Collaborative Moose Health Monitoring Program: Expanding the scope of traditional risk assessments to include country foods.
Abstract
In response to the rapid rate of multiple natural resource developmentsin British Columbia (BC) First Nations across the province are raising concern of the health and safety of traditional food or ‘country food’ sources.The concern and uncertainty created by the highly variable requirements for measuring impacts of resource developments has lead to a backlog of requests by BC First Nations to monitor country foods.Furthermore, a progressive approach to environmental assessment of mines in BC includes the implementation of a program to monitor country foods. However, neither provincial nor federal impact assessment specifically addresses the concern of country foods. Such monitoring programs can also be incorporated into Impact Benefit Agreements, which have become an important social tool for mining companies working on or near aboriginal lands. New Gold, a mid-tier mining company, has implemented a ‘Country Food Monitoring Plan’ as part of an application for an environmental impact assessment of the proposed Blackwater Mine in Central BC. In particular, moosewere identified by First Nations near the proposed project as a ‘country food’ of primary concern. This paper describes a unique collaboration of a mining company with the cooperation of First Nations communities and resident hunters, guide/outfitters, and is supported by wildlife veterinarians and biologists to develop and implement a moose health monitoring program. The goal is to establish a baseline database of moose health in order to facilitate an ongoing, community based monitoring program that can provide assurance to First Nations that this key food source remains viable throughout the entire life cycle of the Blackwater Mine.
INTRODUCTION
In British Columbia (BC) the rapid rate of multiple natural resource developments has amplified concern of the health and safety of country foods (those harvested through hunting, gathering or fishing activities[i].First Nations in BC haveraised concern over mine development. Untended concerns voiced by the ?Esdilagh Nation regarding impacts of the Gibraltar Mine triggered an independent Health Impact Assessment (personal communication, Janis Shandro, Population Health Specialist, 2015). As well, the Mount Polley Tailings Dam Breach in August, 2014 triggered an environmental impact assessment that includes addressing concerns by First Nations of potentially affected country foods [ii]. Concern of the health and safety of wildlife in the face of this rapid extractive industry/ mining development coupled with the environmental disaster of Mount Polley has resulted in a backlog of requests by BC First Nation communities to assess and monitor traditional wildlife food sources [iii]. For Aboriginal people, hunting and the consumption of country food contributes to cultural and social well being as well as food security (Aboriginal Affairs and Northern Development Canada, 2015). Indeed, Aboriginal peoples of BC may well have just cause to be concerned about their food security.
Astudy on First Nations food and nutrition in BC reported food insecurityto affect 41% of First Nation households living on reserve[iv]. Since diet quality is improved when traditional foods are consumed, the report recommends a return to country foods.
The concern of the health and safety of country foods is compounded by an uncertainty created by the highly variable requirements for measuring impacts of resource developments.Additionally, there is limited guidance available with respect to the sampling and analysis of country foods. Neither provincial nor federal impact assessments of mines address specifically how concerns about country foods should be considered(personal communication, Steve McNaughton, BCEAO, November, 2015). Typically, country foods are assessed using a multi-pathway exposure model of human health risks related to contaminated sites (Health Canada, 2010).However, this assessment is inadequate as country food safety is analyzed in terms of exposure to Chemicals of Potential Concern (COPC), which only narrowly addresses Aboriginal concerns regarding ‘health’.Given the significance of country foods to First Nations and that the success of a mine permit application can hinge on the perceived support of local communities; there is ample justification for improved integration of country foods into the assessment process. Moreover, a progressive approach to assessment of mining projects in BC would include the account and monitoring of country foods.
New Gold Inc., a mid-tier mining company,has applied for an Environmental Assessment Certificate to develop the Blackwater Gold Project. The proposed project, located in central BC, will be a major open pit gold and silver mine with ore processing facilities [v]. The project triggered an environmental assessment requiring independent, yet coordinated provincial and federalreviews beginning January, 2016.[vi].
As part of the assessment, New Gold has implemented a Country Foods Monitoring Plan (CFMP) to determine if project activities generate effects to country foods (Amec Foster Wheeler, 2014a). The CFMP report describes the design and sampling program to track changes in metals concentrations for select species of indicator species that could act as pathways for contaminant to people. The report notes that, while not included within the CFMP, moose should also be sampled since they are an important food source to First Nations. The report indicates that studying such a mobile species is difficult and that further consultation and research is needed to develop a plan to monitor moose. Furthermore, New Gold resolved to incorporate a proposed monitoring plan for moose [vii]. In particular, a plan to monitor Moose was specifically requested the Lhoosk'uz Dene Nation (LDN), one of the potentially mine affected First Nations communities.
