Testimony of Cheryl Mendoza of the Alliance for the Great Lakes
on Coast Guard Live Fire Proposal
October 18, 2006
Good afternoon. My name is Cheryl Mendoza and I am the Manager of Water Conservation Programs for the Alliance for The Great Lakes, the oldest Great Lakes citizen action group. As an organization, the Alliance has been actively involved in Great Lakes protection since its founding in 1970.
I would first like to thank the Coast Guard for their Great Lakes clean-up efforts in cooperation with the Alliance for the Great Lakes’ Adopt-a-Beach program in Michigan, Indiana and Illinois. Current and retired Coast Guard staff has given their most valuable resource – their time – to improve and enhance recreational beaches in Chicago, Indiana, and several cities in Michigan including Grand Haven. This commitment to cleaning up the Great Lakes with the help of friends and family speaks volumes about the Coast Guard’s dedication to a healthier Great Lakes. Secondly, I would thank you for extending the public comment period. This has allowed the Alliance and concerned citizens an opportunity to better understand the Coast Guard’s proposal.
The Great Lake – An International Treasure In Peril
Here in our backyards we have one of the natural wonders of the world, a gift of nature, and an economic engine for our region – the Great Lakes. Their beauty and bounty enriches our lives. These precious waters are a resource for us to use and protect. Historically, we have arrogantly dumped waste into the Great Lakes, assuming that the vast resource would not be damaged.
How wrong we were. The Great Lakes are virtually a closed system, with less than one percent of the water in the lakes renewed each year. This means that what we put in the lakes generally stays in the lakes. As a result, pollutants have been building up in the Great Lakes ecosystem for many years. Some persistent chemicals, including lead compounds found in bullets, do not tend to break down in the environment. These chemicals enter the food chain at the most basic levels, ending up in humans through the fish we eat and the water we drink. They build up in the bodies of animals and people, and affect development and survival for generations. Persistent chemicals have been linked to developmental delays in children, attention deficit disorders, impaired immune systems, reproductive disorders, even diabetes and heart disease.
Great Lakes and Great Recreation
Despite this legacy of pollution, the waters of the Great Lakes continue to provide unparalleled recreational opportunities, and we find that those who know the lakes best are often those who use it the most. The Great Lakes support a $5 billion sportfishery – an industry that is absolutely dependent on recreational boating. Tourism and recreation is the lifeblood of our regional economy. At a time when economic growth is critical to the state of Michigan, we should be doing everything we can to keep our Great Lakes open and welcoming for recreation. We ask that USCG develop a new iteration of the plan for live fire zones on the lakes with the full cooperation and support of recreational boaters and anglers.
Impacts Beyond This Generation
In addition to the immediate impacts on our tourism economy, the Alliance has serious concerns over the long-term impacts of lead deposition in the Great Lakes. Under the current live firing plan, the Coast Guard would nearly double the annual amount of lead discharged to surface waters from the entire state of Michigan into the Great Lakes. This type of activity obviously calls for a detailed, long-range environmental impact statement before commencement. Unfortunately, the existing environmental assessment:
Is short-sighted, with only a 5 year outlook for potential problems
Does not consider the locations of “critical habitat, special – status species or potable water intakes”;
Fails to account for “compounding existing levels of contamination with the potential for cumulative impacts” despite acknowledging that “plants and animals that exist at the bottom of the food chain might ingest and be directly exposed to the metals in the sediment”; and
Ignores migratory bird patterns.
Better Evaluation Needed to Protect Great Lakes Ecology
The study used a numerical “screening quotient” score for pollutants that will be released to the lakes. Scores of 1 or more are deemed “risks requiring further evaluation.” The screening score for lead was .96. With the Great Lakes at a tipping point of ecosystem meltdown, the score is more than high enough to warrant further evaluation of the potential cumulative impacts on our international treasure. At a time when thousands of leaders from around the region are coming together around a multi-billion dollar plan to restore the Great Lakes the Coast Guard – the Guardians of our Great Lakes -- must show leadership to ensure their actions will not further degrade the Great Lakes. The Alliance for the Great Lakes does not believe impacts from live firing have been adequately examined, and we ask that the Coast Guard prepare an environmental impact statement to ensure that live fire exercises do not result in additional cumulative damage to the Great Lakes. Thank you for your time.