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Good evening. Thank you for conducting this review, for mailing this report and for receiving my comments today. My name is Glenda Whiteman and I am speaking to you on behalf of Concerned Residents of Winnipeg (CROW) Inc. a non-profit organization whose mandate is to reduce pesticide use in Manitoba.  This issue also affects me personally, as I have recently purchased property in the Interlake and hope to soon be living a half-mile from Lake Winnipeg.

You can find this presentation on our website where I have provided most of the links for the resources that I am going to leave with you today at www.CROWinc.org/PresentationtoLWSBmay10,05.html

After listening to your presentation last week in Winnipeg, I must admit to being somewhat frustrated with the narrowness of your focus and with your inability to pinpoint the sources of the problem. “How can pesticides and herbicides, with names like “organoPHOSPHATE” be excluded from a study on how to reduce nitrogen and phosphorous levels?” I fumed. How can we take steps to solve this problem if we're not willing to admit where the problem originates? But when I made enquiries with other scientists and environmentalists in preparation for writing this submission, I was reminded that you have every right to follow whatever mandate you choose or whatever mandate the Minister chose for you.

Overwhelming

Please don't think though that I have come here today to criticise your efforts or even those of Steve Ashton. The problem about what is going on in Lake Winnipeg is so overwhelming that we must start somewhere. I can understand that the Minister wants to focus on 2 nutrients, because it seems manageable. And even that tiny little piece of the total picture of pollution in Lake Winnipeg is so huge that by the time you're through, it will have taken you 3 years to complete your recommendations.

Other experts I approached were encouraged by some of your recommendations and hopeful that some of them may be implemented in spite of expected lobbying from ILO interests and agribusiness who may pressure government NOT to implement any regulation of nutrients. It is important for government to get the message that there is A LOT OF PUBLIC SUPPORT for meaningful, enforceable regulations. I am told that in Denmark, farmers have to fill out something like an income tax form detailing their nutrient use and applications, as well as that lost via atmospheric deposition and there may be a similar requirement in Holland.

What I hope to do today is convince you that even within your strict mandate, you have an opportunity to make a huge difference. You have an opportunity to bring forward the public's very real concerns about the deterioration of our environment and our water resources and to pressure the government to take action NOW to reverse this trend. I hope to convince you that your recommendations on reducing pollution need to be strengthened, that land application of effluent is a grave concern and all other alternatives must be more than simply researched; they must be implemented, that you must do more than simply recommmend that the provincial government raise the issue of phosphorous content in cleaning supplies, and finally that you recommend the adoption of the Precautionary Principle as a decision-making guideline for every future government decision which could potentially impact human and/or environmental health.

Even though the scope of your project is clearly quite vast, it is equally clear that it covers a minute portion of what must be ailing Lake Winnipeg. When I called a scientist friend in Saskatchewan, complaining that you were only investigating N and P while there are now some 77,000 chemicals out there, interacting and affecting us in unknown ways, she corrected me, saying we now think that figure is closer to 85,000. She also reminded about Rachel's Environment & Health News Bulletin called, Beyond Erin Brockevitch, written by Sonja Biorn-Hansen, a water quality researcher for the Oregon Department of Environmental Quality.

Among other things, Biorn-Hansen attempts to explain the origins of the US EPA's Priority Pollutant List. This list was generated in the early 70's, contains 120 chemicals, and was the result of some brainstorming by EPA officials and haggling between industry and environmental groups. She writes, “Since that time, tens of thousands of chemicals have made their appearance in the US economy. Not a single one of them has been added to the Priority Pollutant List.”

She goes on to explain what this means for water quality. “So, let's do the math: if there are 70,000 chemicals, give or take, in use in our economy and the list of Priority Pollutants is 120 chemicals long, that means that as far as water quality is concerned, we are regulating 0.17% of the chemicals out there. To put matters as bluntly as possible, we are regulating an out-of-date and possibly arbitrary 0.17% of the chemicals out there.”

Let's compare this with what we do in Manitoba. Do we have something comparable to the Priority Pollutant List? Not to my knowledge. The receptionist who answered my call at Manitoba Conservation did not think so either. And how do we regulate what goes into our water? Do we currently enforce waterway buffers from chemical fertilizers, pesticides and herbicides? No, in fact we have government-operated golf-courses abutting rivers and lakes all over Manitoba, not to mention sports fields, universities and hospitals. But you know this already.

