Environmental Impact Assessment of Uranium Mining on Indigenous Land in Labrador (Canada): Biases and Manipulations

Abstract

Studies in Canada reveal the entrenched nature of the nation's mining paradigm that fundamentally undermines the interests of Indigenous peoples. However, very few research studies have explored the hidden biases and manipulations in the process of framing the Environmental Impact Assessment (EIA) of mines, particularly if developed on Indigenous land. The objectives of the study were to explore what biases and manipulations played roles in framing the EIA of uranium mining on Indigenous (Inuit) land in Labrador (Canada). The study analyzed all the archived documents (print and audio/video) related to the EIA process of the Kitts–Michelin project in Labrador (Canada). The EIA of the Kitts–Michelin project was poorly designed, with ill-planned public dissemination. The study demonstrates how hidden biases and manipulation in the entire process of EIA have served the purposes of certain interest groups and willfully neglected community concerns. The analysis of EIA reveals the institutionalization of biases and exclusionary processes and also exposes institutional racism that is running much deeper than merely prejudice. Although Inuit representatives attended the environmental review panel hearings, the decision makers were predominantly non-Indigenous (external consultants and members of the EIA review panel) and the final decision makers were always non-Inuit (and not local). The study shows that in-depth analysis of existing EIA along with the unpublished documents and audio and video records of panel hearings can provide a comprehensive understanding of racial, social, and environmental inequities associated with historical mining activities in Canada's Indigenous territories.

Introduction

Indigenous peoples in Canada experience disproportionately high levels of environmental risk due to mining activities. Since the majority of mines are located in and around the lands that belong to the Indigenous communities, any adverse outcomes of environmental hazards harm them first. Thus, the Indigenous communities encounter disproportionately higher burden of fallouts in terms of adverse health impacts, loss of livelihood, culture, and displacement.¹ The Indigenous communities essentially blame lack of power—including resources, skills, capacity, and political clout for the existing environmental racism.²

Environmental Impact Assessment (EIA) is an essential process before the decision to move forward with any proposed mining activity. EIA is conducted to predict any adverse or beneficial effects of mining proposals on the physical, biological, and human environment; ensure public discourse on a project; and develop monitoring programs, mitigation measures, and remediation plans.³ Since EIA is a multistakeholder initiative, ideally, its final approved version is expected to satisfy the aspirations of all the participants of the process.

However, there are numerous examples of public outrage ranging from peaceful civil disobedience to violent protests against unacceptable terms and conditions and unresolved contentious issues, even after the formal approval of EIA of any proposed mining by the regulatory authority. Rather, it seems that several stakeholders have different interests, expertise, and positions in the power hierarchy (imbalance) leading to bias and/or the manipulation of EIA.⁴ Unfortunately, for mining in the Indigenous land, biases and manipulations of EIAs have been more frequent. Furthermore, in the context of Indigenous communities and their ancestral land, follow-up to EIA, that is, monitoring, evaluation, management, and communication, remains the weakest in all jurisdiction where EIA is practiced.⁵

Usually, the development of EIA focuses on a single set of decision that is, to get approval of project and the conditions attached to it. Since after gaining approval of EIA, the concerned panel and committee or commissions are disbanded, there is little scope for focusing on decision on ongoing environmental management throughout the life cycle of a mine.⁶ The most important issue is active participation of Indigenous peoples in decision making, not merely making presence in the hearing panel or affording them an advisory or titular role.⁷ However, there is limited literature that adequately addresses the hidden biases and manipulations in the process of formulating EIA and its follow-up, particularly in the context of mining in the Indigenous land.

