OPEN LETTER to Hon. Rick Doucet, Minister of Dept. of Energy and resource Development

March 16, 2017

Minister Rick Doucet, Minister DERD
Agricultural Research Station (Experimental Farm)
P. O. Box 6000
Fredericton, NB
E3B 5H1
Canada

Dear Honourable Rick Doucet,

Mr. David Coon’s office has forwarded your letter in response to petition 3, which was tabled in the Legislature on December 6, 2016 by Mr. David Coon (MLA Fredericton South) to our group, Stop Spraying NB. We have reviewed your letter and have prepared a response.

Please review our comments and references. Our group strongly stands by our request to stop herbicide spraying of our Crown forest land and NB Power rights of way. New Brunswick tax payers are paying $2.2M annually for this spray program with no benefit in return: less jobs, less revenue for the province and loss of biodiversity.

Stop Spraying NB and allies request a meeting to make a presentation to you and your department at your earliest convenience. We will need one hour to allow enough time to cover our arguments and answer questions.

Regards,

Dr. Caroline Lubbe-D’Arcy on behalf of SSNB
Ms. Jean MacDonald on behalf of Écovie
Stop Spraying New Brunswick (SSNB)
P.O. Box 20313, King’s Place Post Office
Fredericton, NB
E3B 0N7

March 16, 2017

RESPONSE to Minister Rick Doucet’s letter dated Dec. 21, 2016, regarding “petition 3” (re: Herbicide Spraying) which was tabled in the Legislature on December 6, 2016 by Mr. David Coon, MLA Fredericton South.

SSNB addresses each point made by Minister Doucet in this response:

Minister Doucet: “Our forestry sector is important to the New Brunswick economy. More than 20,000 New Brunswickers put food on the table each day because of jobs in forestry.”

SSNB’s response:
The proponents of the discontinuation of chemical herbicides are very aware of the forestry
sector’s major role in the economy of New Brunswick, and in fact suggest alternatives that
would increase employment such as the use of mechanical silviculture. This in turn would put more food on the table of New Brunswick residents. Thinning also leads to more biodiversity, and a sustainable forest sequesters a considerable amount of carbon which along with other measures plays a role in climate change mitigation (Jared 2010).

Minister Doucet: “A very small portion of Crown forests gets treated annually. The use of herbicide is very selective and generally done once or twice during the forest’s lifecycle.”

SSNB’s response:
Could the Minister be more specific regarding the exact amount of crown (unceded) land that is being “selectively” sprayed e.g. in terms of percentages? In fact there are 13,000 hectares of forest plantation sprayed in NB annually, at a cost of over 2 million taxpayer dollars. New Brunswick is ranked second after Ontario in the the amount of glyphosate used for forest management ( Report prepared for NB OCMOH on glyphosate). In 2014, 28% of the glyphosate used in forestry in Canada was sprayed in New Brunswick alone. In terms of selective spraying, environmental groups have heard of reckless spraying tactics near lakes and cottages which have put residents at risk. The use of glyphosate also occurs near sugar bushes, which could compromise their ability to be considered organic suppliers. Through the Right to Information Act it has become evident that some parcels of land have been sprayed up to three times.

Minister Doucet: “Making sure our forests are productive is vital to having a competitive and viable forest industry. As a result of our management practices, New Brunswick continues to have a vibrant and and healthy forests and forest ecosystem. The vast majority (more than 75%) of our forest regenerate naturally. Less than 25% of the areas harvested are regenerated through planting a variety of tree seedlings.”

SSNB’s response:
The Province of Quebec’s forest industry has remained competitive in the world market without the use of herbicides, and it has used selective cuts to promote a sustainable forest with enhanced biodiversity. In New Brunswick the actual percentage of Crown/unceded land targeted, harvested and converted to plantations (as permitted by the 2014 Forest Strategy) is 40% and not 25%. It is important to note that the most fertile, most productive soils and sites are always targeted to be planted and sprayed versus being allowed to regenerate naturally. Less than half of the remaining 60% grows browse suitable to sustain deer, as has been found in two independent reviews by the past two deer biologists at DERD. It is common knowledge that the deer population in northern New Brunswick has been drastically reduced. Access to food sources for deer has been greatly reduced over the years, because clear-cuts sprayed with herbicides and converted into plantations (versus natural regeneration) do not provide such resources.

Minister Doucet: “We are using a number of new technologies and modern techniques to better manage our forests. Our seedlings are third generation plus trees with improved growing characteristics. Herbicide is only one tool used to help these planted trees survive the early competitive vegetation that would otherwise prevent then from growing freely.”

