Saturday, August 24, 2019


Basically Dr. Jackson, Chair of TAG at the time, told them that it might very well be necessary. He knew and said that the problems in Elmira were not technical problems they were public policy issues. In other words our politicians, local, regional and provincial were hopeless. They lacked the will for the fight necessary to get the Elmira cleanup on track. It was obvious to Dr. Jackson that the Ontario MOE were part of the problem versus part of the solution. The real solution was to go over the politicians heads and go directly to the public.

I did not blame the new TAG members for their reluctance. With the exception of two veterans on TAG with a history of making private deals and concessions to Uniroyal/Chemtura, the rest, even those with technical backgrounds, were totally new to the dynamics, the politics, the issues and the inherent dishonesty of the whole process. They were honest people still new to what they had gotten themselves into. They were not the least comfortable with news conferences and or speaking publicly about issues with which they had just barely gotten their feet wet. Dr. Jackson asked them to essentially jump off a cliff and to trust him. They respected him but they did not know him well. They hoped that there was a less dramatic method to achieve their goals. They were wrong and Dr. Jackson was correct.

I posted yesterday about the August 20/19 TAG Review Comments sent to Lanxess and to be presented to RAC (Remediation Advisory Committee) presumably on September 5/19 in Woolwich Council Chambers. I view those comments very, very positively. Lanxess and GHD will not. This is where the rubber meets the road. Lanxess will push back. They will respond just like Chemtura, Crompton and Uniroyal Chemical before them in the time honoured way. That is they will bullshit and bafflegab. This is exactly what they did with TAG and Dr. Jackson from September 2015 until the end of December 2016 when he departed. That is exactly what they have done since the start of the Uniroyal Public Advisory Committee (UPAC) in January 1992 with able assistance from Woolwich Council and friends.

Pat McLean and Susan Bryant essentially "captured" UPAC in the very late 1990s by filling it with their appointees only to throw it away by making UPAC a committee of Woolwich Council in 2000. They lost sight of the public interest by trying to please everybody. They knew that to keep their status and positions of Chairwoman (Pat) and secret executive committee member (Susan & 1 more) they had to please council, UPAC members, Uniroyal and the MOE. The two of them were excellent politicians whose primary goal was their own self-importance and enhancement. They told both sides what they wanted to hear and they sold out the public interest in favour of their own for which they were rewarded and honoured by both Uniroyal and friends and as well by local authorities such as the GRCA and the Region of Waterloo.

Yet again our authorities determined that their best interests aligned with those of big money and power, not with the publics' interests. They were experts in saying one thing publicly while making deals privately with the powerful. Pat and Susan understood this long before I did and cut their own deals with our local authorities and Uniroyal and successors. It has served them well, not the public.

Friday, August 23, 2019


The Technical Advisory Group (TAG) have sent their review comments to Lanxess in a seven page document dated August 20, 2019. While smooth and professionally done they are forceful and blunt at the same time. TAG advise that they do not agree with the methods used to screen for Contaminants of Potential Concern (COPC). This includes 22 of 23 substances with soil exceedances that were not retained as COPCs (pg.2). On page three TAG point out that high Method Detection Limits (MDL) greater than the Table 8 criteria and/or the ISQG guidelines may have affected the final list of COPC.

Also on page three TAG point out that Lanxess's consultants GHD made an inaccurate statement in regards to a number of former waste pits being remediated and/or contained by the Upper Aquifer Containment System. Finally on this page (3) TAG remind Lanxess that the Upper aquifer is not consistently contained (Cynthia Doughty-MOE) and that toluene on site can mobilize "hydrophobic" dioxins/furans and DDT. Further north on the west side as well as the east side groundwater is totally uncontained.

Page four is excellent as well with the following: "...TAG wants to ensure that the potential pathway for impacted soil and sediment to reach the Stroh Drain and be transported via the drain to the Canagagigue Creek be exhaustively examined including confirmatory soil and sediment sampling in the Stroh Drain...".

Page five references tissue sampling done in cattle and sheep in 1999. "The tissue analysis indicated that dioxins in lamb and beef were not detected or detected at the detection limits." Well this statement begs the question as to what the criteria/guidelines are and were the detection limits above or below these criteria? That information will tell the tale!

