I emailed about Dome Mine Effluent Testing on fish, and about killing beavers, and I got an absolutely convoluted BS response defending the animal killing. Please say something about the Dome Mine. Deadline is tomorrow. https://www.canada.ca/en/environment-climate-change/corporate/transparency/consultations/dome-mine-project.html
On Monday, August 28, 2023 at 03:49:46 PM EDT, MDMER / REMMMD (ECCC) <mdmer-remmmd@ec.gc.ca> wrote:
Hello Nicole,
Thank you for your emails today, on Aug 15th, July 25th and July 24th. We appreciate you taking the time to reach out with your concerns.
Newmont Porcupine (proponent of the Dome Mine) has a beaver management program that was developed and implemented in consultation with Indigenous communities that are signatory to the Resource Development Agreement, who also include the Trapper for the line within the property boundaries (who have maintained the line for over three generations), the Timmins Fur Council, the Mattagami Region Conservation Authority, and the Ministry of Natural Resources. This program also follows the Beaver Dam Breaching and Removal Code of Practice published by Fisheries and Oceans Canada in September 2022. The program is only initiated if beavers are located near the operations, near any proposed disturbance sites, and/or if water levels within the South Porcupine River are above or below ordinary high-water mark.
As for your second concern regarding “acute lethality tests”, I would like to emphasize that the proposed amendment to Schedule 2 of the Metal and Diamond Mining Effluent Regulations (MDMER) would not change the mine’s testing obligations under the MDMER.
In terms of scientific rationale/guidance, these laboratory-based tests have been used for decades to assess the toxicity of effluents prior to and following their release into the environment. Laboratory-based tests using fish and other species (e.g., invertebrates, aquatic plants, algae) are valuable tools for protecting the health of wild fish and fish habitat, which is the intention of regulations pursuant to the Fisheries Act, such as the Metal and Diamond Mining Effluent Regulations. These effluent tests can detect toxic responses in organisms that are not always detected by chemistry tests (e.g., due to interaction between different chemicals or conditions in the effluent that may cause additive or synergistic toxic effects). As well, the toxicity of the effluent can differ between species (e.g., fish may experience more toxic effects than invertebrates, or vice versa, depending on the contaminant mixture in the effluent). Laboratory tests are typically performed in accredited facilities and assessed by the Canadian Council on Animal Care or other animal care committees to ensure best practices for fish handling are used and to try to minimize the pain and distress experienced by fish during the process. The use of laboratory-based tests using fish and other species has led to a general improvement in the quality of effluent discharge from most Canadian mining facilities over the years.
Environment and Climate Change Canada is committed to reducing the use of vertebrate animals in toxicity testing, as evidenced by the recently added statements in the preamble of the amended Canadian Environmental Protection Act (CEPA). However, similar statements do not appear in the federal Fisheries Act. Encouragement of the use of animal alternative tests is a Government of Canada goal for testing of individual chemicals under CEPA but not a near-term goal for the Fisheries Act and its associated regulations. Fish acute lethality testing requirements directly address whether an effluent is considered deleterious or harmful under the Act (i.e., proof of direct acute lethality to fish) and therefore safe to discharge; the fish acute lethality testing requirement is incorporated into many federal and provincial regulations and permits; no standardized animal alternative tests are available to replace direct fish acute lethality testing for effluent regulation; and to our knowledge there is currently no precedent for using the results of animal alternative tests in legal cases of compliance test failures under Fisheries Act regulations. On the other hand, the results of laboratory-based acute lethality tests using fish have been reliably used in legal cases for decades. We would like to point out though that the MDMER also includes requirements for acute lethality testing using invertebrates species (Daphnia magna or Acartia tonsa). The reason behind having two effluent compliance requirements for acute lethality in the MDMER is that some effluents from mining facilities are more likely to be acutely lethal to fish than aquatic invertebrates, but the opposite response has been demonstrated as well (i.e., where Daphnia magna is more sensitive to the effluent contaminant mixture).
Division mines et traitement / Direction des secteurs industriels et des produits chimiques
Environnement et Changement climatique Canada / Gouvernement du Canada
Mining and Processing Division / Industrial Sectors and Chemicals Directorate
Environment and Climate Change Canada / Government of Canada