Government of British Columbia requests feedback on mountain caribou conservation plan

Photo credit: Jim Lawrence/Kootenay Reflections

Photo credit: Jim Lawrence/Kootenay Reflections

For decades, industrial activity, including logging, mining, oil & gas have decimated caribou habitat throughout British Columbia. These industries went unchecked while mountain caribou populations dwindled. In the past two years, two herds in southeastern British Columbia were extirpated. Meanwhile, high-impact recreational activity (snowmobiling, ATVing and heli-skiing) has added additional pressure to mountain caribou populations.

While the provincial government focuses on killing wolves in a misguided attempt to save caribou, logging companies are cutting down what’s left of critical habitat. British Columbians have an opportunity to call for genuine habitat protection.

Through the Provincial Caribou Recovery Engagement website, the provincial government is asking for feedback on their Draft Section 11 Agreement Between Canada and B.C. & Draft Partnership Agreement Between Canada, B.C., West Moberly and Saulteau First Nations. We’re encouraging our supporters to participate in the consultation process before the May 31st deadline.

See our submission below to the questions posed by the provincial government. Please make sure to personalize your response and avoid copying and pasting.

Active logging in mountain caribou habitat. Photo credit: Nathaniel Atakora

Active logging in mountain caribou habitat. Photo credit: Nathaniel Atakora

Caribou: Draft Section 11 Agreement

Are there any actions in Annex 2 that you strongly disagree with? Please describe them and explain why you do not support them.

The Section 11 Agreement lacks a strong and immediate commitment to protect mountain caribou habitat. Logging has decimated mountain caribou habitat for decades. An immediate moratorium should be placed on logging in caribou habitat. High-impact recreational activity, including heli-skiing, ATVing and snowmobiling is extremely disturbing to mountain caribou. A moratorium should be placed on these activities within the habitat of mountain caribou.

The heavy focus on predator culling via aerial gunning and trapping is unacceptable. In addition, the lack of professional oversight is another major concern. Wolves and other predators have been scapegoated for the decline in caribou while industry continues to destroy caribou habitat. The culling of wolves has failed to protect mountain caribou, as evidenced by programs in the South Selkirk and across Alberta where caribou have failed to recover. Table 4 in Annex 2 suggests other predators, including cougars, wolverines and bears may also be culled. Predator culling in general fails to address the underlying cause of caribou decline (habitat destruction).The negative ecological repercussions of removing apex predators must also be considered.

Are there any actions in Annex 2 that you strongly support? Please describe them and explain why you support them.

Linear feature deactivation/rehabilitation is an important action, but it should extend to all herds across the province. A recent study recommends making it more challenging for wolves to access caribou habitat via cutlines and forestry roads by dropping tree debris. The study found this approach reduced predator use of such roads and cutlines by 70 percent. This practice is a more effective and ethical approach than culling wolves.

It is also crucial that the provincial and federal governments work with and in support of indigenous communities.

The creation of a scientific committee is another important action, but it must be comprised of independent caribou biologists.

Are there any actions that you think are missing from the draft Section 11 Agreement? Please describe them and explain why you feel they should be added.

The draft Section 11 Agreement lacks a concrete commitment to habitat protection and restoration. The best available science states that habitat conservation should be a top priority in the recovery of mountain caribou. A moratorium on industrial activity within caribou habitat should be implemented immediately and additional closures to high-impact recreational activities, including heli-skiing, ATVing and snowmobiling should be implemented and effectively enforced immediately.

Overall, do you support the Parties entering into the Section 11 Agreement? Why or why not?

Currently, the Section 11 Agreement would allow for another two years of the status quo while planning continues. This means two more years of continued habitat loss and degradation, which will only continue to threaten caribou.

A Section 11 agreement must include the following priorities:

  • An immediate moratorium on habitat destruction in caribou habitat

  • An immediate moratorium on high-impact recreation (heli-skiing, snowmobiling and ATVing) in caribou habitat

  • An end to the culling of predators via aerial gunning and trapping

Draft Partnership Agreement

For the 1 to 4 rating questions:

"Strongly support" for all, except “habitat mitigation and offsetting” and “predator control” which are “strongly do not support”. Offsetting allows industry to continue destroying caribou habitat and predator control allows government to scapegoat predators while leaving industry unchecked.

Are there any actions identified in the draft Partnership Agreement that you strongly disagree with?  Please describe them and explain why you do not support them.

The Partnership Agreement lacks adequate protection for low elevation caribou habitat. The continued use of lethal predator control by the government of British Columbia is also ill-informed and unethical.