TAG also would like to know if the indicated sediment and soil depositional areas in the downstream Canagagigue Creek will be tested for the contaminants of potential concern to ensure that they are not also hot spots (pg. 6). On the same page TAG ask whether there is a more precise method to sample sediments than using a shovel. Yes proper core samplers were used 24 times while less precise and likely to miss sediments via the shovel method was used 338 times. To me this is similar gamesmanship to sampling three quarters of the sediments with detection limits higher than all the criteria and guidelines. It is effectively useless.

The last page (pg. 7) debunks GHD's claim that "...there are currently no additional ongoing contaminant sources and impacts from the Facility to the Creek." This claim was based upon a lack of currently active seeps into the creek. TAG also ties greater concentrations at depth for DDT, DDE, and DDD to their concerns with the Stroh Drain on page seven.

I have long praised Dr. Richard Jackson's blunt and forceful criticisms if not outright contempt for the longterm gamesmanship that has gone on here in Elmira, Ontario regarding attempts at remediation and cleanup. I am growing nonetheless to appreciate Tiffany Svensson's different style and reports like this can only magnify my admiration.

Thursday, August 22, 2019


The short answer is horribly. Thirty years after the south wellfield was shut down after NDMA was found there our drinking water aquifers are still way above the Ontario Drinking Water Standards (ODWS). The good news I suppose is that every year chlorobenzene and NDMA and a host of other contaminants are being pumped slowly out of the ground. By the way by "aquifers" I mean the municipal upper aquifer (MU), the municipal lower aquifer (ML), and the Bedrock aquifer (BR). Each of these are very deep from perhaps sixty feet below the surface (MU) to well over one hundred and twenty feet deep(BR). Keep in mind there are areas where the MU is much closer to the surface and unfortunately that is below the former Uniroyal Chemical site among others.

Today I will focus on NDMA with a drinking water standard of 9 parts per trillion (ppt) and chlorobenzene with a drinking water standard of 80 parts per billion (ppb). Parts per billion are one thousand times larger than parts per trillion. There are many more contaminants such as ammonia, benzene, toluene, aniline, MBT, chlorophenols although we are advised that they too are being reduced along with NDMA and chlorobenzene by the pump and treat systems.

Large parts of Elmira in the MU still have NDMA at 100 ppt namely from First St. south to Southfield Dr. Other smaller areas of Elmira have NDMA at 1,000 ppt such as on the east side of town between Howard Avenue and Oriole Parkway as well as a small area at the south end of Industrial Dr. There is also a very high but localized area near Park and Queen St. with concentrations of 10,000 ppt.

NDMA in the ML, the next deeper aquifer is actually worse. Oriole Parkway at Arthur St. spreads south and west in a plume which is at 1000 ppt. It goes all the way south to South Parkwood Blvd. The area at Union St. and Erb south to First St. and west halfway to Duke St. has a plume at 10,000 ppt.

NDMA in the deepest aquifer (BR) has a plume centred around Arthur St. and going south to Oriole Parkway at 1,000 ppt. Again at the south end of Industrial Dr. as well as part of Arthur St. there is a plume at 1,000 ppt.

Chlorobenzene in the MU is above drinking water standards from and including the Lanxess (Uniroyal) site south-west to First St., west along First St. more than halfway to Duke St. then south to Howard Avenue, back east to Union St. and then heading north-west back to the Lanxess property. Concentrations within this large loop 100 ppb up to 637 ppb all well above the 80 ppb ODWS.

Chlorobenzene in the ML has a very similar large loop to the south-west although it is not connected to the Lanxess site as it is in the MU. Concentrations are between 135 ppb and 372 ppb. There are also very high concentrations between 100 ppb and 2,900 ppb on the former Nutrite (Yara) property near Union St. and Bauman St. if Bauman extended all the way to Union St.

We have a very long way to go to restore our drinking water aquifers. My and others predictions are 2050 at the earliest. Even then without sub-surface source removal mainly at Lanxess and possibly elsewhere in Elmira would you be confident to drink that groundwater?

Wednesday, August 21, 2019


First point. Looking at Figures 4.6 and 4.7 (plume maps for NDMA) and Figures 4.8 and 4.9 (plume maps for chlorobenzene) in the 2018 Lanxess Annual Monitoring Report, things are not so good. Sure there have been large reductions in the concentrations of both chemicals in the upper and lower municipal aquifers, but oh my God, there is so much more left to do just to achieve drinking water standards for both. Keep in mind drinking water standards are not zero. Even after they've lowered the concentrations to 9 parts per trillion for NDMA and 80 parts per billion for chlorobenzene, the groundwater is far from clean much less pristine.

