The lodge and resort proposal is entirely inside a designated ungulate winter range (UWR). The province establishes mountain goat winter ranges to provide high suitability habitat. Habitat attributes include snow interception, foraging opportunities, escape terrain, steep south and west-facing windswept ridges/slopes, conifer bluffs, shrub/grass communities, and security cover.

The range on the west side of Mount Garibaldi is known as MQ-1. It extends from Cheekye River to the top of Brohm Ridge and includes Natasha Lake. The winter range is used by mountain goats and is one of largest winter ranges in the south coast region.

There are two other UWR in the adjacent Clinker Ridge—WR-2 and WR-3. Summer range for mountain goats is in Garibaldi Park, for example the nearby Table Meadows area on the flanks of Mount Price and The Table. It is probable that mountain goats are traveling between winter ranges in winter and that path would take them through the proponent's tenure or that of Garibaldi At Squamish (the Aquilini project). Likewise, travel between summer and winter terrain would normally pass through proponent's tenure.

Biologists are uncertain as to where mountain goats are birthing and to what extent the cumulative development proposals on Brohm Ridge will have on the animals and their very young, especially during seasonal migration. The problem with the approach taken by project proponents on Brohm Ridge is that they only study the impacts on animals within the project boundary. The Garibaldi At Squamish proposal, for example, did not look at the impacts on mountain goats during their birthing period and seasonal migration. An environmental certificate was issued in error, in my opinion because it lacked taking into account regional impacts.

Mountain goats are extremely sensitive to noise and overhead disturbances. The presence of helicopters is a well known harmful impact on mountain goats. The presence of wind turbines is not a known hazard but extrapolating from the generally accepted scientific literature, they would be threatened by large overhead towers with rotating blades, especially above them.

The proposal is not compatible with the objective of preserving mountain goats. There are concerns about migration patterns being disrupted both summer and winter, cumulative impacts from the number of projects proposed on Brohm Ridge, threatening structures such as wind turbines, displacement from increased human activity and construction and lack of detailed environmental studies of a regional nature.