Common Sense

What you may not know, and neither did a senior official at Manitoba Conservation at the Pesticides Approvals Branch, is that a recommended buffer distance from waterways is being removed from pesticide labels. This means that those rare individuals who do bother to read the label will no longer find that information. (And by the way, Manitoba Conservation wasn't really sure of what the buffer distance should be.)

So, let's recap. We don't know what the priority pollutants are, we don't know how they interact, and we don't know how far from waterways we should not use them. One would think that common sense and the Precautionary Principle should prevail here. If we don't know, we shouldn't do it.

Toxic

To the contrary, our neighbours to the south have recently decided that it is prudent to amend their so-called Clean Water Act to permit more water pollution. This will not help reduce the 64% of nutrients that enter Lake Winnipeg from the Red River.

Biorn-Hansen also talks about toxic sludge and the failure of most wastewater treatment plants to remove toxins. She talks about the failures of a regulatory system that does not know how many things it is not regulating that it ought to be. And she worries about the overwhelming silence around that issue.

Choice

Limiting your focus to only 2 nutrients is understandable. It is an achievable goal—and I am glad you're doing it. But ignoring the rest of the picture because it's too big to comprehend is slow suicide. We have to stop doing things if we don't know what the consequences of our actions will be. The easiest place to start that process is with our consumer choices. We do not have to buy toxic products for non-essential or cosmetic uses. Organic lawn maintenance companies are fiscally out-performing their chemical competitors. Organic food production is gaining respect and a continually-growing market share. Ecologically sustainable technologies for sewage treatment, construction and maintenance are being created all the time. Doing things the right way is profitable.

Your report includes a number of recommendations that you are encouraged to word much more strongly.

• 4.0 soil testing should be a requirement, not just a recommendation

• 13.0 ...other proven technologies need to be implemented...

• 17.2 ...and the public and all levels of government should be encouraged to reduce all unneccessary and cosmetic uses of toxic or potentially toxic substances. (Why not teach people how and why to use alternatives to toxins rather than providing more opportunities to 'safely' dispose of their toxic waste? The pretense that toxins can be safely disposed of encourages their use.)

• 28.1 the Federal Government should restrict ALL toxic ingredients from cleaning products and require labelling of all ingredients

• 31.1 The Province of Manitoba should lead by example and institute its own pollution prevention strategies, beginning by adopting organic lawncare practices on all Crown properties

There are other recommendations that need to be included.

• Adopt the Precautionary Principle in all decisions affecting human & environmental
  health and especially in cases where less-toxic alternatives exist

• Adopt a Policy of Prevention: All unnecessary and cosmetic uses of chemical fertilizers and pesticides, other phosphorous-based products and other toxins should be avoided

• Encourage and support a local economy based on producing for local markets, thereby reducing pollution caused by over-production and needless shipping

• Engage the public in a meaningful way to rehabilitate the lake

• Compile a current, local Priority Pollutant List

• Encourage municipal cosmetic pesticide by-laws or a Provincial Code such as Quebec's to prevent unneccessary chemical use

• Discourage the US from enacting legislation which will further pollute waters draining into our watershed

• Encourage an updated Noxious Weeds act. (ie. The dandelion is known as taraxicum officinale, meaning it has been officially recognized as having medicinal properties. Meanwhile, pesticides are, by design, toxic at any dose.)

Finally, you have made recommendations which are deeply concerning.

• If you are truly considering potential health risks, you cannot promote land application of effluent or any waste if it is not known to what degree the sludge is toxic. Increasing numbers of people are developing chemical sensitivities and asthma, not to even mention cancer. Spreading manure and other sewage on land where untold amounts of it off-gas into the air and untold more leaches into our water, is simply not good sense.

I hope that I have not offended you with this presentation. In fact, I hope to come knocking on some of your doors, to seek your support for our own organization's narrow-focused 2-chemical campaign. The message I hope you will take back to the table with you is the problem is overwhelming. The longer we ignore it; the worse it gets. We can make a difference now by acknowledging that what we don't know CAN hurt us, and that we can all make better choices everyday. That by adopting a policy of prevention today, we can minimise our impact tomorrow.

Thank you all for your energy and your efforts in trying to save the Lake, and thank you for your attention to our concerns today.

Sincerely,

Glenda Whiteman