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E-M:/ Comments needed on Great Lakes agreement by 3/8

From: "Jennifer Nalbone" <jen@glu.org>
To: "'Jennifer Nalbone'" <jen@glu.org>
Subject: ACTION  NEEDED on the Great Lakes Water Quality Agreement by 3/8
Date: Fri, 4 Mar 2005 12:24:29 -0500
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Comments due on the Proposed Review Process for the US/Canada Great Lakes Water Quality Agreement!
Great Lakes United (GLU) and the National Wildlife Federation (NWF) are encouraging broad participation in the Review of the U.S.- Canada Great Lakes Water Quality Agreement.  The Canadian (al.jamal@ec.gc.ca) and American (mark.elster@epa.gov) governments are inviting comment on the Proposed Review Process (find the proposed review process at the Environment Canada website: http://www.on.ec.gc.ca/greatlakes/default.asp?lang=En&n=59A1BCDB-1
) through to Tuesday March 8, 2005.   Also attached for your information and use are joint comments of GLU and NWF.  Your organization can endorse the comments below by emailing John Jackson (jjackson@web.ca) before end of business Monday March 7, 2005. 
What is the Great Lakes Water Quality Agreement? Go to: http://www.ijc.org/rel/agree/quality.html
For more on the Great Lakes Water Quality Agreement Review process, go to: http://www.ijc.org/rel/agree/review_glwqa_e.htm
March 8, 2005
Al Jamal                                                           Mark Elster
Interagency Program Co-ordinator                    Senior Program Analyst
Great Lakes Environment Officer                      Great Lakes National Program Office
Environment Canada                                         US EPA
4905 Dufferin Street                                         77 W. Jackson Blvd. G-17J
M3H 5T4                                           Chicago, Illinois  60604
RE:  Comments on Great Lakes Water Quality Agreement: Proposed Review Process: 2004
We are pleased that Canada and the United States are launching a review of the Great Lakes Water Quality Agreement. This Agreement is an essential forward thinking document, which has helped provide visionary leadership on how to address the problems in the Great Lakes ecosystem. The visions and tools in the Agreement have had impacts far beyond the Great Lakes ecosystem, since it has stimulated similar actions elsewhere in the world. It is timely to assess how well the GLWQA has been implemented and whether changes are needed in the implementation of the Agreement or in the Agreement itself.
We generally support the review approach being proposed by the governments. We have only a few comments:
      Need to review the implementation of the Agreement as well as the wording of the Agreement itself: In ?The Overarching Questions? section in Chapter 3: Review Questions, for example, in each question ?implementation? needs to be added. The problem may be the failure of the governments to implement the Agreement rather than the Agreement itself being the problem. Each question should be divided into two parts: 1) a discussion of implementation and of whether it needs to be improved, and 2) a discussion of the Agreement and of whether it needs to be improved. If implementation is determined to be the main problem, one of the mechanisms for improving the implementation may be changes to the Agreement among other mechanisms.
      The GLWQA needs to be seen as a leading-edge document rather than a mere statement of the existing: Under the questions on ?relevancy? in Table 1: Evaluation Framework, is the question: ?Are the articles/annexes compatible with current domestic laws and policies of each country?? This implies that the Agreement should follow the policies and programs already set by each country. One major value of the Agreement should be that it is a document that pushes governments to look at new, improved goals and ways of addressing problems. Therefore, this question is not appropriate.
      Public involvement: We support the proposal to include non-government people on the ?Review Working Groups.? The governments must make resources available to help non-government people participate on these working groups. In addition, the public should be given the opportunity to comment on findings and recommendations from the ?Agreement Review Committee? to the ?Binational Executive Committee? before the BEC makes decisions. Likewise the BEC?s draft report to be conveyed to the governments should be put out for public comment.
      Role of the International Joint Commission: The governments have committed to giving the IJC a role in the public consultation around the review of the Agreement. The IJC has experience at conducting consultations and, therefore, may well be an appropriate body to conduct such meetings. We have concerns, however, that the public will become confused about who is conducting the review and who they should be speaking to and holding accountable for the review when the IJC is conducting the consultation. It is essential that it be made very clear by the IJC that they are conducting the consultation for the governments. The IJC should be careful to convey to the governments the findings and recommendations that the public brings to them as they received them ? not through the prism of the IJC?s own views. As a body that has an essential role in the implementation of the Agreement, the IJC should convey its own findings and recommendations to the governments, but these should always be contained in documents separate from those that convey the results of the public consultation.
Thank you for the opportunity to comment on the review process. We look forward to participating in this review.
Your organization can endorse these comments by emailing John Jackson (jjackson@web.ca) before end of business Monday March 7, 2005.

Jennifer Nalbone

Habitat and Biodiversity Coordinator

Great Lakes


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Great Lakes United staff represented by UAW Local 55

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