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Le Comité communautaire de l’étude des sols de Sudbury soyez venu ensemble en 2008 en raison du public soucis avec processus et résultats de l'étude de sols de Sudbury Risque pour la santé humaine Évaluation. The Community Committee on the Sudbury Soils Study came together in 2008 as a  result of public concerns with the process and findings of the Sudbury Soils Study Human Health Risk Assessment.

Community Committee on the Sudbury Soils Study
c/o Joan Kuyek, Chair
joankuyek@sympatico.ca

August 31, 2009

The SARA Group
c/o Aecom Canada Ltd
512 Woolwich Street, Suite 2
Guelph ON  N1H 3X7

By e-mail: questions@suburysoilsstudy.com

Dear Sir or Madam:

Thank you for the opportunity to comment on the Ecological Risk Assessment.  The Community Committee on the Sudbury Soils Study engaged Environmental Defence Canada to help us respond to the ERA, and they, in turn, engaged Glen A. Fox to do the analysis for them. We have been pleased with the quality of Dr. Fox’s work and agree completely with his findings.

As a result, we have submitted his findings as ours, accompanied by his impressive CV.

We hope that the City of Sudbury, in particular, will pay attention to his findings, and ensure that any proposals for enhancing Biodiversity in the Sudbury Region take his recommendations into account. We believe that Dr. Fox’s findings make the need for further study obvious, and call on the Province and the City to ensure these additional studies are undertaken.

We especially want to note that the work undertaken by Sudbury scientists to fulfill the first Objective of the study – “ the extent to which the Chemicals of Concern are preventing the recovery of regionally representative, self- sustaining terrestrial plant communities”  is considered to be superb, by Dr. Fox, with the exception of severe limitations on the number of reference sites.

On the other hand, the wildlife assessment, undertaken by Intrinsic Environmental Services, is considered to be problematic. The lack of “ground-truthing” for effects on wildlife and the reliance on questionable modeling is similar in character to the Human Health Risk Assessment, and raises many of the same concerns.

The key findings in Dr. Fox’s analysis are the following:
 

• The weight-of-evidence suggests terrestrial plant communities in the Greater Sudbury area have been and continue to be impacted by the chemicals of concern (COC) in the soil and other factors such as soil erosion, low nutrient levels, lack of soil organic matter, and/or low soil pH.
• The validity of that conclusion hinges on the results from the 3 reference sites. Ideally, one would like an equal number (18) or twice as many reference sites as test sites. Further selecting a number of reference sites in an area with similar geological, botanical, and climatic characteristics would have allowed the possibility of separating the localized impacts of the atmospheric deposition of metals from the confounding influences of declining levels of acid precipitation, climate change, and other non-metal stressors.
• Assessment endpoints explicitly define characteristics or attributes that are important to protect and which are potentially at risk.  The chosen endpoint for terrestrial wildlife, population persistence, is inadequate as this may occur due to constant immigration. It is felt that the appropriate endpoint for terrestrial wildlife would have been adequate survival and reproduction to maintain a stable population.
• There are not accurate, real, or current measures for many of the variables required by the risk assessment model.  Of the 25 dietary “items” used in the risk assessment, 80% were estimated. All the inter-individual and interspecific variation in metal content that results from an individual food organism’s “taxonomy”, physiology, ecology, and behavior is eliminated. This reduces the confidence in the model conclusions.
• It is felt that the approach applied to the exposure assessment, which is the only site- and VEC-specific component of the risk assessment, compromised the risk assessment, making it difficult to say anything about the likelihood of adverse effects of a COC on any valued ecosystem component (VEC).
• The efforts of assessors’ to ground-truth conclusions using existing field information on reproductive success and population trends relied heavily on data that was anecdotal or qualitative. Quantitative data on ducks and loons suggest that numbers have responded positively to improved food resources and habitat quality that have accompanied reductions in acid deposition. However, whether or not adverse effects of metals pollution is limiting these increases in numbers and breeding success is unknown.
• The effect of the exposure to a “cocktail” of COC should be of concern. The cumulative impact of exposure to multiple chemicals and habitat quality plus potential frank or sub-lethal toxicity must be investigated.
• The problem formulation for a possible future detailed aquatic risk assessment highlights the lack of information on Sudbury-specific metal impacts on algae, macrophytes, invertebrates, additional species of fish, and amphibians. The marshes and wetlands have not been studied recently.  It is therefore difficult to determine if metals are having a significant deleterious effect on these populations directly or through reductions in food or habitat quality.

The Community Committee on the Sudbury Soil Study came together in the summer of 2008 as result of public concerns with the process and findings of the Sudbury Soil Study Human Health Risk Assessment.

The purposes of the Committee are:

• To ensure that the Sudbury public provides their informed consent for the risks to the environment and human health from historic and current mining and smelter activities, and determines effective response to those risks.
• To move the Ontario Government and its agencies to respond effectively to the Sudbury Soil Study findings. This response must ensure that contamination from mines and smelters in the Sudbury region is properly identified, remediated and (where it cannot be remediated) contained, and that those whose health might be affected (or may be affected) by contamination are provided with diagnosis, treatment and (where this is not possible) with compensation.

We hope that our submission will help the community understand and deal with the long-term impacts of mining and smelting on Sudbury Soils.

Yours truly,
 

Joan Kuyek, Chair