Summary of public comments received on the draft federal environmental quality guideline for aluminium

Comments on the draft Federal Environmental Quality Guideline for Aluminium by the Alberta Ministry of Environment and Parks (AEP).

Summarized public comments and responses are provided below, organized by topic.


Summarized comment Summarized response
Editorial comments related to formatting and repeated text All editorial suggestions were accepted and edits made.


Summarized comment Summarized response
Is it possible to identify aquatic ecosystems where the Federal Water Quality Guideline (FWQG) will likely not apply? This is outside the scope of Federal Environmental Quality Guidelines (FEQG) factsheets. Information on the acceptable water chemistry ranges, guidance on extrapolating outside these ranges, as well as a note to consider site-specific objectives are provided.
It may be useful to conduct an independent statistical review of the multiple linear regression (MLR) approach. The MLR approach is not new, having been used in several previously published guidelines and by many jurisdictions. The Al MLRs have been published in two peer reviewed journal articles (DeForest et al. 2018, 2020). In addition, the United States Environmental Protection Agency (US EPA) conducted an independent statistical review for use of the aluminium MLRs in their ambient water quality criteria (AWQC). ECCC has reviewed all available resources and concluded that the MLR approach is valid for use in the Al FWQG.
Are the differences between the US EPA AWQC and the FWQG for Al understood? The US EPA AWQC (US EPA 2018) was consulted for the derivation of the Al FWQG and the various differences in approaches by the two jurisdictions are generally understood. The two jurisdictions differ in general guideline derivation methods, which includes differences in species sensitivity distribution approaches, data acceptability, and preferences for EC10/ EC20 values. In addition, the two jurisdictions used slightly different Al MLRs that retained different terms with different slopes.
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