This final submission from Colville includes the following:
- Colville's interest
- The requirements of the SDMCLCA have not been met
- Conservation issue not established (1st requirement of 13.5.2)
- Not established that Total Allowable Harvest (TAH) is required for conservation (2nd requirement of 13.5.2)
- The proposed TAH goes further than required (3rd requirement of 13.5.2)
- Conclusion - Colville recommendations
- Exhibit "A" - April 30, 2015 letter, Colville to ENR
- Technical summary of the key concerns, regarding the proposed management plan for the Bluenose-East caribou herd - Norman Barichello
- We are concerned about the lack of co-management.
- Deployment of radio-collars should be prohibited.
- Currently management actions are based almost entirely on a population census that is of questionable accuracy, and is undertaken at a time when caribou should be left alone.
- The observed changes in the number of caribou in the Bluenose East population has prompted a “caribou conservation crisis”, despite wide-spread acknowledgement (likely consensus) that barren ground caribou cycle in numbers over a 30-50 year period.
- There are many factors believed to be at play in the climate-caribou cycle to explain observed cyclic pattern, yet there is minimal effort to monitor these potential factors, or include them in analytical projections of herd trend.
- The decline in caribou has coincided with northern development (diamonds, oil and gas, mineral exploration), yet meager effort is made to manage adverse impacts associated with
- Harvest is singled out despite any compelling evidence that harvest caused the decline or will influence its recovery.
- Significant impacts to the Dene way of life.
- The determination of harvest is badly flawed.
- ENR’s population projections are very simplistic and unrealistic.
- ENR’s promotion of bull-only harvest is also far too simplistic and ignores what is likely a far
more complex relationship between sex ratio and caribou productivity and survival.
- Recommendations to the Sahtu Renewable Resources Board.