24D-Objection-Sears-Aug15-2008.pdf  [437.35K]

SAVING THE REGION OF ONTARIO NORTH GROUP    Herbicide Alert    http://www.theglobeandmail.com/servlet/story/RTGAM.20081022.wpesticides22/BN Story/National/home   Ban on pesticides may face NAFTA test   MARTIN MITTELSTAEDT AND LUKE ERIC PETERSON From Wednesday's Globe and Mail October 22, 2008 at 1:12 AM EDT Dow AgroSciences is considering using the controversial investor-protection provisions of the North American free-trade agreement to seek compensation from the federal government over Quebec's ban on the cosmetic use of pesticides. The company, a maker of the weed-killer 2,4-D, filed a notice of intent to submit a claim to arbitration under NAFTA in late August. The 27-page legal action was posted yesterday on the Foreign Affairs website, where it is listed as a dispute to which Canada is a party. In its notice, Dow says the Quebec ban outlawing the use of bug and weed sprays for merely appearances' sake around homes breaches legal protections owed by Canada to U.S. investors under the trade agreement. NAFTA has provisions, known as Chapter 11, that restrict the ability of a country to take measures “tantamount to nationalization or expropriation” of an investment from a firm from another NAFA member. Besides Canada, the United States and Mexico are in the trade pact. The Indianapolis-based company, whose 2,4-D is a standard ingredient in many commercial weed sprays, is seeking compensation of not less than $2-million, plus legal costs and yet-to-be specified damages. Dow's legal brief accuses the Quebec government of implementing a pesticide ban that “is not based on science” and was applied to 2,4-D “without providing any meaningful opportunity” for the company to make its case that the herbicide is safe. Quebec instituted its pesticide ban in 2006, and Dow's action could have wide-ranging impacts. Ontario has recently adopted a similar measure, as have many municipalities, based on a precautionary public-health approach of minimizing exposures to these chemicals. Although pesticide bans are spreading in Canada, the degree of health risk posed by the sprays is highly contentious. While such respected groups as the Canadian Cancer Society have argued in favour of bans, Health Canada says the pesticides it allows on the market are safe, if used as directed. Ironically, Health Canada issued its assessment backing the safety of 2,4-D in May, shortly after Ontario said it would follow Quebec's lead by banning the lawn and garden chemicals. The Dow claim is the latest in a long string of disputes to arise under Chapter 11 – a legal back-channel that permits foreign investors to detour local courts and sue the federal government before an international tribunal. Foreign Affairs lists nine active arbitrations to which Canada has been named as a party. The government is defending against a similar Chapter 11 claim filed by another U.S.-based chemical producer over lindane, a suspected carcinogen banned or no longer used in many countries. When Canada moved to end the use of the fungicide on seed treatments, U.S.-based Chemtura Corp. sued for $100-million in damages. That arbitration is going on behind closed doors. Many of the NAFTA Chapter 11 actions have been based on complaints that pollution regulations harm business, raising concerns that companies are trying to use the trade treaty to stop governments from taking actions to protect public health or the environment. Kathleen Cooper, a senior researcher with the Canadian Environmental Law Association, says that the Quebec ban is backed by medical and environmental organizations, and enjoys wide support in public-opinion surveys. She says she is troubled that chemical producers can invoke NAFTA in an effort to “undermine the decisions of democratically elected governments.” Rick Smith, executive director of Environmental Defence, says Dow is “quite transparently” trying to stop pesticide bans from spreading around the country and he predicts the company will face a public backlash for its position. But Dow, in its submission, says Quebec has consistently ignored decisions supporting as safe the continued use of 2,4-D from Health Canada and other regulators. U.S. Chemical Company Challenges Pesticide Ban      October 22 2008   U.S. Chemical Company Challenges Pesticide Ban   by Luke Eric Peterson   The issue of free trade was largely a non-issue during our recent federal election.   