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BCSF comments on Winter Motorized Recreation Management Plan in the South Peace

The BC Snowmobile Federation (BCSF) and our member clubs participated in developing the South Peace Snowmobile Advisory Committee (SPSAC) Recommendation Report that was delivered to the Province in February 2021.  This report was a culmination of over 400 hours of time and $20,000 in BCSF member funds.   We stand behind the recommendations of this report and are submitting this report in its entirety as our response to the draft management plan that is currently circulating.  We request that the Province refer to the maps in our report that provided for the protection of 92% of occupied habitat in the South Peace and allow the members of the SPSAC to be true partners with you in Caribou Recovery.    

The SPSAC was tasked with finding a balanced approach that supported caribou recovery and continued snowmobile access.  The SPSAC focussed our recommendations on occupied habitat and included a core principle for Adaptive Management whereby public access is adjusted seasonally or temporarily when caribou are not present. This allowed for the communities to continue to grow snowmobile tourism without impacting caribou recovery.  Snowmobiling does not alter habitat, there has been no evidence of a snowmobile trail leading to a predation event in the South Peace, and today the collar data collected by the Province provides no evidence of habitat abandonment due to snowmobilers.  

In addition to submitting our report in its entirety we are also submitting the following direct comments on areas that the Province has not addressed:

  1. Legal Establishment of Snowmobile Polygons:  The legal establishment of all snowmobile areas that remain open must be included as an immediate next step. These applications need to be fast-tracked as it is our understanding that Recreation Sites and Trails BC (RSTBC) is no longer considering new applications.  A typical application has been taking five to seven years to process which is not acceptable.  The clubs in this region that have been trying to get their trails established have continued to be pushed off until the caribou planning process was started.  We believe that if you can implement a closure in less than six months then the protection and clear definition of what remains open should also be able to occur in that timeframe.   

These areas must be established as recreational polygons and include the access trails, the grandfathering of existing cabins, and approval for new shelters or parking infrastructure required as part of the enhancement funds.   The Province should then enter into Partnership Agreements with the snowmobile clubs in each community to ensure the continued management of these areas long-term for public benefit.   Without this establishment of the entire polygon there is no legal recognition on the landscape of our usage and we will see our remaining areas further eroded through other land planning processes.

  1. Industrial pressure requires additional FRPA Objectives to be set: The snowmobile closures proposed align directly with the boundaries of the Industrial Moratorium, as such, it would appear that this will lead to increased pressure on the remaining land base below 1200M.  This will put public recreation areas directly overlapping industrial work sites and roads.  Therefore the legal establishment of the recreation polygons should include site-level objectives requiring forest licensees to communicate with recreation stakeholders and define mitigation strategies for the protection of public recreation resources including:
    1. The alpine and coniferous forest features along recreation sites or trails will be retained to preserve the outdoor recreation experience and prevent early season melt on snowmobile trails.
    2. Forest planning will include safety considerations for recreational access during the winter months and after harvesting is complete.  This will include harvest planning consideration above and below a recreation site or trail to ensure that new exposures and avalanche paths are not created. Or that any new avalanche paths are mitigated by terrain modifications such as deflection berms.
    3. This recreation site or trail is part of the working forest, and as such, activities that are likely to impact access or the recreation experience need to be communicated with the Designated Partner on the trail at least six months in advance.  
  2. Access must be protected:  All access routes into areas that remain open must be protected and in most cases improved to allow safe access to what remains.   This will require a commitment from many decision-makers and budget considerations across departments.  We need a commitment that the Province will manage all the decisions and provide an adequate budget to ensure areas that remain open can be safely accessed by snowmobilers long term.  This includes:
    • Forestry Roads for access or part of trail networks will need to be established by the Province as a provincial responsibility and an adequate budget allocated to ensure that they are safe for winter passage including replacing bridges, repairing unstable slopes, water damage, etc must all be mitigated, repaired or replaced.  It is not ok to come back a year later and remove a road to an open snowmobile area because the Province does not have the budget to replace a bridge.  
    • All restoration work will need to be done in close consultation with the snowmobile clubs in the area with clear details and commitment/assurance provided in writing that restoration work is not further limiting access or removing active trails in areas that have remained open.  That is not enough to ensure that future restoration work that is contracted out or done by industry as part of their deactivation of roads or lineal lines will not further limit our access.  It needs to be a firm commitment that someone within Government will ensure that the snowmobile access will remain open across departments and Ministries.  The snowmobile clubs cannot be responsible to track and try to manage multiple consultations across Ministries.  Government knows we are there, has committed to keeping these areas open for the continued economic benefit of the communities in the region, and therefore needs to commit to managing all processes that could further limit snowmobiling in the region.
  3. Enhancement Budget Needs to be Confirmed: Increased traffic to these areas will be immediate and therefore any approvals and subsequent infrastructure development must be completed prior to December 1st of this year.  Enhancement funding needs to be confirmed immediately and amounts for the next five years shared with the snowmobile clubs.  Once known, the clubs should meet with the Province to prioritize projects and begin implementation of key tasks focused on managing capacity, economic benefit, and safety immediately

The British Columbia Snowmobile Federation does not support the current plan as circulated with sentiment echoed by the eight thousand signatures collected by the public. The Province’s draft plan has taken the precautionary principle and used a long planning lens with no consideration of the secondary objective, which was for snowmobiling to remain viable.  The SPSAC focussed on creating a comprehensive plan reactive to where caribou are and adapting public access regularly to maintain separation as herds grow and habitat usage changes.  The Province’s plan, however, is to apply a blanket closure of lands to the public whether caribou are present or not, and use punitive means to gain compliance. What the Province’s plan fails to acknowledge is that, according to the science, snowmobiling is considered a low threat to the herds and should only be managed where access is considered pervasive.  In the South Peace, on today’s landscape, the number of riders is low and spread across the region which prevents snowmobiling from being considered pervasive in any one area.  With this plan that will change. 

It is our position that the members of the South Peace Snowmobile Advisory Committee diligently completed the work that was requested of us in the Terms of Reference and now ask the Province to follow through and review that work to ensure that quality snowmobile opportunities remain.  Closing 1 million hectares completely to recreational snowmobiling in the South has not provided any improvements to the herds but has directly impacted the economy of many communities and provided much financial burden to snowmobile clubs that are now trying to manage a growing sport with much less available terrain.   

This plan will not be successful without the support of the BC Snowmobile Federation, the snowmobile clubs, the riders, and the communities they support.  So we again ask the Province to follow due-process: review the recommendations forwarded in the SPSAC report, and implement the plan presented outlining the protection of  92% of occupied habitat with a strong adaptive management principle establishing the clubs as partners.  This collaborative effort will allow us to stand with you in support of your work and assist the province in the implementation of a successful caribou recovery initiative in the South Peace.