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2008 December Report of the Commissioner of the Environment and Sustainable Development

Main Points

What we examined

Established in 1995 as a result of amendments to the Auditor General Act, the environmental petitions process provides Canadians with a formal means to bring their concerns about environmental issues to the attention of federal ministers and departments and to obtain a response to their concerns. Ministers are required to respond in writing within 120 days. On behalf of the Auditor General of Canada, the Commissioner of the Environment and Sustainable Development manages the environmental petitions process and monitors responses of federal ministers. As required by the Act, the Commissioner reports annually on the quantity, nature, and status of petitions received and on the timeliness of departmental responses. This chapter contains this year's annual report on petitions.

Why it's important

Environmental petitions are a simple, unique feature of our parliamentary democracy. Submitting a petition is a way for Canadians to bring their environmental concerns to the attention of federal departments and agencies that are subject to the process. Monitoring and reporting on petitions and petition responses, as well as publishing those documents on our website, contributes to transparency in federal environmental management. The Office of the Auditor General also helps to promote federal accountability for environmental management by considering the issues raised in petitions and the responses they generate when it plans and conducts audits.

What we found

  • This year, we received 56 petitions—a 24 percent increase over last year. While petitions were submitted from petitioners residing in seven provinces and one territory, Ontario accounted for more than half of the petitions received.
  • Human and environmental health, environmental assessments, and water are the top issues raised in petitions this year. More than half of the petitions were grouped around a number of specific issues, with the largest group concerning the effects of exposure to electromagnetic radiation, which we highlighted as an emerging issue in last year's annual report.
  • A number of issues raised in petitions have been of interest to members of Parliament. Issues raised by petitioners have also received media coverage in the past year, ranging from newspaper articles to television documentaries and radio interviews
  • The 200 responses requested from departments and agencies this year represented a significant increase over last year. Environment Canada continues to account for the largest number. The proportion of responses provided within the required 120 days decreased overall, from 95 percent last year to 86 percent this year. Two departments, Environment Canada and Indian and Northern Affairs Canada, accounted for more than 70 percent of the late responses, while Fisheries and Oceans Canada and Industry Canada improved the timeliness of their responses this year.

Introduction

5.1 The environmental petitions process is a formal way for Canadians to bring their questions and concerns about the environment and sustainable development to the attention of federal ministers. The process was created by amendment to the Auditor General Act in 1995. It allows any Canadian resident to submit an environmental petition to the Auditor General of Canada for forwarding to the responsible federal minister or ministers and obtain a timely response. The petitioner may act alone or on behalf of an organization, business, or municipality. The Commissioner of the Environment and Sustainable Development (CESD) administers the process on behalf of the Auditor General of Canada (Exhibit 5.1).

Exhibit 5.1—The environmental petitions process and the role of the Commissioner of the Environment and Sustainable Development

The environmental petitions process was established under the Auditor General Act in 1995. It is a way for Canadians to take action on environmental issues that they care about. The federal government is the focus of the petitions process. The Commissioner of the Environment and Sustainable Development oversees the petitions process on behalf of the Auditor General.

Starting a petition

A Canadian resident submits a written petition to the Auditor General of Canada.

Reviewing a petition

The Commissioner's team reviews the petition to determine if it meets the requirements of the Auditor General Act.

If the petition is accepted, the team will

  • determine the federal departments and agencies responsible for the issues addressed in the petition;
  • send it to the responsible ministers; and
  • send a letter to the petitioner, listing the ministers to whom the petition was sent.

If the petition is not accepted, the petitioner will be informed in writing.

If the petition is incomplete or unclear, the petitioner will be asked to modify and re-submit it.

Responding to a petition

Once a minister receives a petition, he or she must

  • send a letter, within 15 days, to the petitioner and the Commissioner acknowledging receipt of the petition, and
  • consider the petition and send a response to the petitioner and Commissioner within 120 days.

Ongoing petitions activities

Monitoring

The Commissioner monitors acknowledgement letters and responses from ministers.

Reporting

The environmental petitions chapter allows the Commissioner to report to the House of Commons on the number of petitions received, their subject matter and status, and departmental compliance with statutory timelines.

Posting on the Web

The Commissioner posts petitions, responses, and summary information on the Web.

Auditing

Issues raised in petitions are considered for audit by the Office of the Auditor General.

5.2 A petition must be in written form and it must address an environmental matter in the context of sustainable development. The matter must also be the responsibility of a federal department or agency subject to the petitions process. Unlike a typical petition, it does not require multiple signatures; however, it must be submitted and signed by at least one resident of Canada. If the petition is being submitted on behalf of a group (for example, an organization or association), it must be signed by a representative of the group.

5.3 Requests made and issues raised in petitions vary widely. For example, requests may include asking ministers to explain federal policy, investigate environmental problems, examine the enforcement of environmental legislation, or review and improve environmental laws and regulations. Issues raised in petitions over the years include protection of species at risk, environmental and health impacts of contaminated sites or toxic substances, and environmental assessments of projects.

5.4 Once federal ministers receive a petition, they must respond within 120 calendar days. Ministers and departments are required only to respond to petitions within the time periods set in the Auditor General Act. They are not obligated to carry out remedial action to resolve the issues raised by petitioners.

Focus of the chapter

5.5 The purpose of this chapter is to report to Parliament and Canadians on the use of the petitions process and on our monitoring of petitions received between 1 July 2007 and 30 June 2008.

5.6 More details on our objective, scope, and approach are in About the Chapter at the end of this chapter.

Petitions and Responses Received

5.7 Section 23 of the Auditor General Act requires the Commissioner to monitor petition responses from ministers and to report annually to the House of Commons on the number of petitions received, their nature, and their status. This year's annual report also includes a number of observations on the use of the petitions process to highlight good practices and opportunities for improvement.

Use of the petitions process

5.8 This year, we received 56 petitions—a 24 percent increase over last year. Exhibit 5.2 shows that the number of petitions received has increased steadily in recent years.

Exhibit 5.2—The number of petitions received has increased in recent years

5.9 Petitions were submitted from petitioners residing in seven provinces and one territory (Exhibit 5.3), with more than half of the petitions originating in Ontario (32 petitions). Residents of British Columbia submitted the second largest number of petitions (7 petitions), followed by Alberta (6 petitions) and Quebec (4 petitions).

Exhibit 5.3—Petitions came from across the country (1 July 2007 to 30 June 2008)

Map of Canada indicating where petitions came from

[text version]

Petition No. Subject
158B Follow-up petition on subsidies to the oil and gas industry and on federal efforts to address climate change
212B Follow-up petition on airport expansion in Dorval, Quebec
214 Impact of herbicides on fish and fish habitats in northern Ontario
215 Impact of oil sands development in Alberta
216 Request for an environmental assessment of a niobium mine project in Oka, Quebec
217 Environmental contamination at a First Nations reserve in Manitoba
218 Contaminated site in New Harbour, Newfoundland and Labrador
218B Follow-up petition on a contaminated site in New Harbour, Newfoundland and Labrador
219 Environmental impact of federal Metal Mining Effluent Regulations
219B Environmental impact of the Metal Mining Effluent Regulations on fish habitats
220 Collapse of snow crab fishery in Glace Bay Hole, Nova Scotia
221 Health and environmental concerns regarding fluoridation of drinking water
221B Follow-up petition on health and environmental concerns regarding fluoridation of drinking water
221C Follow-up petition on health and environmental concerns regarding fluoridation of drinking water
221D Follow-up petition on health and environmental concerns regarding fluoridation of drinking water
222 Subsidies to the oil and gas industry and federal initiatives for greenhouse gas emission reductions
223 Green procurement and use of recycled paper by federal government departments
224 Science underlying the Kyoto Protocol and Canada's action plan on global warming
225 Protecting Cat Stream and Jingle Pot Marsh in Nanaimo, British Columbia
226 Canada's use and export of chrysotile asbestos
227 Use of letters of advice and operational statements by Fisheries and Oceans Canada: Impact on the environmental assessment process
228 The federal government's alleged failure to inspect coal-fired power plants for mercury emissions
229 Installation of cellular towers in Simcoe, Ontario
230 Impact of cellular phone transmitters on human health
230B Follow-up petition on the impact of cellular phone transmitters on human health
231 Barrel burning
232 Radioactive waste cleanup in Port Hope, Ontario
233 Health risks posed by radiation exposure in Port Hope, Ontario
234 Radioactive contamination in Port Hope, Ontario
235 Health risks posed by electromagnetic radiation exposure from cellular towers
235B Follow-up petition on the health risks posed by electromagnetic radiation
236 Nuclear-related environmental health concerns in Port Hope, Ontario
237 Low-level radioactive waste cleanup project in Port Hope, Ontario
238 Water and sediment contamination of the Athabasca River due to oilsands production
239 Development of the Nahanni National Park Reserve
240 Environmental concerns regarding the Cacouna Marsh
241 Mercury waste from compact fluorescent lightbulbs entering the environment
242 Use of road salt at the 2010 Vancouver Olympics Cypress Bowl venue
243 Use of fluoride (fluorosilicates) in drinking water
244 Harm to susceptible populations of aquatic life and humans due to the addition of fluoride (fluorosilicates) in drinking water
245 Impact of fluorosilicate compounds on lead levels in drinking water and on water distribution infrastructure
246 Potential environmental impacts of a proposed housing development project in Mission, British Columbia
247 Environmental health impact of electromagnetic radiation
248 Environmental impact of toxic chemicals leaking into Lake Ontario
249 Potential environmental impact of the Devils Lake outlet project on Canadian waters
250 Petition withdrawn
251 Federal policy related to potential bulk freshwater exports
252 Environmental health issues related to a hydroelectric transmission project in Tsawwassen, British Columbia
253 Potential adverse health effects from phones using Digital Enhanced Cordless Telecommunications
254 Environmental and human health effects of compact fluorescent light bulbs
255 Health impact of electromagnetic radiation from telecommunication towers located in close proximity to residential areas
256 Policies and regulations under the Canadian Environmental Protection Act, 1999
257 Potential environmental and health impacts of soil contaminated with heavy metal and deposited in a landfill near Lake Erie
258 Alleged pumping of water contaminated with mercury from a brownfield development into a sewer system near Lake Ontario
259 Heath concerns related to the construction of a high-voltage power line in Tsawwassen, British Columbia
260 Electromagnetic sensitivity
261 Public participation process related to the Sydney Tar Ponds and Coke Ovens Remediation Project