However, the North American Free Trade Agreement might have garnered a few headlines if the Feds had disclosed that U.S. chemical giant Dow signalled in late August that it is gearing up to sue Canada.   Dow Agrosciences insists Quebec's province-wide ban on the residential use of weed-killing chemicals breaches legal protections owed by Canada to U.S. investors under the NAFTA.   The U.S. company, which has an extensive manufacturing and sales operation in Canada, wants to be compensated by the Feds for losses incurred to its star product, 2,4-D, one of the most popular chemical ingredients used in commercial pesticides.   The Dow claim is the latest in a long string of disputes to arise under Chapter 11 of the NAFTA—a legal back channel which permits foreign investors to detour around local courts and sue the federal government before an international tribunal.   The company triggered a 90-day waiting period in August, after which it can bring the federal government to binding arbitration.   For cross-border investors, these types of legal protections can come in handy if a tin-pot dictator sends in the tanks and seizes your factories or oil fields. But when such legal provisions are invoked by foreign investors in an effort to ward off health or environmental regulations, eyebrows drift skyward.   Kathleen Cooper, a senior researcher with the Canadian Environmental Law Association, says the Quebec ban has been warmly endorsed by medical and environmental organizations—and enjoys wide support in public opinion surveys. She's troubled that chemical producers can invoke NAFTA in an effort to "undermine the decisions of democratically-elected governments."   The spectre of a NAFTA lawsuit comes at an auspicious moment.   The Province of Ontario has signalled that it will follow Quebec's lead, passing legislation earlier this year, and working on regulations that could come into force next spring.   Such regulatory moves will eventually draw wider attention and scrutiny in other jurisdictions—including the far more lucrative U.S. market. If the U.S. chemical industry hopes to avert a domino effect, it may need to borrow a page from the War on Terrorism tactics book: fighting tougher regulation abroad, so they don't have to fight it on the homefront.   For its part, Dow insists Quebec and Ontario are out of step with the international consensus on a product that has been used for decades in dozens of countries.   The company points to a 2007 risk assessment by Canada's own Pest Management Regulatory Agency which said the product could continue to be used safely on lawns. Dow stresses that Quebec's decision to ban certain uses of the product is not based on scientific evidence. Spokesperson Gary Hamelin says it is a real problem when companies are "making investments of tens of millions of dollars for products that— based on a scientific assessment—[are] acceptable."   While Dow jousts with its critics over the scientific evidence, Quebec (and now Ontario) have taken the view that more stringent standards should be imposed by provincial health regulators—particularly where the product is not necessary, but is used for purely cosmetic purposes.   It could fall to a panel of three arbitrators to decide whether such provincial regulations run afoul of Canada's NAFTA commitments.   Of course, threatening to file a NAFTA claim is hardly a guarantee of success. Nevertheless, chemical producers seem to be warming to the NAFTA option.   Already, the government is defending against another NAFTA Chapter 11 claim filed by another U.S.-based chemical producer. When Canada's Pest Regulatory Management Agency moved to ban the use of Lindane- based seed treatments, U.S.-based Chemtura Corporation sued for $100 million in damages. That arbitration is currently going on behind closed doors, following a January confidentiality order.   One wonders if this is the tip of the legal iceberg. After all, the Feds are now undertaking a broad review of thousands of under-tested chemicals currently on the market.   Just last week, the government added the controversial substance Bisphenol A (BPA)—which is used widely in plastics—to a registry of toxic substances. Although there are no immediate plans to ban the use of the substance as a lining in food and drink cans, it is very likely that BPA will be eliminated from polycarbonate baby bottles.   It remains to be seen whether tougher regulations on BPA and other chemicals will also be challenged under NAFTA Chapter 11.   