Let’s celebrate! Your Great Lakes toxic hotspot is about to be erased from the International Joint Commission’s Areas of Concern map. In three instances this celebration has occurred. For forty other communities, grit and hard work is trying to bring that day forward.
But what does it mean to be delisted?
As we work to meet a clean up objective that ensures the area is “fishable, swimmable and drinkable”, isn’t it reasonable for the public to make the assumption that we have met those targets when we announce that the toxic hotspot is being delisted? Of course it is. Yet, even when delisted, communities still face fishing advisories and the water must be treated before it is drinkable.
Fishable?
The first area of concern to be delisted was Collingwood Harbour in Ontario in 1994. Fifteen years later, the provincial government’s guide to sports fish consumption still calls on people to avoid or limit their consumption of fish caught in the harbour.
These warnings are the result of the levels of mercury, PCBs, mirex, pesticides, polycyclic aromatic hydrocarbons, and dioxins and furans measured in the fish. For example, the Ministry of the Environment asserts that “sensitive populations” should not eat any pink salmon or whitefish that are over 45 centimetres (18 inches) in length caught in Collingwood Harbour.
How can Collingwood Harbour be considered ‘cleaned up’ if the fish are still contaminated with a toxic soup of chemicals and metals?
An Area of Concern can be officially delisted if it is determined that the contamination of the fish is no longer a result of local sources. Instead, the fish consumption advisory is as a result of contaminants washing in from the lake or dropping from the air from sources outside of the area.
When the announcement was made in July 2006 that the lower Oswego River in New York State was no longer an area of concern, Dr. Christopher De Rosa, then Director of the Division of Toxicology for the U.S. Agency for Toxic Substances and Disease Registry, urged the governments to be cautious in their announcements so as to not mislead the public into thinking that the waters are now truly “fishable” without limitation. He pointed out that we should still be warning people to limit their fish consumption.
Swimmable and drinkable?
Severn Sound, which is in a major cottage and tourist area in southern Georgian Bay in Ontario, was delisted in January 2003. The report that justified the delisting said that the objective for swimmability “can be considered to have been met.”
This conclusion was reached despite the fact that the same report stated all swimming areas in Georgian Bay Islands continue to be posted “swim at own risk” and that the area off the Coldwater River wharf is posted “No Swimming: Contaminated Water.” Midland Beach bacteria levels exceeded provincial standards in 5 to 10 percent of the samples. In other words the area was delisted despite the fact that it is only swimmable in some places, some of the time.
Similarly, the drinkable goal doesn’t mean that you can go and drink straight from the waters. For example, Michigan’s guidelines for delisting state that the “drinkable” goal is met if the water is safe to drink after the use of standard water treatment methods. A similar criterion for the drinking water goal is found in all jurisdictions.
What needs to happen after delisting?
We must be cautious when we delist an area of concern. We must make sure that our celebratory news announcements are tempered with cautions to the residents that they should not assume that the waters are now “fishable, swimmable and drinkable” without restriction.
In addition, at the same time as we celebrate the delisting of the toxic hotspot, we need to publicly commit ourselves – as governments, industry, environmental groups and the public who worked on the RAP – to continue with our work in at least three areas.
Firstly, we must work in the broader Great Lakes arena for the elimination of pollution sources beyond our area of concern that are affecting the local area. As Collingwood Harbour demonstrates, contamination doesn’t follow city limits. Our communities are interconnected and only by eliminating pollution can we truly overcome the toxic burden.
Secondly, we must work for continued improvement of the area so that the environment is enhanced beyond current conditions. Meeting the minimum standards of cleanliness is no different than celebrating a ‘C’ grade on a report card. Delisting isn’t the end of a journey, it’s the start of a new effort to truly revitalize a community that has turned its toxic tide. We must take advantage of the momentum delisting creates.
Finally, we must be strong watchdogs to ensure that there is no backsliding and that no new threats are introduced to the former area of concern. Delisting isn’t immunity. New threats are constantly emerging. We must use the knowledge and experience gained through the past to safeguard us against the threats of the future, and to act swiftly when pollution problems re-emerge.
Delisting is a time for celebration. But this must not be blind revelry; it must include cautions and long-term commitments. The pride of the community and the effort of the people whose hard work made the celebration possible deserve nothing less.
This is an important cautionary note, especially considering the political motivations sometimes present in declaring the delisting of beneficial use impairments