol. 31: 195-203.

Komers, P.E. and E.J. Komers. Differences.

1992.

Juvenile Male Magpies Dominate Adults Irrespective of Size

Can. J. Zool. 70: 815-819.

Dhindsa, MS, P.E. Komers, and D A. Boag.

1989.

Nest Height of Black-Billed Magpies: Is it

Determined by Human Disturbance or Habitat type? Can. J. Zool. 67: 228-232.

Komers, P.E.

1989.

Dominance Relationships between Juvenile and Adult Black-Billed Magpies.

Anim. Behav. 37: 256-265.

Komers, P.E. and M.S. Dhindsa.

1989.

Influence of Dominance on Mate Choice in Black-Billed

Magpies: An Experimental Study. Anim. Behav. 37: 645-655.

Dhindsa, M.S., P.E. Komers, and D A. Boag. 1989. The Effect of Familiarity with an Environment on Orn. the Dominance Relationships between Juvenile and Adult Black-Billed Magpies. Scan. 20: 187-192.

Dhindsa, M.S., D A. Boag, and P.E. Komers. 1989. Mate Choice in Black-Billed Magpies: The Role of Male Quality vs. Quality of Defended Resources. Orn. Scan. 20: 193-203. Komers, P.E and D A Boag 1988. The Reproductive Performance in Black-billed Magpies: Related to Mate Choice? Can. J. Zool. 66: 1679-1684.

Is it

Reports and Proceedings

Komers, P.E. 2002 Non-Linear Responses Of Ecosystem Components To Provide Threshold Values For Cumulative Effects Management. Proceedings of the Cumulative Environmental Effects Management Conference in Calgary, November 2000. Komers, P.E. 2002 Book Review: Repairing Damaged Wildlands; A Process Oriented Approach, by S.G. Whisenant BIOS, The Alberta Society of Professional Biologists, Volume 17 (1): 8. Patriquin, D.L. and Komers, P.E. 2000. An Ecosystem Approach to Reclamation: The Gregg River Mine Project. Canadian Land Reclamation Association, Conference Proceedings, Edmonton, October 2000.

40MSES an* SoWww ÂŤ t?Yrgnr*RM ScÂŤn<v

P.E.,

Komers,

Curman,

G.P.

and

Birgersson

Ekvall.

2000.

Success

The

of Ungulate

Re-

introductions: Effects of Age and Sex Structure. In: L. Darling, ed. Proceedings of the Species and Habitats at Risk Conference, Kamloops, BC, Canada, February 15-19, 1999. Gilson. 1998. The Development of Wildlife Corridors and Green Spaces; an

Komers, P.E., and J

Information Package. Environmental Committee, Municipal District of Foothills No. 31, Alberta,

Canada. P.E.

Komers,

and

Ulfstrand.

1997.

Behavioral

Management of Fragmented Populations.

Fallow Deer Related to the

Roche Research Foundation, Annual

Basel: Editiones.

Report, 1996.

Komers, P.E.

Plasticity

Final report.

Monogamy in Dik-Dik Antelopes and its Relation to Population Parameters

1994

and Territory resources. Final research report.

National Council for Science and Technology,

and the Office of the President, Kenya.

Gates, C.C., N.C. Larter and P.E. Komers.

1991.

Size and Composition of the Mackenzie Wood

Bison Population in 1989. Government of the NWT, DRR, File Report No. 93.

Popular Publications Komers, P.E. 1997.

Komers, P.E.

Property Rites. Natural History, March 106: 28-31.

Fallow Deer Breeding: What Can We Learn from Observing Deer Behavior?

1996

[Swedish] Svensk Hjortavel 3/1996: 14-16.

Komers, P.E.

A Wood Bison Summer.

1991.

Educational video, 31 minutes.

Presented at the

International Behavioral Ecology Congress, Princeton, 1992; Award Winner of the 1993 Animal Behavior Society Film Festival.

Komers,

Erdmann.

P.E. and H

1990.

Waldbisons:

Die Geschichte Eines Wenig Bekannten

Grosswildes. Das Tier 1990: 11.

Komers,

P.E.

1989.

Schreikraniche

vom

Aussterben

Bedroht:

Hiirde fur Amerikanischen

Naturschutz. Die Tierwelt. 99(28): 13.

Komers, P.E.

1988.

Wood Buffalo National Park. Video copy available at the Wood Buffalo National

Park interpretive centre, Fort Smith, NWT. Komers, P.E.

1988.

Elstern und Rabenvogel. Die Tierwelt. 98(14): 13-14.

SITE C CLEAN ENERGY PROJECT Panel Hearing Submission November 25, 2013

Wildlife Valued Component: Furbearers, Ungulates, and Large Carnivores

R. Scott McNay, Wildlife/Forest Ecologist, Wildlife Infometrics Inc. on behalf of the Treaty 8 First Nations

iif

ildlile Infometrics

THIS IS EXHIBIT" ....

referred to in the Affidavit of

.JkkL...knj&££L Sworn before me this day of

ttf.ih.A.D. 20 ,-i co^4*iisrBknrR)ii'oaths IN AND TOR AUSTR IA

1 erry e gilholme Barrister & Solicitor Commission

In an'd for Alberta'3^ Pu'"'c

Table of Contents

INTRODUCTION 1.1

Role of Scott McNay, Wildlife Infometrics Inc

REVIEW OF THE AMENDED EIS

2.1

EIS Guidelines

2.2

Proponent Information and Findings

2.3

Informational Deficiencies

2.4

Analytical Deficiencies

REVIEW OF THE PANEL INFORMATION REQUESTS AND RESPONSES

10 16

3.1

Informational Deficiencies

3.2

Analytical Deficiencies

ADVICE CONCERNING SIGNIFICANT RESIDUAL ADVERSE ENVIRONMENTAL

EFFECTS 4.1

Key Concerns Regarding Proponent Findings

APPENDIX A - PROFESSIONAL PROFILES

November 2013

20 20 22

ÂŠ2013 Treaty 8 Tribal Association

INTRODUCTION

1.1

ROLE OF SCOTT MCNAY, WILDLIFE INFOMETRICS INC.

I am a professional biologist registered with the BC Association of Professional Biology, the BC College of Applied Biology, and the Alberta Society of Professional Biologists. I

hold Masters- and Doctorate-level post-graduate degrees in forest wildlife studies from the University of British Columbia and have 32 years of experience in wildlife inventory, management, and research on a wide range of terrestrial species throughout BC and at

localized areas in Alberta (see professional profile in Appendix A). My role was to provide a technical review of the Site C EIS and related materials concerning wildlife resources, specifically furbearers, ungulates and large carnivores including (but not

limited to) EIS guidelines, baseline studies, response to information requests and amendments, and to provide advice regarding significant residual adverse environmental effects of the proposed Site C project.

