Forty-one citizens’ groups have jointly conveyed their dismay that the indications the negotiators have been giving us in the limited information they have made available to the public appear to contain serious setbacks for the GLWQA.
These groups from throughout the Great Lakes basin made a joint submission in September to the negotiators at the end of the critical final stage for public comment on the renegotiation of the Great Lakes Water Quality Agreement. Our shared concerns include:
· The vision and scope isn’t bold enough for the times and the challenges ahead.
· The urgency for action is not present; planning processes appear to be further extended. After almost 40 years, we know enough to act.
· The overall design and strategy of the new Agreement appear to result in a loss of specificity, clarity, transparency and continuity.
· The proposed binational government structures appear to do little to build constituencies, promote participation, or foster transparency to improve and sustain the Great Lakes.
· Timelines, benchmarks, chemical lists and targets are the muscle of the current Agreement; without them a new Agreement would have little weight or value.
· There has been no overall evaluation of the Remedial Action Plans (RAPs) program. Without that evaluation, how can we properly revise the RAP strategy to address its shortcomings?
· Lakewide Management Plans, a Nearshore Framework, Watersheds, Tributaries, and Groundwater appear to be the core of the new Agreement, but the strategy and mechanisms underlying these are completely unclear.
· Critical threats such as mining and the use, transportation, and disposal of radioactive materials are missing.
· The Great Lakes-St. Lawrence River ecosystem is truncated part way down the St. Lawrence River.
· The addition of climate change is welcomed, but the described focus of the anticipated climate change annex falls far short of the need for a visionary and anticipatory strategy for climate change in the new Agreement.
We call upon the government negotiators to respond to these concerns as they continue with their negotiations. The future of the Great Lakes and St. Lawrence River and all their inhabitants are depending on the negotiators to ensure that the new GLWQA takes a significant leap forward in laying out a strategy and commitments for the long-term well-being of the ecosystem.
The full citizens’ groups comments are available at http://www.glu.org/en/system/files/ENGO%20GLWQA%20Comments%20Sept%2020%2C%202011.pdf