Evaluation of Lethal Fish Sampling and the Nonlethal Alternative Under the Canadian Metal and Diamond Mining Environmental Effects Monitoring Program

Abstract

The Environmental Effects Monitoring (EEM) program, federally mandated to metal and diamond mines and mills in Canada, aims to ensure that fish, fish use, and their environment are sufficiently protected by the Metal and Diamond Mining Effluent Regulations (MDMER). Concerns have been raised regarding lethal fish sampling conducted for the program and the potential risk to fish populations. This study endeavored to calculate the extent of fish sacrificed during lethal EEM fish surveys to provide a more informed characterization for stakeholders. By extrapolating data from 28 studies conducted at 8 metal mines in Saskatchewan between 2004 and 2017, it was conservatively estimated that 60 060 ± 19 978 fish have been sacrificed for the program nationwide since its promulgation in 2002. This is almost 2 times greater than guidance recommendations due to numerous factors. Challenges faced when implementing the nonlethal fish population survey alternative were also evaluated, and some of these included data interpretation inconsistencies due to the lack of critical effect sizes (CES) included in the regulations for nonlethal effect endpoints, and reliance on capturing young of the year fish to assess the prescribed effect endpoints. Finally, a case study conducted to evaluate the congruity of lethal and nonlethal fish population survey results identified that the effect endpoints often produced conflicting conclusions for the same response variable. Ultimately, this study highlights that in order to strengthen and promote the use of nonlethal fish sampling as an alternate to the current standard of conducting lethal fish population surveys under the EEM program, the effect endpoints, study designs, and adoption of CES need to be thoroughly evaluated and included in the MDMER. If nonlethal sampling designs adequately provide the required data and meet program objectives, then there would be no need to continue sacrificing fish for the Canadian metal and diamond mining EEM program. Integr Environ Assess Manag 2019;00:1–10. © 2019 SETAC

Authors' Reply: Getting on Board with Nonlethal Fish Sampling

“…The overarching objective of the critical review by Kambeitz et al (2019) is to further the conversation on enhancing the utility of nonlethal fish sampling conducted as part of the Environmental Effects Monitoring (EEM) program federally mandated by the Metal and Diamond Mining Effluent Regulations (MDMER). This publication has been well received by regulators, industry representatives, and Canadian mining associations, and we are excited to continue this conversation in the journal setting by responding to Tannenbaum (this issue).…”

“…There are multiple confounding factors (e.g., other fishing pressures, ecosystem dynamics, life history of sentinel species) to consider, and illustrating population effects is not as simple as showing a reduced fish number over time. Additionally, the hypothesized fishing pressure effects discussed in the literature (see discussion in Kambeitz et al 2019) includes the potential for impacts on metrics beyond abundance decreases. Regardless of whether losses caused by repeated lethal EEM fish surveys are researched and proven to be harmful to fish populations, we argue that the effective implementation of a nonlethal alternative will mute the impact potential.…”

“…As such, our critical review aimed to further the discussion on fish mortality concerns regarding lethal EEM fish surveys as well as highlight challenges associated with current nonlethal survey effect endpoints and data interpretation. As we note in our critical review, "vetting of the nonlethal alternative to ensure EEM program objectives are being met has not occurred since implementation, as the original sample size recommendations, effect endpoints, study design guidance, and statistical tests for nonlethal fish population surveys provided in the metal mining EEM technical guidance document have remained unchanged" (Kambeitz et al 2019). Although we did not discuss challenges regarding the existing lethal EEM fish population survey effect endpoints in detail, as that was not the focus of the paper, we were very pleased to see an expanded critique regarding the utility of these endpoints by Tannenbaum (this issue).…”

Missing the Boat with Nonlethal Fish Sampling

“…The critical review on the potential merits of a nonlethal alternative to lethal fish sampling in support of environmental effects monitoring that appeared in IEAM's volume 15, issue 6 (Kambeitz et al 2019) would appear to be raising more complications than it is quelling. The critical review's central thesis is certainly sound; it would be hard to imagine responsible environmentalists not favoring the development and implementation of nonlethal alternatives in required field assessment work, provided, of course, that the data quality to follow from a new approach would not be compromised.…”