Subject: 3rd submission: Trophic status determination and an addendum to our 2nd submission dated February 19, 2008

 

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Addendum to our 2^nd submission: We request that your department adopt an official policy on Lake Carrying Capacity that is similar to that of the Province of Québec (see a select extract here in French), or to the one proposed by the Province of Ontario. Those policies are based on the `natural background values’ in Total Phosphorus, i.e., those values that existed prior to any disturbance in the watersheds; hence they take into account the varying concentrations in lakes/ponds throughout the Province.

 

3^rd submission: Our recommendations on trophic status determination:--

 

We request that the department immediately implement the final recommendations of the peer consensus, 16-year, 18-country Organization for Economic Co-Operation and Development (OECD) research which also forms the primary backbone of the Canadian Council of Ministers of Environment- CCME (2004) guidelines on trophic states. But the CCME committed grave errors which we enunciate below.

 

The final recommendation of the OECD is clearly enunciated in our webpage titled, OECD Probability Distribution Diagrams, which also contains a 4-minute mp3 sound extract from hours of our intense discussions with the OECD’s chief scientist, Dr. Richard Vollenweider.

 

We are willing to submit the entire taped discussions with Dr. Vollenweider on a written request of your Minister of the Environment.

 

(But the CCME committed severe scientific errors by not taking into account the OECD’s probability distribution diagrams, and thus the CCME ignored the fact that Total Phosphorus represents phosphorus species of varying `biological availability’, a fact known to most authentic limnologists!)

 

Herewith we state that the majority of studies conducted in Nova Scotia do not take into account the probability distribution diagrams and this includes reports published by your own staff which you have cited in your related webpage, and thus you are totally misleading the citizens who may access that website, alas!

 

In addition, most of Nova Scotia’s lakes are shallow, and in order to set the trophic status at a high confidence level, one has to take into account the littoral production as well.

 

We have been implementing that modus operandi in some of our formal studies indeed.

 

And finally, kindly study the 3-page informal submission we made to your manager, David Briggins, on May 22, 2002.

 

 

 

 

Shalom Murti Mandaville Post-Grad Dip., Professional Lake Manage.

Chair & Scientific Director

Soil & Water Conservation Society of Metro Halifax- SWCSMH, a multi-discipline scientific/technical stakeholder group

 

 

 

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