Are there any actions identified in the draft Partnership Agreement that you strongly support? Please describe them and explain why you support them.

Protection of additional caribou habitat is a crucial step in the right direction, including low elevation and high elevation ranges. Additionally, the creation of protected areas and habitat restoration are also important for caribou recovery.

Are there any actions that you feel are missing from the draft Partnership Agreement? Please describe them and explain why you feel they should be added.

The Partnership Agreement must protect more caribou habitat, including low elevation ranges.

Overall, do you support the Parties entering into the Partnership Agreement? Why or why not?

The federal and provincial governments must work with First Nations in a genuine and meaningful way to protect caribou. It’s crucial that action focus on habitat protection and not rely on lethal predator control.

Do you have any additional comments?

It is important that the federal and provincial governments work in partnership with the West Moberly and Salteau Nations who have advocated tirelessly for the protection of their traditional territories from exploitation. The decline in caribou across the province must serve as a lesson for the provincial and federal governments - we cannot continue to endlessly exploit and destroy habitat and expect that wildlife will survive. Government must take immediate and concrete actions to protect caribou habitat and end the scapegoating of predators and other prey species.

**Please note the comment section below is for commenting on this blog post - it is not part of the caribou consultation and comments aren’t submitted to government.

Public consultation on predacide use in Canada


Health Canada’s Pest Management Regulatory Agency (PMRA) is currently offering a public consultation to determine how the humaneness of pesticides used to kill predators (predacides) could be considered during their approval and use.

Wildlife Defence League (WDL) has made a submission and we’re encouraging our supporters to also participate in the consultation before the April 18th deadline. Please see the consultation questions below, as well as our feedback.

Consultation Questions:

  1. Should PMRA include humaneness considerations as part of the pesticide registration process for products intended to control large vertebrate predators? If so, what would be the best options and approaches for doing so?

  2. Should PMRA develop public information, such as best practices / standards on humaneness considerations, that pesticide users could take into account when deciding whether to use a pesticide for controlling large vertebrate predators?  If so, what kind of information would be most useful?

  3. In either case, what should be the parameters to measure humaneness?

Visit the consultation page for more background information. Feedback can be submitted via email to Please be sure to personalize your response and do not just copy and paste.

It is the position of the Wildlife Defence League that humaneness must be a central part of all wildlife management strategies. The Canadian Veterinary Medical Association’s pest control position statement states that “the welfare implications, safety, and ecological impact of the chosen strategy should always be considered”. 1

Predacides such as sodium fluoroacetate (Compound 1080), sodium cyanide and strychnine are inhumane, as they result in severe and often prolonged suffering. Animals that ingest these poisons can experience seizures, cessation of breathing, hyperthermia, extreme suffering and death from exhaustion or asphyxiation. Death may occur within 1-2 hours but, depending on the dose ingested, it can take up to 24 hours or longer for the animal to die. 2,3

These predacides fail to meet the Canadian Council on Animal Care guidelines, which defines a killing method as humane if it causes rapid (immediate) unconsciousness and subsequent death without pain or distress. 4 They also fail to meet the Canadian Veterinary Medical Association guidelines for humane pest control. 5

Predacides are indiscriminate killers. The baited poisons used to attract the target species inevitably attract other animals (including pets), who suffer the same cruel fate. Secondary poisoning of animals that scavenge on the toxic carcasses is an additional concern. 6 The widespread impact of these poisons is likely not fully understood either, as they may not always be directly lethal to non-target animals, but may seriously compromise reproduction, immune function, overall fitness, and longevity. 7

Ultimately, these predacides cannot be used humanely, due to the very nature of the products themselves, as well as the risks they pose to biodiversity, entire ecosystems, and public safety. Existing animal welfare guidelines, as outlined in this submission, offer a baseline for humaneness considerations. As wildlife face increased human pressure, it’s crucial that root causes of conflict be addressed, rather than reliance on lethal strategies that often fail to address these root causes. WDL is calling on the Minister of Health and the Pest Management Regulatory Agency (PMRA) to include humaneness considerations in the pesticide registration process and to prohibit these predacides under the Pest Control Products Act.



  2. Khan, S.A. (2010) Overview of strychnine poisoning. In: The Merck Veterinary Manual, Tenth Edition, ed. C.M. Kahn & S. Line, pp. 2744–2746. Whitehouse Station, NJ, USA: Merck & Co

  3. Eason, C.T. & Wickstrom, M. (2001) Vertebrate Pesticide Toxicology Manual (Poisons). Department of Conservation Technical Series No. 23. Wellington, New Zealand: Department of Conservation