REVIEW OF THE AMENDED EIS

2.1

EIS GUIDELINES

2.1.1

Wildlife Resources Spatial Boundaries (EIS Guidelines, Section 12.2.1 and Table 12.2)

The Proponent proposes the LAA and RAA as described in Table 12.2. Local Assessment Area An approximate 4-km-wide corridor centered on the Peace River from

Hudson's Hope to the Alberta border; a 1-km-wide corridor centered on the existing 138 kV wood pole transmission line from the Peace Canyon Dam

to Taylor and Fort St. John; a 400 m corridor centered on roads identified for upgrading; a 1 -km wide corridor centered on new roads; and a 500 m

buffer around the proposed quarry and till sites. Regional Assessment Area Peace Lowlands Ecosection

2.1.2

Wildlife Temporal Boundaries

(EIS Guidelines, Section 12.2.2) The EIS will describe the temporal boundaries which will reflect the methodology described in Section 8 of these EIS Guidelines.

November 2013

ÂŠ 2013 Treaty 8 Tribal Association

2.1.3

Wildlife Resources Baseline Furbearers (EIS Guidelines, Section 12.2.3.7)

The furbearer baseline information will provide an understanding of the population estimates and distribution of beavers, distribution of potential

fisher den trees, seasonal habitat use, orientation and size of fisher home ranges within the LAA as proposed by the Proponent. All species observations will be summarized, but the focus will be on

species that are provincially listed. The baseline information will be collected following the protocols outlined in Inventory Methods for Beaver and Muskrat (RIC 1998i) and Inventory Methods for Medium Sized Terrestrial Carnivores: Coyote, Red Fox, Lynx, Bobcat, Wolverine, Fisher and Badger (RIC 1997b). Ungulates

(EIS Guidelines, Section 12.2.3.8) The ungulate (including moose, elk and mule deer) baseline information will provide an understanding of the population estimates; habitat use; movement and migration patterns, including river crossings; and birthing site locations and characteristics within the LAA as proposed by the

Proponent. The baseline information will be collected following the protocols outlined in: Aerial-based Inventory Methods for Selected Ungulates: Bison,

Mountain Goat, Mountain Sheep, Moose, Elk, Deer and Caribou (RIC 2002); Ground-Based Inventory Methods for Selected Ungulates (Moose, Elk and Deer) (RIC 1998j); and Ground-Based Inventory Methods for Ungulate Snow-track Surveys (D'Eon et al. 2006). Large Carnivores

(EIS Guidelines, Section 12.2.3.9 The baseline conditions will be characterized using information from published studies and information made available to the Proponent from

local, regional, and provincial organizations and governments. 2.1.4

Potential Effects of the Project and Proposed Mitigation

(EIS Guidelines, Section 12.2.4)

November 2013

The EIS will assess how the Project has the potential to adversely affect habitat available for wildlife resources, as represented by the key species groups.

The potential to adversely affect wildlife resources will be assessed by taking into account the potential for the Project to result in changes to the following key aspects: •

Permanent and temporary habitat alteration and fragmentation;

•

Disturbance and/or displacement; and

•

Potential for direct and indirect mortality to individuals.

Should potential adverse effects be identified, the potential mitigation measures will be identified and will include a description of how the

mitigation measures can address the potential adverse effects. The EIS will describe project residual effects, and cumulative effects, if applicable, using the residual effects characterization described in Table 8.3. A statement of significance will be provided.

2.1.5

Summary of Residual Effects on Wildlife Resources (EIS Guidelines, Section 12.2.5)

The EIS will summarize residual effects in a table format as shown in Table 8.4.

2.2

PROPONENT INFORMATION AND FINDINGS

The potential residual effects presented by the Proponent respecting furbearers, ungulates and large carnivores are summarized in the table below (see EIS Table 14.19, Table 14.20, Table 14.21).

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Table 1: Summary of Characterization of Residual Effects Key Species

Furbearers

Ungulates

Large Carnivores

Group Residual

Habitat

Disturbance

Direct and

Habitat

Disturbance

Direct and

Disturbance

Effect

Alteration and

and

Indirect

Alteration and

and

Indirect

and

Indirect

Fragmentation

Displacement

Mortality

Fragmentation

Displacement

Mortality

Displacement

Mortality

Construction

Phase

Construction

and Operations Direction

Magnitude

Direct and

and Operations

Negative

Low to

Low

Low to High

Low

Site-Specific to

Site-Specific -

Local

Site-Specific to

Local

Site-Specific

Local

local

Moderate Term

Moderate term

Moderate

Moderate term

Moderate

Geographic Extent Duration

Local

Moderate term

to Permanent Frequency

Reversibility

Long-term to

Moderate term

Permanent

Once to

Continuous -

Continuous

monthly

Continuous

Reversible-

Reversible

Low to High

Low and High

Low to High

resilience

Low to High

Low

Once to

Term

Moderate term

Monthly

Continuous

Monthly

Continuous

Reversible

High resilience

High

High resilience

High

Continuous

Irreversible Context

Level of

Confidence Probability

resilience

Moderate to

resilience

High

Moderate

Low

High Low to High

Moderate

Low

Moderate to High

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ÂŠ2013 Treaty 8 Tribal Association

2.3

INFORMATIONAL DEFICIENCIES

Impacts to ungulate ranges other than winter and natal ranges were not evaluated (ab_0001-327)

In order to fully understand the adverse effects of the proposed Project on ungulates, a detailed study of all important habitat features during the life cycle of a specific species is required.

Focusing only on winter habitat does not give a complete picture of the

habitat requirements of the animal and does not adequately inform decision makers about impact severity.

Using winter habitat use alone results in a significant data gap

for effects assessment purposes. The Proponent's response is a justification for focusing the EIS on winter range. There is agreement that winter range is a critical habitat. However, other ranges should have

also been considered because impact to winter range is not the only concern. All seasonal ranges are important to wildlife, and the Proponent cannot simply ignore a particular seasonal range value until it has been proven that there will be no material

residual adverse effect to that range. The Proponent argues that winter range is the most limiting range type for ungulates and hence the only range that needs evaluation under an impact assessment. The argument is inappropriate since ungulates and other wide-ranging wildlife have significantly different seasonal range locations and needs.

the project has a disproportionate impact on a range other than winter range, then that range could become limiting. Consider for example, that survival rates during winter cannot be isolated from, and are not independent of, the relative benefits received from other seasonal ranges. As further rationale, the Proponent implies that a focus on winter range [only] is aligned with approaches used by regulatory authorities but that is incorrect. While regulatory authorities do address winter range issues for ungulates, other range types are also addressed depending on species and circumstance. As pointed out elsewhere (see ab_0001_356), it is simply wrong to restrict an effects assessment to any single range type until it has been proven the other seasonal ranges and life requisites will be unaffected. 2.

