Notice of objection filed by the World Wildlife Fund (WWF) and the Canadian Environmental Law Association (CELA)

11 April 2001

By Facsimile
(Original to follow)
819-953-3457

Hon. David Anderson, P.C., M.P.
Minister of Environment
Government of Canda
Terrasses de la Chaudière, 28^th Floor
10 Wellington Street
Hull, QC K1A 0H3

Dear Minister:

The 1969 PCPA and 1999 CEPA are founded on different principles. This difference is apparent in the relevant operational provisions. For example, the precautionary principle is a cornerstone of CEPA 99 and is not part of the current PCPA. Further, public participation in environmental decision-making is another cornerstone of CEPA and is also not part of the current PCPA.

We appreciate your on-going commitment to the health of Canadians and their environment and encourage your vigilance in respect of this important phase of CEPA 99 implementation. The PCPA was passed in 1969. Since then, we have learned a lot about pesticides, for example, endocrine disruption, the special vulnerability of children and wildlife and the consequences of bioaccumulation in the North.

Pesticide management in Canada is long overdue for a major overhaul, led by a renewed, publically supported PCPA. It is our hope that new pest control legislation will remedy the failings enumerated in this Notice of Objection. Until that time, we strongly believe that the PCPA should not be judged as CEPA-equivalent.

Thank you, in advance, for your prompt attention to this matter.

Yours truly,

c.c.

• Hon. Allen Rock, P.C., M.P., Minister of Health
• Cynthia Wright, Director General, Strategic Priorities Directorate
  Environmetal Protection Service, Environment Canada
• Arthur Sheffield, Team Leader, Regulatory and Economic Analysis Branch
  Policy & Communications, Environment Canada