Before Minnow’s involvement, the Arctic mine conducted its own lethal sampling program to monitor tissue metal concentrations in fish, as a requirement under its environmental permit. This method involved using gill nets to capture and kill fish to gather the necessary data. When the MDMER were enacted, the mine turned to Minnow to conduct the EEM study as part of its new regulatory obligations. Minnow’s study revealed that the fish population was declining and would continue to sustain sampling-related impacts if the lethal sampling approach continued. Analysis of long-term annual monitoring data highlighted declines in fish length and weight as the larger, older fish continued to be removed from the system, while the population’s growth rate could not keep pace with this removal for sampling.

With EEM requirements demanding scientifically defensible, ongoing monitoring, the mine faced the dual challenge of fulfilling its regulatory obligations while protecting the health of a vulnerable fish population.