Consideration of potential project effects on caribou is missing (ab_0001-332)

BC Hydro was requested to provide evidence and rationale for the determination that the proposed Project will have no interactions with caribou. The Proponent used a technical memo on caribou in response to the IR for more detailed analysis supporting the notion that the proposed Project is not expected to

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ÂŠ 2013 Treaty 8 Tribal Association

have an adverse effect on that species. The principle pieces of evidence were noted as: 1 ) the claim that no caribou use the area except for a minor overlap of the West Pine Quarry, 2) the overlap at the quarry is not within designated critical winter range, and 3) that because the quarry has been in operation since 2001, continued operation will not create further adverse effects. Since caribou are a threatened species and many populations are in steep decline (including those adjacent to the Project area), recovery planning for this species is focused on restoring environmental conditions so that future populations may exist in a self-sustaining condition. Restoration activities will be pursued well beyond the current range of the species because caribou range in general is known to have contracted significantly in response to decades of anthropogenic disturbance. Historic records and Aboriginal Traditional Knowledge have shown that caribou used the project area in the past and habitat mapping used in current recovery planning has identified areas within the Project area to be important for recovery of caribou populations.

Furthermore, current designated areas (e.g., UWRs and WHAs) have yet to be proven effective as a recovery tool for declining populations (i.e., these measures are used by Government to maintain populations not to recover them). Recommended recovery actions go well beyond winter range alone and include restoration and protective

measures for calving and summer range, rut range, as well as restrictions on matrix habitat between these ranges.

It is for these reasons that the Proponent's response to

the IR is considered inadequate. The proposed Project does in fact overlap areas that are considered important for recovery of adjacent caribou populations (i.e., the Moberly herd) and will have a

significant impact on the likelihood of interaction between the Moberly and Graham River caribou herds, the interaction between these herds being an important indicator of

population recovery. By definition, any increase in or continuation of anthropogenic disturbance within the recovery plan area will be counter to recovery of caribou populations in the area. 3.

There is essentially no baseline information on carnivores (ab_0001-370)

The conclusion that the proposed Project is not expected to have residual effects on large carnivores cannot be substantiated based on the available data and information presented in the EIS.

In response, the Proponent merely reiterates that an analysis of large carnivores was described in the EIS. The IR forwards the notion that the analysis was insufficient. The

Proponent has not provided clarity in response to the IR, altered the text of the EIS in a

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manner that addresses the IR, or provided a rationale based on substantive evidence for failing to address the IR.

When addressing the lack of baseline information on carnivores, the Proponent states that: " telemetry studies would not be required because the habitat requirements of the

species mentions is well understood, and they are common (black bear, wolves, coyotes) or unlikely to be found in the Peace River valley (grizzly bear and cougar)". Notwithstanding our disagreement about habitat requirements for these species being

well understood, the most significant reason for undertaking baseline studies on carnivores is to gain information about relationships with prey densities. The predominant effect of the Project will be to displace prey from the LAA thereby forcing them to use other adjacent habitats. These habitats may, or may, not have security from predators. Regardless, a new dynamic will be established between predators and prey and the assessment of impact from the Project needs to address and characterize that dynamic.

2.4

ANALYTICAL DEFICIENCIES

Substandard sample sizes for ungulates

Sample sizes and analytical techniques used to assess current environmental

conditions for ungulates are substandard in many ways: •

The study was conducted in a period of moderate to low snow accumulation and so conclusions about use of the potentially impacted area by ungulates must be qualified within that context.

•

While it is maybe true that the author(s) could claim that they have interpreted the collected data from ungulate baseline studies, the level of interpretation was nothing more than general qualitative statements which sounded more like personal opinion rather than results from technical assessment (i.e., a

general lack of statistical tests). •

It is not clear (in the ungulate baseline studies) how the project design and subsequent analyses incorporated the standard primary

(upd stream/down stream of proposed dam, inside/outside of the anticipated

reservoir footprint) and secondary (species, sex, temporal, geographic, behavior, weather) analytical stratifications or that the sample size (i.e., number of animals) was sufficient.

In fact, there is really no mention of a

statistical sampling design and there are few to no results presented in any statistically meaningful way.

For example, one would typically rely on

statistical parameters to indicate similarity or differences in results but the

authors often used qualitative descriptions like "very long movements", "did

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ÂŠ 2013 Treaty 8 Tribal Association

not have distinct seasonal ranges", etc.

In the one case where proper

statistics were reported, interpretation of the results and the conclusion drawn were incorrect. For example, the author(s) states that "results show that elk

numbers have steadily increased" but actually the results don't show that at all. Elk numbers in recent years are significantly greater than they were in 1991 but have not changed significantly since 2006. 1 can say that because in this one case, sufficient statistics were presented to allow an independent

assessment of the data. â&#x20AC;˘

The collected data may be sufficient but analyses and interpretation of the

results has yet to be completed so it's difficult to say for sure if the study is adequate. There was a general absence of any true analysis (other than occasionally referring to averages with no presentation of other statistics). There was no presentation of the experimental or sampling design to help establish an analytical context. Without this context, it is next to impossible to understand what the results really mean. An example, there was a lot of discussion presented about the variance in home range sizes among the

sample of moose and deer.1 It would be more helpful to have this variance associated with the factors leading to that variance (i.e., through the use of some modeling). Doing so would help inform the impact assessment. Simply

discussing the breadth of home range sizes does nothing to inform the impact assessment.

â&#x20AC;˘

In the case of an EA, is it proper to assume that one sex is the most important to study? One can make the argument that females contribute to population dynamics in an important way (especially for polygynous mating systems). However, if by sexual range segregation, males are more at risk of adverse

project effects than this must be addressed in the impact assessment and by appropriate mitigation. I forward the notion that it is incorrect to have made

the assumption about females being more important.

Keystone Wildlife Research Ltd. September 2012. Peace River Valley Ungulate Study Program Final Report, p. 61.

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•

I am particularly concerned about the lack of a systematic and unbiased approach to determining animal behavior types and seasons. Because these are very likely to be two of the most important explanatory factors, the rest of

the analyses become a house of cards dependent on how these stratifications were made. Seasons, for example, could be defined based on a variety of things - the calendar, day length, temperature, forage condition, etc. Some (but definitely not all) animals will be in a position where they will need to move from one range to another every year (obligate migrators) because the

specific environmental conditions regularly achieve some threshold value instigating the movement. Some animals may apparently never need to move (resident) for the opposite reason, environmental conditions rarely reach the

threshold. Still other animals may need to move on an apparently irregular basis; when and if forced to move (facultative migrators). If seasons were defined based on the calendar, obligate and facultative migrators will be judged to have unexplained variance (movement types, habitat selection patterns, use of the peace valley position, etc.) because of the inherent annual variance in when the environmental conditions change. The same is true for any other arbitrary approach to establishing the definition of seasons.

My recommendation is to find an analytical approach to distinguishing seasonal movements from daily movements and use the dates of those movements to define seasons - likely different each year. This will help track the variance in observations and make statistical models more robust. It would also hopefully lead to more ecologically meaningful seasons (e.g., rut, natal, migration, etc.). Without such an approach, there will be little to instill

confidence in the subsequent explanation of what factors do or do not contribute to explaining variance around subsequent analyses (e.g., home range sizes, habitat use patterns, survival estimates, use of the valley or anything else) •

There was a lot of data pooling (example day-time and night-time locations, male and female locations) on the basis that the factor levels did not explain

any of the variance but no results of the statistical tests were presented. •

White-tailed deer samples were opportunistically taken from another study with objectives that do not suit the EIS.

