Synthesis of Public Comment >

Expectations

Participants were asked what issues they want to see addressed during the review of the Agreement and three questions were used to probe for responses:

• Are you concerned about the quality of groundwater and surface water near where you live? If so, what concerns you?
  
  
• Do you have concerns about other components of the Great Lakes-St. Lawrence River ecosystem? If so, what are they?
  
  
• Is government action required to address your concerns? If so, which level of government should that be: municipal, state, provincial, federal or international?

Water quality
Sewage and land use
Aquatic invasive species
Aquaculture
Protection of wetlands
Contaminated sediments
Economic issues
Monitoring
Water quantity
Great Lakes-St. Lawrence Seaway
Accountability

Water Quality

Water quality was the primary issue that participants in the public meetings want to see addressed. "The first thing we would all expect would be clean water," said one elected official in a shoreline community along Lake Huron: "I don't think that is asking too much, knowing that we are the keepers of the largest natural bodies of fresh water in the world."

A retired environmental scientist was just one of the many people who made a similar point, this time during the Web dialogue:

In fact, good water quality was a universal theme underscoring virtually all of the comments in the public meetings, web dialogue and other forums. Clean water was seen as a boon to health and a healthier future for the lakes and their people, as well as to tourism and recreation. In different versions, a remark by one participant was heard across the basin: "The reason why we are concerned about the water quality of the Great Lakes is, of course, because it is a food source and because of the quality of life in general."

There also was a pervasive feeling that the public's expectations for clean water are not being met: "We talk about water quality," said one person in a version of what was heard elsewhere across the basin, "and you don't see it getting any better."

Many other participants made similar statements:

Beach closings were a frequent indicator used to assess the quality of water. "One of the reasons I am here this evening," said a local elected official, "is that, in my township, our beaches have been closed for the last five years because of elevated levels of E. coli, and that is of great concern to all the residents of our community." Or a mother, worried about the welfare of her family: "Here, on Lake Superior, we have had many beach closings over the last few years since our beaches have been tested, and I am concerned about that."

The health and survival of wildlife was another concern of many participants:

Some participants integrated the various aspects of water quality into a vision for a healthy Great Lakes basin ecosystem. According to one written submission from an ongoing roundtable discussion of Great Lakes stakeholders, "the current and emerging review of the Great Lakes Water Quality Agreement provides a particular opportunity to advance a vision." The submission provided a statement envisioning that "the people of the United States and Canada will work together as stewards to protect and improve the unique shared Great Lakes and St. Lawrence resource for use by future generations." The statement articulates specific goals for the environmental, economic and social well-being of the Great Lakes and St. Lawrence region.

Sewage and Land Use

With respect to sources of pollution, issues related to sewage were universally raised in the public meetings, Web dialogue and written comments. A common remark was voiced by one participant about his municipality: "Every time it rains, any little bit of rain or a little snow melts, they just open their tunnels up and dump it in the lake." Another person complained that, like 14^th century medieval villagers, contemporary society treats rivers as sewers: "It is incredibly discouraging," he said, "to read in local newspapers, after even minor rainfall, that hundreds of thousands of gallons of raw or partially treated human sewage have been dumped in the Saginaw River and, ultimately, the bay, the source of our drinking water." One organization representing millions of people engaged in outdoor recreation called for stiff penalities in cases of municipal sewage overflows: "Severe consequences should be levied against municipalities that continue to discharge sewage and contaminate the water with pathogens and bacteria."

Land uses, especially urban development and agricultural operations, were also cited in most of the sessions as contributing significantly to water pollution. One participant, a consultant, captured the point made by many others when she said that, "Many environmentalists and government officials view out-of-control development as one of the top threats to a sustainable ecosystem." Another person made a similar point in a written submission:

The practice of using manure as fertilizer was generally cited as a water contaminant and a risk to health. A popular refrain was expressed this way by one participant:

Another person, a local elected official, said that industrial agriculture has been prevalent in her county for ten years: "We all feel that the waters are being compromised through this type of land use. We're seeing nutrient overloads and high levels of E. coli."

Some farmers, however, contested this assessment, saying that agriculture has made many positive contributions to water quality: "Best management practices have been hammered down to farmers for many, many years already ... and many of those practices are routinely done all the time."

Agricultural practices also arose during the Web dialogue and were blamed for other effects as well:

Another land use issue was garbage disposal sites and their impact on the ecosystem:

For these reasons, many participants urged that the review look at land use in the broadest sense. In a written submission, one participant summarized the issue as follows:

Aquatic Invasive Species

Participants in the public comment process frequently cited aquatic invasive species as one of the main issues that should be addressed during the review of the Agreement because of the scope of its impact on the ecosystem and economy of the basin. Some argued that this issue fit into the current Agreement's focus on addressing the impacts of pollution:

Comments on the aquatic invasive species issue are described in greater detail in the section below on the Scope of the Agreement.

