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Stratus Consulting Memorandum (4/16/2010) 3.4 Adaptive Management Dr. Maest will critique the Proponents’ suggestion that they can address unplanned contaminant releases with adaptive management. She will present information from a recently published governmental guide for adaptive management (Williams et al., 2009) that specifies the need for proponents to adequately plan for and mitigate all potential impacts, using adaptive management as an incremental step to adjust existing plans rather than as a strategy to avoid testing, monitoring, mitigation and mine planning. Dr. Maest will discuss examples where adaptive management has been attempted, including previous case studies in which mining companies either failed entirely to address the contamination they generated or were required to retrofit with very expensive water capture and treatment designs that they will need to maintain in perpetuity. 4. Effects of Metals on Salmonid Fisheries Given the risk that Taseko has underestimated contaminant generation and transport, plus their lack of planned water capture and treatment onsite and the preponderance of evidence from other mine sites, it is highly likely that mine contaminants will be released to downstream and downgradient resources. Specifically, we believe that heavy metals likely will be released to Fish Creek, Big Onion Lake, and the Taseko River, at concentrations that could exceed the proponent’s “worst case scenario” by orders of magnitude. Metals releases to cold-water fisheries could have profound adverse impacts on aquatic biota. To illustrate examples of such effects, Dr. Morris will present data from many toxicology studies that have examined the effects of heavy metals on fish, with Dr. Josh Lipton on teleconference if possible. As mentioned previously, the underlying data on which the water quality predictions at this mine are based are flawed. We do not believe the Proponents have adequate data to accurately quantify the releases of contaminants to downstream receptors in Fish Creek and the Taseko River. However, we can compare the Proponents’ predicted “worst case” metals concentrations to known effects from our toxicity testing, and we can show the small margin of safety in those estimates. We conclude that even a small underprediction in the Proponents’ modeling would lead to metals concentrations that are associated with lethality to salmonid fish. To keep the presentation simple and short, Dr. Morris will likely focus his presentation on the effects of dissolved cadmium and copper on salmonids, although other metals and other mechanisms of adverse impact will be discussed briefly. 4.1 Background Information Dr. Morris will present basic concepts in aquatic toxicology, including acute toxicity, chronic toxicity, and different types of adverse effects of metals. He will also briefly discuss the many Page 10 SC12041
Stratus Consulting Memorandum (4/16/2010) ways in which metals can adversely affect aquatic biota, including sediment and food chain effects. He will also discuss some of the many factors that can effect metals toxicity, and how those factors suggest that the impacts of metals could easily be far greater than predicted. Background information on basic metals toxicology will draw on information from Meyer et al. (2007) in addition to other sources cited below. 4.2 Cadmium Toxicity Dr. Morris will discuss the mechanisms of cadmium toxicity and present data showing concentrations of dissolved cadmium in surface water at which deleterious effects occur. He will show concentrations at which lethality occurs, and lower concentrations at which sub-lethal effects such as reduced growth and behavioral avoidance occur. Dr. Morris will show that the predicted “worst case scenario” concentrations of cadmium in Fish Creek and the Taseko River exceed thresholds for sub-acute effects on salmonids and exceed the Canadian Council of Ministers of the Environment (CCME) acute threshold for cadmium (CCME, 1999). If the Proponents’ worst case scenario underestimates cadmium concentrations, cadmium would likely be acutely lethal in Fish Creek, would at least exceed concentrations that reduce growth and cause behavioral avoidance in the Taseko River, and could exceed acutely lethal concentrations in the Taseko River. Dr. Morris’ analysis of cadmium toxicity will draw on several sources of data, including McNicol and Scherer (1991), Stratus Consulting (1999), Hansen et al. (2002a, 2002b), Sloman et al. (2003), and Riddell et al. (2005). 4.3 Copper Toxicity Dr. Morris will discuss the mechanisms of copper toxicity and present data showing concentrations of dissolved copper in surface water at which deleterious effects occur to salmonids. He will show concentrations at which lethality occurs, and lower concentrations at which sub-lethal effects such as reduced growth and behavioral avoidance occur. Dr. Morris will show that the predicted “worst case scenario” concentrations of copper in Fish Creek exceed thresholds for sub-acute effects on salmonids and exceed the BC Ministry of Environment water quality guidelines acute threshold (BC MOE, 2006). Predicted copper concentrations in the Taseko River would exceed thresholds for sub-acute effects on rainbow trout. If the Proponents’ worst case scenario underestimates copper concentrations, copper would be acutely lethal in Fish Creek, would at least exceed concentrations that reduce growth and Page 11 SC12041
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SESSION-SPECIFIC COMMENTS & REQUEST
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Attachment A Written Submission for
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Attachment B Written Submission for
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Education Attachment D Dr. Gordon H
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3 Prosperity EA Review. Taseko Mine
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Prosperity Mine Aquatic Impact Asse