This paper describes a unique collaboration of New Gold with the cooperation of the LDN community, along with hunter guide/ outfitters, andsupported by wildlife veterinarians and biologists to develop and pilot the implementation ofacollaborative moose health monitoring program(CMHMP). This collaborative initiative highlights a scenario where the traditional approach of the mining industry to evaluate a project is challenged to incorporate a broader, more interdisciplinary approach to environmental assessment. The ultimate goal is toestablish a moose health database via the implementation of a community based monitoring program that will provide information to First Nations and others on moose health and any potential threats to humans throughout all stages of the Blackwater Mine.
A desired outcome of this research is for the framework developed for the CMHMP to be used as a reference or planning tool for the mining industry to incorporate country food monitoring programs into impact assessments of mine development. Currently, the BC First Nations Energy & Mining Council is at the formative step with the BCEAO in defining how to proceed on amending, or repealing and replacing, the Environmental Assessment Act[viii].Thisresearchmay be used to help modernize the environmental assessment process with a framework that specifically addresses the concern of the health and safety of country foods.
This paper describes the CMHMP which was developed with a literature review of existing country food/ moose monitoring programs monitoring programs and protocolsas well as via consultation and personal communication with experienced implementers and coordinators of these programs.The proceeding discussion seeks to provide a framework to inform how such a programcan be implemented as well as integrated into the environmental assessment process. Realities of the CMHMP are discussed in turn to provide context and present some of the intricacies and challenges of implementation.
The data generated by a country foods study represent just one component of a larger human health risk assessment that often involves multiple exposure pathways[ix].
Yet, special attention to country foods is stipulated given their cultural, spiritual and dietary importance to Aboriginal people.
Environmental assessment also provides key information for designing and appending negotiated agreements, such as Impact Benefit Agreements (IBAs), with First Nations communities. Country food monitoring programs may be incorporated into IBAs. Noble and Birk (2011) examine the potential benefits of linking such agreements and associated monitoring programs with environmental assessment-based follow-up practices to improve community engagement and project effectiveness[x]. When follow-up of these programs is solely defined within the framework of negotiated agreements they risk becoming ‘comfort monitoring’ programs whereby community-industry relations are improved but effects-based management is neglected. To maximize credibility of follow-up under these agreements, Noble and Birk suggest that results from monitoring programs are integrated with regulatory-based monitoring and project impact management practices.
A theoretical framework can provide a guide for implementation of a country food monitoring program. Realities on the ground described abovefor the CMHMP, however, point to the needfor flexibility during implementation. Despite the importance of country foods, competing priorities within Aboriginal communities entail that adhering to this theoretical framework is not always possible. What at first appears to be a study focused on wildlife, takes on characteristics of a social experiment where the needs, desires and interests of everyone must be considered to facilitate a collaborative approach. In the LDN, socio-economic priorities along with budgetary limitations and overburdened band administration are examples of challenges that required a rework of expectations for this monitoring program. Often the expectations and timelines of a researcher or mine proponent trying to advance a project may not mesh well with those of a First Nations community. Taking the time to form relationshipswith both band managers and community members that foster mutual respect and understanding is crucial. Without well formed relationships the collaborative backbone of this framework is weak and a monitoring program may be faced with a lack of buy in, enthusiasm and ultimately lack of participation by community members.
The ultimate objective of these monitoring programs is to determine the health and safety of country foods in the face of resource developments such as mining. If risks associated with the consumption of country foods are identified, data gaps and uncertainties should be further explored. In particular, in cases where deficiencies in sampling design inhibit interpretation of results, or where data are deemed to inadequately represent a community, additional sampling should be conducted.
CONCLUSION
Assembly of First Nations National Chief, Perry Bellegarde, suggests that we should go one step further to considering whether natural resource projects not only have a SLTO, but an "Indigenous License" where FN involved at every step in the process and that includes an indigenous perspective (i.e. we’re all connected clean air, water, environment)[xi]. Perhaps the CMHMP can be seen as a model or even necessary step towards obtaining an Indigenous license for future proposed mine developments in Canada.
This research provides an example of a bold initiative bya mining company that calls on multiple disciplines to develop a country foods monitoring program that is meaningful to First Nations communities nearby a propose mine. Unconventionally, veterinarians have been invited to contribute towards the environmental assessment of the project by helping to formulate a more robust wildlife health and country foods monitoring program. This model of collaboration represents new opportunities for advancing the scope and relevance of the environmental assessment process within the design and planning for future sustainable mineral development.
Amec Foster Wheeler. “Blackwater Gold Project, British Columbia: Project Description Summary.” Prepared for New Gold Inc., October 2012.