The article focuses on the chronology of the development of EIA of the Kitts–Michelin project, located on the Indigenous land of northern Labrador of Canada, its critical review and community responses and finally the fate of the mining project. The study was based on analysis of archival documents (1975–1980) related to the EIA process of the uranium mining. The printed materials were available at the Centre for Newfoundland Studies and Labrador Institute Library, Memorial University of Newfoundland, Canada. Six videos (CD) recorded in 1977 containing discussions with the community members, ministers, and company officials, as well as public hearings were also viewed.⁸

Results

The Central Mineral Belt is the most abundant source of uranium mineralization in the province of Newfoundland and Labrador (NL) in Canada.⁹ In 1953, the Government of NL permitted the British Newfoundland Development Corporation or Brinco to survey Labrador for uranium deposits as part of a long-term exploration lease between industry and government¹⁰ (Fig. 1). The first significant uranium discovery was made at a location near Kitts Pond. Upon this discovery, Brinco developed an exploratory division of the company, British Newfoundland Exploration Limited (Brinex), to conduct a feasibility study on the Kitts and Michelin site. The site was assessed through surveys, financial projections, and preliminary mining, and it was determined that the deposit was a small but rich source of uranium.¹¹

FIG. 1.

Kitts–Michelin deposits, Labrador Inuit land, and Inuit communities (adapted from Google map).

After the discovery of the substantial ore bodies from the Kitts and Michelin deposits, Brinex proposed the construction of a uranium mining and mineral concentrating facility in Labrador, near the Inuit communities of Makkovik and Postville (Fig. 1). It was estimated that the facilities would employ ∼300 people.¹² In accordance with the mining rate projected for the sites, it was estimated by Brinex that the joint Kitts–Michelin project would yield 1.3 million pounds of uranium oxide per year for 15 years.¹³

For the mine to function at its greatest capacity, Brinex recognized the many support facilities that would be necessary. For example, support facilities for the proposed mines and mill site would include a deep water dock and float-place dock; shops and warehousing; substantial power and water supply for mining, milling, and auxiliary purposes; tailings disposal and control; sewage treatment and disposal; and living accommodations equipped with services and amenities for the workforce. In addition, transportation between the sites would be possible through the recommended all-weather road.¹⁴ Brinex proposed that the operational workforce for the mines and mill be drawn from local communities and other areas within the province.

Project feasibility assessments and environmental studies

In 1973, during the developmental stages of the Kitts–Michelin project, the Government of NL was in the process of drafting legislation requiring the submission of an environmental study and impact statement for all the key developments. The purpose of these environmental studies and assessments was to evaluate the existing environment, establishing a baseline condition; to identify project concepts, and indicate how the surrounding environment would be affected by the project; to outline costs and benefits associated with the development; and to describe mitigation plans to prevent or reduce adverse impacts.¹⁵

Throughout the duration of the development in Labrador, Brinex contracted various consulting firms to evaluate the project site and proposal. In 1979, after a review of development alternatives and a discussion with government officials and public representatives, it was decided that project development at the Kitts–Michelin site would proceed and the entire operation would be contained locally in Labrador.¹⁶

Environmental impact assessment

The EIA was based on the studies conducted and information collected by Beaks Consultants Ltd.¹⁷ The EIA incorporated the area of the project site, which was composed of exposed bedrock, soils, lake and sea water (solids, nutrients, and trace metals), wetlands, and vegetation. The EIA also described the presence of both terrestrial and aquatic animal populations at the Kitts–Michelin site. Concerning aquatic life, a low level of biomass and species diversity was observed. There were relatively few birds (Canadian geese, ducks, and seabirds) present in the study area and no significant concentrations of furbearing mammals (caribou) were observed in the project area.¹⁸ Therefore, as per this EIA, land animals would not be affected by the project. According to the EIA, numerous marine mammal species were present in Kaipokok Bay; therefore, the bay was classified as a sensitive environment.

However, the EIA stated that the Kitts–Michelin project was not expected to affect the physical or chemical composition of Kaipokok Bay due to its substantial distance from the mining sites. The EIA also described two communities neighboring the Kitts–Michelin site, Postville, and Makkovik. The communities consisted of 189 and 325 residents at the time of the study, and were described as mainly Settler and Inuit. Hunting, trapping, and fishing were also described to be important activities of the community. According to the EIA, the proposed Kitts–Michelin project would have a minimal effect on the local ecosystems, affecting the geology (essentially surface disturbances), water and air quality, and plant and animal life.

