Great Lakes Virtual Elim. Strategy

[Scott Sederstrom <sederstrom@igc.apc.org>]

        Great Lakes United and 16 other organizations sent the following
letter to Environment Canada and US EPA in response to the Federal Register
notice regarding the availability of the bi-national Virtual Elimination
Strategy and public comment solicitation.  Substantive comments on the
merits of the VE Strategy will hopefully be available in the near future.

Scott Sederstrom
Great Lakes United


August 28, 1996

Ron Shimizu
Environmental Protection Branch
Environment Canada
4905 Dufferin Street
Downsview, Ontario M3H 5T4

Gary Gulezian
Environmental Protection Agency
Great Lakes National Program Office
77 W. Jackson Blvd.
Chicago, IL 60604

        RE: Review of Binational Virtual Elimination Strategy

Dear Messieurs Shimizu and Gulezian:

We are pleased that the Canadian and U.S. governments are continuing to
develop a Binational Virtual Elimination Strategy.  We look forward to the
completion of this critical document and to the implementation of such a
strategy.

The successful development and implementation of a Binational Virtual
Elimination Strategy will require the full involvement of all concerned
people throughout the Great Lakes Basin.  Unfortunately, the way in which
you released the August 19, 1996 draft of the Binational Virtual Elimination
Strategy and the review that you have announced for it are inconsistent with
serious public involvement.

On the US side the Binational Strategy was simply placed on the Federal
Register for a 30-day comment period ending on September 19, 1996.  On the
Canadian side it was couriered to those who attemded the stakeholders'
workshop in Windsor a year ago and these people were given until September
19 to comment.

This review process is completely inadequate and shows a lack of respect to
those who have participated in these deliberations and to those who wish to
participate in them.  It fails in the following major ways:

        * In a letter on September 19, 1995 to the participants in the
Binational Virtual Elimination Strategy in Windsor in August 1995, Ron
Shimizu and Jim Giattina referred to the promise they made at the workshop
"to give feedback on the disposition of your comments."  The US and Canadian
governments have failed to do this.  A revised draft on its own does not
give us feedback.  Feedback involves written comments on the input received
and explanations of how the comments were incorporated or, in those cases
where the comments were not incorporated, explains why they were rejected.

        * The draft has not been adequately distributed.  Simply placing it
in the Federal Register, as it was in the US, or mailing it out to those who
participated in the workshop a year ago, as it was in Canada, is not
adequate.  This excludes those who were not part of that workshop and those
who do not check the Federal Register.  These methods of distribution mean
that only a select few groups are reached.

        * Thirty days to comment on this document is completely inadequate.
This situation is made even worse by the fact that half of this review
period is the latter part of August, a period known by all as a prime period
for people to be away on holidays.  This fact is proven by the messages we
received on government message machines when we called to discuss this matter.

The August 19, 1996 letter sent to Canadian participants in the Workshop
makes it clear that this shoddy public participation is happening because
the governments wish to finalize the Binational Virtual Elimination Strategy
by early October.  The fact that the governments took almost a year longer
to prepart the next draft for public comment than they had originally
planned should not become an excuse for squeezing the time left for public
comment.  Why should the public be put under unreasonable time lines because
the governments expanded the time for doing their revision from one month to
12 months?

We urge you to revise the current plans for public review by undertaking the
following:

        1) Send a response document to all those who participated in the
workshop in Windsor in August, 1995.

        2) Hold another workshop to discuss the revised draft.

        3) After revising the draft on the basis of input received at the
new workshop, put the Strategy out for a sixty-day public comment period and
distribute it widely to concerned groups around the Great Lakes Basin.

We are pleased that the Governments are finally putting together a
Binational Virtual Elimination Strategy, something that the IJC has been
recommending for over a decade.  This critical document deserves serious
public consulation.  That is why we urge you to follow the recommendations
we have made in this letter.

Yours sincerely,

John Jackson, Great Lakes United
Paul Muldoon, Canadian Environmental Law Association
Anne Mitchell, Canadian Institute for Law and Policy
Anne Rabe, Citizens' Environmental Coalition (NY State)
Joanna Hoelchler, Citizens for a Better Environment (IL)
Charles Griffith, Ecology Center of Ann Arbor
Jack Weinberg, Greenpeace
Jackie Hunt-Christensen, Institute for Agriculture and Trade Policy (MN)
Marty Visnosky, Keystone Action Network (PA)
Jan Conley, Lake Superior Greens (WI)
Kira Medlin-Henschel, Mining Impact Coalition (WI)
Ruth Burton, Ontario Toxic Waste Research Coalition
Debbie Ortmann, Regional Environmental Action League (MN)
Daniel Green, Societe pour Vaincre la Pollution
Kris Lee, St. Clair River International Citizens Network
Lois Corbett, Toronto Environmental Alliance