Second point. Uniroyal and corporate successors are not going to make their 2028 deadline for achieving drinking water standards.

Third point. That deadline is damn near FOURTY YEARS after discovering toxic levels of NDMA in our drinking water.

Fourth point these Figures are plume maps showing us the concentrations in 1998 prior to off-site pumping and then in 2018 after twenty years of pumping and treating the off-site groundwater under the town of Elmira. Both the 1998 and the 2018 plume maps have something in common. Careful examination leads to the obvious conclusion that there are multiple sources of contamination to the Elmira aquifers. This likely goes for chlorobenzene as well as NDMA. Ammonia we'll leave for the moment because all the guilty parties have admitted that there were at least two sources namely Uniroyal Chemical and Nutrite Fertilizers. I also suspect a third source further south.

Possible additional NDMA sources would be either Sanyo Canada or a very nearby industry with a small chance that it could be the former McKee Harvestors. In addition there is an unexplained high concentration area very close to the former south wellfields namely E7 and E9. Lastly there are additional sources of NDMA both near Park St. and Queen St. as well as apparent sources in and around the former Varnicolor chemical site on Union St.

Possible additional chlorobenzene sources would be sub-surface DNAPL near the water tower and fire station on Howard Avenue. That free phase DNAPL possibly comes all the way from Uniroyal Chemical but more likely comes from the much closer Borg Textiles or Varnicolor Chemical. Issues complicating reading these plume maps are a lack of monitoring wells between Howard Avenue and Oriole Parkway. Also the Conceptual Site Model produced by Dr. Neil Thompson suggests that there is an additional 1900 kg. of chlorobenzene in the Elmira aquifers than what solely came from Uniroyal Chemical. Very strange without a second source and certainly both Borg and Varnicolor should not have been strangers to chlorobenzene despite MOE shallow sampling on the Varnicolor site.

Lastly all these likely additional sources could easily have been determined between 1990 and 1992. They were not intentionally for political reasons. They likely still could be determined with honest, unbiased, shallow soil and groundwater sampling. Honest and unbiased sampling means out of the control of Lanxess, GHD, MOE (MECP) and Woolwich Township at the very least.

Tuesday, August 20, 2019


Actually I have two predictions for the 3 pm. September 5/19 Remediation Advisory Committee (RAC) meeting to be held in Woolwich Council Chambers. I sincerely hope that I am wrong with both of them. They are that there will be no questions whatsoever from RAC members after my Delegation to them and secondly that there will be no mention of Cynthia Doughty's (MOE) letter of June 20/19 to Jason Rice (MOE) indicating the failure of the Upper Aquifer Containment System (UACS), essentially since its inception.

I posted here on July 31/19, the day before the last TAG meeting, about Ms. Doughty's very interesting letter. She has flat out stated what I have long suspected and in years past have raised at CPAC meetings. Unfortunately as always in subjective matters, the polluter's well paid consultants have interpreted the data favourably at all times to their client, whether Uniroyal Chemical, Crompton Co., Chemtura or Lanxess as they will always do.

Regarding my prediction that there will be no questions from RAC members, that is almost a given. I believe that the parameters and results for the upcoming threatened Risk Assessment for the Canagagigue Creek have long been settled privately among all the parties. This would include Lanxess, the Ontario Ministry of Environment (MOE), GHD, Grand River Conservation Authority (GRCA), Woolwich Township, Region of Waterloo etc. The Risk Assessment and lead up work to it are merely window dressing, or as Dr. Henry Regier said about the last one on the Chemtura site years ago... "green washing". Hence the window dressing is for the media, local citizens and the general public. Therefore my Delegation is unlikely to be well received or appreciated as I discuss the Stroh property contribution to the dioxins/furans and DDT in the creek.

If there were any well informed members on the RAC committee, they might decide to ask me difficult questions in an attempt to lessen my impact or credibility. Perhaps the MOE or even Lanxess reps might do so but likely they too are scared of opening a can of worms that they can't close.

