Oh, great. That's good.
I'm going to focus on the Canadian Council of Ministers of the Environment's Canada-wide standard for dioxins. But that is only as an illustration of my point. The same kinds of points could be made about other subjects that are subject to Canada-wide standards, such as ozone or particulate or mercury, or even the CCME guidelines for water quality or risk assessment to determine if a substance is CEPA-toxic.
My illustration using dioxin is about a process I am having some trouble with. I think the problems are endemic to a baroque structure of committees and internecine power struggles that allow government to abdicate its responsibility to protect human health and the environment.
The main conclusions--the take-away messages--are, first of all, that we don't believe CEPA 1999 needs substantive revision. We believe the law is capable of dealing with Canada's environmental problems. There may be the odd fix required, but there's nothing really wrong with CEPA.
The problem lies in the relationship between the federal and provincial governments. Much time and money is being wasted in multi-stakeholder, interjurisdictional consultations that merely confuse the lines of accountability. There is a culture of inadequacy in the bureaucracy among politicians and the ministers who do not have the will to make CEPA live up to its potential to protect the environment and Canadians' health.
Finally, despite all of that, I would say that we do need a mechanism to reactivate the Canada-wide standards system in the event of significant changes, such as technological improvements for pollution prevention, new industrial developments that will change pollution levels, or new science. That mechanism doesn't seem to exist now. I'm not sure you have to rewrite CEPA in order to have that mechanism; you might just need to redesign the process.
My organization, Reach for Unbleached, is a national foundation. It is a Canadian registered charity with a focus on consumer education and pulp mill monitoring. We work for a sustainable pulp and paper industry by making pulp mills clean up and by promoting clean, environmentally preferable paper. Over the last decade and a half, we have worked in alliance with pulp unions, first nations, international environmental organizations such as Greenpeace, and citizens groups in most of the forest towns of British Columbia.
We participated as a member of the Canadian delegation in the negotiation of the United Nations treaty on persistent organic pollutants, the POPs treaty, and we've worked on numerous Environment Canada and British Columbia toxics-related processes. Our work is cited by grassroots campaigns all over the world.
I'm also the editor of the Watershed Sentinel news magazine, which is in touch with dozens, if not hundreds, of other grassroots organizations across the country.
It's a very rare opportunity for a community-based activist to have this chance to present our comments on how we see the workings of government's structure for the control of toxics and to tell you how we ENGOs have to deal with it. We're not offering a legal viewpoint; we're offering a layperson's understanding of toxicology, bureaucracy, and the technology of pulp and paper production.
The system is not broken, but the hands on the levers need to do more than a little heavy lifting. Considerable taxpayer money, and even more volunteer time, is being wasted in these consultations that do not remain focused and do not deliver the pollution prevention Canadians expect. These processes serve to confuse the lines of accountability. In British Columbia, we call this “talk and log”, where we sit and negotiate and the trees are falling outside the window while we talk. That's exactly what's going on with toxics policy in this country.
This is not mandated by CEPA 1999; it's the way it's been interpreted by the governments.
Let me tell you a little bit about myself, then you'll sort of see why I'm coming to these conclusions. My home is on a small island off the coast of British Columbia. I moved there in 1987 to live a quiet rural life. My partner and I were growing our own food and were working as clam diggers to earn a little extra money. Our island, having finished logging its old growth forest, was and is heavily concentrated on family operations growing oysters for the export market, but in about 1989, trouble started in paradise.
At that time, fisheries closures were beginning to spread along the coast of British Columbia because of dioxin contamination of the shellfish from chlorine bleaching pulp mills. Eventually about 120,000 hectares of foreshore were closed to crab and shellfish harvesting, of which more than half remains closed to this day.
On our island we were threatened with economic disaster, so we were looking for a solution. That's why the name of my organization is Reach for Unbleached, because if the pulp mills weren't using chlorine to bleach their product, if they were using unbleached or, alternatively, making bleached paper, there wouldn't be any dioxin and then our oyster fishery would be okay. So that's where we came from.
I don't have time to take you through the whole process of multi-stakeholder meetings, scientific twists and turns, market scares, job blackmail, the harmonization agreement with the Province of B.C.--which wasn't very harmonious, and the federal and provincial governments never renewed it--and then lots of B.C. elections, although the B.C. elections tend to be a lot more fun than the rest of it.
In summary, the federal government declared dioxin CEPA-toxic and subject to virtual elimination. It then acted to stop the outpouring of dioxin by using a regulation under the Fisheries Act that prohibited the mills from putting dioxin out in their effluent. It was a strict command and control regulation, and it worked. Dioxin levels in effluent plummeted.
In my paper, there's a description of dioxin's health impacts, the fact that it's slated for international ban under the POPs treaty, etc., but I'm going to skip that in the interest of time.
However, given all of those things, including the EPA's science reassessment of dioxin's health impacts at very, very low levels, it's not too surprising that Canada continued with its dioxin elimination program by developing Canada-wide standards. What is surprising, given the elimination mantra under which the CWS was justified, is that the process focused only on airborne emissions of dioxin, not on the creation of dioxin. This is a directive of the national advisory committee that seemed absolutely impossible to change when we got down to discussing the nuts and bolts of dioxin production.
British Columbia was given the lead as champion of the dioxin Canada-wide standard, and our organization and numerous others from coastal communities followed through on the process. Pulp mills were burning chips from wood that had been towed in the ocean. By being in the ocean, the wood soaked up salt, then when they burned those chips they made dioxin. That's the nub of the problem, but the really important part is that the Canada-wide standard was only looking at the airborne emissions instead of at the creation of dioxin. Most of that dioxin actually goes into landfill, rather than up the stack and out into the air.
However, we did manage to get pollution prevention written into the Canada-wide standard after about two years of committee infighting. Unfortunately, the pollution prevention turned into a bit of a bad joke. Many expensive and time-consuming meetings later, to which we coastal environmentalists donated our time, consultants' reports proved to almost everyone's satisfaction that it was far too expensive to consider taking the logs out of the salt water, that the salt could not be washed out of the wood chips, and that it was okay, because the dioxin was sealed away forever in the pulp mills' landfills.
Many of these landfills have no liners. In cases where there have been tests, dioxin frequently shows up in the leachate and in the groundwater around the landfills. In any event, the best of these landfills is only built for a hundred-year weather event, and I think we're looking at a little more than that these days.