December 21 st , 2004

International Joint Commission,
Secretary Canadian Section,
234 Laurier Avenue West 22 nd Floor
Ottawa, Ontario

International Joint Commission
Secretary, United States Section
1250 23 rd Street NW Suite 100
Washington DC 20440

Comments Re:

International Missisquoi Bay Task Force Final Report to the International Joint Commission (20/10/04 )

As President of the National Council of Women of Canada (NCWC), which has a long standing interest in the protection and enhancement of the Great Lakes and St. Lawrence River eco systems I am pleased to have the opportunity to comment on the October 20 th 2004 report of the International Missisquoi Bay Task Force to the IJC.

NCWC represents many thousands of Canadians across Canada, through our member organizations of 18 Local Councils of Women 5 Provincial Councils of Women and 27 Nationally Organized Societies eg. National Association of Women and the Law, Canadian Victorian Order of Nurses. This past year at our Annual Meeting in Edmonton these member groups voted to strengthen NCWC policy on the protection of the Great Lakes – asking for instance, that the government of Canada :

“ support the Great Lakes Water Quality Agreement, its 1978 and 1987 Protocol Commitments, and the Annex 2 Commitments on Remedial Action Plans for Areas of Concern, through funding and strong legislation and enforcement, and strengthen the Agreement through new Protocols when necessary.”

Mindful of this important issue, over the past several months various NCWC members have attended meetings related to threats to the long term future of the Great Lakes. For instance, Anne McLeish (representing le conseil provincial des femmes du Québec) attended a meeting regarding the Missisquoi Bridge Project, where it was apparent that there is considerable public concern regarding such important issues as very significant phosphorus loadings, increased amounts of toxic blue green algae and vascular aquatic plants, threats to human health and safety eg. closed beaches, and the need to protect the habitat of the spiny soft shelled turtles.

Upon review of the International Missisquoi Bay Task Force report it is obvious that it confirms these public concerns as valid, and seeks to meld them with the scientific

studies done in 2003 and 1997, recently commissioned reviews of the 1997 studies and responses from the study authors, in order to advise the IJC as to the wisdom of removing the Missisquoi Bay causeway.

We note that although the general expert review opinion appeared to find the 1997 studies valid, there were several caveats , even from supportive scientists. For instance, although reviewer, Marc Simoneau of Environnement Quebec, stated that :

“ I believe that the IJC now has enough technical information to make an informed decision regarding the partial or complete removal of the two causeways”,

he had earlier noted some shortfalls in the studies eg

“ at no time does the author ( of Study 2) document the presence of macrophytes in Missisquoi Bay, which is unfortunate”.. “ I assume the model was calibrated using drogue-derived current-measuring data, which as I mentioned earlier , appear very low to me” …. “The current measurements (speed and direction) made with a current meter..were limited to the zone between the two causeways of the bridge: it is unfortunate that this equipment was not used for several cross sections within the bay as this data could have been used to calibrate the model.”… The S4 current meter , which was supposed to take Eulerian current measurements failed to work…finally, few data from these two survey campaigns can be used to calibrate the model, which is disappointing in hindsight .”

Further to this, Maurice Sydor Chief, Data Integration Modelling and Analysis Watershed Management & Governance Branch. Environment Conservation Service, Environment Canada, noted the following:

“ It has not been determined what might be the longer- term impacts from a continuous modeled period that include changing perameters within the system, such as weed growth for example”…. From a water quality point- of- view there definitely needs to be a better understanding , but the data associated with hydraulics may not always be “in sync” with water quality data. Both need to be properly co-ordinated so as to obtain the maximum amount of consistency within the system as well as at those points considered to be boundary limits of the problem area.”… and finally, perhaps most tellingly .. “but I do know that we are no where near saturated in data in this particular project .

Given the apparent contradictions and questions raised in relation to a less- than- current 1997 study, the advice of the Task Force to the IJC to “Rely on the scientific findings” may be over-optimistic, but its advice to “ encourage further research on areas where information gaps were identified ” is important if the right decision is to be made in the interest of protecting this special area of the Great Lakes/River system.

NCWC also supports the Task Force recommendation that the IJC

“ encourage ongoing and planned actions to reduce phosphorous loading to the bay from the watershed ”

This should be bolstered considerably by actions arising out of the 1996 Opportunities for Action basin plan , particularly the most recent actions of the Vermont and Quebec Governments. NCWC is most impressed by the record of specific actions in Quebec ( page 11) such as,

“the inspection of 450 of 550 farm visits have been conducted” .. and “plans to develop at least 115 agro-environmental plans to assist farmers with fertilizer management .”

These plans in both states, and the actions already in motion, show a commitment to solve the very important phosphorous -overload problem. There are other areas in the Great Lakes that could benefit from the same kind of dedication and plans for phosphorous reduction.

Finally, NCWC is most appreciative of the Task Force’s understanding in Recommendation #3 of the very important role of the public in this case. It is their environment to live and work in – and to help protect. . In finding a solution to the task at hand i.e. whether, and how, the Missisquoi Bridge Project should go ahead, we urge the IJC to continue to consult and work with the public towards an environmentally sound future for this area and its inhabitants.


Catharine Laidlaw-Sly

Prepared by: Gracia Janes, NCWC Environment Convener