Chilcotin Parks Plan – public comments needed by April 30, 2014


The South Chilcotin is one of the largest networks of contiguously linked subalpine and alpine singletrack in North America. Located just 5 hours from the major metropolitan area of Vancouver, mountain bikers have been venturing to the area to ride for past few decades. During that time they’ve happily co-existed with other recreational users and wildlife (account from one of the biking pioneers here).

In 2010, the Chilcotins became part of the BC Parks system. Mountain bikers initially viewed this development neutrally hoping that their long-standing use of the park would be recognized and grandfathered, as is generally true for most other user groups. BC Parks began soliciting comments on a plan for the Chilcotin in 2011, closing the initial public input process in early 2012. Comments and actions from Parks and other user groups during that phase alerted mountain bikers that the plan might not be very bike-friendly. The Draft Management Plans for the area have now been released and confirmed this suspicion with language that singles out mountain biking as an unwelcome activity and that proposes to restrict mountain biking.

While the Chilcotin attracts a growing ridership that ridership is without a voice. The purpose of this article is to analyze BC Park’s draft management plan; explain the ramifications of the plan and to provide some comments. Hopefully other mountain bikers will see fit to also provide comments.

In summary, before 2010, the Chilcotins was not a park. Outdoor recreationalists could freely travel in the Chilcotins in the same way they can in the rest of British Columbia’s crown land. After much of the Chilcotins became a BC Park, BC Parks proposes to limit outdoor recreationalists (with the majority of proposals targeting mountain biking). Parks also proposes to drastically limit floatplane useage; the means by which some mountain bike and hiking day trips are conducted.

Public comments on this draft plan must be received by April 30, 2014 to be considered. See the links coming next as a way to provide public input. There is no geographical restriction on providing input so anyone can provide input … whether you live here, or somewhere else; whether you’ve ridden or want to ride in the Chilcotin.

Cinnabar Basin

Useful links

Some useful links are as follows:

Home page for the Management Plans
– South Chilcotin and Big Creek Draft Management Plan
– Yalakom Draft Management Plan (Mountain biking will be prohibited on 9 Mile Ridge – a trail in this park)
– Online comment form
– PDF comment form

South Chilcotins and Big Creek Draft Management Plan

Relevant portions of the South Chilcotins and Big Creek Draft Management Plan as released for public input on March 19, 2014 (“Draft Plan”) are reproduced below. Italics are the quoted text.

Please note that these are draft documents. The content was prepared in consideration of diverse input on recreational and conservation values. Changes are expected to these drafts based upon further input. Should you wish to provide input, please follow the directions on the webpage above or contact me directly to discuss your concerns or to set up a meeting.

2.5 – pg 15 – Hikers are 2/3rds of the park’s user, biking is 1/3rd. Neglects to mention that many bikers also access day trips and multi-day trips via drive-to trailheads (same as hikers, and same as horseback riders).

Hiking is the most popular recreational activity occurring in the parks. It is estimated that close to two thirds of visitors participate in hiking activities. The trail system allows for hikes of one or two days in areas near the trailheads (Figure 5), or for multi-week hikes for those who wish to explore more remote areas.

Mountain biking has become increasingly popular. An estimated one third of visitors participate in mountain biking while visiting the parks. Warner Lake and Spruce Lake are the main drop-off points for many bikers, who access the park by floatplane and bike out to the Jewel Creek trailhead. A smaller number of bikers also use the other trails throughout the parks.

3.2.2 – pg 22 – singles out mountain bikers as more likely to impact grizzly bears

Hikers and horse riders are more likely to go off-trail and show up in unpredictable times and places, but the slow pace usually alerts bears to their presence well ahead of any encounter. Mountain biking is the most fast-paced activity, and depending upon frequency, time and area of use, has the highest potential for bear/human interactions or disturbance of bears. Interactions between bikers and bears have been documented in the park. All recreational activities within the parks are a potential threat to Grizzly Bear recovery if not carefully managed.