5.10 Similar to last year, most petitions continue to come from small groups of people or individual Canadians (68 percent this year), but many grassroots coalitions and local and national organizations also use the petitions process. Other petitioners this year included a First Nations community and an industry association.

5.11 An overview of petitions activity during our reporting period (1 July 2007 to 30 June 2008) is in the appendix. It includes summaries of the petitions received during this period. With the consent of the petitioners, petitions and responses are posted in our petitions catalogue on the Office of the Auditor General website. Petitions are posted on the website only after they have been tabled in Parliament.

Issues raised in petitions

The main concerns are similar to last year's

5.12 As in last year, petitioners' main concerns related to human and environmental health, environmental assessments, and water quality. Issues related to toxic substances replaced compliance and enforcement issues as one of the top concerns for petitioners this year.

The majority of petitions were grouped around specific issues

5.13 Of the 56 petitions received this year, more than half were grouped around several specific issues (Exhibit 5.4). The largest group related to the effects of electromagnetic radiation exposure, which was mentioned as an emerging issue in last year's annual report and was the subject of 11 petitions this year (229, 230, 230B, 235, 235B, 247, 253, 254, 255, 259, and 260).

Exhibit 5.4—Main issues with multiple petitions

Electromagnetic radiation exposure

Five petitions deal with the effects of electromagnetic radiation exposure related to the location of a cellular tower in Simcoe, Ontario (petitions 229, 230, 230B, 235, and 235B). The petitioners express concern about a cellular tower that was installed next to their properties, a school, a hospital, and a nursing home—closer than the federal government's Safety Code 6 guidelines permit and without any public consultation. The petitioners are worried about the health effects of the microwave radiation emanating from this tower, and they allege that, since the transmitter was installed, they have suffered physical, and in some cases, financial and emotional harm.

In petition 259, the petitioners raise similar questions in expressing their concerns about the potential health impacts that the construction of a high-voltage power line in a densely populated area of Tsawwassen, British Columbia, could cause to people living near the power lines.

Other petitions raise general questions on the electromagnetic radiation issue. In petition 247, the petitioner alleges that since 1999, scientific research has indicated an increase in health effects related to electromagnetic radiation from cellular towers and other sources. The petitioner asks the government to review Safety Code 6, to pass regulations for safer siting of cellular towers, and to mandate labelling of electromagnetic radiation levels of everyday products.

In petition 255, the petitioners claim that electromagnetic radiation emitted from telecommunication towers is causing significant health issues to people living in close proximity to them. The petitioners raise questions about the objectivity of scientific studies supporting the government's position on potential health hazards, as well as about the perceived independence of departmental staff assessing these studies.

In petition 260, the petitioner alleges that little research is being conducted to understand the pain and discomfort due to electromagnetic sensitivity and to help people suffering from it. The petitioner wants to know what the federal government has done to acknowledge and deal with this illness and to warn Canadians of the dangers of electromagnetic fields.

Other petitioners raise more specific questions about the potential health effects from electromagnetic radiation. For example, petition 253 raises questions about the effects of radiation from cordless phones using Digital Enhanced Cordless Telecommunications. Petition 254 states that, apart from emitting radio frequency radiation, energy-efficient compact fluorescent light bulbs also emit ultraviolet (UV) radiation, cause electrical pollution, and contain mercury content, which makes them hard to dispose of safely.

Fluoride in drinking water

The potential environmental and health impacts of adding fluoride to drinking water was the subject of another significant group of petitions in 2007–08. One petitioner submitted four petitions on the impact and cost of fluoride in drinking water (petitions 221, 221B, 221C, and 221D). The petitioner asks the government to demonstrate the safety of the products currently used to fluoridate drinking water, alleging that they cause harm to humans (dental fluorosis), aquatic life (destruction of salmon stocks), flora, and the environment. The petitioner questions the government's plan for protecting the environment as well as at-risk groups, such as children and the elderly, from fluoride in water and food. Petition 244 raises similar points.

Other petitions on the impact of fluoride in water focus on issues such as the government's definition, management, and regulation of fluoride (petition 243), as well as the potential detrimental effect on water distribution infrastructure (petition 245).

Radioactive waste in Port Hope, Ontario

A number of petitions were submitted this year about different aspects of the government's management of low-level radioactive waste in Port Hope, Ontario. Petitioners are concerned about the extent of the contamination in the town, specifically at one elementary school (petitions 232 and 234), and the potential health impacts from exposure to the low-level radioactive waste, as well as to toxic chemicals that allegedly leaked into Lake Ontario from a uranium processing facility (petition 248).

The federal government's Port Hope Long-Term Low-Level Radioactive Waste Management Project was the subject of a number of petitions. Issues raised by petitioners include the scope and assessment of the cleanup project and the health risks posed (petition 232); the associated environmental assessment process (petition 234); and the management of the project in terms of time and budget (petition 237). One petitioner raises questions about the level of environmental assessment normally done for nuclear projects and requests that human health considerations be included among the criteria for environmental assessments and the licensing of nuclear projects (petition 236).

In petition 233, the petitioner raises concerns about health risks posed by exposure to radiation and about the levels of radiation considered allowable in Canada. The petitioner questions the way that Canada establishes allowable radiation levels. Other petitioners request that health studies and investigations be done to assess and monitor the health of the Port Hope community (petition 236) and raise questions on previous health studies conducted in the community (petitions 232, 233, and 236).

Source: Submitted petitions

5.14 Other issues with multiple petitions included

  • the impact and cost of fluoride in drinking water, the subject of seven petitions (221, 221B, 221C, 221D, 243, 244, and 245);
  • the government's management of radioactive waste in Port Hope, Ontario, an issue going back several years and the subject of six petitions this year (232, 233, 234, 236, 237, and 248);
  • contaminated sites, the subject of five petitions (217, 218, 218B, 257, and 261); and
  • oil sands development, with four petitions received, including subsidies to the oil and gas industry (158B, 215, 222, and 238).

5.15 Other issues raised in petitions this year were the environmental and human health effects of compact fluorescent light bulbs, including the possible leakage of mercury from them (petitions 241 and 254); and the absence of federal policy to protect Canada's freshwater from the possibility of bulk water export and/or diversion (petition 251).

Parliamentarians expressed interest in petitioners' concerns

5.16 Issues raised by petitioners have been of interest to members of Parliament. One of these issues relates to the environmental impact of amendments to the federal Metal Mining Effluent Regulations under the Fisheries Act, which allow healthy fish-bearing water to be classified as a tailings impoundment area (issue raised in petitions 219 and 219B). This issue is the subject of a private member's bill currently before Parliament, and it received considerable media coverage.

The media has covered various issues raised in petitions

5.17 Over the past year, the media has covered a number of current issues that were also raised in petitions. This coverage has included newspaper articles, television documentaries, and radio interviews. For example, the environmental impact of oil sands development was the subject of a number of television documentaries, such as the Canadian Broadcasting Corporation's presentation of "Crude Awakening" and "Du sable dans l'engrenage" shown by Radio-Canada.

5.18 There were also reports on the potential environmental impact of the United States Devils Lake outlet project on the Red River and Lake Winnipeg, an issue raised in petition 249. In addition, a number of articles were written on the environmental impact of brominated flame-retardants (known as polybrominated diphenyl ethers), which was the subject of several petitions, including petition 204. The media also covered petition issues at the local level—for example, a local radio interview related to issues raised in petition 240 about the protection of Cacouna Marsh in Quebec from industrial activity.

Timeliness of responses

5.19 This year, departments and agencies prepared 200 responses to petitions, which represented a significant increase from the 128 the previous year. Environment Canada continues to account for the largest number, being responsible for 45 responses compared with 33 in 2006–07. Health Canada, Fisheries and Oceans Canada, Natural Resources Canada, and Indian and Northern Affairs Canada also recorded increases in the number of responses prepared.