For almost two months, the federal government has been mum about the latest legal salvo from Dow.   Although Dow formally signalled its intentions in late August—setting in motion a 90-day consultation period—the Department of Foreign Affairs only disclosed the potential lawsuit yesterday.   Until now, Canadian taxpayers—who foot the bill to defend NAFTA lawsuits and pay any compensation awarded by arbitrators—have been denied the opportunity to weigh in with their own views on the matter.   However, given that nearly 7,000 members of the public submitted comments on the Ontario Government's proposed pesticides ban, one can guess that the Feds will receive plenty of feedback in the weeks to come.   Luke Eric Peterson is a columnist for Embassy and the editor of an investigative reporting service tracking NAFTA-style arbitrations, the Investment Arbitration Reporter (www.iareporter.com).   editor@embassymag.ca   http://www.embassymag.ca/page/view/peterson_nafta-10-22-2008   Expédié par: Forwarded by: L’Association pour la santé environnementale les hypersensibilités et les allergies du Québec- AEHAQ The Allergy and Environmental Health Association of Quebec - AEHAQ  <http://www.aeha-quebec.ca/>     August 29, 2008 Nine additional pesticides must be added to new Ontario ban By: David Suzuki Foundation Toronto – Ontario’s new pesticide regulations now under development must add nine more to the preliminary list of banned lawn and garden pesticides so as not to undermine restrictions already in place when the Cosmetic Pesticide Ban Act comes into force next summer, according to a brief released by the David Suzuki Foundation today. “For the new law to be effective, the ban must be comprehensive,” says Lisa Gue, health and environmental policy analyst with the David Suzuki Foundation. “Toxic lawn and garden pesticides pose unnecessary risks and we need to make sure we include all the dangerous ones in the new regulations to protect our health and our environment.” In addition to those already included in the preliminary lists, De-bugging the ban: nine missing pesticides from Ontario’s proposed prohibitions recommends banning the use and sale of pesticides with the following active ingredients: abamectin, acetamiprid, glufosinate ammonium, glyphosate acid, isopropylamine salt of glyphosate, metam, napropamide, spinosad and thiram. Seven of these ingredients are already banned in several Ontario municipalities including Toronto, Peterborough and Markham. The new law will replace municipal bylaws and the provincial regulations now under development must be inclusive so as not to dissolve these restrictions. To ensure that new toxic ingredients don’t find a way onto lawns and gardens in the future, the Foundation also recommends that the regulations include guidelines providing that only lower-risk, naturally occurring substances be permitted for lawn and garden pest control. De-bugging the ban: nine missing pesticides from Ontario’s proposed prohibitions can be downloaded here or go to www.davidsuzuki.org/publications. Media contact: Lisa Gue, Health and Environmental Policy Analyst David Suzuki Foundation Cell: (613) 796-7699 lgue@davidsuzuki.org Sana Khan, Communications assistant David Suzuki Foundation Tel: (416) 644-1032 Cell: (416) 556-6138 skhan@davidsuzuki.org source: David Suzuki Foundation     WARNING HUNTERS !!! Are you eating chemically contaminated meat?      The proposed application of chemical herbicides in Ontario’s forests (and Canada's forests) has a real potential to chemically contaminate the wild game animals in region, many of which will be slaughtered for human consumption.  No attempt has been or is proposed to be made to ensure that legally required separation periods are met in regards to chemical herbicide applications on grazing areas used by animals destined to be slaughtering for human consumption.   Livestock and wild animals are both harvested for human consumption.  Chemically contaminated meats which would not pass standards set in agriculture are being unknowingly consumed by Aboriginals, Metis, and all other peoples who hunt, fish, and gather food from the forests. The Ontario government sells hunting licenses. The Canadian government sells migratory bird stamps.  Like farming, these parties are both selling meat to the public, though the public must harvest that meat themselves.  Both Ontario and Canadian Governments have a constitutional obligation under s. 35 of the Constitution Act to minimally infringe the rights of Aboriginals and Metis to hunt, fish, gather berries and medicines from the forests.  