SIDMS Letter to Ministry of Forest Officials Challenging the Validity of Permits Allowing Helicopter and Dog Hunting on Sidney Island
October 30, 2023
To: Director of Fish and Wildlife
Senior Wildlife Biologist
Section Head, Fish and Wildlife
Re: General Wildlife Permit Application No. 100418671
Submitted by Parks Canada June 16, 2023
From: Sidney Island Deer Management Society
Parks Canada (PC) has provided us with a copy of the above noted application for a Permit under the Wildlife Act and the Permit Regulation. The application also seeks exemptions from a number of legislated hunting restrictions.
The application seeks authority to eradicate all the deer on Sidney Island both in the national park and in the strata corporation property which makes up about 80% of island. The Sidney Island Deer Management Society (the “Society”) is made up of a number of owners of residential strata lots on Sidney Island who are therefore persons affected by the decision on PC’s application. If the application is approved and a permit is issued, PC has committed to providing a copy of the permit to one of our members and we presume this will include the reasons for your decision. We believe you are familiar with the details of the proposed deer eradication project as your office was represented on the Sidney Island Ecological Restoration Project committee since its inception in 2019.
You will know there is considerable opposition to the eradication project based on the lack of current, factual information demonstrating the necessity of killing all the deer. Specifically:
PC’s assertion that Sidney Island is currently in a severely degraded state as a result of the deer may have been accurate in 2012 when PC first proposed the project to the strata. However, the most recent study done by anyone qualified covered the period 2013-2018. It cited a 30% increase in native plant cover demonstrating the success of the strata’s well-managed deer hunt and cull. 1
PC has acknowledged the continuing improvement of the island’s vegetation and ecology but has not taken any steps to update earlier research.
PC has also failed to provide any scientific information on the size of the current herd that it seeks to eradicate. 2
The over abundance of deer which was recognized as very unhealthy for the deer herd and very damaging to the ecology no longer exists. The annual number of deer killed on the strata property as recorded by the strata’s hunt committee over the past 5 years has remained steady and significantly lower than in previous years. 3
the proposed method of hunting using helicopters and dogs is inhumane, unethical , expensive and not demonstrably necessary.
it removes the existing and longstanding hunting rights of strata owners
The Society is of the view that the Wildlife Act does not allow for the issuance of the permit and exemptions to Parks Canada given the circumstances of Sidney Island. The relevant sections of the Permit Regulation requires that in order to obtain a permit and the requested exemptions, including use of hunting dogs and helicopters and possible injury to eagles, the applicant must demonstrate that the purpose of the activity is to “control wildlife populations”. The deer population in Sidney Island is already well managed and controlled. Moreover “control” of a deer herd does not include eradication. The alternative is that the applicant must convince a Wildlife regional manager that the permit is necessary for the proper management of a wildlife resource. There is no basis for eradicating the deer on Sidney island in order to properly manage any other species of wildlife on the island.
The Society is concerned that Parks Canada has advised strata members that the first phase of the eradication project will commence on November 25, 2023, less than a month away. Yet no permit appears to have been issued nor have the results of Parks Canada’s most recent detailed impact assessment consultation done this summer been compiled, made public or submitted with the application.
We request that your consideration of PC’s application be put on hold until PC is able to provide needed up-to-date information that supports its application and meets the requirements in the Wildlife Act and Permit regulation.
Would you please confirm receipt of this email.
Thank you for you attention,
John Albrecht, President
Sidney Island Deer Management Society
sidms@gmail.com
sidmsociety.com
cc
Elizabeth May, MP
Animal Alliance of Canada
Project Manager, Parks Canada
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1. With reference to plots on Sidney Island “…we hypothesized that more recent efforts to reduce deer density on the island have the potential to reverse the effects of trophic downgrading by initiating an increase in the richness, diversity, and cover of palatable plant species (‘trophic upgrading’). To test this hypothesis, we re-surveyed 35 plots established in 2013 to assess change in plant communities. We observed that native species richness and diversity nearly doubled, and native plant cover increased by 30%, from 2013 to 2019.” Deer Abundance and the Recovery of Woody Plants of the Coastal Douglas Fir Ecosystem, 2019 UBC. Link to study, 1.69MB PDF.
2. PC’s Detailed Impact Assessment P. 13 refers to an unscientific estimate for the number of deer that came from 2 owners, who are not hunters, in 2020 and 2021. “The current population size is unknown, but estimates range from 300 to 900 individuals (Johnston, 2020; K. Poskitt, personal communication, January 2021).” Link to Detailed Impact Assessment, 2.85MB PDF.
3. Graph: Sidney Island Corporation Annual Hunt Results. Link to graph, 34KB PDF.