Summary of public comments received on the draft Federal Environmental Quality Guidelines for Lead
Comments on the Federal Environmental Quality Guidelines (FEQG) for Lead (Pb) to be addressed as part of the Chemicals Management Plan (CMP) were submitted by the International Lead Association, Red Cap Consulting, Mining Association of Canada, Alberta Environment and Parks, British Columbia Ministry of Environment and Climate Change Strategy, Nova Scotia Environment and Ontario Ministry of Environment, Conservation and Parks.
Summarized public comments and responses are provided below, organized by topic:
Topic 1: Editorial
| Summarized comment | Summarized response |
|---|---|
| Various editorial comments were received to improve the clarity and flow of the factsheet. | With the exception of comments related to the introduction section (e.g. how FEQGs are used and why they are developed via the FEQG forum), all editorial suggestions were incorporated into the factsheet. More details, such as what are FEQGs, why and when they are developed and how they differ from CEQGs are available online. |
Topic 2: Data updates
| Summarized comment | Summarized response |
|---|---|
| Update data for Canada’s position as lead producer and supplier to global market. | Suggested data have been updated using the latest information from Natural Resources Canada. |
| Include lead monitoring data for British Columbia in Table 2. | Monitoring data provided by British Columbia have been included in Table 2. |
| Include additional freshwater lead toxicity studies that reviewers identified and re-evaluate acceptance of specific studies for deriving the FWQG for lead. | Identified toxicity studies were evaluated and the toxicity dataset was updated. The updated FWQG is now based on 28 species instead of 16 species. |
| Provide more details on geomeans and include both reported and normalized effect concentrations in Table 4. | Geomean details and reported and normalized effect concentrations are provided in updated Table 4. |
Topic 3: Methodology
| Summarized comment | Summarized response |
|---|---|
| Instead of a single species MLR (multiple linear regression) approach used by the ECCC, a pooled MLR approach that combines data for all species in a single MLR model is recommended for guideline derivation. | A pooled MLR method is now considered using invertebrates and fish data. Pooled MLR approach has provided a more robust model as well as it extends the ranges of input water chemistry for deriving the site-specific water quality guideline for lead. |
| Use Species Sensitivity Distribution (SSD) approach that applies maximum likelihood and model averaging instead of SSD Master. | A R-based SSD tool that fits five models using maximum likelihood estimation (MLE) is now considered. |
| Why was the biotic ligand model (BLM) for lead not considered? | ECCC is aware of the BLM approach and ongoing developments. ECCC used the pooled MLR approach (recommended by reviewers’) because it considers important toxicity modifying factors, is transparent and user-friendly, considers the most up-to-date toxicity data, and meets CCME guiding principles with respect to protection of aquatic life. |
| Provide a calculator for calculating guideline. | An Excel based calculator has been developed and added as an appendix to FEQG factsheet. |
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