23-24 – re protecting grizzly habitat by closing or moving bike trails

Reduce or minimize human presence in important foraging areas, such as whitebark pine in fall or wetlands in spring and early summer. Move campsites and trails if necessary and possible. Avoid or minimize human presence in areas with concentrations of spring. Grizzly Bear forage areas (Figure 4). Of note are six general areas:

1. Large areas in the southwest corner of South Chilcotin Mountains Park, just outside of the park but also in the pass entering Leckie Creek in the area of Leckie Lakes.
2. The upper portions of North Cinnabar, Pearson, Taylor and Eldorado creeks.
3. The meadows south and west of Spruce Lake and extending north along Spruce Lake Creek.
4. The meadows along the north side of Tyaughton Creek from the confluence of Spruce Lake Creek.
5. The wetland areas in the northern half of Big Creek Park.
6. A large area encompassing much of Big Creek downstream from Lorna Lake to the confluence of Graveyard Creek, lower Grant Creek, Tosh Creek, Graveyard Creek, Little Graveyard Creek, and the area from Dash Hill to the northeast and into Dash Creek to the east.

The high recreational use area of Spruce Lake should receive specific management attention due to the concentration of human activities and proximity to bear habitat. Specific strategies for this area include:
– Any increase in facilities, trails and use within or immediately adjacent to the meadow complexes should be discouraged.


On bluffs overlooking Eldorado Creek

pg 26 – contains more restrictions identifying bikes

Specific attention should be put toward mountain biking activity. With input from commercial operators and any other mountain biking organizations, management of mountain biking should focus on:
 Further investigation into the possibility of restricting the timing, location and zoning of biking activity (e.g., make mountain biking predictable by concentrating by area and time, no use before 8:00 am or after 4:00 pm, 3 days a week; avoid any biking in May).
 Agreeing to a “Code of Conduct” on how to avoid conflict with bears or other wildlife and how to respond if wildlife are encountered.
 Monitoring of mountain biking activity.
 Recognition that successful integration of mountain biking and Grizzly Bear recovery will recognize that not all areas of the parks should be available for biking and there is a limit to the number of bikers using specific areas of the parks.


Trails overlooking the Bendor Range

3.2.5 – pg 33 – identifies certain mountain biking guidelines under the “Recreation” heading. Many of these guidelines appear reasonable

Apply the following guidelines to mountain biking in the parks:
 Cross-country mountain bike riding, rather than downhill, will be the principal form of mountain biking in the parks.
 Development or construction of technical trail features will not be considered.
 Mountain biking will be restricted to existing or future trails; off-trail use will not be permitted.
Trails used by mountain bikes should have good sight lines on downhill sections (e.g., 3X3m width and height)..

pg 34

Work with the local communities and adjacent land managers to provide complementary recreational experiences in adjacent areas (e.g., providing mountain bike trails for those who want a more technical experience).

Use the separation of activities (e.g., use-specific trails in high use areas, twinning trails, timing, location, trail direction, etc.) as a suitable management tool in specific instances, but should not be used as a widespread strategy in the parks. Consider designing some trails for one user type (long sections of such trails should not exclude other users). This will make some trails generally more attractive to one user group, decreasing pressure on more heavily used trails. For example, consider construction of a new Tyaughton Creek trail, primarily for mountain bikers to attract bikers away from more heavily used trails; consider reopening the trail from Windy Pass to the north end of Spruce Lake for bikes only..

Under the heading of obligations undertaken by Tourism and Commercial Operations – pg 37

Encourage a shift from day-use mountain biking (fly in – ride out) to a more leisurely, group oriented, multi-day approach to reduce the potential for wildlife disturbance and conflicts with other users.


Horses and bikers co-existing


On its face, the Chilcotins Draft Management Plan’s general principles are innocuous but digging deeper there are substantial concerns that impact mountain biking. These are my questions.

Integrity of the survey

From October 2011 to January 2012, BC Parks conducted an online survey of Chilcotin park users (the “Survey”)(results here). 1432 people responded. 55% of people mountain biked. 22% hiked. Note that many people crossed over taking part in more than one activity.

Yet the Draft Plan states that hikers comprise 2/3rds while bikers comprise 1/3rds of users. Can BC Parks explain the discrepancy between the Survey and the Draft Plan?