In addition, the local communities would benefit, both socially and economically (job creation). Also, the access road was expected to be beneficial to the area, increasing the opportunity for further mineral exploration. Finally, the report indicated that the production and operation of the Kitts–Michelin project would follow the best identified industrial practices and that the risks associated with radiation were expected to be minimal due to the precautions taken through planning, education, and compliance with regulatory agencies.¹⁹

Criticism of the EIA

Throughout the progression of the Kitts–Michelin project, many local agencies voiced concerns opposing the project development. Once the EIA was complete, public hearings were conducted by the Environmental Assessment Board for the Kitts–Michelin project in various communities of Labrador.²⁰ It was during this hearings panel that individuals and organizations presented the potential negative impacts of the project as well as the shortcomings of the EIA and Brinex in general (Table 1).

Table 1.

The Shortcomings of Environmental Impact Assessment of Kitts–Michelin Project

	Shortcomings
1.	The Brinex report was highly inadequate, too complex, using statistical figures and biological terms, thus making it highly inaccessible to the average person and preventing local input.^a
2.	Many statements within the report concerning wildlife were identified to be inaccurate. For example, the general claim was made that the mine development would not impact local wildlife or related activities such as trapping, hunting, and fishing. However, the LRAC indicated that many local traplines were already affected by the preliminary work completed at the project site.^a
3.	EIA lacked an assessment of the impact on the social environment within communities, and there was a general feeling that the interests of the residents were not protected. The number of jobs created by the project was likely overestimated due to the incorrect use of models and projections by the consultants, and it was not clear how many jobs would be made available to local residents. The number of indirect jobs created was calculated based on the proportion of regional purchases of goods. Many of the goods required for the project were not produced in the local area; thus, other parts of Canada or the United States would be the beneficiaries of the created jobs.^b
4.	Brinex was also undermining the merit of the environmental study by constructing roads before the approval of the project's EIA, completely disregarding the purpose of the environmental study.^c
5.	At the time of the Brinex development, there was only one environmental inspection officer assigned to the entirety of Labrador, and this officer was permitted only two trips to Labrador annually. The LRAC suggested that to monitor activities at the Kitts–Michelin site, or any future developments, a full-time environmental officer was required.^a
6.	In the policy statement presented by the LRAC, it was recognized that the government appeared to have limited power in monitoring the activities of Brinex, and that legislation had been passed in 1953 giving Brinex control of the development. Therefore, it was suggested that the legislation be renewed to give the province more control over the company's activities. In addition, the LRAC thought it was imperative that a member of the Atomic Energy Control Board sit on the Environmental Assessment committee for the Kitts–Michelin project, and that the board would be able to exercise its legal authority to mandate full-scale public hearings in Labrador, so the advantages and disadvantages of the project could be more closely examined.^a It was this suggestion by the LRAC that eventually led to the public hearings for the Kitts–Michelin project in December of 1979.^a
7.	The LIA, an organization formed in 1973 to promote culture; improve health and well-being; and to protect the constitutional, democratic, and human rights of the Inuit people, presented a submission to the environmental hearings panel. The credibility of the EIA presented by Brinex was the primary concern identified by the LIA during the hearing. The LIA indicated that the report was not independently complete, and instead relied on supporting documentation (LIA and Sweetnam 1979). It was also a concern that the EIA document was not made available to the public until 1 day before the review process. This delay by Brinex prevented the preparation of sufficient project evaluation or criticism. Both the government and Brinex confirmed that the EIA presented was not the final version of the document. This gave the company leeway to continually change the information presented, thus making it difficult to establish current and exact information regarding the process, again, making the project difficult to examine and critique.^d
8.	The LIA indicated that they firmly opposed the project on the grounds that the EIA was not adequate, the research and methodology used were not “academically sound,” and that a final decision should not be made concerning the project until a final version of the EIA was available and additional hearings were commissioned.^d