Aquaculture

Like industrial farming, open-cage aquaculture was cited by many participants as a significant cause of water pollution. The concern is that waste from these operations flows into surrounding water or settles onto the lake bottom to build up in a thick sludge, consisting of uneaten feed and fecal matter that depletes oxygen levels, generates methane and causes other environmental problems. Typical comments include the following:

It was stated that, "There are proven, alternative methods for rearing fish for protein consumption, and this clean aquaculture has been undertaken for centuries and centuries." Land-based aquaculture was generally seen as a preferred technology because, as one participant said: "More than 90 per cent of the water in a recirculating system can be treated, pumped back into these tanks, recycled and the waste products used as fertilizer, for example."

Protection of Wetlands

The loss of wetlands was a recurring issue in the public meetings, Web dialogue and written comments. Wetlands, it was noted many times, filter and remove pollutants and absorb nutrient loadings from shoreline development, and their degradation was a matter often proposed for inclusion in the review:

The loss of wetlands was attributed to many factors, including large-scale agriculture, development infilling and fluctuating water levels. One participant stated that, in some locations, significant declines in water levels have caused losses of wetlands that "cannot be restored because the adjacent steep granite shorelines do not support that." At the same time, however, it was noted that low water levels have seen the return of some coastal wetlands, and concerns were expressed that this phenomenon is sometimes compromised by property owners:

Contaminated Sediments

There was a widespread sense of frustration and resentment that contaminated sites are not being cleaned up. An Aboriginal woman spoke about a former glue and animal hide factory that polluted the creek where she and her sisters played as youngsters, swimming in the water and eating the berries and rhubarb that grew alongside it. "The list of toxins that place still puts into the water is extreme," she told a public meeting. "This plant has been closed for over 20 years. EPA recently came up with a decision to leave it in there. And it contaminates our creek, it contaminates Lake Erie."

Others, including a Mayor during the Web dialogue, made similar comments:

Economic Issues

A widespread notion was that preventive action is far less expensive than remediation. This was often discussed in terms of making the Agreement more proactive, identifying and eliminating problems before they emerge rather than having to deal with them after they have become apparent. One participant, referring to the estimated restoration price tag proposed by the recent U.S. Great Lakes Regional Collaboration initiative, said: "We won't have to spend $20 billion to restore it [Lake Superior] if we do some things now to protect it." This refrain was heard many times:

Good water quality was seen not just as a human health or environmental issue, but also as something that impacts a community's economic development. "It's extremely hard to promote our community as a tourist destination, for new business growth, when frequently, with very little rainfall, we get our news reporting that we have combined sewage overflows," said one participant. Sewage discharges were also seen as an economic burden on industry, local governments and taxpayers: "It's costing anybody that has water from the lake an extra fee because they have to purify that water," said one person.

Economics also figured in another way, when some participants advocated putting an economic value on ecosystem services (that is, the benefits derived from the environment): "When it comes to ecosystem services, most people don't have a clue - other than they have a passion for it. They can understand an inherent value, but when it comes to the decision-making process, that's not at the doorstep, it's left outside the process. And I think that, as a society, we need to start putting that back in or put it in the concept." Such circumstances, it was suggested, would lead to changes in, for example, decisions regarding coal-fired plants, air quality emissions and regulations.

A representative from a regional industry organization suggested that a revised Agreement could and should be supportive of the sustainable development of the Great Lakes region while guiding basin policy in its management of the waters of the Great Lakes:

Monitoring

Water quality monitoring was widely seen to be in need of improvement through further investments in equipment, personnel and activity. A member of the Public Advisory of a delisted Area of Concern cast the issue this way:

Several participants complained that water testing seems to be limited to E. coli: "How many other organisms are there in beach water that we can't test for because we just don't have the money for, you can only guess," said one person. "But there are many pathogens out there that are much worse than old 157H7, the E. coli that killed people in Walkerton."

One scientist suggested that in order to really understand or know the concentrations of nutrients in the water, samples need to be taken in winter when there are minimal periods of daylight and a reduction in the level of phytoplankton. "Without this, you can't say clearly what's going on."

In addition to water quality, some participants raised the issue of air quality monitoring. An environmental graduate student recalled his experience during a summer research job: "We would come up the river from the corner, about a kilometer past the bridge, and it was all we could do not to breathe. It was disgusting. We would see, at certain times of the day, the smoke coming from the stacks ... the smoke would turn from white to yellow to orange. And I just don't know if those things are being monitored."

