On May 24, 2002, MiningWatch Canada and the Pembina Institute wrote to Minister Anderson asking that mining be included in the National Pollutant Release Inventory or NPRI (under the Canadian Environmental Protection Act).

The NPRI is one of Environment Canada's most important programs. The Inventory provides communities with vital information on the sources of local pollutant releases and transfers that may affect their health and environment, allows governments, industry, non-governmental organizations and the public to identify key sources of priority contaminants, and to assess the impact of government, industry and community pollution prevention programs and initiatives.

Mining operations are currently exempted from reporting under the NPRI. This constitutes a serious gap in the NPRI reporting structure. Environment Canada has estimated that mining operations in Canada produce approximately 650 million tonnes of tailings and waste rock each year. In Canada, most of the base metals, precious metals and uranium occur in association with sulphur, and therefore these wastes are often subject to Acid Mine Drainage (AMD). It has been estimated that as of 1993 there were 700 million tonnes of waste rock and 1.8 billion tonnes of sulphide tailings in Canada, having the potential to cause AMD. AMD is associated with major and ongoing releases of metals to surface waters.

In addition to the generation of wastes with potential to generate AMD, certain types of mining operations, such as heap leaching, can lead to other types of major releases of hazardous and toxic substances into the environment. Mining operations are also a significant source of releases of critical air pollutants. Environment Canada estimated as early as 1980 that 63,000 tonnes of particulate emissions per year originated from mine tailings in Canada. Finally, coal and particularly oil sands mining are major sources of greenhouse gas emissions.

The exemptions from reporting for the coal and metal mining sectors were removed from the US Toxics Release Inventory (TRI), beginning in the 1998 reporting year. As a result, the metal mining sector in the US emerged as the largest source of total on-and off-site releases of TRI substances, constituting 51.2% of all releases reported in 1999.

These outcomes indicate that the exemption for the mining sector constitutes a major gap in the NPRI reporting structure, particularly with respect to on-site land releases, which may ultimately result in water pollution.

We are asking that given the scale of its potential contributions to releases and transfers of hazardous pollutants, criteria air contaminants and greenhouse gases, the exemptions from reporting for the mining sector should also be reviewed and removed for the 2003 reporting year.