5.20 We noted a decrease in the number of on-time responses: 86 percent of responses were on time compared with 95 percent last year. Nine departments responded late to at least one petition (Exhibit 5.5). Two of these departments, Environment Canada (with 14 late responses out of 45) and Indian and Northern Affairs Canada (with 7 late responses out of 13), accounted for about 70 percent of the late responses.

Exhibit 5.5—Timeliness of petition responses due between 1 July 2007 and 30 June 2008

Department/Agency Number of responses due Number of late responses Percentage on time (%) Extension requested*
Agriculture and Agri-Food Canada 5 0 100 0
Atlantic Canada Opportunities Agency 1 0 100 0
Canada Border Services Agency 2 1 50 0
Canada Economic Development for Quebec Regions 2 0 100 1
Canada Public Service Agency 1 0 100 0
Canada Revenue Agency 1 0 100 0
Canadian Heritage 1 1 0 0
Canadian International Development Agency 2 0 100 0
Citizenship and Immigration Canada 1 1 0 0
Environment Canada 45 14 69 1
Finance Canada 4 0 100 0
Foreign Affairs and International Trade Canada 4 0 100 1
Fisheries and Oceans Canada 24 1 96 3
Health Canada 27 1 96 1
Human Resources and Social Development Canada 2 0 100 1
Indian and Northern Affairs Canada 13 7 46 0
Industry Canada 9 0 100 0
Justice Canada 3 0 100 0
National Defence 3 0 100 0
Natural Resources Canada 23 0 100 1
Parks Canada Agency 3 0 100 0
Public Health Agency of Canada 3 1 67 0
Public Safety Canada 1 0 100 0
Public Works and Government Services Canada 3 0 100 1
Transport Canada 11 0 100 0
Treasury Board of Canada Secretariat 4 2 50 0
Veterans Affairs Canada 1 0 100 0
Western Economic Diversification Canada 1 0 100

0

Total 200 29 86 10
* Note: A response is not considered to be late if an extension to the 120-day timeline is requested before the due date. (Return)

5.21 The number of days late for a response in 2007–08 ranged from 1 to 89 days. We noted that, in several cases, departments missed the 120-day deadline by three days or fewer. Overall, the average number of days late was 12 days. Indian and Northern Affairs Canada had the highest average number of days late for its responses (29 days). We noted improvements from last year in timeliness for Fisheries and Oceans Canada (80 to 96 percent) and Industry Canada (86 to 100 percent).

5.22 The Auditor General Act allows a federal minister to obtain an extension to the 120-day timeline when more time is required to respond to a petition. This year, extensions were requested in 10 cases. A response is not considered to be late if the department notifies the petitioner that an extension will be required before the 120-day timeline. When extensions are necessary, we advise departments to specify, if possible and as a courtesy to petitioners, the additional time required to respond.

Highlights of petition responses

We monitor and review petition responses

5.23 As part of our monitoring role, we review petition responses that departments have sent to petitioners to see if all the questions raised by petitioners have been addressed. If a response does not answer the questions or address the concerns raised in a petition, the Commissioner may bring that observation to the attention of the departments concerned. However, the Auditor General Act does not grant the Commissioner power to compel federal authorities to take the necessary action to solve environmental problems. The following paragraphs include highlights of responses to petitions received this year.

5.24 The state of environmental health research in Canada. In petition 201, the petitioner raises questions on the state of environmental health research and policy in Canada. The petitioner asks the federal government for information related to federal funding for environmental health research, a national environmental health strategy, statistics quantifying the amount of disease or death caused by environmental risks, and identification of geographic areas in Canada subject to a disproportionate share of pollution.

5.25 The response, submitted jointly by Health Canada and Environment Canada, provides detailed information to answer many of the questions raised. The departments state that investments in environmental health research, based on available information from organizations under the responsibilities of the Minister of the Environment and the Minister of Health, increased from $41.7 million in the 2001–02 fiscal year to $66 million in the 2006–07 fiscal year. The departments also describe initiatives aimed at improving surveillance and tracking to support the government's policies and programs on environmental health. For example, they state that the government is currently developing a set of environmental health indicators and will report on them following extensive consultations with relevant stakeholders. In addition, they indicate that Statistics Canada is carrying out the Canadian Health Measures Survey between 2007 and 2009, which will collect information from Canadians about their health. The survey includes a bio-monitoring component to measure levels of environmental chemicals in humans.

5.26 Herbicides used in forestry operations. In petition 214, the petitioner raises concerns about the risks associated with the use of herbicides in forestry operations. The petitioner alleges that herbicides, such as 2,4 Dichlorophenoxyacetic acid (2,4-D) and glyphosate, were deposited by some forest management companies into Ontario waterways containing fish. The petitioner is concerned that the contamination of these waterways poses a threat to the environment and the health of the residents of northern Ontario, who may eat the fish or drink the water. The petitioner requests information and asks the federal government to investigate these alleged violations.

5.27 In their responses, Health Canada and Environment Canada provide lists of published documents and literature reviewing the health and environmental effects of the two herbicides, as requested in the petition. The departments indicate to the petitioner that they did not have any information about the environmental interaction and impact of these two herbicides used in combination. Health Canada also indicates that the Pest Management Regulatory Agency recently completed the re-evaluation of 2,4-D and that its proposed decision is available on the Agency's website. Health Canada also indicates that the Agency is currently addressing comments received in response to that proposal prior to publishing a final decision on all products containing 2,4-D.

5.28 In addition, based on the occurrences described in the petition, Environment Canada indicates that Ontario Region enforcement officers will conduct an inspection to verify compliance with the Fisheries Act.

5.29 Impact of scrap-metal storage activities. In petition 206, the petitioner raises concerns about the potential impact of scrap-metal storage activities in the Gros-Cacouna port (Quebec) on the quality of water in the St. Lawrence River, on marine ecosystems, and on species at risk.

5.30 Environment Canada, Transport Canada, and Fisheries and Oceans Canada provided a joint response explaining their respective roles and mandates regarding this issue. In response to a specific question, Transport Canada indicates that it asked the port tenant to test the leachate emanating from the scrap metal stored at the dock for several parameters, such as cyanides, cadmium, PCBs, mercury, lead, oil and grease, as well as any other element that might be present.

5.31 Use of recycled paper by federal departments and agencies. In petition 223, the petitioner wants to know the percentage of recycled paper that federal departments and agencies are using for internal documents and publications. This petition was sent to all of the federal departments and agencies subject to the petitions process, with the exception of Environment Canada, which the petitioner claimed was already using products that are approved by the Forest Stewardship Council.

5.32 Most of the departments provided information and statistics about their use of recycled paper for internal documents and publications. In addition, a number of departments committed to increasing the use of recycled and third-party certified paper.

Limitations of petition responses

5.33 While petition responses may provide detailed information, as shown in the examples in the previous section, departments and agencies may not always be able to provide fully informative responses. This may occur when the petition issues involve the following matters:

  • Litigation. The subject of the petition is currently before the courts or relates to ongoing investigations or imminent legal action.
  • Cabinet confidences. These are records or any information in records that describe the individual or collective decision- and policy-making process of ministers or Cabinet, including records on proposed legislation or regulations (examples include records of Cabinet decisions, Cabinet agendas, committee reports and memoranda to Cabinet, Treasury Board submissions, and Treasury Board decisions).
  • Legal opinions. The Department of Justice Canada cannot refer to legal opinions it has prepared for departments or agencies; nor can it provide legal opinions to individuals.
  • Issues beyond federal jurisdiction. Federal departments may not respond to some questions if they address issues that are primarily the responsibility of provinces or municipalities or if they fall under the responsibility of another entity that is not subject to the petitions process.
  • Personal opinions. Ministers generally do not respond to requests for personal opinions on the benefit of existing or proposed legislation, policy, programs, plans, and initiatives.

Opportunities for improvement

5.34 Based on our monitoring of petitions and responses received this year, we describe in the following paragraphs some good practices and opportunities for improvement that we identified.

Petitioners can make their petitions more effective

5.35 Take advantage of the online petitions catalogue. As described in paragraph 5.13, we received multiple petitions on several specific issues this year. This increases the likelihood of repetitive questions being asked. Our petitions catalogue on the Office of the Auditor General website contains more that 300 petitions received since the petitions process was created in 1995. Before submitting a petition, we encourage people to visit our website and review this petitions catalogue. The responses to questions posed on similar issues in previous petitions may address some of their concerns, or may form a useful basis for writing new questions.

5.36 Consider coordinating efforts. The submission of multiple or repetitive petitions on the same subject requires significant federal resources to respond under the Auditor General Act. When organized groups or issue-based networks are submitting environmental petitions, we suggest that they consider coordinating their efforts. If their petitions deal with distinct aspects of the issue and are not repetitive, they may be more effective.

5.37 Write petitions clearly and concisely. Several petitions received this year were lengthy, containing more than 10,000 words and up to 80 questions. Although the Auditor General Act does not specify restrictions on the length of petitions, in our experience it is to petitioners' and departments' advantage to limit petitions to a maximum of 5,000 words and 20 questions or requests. We believe that the public is more inclined to read petitions if they are concise. In addition, departments and agencies have limited resources to review, assess, and prepare timely responses to petitions. It is important that petitioners be as clear and concise as possible when writing their petitions. To make best use of our limited resources, we reserve the right not to publish petitions in the online petitions catalogue on our website should they exceed the suggested limits.