As Quebec and Scandinavia have sucessfully eliminated the use of chemical herbicides to manage the vegetation in their forests, Ontario is failing in its duty to minimally infringe constitutionally protected rights. The forests being sprayed, after harvesting or some other major disturbance, are full of saplings and berries.  These area’s are the grazing grounds for many species in Ontario’s forests, many of which will be hunted and consumed by humans.  Pesticide separation times at the center of approval for usage by the federal government’s Pest Management Regulatory Agency (PMRA) and the Ontario Ministry of Agriculture, Food, and Rural Affairs have not been followed during previous forestry applications or the proposed applications for 2008.  There has been absolutely no attempt to create and maintain a physical barrier to prevent wild animals (which may be consumed by humans) from entering the sprayed areas.  The chemical herbicide spray season directly overlaps with several hunting seasons, including moose, bear, deer, partridge, rabbit, and ducks to name a few.  Many seasons vary geographically and by weapon.  Below is a general seasons outline (earliest opening to latest hunt) for the following animals in area’s proposed to be sprayed with chemical herbicides for forest vegetation management in the summer / fall of 2008.  A full list of hunting seasons in Ontario can be found at the following link:  http://www.mnr.gov.on.ca/en/Business/FW/Publication/MNR_E001275P.html Moose – Sept 20 to December 15  Bear – August 15 to November 30  Deer – Sept 1 to December 31 Partridge – September 15 to December 31  Rabbit – September 1 to June 15th of the next year The Canadian Wildlife Service is responsible for migratory bird hunting seasons.  Below is a general seasons outline(earliest opening to latest hunt) for the following animals in area’s proposed to be sprayed with chemical herbicides for forest vegetation management in the summer / fall of 2008.  A full list of hunting seasons in Ontario can be found at the following link: http://www.cws-scf.ec.gc.ca/publications/reg/2007/ont_e.pdf Duck and Geese –  September 1 to December 15   It is also important to note that Aboriginals and Métis peoples have a constitutionally recognized right to hunt, and may not be required to adhere to all provincially or federally mandated hunting seasons.    The chemical herbicide spray season runs from approximately July 1 to September 30. A chemical herbicide spraying from July 1 to Approximately August 15 will result in a total kill of all vegetation in the exposed area.  Chemical herbicide applications aimed at eliminating broadleaf and grass vegetation, without killing the conifer trees, occurs from approximately August 15 to September 30.  The Ontario Ministry of Agriculture, Food, and Rural Affairs has published a document titled, “Publication 75, Guide to Weed Control”.  You will find this guide helpful and informative.          The guide indicates that grazing restrictions are required in situations where meat animals may enter areas which have previously been exposed to  glyphosate and 2,4-D herbicides, like those commonly sprayed by the forestry industry with common names including Vision, Vantage, and Round up.  These restrictions are put in place to protect the health of the animals, and of the people who will be eating those animals.    Given the broad geographic range covered by many of the animals hunted and consumed by people in the regions to be sprayed, and the lack of any attempt to restrain wild animals from entering and feeding in these areas, there is no certainty that the wild animals which will be harvested in 2008 (or previous years) will not contain chemical herbicide residues grossly in excess of government standards.     http://www.omafra.gov.on.ca/english/crops/pub75/14bl1pgb.htm Glyphosate Trade Name glyphosate or glyphosate or glyphosate or glyphosate Active Ingredient glyphosate or glyphosate or glyphosate or glyphosate Formulation 360 g/L 480 g/L 500 g/L 540 g/L Rate per hectare (active) 1 to 2 kg/ha 1 to 2 kg/ha 1 to 2 kg/ha 1 to 2 kg/ha Rate per hectare (product) 2.8 to 5.6 L/ha 2.08 to 4.17 L/ha 2.0 to 4.0 L/ha 1.85 to 3.7 L/ha Rate per acre (product) 1.12 to 2.24 L/ac 0.83 to 1.67 L/ac 0.8 to 1.6 L/ac 0.74 to 1.48 L/ac Precautions Apply as a directed spray under the bushes, avoiding new shoots. Apply in 200-300 L/ha water (80-120 L/ac), using no more than 275 kPa pressure. Avoid contact with fruit, foliage or canes. Use only one application per season. Do NOT apply closer than 30 days to harvest.     