9.	The Labrador Institute (established by Memorial University of Newfoundland, for research, education, policy, and outreach in the Canadian Arctic/Sub-Arctic North) also questioned the merit of the EIA during the hearings panel, as representatives from the institute indicated that there was not adequate evidence presented in the EIA to support requests by Brinex to approve the Kitts–Michelin project. It was concerning that the EIA included little qualitative and quantitative data on local soils, terrain, vegetation, water quality, fisheries, wildlife, or social conditions. Baseline data were not presented for the previously mentioned parameters; therefore, any predictions made in the EIA were poorly founded.^b
10.	Biomagnification of heavy metals and radio-nucleotides as a health issue was not addressed in the EIA, aside from the acknowledgment that the process was a complex mechanism; no concrete estimates or quantifications of dilution or dispersion, biological uptake, or radioactive decay were given. In addition, the EIA indicated that fish spawning grounds may be disrupted by project activity and it was suggested that the negative impact should be minimized (i.e., “exceptional care should be taken”); however, no specific strategies were mentioned to avoid potentially negative effects. The medical implications of long-term exposure to ionizing radiation were not discussed in the EIA. According to the EIA, the radiation levels of the project were expected to be far less than background radiation levels and would meet government standards.^b
11.	No long-term impacts of tailings disposal or management strategy were discussed, and it was recommended by the institute that similar mining developments be studied to determine best practice for disposal.^b
12.	Another potential source of pollution was the sulfuric acid used during the yellow cake production at the mill. In project documentation, the construction of the sulfuric acid plant was discussed; however, the impact of such a site was not discussed in the EIA.^b
13.	According to the Department of Wildlife at the time of the development, caribou was identified to be possibly the most important wildlife species inhabiting the Kitts–Michelin area, and its meat was considered traditional food for the Inuit population. Historically, caribous used the proposed project site and it is likely that they would continue to use the site in the future. The EIA did not provide any specific information regarding the impact on the caribou population other than claiming that the population or other furbearing mammals would likely not be affected by the project. Again, in this case, no baseline data were provided, making realistic impact assessment difficult.^b
14.	In addition, a list of bird species “likely” present in the area was reported. This identification was done based only on bird songs observed in the area, and information was presented in general terms such as “low,” “moderate,” and “high” populations with no statistical reference point noted to indicate the magnitude of the proposed impact on the bird populations.^b
15.	In light of the many issues outlined by the institute, it was concluded that sufficient time was not dedicated to the EIA study and baseline data were not provided, preventing predictions and potential impacts from being adequately determined. According to the representatives of the institute, the biological and socioeconomic environments were jeopardized by the project and, therefore, the institute suggested that the EIA and the project should not be accepted in their present state.^b Overall, the EIA was implicitly biased in favor of the development and was not accessible to the general population.^b,e

LRAC, and Sharpe, I. 1976. Policy statement. Labrador: the Council. Labrador Resources Advisory Council (Unpublished material. Available at Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University, NL). (LRAC was set up in 1976 to promote Labrador's interest with natural resources.)

LINS. 1979. Submission to the environmental hearings panel, Kitts–Michelin project. December 3. Submitted to Kitts–Michelin Environmental Assessment Board by J Rowell, Labrador Institute of Northern Studies, Memorial University of Newfoundland. (Unpublished material. Available at Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL).

Kilborn Ltd. 1979. Preliminary site evaluation report in support of an application for approval of the proposed sites for waste management facilities at the proposed Michelin mine-mill and the proposed Kitts mine for Brinex limited, Labrador. Mississauga, ON: Brinex Ltd.

LIA, and Sweetnam, R. Kitts–Michelin Environmental Assessment Board. 1979. A summary report to the environmental hearings panel, Kitts–Michelin project. Nain, NL. Labrador Inuit Association (Unpublished material. Available at Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University, NL).

