November 29, 2017 Letter of Complaint to Premier Horgan; re: The Recruitment and Operations of Conservation Officers in B.C.

November 29, 2017

Dear Premier Horgan et al,

We are writing to file a public service complaint regarding the operational and
recruitment (or hiring) practices of the BC Conservation Officer Service (COS).

We assert that a clear conflict of interest is present within the COS, its hiring practices,
and its operational policies. This identified conflict has created a significant risk to our
environment and the wildlife in this province for decades. We ask the Premier’s Office to
direct the Public Service Agency to conduct a review of the mandate, role,
organizational culture, and operational policies of the COS and to take immediate action
to correct these identified deficiencies.

Over the past sixteen years, honesty, integrity and accountability in Government were
bankrupted by the previous regime. Election 2017, we gave the NDP our trust, our
votes, and a mandate to bring about proactive change in the governance of British
Columbia.

In this letter, we will:
1. Demonstrate why there needs to be a review of the Conservation Officer Service
policies and mandate, including the need for the formalizing of ethics policies for public
servants that are involved in looking after wildlife in the wild, and in the wildlife’s
interface with communities.

2. Identify and address the public’s failing trust in the Conservation Officer service,
and what needs to be done to build trust in policies, education, and enforcement.

3. Address the fact that many Conservation Officers are hunters / trophy hunters, and
what this means to the public’s trust / lack of trust in the ability of COs to make decisions
with impartiality.

4. Ask for the independent oversight of the Conservation Officer Service just like
police have independent review boards in place.

5. Recommendations / solutions for the “conservation” of wildlife including preventative
education, wildlife laws with teeth, and proactive enforcement of laws, that apply to all
British Columbians.
Concerns

In a recent publication titled ‘In Defence of a Fallen King’, former BC Conservation
Officer Bryce Casavant wrote that he has personal knowledge of conservation officers
tranquilizing grizzly bear cubs, taking trophy photos, and then killing them quietly off site
out of the public’s eye
http://www.brycecasavant.ca/wp-content/uploads/2017/11/UPDATED-In-Defence-of-a-Fallen-King-formal-submission-2.pdf. The paper alludes to the need for a review of the
conservation officer program, calls for an ethics guideline for public servants involved in
wildlife management, and raises the issue of taxpayers funding the current model that
we have described.

The Conservation Officer Service recently posted a recruitment advertisement: https:// www.facebook.com/ConservationOfficerService/photos/a. 282020058506219.61904.282011641840394/1808079409233602/?type=3&theater
that reinforces the following concerns:

1. The Conservation Officer Service field operations is largely staffed by licensed
hunters, members of the BC Wildlife Federation, and in some cases, trophy hunters.

2. There is no independent oversight of this agency. Although it operates as a police
department, it is not accountable under the Police Act and it has no independent board
overseeing its operations and policy development.

3. Officers who are licensed hunters are afforded the opportunity to hunt for work
irrespective of closed seasons, permits, and licensing requirements. They benefit
personally (getting to hunt all year for work) and financially (they don’t have to purchase
licences or abide by standard laws) from their employment. This situation creates an
inherent bias and conflict of interest when responding to human-wildlife conflicts. It is
not reasonable to think that a licensed hunter, whose passion is killing wildlife, can
separate his hobby from his job and the need for him/her to maintain at least the
perception of impartiality as required by the BC public service code of conduct.
Therefore, the BC public service code of conduct is not being met.

4. Many examples illustrate a complete lack of “conservation”, education, or proactive
community policing, in combination with neighbourhood bears and their cubs being
killed , leaves the public completely distrustful:

See https://www.nationalobserver.com/2016/05/10/news/bear-cub-rehab-option-killedbc- conservation-office, or comments on social media such as “No one respects our
conservation officers and they are the biggest disgrace in BC for the slaughter they and
the RCMP do to our wildlife. So busy killing and making up lame excuses they have
forgotten how to conserve. Stop hiring hunters and get people who want to save our
wildlife.”

With the public’s lack of trust in the operational and hiring practices, there is great
concern regarding the Conservation Officer Service being placed in charge of “policing”
any new regulations regarding hunting, that the new government may develop.

5. The take-away message in the recruitment post:  https://www.facebook.com/ ConservationOfficerService/photos/a. 282020058506219.61904.282011641840394/1808079409233602/?type=3&theater
is that if you want to shoot wildlife for a job, you should join the Conservation Officer
Service. The fact that the agency believes it is okay to present this “message” to the
public, is exactly why the service mandate needs to be reviewed. There is no
messaging about actual conservation, rehabilitation, preventative education, coexistence,
or proactive community policing/outreach. It’s about shooting and killing (i.e.,
hunting) wildlife for work. This is the problem, and it has clearly created widespread
mistrust in the service’s ability to perform its mandate with a reasonable expectation of
impartiality and unbiased decision-making.

