Regarding ERO File 019-0481…

Regarding ERO File 019-0481

1.There are no safe water quality limits (PWQO or Canadian Environmental Quality Guidelines) for a large number of Pesticides whose labels indicate toxic to the ecosystem i.e. Iprodione Mercoprop, Fluidoxonil, Fosetyl-AL , Propiconazole, Trifloxystrobin, Triticonazole. Environment Canada studies support this finding.
2. There are pesticides being applied that we can find no MECP licensed/certified laboratories that can test for their presence i.e., Foestyl-AL, Triticonazole. University of Guelp, Lakeside
3. At present, 2018 Pesticide Reports are posted too late i.e., up to 20 months from application for any required corrective action. The proposed date of January 31, 2019 is still too late for corrective actions. We recommend the filing of pesticide applications should be done as soon as possible i.e., within 5 days of their application and that the pesticide applied be posted on the golf club’s website at that time and made available to the public.
4. Monitoring of golf club’s surface and ground waters is seldom done to confirm that the water is safe and has no impact on the environment. There should be monitoring.
5. Pesticide mixtures are regularly applied and there is no testing by Health Canada to show the impact of mixtures. The active ingredients when blended could be additive, that is their toxicity when blended would be higher than when used separately.
6. The Best Management Practices that many of the golf courses recommends maintaining adequate vegetated buffers from ponds and watercourses to prevent erosion and the run-off of suspended solids which are detrimental to the surface waters and could contain pesticides. This requirement needs to be made mandatory
7. We recommend that Blue Mountain Watershed Trust’s report on Watershed Pesticides Concerns be reviewed as a source document for the above comments.