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September 20, 2006 - Dr. Jack Manno, Great Lakes Research Consortium, New York

Dear IJC Commissioners,

Thank you for considering public comments on the Lake Ontario/St. Lawrence Study and the decision you now face to choose a regulation plan. Please note that I make my comments as an individual and a scholar, not on behalf of the Great Lakes Research Consortium that I serve as Executive Director, nor the SUNY College of Environmental Science and Forestry, where I teach, nor as a member of the Environmental Technical Working Group (ETWG) of the LOSL study, which I was. While serving as on the ETWG, I was also carrying out a participant observation research project in the sociological tradition of symbolic interactionism, a qualitative research approach that analyzes how through formal and informal interactions such as occur in an IJC study people endow things like rivers, ecosystems, dams, decision-processes, control boards, wetlands, and models with meaning, turning them into symbols. Communicating through language involves continuous exchange of symbols that often mean different things to the different people involved in the exchange. In this way, the communication between the Study Board and the ETWG regularly bogged down as the Study Board regularly interpreted the meaning of environmental facts and figures in the context of its decision process as technically structured by the Shared Vision Model, largely an engineering and economics framework and the ETWG understood those same facts and figures in a conceptual framework of biology and ecology. I am not going to go into the details of my research. I have waited to publish my results until you have finished making your decision. I give you this background so you can understand on what basis I make my suggestions to you.

My major suggestions are:

1) Even though the Study Board has given you three alternative plans to select from I urge you not to limit your deliberations to that choice. The Plan you choose is a major component of the control strategy but not the only component. Your decision should include, as the Study should have included, all aspects of binational water levels and flow management.
2) The Control Board should include a broader range of professionals, including an environmental advocate, a Mohawk representative to bring traditional environmental knowledge of the river, an ecologist and coastal processes specialist.
3) The Board of Advisors who provide expert information to the Control Board should not just include representatives of the shipping and hydropower interests but include at least one professional ecologist
4) The IJC should recommend that structural measures be considered to protect and restore wetlands damaged by long-term dampening of water level extremes.
5) The IJC should recommend the ecologically sound coastal zoning and management practices so that in the future occasional water level extremes may be easily tolerated.
6) The IJC should examine the Boundary Waters Treaty in light of the latest scientific information about the ecosystem services historically provided by the river in its "natural flow" state in order to recognize ecosystem services as prior and protected water uses, thereby on an equal footing to the economic services protected by the Treaty.
7) The IJC should prepare and the governments should fund an adaptive management strategy to monitor the effects of changes in regulation especially in light of climate change and a flexible adaptive management infrastructure that can and will change course on the basis of environmental protection as well as on the basis of erosion and flood management and protecting economic investments.
8) The IJC should adopt regulation plan option B+ with direction allowing the new control Board to deviate from the plan when conditions warrant, Rules for deviation should be clearly developed by the IJC with input from environmental professionals and informed by Mohawk traditional environmental knowledge as well as coastal, shipping and hydropower expertise.

Thank you for your consideration of these suggestions.

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