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4 • Remain stable and capable of
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something that is proposed and ‘p
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adjacent meadow or lowland areas ar
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Concluding Comments The proposed co
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The following briefing on mine-rela
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Impact of Shift/Rotation Schedule o
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Impact of Shift/Rotation Schedule o
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Boom/Bust Cycle of Mining Industry
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Social Change in Cohesion of Commun
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Social Change in Cohesion of Commun
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Impacts on Culture • Consequences
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Impacts on Community Resources •
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Impacts on Community Resources Incr
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On the Positive Side on Things…
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LITERATURE CITED 1 Heiler, K., Pick
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23 Story, K. and L.C. Hamilton. 200
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AN INDEPENDENT REVIEW OF THE TERRES
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I. GENERAL APPROACH & OVERVIEW BY M
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A. REVIEW OF PROPOSED TASEKO LAKE/W
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occasionally used for wild horse do
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9 with other direct and indirect mo
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11 grizzly bear mortality that I pr
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13 mortality as a result. I predict
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LITERATURE CITED: 15 Austin, M.A.,
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17 Wakkinen, W.L. and B. Allen-John
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� Forestry-wildlife research �
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� Spirit Bear (Cross-Country Cana
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McCrory, W. 2006. Bear hazard asses
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McCrory, W. 1997a. Preliminary eval
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2010 Xeni Gwet’in Community‐bas
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EXECUTIVE SUMMARY TABLE OF CONTENTS
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iii
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These longer‐term impacts could w
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Adaptation to climate change is typ
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5. Develop a realistic and practica
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Conclusions concerning the impact o
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Awareness raising and capacity buil
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3.2. Geography The study area is lo
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The XGCA is a remote, wilderness ar
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Figure 3: XGCA BEC Zones 14
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station closest to the Study Area w
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• Overall: Winter weather has got
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Source: Theo Mlynowski, UNBC Precip
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Figure 7: Comparison of Mean Annual
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Gwet’in Territory. It should be n
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Glaciers 28 Like snowmelt, glaciers
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Table 7: Research studies ongoing i
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interation under different scenario
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elatively uniform climate are calle
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Box 2: The importance of curre nt a
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Box 3: Forest Fire Hazard in the XG
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will likely be scattered Douglas‐
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• Effects of climate change: Kinn
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• Whitebark Pine: Of the two tree
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This section provides a summary of
Page 183 and 184: Past climate changes and their impa
Page 185 and 186: Projected Climate Changes and Impac
Page 187 and 188: system. They are relatively healthy
Page 189 and 190: 6.2. Health and Safety At present,
Page 191 and 192: The Xeni Gwet’in depend on a vari
Page 193 and 194: obligated to finance these repairs
Page 195 and 196: the ecosystem may experience over t
Page 197 and 198: they traditionally have as well as
Page 199 and 200: • Dam and store water at Abelache
Page 201 and 202: 8.3. Water Supply Protection and Co
Page 203 and 204: so no further elaboration is requir
Page 205 and 206: • Re‐introduce fire and allow n
Page 207 and 208: Biodiversity Protection and Conserv
Page 209 and 210: Preserve Wild Plants & the Habitats
Page 211 and 212: Water Supply Protection and Conserv
Page 213 and 214: Increase Preservation of Wild and C
Page 215 and 216: Adaptation Objective Develop Nature
Page 217: Adaptation Strategies into Local Go
Page 220 and 221: Ecolibrio (2009). Xeni Gwet’in Co
Page 222 and 223: Nelitz³, M. and M. Porter. 2009c.
Page 224 and 225: ANNEXES - BACKGROUND PAPERS (NOTE -
Page 226 and 227: Stratus Consulting Memorandum (4/16
Page 242: Stratus Consulting Memorandum (4/16
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