6. In almost every case where wildlife, particularly bears—both black bears and
grizzlies—are killed by a CO, the situation has been caused or exacerbated by
individuals or companies that are in contravention of the Wildlife Act because they have
not managed specific attractants. Yet very few tickets are handed out. Enforcement by
COs is almost nonexistent. Public education on the law is one of the primary
responsibilities of the COS, yet most of it is done by volunteers or low-paid employees
of a variety of community-based agencies. The primary reason given by government is
that there are far too few COs in BC to do this work. In order to be effective, the COS
needs to be properly funded by government specifically to do this public education and
enforcement work. Public safety is a direct result of public education, and public safety
is often the reason given for killing wildlife.

Supporting Information

In specific reference to the recruitment advertisement, the language used (“Want to
tranquillize a Grizzly Bear? Have you ever wanted to be up close and personal with a
live grizzly bear and get paid for doing it? Well now’s your chance. You could be the
next BC Conservation Officer who responds to human wildlife conflicts keeping our
communities safe.”) is not conducive to recruiting personnel whose primary concern is
conservation of wildlife. This is the juvenile, self-aggrandizing “sales” slang of an agency
that has lost touch with its conservation mandate.
In addition to these callous words, which clearly demonstrate the COS intends to
pander to a hunting audience, there is the accompanying photo of a CO holding a
grizzly bear cub mimicking those displayed by trophy hunters (This photo shares an
uncanny resemblance to the one in MOE 2017-73290).

One only has to look at the FaceBook profile pages of those who have been tagged in
the comment section to understand who the COS is pandering to. Most are hunters.
For more photos of Conservation Officers posing with their “trophies”, see: http:// www.westerncanadiangamewarden.com/S2012Phantom.html
A “story” of the “glory” of 2 COs:   https://www.outdoorlife.com/articles/jon-farley/2007/09/ phantom-hungry-hill
Outdoor Life a hunting magazine   https://www.outdoorlife.com
glorifying the killing of a bear by COs, (and more than 1 bear was killed on “Hungry Hill”,
according to some locals.

While this bear was in someone’s home, who was really responsible? Do you think
images like this help the reputation of hunters / COs? http://www.cbc.ca/news/canada/ british-columbia/grizzly-bear-shot-dead-inside-kimberley-home-1.3185310
“65% more bears killed by COs on Vancouver Island but complaints down.” That’s not
surprising, given the discussion in this letter.. ie no one wants to report wildlife being in
their area but more bears are killed anyway, by COs.   http://vancouverisland.ctvnews.ca/ number-of-bears-killed-by-b-c-conservation-officers-up-65-per-cent-this-year-1.3600502
As an agency, the COS professes integrity by stating, “Integrity. We maintain the
public’s confidence and trust by acting with sincerity and transparency.” However, their
recruitment ad demonstrates quite the contrary and is in violation of the code of conduct
for BC public servants for the reasons described above https://www2.gov.bc.ca/gov/ content/environment/plants-animals-ecosystems/wildlife/human-wildlife-conflict
In the Globe and Mail on 24 October 2017, Environment and Climate Change Minister
George Heyman publicly stated, “We want to restore and increase transparency and
public confidence in our ability to protect our natural environment, starting with this
iconic species, the grizzly bear, that is so important to so many British Columbians.” The
nature of the aforementioned recruitment ad on the COS Facebook page will hardlyallay the public’s fears.

To the contrary, the public’s trust in the agency has been
decreasing for many years. The Ministry of the Environment and Climate Change’s
ability to protect grizzly bears, especially during this time with the very contentious
grizzly bear hunting issues on the table, is being undermined by the very officers sworn
to protect them (http://www.theglobeandmail.com/news/british-columbia/habitat-loss-nothunting- main-threat-to-grizzly-bears-auditor-general-says/article36710111/).
Further, as Casavant said in his introduction to To Conserve and Protect:
Talking about public trust and how wildlife enforcement in British Columbia is conducted
and perceived isn’t always simple, but it is an integral part to ensuring our democratic
values are upheld.
http://(http://www.brycecasavant.ca/2017/10/27/discussion-starter-conserve-protect/)
Bears are paying for poor guidelines and practices, with their lives (500 bears killed by
Conservation Officers in BC so far in 2017).

