Open Letter: Troubled Triggers: Correcting the Aim on B.C.’s Wolf Cull

Dear Minister, 

 [1]. Pacific Wild Alliance is a registered Canadian environmental charity specializing in  visual storytelling and public conservation education. Pacific Wild has a direct interest in the  Province of B.C.’s wolf cull program. 

 [2]. Pacific Wild seeks the Ministry’s proactive release of pictures and videos pertaining to  the B.C. wolf cull. This proactive release would be consistent with the statutory intent of the  Province’s information laws.

 [3]. In response to recent mainstream news media coverage about the wolf cull, the  Ministry did not publicly provide the photos of killed wolves currently in the Ministry’s  possession. 

 [4]. In December 2022 Pacific Wild tried to recover the aforementioned photos in the  government’s possession by filing information requests with both the Ministry of Forests (MoF)  and the Ministry of Water, Land and Resource Stewardship (referenced here as “the responsive  Ministry”). The program head for the MoF responded that the records could not be found and  that a new ministry had taken over the government’s wolf killing program (i.e., the responsive  Ministry). No confirmation of records transfer, retention, or information security for responsive  records between the responsible ministries was provided to Pacific Wild. The request for  records was unilaterally closed by MoF, in part. 

 [5]. In late December 2022 and early January 2023, Pacific Wild responded with a series of  questions for the government’s communications branch. Pacific Wild sought clarity on the  retention of responsive records (i.e., photos and videos of government sanctioned wolf kills) and  confirmation that they were being handled securely and without deletions. 

 [6]. The government did not provide any further substantive response, other than no  further information would be forthcoming while Pacific Wild pursued the long and arduous  information process. 

 [7]. Pacific Wild was then informed by the responsive Ministry (Water, Land, Resource  Stewardship) that a preliminary search revealed the government may, at a minimum, have  approximately 600 photographs and 14 videos relating to the wolf cull. Pacific Wild was  requested to pay a preliminary fee of $810 dollars for the government to continue to search its own records systems for further photographs and videos relating to the wolf cull. 

 [8]. On January 5th 2023, Pacific Wild did pay the fees from charitable funds received from  our donors. Although this information request continues, in Pacific Wild’s view it should not be  necessary. This letter is the next logical step in escalating the matter of proactive disclosure for  photos and videos of the wolf cull. 

A brief history of public interest & controversy 

 [9]. The B.C. wolf cull has a long history of controversy and public outrage dating back to  the early 1900s. Between 1920 and 1950 a “bounty” program killed over 27,000 wolves in B.C..  This was ended, in part, due to public outrage and political protest surrounding the government  expenditures of large-scale bounty payments to individual civilian hunters, often because of  fraudulent claims for compensation.

[10]. Between 1950 and 1980, resulting in large part from provincial fraud investigations,  the bounty system was replaced with a government-run predator culling program in which  thousands of wolves were killed. Following renewed public outrage and media scrutiny, a  successful court case in the late 1980s was filed by the Wilderness Committee and the cull was  halted.  

[11]. In 2015 the wolf cull was once again revived. Between 2015 and 2022 around 1704  wolves were killed at a cost of approximately 6 million program dollars. The government has  stated it intends to continue with the cull. The government’s killing of wolves has a long history  directly tied to heated public controversy surrounding the ethics of the killing activities and the  expenditures of public finances for such killing actions.  

[12]. Since the 1980s, the Wildlife Act has undergone many iterations with the most recent  being 2020, following a legal challenge to the wolf cull’s permitting provisions filed by Pacific  Wild. In that case, to avoid negative judicial consideration, the Province facilitated an  emergency rewrite of the applicable regulations and also obtained the missing federal  exemption permits it otherwise required. Although Pacific Wild was grateful to the courts for  their analysis and granting of public interest standing in the wolf cull, it remains a frustrating  point of contention that the public service is able to avoid legal challenge to its programs by  emergency regulatory drafting and secretive records retention processes. From Pacific Wild’s  perspective, the Ministry is not able to stand public or judicial scrutiny on the factual, ethical, or  substantive legal merits of the wolf cull. Rather, it is required to resort to clandestine records  retention regimes and underhanded carpet-pulling litigation strategies to avoid an independent  weighting and review of the wolf cull. Currently, the B.C. wolf cull employs individuals with semi automatic rifles (i.e., assault-style weapons) to shoot wolves from helicopters during the winter.  Recently, the public learned that the government was also killing wolf pups. The government  maintains that its shooting activities are ethical and humane and that the kills are verified by the  shooters and independently by a provincial veterinarian. Yet, at the same time, the public is  being denied access to records that could verify or challenge such claims. 