Singling out mountain biking

The plan is redolent of negative bias towards mountain biking in the park. Mountain bikers are singled out as the user group that needs to be controlled in time and scope of activity (3 days/week allowed to bike; only biking between 8am to 4pm). Mountain bikers are singled out as the user group more likely to spook grizzlies. They are the only group which have to be “monitored”. Most troubling is the vague, amorphous and rather alarming statement that parts of the park will be off-limits of bikes in support of grizzly bear recovery. Note that it’s only mountain bikers that would be the endangered species. Not hikers. Not horseback riders.

Can BC Parks explain why it is assumed that mountain bikers are the group which have the most negative impact on wildlife (particularly grizzlies) if Parks contends that mountain bikers are not the most populous user group in the park? Is there proof that mountain bikers have had a negative impact on grizzly bears?


2% of survey participants list grizzly bear conflicts as being an issue. With the assumption that BC Parks would engage aerial helicopter surveys from local companies I asked local heli companies (Blackcomb, CCH) whether aerial surveys had been conducted; establishing that none had been undertaken.

Cursory research has shown that the only number cited for grizzly populations is 203 from the Coast to Cascades Grizzly Initiative which cites a BC government Ministry of Forests 2012 bear population estimate. That BC Government estimate uses regression analysis modelling estimates on pre-selected variables. It does not rely on actual population counts.

Based on 14 years of experience travelling in the Chilcotin my gut feel was that the 200+ bear numbers was high. I’d expect to have multiple encounters on every trip (which most definitely was not the case)! I took the liberty of asking Warren Menhennick (40+ years of Chilcotin experience) and Jamie Davidson (60+ years of experience) their impressions. To paraphrase both of them were of their opinion that grizzly bears and outdoors recreationalists (whether on bike, foot or horseback) and grizzlies have co-existed in the past and could co-exist in the future. Both also viewed the 203 grizzly bear estimate claim to be somewhat surprisingly high. Note that the above are unsubstantiated opinions based on real-world observations but do beg the following questions. Are grizzly bear numbers known or are current numbers just a guess? Can BC Parks explain how they intend to base their decisions vis-a-vis grizzly Bears and conflicts with mountain bikers? Will BC Parks inventory the grizzly bear population numbers? Will BC Parks proceed under the assumption that mountain biking and grizzly bears cannot co-exist?

Manson Creek descent

Ideas without (resources for) implementation

For some time BC Parks has been denuded of resources and generally underfunded (article summarizing funding cuts here) to the extent that outhouses cannot be rebuilt and toilet paper procurement cut. In 2011 there were 10 full time rangers for the entire province. There are a lot of praiseworthy initiatives in the Draft Plan spread among the more dubious negative prescriptions targeting mountainbiking. They all share one thing in common; there is no budget to implement them. You will need resources (ie people and dollars) to develop educational and etiquette policies, decommission or relocate trails; police the times and dates that bikes can ride.

Can BC Parks explain how it will deliver on the ideas in the Draft Plan? Does BC Parks think its a good idea to promulgate regulation that is unpoliceable given its (i) lack or resources; and (ii) lack of evidence for such regulation; and (iii) its lack of resources to gather evidence for regulation?

Reasonable apprehension of bias

Several comments were made by the Draft Plan and Survey’s author which give pause:

pg 1 Survey – It was known that a campaign was underway by the mountain biking community to provide input to the survey. This is likely the reason for the large number of respondents reporting as participating in biking and should be taken into consideration when viewing the results of this report.

pg 5 Survey – Keeping the park accessable [sic] for all users, and specifically for mountain biking, was the main input for future management. A lower number of recommendations called for removing hunting, setting carrying capacity for use and maintaining access. Again, it must be taken into consideration that most respondents were from the mountain biking community.

These comments are strange in at least a couple of ways. Firstly the reason for the public survey process is to gather as many responses as possible. Why then complain if a user group actually participates in the process and canvasses members to be active in the public process? Secondly, the author ignores the fact that other groups including hikers/mountaineers represented by the FMCBC (initial article & later more tempered submission) and at least some local groups (the Wilderness Stewards f/ka/ Chilcotin Wilderness Society) also actively solicited responses from their respective viewer base (submission here).