http://www.omafra.gov.on.ca/english/crops/pub75/10le2pgb.htm   Glyphosate Trade Name glyphosate or glyphosate or glyphosate or glyphosate Active Ingredient glyphosate or glyphosate or glyphosate or glyphosate Formulation 360 g/L 480 g/L 500 g/L 540 g/L Rate per hectare (active) 1.71 to 4.32 kg/ha 1.71 to 4.32 kg/ha 1.71 to 4.32 kg/ha 1.71 to 4.32 kg/ha Rate per hectare (product) 4.75 to 12 L/ha 3.56 to 9 L/ha 3.42 to 8.64 L/ha 3.17 to 8 L/ha Rate per acre (product) 1.7 to 4.8 L/ac 1.42 to 3.6 L/ac 1.38 to 3.5 L/ac 1.27 to 3.2 L/ac Precautions SPOT TREATMENT ONLY: Apply when field bindweed has reached full bloom and other weeds are in the bud to full bloom stage. Do NOT graze or harvest forage from treated spots until the treated plants turn brown.   http://www.omafra.gov.on.ca/english/crops/pub75/10sorpbh.htm 2,4-D Amine Trade Name  2,4-D Amine 600 Active Ingredient 2,4-D Formulation 470 g/L Rate per hectare (active) 0.28 to 0.56 kg/ha Rate per hectare (product) 0.6 to 1.2 L/ha Rate per acre (product) 0.24 to 0.48 L/ac Precautions Apply when crop is at 4-6 leaf stage before closure of canopy. Do NOT apply within 30 days of harvest. Do NOT spray in hot (over 27°C) humid weather.   http://www.omafra.gov.on.ca/english/crops/pub75/10paspbp.htm 2,4-D + Banvel or Oracle Trade Name 2,4-D or 2,4-D or 2,4-D + Banvel II or Oracle Active Ingredient 2,4-D 2,4-D 2,4-D + dicamba Formulation 470 g/L 564 g/L 660 g/L 480 g/L Rate per hectare (active) 1.1 kg/ha 1.1 kg/ha 1.1 kg/ha 1.01 kg/ha Rate per hectare (product) 2.34 L/ha 1.95 L/ha 1.29 L/ha 2.1 L/ha Rate per acre (product) 0.94 L/ac 0.6 L/ac 0.52 L/ac 0.84 L/ac Precautions For wild carrot. Apply in early fall for control of first year plants. Wait 14 days between treatment and harvest or grazing for dairy animals. Meat animals may graze or feed in treated pastures 30 days after dicamba application without restrictions on slaughter. If treated vegetation has been consumed by meat animals within 30 days of dicamba application, feed the animals with untreated diet for 30 days before slaughter.     Similar cautions are found on the Federal Pest Management Regulatory Agency (PMRA) Website.  The Product Label for all products registered for use are accessible through this website.  The product labels include restrictions, and breach of the restrictions puts product use outside of approval criteria. http://pr-rp.pmra-arla.gc.ca/portal/page?_pageid=34,17551&_dad=portal&_schema=PORTAL Try the the following search terms: Active Ingredient: 2,4-D    Additional Search term: Livestock Product Type:  Commercial    Common restrictions include: • Do not permit lactating dairy animals to graze fields within 7 days after application. • Do not harvest forage or cut hay within 30 days after application. • Withdraw meat animals from treated fields at least 3 days before slaughter.   •  Do not permit meat animals being finished for slaughter nor dairy animals to forage or graze treated fields within two weeks of treatment.  • Do not contaminate any body of water, or watercourse, water used for livestock or for domestic purposes. Try the the following search terms:   Active Ingredient:  Glyphosate Additional Search term:  Livestock Product Type:  Commercial      •  ALLOW 3 TO 5 DAYS FOR ROUNDUP ORIGINALTO TRANSLOCATE INTO ALL PLANT PARTS BEFORE GRAZING OR HARVESTING TREATED AREAS IN FORAGES.       MPP GILLES BISSON PRESENTS STRONG PETITION vs. CHEMICAL HERBICIDES ONTARIO PARLIAMENT - QUEEN'S PARK - MARCH 17, 2008 http://www.gillesbisson.com/newsitem.php?id=521 http://www.gillesbisson.com/newsitem.php?id=522  Comment directly to your Member of Provincial Parliament (MPP) !!! FIND THEIR EMAIL / MAIL / PHONE HERE Continue to send your comments directly to the following people, and reference Ontario Environmental Registry (www.ebr.gov.on.ca)  PROPOSAL # 010-2248 Ontario Premier, Ottawa South MPP, Dalton McGuinty dmcguinty.mpp.co@liberal.ola.org Ontario Minister of Environment Minister@ene.gov.on.ca Robert Bilyea - Policy Advisor Robert.Bilyea@ene.gov.on.ca Consultation is over after third reading of the legislation and we are awaiting first reading ... which was indicated as Spring 2008 in the EBR posting.  Get active, write a letter to the editor !!!! JOIN THIS FACEBOOK VOTING EVENT !!!   -  " NON-ESSENTIAL CHEMICAL HERBICIDES " For a great conversation on herbicides & forestry with Clyde Gagnon and Joel Theriault, see this link. http://instantteleseminar.com/?eventid=2259714  Who Has Signed? Check Petition Support List >> http://www.thestrongroup.org/index.php?pr=Support_List This issue can be boiled down to one sentence: The Ontario government proposes to expose you and your family to non-essential chemical herbicides so that you can do your small part to slightly increase shareholder profit margins (or save money) for multinational forestry corporations, golf courses, Ontario Power Generation, Ontario Ministry of Transporation, and Canadian National Railway (CNR). Many people have asked me, “Why should it matter to me whether chemical herbicides are being sprayed in Ontario’s boreal forest? I don’t live in the forest, or even the country.” The truth is, Ontario’s boreal forest is very connected to the rest of the province and indeed, the world … and one such CONNECTION COMES FROM THE MOVEMENT OF WATER. Chemicals leaving the boreal forest reach the shorelines of Manitoba, Quebec, Minnesota, Wisconsin, Michigan, Ohio, Pennsylvania, and New York. Of course, when these chemicals reach the ocean, they find their way to the shorelines of all Canadian provinces. The government will implicitly interpret silence by the public during this period of “consultation” as ACCEPTANCE of the government’s proposal. Comments from all jurisdictions are invited. Chemicals leaving Ontario’s boreal forest will reach the fresh-water shorelines of Manitoba, Quebec, Minnesota, Wisconsin, Michigan, Ohio, Pennsylvania, and New York. The Proposal(S) are broken into several parts, and comment on all is aspects would be appropriate. The proposal(S) are that: 1 – We ban non-essential chemical herbicides and pesticides from being applied in municipalities (GREAT) 2 – We allow non-essential chemical herbicides and pesticides to be applied on Golf Courses (???? WHAT ARE THEY THINKING ???) 3 – We allow non-essential chemical herbicides to be sprayed in pristine wilderness area’s of Ontario’s boreal forest (A travesty … A TERRIBLE POLICY !!!) 4 – We allow non-essential chemical herbicides to be sprayed under OGP power lines, on the side of highways by MTO, and on the side of railways by Canadian National Railway(???). Note that Canadian Pacific Railway has used steam for the last decade as opposed to chemical herbicides, but CNR still sprays for the $$$ ... The non-essential chemical herbicides that you will be exposed to by the forestry industry include 2,4-D which is 50% of the herbicide mixture commonly known as “AGENT ORANGE” and now known as "Killex" … and glyphosate, which is commonly known as "RoundUP" and known to cause mortality and genetic malformations in amphibians. Give praise where needed (Item 1) and scorn where the policy is ridiculously inadequate (Item 2, 3, 4). Demand a provincial wide ban on non-essential chemical herbicides and pesticides. *** DIRECT LINK TO GOVERNMENT PROPOSALS ***   Comment directly to your Member of Provincial Parliament (MPP) !!! FIND THEIR EMAIL / MAIL / PHONE HERE "Men are apt to settle a question rightly when it is discussed freely" ... It is imperitave to submit your comments. Comments can be as brief as a single sentence of support for the proposal to require Ontario's forestry industry to make use of recognized and well known non-chemical alternatives to manage vegetation in the boreal forest. Without your comments, the government will give into lobby pressure from multinational corparations and continue to allow non-essential chemical herbicides to be sprayed in the headwaters feeding the Great Lakes (maps), the Ottawa River (maps), and the James Bay. Such is the government proposal, and silence by the public during this "consultation" is interpreted as acceptance of the government proposal. DRAFT SUBMISSION TO PROPOSAL# 010-2248 In regards to the proposed legislation to ban non-essential chemical herbicides and pesticides, I am deeply concerned about the broad sweeping exemptions which propose to allow non-essential chemical herbicides and pesticides to be applied. I agree with your proposals that non-essential chemical herbicides and pesticides should not be applied on gardens, parks and school yards. I do not agree with your proposals that non-essential chemical herbicides and pesticides may be applied when non-chemical alternatives exist: (Pick one or all) - in Ontario’s forests - by the forestry industry - by