•

One of the more significant analytical deficiencies for interpretation of the

ungulate baseline studies, and the wildlife VC in general, is that the LAA for wide-ranging animals was considered to be the same 1 ,000m buffer as was

used for vegetation indicators. This was noted as a concern in review of the draft EIS Guidelines as follows: The preliminary local and regional assessment areas in the Draft EIS Guidelines have no ecological basis and no basis in the exercise of November 2013

ÂŠ 2013 Treaty 8 Tribal Association

Section 35(1) rights. The Project would force wildlife into adjacent

habitats. The EIS Guidelines present no evidence concerning current home ranges of wildlife species potentially affected by the Project that would justify the selected spatial boundaries based on literature, telemetry studies or field studies.

Details regarding this specific deficiency are expounded upon below (see section 3.2, Inappropriate LAA JRP #58) 5.

Potential effects on natal range (ab_0001-343)

The evaluation of potential adverse effects on natal range is suspect. It is still unclear if natal sites were actually confirmed or not - it appears as though there was no field verification. The Proponent was asked to clarify why no information was collected in order to confirm species (e.g., material for conducting DNA analysis e.g., hair

fragments, etc.) since collection of evidence at birthing sites would have been relatively

straightforward. The Proponent's response seems to indicate that the potential birthing sites were identified by analysis of information from radio-collared animals but were not actually confirmed as birthing sites. If this is true then the subsequent interpretation of results is suspect and the entire assessment of impact to ungulate natal range is of little to no value. 6.

Effects on wildlife mortality (ab_0001 -329-331)

The Proponent presents the perspective that the proposed Project will not cause

excessive harm to, or lead to the death of, animals but rather animals will simply be displaced from the footprint into adjacent habitats. This is a fallacy designed to support the notion that the project will not have significant adverse effects. Table 14.2 Rationale for the Exclusion of Suggested Species

Canada Lynx A species whose population and density is strongly linked to cyclical

fluctuations in prey (especially snowshoe hare). Since changes to snowshoe hare are not expected, the same is assumed for Canada lynx. The above assumption is invalid. Animals will die after moving to adjacent areas as a

result of intra-specific competition. The Proponent was requested to modify the wording in Table 14.2 to reflect the reality concerning changes to the population of lynx that

would result from the proposed Project. The Proponent disagreed that the wildlife populations are at ecological carrying capacity and that there is an adjacent area of suitable habitat that is vacant or otherwise able to

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ÂŠ2013 Treaty 8 Tribal Association

support the animals that would be displaced from the footprint once flooded. Since ecological carrying capacity was the expression used to characterize the condition of this hypothetical adjacent area, the animal population (e.g., squirrel, lynx, etc.) in the Proponent's argument must not be at full capacity for some non-ecological reason - can

the Proponent describe what non-ecological factors might lead to that condition? 7.

No consideration of habitat potential or capability (ab_0001-336, ab_0001-371)

The Proponent did not make comparisons of current conditions (with and without the project) to unmanaged natural conditions (i.e., habitat potential or capability). There is no other way to properly address the criteria of magnitude (i.e., ...comparison to

natural... variation) and context (i.e., ...already been adversely affected...). The Proponent states they took into account a comparison to natural or background variation.

However, there was no determination of environmental conditions under a

scenario of natural, unmanaged (i.e., potential) conditions. The Proponent has failed to

demonstrate how this comparison to natural conditions was made. There are no methods or documentation to demonstrate transparency around the analysis.

For

clarification, the IR in ab_0001-336 restated below was not suggesting the development of any new criteria to be used in the characterisation of residual effects but rather to adhere to the full criteria as outlined in Table 8.3 of the EIS Guidelines.

ab 0001-336 In general, there is no mention of capability modeling for the indicators. The suitability

modeling that was done represents a planning scenario characterized by current baseline conditions. An ecological baseline (i.e., capability modeling) will be required in order to address the criteria of magnitude (i.e., ...comparison to natural... variation) and

context (i.e., ...already been adversely affected...) in the assessment matrix. BC Hydro was requested to conduct capability modeling for each of the proposed indicators. The definitions of capability and suitability are understood. It is not necessary for the Proponent to restate these definitions. The Proponent claims "capability is used to assign value to habitats in their pristine conditions which are not being considered in the

EIS". We know that already. The IR is for augmenting the effects assessment with capability mapping because there is no other way to properly address the criteria of

magnitude (i.e., ...comparison to natural... variation) and context (i.e., ...already been adversely affected...) in the assessment matrix. The Proponent claims that "an analysis

of capable habitat would indicate a smaller magnitude than using current suitability" but that is not the appropriate comparison anyway. The more appropriate comparisons

November 2013

ÂŠ 201 3 Treaty 8 T ribal Association would be current suitability versus capability and current suitability plus the project versus capability.

It is only by making these comparisons that one would begin to

properly address the criteria of magnitude and context.

Habitat capability classification and mapping would be a reasonable approach to estimating the losses of habitat already experienced especially in the valley bottoms of the main stem of the Peace River its major tributaries - the Parsnip and Finlay Rivers that have been flooded already. The T8FNs have a very high level of interest in the cumulative effects of these projects collectively on the habitat capability of the environments that existed when Treaty 8 was signed. ab 0001-371

Table 8.3 of the EIS Guidelines reads as follows: Magnitude - This refers to the amount of change in a key indicator or variable relative to baseline case (low, moderate, high), consideration is given to factors such as the uniqueness of the effect, and the comparison

to natural or background variation. The descriptions of criteria contained in Table 14.18 do not parallel the definitions presented in the EIS Guidelines to the extent that the proposed quantitative measure is either incomplete or misleading. The description of "magnitude" contains only part of the requested characterization of magnitude as there is also the need for a comparison to natural or background variation, which can only be done by considering hypothetical unmanaged (i.e., potential) ecological conditions. There is no measure associated with unmanaged ecological conditions. In characterizing the magnitude of the residual effects on wildlife resources, the

Proponent was asked to include a measure associated with comparisons to natural, unmanaged ecological conditions.

The Proponent states they took into account a comparison to natural or background variation. However, there was no determination of environmental conditions under a scenario of natural, unmanaged (i.e., potential) conditions. The Proponent has failed to demonstrate how this comparison to natural consideration was made. There are no

methods or documentation to demonstrate transparency around the analysis. For clarification, the IR was not suggesting the development of any new criteria to be used in the characterisation of residual effects but rather to adhere to the full criteria as outlined in Table 8.3 of the EIS guidelines.

