Mr. Andy Oetter
Adventure Tourism Manager
510-175 2nd Avenue
Kamloops, BC V2C 5W1

Re: Case File 3411014: Application by Coast Range Heliskiing for tenure

Thank you for allowing the Association of Whistler Area Residents for the Environment (A.W.A.R.E.) to comment on the tenure application by Coast Range Heliskiing. There are 2 main points that we would like to raise:

1. Areas of the tenure overlap Sea To Sky LRMP Wildland Zones
Sea To Sky Land Resource Management Plans (LRMP) Wildland Zones have been designated as zones that:” a). The Wildland Zone is to be managed primarily for wildlife, ecological conservation and natural backcountry/wilderness characteristics and to provide for public recreation and the development of tourism opportunities where appropriate.

b) Motorized and non-motorized recreational access will generally parallel the recreation use zoning found in the Recreation chapter.” (Sea to Sky Draft LRMP Section 2.3, pg. 19)

Coast Range Heliskiing’s tenure overlaps sub-zones 21 (Phelix), 24 (Upper Haylemore) and large areas of 25 (Upper Haylemore). Sub zone 22 (Phelix to D’arcy) will also be impacted by helicopter flights as it will have to be flown over to access the ridges in sub-zone 21. These Wildland sub-zones are to “maintain the wilderness, natural and visual and aesthetic (including noise management) qualities…as well as to “maintain wildlife habitat values…in particular for mountain goat” among others.

Also, recreation use zoning for these sub-zones is shown to be non-motorized:

http://ilmbwww.gov.bc.ca/lup/lrmp/coast/s2s/mapgallery.htm#RecreationandTourism

(Zoning guidelines for Commercial Recreation Planning- Winter)

Also note the LRMP Interim Management policy (also from April 2006 draft)…”govt. agencies are not to issue new permits, tenures etc that conflict with the management direction outlined in this draft LRMP (e.g. no new cutting permits in the Wildlands, no new motorized commercial recreations tenures in the Wildlands, etc). (see p83 in http://ilmbwww.gov.bc.ca/lup/lrmp/coast/s2s/reports/CH5.3.6-Ch6.pdf).

We feel that based on the documents cited above that a heli ski tenure is not compatible with the LRMP zoning for the requested areas.

2. Mountain Goats

Provincial mountain goat population surveys have shown that mountain goat populations in the proposed tenure areas have one of the highest population densities in the province. Accepted practice in the province is for helicopter flights to keep a minimum 2 km distance from mountain goats. In an area with the density of mountain goats that this tenure application has it is unrealistic to allow repetitious helicopter flights. There will never be any areas that are not within 2 km’s of a goat, seen or unseen. To jeopardize the health and success of one of the largest remaining mountain goat herds in North America for a luxury pastime that can be moved elsewhere would be reprehensible.

In conclusion AWARE feels that the proposed Coast Range Heliskiing tenure #3411014 should be rejected for its general unsuitability to the area

Sincerely

AWARE Board of Directors
P.O. Box 1370
Whistler, B.C.V0N 1B0

July 28, 2007

PO Box 1370
Whistler, BC V0N 1B0

Attn: Mr. Graeme McLaren, Mr. Archie Riddle, Project Assessment Directors, Environmental Assessment Office

Re: Garibaldi at Squamish Inc. Proposal

I am submitting this letter on behalf of the Association of Whistler Area Residents for the Environment (AWARE) regarding the ‘Garibaldi at Squamish’ proposal. Although we understand the economic gains are appealing and the BC government is determined to double BC’s tourism industry by 2015, AWARE has several environmentally-related concerns, which we believe will eventually lead to economic concerns, with this project as outlined below:

$ Building of micro-landscaped subdivisions would lead to the creation of a completely separate tourist destination in direct economic competition with Downtown Squamish, Whistler and Pemberton; each of these communities currently are unable to reach maximum capacity. (Whistler resort overall room revenue in the 2004/05 ski season ($114.9 million) slumped 8.3%, dropping to a six-year-low level).

$ Habitat fragmentation and wildlife displacement that will result from the construction of roads and ski runs will be considerable and irreversible.

$ The estimated damage to both Brohm and Cat Lakes, and the surrounding wetlands, subsequent to the building of the golf courses, and the future water use and fertilizer/pesticide management necessary to operate two golf courses, will be extensive.

$ The project is not only environmentally unsustainable, but also highly unsustainable from an economic point-of-view due to the competition of more than eight existing golf courses currently within the S2S corridor, from Furry Creek to Big Sky. As of the second week in August, the Pemberton Valley Golf Course will close due to monetary problems.

$ The increased amount of CO2 emitted from the construction of urban sprawl following the completion of the ‘Garibaldi’ project will only further contribute to the already low air quality in Squamish on an average day (real-time monitors in the region indicate that ambient concentrations of air pollutants are currently at levels that can have adverse effects on human health).

$ While not an environmental concern but a recreational one, future private development encroaching into Garibaldi Park prevents free and easy access to those wilderness areas for people. There is concern that the possibility of the application to extend the tenure of the ski hill into the existing park within the next 10 to 30 years.