the Canadian National Railway (CNR) … as Canadian Pacific (CP) has perfected vegetation management with steam - by Ontario Power Generation (OPG) under their electrical lines - by the Ontario Ministry of Transportation (MTO) on the side of highways - on Golf Courses - in agriculture - to kill all mosquito’s in an area, exposing the population with insecticides that attack the nervous system, but aimed at attempting to prevent infection of West Nile Virus I do not agree with the proposed approach that ““The focus of our (Government) efforts will be on outreach and education on alternatives to pesticides on lawns. Enforcement will be a last resort.” While outreach and education are essential to overcoming non-essential chemical herbicide and pesticide usage, government capacity and willingness to enforce pesticide legislation is essential to any ban on non-essential chemical herbicide and pesticide usage. I do not agree with the proposal that “the focus of the ban would be on “towns and cities, and not on restrictions on rural residents.” Residents living in remote and rural communities have every right to health, well being, and safe drinking water. Furthermore, pesticides are known to migrate, and application in rural and remote areas threatens the health of those residents as well as residents in towns and cities as they contaminate our shared drinking water supplies. By stopping the non-essential application of chemical herbicides in Ontario's forests, we would be: 1 - Protecting endangered species habitat 2 - Protecting the soil of the forest and its carbon storage capacity, all very prone to decomposition and erosion following chemical herbicide applications. The forest and its soil is a major carbon sink protecting the world from global warming. Save it to save the world !!! 3 - Protecting the rights of all peoples who would otherwise be exposed to these chemicals (downstream, or by migratory animals which have been contaminated). Resource dependent first nation communities are especially vulnerable to the chemical contamination of the forests. 4 - Preventing the non-essential chemical contamination of all wildlife passing through areas on which these chemicals are found 5 - Protecting the water, and all of those people who rely upon it. Contaminated waters leaving Ontario's boreal forests will reach the fresh water shorelines of Manitoba, Quebec, Minnesota, Wisconsin, Michigan, Ohio, Pennsylvania, and New York and will eventually dump into the ocean. These toxins cannot be removed from water filtration plants such as Toronto and Ottawa. Do you think your town is doing any better? 6 – Protecting Ontario’s long term prosperity as nearly half of its budget pays for health care … 7 – Increasing local employment opportunities in remote areas of Ontario, rather than paying for chemicals and airplanes. 8 – Protecting the employment opportunities for everyone dependent on wilderness tourism in Ontario I do not agree with the proposal “to introduce legislation in the spring of 2008, with a phased-in implementation (e.g. 3 years).” If other jurisdictions currently have in place non-chemical alternatives for the above-mentioned uses, such as herbicides in Ontario’s forests, I would like to see those alternatives implemented immediately. There is no need to expose us to non-essential chemical herbicides and pesticides for another 3 years before something is actually done. Most sincerely, (YOUR NAME) (YOUR CONTACT DETAILS) Send your comments directly to the following people, and reference EBR PROPOSAL # 010-2248 Ontario Premier, Ottawa South MPP, Dalton McGuinty dmcguinty.mpp.co@liberal.ola.org Ontario Minister of Environment Minister@ene.gov.on.ca Robert Bilyea - Policy Advisor Robert.Bilyea@ene.gov.on.ca Comment directly to your Member of Provincial Parliament (MPP) !!! FIND THEIR EMAIL / MAIL / PHONE HERE   ****** In 1999, the 35th Senate Subcommittee on the Boreal Forest published a report titled, “COMPETING REALITIES: The Boreal Forest at Risk". The subcommittee recommended that, “All herbicide and chemical pesticide use in the boreal forest should be phased out as soon as possible.” The environmental registry posting indicates that “The government will look at other communities and jurisdictions, including Quebec, that have implemented bans on cosmetic uses of pesticides. Currently, the use of pesticides (including herbicides, insecticides, fungicides, or combinations of any of these) is restricted in a number of