Why does BC Parks editorialize in a way to diminish the impact of mountain bikers’ input into the Survey and Draft Plan? To the extent that BC Parks even takes user group’s comments into account, how much impact does the bias in the document have on BC Parks’ recommendations in the Draft Plan?

Undue Influence of competitors on the plan

A group of individuals known as the Wilderness Stewardship Foundation made a rather pointed submission to BC Parks during the public comment period. Many of their submissions were directed at regulating mountain biking and regulating floatplane flights into the park.

Many of their prescriptions particularly those targeting the floatplane tourism operator (Tyax Adventures) and targeting mountain biking made their way into the Draft Plan. There is another tourism operator in the Chilcotin competitive to Tyax Adventures — Chilcotin Holidays. It is interesting to note that directors, guests and employees of Chilcotin Holidays are also on the board of the Wilderness Stewards namely the following persons:.

• Helen Williams – has been guest at Chilcotin Holidays (was listed as a director in a 2011-12 cached copy of the Wilderness Stewards website – entry now removed)
• Andre Kuerbis – manager at Chilcotin Holidays (was listed as a director in a 2011-12 cached copy of the Wilderness Stewards website – entry now removed)
• Rob Denier – employed by Chilcotin Holidays as an Outdoor Adventure Specialist.

(Please note that no aspersions are meant to the character of the persons named above. Google searches show the links between such persons and their associations with Chilcotin Holidays).

This leads to the following questions. Does BC Parks know about the ties of the Wilderness Stewards to a tourism operator in the Chilcotins? Why is BC Parks accepting the wholesale recommendations of one competitive outfitter against another outfitter? Is BC Parks being brought into the tactics of a competitor seeking to outmaneuver another tourism operator (Chilcotin Holdays vs Tyax Adventures? Is BC Parks concerned about the optics of seemingly adopting the role of advocating on behalf of a specific operator in the Parks they are attempting to regulate?

Germane references from the Wilderness Stewards submission which found their way into the BC Parks Draft Plan follow:

Tyax Air references

pg 2 – Limitation of fly-in access within the park.

pg 10 – Ensure that efforts are made to minimize impacts of facility developments and visitor use on wildlife habitats or disturbance of wildlife. Aircraft use, helicopter use and other uses must be regulated to eliminate or reduce impacts.

pg 12 – To limit and regulate aircraft use in the park
• Monitor aircraft use and impose restrictions to prevent environmental or social impacts.

pg 18 – • Use will be monitored and operational measures may be applied to manage and limit visitor use if required to maintained the desired use levels. Measures could include longer hike-in routes, restricted air access, and user fees for visitors.

Mountain biking References

– pgs 15 – 16 – • Establish a zoning system for trails and designate trails for combination use or exclusive use:
– Designate trails that lead to the Chilcotin Holidays guest ranch as “horse use only”
– Lick Creek Trail
– B&F Creek Trail

Editorial note – Lick Creek and B & F trails are used by bikes. The effect of this proposal would be to close them to bikes for the benefit of Chilcotin Holidays.

Mountain Biking is a relatively new use form within the park area. As a form of non-motorized use, it will continue to be allowed in the park area. Limitations for suitability (wet soils, enclosed trails, etc.) apply to mountain bike use and management decisions must be made to reduce conflicts with other users.
Objective :
• To allow mountain bike use throughout the park within acceptable levels of impacts to trails, social experience and the environment.
• To resolve user conflicts between mountain bikers and other users of the trail system

Strategies :

• Permit Mountain Bike use within the park area. Mountain Bike use should not be promoted.
• Establish a zoning system for trails and designate trails for combination use or exclusive use:
– Day use zoning: Establish, designate and maintain Mountain Bike use only trails around
Tyax Lodge:
– On North and South ridges of Crane Creek
– On North and South ridges of North Cinnabar Creek
– Taylor Creek and Pearson creek mining roads, both multi use trails
– Fly-in day use: Establish, designate and maintain a new primary “Mountain Bike use only” trail from Spruce Lake to Tyax Lodge:
– From Spruce Lake Creek Trail
– Down Tyaughton Creek Trail leading East
– Connecting Mud Creek FSR leading South
– To Tyaughton Lake Road FSR
– Arriving at Tyax Lodge
– Multi-day use: everywhere on the park’s existing trail system
– Fly-in access points for multi-day use on Warner Lake and Lorna Lake
• Mountain bike use should be monitored and, if use and related impacts dictate, portions of
the park may be closed to this activity.