“Conservation” Officers who may themselves be hunters and/or trophy hunters, are
going to police the proposed regulations that the new BC government says will “close
the loopholes” on grizzly bear hunting. We believe this constitutes a conflict of interest.
Further examples of the COS’ organizational culture are displayed within various
publicly available information links. For example, if you watch the YouTube link https:// youtu.be/WG6u-xEsx1k, you will see wildlife trophies on the wall behind the officer in
the Conservation Officer Service office . Another example can be found in a blog where
the same CO expresses his interests as: “fishing, hunting and trapping” (https:// fernie.com/blog/2012/11/joe-caravetta-receives-queens-diamond-jubilee-medal/).

When the COS mandate on the BC government website includes the words “prevent
dangerous wildlife from entering our communities and becoming a public safety
concern,” we are reminded of similar statements made by those who hunt grizzly bears.
It is not the wildlife that is dangerous, but the people who are leaving out attractants and
endangering their communities. A CO’s job is the proactive, preventative policing of
these issues, not strictly the reactive killing of wildlife because they like to hunt for work.
The recruitment ad on the COS Facebook page very clearly demonstrates the toxic
culture of killing within the agency, and a lack of respect for wildlife. As the new
government of our Super Natural British Columbia has said, “It’s time for change.”

Recommendations:

In the election campaign, BC NDP said it would create COS jobs and put more of these
“boots on the ground.” Regardless of if these “promises” hold true or not, the mounting
kill stories (as reported by the Vancouver Sun in multiple articles this year) blatantly
illustrate that the new government must immediately address the conservation officer
program. Our immediate concerns/recommendation are the following:

1) Amend BC’s Wildlife Act to promote commercial/residential attractant audits;
mandatory preventative attractant management; abolish attractant loopholes for any
British Columbian and any business in British Columbia; and enforce/increase monetary
penalties Section 33.1 & 88.1 directly applied to either:

a) property taxes
b) ICBC insurance premiums or BC vehicle licensing
c) MSP “tax”
d) or other efficient/effective method TBA

2) Immediately change the curriculum of COS training such that successful graduates,
i.e., Officers, can finally understand and responsibly communicate the critically different
behavioural definitions for the following:

a) “habituated” and
b) “food-conditioned”
Additionally, mandatory psychological screening and PTSD counselling should be made
available for the safety of the officers and the roles they play in the community, as
occurs in other policing agencies.

3) Educate and enforce prevention of loose, roaming dogs harassing/abusing bears
(Section 78 BC Wildlife Act), while “baiting” cougar and wolf predation/conflict into
wilderness interface neighbourhoods/communities.

4) Provide independent oversight just like a police board (maybe the environmental
appeal board?) and demolish the organizational structures that are empowering an
agency that is, in our opinion, a Corrupt Organization of Shooters. Cease being a
reactive model that ensures wildlife conflict and reprehensible kill numbers, to a
responsible, proactive, preventative ‘enforcement’ agency http://www2.gov.bc.ca/gov/ content/environment/plants-animals-ecosystems/wildlife/ human-wildlife-conflict

5) “Recommend that a special conflict of interest or ethics guideline/policy be developed
for public servants engaged with work on the grizzly bear file or in the development of
formal BC policy on this issue. Public servants or consultants with a conflict identified
under this new policy should be excused from the file, or subjected to a performance
review of their conflict, in order to maintain public trust and confidence in the process.”
per Bryce Casavant’s suggestions in” In Defense of a Fallen King”

Mr. Jefferson Bray’s letter follows, in which he shares specific incidents that
demonstrate why we are asking the Premier’s Office to direct the Public Service Agency
to conduct a review of the mandate, role, organizational culture, and operational policies
of the COS and to take immediate action to correct our identified deficiencies outlined in
this letter.

Yours truly,
Trish & Eric Boyum
Barb Murray – Bears Matter
Jefferson Bray

November 29, 2017

Dear Premier Horgan et al,

My name is Jefferson Bray. I am a signatory to the recently filed public service complaint to your
office.

As described within that complaint, I am providing further details pertaining to the Bella
Coola Valley and the conduct of the Conservation Officer Service. I consider this letter a part of
the complaint filed on November 29, 2017 and signed by Eric and Trish Boyum, Barb Murray –
Bears Matter and myself. I have attached photos of incidents that have occurred here, and
serve as examples of situations that still remain unresolved in this community, are known to the
COS, and that have resulted in bear deaths. I have provided my conclusion and necessary
recommendations.