5.38 Ensure that language is appropriate and information is accurate. Petitioners are responsible for statements made in their petitions. Petitioners should avoid using defamatory or intemperate language and should avoid making allegations that are not well supported by facts, as this could expose the petitioners to legal action. All information, including confidential documents, submitted with a petition is subject to the Access to Information Act. This means that the Office of the Auditor General may be required to provide this information to individuals requesting it under that Act. Petitioners are therefore cautioned not to submit personal or private documents with their petitions.

Departments can ensure that their responses are clear and complete

5.39 Indicate responsibility for questions. When a petition is sent to multiple departments, they can choose to provide a joint response or to respond separately within their area of responsibility. In the latter case, we encourage departments to clearly indicate which questions they are responsible for responding to. We noted this year that most departments provided well-structured responses—for example, they repeated the petitioner's question and question number, followed by their response to that question. We found that this structure makes it easier for the petitioner to determine if all of the questions have been answered, and who has answered them.

5.40 Address petitioner's requests. As part of our monitoring role, we review responses to petitions to determine whether a department addressed the petitioner's questions and requests. In a few cases, we found that, while a department answered the questions, some responses were vague and conveyed little meaningful information. A number of petitioners contacted our Office or sent follow-up petitions expressing concerns that departments had not adequately addressed the issues they raised in their petition. Departments can contribute to the efficiency and effectiveness of the petitions process by providing, to the extent possible, responses that clearly and fully address all matters raised by petitioners. We also encourage departments to clearly explain why they are unable to answer certain questions.

The Commissioner will continue to review and improve the petitions process

5.41 Building on our October 2007 retrospective study, the petitions team began an awareness campaign to let environmental non-governmental organizations and groups know about the environmental petitions process. We also made similar presentations explaining the process to department officials. A new guide to the environmental petitions process will be released in 2008 to provide guidance to Canadians wishing to submit a petition.

Conclusion

5.42 The environmental petitions process allows Canadians to bring their questions and concerns about the environment and sustainable development to the attention of federal ministers. In 2007–08, they did so in record numbers, with 56 petitions being submitted.

5.43 Human and environmental health issues remain the top concern of petitioners. We also noted that more than half of the petitions received this year were grouped around several specific issues. When organized groups or issue-based networks are submitting environmental petitions, we suggest that they consider coordinating their efforts. If their petitions deal with distinct aspects of the issue and are not repetitive, they may be more effective.

5.44 The percentage of on-time responses by departments decreased this year, with two departments accounting for 70 percent of the late replies.

5.45 The Commissioner will continue to look for ways to enhance and improve the petitions process so that it continues to be an effective tool for Canadians wishing to bring environmental issues to the attention of federal ministers.

About the Chapter

Objective

The objective of this chapter is to inform Parliament and Canadians about the use of the petitions process. In accordance with sections 22 and 23 of the Auditor General Act, the chapter describes the number, nature, and status of petitions received, and the timeliness of responses from ministers.

Scope and approach

The annual report on petitions summarizes monitoring of the petitions process by the Commissioner of the Environment and Sustainable Development within the Office of the Auditor General of Canada. It covers the period from 1 July 2007 to 30 June 2008. The appendix provides summaries of the petitions received during this reporting period.

Work completed

Work for this chapter was substantially completed on 17 July 2008.

Team

Principal: Paul Morse
Director: David Willey

Hélène Charest
Roger Hillier
Mark Lawrence
Lyane Maisonneuve
Marie-Soleil Nappert
Josée Perrier

For information, please contact Communications at 613-995-3708 or 1-888-761-5953 (toll-free).

Appendix—Petitions activity (1 July 2007 to 30 June 2008)

This appendix includes a summary of the petitions (follow-up and new issues) received during the activity period noted above. To access the full text of petitions and responses from December 1995 to 30 June 2008, go to the petitions catalogue on our website. If necessary, paper copies of the catalogue can be obtained on request.

Petition No. 158B: Follow-up petition on subsidies to the oil and gas industry and on federal efforts to address climate change

Date submitted: 20 November 2007

Petitioner(s): Friends of the Earth, Ecojustice Canada, and a Canadian resident

Summary: The petitioners allege that federal tax breaks to the oil and gas industry contradict and undermine government statements and spending on the fight against climate change. They are seeking explanations by federal departments on why tax breaks have been, and continue to be, awarded to oil and gas corporations. They also want to know what the government's stance is on global warming and on greenhouse gas emissions and why the EnerGuide Program for Low Income Households was cancelled.

Issues: Aboriginal affairs, air quality, climate change, human health/environmental health, and natural resources

Federal departments/agencies replying: Environment Canada, Finance Canada, Natural Resources Canada

Status: Completed


Petition No. 212B: Follow-up petition on airport expansion in Dorval, Quebec

Date submitted: 4 January 2008

Petitioner(s): The Green Coalition

Summary: This follow-up petition concerns the expansion of an airport onto land presently used as a golf course in Dorval, Quebec. The petitioner questions the need to expand the airport and raises a number of concerns about the public consultation and environmental review conducted for the project. The petitioner requests a halt to construction activities until a full environmental assessment and public consultation is conducted.

Issues: Air quality, environmental assessment, governance, human health/environmental health, and transport

Federal departments/agencies replying: Environment Canada, Transport Canada

Status: Completed


Petition No. 214: Impact of herbicides on fish and fish habitats in northern Ontario

Date submitted: 14 August 2007

Petitioner(s): Joel Theriault

Summary: Protecting and preserving northern Ontario waterways from the risks associated with herbicide use in forestry operations is the focus of this petition. The petitioner alleges that there have been numerous unauthorized discharges of herbicides, such as 2,4-Dichlorophenoxyacetic acid (2,4-D) and glyphosate, by forest management companies in Ontario. The petitioner is concerned that the contamination of these waterways poses a threat to the environment and to the health of the residents of northern Ontario. In addition, the petitioner claims that these actions violate section 36 of the Fisheries Act, which prohibits the deposit of deleterious substances into waterways that are frequented by fish. The petitioner presents a series of requests for information and for action to investigate these violations.

Issues: Fisheries, human health/environmental health, pesticides, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada, Indian and Northern Affairs Canada

Status: Completed


Petition No. 215: Impact of oil sands development in Alberta

Date submitted: 9 September 2007

Petitioner(s): Pembina Institute, Sierra Club of Canada, and Prairie Acid Rain Coalition

Summary: This petition concerns the recommendations contained in the Oil Sands Consultation—Multistakeholder Committee Final Report, which was submitted to the Government of Alberta on 30 June 2007. The Committee includes representatives from governments, First Nations, Métis, industry, and environmental organizations. The recommendations in the report cover a wide range of issues, including the tax and royalty regime, capital costs allowance, environmental impact assessments, watershed management, research and development, long-term health effects, consultations with First Nations, and transportation safety plans. The petitioners are expecting answers from the Government of Canada about its position on these recommendations, including details of implementation plans.

Issues: Aboriginal affairs, environmental assessment, natural resources, and water

Federal departments/agencies replying: Environment Canada, Department of Finance Canada, Fisheries and Oceans Canada, Health Canada, Indian and Northern Affairs Canada, Natural Resources Canada

Status: Reply (replies) received but not yet posted


Petition No. 216: Request for an environmental assessment of a niobium mine project in Oka, Quebec

Date submitted: 13 September 2007

Petitioner(s): A Canadian resident

Summary: This petition is about a niobium mine project in Oka, Quebec. The petitioner is concerned about potential environmental effects of planned mining activities on water and species at risk in the area. The petitioner alleges that studies done to assess the environmental impact of the project were incomplete and asks the federal government to conduct a full environmental assessment of the project.

Issues: Biological diversity, environmental assessment, human health/environmental health, natural resources, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada

Status: Completed


Petition No. 217: Environmental contamination at a First Nations reserve in Manitoba

Date submitted: 19 September 2007

Petitioner(s): Mathias Colomb Cree Nation

Summary: This petition concerns contaminated soils on First Nations land in Manitoba. In the 1980s, diesel fuel was discovered in the crawl space of the school, and the area was contaminated with polychlorinated biphenyls (PCB). The buildings and infrastructure were affected—many had to be demolished, and the people in the community had many health issues. The petitioner indicates that many of the recommendations made by different engineering firms over the years, including rebuilding the community and addressing human health issues, still need to be addressed. The petitioner asks questions about the budget figures and specific timelines for dealing with the contamination. The petitioner also asks the Government of Canada to fund a study to look into the possible impact of this contamination on health in the community.

Issues: Aboriginal affairs, environmental assessment, human health/environmental health, and toxic substances

Federal departments/agencies replying: Environment Canada, Health Canada, Indian and Northern Affairs Canada

Status: Completed


Petition No. 218: Contaminated site in New Harbour, Newfoundland and Labrador

Date submitted: 1 October 2007

Petitioner(s): Allan Williams

Summary: This petition is about an alleged failure to adequately treat polychlorinated biphenyls (PCB) contaminants from transformers buried in a landfill site on the New Harbour Barrens in Newfoundland. The petitioner claims that, as a consequence, the health of the local environment is being endangered. He asks the federal government to ensure that the site is properly cleaned up and managed, that offenders are held accountable, and that the health of the area residents is protected.