Effect on trail maintenance

The BC Parks plan has many recommendations for trail work, trail realignment and trail closures. Most readers will view those prescriptions dubiously given the paucity (absence?) of Park’s resources. Another consequence of BC Parks’ recommendations is that the restrictions they will impose on floatplane flights (reduced hours of operations, limited flights per week) will probably put Tyax Adventures out of business. Tyax Adventures is a major contributor to trail maintenance and upkeep in the Chilcotins (so is Chilcotin Holidays for the record).

Does BC Parks have a plan to do trail maintenance and upkeep trails once their Draft Plan puts Tyax Adventures out of business? Does BC Parks have resources to implement such a plan?

Eldorado Creek cabin – built, maintained by Tyax Adventures who also maintains the trails/bear caches around the area

Summary and comments required

To repeat the summary, before 2010, the Chilcotins was not a park. Outdoor recreationalists could freely travel in the Chilcotins in the same way they can in the rest of British Columbia’s crown land. After much of the Chilcotins became a BC Park, BC Parks proposes to limit outdoor recreationalists (with the majority of proposals targeting mountain biking). Parks also proposes to drastically limit floatplane useage; the means by which some mountain bike and hiking day trips are conducted.

BC Parks has a lamentable reputation in accommodating mountain biking as a valid form of recreational use of parks. It seems that mountain bikers are a pariah user-group in the eyes of Parks. The recent farcical Garibaldi Park amended management plan exercise where public input was solicited then ignored was emblematic of this process (article re draft plan then final plan where survey numbers were cooked). The Chilcotin Draft Plan unfortunately seems to continue down this path.

At this point in time BC Park’s process has done much to demonstrate that they are at best ambivalent and at worst, hostile to mountain biking. My input on the Draft Plan is that it needs a more measured approach that does not single out mountain biking as the problem group. If you agree with some or all of the analysis in this article please feel free to ask the following of BC Parks.

• Why are user group breakdowns so different from Survey to Draft Plan?
• Why does the Draft Plan single out mountain bikers as the group that will most negatively impact wildlife?
• From where does BC Parks establish grizzly bear population numbers?
• is there proof that mountain bikers have a negative impact on grizzly bears?
• If grizzly bear population numbers are based on estimates, is it appropriate to single out and limit one user group (mountain bikers) based on what amounts to guesses?
• From where will BC Parks will get resources to implement its policy recommendations?
• Why does the Draft Plan author seem to be so apprehensive of mountain bikers’ interest in responding to the Survey?
• What impact did Chilcotin Holidays have on Draft Plan recommendations?
• If the Draft Plan puts Tyax Air out of business how will BC Parks replace the trail maintenance hole left behind?

In my opinion, this is not just a mountain biking issue. If you had a commercial operation, or were a hiker, mountaineer, ski-tourer, sledder, heli or float-plane-accessed any Crown land anywhere in this province and that land became a BC Parks you should be concerned about how BC Parks is handling this process. Again, anyone living anywhere can comment. Be polite but do not hesitate to be pointed. Here are the comment forms

– Online comment form
– PDF comment form

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  1. Lee Lau
    Posted April 7, 2014 at 9:47 pm | Permalink

    The Chilcotin is one of the world’s beautiful places to ride mountain bikes in the alpine. It’s now become part of the BC Parks system. BC Parks has put forward a draft plan seeking to regulate and restrict mountain biking in the area.

    The BC Parks’s draft plan unfairly singles out mountain bikers as impacting wildlife. The draft plan is based on conjecture, guesswork and is unfair in its recommendations. Please ask BC Parks to make decisions on a science-based factual approach and not just restrict mountain biking because of stereotypes of the mountain bikers.

