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Letter to ECCC Regarding Proposed Coal Mining Effluent Regulations

February 28, 2022

Click the link below to view AWA’s letter submitted to the Environment and Climate Change Canada (ECCC) on February 28 outlining our concerns with ECCC’s proposed approach for coal mining effluent regulations scheduled for implementation in 2023.

After reviewing the discussion document as well as participating in the February 16th Info Session hosted by ECCC, we have significant concerns with the regulations being proposed for implementation under the Fisheries Act, which are summarized in the list below, and outlined in greater detail in our letter.

Summary of Concerns:

  1. ECCC should continue to prohibit the deposit of coal mining effluent indefinitely until Industry can ensure water quality is equal to or greater than in the receiving watershed;
  2. Limits and thresholds need to be science-based and ensure the protection of water quality and ecosystem health – not based on what is practical or feasible for Industry;
  3. Revised limits and thresholds need to apply to all mines, including those currently operating or currently under development; and
  4. ECCC needs to consider both the downstream and cumulative effects of these Proposed Regulations as opposed to solely focusing on end-of-pipe concentrations of deleterious substances as currently proposed.

We hope to see these concerns addressed in the next set of revisions for the Proposed Regulations scheduled for publication in the Canada Gazette at a future date in 2022.

View the full letter at the link below.

20220228_lt_awa_eccc_proposed_cmer

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