Issues: Compliance and enforcement, human health/environmental health, toxic substances, transport, and waste management

Federal departments/agencies replying: Environment Canada, Health Canada, Transport Canada

Status: Reply (replies) received but not yet posted


Petition No. 218B: Follow-up petition on a contaminated site in New Harbour, Newfoundland and Labrador

Date submitted: 26 March 2008

Petitioner(s): Allan Williams

Summary: This follow-up petition is about the alleged failure to adequately treat polychlorinated biphenyls (PCB) contaminated waste in a landfill site in New Harbour, Newfoundland and Labrador. The petitioner asks that the PCB-contaminated waste buried in a landfill site be excavated and that the area be thoroughly tested. The petitioner also asks that the government obtain relevant information from owners of companies who were contracted to transport the PCB-contaminated waste and deposit it in the landfill site.

Issues: Compliance and enforcement, human health/environmental health, toxic substances, transport, and waste management

Federal departments/agencies replying: Environment Canada

Status: Completed


Petition No. 219: Environmental impact of federal Metal Mining Effluent Regulations

Date submitted: 7 October 2007

Petitioner(s): Mining Watch Canada

Summary: The petitioner alleges that a 2002 regulatory amendment, Schedule 2, to the Metal Mining Effluent Regulations approved by Environment Canada and Fisheries and Oceans Canada, lacked sufficient public consultation. The petitioner is concerned that this amendment allows the mining industry to deposit its toxic by-products into healthy lakes and rivers. These water bodies then become "tailing impoundment areas" that have a variety of impacts on water quality, fish, and wildlife. The petitioner asks a number of questions and requests that no other lakes be added to Schedule 2 until full public consultation on this matter has been held.

Issues: Environmental assessment, fisheries, human health/environmental health, natural resources, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Indian and Northern Affairs Canada, Natural Resources Canada

Status: Completed


Petition No. 219B: Environmental impact of the Metal Mining Effluent Regulations on fish habitats

Date submitted: 13 November 2007

Petitioner(s): Mining Watch Canada

Summary: In this follow-up petition, the petitioner asks additional questions about Fisheries and Ocean Canada agreeing to the Schedule 2 amendment to the Metal Mining Effluent Regulations and about the impact of the amendment on fish and fish habitats. The petitioner alleges that the Schedule 2 amendment allows the mining industry to turn healthy lakes and rivers into "tailing impoundment areas," by authorizing them to deposit their toxic by-products into lakes and rivers. Among other things, the petitioner asks that a joint panel environment assessment, under the Canadian Environmental Assessment Act, be required for any other lakes or rivers being added to Schedule 2.

Issues: Environmental assessment, fisheries, human health/environmental health, natural resources, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Indian and Northern Affairs Canada, Natural Resources Canada

Status: Completed


Petition No. 220: Collapse of snow crab fishery in Glace Bay Hole, Nova Scotia

Date submitted: 26 October 2007

Petitioner(s): Area #22 Offshore (Glace Bay Hole)

Summary: The petitioner alleges that the collapse of the snow crab fishery in an area known as Glace Bay Hole, in Nova Scotia, is due to overfishing in three crab-fishing zones. The petitioner also alleges that agreements between Fisheries and Oceans Canada and Area #22 offshore fishermen that related to co-management and a sustainable development strategy were breached. The petitioner requests a meeting with the Minister to review concerns about the breached agreements, the science advice provided, and the management of this unique area. The petitioner also requests that the boundary line that delineates the fishing area for the snow crab fishermen be reinstated, according to the agreement with Fisheries and Oceans Canada. Finally, the petitioner asks the Treasury Board of Canada Secretariat to review the actions of Fisheries and Oceans Canada to determine whether the Department respected mandated policies and principles.

Issues: Compliance and enforcement, environmental assessment, federal provincial relations, and fisheries

Federal departments/agencies replying: Fisheries and Oceans Canada, Treasury Board of Canada Secretariat

Status: Completed


Petition No. 221: Health and environmental concerns regarding fluoridation of drinking water

Date submitted: 19 November 2007

Petitioner(s): Carole Clinch

Summary: The petitioner seeks responses from several departments on the addition to our drinking water of fluoride (hydrofluorosilicic acid), which she alleges contains arsenic, lead, and other toxic substances. She asks departments to provide toxicology studies demonstrating the safety of the chemical compounds currently used to fluoridate drinking water. She also asks departments to warn those involved in the fisheries industry of the effects of water fluoridation on our ecosystem. The petitioner further asks what departments plan to do to protect children and other groups at risk (for example, diabetics) from fluoride in water and food.

Issues: Environmental assessment, fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada, Indian and Northern Affairs Canada, Natural Resources Canada

Status: Reply (replies) received but not yet posted


Petition No. 221B: Follow-up petition on health and environmental concerns regarding fluoride in drinking water

Date submitted: 7 April 2008

Petitioner(s): Carole Clinch

Summary: In this follow-up petition, the petitioner asks for more responses from several departments about the addition of fluoride (hydrofluorosilicic acid) to our drinking water, which she alleges is causing harm to humans, aquatic life, flora, and the environment. Among other things, the petitioner asks for toxicology reports and studies that demonstrate that the products currently used to add fluoride to drinking water are safe. The petitioner also asks about the potential impact of fluoride on western salmon stocks.

Issues: Environmental assessment, fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada, Public Health Agency of Canada

Status: Reply (replies) received but not yet posted


Petition No. 221C: Follow-up petition on health and environmental concerns regarding fluoridation of drinking water

Date submitted: 14 April 2008

Petitioner(s): Carole Clinch

Summary: In this follow-up petition, the petitioner seeks further responses from Health Canada regarding the environmental health impacts of adding fluorosilicates to our drinking water, particularly as it relates to dental fluorosis. The petitioner alleges that water fluoridation is the main source of fluoride exposure and therefore serves as a major cause of dental fluorosis. The petitioner raises questions concerning the perceived social harm, financial burdens, and dental harm caused to Canadians by dental fluorosis.

Issues: Human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Health Canada, Public Health Agency of Canada

Status: Reply (replies) received but not yet posted


Petition No. 221D: Follow-up petition on health and environmental concerns regarding fluoridation of drinking water

Date submitted: 14 April 2008

Petitioner(s): Carole Clinch

Summary: In this follow-up petition, the petitioner seeks further responses from several departments regarding the toxic effects of fluoride added to drinking water. The petitioner alleges that fluoride has been treated differently for risk assessment than other trace elements with similar long-lasting toxic effects. The petitioner asks that the recommended levels for fluoride intake be reduced and that the addition of fluoridation chemicals (hydrofluorosilicic acid and derivatives) to drinking water be discontinued.

Issues: Compliance and enforcement, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Health Canada, Public Health Agency of Canada

Status: Reply (replies) received but not yet posted


Petition No. 222: Subsidies to the oil and gas industry and federal initiatives for greenhouse gas emission reductions

Date submitted: 12 November 2007

Petitioner(s): KAIROS: Canadian Ecumenical Justice Initiatives

Summary: This petition is about the apparent conflict of objectives in federal government policies related to energy efficiency and greenhouse gas. The petitioner requests information about how the federal government reconciles the apparent contradiction of encouraging the production of fossil fuels, through subsidies to the oil and gas industries, with encouraging the reduction of fossil fuels, through energy efficiency and greenhouse gas reduction initiatives (such as ecoENERGY Renewable and ecoENERGY for Bio-fuels).

Issues: Air quality, climate change, governance, human health/environmental health, and natural resources

Federal departments/agencies replying: Canadian International Development Agency, Environment Canada, Department of Finance Canada, Foreign Affairs and International Trade Canada, Natural Resources Canada

Status: Completed


Petition No. 223: Green procurement and use of recycled paper by federal government departments

Date submitted: 23 November 2007

Petitioner(s): A Canadian resident

Summary: This petition is about the federal government's commitment to implement a green procurement policy. The petitioner asks questions about the percentage of recycled paper being used for publications and internal documents. The Green Procurement Policy, which was implemented in 2006, seeks to reduce the environmental impact of government operations, by integrating environmental performance considerations in the procurement process. Section 6 of the policy states that "the Government of Canada expects that the application of this policy will benefit the environment by contributing to environmental objectives such as reducing waste and supporting reuse and recycling." The petitioner is concerned that the government is not following through on its commitment to use recycled paper and recommends that all federal departments use paper that contains a minimum of 30 percent post-consumer content and is third-party certified.

Issues: Air quality, climate change, and human health/environmental health

Federal departments/agencies replying: Agriculture and Agri-Food Canada, Atlantic Canada Opportunities Agency, Canada Border Services Agency, Canada Economic Development for Quebec Regions, Canada Revenue Agency, Canadian Heritage, Canada Public Service Agency, Canadian International Development Agency, Citizenship and Immigration Canada, Department of Finance Canada, Fisheries and Oceans Canada, Foreign Affairs and International Trade Canada, Health Canada, Human Resources and Social Development Canada, Indian and Northern Affairs Canada, Industry Canada, Department of Justice Canada, National Defence, Natural Resources Canada, Parks Canada Agency, Public Health Agency of Canada, Public Safety and Emergency Preparedness Canada, Public Works and Government Services Canada, Transport Canada, Treasury Board of Canada Secretariat, Veterans Affairs Canada, Western Economic Diversification Canada

Status: Reply (replies) received but not yet posted


Petition No. 224: Science underlying the Kyoto Protocol and Canada's action plan on global warming

Date submitted: 22 November 2007

Petitioner(s): A Canadian resident

Summary: The petitioner questions whether Environment Canada and the Minister considered the dissenting views on the clarity of climate change science in creating the Department's Turning the Corner action plan on global warming. The petitioner asks why these dissenting views were not considered persuasive in reference to five points raised in the petition, including several points on the credibility of historical data.