———. “Draft Application Information Requirements: Comments From Aboriginal Groups.” Prepared for New Gold Inc., May 9, 2014.
British Columbia Environmental Assessment Office. “Mount Polley Mine Tailings Breach: Environmental Mitigation and Remediation Progress Report: End of Phase I.” Government of British Columbia, July 2015.
———. “Project Information Centre (e-PIC): Blackwater Gold Project,” January 12, 2016. http://a100.gov.bc.ca/appsdata/epic/html/deploy/epic_project_home_390.html.
CBC Radio program: the House. “Projects Need Indigenous License,” February 13, 2016.
Chan, L., O. Receveur, D. Sharp, H. Schwartz, A. Ing, and C. Tikhonov. “First Nations Food, Nutrition and Environment Study (FNFNES): Results from British Columbia (2008/2009).” Prince George: University of Northern British Columbia, 2011.
Emery, A.R. “Guidelines: Integrating Indigenous Knowledge in Project Planning and Implementation.” Prepared by KIVU Inc. for the World Bank and the Canadian International Development Agency, 2000.
Forgarassy, Tony. “Personal Communication.” Lawyer and First Nations and environmental assessment consultant, December 1, 2015.
Gauthreau, Neil. “Personal Communication.” Lhoosk’uz Natural Resource Manager, 2015.
Government of Alberta. “Best Practices Handbook for Traditional Use Studies.” Ministry of Aboriginal Affairs and Northern Development, Alberta, 2003. http://www.aand.gov.ab.ca.
Government of Canada. “Canadian Environmental Assessment Act, 2012,” 2012.
Health Canada. “Federal Contaminated Site Risk Assessment in Canada: Supplemental Guidance on Human Health Risk Assessment for Country Foods,” 2010.
Larter, Nicholas C. “A Program to Monitor Moose Populations in the Dehcho Region, Northwest Territories, Canada.” Alces: A Journal Devoted to the Biology and Management of Moose 45 (2009): 89–99.
Linnell, Jim, and John Blackwell. “Personal Commuication.” BC Guide Outfitter Association, 2015.
Noble, Bram, and Jasmine Birk. “Comfort Monitoring? Environmental Assessment Follow-up under Community–industry Negotiated Environmental Agreements.” Environmental Impact Assessment Review 31, no. 1 (January 2011): 17–24. doi:10.1016/j.eiar.2010.05.002.
Schwntje, Helen. “Personal Communication.” Wildlife Veterinarian, British Columbia Ministry of Environmentment, Forest, Lands and Natural Resource Operations, 2015.
Tobias, T.N. “A Guidebook to Land Use and Occupancy Mapping, Research Design and Data Collection.” Published jointly by the Union of British Columbia Indian Chiefs and Ecotrust Canada, 2010.
“Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans.” Government of Canada, 2014.
[i]Health Canada, “Federal Contaminated Site Risk Assessment in Canada: Supplemental Guidance on Human Health Risk Assessment for Country Foods,” 2010,
[ii]British Columbia Environmental Assessment Office, “Mount Polley Mine Tailings Breach: Environmental Mitigation and Remediation Progress Report: End of Phase I” (Government of British Columbia, July 2015).
[iii]Helen Schwntje, “Personal Communication” (Wildlife Veterinarian, British Columbia Ministry of Environmentment, Forest, Lands and Natural Resource Operations, 2015).
[iv]L. Chan et al., “First Nations Food, Nutrition and Environment Study (FNFNES): Results from British Columbia (2008/2009)” (Prince George: University of Northern British Columbia, 2011).
[v]Amec Foster Wheeler, “Blackwater Gold Project, British Columbia: Project Description Summary” (Prepared for New Gold Inc., October 2012).
[vi]British Columbia Environmental Assessment Office, “Project Information Centre (e-PIC): Blackwater Gold Project,” January 12, 2016, http://a100.gov.bc.ca/appsdata/epic/html/deploy/epic_project_home_390.html.
[vii]Amec Foster Wheeler, “Draft Application Information Requirements: Comments From Aboriginal Groups” (Prepared for New Gold Inc., May 9, 2014).
[viii]Tony Forgarassy, “Personal Communication” (Lawyer and First Nations and environmental assessment consultant, December 1, 2015).
[ix]Ibid.
[x]Bram Noble and Jasmine Birk, “Comfort Monitoring? Environmental Assessment Follow-up under Community–industry Negotiated Environmental Agreements,” Environmental Impact Assessment Review 31, no. 1 (January 2011): 17–24, doi:10.1016/j.eiar.2010.05.002.
[xi]CBC Radio program: the House, “Projects Need Indigenous License,” February 13, 2016,