$ Finally, a serious concern remains that the proposal shows poor research, with misspellings and inaccurate maps, and has not made public any attempts to make the ski hill, subdivided real estate or golf courses more environmentally-sound, using renewable energy and public transportation alternatives, advanced ‘green’ construction techniques, and at least Silver LEED standards, in order to comply with the current sustainable-living doctrines adopted by the Sea-to-Sky communities.

At a time when global warming is undisputedly contributing to warmer climates and decreased snowfall, and with no overall growth of the local ski industry in several years (since September 11th, US skier visits to Canada dropped more than 31.4%), it is absurd to consider the markedly unsustainable development proposal, ‘Garibaldi at Squamish’. The communities in the Sea-to-Sky Corridor aim to work towards the kind of growth that protects our admired, cherished, and commercially and environmentally, valuable natural areas. For these reasons, AWARE does not support the proposal.

Sincerely,

Sara Jennings
President of AWARE – Association of Whistler Area Residents for the Environment

June 27, 2007

Senior Land Officer
Integrated Land Management Bureau
200- 10428 153rd Street
Surrey, B.C.
V3R 1E1

Dear Sir or Madam,

Re: Westcoast Freeride Guides Ltd. Licence of Occupation- motorized commercial recreation, Heli Biking File: #2409410

I am submitting this letter on behalf of the Association of Whistler Area Residents for the Environment (AWARE) regarding Westcoast Freeride Guides Ltd. application for a proposed heli biking operation in the Rainbow Mountain and Cougar Mountain areas, Whistler, B.C.

The ILBM website indicates that Westcoast Freeride Guides Ltd. has applied for a Licence of Occupation for a heli biking operation covering Rainbow and Cougar Mountains. AWARE strongly opposes any heli biking in this or any other area. The area to the south and east of Rainbow Mountain drains into the Resort Municipality of Whistler (RMOW) watershed. As such any motorized activity should be permanently prohibited in this area to ensure that groundwater, melt water, and run off is not impaired by any oil or fuel contaminants. This would ensure the drinking water quality is maintained to the highest possible standards.

This area is heavily used by both local and non-resident tourist backcountry hikers who specifically enjoy an environment that is free from motorized uses. The area is quickly accessed by municipal trails and then through a sub-alpine forest into beautiful flower meadows. Any motorized activity, especially helicopter traffic, in the area will compromise the quiet enjoyment of the many current, non-motorized users of the area. This is especially critical at a time when one of the aims of the current B.C. government is to increase tourism, especially environmentally friendly, sustainable tourism. If this Licence of Occupation for a Heli biking operation is granted, it will displace many of the current tourist visitors who come to the area to enjoy its natural unspoiled environment.

The area is also heavily used by wildlife. Larger mammals including deer, goats, black and grizzly bears make use of the area. While helicopter noise has a negative impact on the resident wildlife population, groups of mountain bikers, descending at free-ride speeds, will startle and possibly injure many of these animals in a way that hikers and mountaineers cannot. Any detrimental impact on the wildlife population would result in reduced enjoyment for the current users of the area, many of whom visit the area because of the wildlife.

Trail erosion caused by mountain bike descents was first noticed some five years ago, when the “rogue” trails first appeared above the Rainbow section of the Flank trail. More frequent use of the trail would only increase this erosion. When trails are built to be used as both uphill and downhill bike routes, the potential for erosion is not such a large issue as they are designed to be ridden up and down and the need for sliding downhill with the brakes on is minimized.
Additionally, it should be noted that while the Westcoast Freeride Guides Ltd. application states that the bike trail they propose to use down Rainbow Mountain to the Flank trail is an existing bike trail, the trail does not show on any of the local bike trail maps or in bike guide books, including the “Whistler Bikeguide” published by Grant Lamont, a prominent Whistler Off-Road Cycling Association (WORCA) member, in June 2007. This “rogue” trail has continued to show serious erosion in sensitive meadow complexes and between sections of exposed bedrock in the alpine.

The Sea-to-Sky Backcountry Sharing Forum has designated the Rainbow Mountain area as a non-motorized area. The Westcoast Freeride Guides Ltd. motorized commercial recreation heli biking proposal violates this agreement.
As the 2010 Winter Olympics are rapidly approaching, Whistler is poised to showcase to the world its 2020 vision of a more sustainable way of life, we believe granting a new helicopter access would be extremely counter productive. AWARE regards preservation of our natural environment as one of the fundamental principles of maintaining and increasing our outdoor recreation tourism opportunities. As such, it is vital that these areas remain free from the consistent intrusion that a motorized tenure would bring.

At a time when the B.C. government has undertaken a campaign to reduce our greenhouse gas emissions by encouraging us to drive less, take the bus, commute by bike, or to buy a more fuel-efficient vehicle, we consider granting permission for a heli biking operation, or any other motorized operation, as an action which will drastically increase our greenhouse gas emissions, and further global warming. AWARE hopes ILMB sees the situation similarly, and not allow a further increase in such unsustainable tourism.

Sincerely,

Joel Allen
Director, AWARE