I have been a resident of British Columbia for over forty years. I have made my home in the
Bella Coola Valley for the past fourteen. The attitude displayed in the examples provided, and
by many COS officers, is not that of a professional armed law enforcement service, but rather, a
rouge agency that is not accountable for its actions. Based on multiple interactions that I have
personally had with officers, I know that many officers ‘react’ to calls/situations by tracking and
killing wildlife. Indeed, the complaint that accompanies this additional supporting information and signed by others, reflects the true organizational attitude within the COS and an abusive
empowerment killing culture. This allegation is re-enforced by the fact that non-natural attractant laws are rarely enforced by the officers in this community (even after a bear has been killed).

A COS Officer stood in my driveway and told me that fines for offences under Section 33.1 of the BC Wildlife Act aren’t enforced/collected by the Province.

In the attached photographs you will note a female grizzly bear (her single cub was bawling at
the base of the tree) in an unprotected, fruit-laden apple tree that was one of a few that lined the private property boundary adjacent to the Hagensborg fuel/service station “Mecham’s”.
Unprotected fruit trees e.g. cherry (Spring), plum, pear and apple (Fall) illegally “bait” bears into
conflict. The COS has been aware of this for decades and fail to act – refusing to enforce the law
(Section 33.1 & Section 88.1 BC Wildlife Act) that is the foundation for their employed existence.
And Bella Coola Valley has had a “bear working group” for years, represented by MOE Human-
Wildlife Conflict Mike Badry, COS, WildlSafeBC, yet only afforded a part-time Conservation
Officer. Illegally “food-conditioned” bears are executed annually, while any “untrained” eye can
drive the 60 odd kilometres along Highway 20 (@80 km/h), performing a pseudo non-natural
attractant audit, identifying unprotected livestock and fruit trees from South Tweedsmuir to Bella Coola.

Recommendations

BC NDP and BC Liberals stated they would create jobs and put more “boots on the
ground” (Election 2017 campaign statements to increase the number of Conservation Officers in BC). Regardless of whether these “promises” hold true or not, these mounting kill stories
blatantly illustrate that our new NDP Government must immediately address the following
reprehensible failings of the Conservation Officer program1) Amend the BC Wildlife Act to promote commercial/residential attractant audits; mandatory
preventative attractant management; abolish attractant loopholes for various labels, or subsections of peoples e.g. ”farmers” and First Nations, because bears/‘dangerous wildlife’ don’t
care what ethnicity, race, religion, gender, hobby, or form of employment is responsible for the
illegal “baiting” – irresponsible human behaviour is irresponsible human behaviour); and enforce/increase monetary penalties Section 33.1 & 88.1 directly applied to either:
i) property taxes
ii) ICBC insurance premiums
iii) MSP “tax”iv) or other efficient/effective method TBA

2) Immediately change the curriculum of COS training such that successful graduates, i.e.
Officers, can finally understand, and responsibly communicate the critically different behavioural definitions for the following:
i) “habituated” and
ii) “food-conditioned”
iii) Understand bear physiology (and corresponding behaviour), their natural ‘attraction’ to
introduced i.e. non-native fruit orchards, vineyards, carrot patches, etc.https://phys.org/news/2017-08-kodiak-elderberries-salmon-climate.html

3) Educate and enforce prevention of loose, roaming dogs harassing/abusing bears (Section 78
BC Wildlife Act), while “baiting” cougar and wolf predation/conflict into wilderness interface
neighbourhoods/communities.

4) Provide independent oversight just like a police board (maybe the environmental appeals
board?) and demolish the organization structures that are empowering an agency that is, in my
opinion, a Corrupt Organization of Shooters. Cease being a reactive model that ensures wildlife
conflict and indefensible kill numbers, to a responsible, proactive, preventative ‘enforcement’
agency. https://www2.gov.bc.ca/gov/content/environment/plants-animals-ecosystems/wildlife/ human-wildlife-conflict

Based on my own experiences with Conservation Officers, many of whom are licensed hunters
and/or trophy hunters, I would like to know, does an Officer who kills animals for a living, ever
receive counselling, or a 5-year psychiatric check-up like police do? If not, why not?

There exists within this agency, a repetitive pattern of dereliction of duty under the own policy
and mandate. Under the guise of ‘conservation’, a reactive, “toothless” enforcement agency,
that does not enforce preventative attractant management Sections of the BC Wildlife Act – the
foundation of conservation law, but instead kills for convenience of cost/effort, and protection
from potential Provincial liability claims. The uniforms, the badges, the laws, the mantra
“Integrity, Service and Protection” are intended to represent a higher moral authority for the
safety and betterment of our communities and British Columbia’s natural environs. This corrupt,destructive model is the antithesis of that.

Yours truly,
Jefferson Bray

September, approximately midday Hagensborg service station “Mecham’s”. Grizzly mother and cub of the year (at base of unprotected apple tree).