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ÂŠ 2013 Treaty 8 Tribal Association 3

REVIEW OF THE PANEL INFORMATION REQUESTS AND RESPONSES

3.1

INFORMATIONAL DEFICIENCIES

Failure to address impacts on caribou (JRP-IR#54)

In response to the Panel's request for information on mitigation steps for caribou, the

Proponent fails to recognize that most of the proposed Project, including both source areas for rip-rap, are located within the recovery planning area for the adjacent KlinseZa (formerly, Moberly) caribou herd. This herd is close to extirpation, has significantly

retracted its range from the historic distribution, and is undergoing intensive and aggressive management actions in attempts to recovery the population and its former

distribution. The potential for residual adverse effects on caribou was not assessed. Nevertheless, effects were acknowledged to be likely since mitigations were proposed. However, the mitigations simply minimize disturbance but any further disturbance to within the former range of the Klinse-Za herd is counter to the recovery goals and

actions. Mitigations therefore are deemed ineffective - there will be a residual adverse effect on caribou. 9.

Failure to address potential impacts on black bear, hare, squirrels (JRP-IR#51, IR#56, IR#57)

Although other arguments were made, the significant portion of argument for excluding black bear, hare, and squirrels from the EIS is on the basis that these animals are habitat generalists and common in the region. The fact does remain however, that the proposed Project will have a significant effect on these species populations at the local level by a permanent, irreparable loss of habitat that will eventually translate to loss of the local population (see the section below on Failure to estimate wildlife mortality). 3.2

ANALYTICAL DEFICIENCIES

10. Inappropriate LAA (JRP-IR#58) The Proponent notes the following in response to JRP-IR#58:

Disturbance buffers suggested in other BMPs for other habitats and species (including species groups known to occur in the LAA) range between 30 m and 500 m. Therefore a 1,000 m buffer was conservative. These guidelines are species specific, do not apply for all species indicators chosen in the EIS, and focus only on direct impacts of a disturbance to a specific target. A

comprehensive assessment of potential total impact needs to consider both direct and

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ÂŠ 2013 Treaty 8 Tribal Association indirect impacts resulting from the project. If a wide-ranging animal is displaced away

from the PAA, then the effect will permeate throughout that animal's home range, which is likely substantially further than the LAA in many cases. Although the Proponent states that wide-ranging animals were taken into account, the potential project effects on these species were apparently still considered at the standard levels as defined in the EIS (site specific, LAA, and RAA) with the extent affected almost always being considered to be site-specific or local (Table 14.19, page 14-69). The Proponent stated

that " species with larger home ranges may be more tolerant of localized disturbance" and that "species tolerance was included when characterizing a residual effect'. Not only are the methods for this approach opaque, but the assumption about tolerance is

categorically wrong, and the type of disturbance under consideration was identified incorrectly assessed as localized disturbance [from the project]. By first principles, animals will be displaced from the PAA - there is no range of tolerance on that effect since terrestrial habitat is changed to aquatic habitat. Furthermore, the assessment of impact appears to be restricted to sensory disturbance rather than including the more significant effect, which would be from increased competition or predation among species as wildlife is forced out of the PAA and into adjacent (already occupied) habitats. For wide-ranging species, this effect would translate to a regional-level (not local) impact. The Proponent does state that alteration of habitat includes, among other things, increase in predation ((EIS Section 14.3.1, page 14-15) but again, this is

presumably considered only within an incorrectly defined LAA. Also, we note there was no mention or consideration of increased competition. Due to a baseline study design that was apparently lacking in consideration of these more important potential effects of the project, impact areas for most key indicators of the wildlife VC are therefore not available or incorrectly defined and the extent of the potential impact is underrepresented in the assessment of potential effects.

11. Insufficient sample sizes (Ungulates) (JRP #60 and JRP #60S) The Proponent was asked to address the unlikely case that 10 samples of white-tailed deer from an earlier study were sufficient to characterize distribution of white-tailed deer

within the LAA. The Proponent's response focused on where the data came from and how the data were used in the assessment but failed to answer the panels question about the distribution of white-tailed deer in the LAA. Most of the 10 white-tailed deer were caught and stayed significant distances away from the LAA. The Proponent makes the case that the deer habitat use was consistent with what is expected in the "study area" but fails to address what this means in terms of the LAA. Even when

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ÂŠ 2013 Treaty 8 Tribal Association pressed to specifically acknowledge that white-tailed deer may have a wider distribution in the LAA, the Proponent failed to respond.

The discussion regarding white-tailed deer is only an example regarding the adequacy of sample sizes in the ungulate baseline studies. Others were revealed in previous information requests as outlined below. ab 0001-363 The Proponent claimed that "Islands in the Peace River valley and in the reservoir area in general were rarely used for birthing by collared moose, elk, mule deer, or white-tailed deer." We noted however, that only 81 of a

predicted 5,500 ungulates (i.e., 1.5% sampled) were collared and followed for a relatively low number of birthing seasons. The determination above is a result of low numbers of animals being collared in the LAA. The Proponent also claims that "Potential effects of the Project on reproduction of ungulates are expected to be low, since only a small proportion of habitats used for birthing will be influenced by the Project." The Proponent was requested to: a) indicate how these determinations can be made without the appropriate data collected to support them; and b) explain how this conclusion can be made with such a limited amount of data. The Proponent's assertion that "the proportion of collared animals exceeds that generally undertaken for many management applications undertaken by regulatory authorities. . .and is therefore sufficient ..." is

irrelevant. What does matter is if the sample size is sufficiently robust to provide for statistical significance and strong science. The percent of animals collared in this study is an order of magnitude lower than standards for most scientific studies. For this reason the assumption that the collared animals represent the larger population cannot be substantiated. 12. Failure to estimate wildlife mortality (JRP-IR#37, IR#43, and IR#43S) In addressing the places where mortality risk may be high, the Proponent states (JRP #37) "For most species mortality risk will be highest during habitat alteration and

flooding associated with reservoir filling." This is the place and time when mortality will be most direct. For large-ranging mammals, the direct mortality is unlikely to be the most significant component compared to mortality that is likely to occur to displaced animals. It is our opinion that mortality risk for displaced animals is difficult to assess

without consulting results of previous projects of a similar nature. Displaced animals

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ÂŠ2013 Treaty 8 Tribal Association are likely to undergo an increase in risk of mortality and some could undergo that

change at a considerable distance from the LAA as it was defined. Although the Proponent did provide density estimates for ungulates (JRP IR-43S), those estimates were not used to calculate the potential loss of animals due to the permanent,

irreparable damage to ungulate habitat. The Proponent refuses to discuss numbers of animals that are likely to be lost due to effects of the proposed project. The number of animals that will die is exactly equal to the density of the population multiplied by the area of habitat loss. The quantitative analysis to support the impact assessm ent is easily done and would help make the assessment more transparent. If populatio n estimates can be "generated with a reasonable degree of confidence", then so too can population density estimates. The population density can then be extrapola ted to the footprint based on habitat quality.