Issues: Air quality, climate change, governance, human health/environmental health, and science and technology

Federal departments/agencies replying: Environment Canada

Status: Completed


Petition No. 225: Protecting Cat Stream and Jingle Pot Marsh in Nanaimo, British Columbia

Date submitted: 12 December 2007

Petitioner(s): Rory Rickwood and Roger Giles

Summary: The petitioners allege that the Government of Canada's commitment to protecting a fragile ecosystem was ignored during a screening carried out in accordance with the Canadian Environmental Assessment Act. During 2005 and 2006, an asphalt trail (berm) and fencing were built in a fragile aquatic environment that is registered in the government's Sensitive Ecosystem Inventory. The petitioners claim that the asphalt trail contains toxins that are known to be very harmful to mammals, birds, fish, amphibians, and invertebrates and that the page-wire fencing is known to harm low-flying migratory birds. The petitioners ask the responsible departments to provide information about the decisions that led to the building of the trail and fencing. They also question what the departments will do to rectify the situation.

Issues: Environmental assessment, governance, human health/environmental health, and natural resources

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Natural Resources Canada

Status: Completed


Petition No. 226: Canada's use and export of chrysotile asbestos

Date submitted: 18 December 2007

Petitioner(s): David Berliner

Summary: This petition is a follow-up to responses received for a previous petition on the use and export of chrysotile asbestos. The petitioner is concerned about Canada's export policies regarding this substance and questions how the Government of Canada is monitoring and ensuring its safe use in importing countries. The petitioner also inquires about the existence of a national surveillance program to keep track of asbestos-related diseases in Canada and of a public registry of buildings in Canada that contain asbestos. See related petition 179 (in the petitions catalogue).

Issues: Air quality, human health/environmental health, international cooperation, natural resources, and toxic substances

Federal departments/agencies replying: Canada Economic Development for Quebec Region, Environment Canada, Foreign Affairs and International Trade Canada, Health Canada, Human Resources and Social Development Canada, Natural Resources Canada, Public Works and Government Services Canada

Status: Completed


Petition No. 227: Use of letters of advice and operational statements by Fisheries and Oceans Canada: Impact on the environmental assessment process

Date submitted: 19 December 2007

Petitioner(s): Martha Kostuch and The Friends of the Oldman River

Summary: The petitioners allege that Fisheries and Oceans Canada's use of letters of advice and operational statements circumvents specific requirements of the Canadian Environmental Assessment Act, such as project notification and public consultation. The petitioners note that this lack of notification and public input may have a negative impact on fish habitat. The petitioners ask what legislation and/or regulations authorized Fisheries and Oceans Canada to create these processes and whether the Department is actively monitoring and assessing these letters of advice and operational statements to determine their impact on fish habitat.

Issues: Compliance and enforcement, environmental assessment, fisheries, and human health/environmental health

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada

Status: Completed


Petition No. 228: The federal government's alleged failure to inspect coal-fired power plants for mercury emissions

Date submitted: 19 December 2007

Petitioner(s): Ecojustice Canada

Summary: This petition alleges that the federal government has not yet inspected Ontario's coal-fired power plants to determine if these plants are violating Canada's Fisheries Act by depositing mercury, a deleterious substance, into Canadian waters. The petitioner raises a number of questions regarding mercury emissions from coal-fired plants, and asks whether the federal government has followed through, or intends to follow through by a specified date, on the plan to inspect these plants.

Issues: Compliance and enforcement, human health/environmental health, science and technology, toxic substances, and water

Federal departments/agencies replying: Environment Canada

Status: Completed


Petition No. 229: Installation of cellular towers in Simcoe, Ontario

Date submitted: 20 December 2007

Petitioner(s): A Canadian resident

Summary: The petitioner is concerned about the installation of a cellular tower adjacent to his property, as well as next to a school, hospital, and nursing home, without any prior notification and/or public consultation. The petitioner alleges that since the installation, he has been suffering from the effects of radiation emitted by the tower. The petitioner asks, among other things, that the Government of Canada remove this tower to protect his own health and that of his family and neighbours.

Issues: Environmental assessment, human health/environmental health, and science and technology

Federal departments/agencies replying: Environment Canada, Health Canada, Industry Canada

Status: Reply (replies) received but not yet posted


Petition No. 230: Impact of cellular phone transmitters on human health

Date submitted: 19 December 2007

Petitioner(s): A Canadian resident

Summary: The petitioner is concerned about the recent installation of a cellular phone transmitter 11 metres from his property, and the health impact this may have. Since the installation, the petitioner says that he has been suffering from electromagnetic hypersensitivity. According to the petitioner, he and his family have had to live away from their home and have suffered severe physical, financial, and emotional harm since the transmitter was installed. The petitioner asks Industry Canada and Health Canada to take action. He also raises questions on the notification procedure requirements for these transmitters and on the nature of the studies used to verify their safety.

Issues: Environmental assessment, human health/environmental health, and science and technology

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) received but not yet posted


Petition No. 230B: Follow-up petition on the impact of cellular phone transmitters on human health

Date submitted: 30 June 2008

Petitioner(s): A Canadian resident

Summary: In this follow-up petition, the petitioner seeks further responses from Health Canada and Industry Canada regarding scientific studies on the safety of cellular phone transmitters and on siting and notification procedures for such transmitters.

Issues: Environmental assessment, human health/environmental health, science and technology, and other

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) pending


Petition No. 231: Barrel burning

Date submitted: 3 January 2008

Petitioner(s): John Newell

Summary: The petitioner asks the Government of Canada to put a federal policy in place to prohibit the practice of barrel burning in Canada. According to the petitioner, barrel fires burn garbage inefficiently. In addition, the low temperatures at which barrel fires burn do not destroy the chemicals. Instead, the chemicals are released into the air in more lethal forms. The petitioner alleges that people who are repeatedly exposed to barrel-burning emissions have an increased risk of suffering from severe health problems.

Issues: Air quality, compliance and enforcement, federal-provincial relations, human health/environmental health, and toxic substances

Federal departments/agencies replying: Environment Canada, Health Canada, Industry Canada

Status: Completed


Petition No. 232: Radioactive waste cleanup in Port Hope, Ontario

Date submitted: 4 January 2008

Petitioner(s): Pat McNamara

Summary: This petition concerns radioactive contamination and waste cleanup projects in Port Hope, Ontario. The petitioner is concerned about the extent of the contamination, the scope and assessment of the cleanup projects, and the health risks posed by the contamination and cleanup initiatives. The petitioner raises several questions about the federal government's past and future actions in dealing with this issue. The petitioner also questions the low level of environmental assessment currently required for nuclear projects.

Issues: Environmental assessment, human health/environmental health, natural resources, toxic substances, and waste management

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada, Natural Resources Canada

Status: Completed


Petition No. 233: Health risks posed by radiation exposure in Port Hope, Ontario

Date submitted: 4 January 2008

Petitioner(s): Pat McNamara

Summary: The petitioner is concerned about health risks posed by exposure to radiation. He is also concerned about the levels of radiation considered allowable in Canada. The petitioner questions the way Canada establishes allowable radiation levels. He suggests that the precautionary principle should be followed in establishing the levels of radiation allowed. He also wants to know why Canada has a different allowable level for tritium in drinking water than that allowed by the European Union and the United States. Finally, the petitioner seeks answers regarding the results of the November 2007 bio-testing of residents in Port Hope, Ontario, which showed the presence of uranium in some of the residents' bodies.

Issues: Human health/environmental health, natural resources, toxic substances, waste management, and water

Federal departments/agencies replying: Health Canada, Natural Resources Canada, Public Health Agency of Canada

Status: Reply (replies) received but not yet posted


Petition No. 234: Radioactive contamination in Port Hope, Ontario

Date submitted: 4 January 2008

Petitioner(s): Ms. N. Sarah Clayton

Summary: This petition is about radioactive and industrial contamination in the town of Port Hope, Ontario. The petitioner is concerned about health risks posed by the alleged contamination of an elementary school, and seeks answers from the federal government about actions taken on this issue. The petitioner also raises several questions on the environmental assessment process for the Port Hope Long-Term Low-Level Radioactive Waste Management Project.

Issues: Environmental assessment, human health/environmental health, natural resources, toxic substances, and waste management

Federal departments/agencies replying: Environment Canada, Health Canada, Natural Resources Canada

Status: Completed


Petition No. 235: Health risks posed by electromagnetic radiation exposure from cellular towers

Date submitted: 4 January 2008

Petitioner(s): Frank Woodcock

Summary: The petitioner is concerned about the guidelines of Safety Code 6, because a cellular tower has been installed 300 metres from his property without any public consultation. He is concerned about the health effects of the microwave radiation emanating from this tower. The petitioner asks Health Canada and Industry Canada whether it is safe to be exposed to electromagnetic radiation.