A matter of public interest 

[13]. The Ministry has publicly confirmed to news outlets that photos of wolf kills have  been taken during the cull and are retained by various public servants. Indeed, this is also a  requirement of the Wildlife Act permits issued for these activities.  

[14]. Although the government has routinely stated the killing of wolves is humane and  ethical, the shootings have largely been done in a secretive manner with little oversight. This is  reflected in the Ministry’s own correspondences, contracts, policies, and missives; documents  which clearly state that provincial oversight was not always possible due to government staff  availability. The withholding of pictures and videos of the wolf cull unnecessarily restricts the  public’s ability to hold the government to account for the humaneness and ethical aspects of the  wolf killings.

[15]. Pictures which may show dead wolves and various shot placements can speak directly  to the ethical controversies and provide new information to the public debate on this matter. 

[16]. The public’s interest in the treatment of canids was clear during the Whistler sled dog  cull trial, in which sled dogs were shot multiple times and some had their throats slit with a  knife. The Crown Prosecution Service prosecuted the file in the public’s interest – a focal point  of the case were the actions being used to kill the sled dogs, and if those processes were  humane and ethical or caused unnecessary suffering. 

[17]. Recently, Global News has reported that renowned animal behaviorist Temple  Grandin maintains third-party auditing of the government’s wolf kill actions are essential to  accountability and transparency. The photos and videos of these wolf kills speak directly to field level killing practices. It is only with this information that the humaneness and ethics of the cull  can be analyzed and assessed by third parties and the public, essential factors to open and  transparent ministerial and public debate.  

[18]. Pacific Wild has also directly participated in public interest litigation on the B.C. wolf  cull which saw substantial revisions to the regulatory frameworks allowing the culling activities  to occur.  

[19]. A partial list of media attention and issues notoriety is attached to this letter as  Appendix A. It cannot be disputed that there is significant notoriety pertaining to the B.C. wolf  cull and that the photos and videos would allow environmental charities and the public greater  transparency of the government’s policy decisions. 

The authority to release 

[20]. The intent of B.C.’s information access laws is clearly established by statute and  further interpreted by various orders of the privacy commissioner. In brief, access to information is essential to an accountable government in a democratic society. It is not  necessary to force all information to go through a lengthy process of information requests. The  government has the statutory authority to take proactive steps in releasing certain information  critical to public discourse and interest.  

[21]. Section 25(1)(b) of the Freedom of Information and Protection of Privacy Act, RSBC  1996, c. 165 (“FIPPA”) provides that the head of a public body must disclose without delay  information that is clearly in the public’s interest or relates to a significant risk to the  environment. 

Information must be disclosed if in the public interest 

25 (1) Whether or not a request for access is made, the head of a public body  

must, without delay, disclose to the public, to an affected group of people or to  an applicant, information 

(a) about a risk of significant harm to the environment or to the  

health or safety of the public or a group of people, or 

(b) the disclosure of which is, for any other reason, clearly in the public  

interest. [emphasis added]. 

Summary remarks 

[22]. The B.C. wolf cull is an issue of significant public controversy and notoriety. A  reasonable and objective observer can see that the release of photos and videos would allow for  verification of killing ethics and more detailed information in the public debate on the matter of  financial allocations and uses of government finances. It may seem cliché to say, “a picture is  worth a thousand words” but Pacific Wild does believe proactive release will help tell a fuller  story about a thousand wolves. Considering no independent research ethics certificate can be  located for the province’s wolf cull, it is reasonable and prudent to allow the public access to  records that can assist in verifying the results of government policies, decisions, and financial  expenditures. As well, this would allow for fact checking of government communications being  made to the public and media about the humaneness and ethics of the cull.  

[23]. The historical information stated in this letter is readily available through provincial  seminal reports and ministerial missives from the years of 1905 to present, as well as, various  government wolf cull contracts, formal policies, and shooting permits between the years of  2015-2022. In the interests of brevity, the expansive referencing catalogs, previous freedom of  information requests, and statutory and case references have been eliminated here. However,  this referencing information is available if required, or on further request from your staff (if  required). 

[24]. As a final comment, Pacific Wild wishes to advise your Ministry (and the MoF) that all  responsive records relating to pictures and/or videos of the wolf cull must be secured and  retained in a manner that future access can be provided should the program head not  proactively release them as requested here. We thank you in advance for your consideration.  Pacific Wild can be reached at the contact information provided within the signature block of  the email dated today.