The Proponent argues in JRP #43 that population estimates (numbers or density) are not necessary for an assessment of potential project effects. The Proponent considers that: Estimates of population sizes are impractical, particularly for large numbers of species over a large area, because of the input data requirements involved, and often vary widely. Project effects on populatio n cannot be reliably distinguished from the many other factors affecting the bird populations in a given area at any given time, including disease, hunting/trapping pressure, predation, social interactions, seasonal and interannual variation, detectability, population cycling, migration rates and timing, mortality rates, weather, and inherent variability. Evaluation of potential population effects due to the Project would be consequently less certain. " We are not sure what has prompted the Proponent to take this view. Populatio n estimates for species are a fundamental component of wildlife managem ent, have been undertaken for many decades, have standard protocols for implementation, and are a necessary and required component of characterizing baseline environmental conditions for environmental assessments in British Columbia. Under the proper sampling design, it is entirely possible to parse out and distinguish project effects on populatio n change from other underlying natural factors that influence that dynamic. In order to effectively articulate the potential for project effects, it is standard to estimate the amount of

affected habitat (ha) and to translate that into how many animals are likely to be affected based on an estimate of population density (#/ha). Loss of habitat will lead to loss of animals and we need to know the significance of that loss.

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ÂŠ 2013 Treaty 8 Tribal Association The proposed Project will irreparably remove terrestrial habitat within the flood zone to the erosion impact line (i.e., the Project Activity Area; PAA) and will indirectly affect an area minimally equal to the cross-section distance of one animal home range away from the LAA (hereafter, the Indirect Disturbance Area; IDA). Also, depending on species typical home range sizes, terrestrial animals will be either wholly or partially displaced out of the LAA, hence causing an indirect project impact across their post-disp lacement home range. The fact is that some animals will also die as a result of that indirect impact. Some animals will die because they cannot be displaced to adjacent habitats (lack of appropriate motility) and others will die through intra- and inter-spec ific

competition (including predation). This is because animals in adjacent areas are already at equilibrium (not intended to imply a steady state). Immigration of displaced animals will increase population density initially but the original population density will prevail through increased mortality until the pre-project equilibrium is restored.

ADVICE CONCERNING SIGNIFICANT RESIDUAL ADVERSE

ENVIRONMENTAL EFFECTS 4.1

KEY CONCERNS REGARDING PROPONENT FINDINGS

As noted, key pieces of missing information render the assessment of the wildlife VC incomplete: seasonal range use other than during winter and natal season, caribou, and carnivores. Key analytical deficiencies render the assessment of the wildlife VC unreliable for use in the E IS. The conclusions regarding significance of residual adverse environm ental effects on the wildlife VC are therefore without basis.

The establishment of LAA and RAA for the wildlife VC is hopelessly flawed. In addition, we noted that the Proponent chooses to mix spatial scales and twist argumen ts about spatial extent to suit their needs for determination of no significant adverse residual effects (in many cases) to the wildlife VC. This is exemplified by the Proponen t's response to JRP #43 where the Proponent states: The Project would impact only a very small portion of the habitat landbase for species which are common and widespread throughout the Province

(e.g., ungulates, black bears, many furbearers, many passerines and waterfowl). The potential for the Project to result in an adverse change in the habitat of these species is limited to the LAA. When measured at the Provincial level, the changes would be very small or not measureable and, consequently, do not contribute to the determination of a significant

adverse effect on Wildlife Resources.

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ÂŠ 2013 Treaty 8 Tribal Association

In reality, the geographic extent for effects on most species was underest imated (i.e., it is not just the LAA) and in combination with the fact that the effect is absolutely

irreversible (i.e., animals will die in proportion to the amount of habitat lost) and should therefore lean the Proponent towards the conclusion of a significant adverse residual effect on many species (i.e., displacement with be significant, and the resulting effects on mortality and predation will be significant).

Furthermore, the spatial scale for

determining significance is not the Province, as indicated above, but rather the regional area that is impacted. For ungulates and other large mammals, the proposed Project will lead to mortality that essentially cannot be mitigated in any way loss of habitat leads to loss of animals - there is no way around that fact, as stated previous ly in our comments in ab_0001-369:

In fact, mortality related to habitat loss cannot be avoided at all, neither can it be mitigated.

The one example provided,

. . .can be reduced with wetland avoidance.. . is avoiding habitat loss and not mitigating mortality due to habitat loss. The other mitigations provided are simply delaying the inevitable for animals that have not suffered direct mortality from flooding or lethal contact with humans. These displaced animals are forced to undergo intra- or inter-specific competition until adjacent areas have stabilized back to their original population density. For example, timing of works mitigations simply means that there will be less direct mortality and more indirect mortality. Avoiding the release of deleterious hydrocarbons, limiting sedimentation, and fencing along roads

are all examples of limiting the area affected by the proposed Project, not mitigating against habitat loss. Mortality due to habitat loss cannot be mitigated. The extent to which the proposed Project can affect animals in adjacent habitats can be mitigated to varying levels of success.

For First Nations and others who use the wildlife resources for a variety of purposes, the permanent and irreversible change to the landscape has a direct and significant impact on wildlife in the area and hence on the way people will use the landscap e.

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APPENDIX A - PROFESSIONAL PROFILES

R. Scott McNay, PhD, RPF (BQ, RPBio (BQ, PBiol (AB) 12 Yukon Dr., Box 1087, Mackenzie, BC, VOJ 2C0

Home: (250) 997-4943, Cell: (250) 997-7928

Career Objective To provide

innovative

solutions to key issues of conflict that impedes the effective integration of

management tactics for wildlife and the sustainable development of renewable natural resources.

Profile •

Accreditations include: Bachelor of Science, Masters of Science, Doctor of Philosophy, Registered

•

32 years of experience in ecological research and management including formal affiliations with academia (University of British Columbia), government (BC Ministry of Forests), industry (Slocan

Professional Forester (BC), Registered Professional Biologist (BC), Professional Biologist (AB).

Forest Products), consulting (Wildlife Infometrics Inc.), and not-for-profit societies (Resources North Association); •

Initiated, managed, and successfully completed large projects with multi-million dollar budgets

(coastal black-tailed deer, coastal montane biodiversity, Omineca northern caribou project, effectiveness monitoring for mountain goat management, industrial environmental assessments) •

Championed the use of habitat supply modeling and adaptive management (see published literature)

•

34 peer-reviewed publications, lead author on 19.