Kennedy, J.C., and House, J.D. 1979. A report on the proposed Brinex Kitts–Michelin uranium project in Labrador. (Unpublished material. Available at Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL).

EIA, Environmental Impact Assessment; LRAC, Labrador Resources Advisory Council; LIA, Labrador Inuit Association.

After concluding the hearings and assessments, the board clearly stated that

In our judgement the potential gain is not worth the risk and we recommend that the development license for the Kitts–Michelin project be withheld until Brinex can show that it can and will safely and permanently dispose of the radioactive waste from its proposed mines and mill. ²¹

One month later, the provincial government accepted the board's recommendation to withhold the project.²² Eventually, development at the Kitts–Michelin site permanently stopped in the 1980s when the market price of uranium dropped. Strong objections from the neighboring communities of Makkovik and Postville due to environmental concerns and their exclusion from project planning likely also had a significant effect on the decision by Brinex to conclude the project.²³

Discussion

The study shows that in-depth analysis of existing EIA along with the unpublished documents and audio and video records of panel hearings can provide a comprehensive understanding of racial, social, and environmental inequities associated with historical mining activities in Canada's Indigenous territories. It reveals the institutionalization of unconscious biases, exclusionary processes, and normative judgments that influence racially meaningful social structures acknowledged in environmental justice discourse.²⁴

A systematic analysis of the different forms of manipulation of the EIA shows that the stakeholders (such as project developers and EIA consultants) adapted multiple strategies, such as false information, false alternatives or unnecessary elements, exaggerated information, withholding information, undervaluing or overvaluing impacts, presenting information in a confusing or complex manner, self-censorship, administrative manipulation of the EIA process, bribes and kickbacks, and extortion. For example, project developers always have a personal interest in a favorable EIA, and they will be tempted to shortcut by manipulation and do not usually favor public participation.

Since, EIA process is based on prediction and anticipatory judgment, the assessment depends on EIA consultants' experience and expertise, which may lead to professional bias. In contrast, EIA consultants work for project developers and so this is a cause of concern about their independent functioning and decision making. In fact, any form of conflicts of interest and pressure from project developers are prone to abuse the EIA.²⁵ However, accusing any stakeholder/s of manipulation is difficult to prove without credible evidence. Regrettably, the conceptual blend of perspectives from environmental justice and political ecology has not found any space in sustained scholarly dialogue in the discipline of environmental health.²⁶

Environmental justice laws and policies frame Indigenous population as racial minorities and environmental justice can be a faulty tool for them that can have adverse impacts. The Louden Tribal Council of Alaska (USA) faced contamination of subsistence resources by the Department of Defense and loss of land rights. The tribal governments constantly encountered the federal government and non-Indigenous denying their rights to self-governance. By identifying the case as an environmental justice issue, tribes were addressed from a race point of view and denied their power as semi-sovereign governments. Reliance on an environmental justice policy framework instead of a government-to-government relationship has resulted in negative environmental and sociocultural impacts.

There were past instances in several U.S. Supreme Court cases, reaffirming Indigenous rights and institutions based on their historical political status, not race. Furthermore, if the Indigenous population in United States were simply defined by their race and not their political status, the programs and benefits they retain could be denied. In fact, with regard to environmental justice, differential treatment of Indigenous and other communities in federal law is constitutionally permissible. Authorizing Indigenous communities that are involved in the environmental justice movement, to be treated in the same manner as states, makes them fundamentally different from other kinds of minority communities. Therefore, while using the environmental justice framework, defining Indigenous peoples of North America by their race (not their political status) is inapposite with respect to tribal goals of environmental self-determination.²⁷

The study demonstrates that how hidden institutional racism, biases, and manipulation in the entire process of EIA has served the purposes of some interest groups, such as the mining company and the consulting farms and they willfully neglected community concerns. Limited capacity of the government regulatory authority and lack of adequate number of staff eventually gave Brinex more power for mining development resulting in unintended consequences. The EIA of the Kitts–Michelin project in Labrador and the detailed analysis of supporting documents show that even in a country such as Canada, which is known as having a well-established regulatory system, a poorly designed EIA with deliberately ill-planned public dissemination and manipulation can be encountered. For example, complex and complicated description of EIA did place Brinex in more advantageous position than the community representatives due to their prior familiarity in understanding and interpreting western science.