    Comments must be received by April 30, 2014. Send comments here

  2. shawn cote
    Posted April 8, 2014 at 1:27 pm | Permalink

    I have had the pleasure of a few Mountain Bike adventures in the Chilcotin range. My first was in 2008. Our approach to every excursion was “leave it like you found it” The BC parks plan unfairly identifies Mtn Biking as a negative impact on the trail system and bear habitat. This is an entirely unfair assumption with no clear data to support this conclusion. Please ask BC Parks to review its stance or proposal to Moutain Biking use. We are here to help and to be a positive impact and influence on the management of all our trail systems.

  3. Charles McLellan
    Posted April 8, 2014 at 8:34 pm | Permalink

    Being an avid mountain biker, a Chilcotin enthusiast and a grizzly bear biologist I find it disappointing that mountain bikers are singled out in their new management plan. I agree that people displace grizzly bears from optimum habitat but a cyclist shouldn’t displace grizzlies more than a hiker, a horse rider or a hunter. I feel it is more of a density issue (ie: more people more displacement). Bikers cover more area but tend to stay on trails whereas hikers often go up valleys or peaks even in the absence of trail networks and therefore might have a larger impact on grizzly bears (particularly if they are 2/3rds of the user group).

    From a grizzly bear population stand point, the largest negative influence is people with guns. Grizzly bear hunting doesn’t occur in the South Chilcotins (to my knowledge) but ungulate hunting does and it is well known that many grizzlies are shot by hunters when they protect themselves and their game meat. Bikers don’t kill grizzly bears and unless they make a light weight carbon rifle we won’t. Even many hikers I have seen in grizzly country carry a gun with an encounter potentially ending with a dead bear (this is not an issue with biking).

    My intention is not to point at other user group as I enjoy hiking and hunting as well. I agree that many of our backcountry locations are becoming overcrowded and this has a negative impact on grizzly bears. I agree that certain trails should be closed in the South Chilcotins but they should be closed to bikers, hikers, horseriders, hunters, Chilcotin Holidays and even the park wardens. Restricting only biking certainly won’t solve the grizzly bear issue.

    Restricting mountain biking is just an easy way to reduce people. The same thing happened in Mount Assinaboine years ago. Today you can no longer bike in the park but hundreds of helicopter trips bring thousands of tourists each year to huge fancy lodges. From an environmental view, which is worse??

    Bikers. We need to stand up to ourselves this time.

    • Posted April 19, 2014 at 3:52 pm | Permalink

      Charles, your comments reflect many of the ideas which we are incorporating into a alternate proposal to parks next week. It would be great to speak with you soon.

  4. Jereomy Pelletier
    Posted April 8, 2014 at 10:36 pm | Permalink

    BC is becoming more and more well known as the mountain capital of the world and this fact has contributed to a huge tourism increase in the province. By eliminating mountain biking in the chilcotins you are not only affecting mountain bikers, you are also affecting the towns in the surrounding area that depend on the mountain biking traffic

  5. Matt Hunter
    Posted April 9, 2014 at 10:32 am | Permalink

    Planning_Project: South Chilcoltin and Big Creek Park

    I Agree With The Following: 1. I agree that protecting the wildlife of the area is a priority.
    2.Agreeing to a Code of Conduct on how to avoid conflict with bears or other wildlife and how to respond if wildlife are encountered

    I Disagree With The Following:
    1. Targeting mountain bikers as a user group that has a greater impact than others on Grizzlies.
    -mountain bikes travel quietly but not silently. Bears are alerted by the sound of bikes and have time to move off the trail.

    -there is no study to confirm that mountain bikers have a greater impact on bears than other users.

    Additional Comments:
    There are changes that will benefit the wildlife in this area, and that all user groups must agree to. Please don’t allow false, unproven, non science based perceptions and assumptions of mountain biking to influence the direction of this plan. Humans on foot, on horse and on bikes all cause disturbance to bears; human traffic may need to be removed from some areas, but by closing trails to only one user group that change will not have an effect. Please also be very aware that recommendations by the widerness stewardship foundation represent the wishes of a group who’s interest is tied to commercial operation and should be treated as such. Their bias towards restricting activities that don’t benefit them should not affect other users of the park.

  6. Annie
    Posted April 11, 2014 at 9:52 am | Permalink

    BC Parks really needs to do his homework and make decision with real facts and not from second hand bias information.

    I am greatly disturbed that this would be implemented without consideration of real facts and data.


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