SSNB’s response:
It needs to be pointed out that the forestry companies are using the most productive forest land found in the Crown/unceded Acadian Forest, which could also explain the improved growth seen in those areas. If the public was aware that the most productive forest land is being turned into plantations as opposed to allowing natural regeneration,: they would be even more opposed to this forest ‘management’ approach. Additionally, the use of new technology to improve the rate of growth of seedlings is not conducive to the regeneration of an original and natural Acadian forest. This remains important to many New Brunswickers as well as to aboriginal people. In a mixed managed forest, seedlings of an appropriate height would grow without the use of chemical herbicides. Again, the bottom line remains; money takes precedence over legitimate concerns of the people who have entrusted this Department to prioritize their best interests. Instead, our government is perceived as catering to big corporations whose only motivation is to make a profit on the backs of the taxpayers of New Brunswick.
We do not consider poplar, maple, alder, and oak trees to be weeds, neither are berry bushes, dogwood or any deciduous tree. They are a part of a natural ecosystem that provides jobs through sugar bushes, the production of cabinets, hardwood floors and furniture. They also provide food for foragers, animal and human alike and habitat for fauna and flora. Conifer- dominated plantations in central and northern Europe are associated with relatively low ecological values, and in some cases, may be vulnerable to disturbances caused by anthropogenic climate change. (Felton 2010).

Minister Doucet: “The Department of Energy and Resource Development is committed to sharing information about herbicides in forestry to address New Brunswickers’ concerns. We are working with our partners and some of the countries leading scientists to do this. In fact a lot of great information on this topic can be found at www.ForestInfo.ca.”

SSNB’s response:
SSNB insists that all current research done by independent scientists should be included on www.forestinfo.ca. When we investigate your suggested web site www.ForestInfo.ca, we only find referenced the exact same government-sponsored scientists as those who toured New Brunswick pontificating the virtues of clear cuts, and the use of herbicides; this website is clearly biased in favour of one point of view. Are the scientists referenced on www.forestinfo.ca the only “specialists” in Canada? New Brunswick researchers and scientists, such as Dr. Rod Savage, Dr. André Villard, Dr. David Coombs, retired  NB Deer Biologist Rod Cumberland and many other in-province experts view the material on www.forestinfo.ca as biased, unscientific, and an insult to the average New Brunswicker’s intelligence. Would it be possible for the Minister to provide us with the government- sponsored 2 year studies performed on mice? Apparently these studies showed that glyphosate posed no negative impacts on its subjects? Would it be possible to establish the validity and reliability of such experiments by independent scientists?


Minister Doucet: “On May 16, 2016, The World Health Organization , in conjunction with the United Nations Food and Agriculture Organization reiterated its findings that glyphosate is unlikely to to pose a carcinogenic or genotoxic risk to humans from exposure through diet. Other world organizations have made multiple, similar statements.”

SSNB’s response:
In March 2015, the International Agency for Research on Cancer (IARC) stated that glyphosate is a probable cause of cancer (Guyton, Kathryn et al, Nov. 2015. Despite the World Health Organization’s (WHO), and the European Food and Safety Authorities’ (EFSA) withdrawal of this classification in November 2015, the findings of the IARC resonated at an international level. The WHO and the EFSA were quoted as saying that glyphosate is “unlikely” to be carcinogenic for humans. The word “unlikely” does not inspire  confidence. The fact remains that the scientists on the IARC panel were vetted to dismiss possible bias, and represented a wide range of qualified scientists as explained during a CBC radio show by Dr McLaughlin, a Canadian environmental health epidemiologist, who served on this panel. Despite the fact that research into health effects of glyphosate is in its infancy and there is a need for research to duplicate evidence of the effects of glyphosate, there still remain many documents written by reputable scientists which are available for government scrutiny. Can Health Canada or Environment Canada do the same for us, or is this considered to be confidential? When Dr. Dean Thompson, a research scientist and Environmental Chemist, was asked if he believed that all scientists who had found health hazards through their rigorous and peer- reviewed studies should be considered credible, he answered that there were only a “a handful” of credible studies. Is this arrogance or ignorance? By contrast, the body of studies referenced by Pest Management Regulatory Agency (PMRA) staff regarding toxicology are largely unpublished, non-peer- reviewed and submitted by the corporations themselves. Only seven of the 118 studies used to assess the toxicology of glyphosate were actually published studies that were not provided by the corporations, and of those seven studies, only one was considered by the IARC (Ecojustice 2015). 
This fact highlights Dr Thompson’s misconception that all studies considered by the PMRA are credible, peer reviewed research.

Minister Doucet: “Glyphosate herbicides continue to be safely used in forestry and agriculture around the world as stated in a recent review by the Acting Chief Medical Officer, and supported by Ontario’s Chief Science Officer and Senior Scientist.”

