Appellants factum - Woodward & Company

8F. Tsilhqot’in Territory and the Claim Area31. The Claim Area is at the heart of a larger Tsilhqot’in traditional territory. Itrepresents a small but critical portion of the lands traditionally used and occupied by theTsilhqot’in Nation. 69 The Claim Area comprises about five percent of what is consideredTsilhqot’in traditional territory. 7032. The Claim Area is situated in the core of traditional Tsilhqot’in territory. As heldby the Trial Judge, “the Claim Area lands, from the time prior to contact and through tothe assertion of Crown sovereignty and beyond, fall well within the much broader areadescribed as Tsilhqot’in traditional territory”. 71 Both Tsilhqot’in and non-Tsilhqot’inrecognized the Claim Area as lying firmly within Tsilhqot’in territory. 72G. Tsilhqot’in Occupation of the Claim Area from at least 1645-1660 A.D.33. Athapaskan people have populated the Chilcotin Region for hundreds of years. 73The Trial Judge found that people of the Plateau Pithouse Tradition (PPT) occupied thisregion prior to the arrival of Athapaskan people, but moved out of the region prior to1500 A.D., before or as Tsilhqot’in people moved into the area. 7434. The archaeological record places Tsilhqot’in people in Tachelach’ed since atleast 1645-1660 A.D. and in the Trapline Territory at the same time or a little later. 7535. The Tsilhqot’in connection to the lands and waters of the Claim Area findsexpression in the abundant Tsilhqot’in place names that blanket the landscape. 76An69 Trial Decision, para. 626.70 Trial Decision, para. 623.71 Trial Decision, para. 621.72 Trial Decision, para. 622.73 Trial Decision, para. 218.74 Trial Decision, paras. 208, 216, 625.75 Trial Decision, para. 625.76 Trial Decision, paras. 672-674.