Mystifying the report with statistical figures and biological terms further made the local Indigenous people defenseless due to lack of relevant skills and knowledge to counter the industry's arguments. Deliberate omission of mentioning the damaged traplines in the report was the clear indication of manipulation of the findings. Inflated projection of potential jobs, lack of clarity on local need, and construction of road before any approval indicated breach of trust, deceit, and manipulation. Although Inuit representatives attended the environmental review panel hearings, the decision makers were predominantly non-Indigenous (external consultants and members of the EIA review panel) and the final decision makers were always non-Inuit (and not local).

The legacy of discrimination and coercion against the Indigenous population in Canada continues, and the corporate response to the environmental concern of the Inuit communities in Labrador is one of many glaring examples. In the mid-1990s, an Indigenous group (Sahtu Dene) from the Great Bear Lake region of the Northwest Territories (Canada) petitioned for environmental health studies on the future impacts of radiation exposure from historical uranium mining on both workers and the community. After numerous denials, the federal government undertook joint historical, scientific, and epidemiological studies to determine the impact of uranium mining in its territory.²⁸

However, the study refuted the claim of any association between the levels of uranium exposure among Indigenous workers and elevated cancer rates and concluded that the radioactive tailings sites are ecologically benign. Indeed, the Indigenous group has disputed these findings despite being one of the stakeholders of the study.²⁹ The Labrador Inuit and Dene experiences connect to a wider history of what has been called “nuclear colonialism,” in which uranium mining, nuclear waste siting, and nuclear testing have treated Indigenous areas in North America as “sacrificial landscapes” in the global geopolitical struggles of the nuclear age.³⁰ Although the benefits of uranium mining accrued to private capital and the state, the environmental effects were disproportionately borne by local Indigenous communities.

Conclusion

Any environmental practice can be labeled as environmental racism if the predictable distributional impacts of that decision contribute to the structure of racial subordination and domination.³¹ Therefore, example of Labrador exposes an institutional racism that runs much deeper than prejudice and prompts the question of how it operates in conjunction with a particular political-economic system that fails to recognize the importance of protecting environmental values.³²

Footnotes

Acknowledgments

I thank Newfoundland and Labrador Centre for Applied Health Research, Canada, for supporting (research grant 2012) the project. I am grateful to the Libraries of Memorial University and Labrador Institute for access to archival documents, including videos.

Author Disclosure Statement

No competing financial interests exist.

1

Peter Mangaly, Salisha Purushuttam, Nicole Latulippe. Highlights Report—Indigenous Environmental Justice Symposium. (York University, 2017). http://iejproject.info.yorku.ca/files/2016/11/IEJ-Symposium-Highlights-.pdf (Last accessed on November 5, 2018).

2

See footnote 1; Ciaran O'Faircheallaigh. “Environmental Agreements, EIA Follow-Up and Aboriginal Participation in Environmental Management: The Canadian Experience,” Environmental Impact Assessment Review 27 (2007): 319–342.

3

Lisa Thiele. Regulating Uranium Mining and Production: Part of a National Nuclear Regulatory Statute. (Canadian Nuclear Safety Commission, 2017). http://www.nuclearsafety.gc.ca/eng/pdfs/Presentations/VP/2017/20171004-lisa-thiele-regulating-uranium-mining-eng.pdf (Last accessed on November 5, 2018).

4

Alvaro Enríquez-de-Salamanca. “Stakeholders' Manipulation of Environmental Impact Assessment,” Environ Impact Assessment Review 68 (2018): 10–18.