Issues: Environmental assessment, human health/environmental health, and science and technology

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) received but not yet posted


Petition No. 235B: Follow-up petition on the health risks posed by electromagnetic radiation

Date submitted: 24  June 2008

Petitioner(s): Frank Woodcock

Summary: In this follow-up petition, the petitioner alleges that the guidelines outlined in Safety Code 6 are outdated and are based on incorrect assumptions. The petitioner questions the objectivity of studies that were cited by the government and that, he claims, were funded by the cell phone industry or were from individuals with vested interests. The petitioner asks Health Canada to consider studies with other points of view and to consider implementing a precautionary approach to the electromagnetic radiation exposure of Canadians.

Issues: Human health/environmental health, science and technology, and other

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) pending


Petition No. 236: Nuclear-related environmental health concerns in Port Hope, Ontario

Date submitted: 4 January 2008

Petitioner(s): Port Hope Community Health Concerns Committee

Summary: This petition concerns the potential health and environmental impact of two nuclear facilities and of the radioactive and heavy metal wastes present in the town of Port Hope, Ontario. The petitioner seeks answers about health risks posed by the emissions from these wastes and by cumulative exposure to radioactive and heavy metal wastes in the area. The petitioner also requests that health studies and investigations be undertaken to assess and monitor the health of the community. Finally, the petitioner raises questions about the level of environmental assessment used for nuclear projects and requests that human health considerations be included among the criteria for environmental assessments and the licensing of nuclear projects.

Issues: Environmental assessment, human health/environmental health, natural resources, toxic substances, and waste management

Federal departments/agencies replying: Environment Canada, Health Canada, Natural Resources Canada, Public Health Agency of Canada

Status: Reply (replies) received but not yet posted


Petition No. 237: Low-level radioactive waste cleanup project in Port Hope, Ontario

Date submitted: 4 January 2008

Petitioner(s): Larry Hall

Summary: This petition relates to the Port Hope Area Initiative, a $260-million project agreed on by the Government of Canada and the municipalities of Port Hope and Clarington, for undertaking a cleanup of low-level radioactive waste in the area. According to the petitioner, the project is running behind schedule and he is worried that continuing delays could be costly for the municipalities and area residents. The petitioner seeks answers from the federal government about why it is taking so long, how much money has been spent, and what is being done on this issue.

Issues: Environmental assessment, governance, natural resources, toxic substances, and waste management

Federal departments/agencies replying: Environment Canada, Natural Resources Canada

Status: Completed


Petition No. 238: Water and sediment contamination of the Athabasca River due to oilsands production

Date submitted: 4 January 2008

Petitioner(s): Keepers of the Athabasca Alliance

Summary: The petitioner is concerned about water and sediment contamination downstream of industrial oilsands development on the Athabasca River, the Peace/Athabasca Delta, and Lake Athabasca. The petitioner is concerned that this contamination may affect the health of the people of Fort Chipewyan, Alberta.

Issues: Aboriginal affairs, fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada

Status: Reply (replies) received but not yet posted


Petition No. 239: Development of the Nahanni National Park Reserve

Date submitted: 29 January 2008

Petitioner(s): NWT & Nunavut Chamber of Mines

Summary: The petitioner is concerned about the transparency and objectivity of the consultation process for the development of the Nahanni National Park Reserve in the Northwest Territories. In particular, the petitioner raises questions on the Mineral and Energy Resource Assessment (MERA) process related to the proposed expansion of the park. The petitioner also focuses questions on the balance between conservation and economic development objectives.

Issues: Aboriginal affairs, environmental assessment, natural resources, toxic substances, and water

Federal departments/agencies replying: Indian and Northern Affairs Canada, Natural Resources Canada, Parks Canada Agency

Status: Completed


Petition No. 240: Environmental concerns regarding the Cacouna Marsh

Date submitted: 7 February 2008

Petitioner(s): Gérard Michaud

Summary: The petitioner is concerned about the steady environmental degradation of the land adjacent to the Cacouna Marsh. He makes a number of requests to the responsible departments, including balancing the operations and maintenance of the neighbouring industrial sites with the measures taken to conserve and protect the Marsh.

Issues: Biological diversity, environmental assessment, human health/environmental health, water, and other

Federal departments/agencies replying: Environment Canada, Transport Canada

Status: Completed


Petition No. 241: Mercury waste from compact fluorescent lightbulbs entering the environment

Date submitted: 28 March 2008

Petitioner(s): Gaston Hervieux

Summary: The petitioner asks what action the federal government has taken to safely recycle compact fluorescent lightbulbs, given that they contain mercury and present a danger to public safety and ecosystems. He claims that no method of any kind, such as packaging that could be reused to discard these lightbulbs in recycling bins, has been put in place to prevent this type of pollution. The petitioner requests, among other things, that various departments take action on this matter. He also asks for an explanation of the laws and regulations that apply to this issue, the size of the market for compact fluorescent lightbulbs, and the impact of this pollution on species at risk and on fish habitats.

Issues: Compliance and enforcement, fisheries, human health/environmental health, toxic substances, and waste management

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada, Industry Canada, Public Health Agency of Canada

Status: Reply (replies) received but not yet posted


Petition No. 242: Use of road salt at the 2010 Vancouver Olympics Cypress Bowl venue

Date submitted: 24 March 2008

Petitioner(s): Bruce McArthur

Summary: The petitioner is concerned about the use of road salt to clear snow from the access road and parking areas at the 2010 Vancouver Olympics Cypress Bowl venue. According to the petitioner, this contravenes an environmental assessment commitment to not use road salt at the site, covering the period from initial construction activities up to decommissioning of the Olympics infrastructure. The petitioner asks the federal government, among other things, what action will be taken to correct the situation.

Issues: Compliance and enforcement, environmental assessment, federal-provincial relations, human health/environmental health, and transport

Federal departments/agencies replying: Canadian Heritage, Environment Canada, Fisheries and Oceans Canada, Health Canada, Public Works and Government Services Canada

Status: Reply (replies) received but not yet posted


Petition No. 243: Use of fluoride (fluorosilicates) in drinking water

Date submitted: 17 April 2008

Petitioner(s): Robert Button

Summary: The petitioner seeks responses from the government on the addition of fluoride (fluorosilicates) to the water supply, which the petitioner alleges is a drug and is dispensed as a drug, but has never been approved as a drug. In addition, the petitioner claims that Canadian consumers cannot be reasonably expected to know the stated risks of fluoridated water. The petitioner raises questions concerning the government's definition, management, and regulation of fluoride.

Issues: Human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Health Canada, Public Health Agency of Canada

Status: Completed


Petition No. 244: Harm to susceptible populations of aquatic life and humans due to the addition of fluoride (fluorosilicates) in drinking water

Date submitted: 18 April 2008

Petitioner(s): James S. Beck

Summary: The petitioner seeks responses from the government on the addition of fluoride (fluorosilicates) in our drinking water, which he alleges causes adverse health effects on humans. The petitioner further claims that the addition of fluoride is also toxic and harmful to certain land species as well as to some species of fish. The petitioner raises several questions on the safe dosage and concentration levels of fluoride.

Issues: Fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Health Canada, Public Health Agency of Canada

Status: Completed


Petition No. 245: Impact of fluorosilicate compounds on lead levels in drinking water and on water distribution infrastructure

Date submitted: 2 May 2008

Petitioner(s): Environmental Training Institute

Summary: The petitioner seeks responses from several departments on potential health concerns related to increased levels of lead in drinking water due to fluoridation. In addition, the petitioner alleges that fluorosilicates have a detrimental effect on water distribution infrastructure and asks whether the government has carried out related cost assessments.

Issues: Environmental assessment, fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Department of Finance Canada, Fisheries and Oceans Canada, Health Canada, Public Health Agency of Canada, Public Works and Government Services Canada, Treasury Board of Canada Secretariat

Status: Completed


Petition No. 246: Potential environmental impacts of a proposed housing development project in Mission, British Columbia

Date submitted: 12 May 2008

Petitioner(s): A Canadian resident

Summary: The petitioner is concerned about potential adverse environmental impacts of a proposed 3,400-acre housing development project in Mission, British Columbia. The petitioner claims that this project would have major impacts on the aquatic ecosystems and terrestrial wildlife of this area. The petitioner asks that federal departments ensure that, among other things, comprehensive environmental assessments of this project be carried out.

Issues: Biological diversity, compliance and enforcement, environmental assessment, fisheries, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans

Status: Completed


Petition No. 247: Environmental health impact of electromagnetic radiation

Date submitted: 22 May 2008

Petitioner(s): A Canadian resident

Summary: The petitioner alleges that since 1999, scientific research has indicated an increase in health impacts related to electromagnetic radiation from cellular towers and other sources. The petitioner asks several departments to review Safety Code 6, to pass regulations for safer siting of cellular towers, and to mandate labelling of electromagnetic radiation levels of everyday products.

