Mr. Ken Plews Manitoba Conservation Pesticide Approvals Branch 123 Main Street, Suite 160 Winnipeg, Manitoba R3C 1A5 Regarding:  University of Manitoba Fort Garry Campus                      Pesticide Use Programs Public Notice                       (Winnipeg Free Press, May 5, 2005) Dear Mr. Plews: On behalf of the University of Manitoba Students’ Union, we respectfully request that you refuse to grant a Pesticide Use Permit to the University of Manitoba Fort Garry Campus.  The use of pesticides, especially for non-essential and cosmetic purposes, presents an unknown and incalculable risk to human health, water quality and the environment.  Many doctors, including the Canadian Association of Physicians for the Environment and the Ontario College of Family Physicians advise against pesticide use.  The Canadian Cancer Society recommends following the Precautionary Principle (when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically) and avoiding unnecessary pesticide use.  "The evidence linking pesticides and cancer is suggestive and the amount and quality of the research is growing. The Canadian Cancer Society believes that appropriate action should be taken to limit the risk to human health. This is especially true when the reason for using pesticides on lawns is to prevent weeds and plants that can be removed in other potentially less damaging ways."   (www.cancer.ca/ccs/internet/standard/0,2939,3543_372059_266291_langId-en,00.html) The Government of Manitoba is currently presenting a case to protect Lake Winnipeg.  As I am sure you are aware, the Fort Garry campus of the University of Manitoba is on riverfront property.  Reducing or eliminating chemical pesticide and fertilizer use on University property (and all Crown property) would be a step toward improving water quality in Lake Winnipeg and would demonstrate to the people of Manitoba that the government is committed to its own new water policies. The Public Notice describes 4 projected programs. 1. To control herbaceous weeds at the Fort Garry Campus using the herbicides Par 111 and Roundup. The program will run from May 29 to September 30, using a ground sprayer. Par III is a mixture including Dicamba, Mecoprop and 2,4-D.  The recent proposed re-evaluation by PMRA of 2-4,D came under fire for, among many other things, excluding relevant human cancer data in favour of animal studies which do not demonstrate a  cancer link.  (http://www.flora.org/healthyottawa/fs-5.htm)  2,4-D has the potential for dioxin contamination, as well as surface and groundwater contamination and is classified in group 2B (possible carcinogen) by the International Agency for Research on Cancer. (http://www.pesticidefree.ca/Impacts.pdf) Roundup or glyphosate is linked to spontaneous abortion, contaminates water, is highly toxic to fish and kills turf if applied incorrectly.  (http://www.pesticidefree.ca/Impacts.pdf) 2.  To limit the population of cankerworms using the biological control Dipel. This program will commence May 29 and continue until July 15, using a ground sprayer. Btk has been known to cause conjunctivitis and other eye problems, skin rashes, respiratory discharge or other problems, and nosebleeds in humans and has been shown to eradicate non-target caterpillar species.  (151 Reasons Not to Spray, Diane Wharton) 3. To control populations of nuisance insects using the chemical Malathion. This program will run from May 29 and continue until September 30. What method is proposed for application?  Regardless of the application method, nuisance spraying is clearly a non-essential or cosmetic use which Precaution would have us avoid. Acute exposure to Malathion causes headaches, loss of vision, and nausea.  It is mutagenic; highly toxic to birds, bees, fish, amphibians, and earthworms; and is listed as a possible carcinogen by the International Agency for Research on Cancer.  (http://www.pesticidefree.ca/Impacts.pdf) 4.  To control Dutch Elm disease using the fungicide Eertavas.  This program is projected to run from June 1 until September 30. Application will be in the form of root flare injection. There are biological-based products available now which are currently being studied for their ability to protect elms against DED (for example, “Dutch Trig” and “Elm Vaccine”). These products are preventatively injected into elms, where they trigger the elm tree’s own natural resistance.  With proper care, the need for any type of injection can be reduced or eliminated. (University of Illinois, http://www.ag.uiuc.edu/cespubs/hyg/html/200013g.html) We note that information regarding safe buffer distances from waterways is no longer included on pesticide labels.  Please provide the required buffer distances for the products included in this permit application. Human and environmental health must become a priority over industry pressure to continue using products of questionable safety.  Non-toxic lawn care and landscaping methods are available and our esteemed university should be using them to set a healthy example for the rest of the province.  On the basis of the Precautionary Principle, please refuse this permit.  Sincerely, signed, Cathy Van De Kerckhove Vice-President University of Manitoba Students’ Union Copies to: Minister of Water Stewardship, Honourable Steve Ashton Minister of Advanced Education & Training, Honourable Diane McGifford Minister of Conservation, Honourable Stan Struthers