5

Ciaran O'Faircheallaigh. “Environmental Agreements, EIA Follow-Up and Aboriginal Participation in Environmental Management: The Canadian experience,” Environmental Impact Assessment Review 27 (2007): 319–342.

6

Pacifica F. Achieng Ogola. “Environmental impact assessment general procedures.” Presented at Short Course II on Surface Exploration for Geothermal Resources, organized by UNU-GTP and KenGen, at Lake Naivasha, Kenya, 2–17 November, 2007. https://orkustofnun.is/gogn/unu-gtp-sc/UNU-GTP-SC-05-28.pdf (Last accessed on November 5, 2018); See footnote 5; Leonard Ortolano and Anne Shepherd. “Environmental impact assessment: Challenges and opportunities,” Impact Assessment 13 (1995): 3–30

7

See footnote 5.

8

LI. Labrador Institute Archive Finding Aid. (Labrador Institute. 2017), 127. http://www.mun.ca/labradorinstitute/archives/20170914_findingaid.pdf (Last accessed on October 5, 2018). Holdings: a.

Uranium I: Uranium Mining, 1977. Anita Best talks about uranium mining with Dr. Bill Wegenast of Memorial's Faculty of Engineering. (00:33:41) FV.001.B.A.0001.

Uranium II: Brinex Development and Makkovik Community Concerns, 1977. Makkovik residents voice their concerns about the Brinex uranium mining development in their area, and government officials respond. Features David Barnes of the Provincial Department of Consumer Affairs and Environment. (00:23:27) FV.001.B.A.0002.

Uranium III: Brinex and the Provincial Assessments Advisory Committee, 1977. Dr. David Barnes talks about the Environmental Assessment Process and the Dames and Moores environmental impact study on the proposed Brinex uranium development. (00:44:22) FV.001.B.A.0003.

Uranium IV: Interview with Larry Coady, 1977. Larry Coady of the Federal Environment Protection Service talks about the environmental hazards posed by uranium mines and what controls are necessary for protection. (00:22:43) FV.001.B.A.0004.

Uranium V: Interview with John Fleming and Norman Kipnis, 1977. John Fleming and Norman Kipnis of the Provincial Department of Mines and Energy discuss various aspects of worker health and safety at the proposed Brinex uranium development in Labrador. (00:36:56) FV.001.B.A.0005.

Uranium VI: Murray Piloski Discusses Brinex Activities in Labrador, 1977. Murray J. Piloski, Manager of Environment and Site Operations for Brinco, talks about the work done to date on the Brinex uranium explorations in Labrador. (00:32:55) FV.001.B.A.0006.

9

Marilyn Scales. “Canada's Next Uranium Hot Spot; Labrador's Central Mineral Belt,” Canadian Mining Journal 127 (2006): 10–12.

10

Brinco. European Economic Community Uranium Mission to Canada: A Presentation. (St. John's, Nfld: Brinco Ltd, Newfoundland, 1975). (Unpublished material. Available at the Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL).

11

Beak Consultants, Kilborn Ltd, and Brinex Ltd. Environmental Impact Statement, Kitts-Michelin Project: A Study for Brinex Limited. (Malton, ON: Beak Consultants, 1979). (Unpublished material. Available at the Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL).

12

Brinex Ltd. Environmental Impact Statement, Kitts-Michelin Project: Summary, Kitts-Michelin Uranium Project, Public Environmental Hearings. (Toronto, ON: Brinex Limited, 1979). (Unpublished material. Available at the Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL).

13

Brinex Ltd. Kitts-Michelin Project Information Summary February 1979. (Nfld: Brinex, 1979). (Unpublished material. Available at the Labrador Institute Library, Memorial University of Newfoundland, Goose Bay, NL); Brinex Ltd. Kitts-Michelin Project Information Summary June 1979. (Nfld: Brinex, 1979) (Unpublished material. Available at the Labrador Institute Library, Memorial University of Newfoundland, Goose Bay, NL).