SSNB’s response:

SSNB needs to correct your statement regarding New Brunswick’s Acting Chief Medical Officer. Dr. Russell did not look into safety of glyphosate but simply looked at what other jurisdictions do and how much New Brunswick uses.
The majority of studies that Health Canada has relied on are 90- day studies performed by Monsanto, which are toxicity studies, and not long- term studies of health exposure. These are less than conclusive and do not show the long term effects of exposure to glyphosate. Furthermore, an increasing number of countries are banning or at least partially banning the use of glyphosate due to health concerns. These include Argentina, Malta, the Netherlands and Sri Lanka. The Province of Quebec has banned forest spraying with glyphosate since 2001, and Nova Scotia no longer subsidizes industry spraying forests with glyphosate. In 2015 the European Union denied Monsanto’s request to commit to a 10- year extension of the use of glyphosate. Due to concerns voiced by an increasing number of scientists and growing public pressure the European Union announced instead an eighteen  month extension to allow for further research and the review of existing research.
In 2012 Dr. Seralini published an independent study in a well- respected journal which documented the negative effects related to the use of glyphosate on rats over a period of 700 days. The results showed alarming rates of tumours and negative effects on livers, kidneys, and organs associated with the endocrine system (Seralini 2014). There was an immediate response by Monsanto, who managed to implant a scientist with no background in plant studies or pesticides into the senior editorial board of that scientific journal. Within a few weeks Dr. Seralini’s article was retracted by the same journal that had once found it appropriate for publication. The study was republished in 2014 in Environmental Science Europe, after the scientific community voiced its anger with corporate interference. If a multi-million dollar company has tentacles that can reach into the world of science, can they not reach into government agencies and policymakers? A paper published by Antoniou et al. (2012) shows clearly how regulatory processes ignore science and are plagued by industry pressure. Canadians and indigenous people have very little trust in government agencies. Perhaps it is time to listen to the people and forego the blatant lies and manipulations of industry and some Government sectors. The Precautionary Principle states “when the health of humans and the environment are at stake, it may not be necessary to wait for scientific certainty to take protective action”(Science and Environmental Health Network. Precautionary Principle. August 11,2016, p. 1). The public of Quebec voiced their concerns and the Quebec Government listened. To date 27,225 citizens (5% of the population) of New Brunswick have voiced their concerns through petitions seeking a ban on glyphosate spraying. Maybe it’s time that the government listens.

Minister Doucet: “I can assure you that the Government and the forest industry are continually evaluating ways to minimize the amount of herbicide needed to effectively control competing vegetation.”

SSNB’s response:
Why won’t the government and forestry sector invite environmental groups, forestry experts, woodlot owners and local community stakeholder groups to the table to discuss alternatives to spraying? These groups and individuals have the experience, knowledge, and expertise to participate in discussions which would identify viable alternatives to the use of herbicides. The people and groups consulted  should not be motivated by politics or monetary benefits in providing expertise and original solutions.

Minister Doucet: “The principle of integrated vegetation management along with better education and awareness programs will help alleviate concerns over responsible forest management.”

SSNB’s response:
The amount of spraying in New Brunswick is perceived by the public as being hazardous to the health of all living creatures, and it is believed that the amount used is far greater than the Government of New Brunswick has stated. Environmental groups across the province are committed to promoting education and public awareness of this threat to their wellbeing. Applying the precautionary principle would mandate a moratorium on spraying herbicides, such as glyphosate, until an independent commission was able to determine its safety. This would provide time to review current and independent studies as well as networking with counties who have banned the use of glyphosate. As always, environmental groups, forestry experts, community stakeholders and woodlot owners would support and provide any assistance required to facilitate this approach. There are many people who did not sign the petition for fear of repercussions from their employer. On election day 2018 the New Brunswick voters may very well vote with their conscience, behind the safety of a piece of cardboard, for political candidates who will stand up for constituents. Environmental and other advocacy groups will work hard to inform voters about what is best for them, their children and their children‘s children’s future.

SSNB and its allies are requesting a meeting with the Minister as soon as possible to further discuss issues surrounding the use of glyphosate.

Respectfully,

Stop Spraying NB (SSNB)


References:
Gordon B. Bonan. Forests and Climate Change: Forcings, Feedbacks, and the Climate Benefits of Forests.Science 2008 p 1444.

Ecojustice, Canadian Environmental Law Association, Wilderness Committee, Ontario Nature Canadian Physicians for the Environment, Equiterre, David Suzuki Foundation and Friends of the Earth, in a letter to the Honourable Rona Ambrossse, Minister of Health ,Health Canada June 12,2015.

Felton et al. Replacing coniferous monocultures with mixed species production stands: An assessment of the potential benefits for forest biodiversity in northern Europe. Forest Ecology 260, 2010 p. 939.

Guyton, Kathryn et al on behalf of the International Agency for the Research on Cancer Monograph working group March 2015.

FAQS. Science and Environmental Health Network. Precautionary Principle. August 11,2016, p. 1.

Serelini et al. Long term toxicity of a Roundup herbicide and Roundup-tolerant genetically modified maize. Environment Science Europe. 26:14, 2014 pp 3-17.

Results of the OCMOH Action Plan on Glyphosate, A report prepared for the Acting Chief Medical Officer of Health (July 29, 2016) page 6

Antoniou, et al: Teratogenic effects of glyphosate-based herbicides: Divergence of regulatory decisions from scientific evidence. Journal of Environmental and Analytical Toxicology S:4 (2012)


 

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