Issues: Compliance and enforcement, environmental assessment, human health/environmental health, and science and technology

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) pending


Petition No. 248: Environmental impact of toxic chemicals leaking into Lake Ontario

Date submitted: 26 May 2008

Petitioner(s): A Canadian resident

Summary: The petitioner is concerned about the environmental impact of toxic chemicals leaking into Lake Ontario from a uranium processing facility in Port Hope, Ontario. The petitioner asks federal departments what action has been taken and if the company has been given a deadline to remediate the contamination. The petitioner also asks the departments for independently verified information on the amount of contaminants released into the lake.

Issues: Compliance and enforcement, fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada

Status: Reply (replies) received but not yet posted


Petition No. 249: Potential environmental impact of the Devils Lake outlet project on Canadian waters

Date submitted: 12 June 2008

Petitioner(s): The Manitoba Chambers of Commerce and Friends of the Earth

Summary: The petitioners are concerned about the potential environmental impact that the Devils Lake outlet project in the United States may have on the Red River and Lake Winnipeg and their commercial and recreational fisheries. They are worried that the outlet project may cause water pollution and introduce invasive species that will harm the environment and the economy of communities around the Red River Basin and Lake Winnipeg. Among other things, the petitioners ask what the government is doing to advance and enforce the related 2005 agreement between Canada and the United States and to prevent and monitor the impact of the project.

Issues: Governance, human health/environmental health, international cooperation, and water

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans, Foreign Affairs and International Trade Canada

Status: Reply (replies) pending


Petition No. 250: Petition withdrawn


Petition No. 251: Federal policy related to potential bulk freshwater exports

Date submitted: 17 June 2008

Petitioner(s): Erinn Burke

Summary: The petitioner is concerned about the absence of federal policy to protect Canada's freshwater from being exported in bulk and/or diverted and asks the federal government, among other things, to explain its strategy for protecting Canadian freshwater. The petitioner is also concerned about the impact of trade agreements on this issue and asks the government what is being done to revise the current NAFTA definition of water, which may help protect Canada's water resources.

Issues: Federal-provincial relations, international cooperation, natural resources, and water

Federal departments/agencies replying: Environment Canada, Foreign Affairs and International Trade Canada, Natural Resources Canada

Status: Reply (replies) pending


Petition No. 252: Environmental health issues related to a hydroelectric transmission project in Tsawwassen, British Columbia

Date submitted: 17 June 2008

Petitioner(s): A Canadian resident

Summary: The petitioner alleges that a significant, new hydro transmission project in their community will cause immediate and long-term health issues for the residents. In addition, the petitioner claims that this project will pose a threat to both endangered and migratory birds.

Issues: Biological diversity, compliance and enforcement, human health/environmental health, science and technology, and other

Federal departments/agencies replying: Department of Justice Canada, Environment Canada, Foreign Affairs and International Trade Canada, Health Canada, Industry Canada, Public Safety and Emergency Preparedness Canada

Status: Reply (replies) pending


Petition No. 253: Potential adverse health effects from phones using Digital Enhanced Cordless Telecommunications

Date submitted: 20 June 2008

Petitioner(s): Magda Havas

Summary: The petitioner is concerned that phones using Digital Enhanced Cordless Telecommunications (DECT) may expose people to adverse health effects from electromagnetic radiation. The petitioner requests a ban on these phones. In addition, the petitioner asks what the federal government is doing to protect Canadians from these potential adverse health effects and what research it is conducting or funding on the safety of this technology.

Issues: Human health/environmental health, and other

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) pending


Petition No. 254: Environmental and human health effects of compact fluorescent light bulbs

Date submitted: 23 June 2008

Petitioner(s): Magda Havas and Thomas Hutchinson

Summary: The petitioners are concerned about a number of environmental and human health issues associated with compact fluorescent light bulbs. The petitioners state that these issues include emissions of ultraviolet (UV) and radio frequency radiation, the generation of electrical pollution, the mercury content in the bulbs, and safe recycling and disposal. The petitioners allege that compact fluorescent light bulbs make some people ill and ask the government to take measures to reduce or eliminate the problems associated with them and to consider alternative technologies.

Issues: Climate change, human health/environmental health, toxic substances, waste management, and other

Federal departments/agencies replying: Environment Canada, Health Canada, Industry Canada, Natural Resources Canada

Status: Reply (replies) pending


Petition No. 255: Health impact of electromagnetic radiation from telecommunication towers located in close proximity to residential areas

Date submitted: 25 June 2008

Petitioner(s): Dennis Noble and Sharon L. Noble

Summary: The petitioners allege that electromagnetic radiation emitted from telecommunication towers is causing significant health issues to people living in close proximity to these transmitters. The petitioners raise questions about the objectivity of scientific studies supporting the government's position related to the potential health hazards of electromagnetic radiation and about the perceived independence of department staff assessing these studies. In addition, the petitioners request that Health Canada invoke the precautionary principle in order to safeguard Canadians.

Issues: Governance, human health/environmental health, science and technology, and other

Federal departments/agencies replying: Health Canada, Industry Canada

Status: Reply (replies) pending


Petition No. 256: Policies and regulations under the Canadian Environmental Protection Act, 1999

Date submitted: 25 June 2008

Petitioner(s): Calvin Dempster and a Canadian resident

Summary: The petitioners raise concerns about what they believe are shortcomings in some of the policies and regulations that are part of the Canadian Environmental Protection Act, 1999 (CEPA 1999). They ask the government several questions about, among other things, the Environmental Emergency Regulations, public participation, the Masked Name Regulations, the assessment and management of toxic substances, the Virtual Elimination List, and enforcement of CEPA 1999.

Issues: Compliance and enforcement, governance, and toxic substances

Federal departments/agencies replying: Environment Canada, Health Canada

Status: Reply (replies) pending


Petition No. 257: Potential environmental and health impacts of soil contaminated with heavy metal and deposited in a landfill near Lake Erie

Date submitted: 26 June 2008

Petitioner(s): Alexander Davidoff and Olivera Davidoff

Summary: The petitioners allege that soil contaminated with heavy metal has been deposited in a landfill site close to Lake Erie. The petitioners are concerned about the potential environmental and health impacts, such as contamination of groundwater and harm to fish habitat and ecosystems. The petitioners request that the contaminated soil be removed from the landfill and that certain federal departments assess the potential risks to Canadians and ecosystems.

Issues: Fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Health Canada

Status: Reply (replies) pending


Petition No. 258: Alleged pumping of water contaminated with mercury from a brownfield development into a sewer system near Lake Ontario

Date submitted: 26 June 2008

Petitioner(s): Alexander Davidoff and Olivera Davidoff

Summary: The petitioners allege that water contaminated with mercury was pumped from a brownfield development into a sewer system that spills into Lake Ontario. They are concerned about the related potential environmental and health impacts, such as contamination of drinking water and harm to Lake Ontario fish habitat and ecosystems. The petitioners ask the federal government whether it will conduct health studies on the communities near Lake Ontario.

Issues: Compliance and enforcement, fisheries, human health/environmental health, toxic substances, and water

Federal departments/agencies replying: Environment Canada, Health Canada

Status: Reply (replies) pending


Petition No. 259: Health concerns related to the construction of a high-voltage power line in Tsawwassen, British Columbia

Date submitted: 27 June 2008

Petitioner(s): John R. Bulloch and Dr. Bruce D. Owen

Summary: The petitioners are concerned about the potential health impacts that the construction of a high-voltage power line in a densely populated area of Tsawwassen, British Columbia, could cause to people living near the power lines. The petitioners present summaries of studies related to electromagnetic effects on human health, and would like to know, among other things, who has the authority to halt the construction of the power line. In addition, the petitioners ask questions related to health concerns raised during the environmental assessment of the power line project.

Issues: Environmental assessment, federal-provincial relations, human health/environmental health, and other

Federal departments/agencies replying: Environment Canada, Fisheries and Oceans Canada, Health Canada

Status: Reply (replies) pending


Petition No. 260: Electromagnetic sensitivity

Date submitted: 30 June 2008

Petitioner(s): Joanne March Laberge

Summary: The petitioner is concerned that there is little research being conducted to understand pain and discomfort caused by electromagnetic sensitivity and to help people suffering from it. The petitioner wants to know what the federal government has done to acknowledge and deal with this illness and to warn Canadians of the dangers of electromagnetic fields.

Issues: Human health/environmental health, and other

Federal departments/agencies replying: Health Canada

Status: Reply (replies) pending


Petition No. 261: Public participation process related to the Sydney Tar Ponds and Coke Ovens Remediation Project

Date submitted: 30 June 2008

Petitioner(s): Sierra Club of Canada

Summary: The petitioner is concerned that recommendations made by the Joint Review Panel, with respect to public participation in the Sydney Tar Ponds and Coke Ovens Remediation Project, have not been implemented adequately. The petitioner is worried that the actual process for community participation is not open and transparent and that it lacks sufficient public input. The petitioner presents several recommendations to the government to improve the public participation process.

Issues: Environmental assessment, human health/environmental health, and waste management

Federal departments/agencies replying: Environment Canada, Public Works and Government Services Canada

Status: Reply (replies) pending


Definition:

Low-level radioactive waste—All forms of radioactive waste except spent nuclear fuel (which is high-level waste) and waste resulting from uranium mining, milling, and mill tailings. (Return)

 

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