14

See footnote 11.

15

See footnote 11.

16

See footnote 11; See footnote 13; Brinex Ltd, and Beak Consultants. Kitts-Michelin Project, Labrador: Addendum to Environmental Impact Statement. (Mississauga, ON: Brinex Limited, 1979). (Available at Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL); Dames & Moore, Centre for Labrador Research, Northland Associates Ltd., NORDCO Ltd. Environmental Study: Kitts-Michelin Project, Brinex (phase one). (Toronto: Dames & Moore, 1976). (Unpublished material. Available at Labrador Institute Library, Memorial University of Newfoundland, Goose Bay, NL).

17

See footnote 11.

18

See footnote 12.

19

See footnote 11.

20

Environmental Assessment Board. Brinex Kitts-Michelin Uranium Project: Report of the Environmental Assessment Board. April 10. St. John's, Newfoundland. Submitted by CW Powell, H Davis, and F Buckle to H Newhook, Ministry of Consumer Affair and Environment, Govt. of NL. 1980. (Unpublished material. Available at Centre for Newfoundland Studies, Queen Elizabeth II Library, Memorial University of Newfoundland, NL). Addendum: Ministerial statement, dated May 29.

21

See footnote 20.

22

See footnote 20.

23

Derek Wilton. Mineral Exploration and Mining History of Labrador. Meridian. 2010. (published by Canadian Polar Commission) Spring/Summer:11–17. (Last accessed on June 17, 2018) http://www.polarcom.gc.ca/uploads/Publications/Meridian%20Newsletter/meri%20%2010%20spring%20en.pdf (Last accessed on November 5, 2018).

24

Sheila Foster. “Race(ial) Matters: The Quest For Environmental Justice,” Ecology Law Journal 20 (1993): 721–753.

25

See footnote 4.

26

Laura Pulido. “A Critical Review of the Methodology of Environmental Racism Research,” Antipode 28 (1996): 142–159. Michael K. Hieman. “Race, Waste, and Class: New Perspectives on Environmental Justice,” Antipode 28 (1996): 111–121. David N. Pellow. “Environmental Inequality Formation: Toward a Theory of Environmental Injustice,” Am Behavioral Scientist 43 (2000): 581–601; David R. Simon. “Corporate Environmental Crimes and Social Inequality: New Directions for Environmental Justice Research,” Am Behavioral Scientist 43 (2000): 633–645; Luke W. Cole; and Sheila R. Foster. From the Ground Up: Environmental Racism and the Rise of the Environmental Justice Movement. (New York: New York University Press, 2000).

27

Carole Anne Holley. “Environmental Justice” for Indigenous Peoples: A Case Study of the Louden Tribal Council. A Thesis Submitted in partial fulfillment of the requirements for the degree Master of Environmental Studies. The Evergreen State College. August 2013. <http://archives.evergreen.edu/masterstheses/Accession86–10MES/Holley_C-MESthesis2013.pdf>. (Last accessed on November 5, 2018).

28

Arn Keeling and John Sandlos. Environmental Justice Goes Underground? Historical Notes from Canada's Northern Mining Frontier. Environmental Justice 2 (2009): 17–125.

29

See footnote 28.

30

See footnote 27; Danielle Endres. “The Rhetoric of Nuclear Colonialism: Rhetorical Exclusion of American Indian Arguments in the Yucca Mountain Nuclear Waste Siting Decision,” Communication and Critical/Cultural Studies 6 (2009): 39–60.

31

Gerald Torres. “Race, Class and Environmental Regulations,” University of Colorado Law Review 63 (1992): 839–840.

32

Robert A. Williams. Jr. “Large Binocular Telescopes, Red Squirrel Pinatas and Apache Sacred Mountains: Decolonizing Environmental Law in a Multicultural World,” West Virginia Law Review 96 (1994): 1133–1164.