The consistency of monitoring activities was also questioned, with several participants noting that the various jurisdictions have different requirements in terms of collection procedures and standards:

In addition to gaps in monitoring and consistency in data collection, there were concerns about how the information is used and about potential overlap and duplication. One expert put it this way:

Another issue that arose in connection with monitoring was the perceived need to make data more accessible to the public. The very first email submission to the Commission touched on this point:

Water Quantity

Although the Agreement deals with water quality, water quantity was very often raised during the public meetings, and many people established a link between the two themes. Said the program manager of a regional environmental organization: "One issue that the Agreement does not take account of is water quantity. ... Periods of very low water levels or available water affect the quality of water and the uses of water."

The issue was also raised during the Web dialogue by several participants. "If there is a drop in water levels," one wrote, "an increase of storm runoff or pollutants will become more concentrated and need further and more intense purification for drinking water to be safe for the general population."

This view was shared among many participants. One, for example, stated that low water levels "will negatively affect river flows, increasing pollutants in directly inverse proportions."

The Chicago diversion was an issue that attracted much comment: "The water that is there [in the Great Lakes basin] should stay in there. It should not be shipped over to the Mississippi basin, like is being done in that Chicago ship canal," said one U.S. participant. This comment was echoed in Ontario, where the diversion was seen as undermining the Great Lakes Water Quality Agreement:

In Quebec, too, the issue was a hot topic. One member of a regional environmental council said that people in that province think that diversions from Lake Michigan amount to water takings from the St. Lawrence River: "In the area where I live," he reported, "diverting St. Lawrence water to the Mississippi is a major issue, a critical point." Another Quebecer linked the Chicago diversion and the Annex 2001 negotiations in terms of impact on the province: "All of these factors reduce or intend to reduce the quantity of water in the St. Lawrence River." And, he went on:

Proposed resolutions to this widespread concern included reviewing the U.S. Supreme Court decision that confirmed the Chicago diversion or establishing an international governing board for the Lake Huron-Michigan basin, similar to the Commission's boards for the Lake Superior and Lake Ontario-St. Lawrence River basins. Many people also urged that the matter be addressed by the Great Lakes Water Quality Agreement.²

Great Lakes-St. Lawrence Seaway

Some concern for ecosystem impacts was raised in connection with periodic proposals to deepen and widen canals in the Seaway, and build larger locks to accommodate PANAMAX ships (so called because they are of the maximum dimensions that will fit through the Panama Canal). One participant opposed to Seaway expansion expressed the concern as follows:

Accountability

Accountability for implementing the Agreement and addressing the public's concerns was a major theme, with participants complaining that the Agreement does not provide adequate mechanisms that ensure accountability. "We would like achievement of its objectives to be made the responsibility of institutions or organizations in a very precise way," said one participant during the Web dialogue. "It would also be desirable to establish time lines for these objectives to be achieved; the Commission could subsequently evaluate the progress made."

Most people assigned major if not exclusive responsibility to the two federal Governments. A former senior official in an environmental agency put it this way during the Web dialogue: "The Great Lakes Water Quality Agreement should include enforcement provisions that allow the Commission, state and provincial governments, NGOs (non-governmental organizations) and citizens to hold the federal governments accountable, in court, if they fail to implement the Agreement." Overall, suggestions that accountability provisions be added to the Agreement attracted considerable support.

Some participants, however, believed that accountability rests with state and provincial governments as well. As another retired environmental official put it, this time in the Canadian context: "It's very important, that what gets put into this Agreement, if there are revisions made, that they be very specific and provide little wiggle room for the federal and provincial governments, either one, to slide out of commitments."

Finally, others argued that municipal governments should also be accountable. A university professor put it this way: "It is clearly up to local governments to invest in actions that improve the lakes - sewage treatment, land use, etc. - yet local, state and provincial governments have absolutely no accountability or governance mandate under the Great Lakes Water Quality Agreement. There is a tremendous opportunity for change during the review."

The question of accountability figured in many comments about effectiveness, and a number of people including several mayors - made a case for including local governments in the Agreement. These issues are addressed in the sections below on Effectiveness and Scope.

² Note from the IJC: The Chicago diversion, which has been confirmed by the U.S. Supreme Court, became operational in 1900 (predating the Boundary Waters Treaty by nine years). The amount it removes from the Great Lakes is less than the amount diverted into them at Longlac and Ogoki, Ontario. The Longlac and Ogoki diversions began operation in 1939 and 1943 respectively.

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