The Canadian Environmental Law Association (CELA), Chemical Sensitivities Manitoba, Ontario Rivers Alliance, Ottawa Riverkeeper, Prevent Cancer Now and Citizens Network on Waste Management are submitting the following comments in response to the Canada Gazette publications (Vol. 150, No. 48 — November 26, 2016) for the Publication of final decision after assessment of a substance — phenol, 5-chloro-2-(2,4-dichlorophenoxy) [triclosan], CAS RN (3380-34-5) and Canada Gazette (Vol. 150, No. 50 — December 10, 2016) for Order Adding a Toxic Substance to Schedule 1 to the Canadian Environmental Protection Act, 1999 (CEPA 1999). In addition, we are also offering comments on the proposed Management Strategy for triclosan.2
by Mike Wilton, April 26/13
“Recently, The International Joint Commission (IJC) formed a body called The Great Lakes St. Lawrence River Adaptive Management Task Team (GLSLRAMTT). The need for this team apparently stems from the fact that water levels in the Great Lakes are going to become more erratic through time, mainly as a result of Global Warming.
While Global warming has by now been accepted as factual by the majority of citizens, history has proven that the future is somewhat difficult to predict, e.g. Environment Canada’s 7-day weather forecast.
“Adaptive” is defined by The New Lexicon Webster’s Encyclopedic Dictionary as “tending or able to adapt”. “Adapt” is defined as “to put oneself in harmony with changed circumstances”.
Who among us has seen circumstances in the natural world change “for the better”? I’m hard-pressed to think of one example. However, countless examples of Humankind’s tinkering with Nature, giving rise to only negative results can be quoted. “Invasive aquatic species – such as the sea lamprey – brought in through the St. Lawrence Seaway” come to mind.
So, adaptive management to me means “adapting to a worsening situation”, which is not management at all, but merely “resignation” with “mitigation”. Perhaps a better name for adaptive management would be “Adaptive Mitigation” – or “Slowing down the inevitable”.
It seems to me that by creating this task team the IJC is drawing attention away from an immediate and proven problem, which is the serious and ongoing loss of water from the Lake Huron – Michigan Basin. This has been well documented through the past decade and is based upon hard facts, rather than conjecture. Many possible and obvious solutions to this problem have been put forth, but the IJC prefers to wait and see, while diverting large amounts of tax dollars to the GLSLRAMTT.
The Webster’s Dictionary defines “conjecture” as “guesswork, opinion or theory based on presumption or insufficient evidence”. To predict the results of global warming at this time is mainly, if not purely, conjecture.
Let’s get on with the job at hand – which is to restore the Lake Huron water level!