Honourable David Anderson
Minister of the Environment
28th floor, 10 Wellington Street
Terrasses de la Chaudière
Hull QC K1A OH3

April 15, 2002

Dear Minister Anderson:

We the undersigned organizations are writing this open letter to you today to notify you of the serious concern we have with respect to increasing levels of mercury in the Canadian environment.   We are requesting that you take precautionary measures that protect the health and well-being of Canadians as you consider the Canada Wide Standard for mercury from coal-fired power plants.  We are asking that you introduce a standard that will reduce the absolute emissions of mercury from coal-fired power plants by 50 percent by 2005 and by 90 percent by 2010.  Present proposals from governments and industry to delay the setting of a standard and to set a weak “capture rate”-based standard will lead to thousands of kilograms of mercury emissions from the coal-fired power sector.  

New medical evidence has concluded that even very low levels of mercury can cause neurological and developmental damage to unborn babies and young children.  The National Academy of Science, the Centre for Disease Control and the Federal Drug Administration (three influential American institutions) have each recently issued reports or advisories warning of the newly discovered dangers of mercury pollution.

Mercury levels are increasing in the Maritimes and New England, due to the concentration of coal plants in the Midwest and Ohio Valley.  Over 90 percent of the fish advisories in eastern Canada are due to high levels of mercury. The US EPA and individual US states are planning aggressive actions to control mercury emissions. The Canadian commitment to reduce mercury emissions from coal-fired electricity generators remains unclear.

Early indications suggest that certain provincial governments are unwilling to take actions to control mercury emissions from coal-fired power plants.  Economic interests are clearly dominating these decisions, with little regard for the health and well-being of humans or ecosystems.  This is contrary to the principles articulated at the outset of the Canada Wide Standards process.  

We recognize that mercury pollution is a complicated issue and that there are many sectors and countries contributing to the problem.  We also know that many sectors in Canada and elsewhere have achieved significant reductions to date as a result of international regulations (e.g. paints, batteries, pesticides) or process changes (e.g. smelting).  Many remaining sectors are being addressed through the Canada Wide Standards (e.g. incineration, dental waste).  The coal-fired power plant sector is one of the last remaining large emitters of mercury with no control strategy in place.  

Our recommendation of a 90% mercury emission reduction standard from the Canadian electric power generation (EPG) sector is achievable with currently available technology.  An international panel of experts brought together by the Commission on Environmental Cooperation (CEC) met in Montreal in March, 1999 and determined that a 90% mercury emission reduction rate could be realized through the application of existing technology to coal-fired electricity generators. Significantly greater mercury emission reduction is possible through renewable energy sources, energy conservation programs and conversion to less polluting fuels, such as natural gas.

Environment Canada’s own studies confirm that voluntary actions do not lead to emission reductions where incremental costs are involved, or to investment in control technologies in the absence of regulation. We are therefore urging you to sign a standard that will be meaningful in the eyes of Canadians and set us on the path for 90% mercury reductions from the EPG sector.  The undersigned organizations will be following the decision at the May meeting of Ministers closely.

As the world’s leading mercury medical research scientist (Dr. Phillipe Grandjean) said in a published journal article:

The current disagreement between regulatory agencies concerning mercury should not be blamed on discrepancies in epidemiologic evidence.  A wealth of highly relevant information already exists on this pollutant.  Given the existence of many other neurotoxicants about which we know much less, a regulatory stalemate on mercury is bad news for the protection of the brains of future generations.

Yours truly,

24 Mercer St., Suite 102, Toronto, ON M5V 1H3
ph: 416-960-9606fax: 416-960-0020
eastern.canada.chapter@sierraclub.org
http://eastern.sierraclub.ca