Work Experience

F orest/ Wildlife Ecologist, Wildlife Infometrics Inc. Mackenzie, BC, 2004 — present In this position I: • Plan and conduct operational inventories of aquatic and terrestrial resources; • Plan, conduct, and report on original applied research concerning the interactions among industrial development and habitat values for sensitive terrestrial wildlife; • Plan, manage, and coordinate environmental studies associated with industrial Environmental

Impact Assessments; • Develop techniques to further the application of habitat supply modeling as a tool to aid integrated planning for industrial and non-industrial natural resource values; • Assist in the development of policy and guidance documents associated with the conservation of

terrestrial wildlife; and

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©2013 Treaty 8 Tribal Association • Provide leadership in teams associated with the recovery of caribou in British Columbia including: BC Mountain Caribou Recovery Science Team (2004-present), Recovery Implementation Group for Northern Caribou in North Central BC (2000-2007), BC Peace Northern Caribou Committee (initiated 2012), First Nations Caribou Alliance (201 1 -present)

Forest Biologist, Slocan Forest Products Ltd. Mackenzie, BC, 1997—2004 In this position I: • Guided the implementation of inventory and research programs on caribou, grizzly bears, moose, wolves, mountain goats, terrestrial forage lichens, and ecosystem mapping;

• Consulted with Silviculture and Operations Foresters (1.4M cubic meters of Allowable Annual Cut) to provide advise and direction for plans and legal document submissions; • Provided advice and direction to Forest Planners (e.g., habitat modeling, landscape and standlevel biodiversity targets) for issues that affect forest management plans; • Developed or reviewed policy on the management of sensitive species; • Provided extension and liaison with researchers conducting investigations on sensitive species; • Planned, conducted, and reported; operational inventory of aquatic and terrestrial resources and applied research on management of biodiversity and management techniques within Wildlife

Habitat Areas; • Planed,

conducted,

and

reported

operational

trials

management

guidelines

concerning

biodiversity.

Wildlife Habitat Ecologist, B.C. Forest Service Victoria, BC, 1984-1997 In this position I: • Planned, conducted, and reported original applied research in wildlife habitat ecology, particularly

the relationships between forest characteristics and wildlife responses; • Initiated

major program

enhance

integrated

management

and

sustainability of coastal

Montane forests; • Initiated research projects concerning management of logging-road bridges as habitat for bats and

integrated management of small coastal owls; and • Completed all phases of a 15-year project concerning the integrated management of forests and habitat for Columbian black-tailed deer.

Education PhD, Forestry (Wildlife Ecology) Univ. of British Columbia V ancouver, BC 1991-1995

Colorado State Univ. Ft. Collins, CO 1995

MSc, Forestry (Wildlife Ecology) Univ. of British Columbia Vancouver, BC 1981-1984

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BScF, Forestry (Wildlife Management) Univ. of New Brunswick Fredericton, NB 1976-1981

Awards and Distinctions Canadian Forest Products Fellowship in Wildlife Management 1982-83 and 1983-84 Gilbert White Ganong Scholarship 1976

Scholarly Activities Graduate students supervised

I have acted as a field supervisor for several post-graduate students: • Laurie Kremsater (MSc) - Edge habitat for black-tailed deer (1994);

• Jeff Morgan (MSc) - Summer habitat selection by black-tailed deer (1994); • Mandy Kellner (MSc) - Ecology of Montane bats (2001 ); • Randy Sulyma (MSc) - Management of pine-lichen woodlands (2001 ) Visiting lecturer or speaker

I have lectured or provided informal talks on an ad hoc basis to: • University of British Columbia (FRST 395); • University of Northern British Columbia; • University of Victoria; • Cowichan Valley Naturalists; • Nanaimo Fish and Game Protective Association.

Memberships or Committees I am or have been a member of: • The Wildlife Tree Committee (technical advisor 1994-1997); • The Integrated Wildlife - Intensive Forestry Research working group (working member 1981-1991); • Mountain Caribou Technical Advisory Committee (working member 1998 - 2004); • Northern Caribou Technical Advisory Committee (working member 2000 - 2005); • Northern Caribou Recovery Implementation Group for North-central BC (2003-present); first five years as chair; • Mountain Caribou Science Team (working member 2004-present); • First Nations Caribou Alliance (working member 201 1 -present); • Peace Northern Caribou Committee (initiated 2012);

• Mackenzie Land and Resources Management Plan round table (1998); • Risk to Biodiversity Technical Review Team (1999); • Forest Science Board Sustainability Program Advisory Committee (2004 - 2008); last two years as

chair of the committee.

Reviewer I provide technical reviews (approximately 2/yr) for the following: • Journal of Wildlife Management;

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• Government agencies internal peer reviews; and • Other review solicited from other organizations, most predominately the Lands Office of many

Aboriginal organizations.

Consulting I consult with forest, wildlife, and lands managers on a regular basis (4/yr) for: • Government agencies regional and district staff; • Lands Offices of Aboriginal organizations (Saulteau First Nation, Halfway River First Nation, West Moberly First Nation, Takla Lake First Nation, Tsay Keh Dene, Kwadatcha); • TimberWest Forest Ltd.; and • Canadian Forest Products Ltd. I also consult on a less frequent basis (1/yr) to: • Alaska Dept. of Fish and Game; • Washington State Dept. of Fish and Game; and • Oregon Dept. of Fish and Game.

References References can be supplied upon request.

Peer-reviewed publications Bunnell, F.L., R.S. McNay, and C.C. Shank.

1985.

ground - a review and quantitative synthesis.

Trees and snow:

the deposition of snow on the

British Columbia Min. of Environ, and Min. of For.,

Research. IWIFR-1 7. Victoria. 440 p.

Bunnell, F.L., F.W. Hovey, R.S. McNay, and K.L. Parker.

1990.

Forest cover, snow conditions, and

black-tailed deer sinking depths. Can. J. Zool. 68:2403-2408. Bunnell, F.L., K.L. Parker, R.S. McNay, and F.W. Hovey.

1990.

Sinking depths of black-tailed deer in

snow, and their indices. Can. J. Zool. 68: 917-922.

Cichowski, D., D. Culling, and R.S. McNay.

2012.

Performance measures for Resource Review Areas

for woodland caribou in British Columbia. Internal Rept., British Columbia Ministry of Forests, Lands,

and Natural Resource Operations, Prince George, BC.

Eng, M.A. and R.S. McNay.

1990.

Development of a habitat assessment and planning tool:

reference and project working plan.

A problem

(EP 1087) British Columbia Min. of Environ, and Min. of For.,

Research. IWIFR-40. Victoria. 44pp.

Eng, M.A. and R.S. McNay.

1990.

Using geographic information systems to assist with the integrated

management of forestry and wildlife habitat.

Pages 146-156 In {A. Chambers, ed.) Proceedings of

the Forestry Wildlife Symposium, March 7-8, 1990. 160. Victoria.

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British Columbia Min. of For., Research FRDA

182pp.

ÂŠ 2013 Treaty 8 Tribal Association

Eng, M.A., R.S. McNay, and R.E. Page.

1991. Integrated management of forestry and wildlife habitat with the aid of a GIS-based habitat assessment and planning tool. Pages 331-336 In (M. Heit and A. Shortreid, eds.) GIS applications in natural resources. GIS World, Inc. Fort Collins, CO

Eng, M.A., R.S. McNay, and R.E. Page.

1990.

Integrated management of forestry and wildlife habitat

with the aid of a GIS-based habitat assessment and planning tool. Pages 185-190 In (M.J. Heit, ed.)

GIS- making it work. Proceedings of a workshop March 13-16, 1990 at Vancouver, British Columbia. FRDA107. Victoria. 541pp.

Eng,

M.A.,

R.S.

McNay,

and

R.E.

Page.

management of deer and forests.

1989.

Refinement of a

Page 67 ]n (J.

model

used

integrate the

McPhalen, ed.) GIS - a wider perspective.

