Comment
The Ministry of Environment, Conservation and Parks should take this opportunity to correct an error in the table of circumstances for significant threats.
The circumstance tables for pesticide application still say that Atrazine, Dicamba, Dichlorophenoxy Acetic Acid (2,4-D), MCPA (2-methyl-4-chlorophenoxyacetic acid ), MCPB (4-(4-chloro-2-methylphenoxy)butanoic acid ), Mecoprop, Metalaxyl, Metolachlor or s-Metolachlor are significant threats in a WHPA A when application is in an area greater than 10 ha.
This is a mathematical impossibility.
No matter how hard you try, you can't fit 10 ha. into a 100 m radius circle (WHPA A).
A 100 m radius circle has an area of 3.1415926536 ha.
Therefore, none of those pesticides are significant threats in a WHPA A but they can be significant in a WHPA B which is further away from the well.
This does make sense and needs to be corrected.
They should make all the listed pesticide chemicals significant threats in a WHPA A regardless of the area of application.
The result would be that pesticide use in the WHPA A would be managed.
The way things currently stand they are not significant threats and are therefore not managed by any Part IV policies under the Source Protection Plans.
Submitted September 28, 2020 2:35 PM
Comment on
Proposed amendments to the Director’s Technical Rules made under section 107 of the Clean Water Act, 2006
ERO number
019-2219
Comment ID
48642
Commenting on behalf of
Comment status