municipalities across Ontario" and over 135 across Canada. While the government proposes to ban the application of glyphosate and 2,4-D based herbicides within municipalities in recognition of the health and environmental impacts, they have taken the opposite approach to forestry. Interestingly, the government proposes to ignore the fact that the province of Quebec banned the application of chemical herbicides by the forestry industry in 2001. They have forced the same multinational forestry corporations who operate in Quebec (and Ontario) to perfect a variety of non-chemical tools to replace chemical herbicides, presently applied in Ontario to regenerate conifer seedlings. However, Ontario divisions of the multinational corporations then insist that in Ontario, herbicides are an absolutely necessary tool to regenerate the forest. ALTERNATIVES TO CHEMICAL HERBICIDES INCLUDE: - Planting larger, nutrient loaded seedlings immediately after harvesting as opposed to waiting years after harvest to replant 2” seedlings. - manual tending (machete) - mechanical tending (brush saw) - animal grazing (sheep / cows / horses) - controlled fire burns Manual release (machete) techniques are widely known to greatly increase local employment opportunities for forest dependent communities. As the boreal forest runs across all of Canada and most of the northern hemisphere (maps), the tools used in Quebec and Scandinavian countries to replace chemical herbicides are similarly available for use in Ontario's boreal forest (maps). Chemical contamination of the headwaters that supply our drinking water is a serious concern. A little over seven years ago, the combination of source water contamination and an inoperable water filtration system had deadly consequences for many in Walkerton, Ontario. Justice O’Connor made many recommendations to prevent future incidents, one such being that we implement a multi-barrier approach to ensure the safety of Ontario’s drinking water. He stated, “Source protection keeps the raw water as clean as possible to lower the risk that contaminants will get through or overwhelm the treatment system.” (Walkerton Inquiry  - Chapter 3) Even large and expensive water filtration plants, such as those used in Ottawa and Toronto, are ineffective to remove chemical herbicides and pesticides from drinking water before it is delivered to the public. In a report titled “Up to the Gills, Pollution in the Great Lakes Fish”, Environmental Defence notes fish consumption advisories due to toxic contamination of the Great Lakes watershed. In regards to pesticides, the report indicates, “Pesticide exposure is linked to non-Hodgkin's lymphoma, leukemia, neurological problems, reproductive abnormalities, immunotoxicity and cancer. Children are at particular risk from pesticides because they are more vulnerable to the effects and have greater exposure to the chemicals. While some municipalities around the Great Lakes have instituted bans on cosmetic pesticide use, there is still widespread use in the Great Lakes basin for domestic, commercial and agricultural purposes.” The effect of acute exposure to these chemicals over decades is largely unknown, as is the effect of exposure to multiple pesticides simultaneously. According to Tony Clement, Canada's Minister of Health, ”The PMRA requires laboratory toxicity studies on standard surrogate species in order to predict effects of active ingredients and their formulations on non-target species. The PMRA does not receive information concerning environmental interactions with other pesticides when considering registration of pesticides in Canada.” (December 21, 2007 Letter) Concerns have been raised by Joel Theriault for STRONG, WhiteMoose, and NAFA to the Auditor General and the Environmental Commissioner.  Auditor General Petition # 214 - AG web Environmental Bill of Rights Submission Ontario Ministry of Health - Petition Response Environment Canada - Petition Response Please call your MPP and explain why its important to you that Ontario mimick leading jurisdictions like Quebec and Scandinavia, follow the advice of our family doctors and senate sub-committee, and finally implement the known alternatives to chemicals herbicides in Ontario's boreal forest. Please sign and support the Petition below:   http://www.petitiononline.com/4nospray/petition.html         Glyphosate-grazing2 [410.66K]

PETITION-NON ESSENTIAL CHEMICAL HERBICIDES [379.15K]

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