Proceedings of a workshop March 6-10, 1989 at Vancouver, British Columbia. 227pp. Eng, M.A., R.S. McNay, D.W. Janz, L.L. Kremsater, I. MacDougall, and R.E. Page. and planning the spatial and temporal features of black-tailed deer habitat.

1992.

Assessing

Pages 81-111 In (J. B.

Nyberg and W. B. Kessler, eds.) Proceedings of the Habitat Futures Workshop, October 16-20, Pack Experimental Forest, Eatonville, Washington.

British Columbia Min. of Forests, Research.

Victoria.

161pp.

Heath, R.H., R.S. McNay, and L.D. Peterson. black-tailed deer in young forests:

1988.

Operational trials of winter habitat creation for

Working plan. (EP 1095) British Columbia Min. of Environ, and

Min. of Forests, Research. Victoria. 39pp.

Marcot,

B.G.,

R.S.

McNay,

and

silviculture-habitat relationships.

R.E.

Page.

1988.

Use

micro

computers

USDA For. Serv., Pac. Northwest Res. Stn.

for

modeling

Gen. Tech. Rep.

PNW-GTR-228. Portland, OR. 19 p.

McNay, R.S.

2011.

An expert-based modeling approach to inform strategic and operational land

management decisions for the recovery of woodland caribou.

Pp 131-152. In Perera, A.H., C.A.

Drew, and C.J. Johnson (eds.) Expert knowledge and its application in landscape ecology.

Springer

Science and Business Media, New York.

McNay, R.S.

2011.

Silviculture options for use in ranges designated for the conservation of northern

caribou in British Columbia. BC Journal of Ecosystems and Management 12:55-73.

McNay, R.S. 2009. .Spatial and temporal patterns of predation risk on woodland caribou in the Wolverine

and Chase herds, north-central British Columbia 1991-2006.

Peace Williston Fish and Wildlife

Compensation Program Report No. 323. Prince George, BC 24p.

McNay, R.S.

2006.

Towards comprehensive and transparent use of ecological information in decisions

about recovery of mountain caribou.

Pp. 90-99,

mountain caribou in mountain ecosystems.

Multidisciplinary approaches to recovering

Proceedings of a workshop held May 29-31, 2006 in

Revelstoke, British Columbia. Columbia Mountains Institute of Applied Ecology. Revelstoke, BC.

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ÂŠ2013 Treaty 8 Tribal Association McNay, R.S.

1995.

The ecology of movements made by Columbian black-tailed deer.

PhD Thesis,

Univ. of British Columbia. Vancouver. 194pp.

McNay, R.S. habitat.

1985.

Forest crowns, snow interception, and management of black-tailed deer winter

British Columbia Min. of Environ, and Min. of For., Research.

McNay, R.S. and F.L. Bunnell.

1994.

Behaviourial limits to movement:

1WIFR-19. Victoria.

111pp.

the effect on habitat choices for

Columbian black-tailed deer. Trans. Congr. Int. Union Game Biol. 21(2):295-303.

McNay,

R.S. and R. Davies.

management:

1985.

problem analysis.

Interactions between (EP 923) British

black-tailed

deer and

intensive forest

Columbia Min. of Environ, and

Min. of For.,

Research. IWIFR-22. Victoria. 110pp.

McNay, R.S. and D.D. Doyle.

1995. Black-tail behavior. British Columbia record book.

McNay, R.S. and D.D. Doyle. (IWIFR) Deer Project.

McNay, R.S. and D.D. Doyle. job completion report. Lands, Research.

1990.

The Integrated Wildlife - Intensive Forestry Research Program

N.W. Environ. 6: 365-366.

1987.

Winter habitat selection by black-tailed deer on Vancouver Island: a

(EP 923) British Columbia Min. of Environ, and Parks and Min. of For. and

IWIFR-34. Victoria. 90pp.

McNay, R.S. and J.M. Voller.

1995.

Mortality causes and survival estimates for adult female, Columbian

black-tailed deer. J. Wildl. Mange. 59:138-146.

McNay, R.S., D.D.

Doyle, and R.E. Page.

black-tailed deer habitat:

1988.

A research working plan.

The spatial and temporal factors of managing (EP 1078) British Columbia Min. of Environ, and

Min. of Forests, Research. Victoria. 52pp.

McNay, R.S., J.A. Morgan, and F.L. Bunnell.

1994.

Characterizing independence of observations in

movements of Columbian black-tailed deer. J. Wildl. Mange. 58:422-429.

McNay, R.S., R.E. Page, and A. Campbell.

1987.

Application of expert-based decision models to

promote integrated management of forests and deer.

Trans. N. Am. Wildl. Nat. Resourc. Conf. 52:

82-91.

McNay, R.S., L.D. Peterson, and J.B. Nyberg.

1988.

The influence of forest stand characteristics on

snow interception in the coastal forests of British Columbia. Can. J. For. Res. 18: 566-573.

McNay, R.S., G. Sutherland, and D.G. Morgan. wildlife in Central British Columbia.

2011.

Standardized occupancy maps for selected

BC Journal of Ecosystems and Management 12:1 18-135.

McNay, R.S., D. Heard, R. Sulyma, and R. Ellis. 2008. A recovery action plan for northern caribou herds in north-central British Columbia. Forrex Forest Research Extension Partnership, Kamloops, BC. Forrex Series 22.

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ÂŠ2013 Treaty 8 Tribal Association

McNay, R.S., B.G. Marcot, V. Brumovsky, and R. Ellis. 2006. A Bayesian approach to evaluating habitat suitability for woodland caribou in north-central British Columbia. Can. J. For. Res. 36:3117-3133.

Morgan, D.G., R.E. Page, M.A. Eng, and R.S. McNay.

1994.

Deer habitat in a visualized programming

environment. Trans. Congr. Int. Union Game Biol. 21(1):357-363.

Morgan, D.G., M.A. Eng, R.E. Page, and R.S. McNay. 1997. An object-oriented decision support system for black-tailed deer on Vancouver Island.

Pp. 31-37 IN I. D. Thompson (Compiler) The status of

forestry / wildlife decision support systems in Canada: Proceedings of a symposium.

Held in 1994 at

Toronto, Ontario. Nat. Res. Canada, Can. For. Serv., Sault Ste. Marie, Ontario. 68pp.

Nyberg, J.B., R.S. McNay, M. Kirchhoff, R. Forbes, F.L. Bunnell, and E.L. Richardson. management of timber and deer: coastal forests of British Columbia and Alaska.

1989.

Integrated

USDA For. Serv.,

Pac. Northwest Res. Stn. Gen. Tech. Rep. PNW-GTR-226. Portland, OR. 65pp.

Richardson, E L., R.S. McNay, J.B. Nyberg, and D.W. Janz.

1990.

Applying the handbook to habitat

management planning. Pages 197-237 ]n (D. W. Janz and J. B. Nyberg, eds.) Deer and elk habitats in coastal forests of southern British Columbia.

British Columbia Min. of For., Special Rep. Ser. 5.

Victoria.

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