Monday, August 19, 2019


Gail Martin wrote an article in the Elmira Independent on May 9, 2013 titled "Creek sample shows increased DDT levels". The sampling in various locations in Canagagigue Creek took place last November 2012. There were some surprises to say the least. Neither the MOE nor CPAC members were expecting any results in the 12,000 to 13,000 ppb. concentrations. This is all rather ironic as George Karlos of the MOE had suggested a year ago or so that this sampling would put the community's fears and concerns to rest. Hardly as both soil and sediment criteria are thousands of times lower than these numbers.

Also of concern was the MOE neatly sidestepping sampling within the Martin man-made in-ground swimming pool that has been used for generations of children. The MOE claimed that there was a geotextile membrane inside the pond that sealed it. In this case I can advise from first hand observation that indeed there is some sort of geotextile membrane on the inside of the pool. The problem is this. While the membrane may reduce sediments and soils from the interior of the pond from entering it, the membrane does absolutely nothing for suspended sediments entering the pond directly from the pipe which runs via gravity flow between the Stroh Drain, Ditch & Berm and the interior of the pond. Dr. Sebastian Seibel-Achenbach and myself saw this pipe and saw it running when we had permission from the Martin family to sample the Stroh Drain etc. on their property along with MBN Engineering & Consulting, who were working with CPAC. Hence it is more than likely that both dioxins and DDT would or could be found in this swimming pond despite the MOE's refusal to test it. Also of interest is the fact that now in August 2019 more than six years later, while there has been more biased and unscientific testing, to date not a shovel full of contaminated sediments or creek or floodplain soils have been removed. Par for the course in Elmira, Woolwich Township, Ontario.

Saturday, August 17, 2019


TAG, RAC, and the public have been told that off-site pumping well W9 was shut down because Lanxess and GHD couldn't effectively treat toluene and benzothizole exceedances in the groundwater pumped from the well. O.K. so what's the next obvious question? How about WHY NOT? Uniroyal/Lanxess on-site groundwater is filled with toluene and benzothiazole (plus a hundred other chemicals) and that groundwater is pumped, treated and discharged back into the Canagagigue Creek. Why is the groundwater a few hundred metres due west of Uniroyal/Lanxess, near the corner of Park St. and Union St. such a problem that well W9 is two years late or more coming on-line?

One fairly obvious answer is that Lanxess just like every corporate body before them are constantly cheaping out every possible aspect of the remediation of both the Canagagigue Creek and of the Elmira Aquifers. Therefore just take a look at the different treatment systems in use for different wells both on and off their property. There is activated carbon treatment, ultraviolet treatment, LNAPL separation and removal, ammonia treatment etc. Ahh but here's the rub. Not for every well, all of which are pumping contaminated groundwater. So which wells get the Cadillac treatment and which wells get the Volkswagon beetle treatment? The general answer is that as few as possible for the former and as many as possible for the latter.

W9 gets ultraviolet treatment only. That's it folks, nothing more. By delaying implementing this well from 1989 until 2019, the company had the benefit of an additional thirty years of groundwater flow and dilution. Or in the alternative since off-site pumping didn't start until 1998, they had the benefit of an additional twenty-one years of groundwater flow and dilution. Maybe they expected lower concentrations of contaminants in behind the large building where W9 is located alongside Shirt Factory Creek.

Hmm. And exactly what is or was that building? Let's see now. At one time it was Park Avenue Textiles and before that it was the Elmira Shirt and Coverall Company. Also of interest is that Elmira's first municipal landfill was located on this property as well. Now this landfill was before Uniroyal Chemical's time but was it before say Roxton Furniture (across the road) or a number of other local polluting industries? Highly unlikely. As is common historical revisionism, Woolwich Township and the MOE would have us believe that nothing but wood ashes and a little municipal garbage went into this landfill. Horsefeathers!

Of course as is the usual answer to these allegations, industrial and political admirers of relatively inexpensive waste disposal will claim that no evidence exists to corroborate that likelihood. Well actually there are two responses to that. If any soil testing both shallow and deep has already been done in and around this property, building, and landfill, rest assured the results are a carefully guarded secret. Secondly if no testing has ever been done then shame on Woolwich Township, the Ontario Ministry of Environment (MOE), Uniroyal Chemical, CRA etc. The Elmira Aquifers are grossly contaminated and ALL sources of contamination should have been looked for and investigated thirty years ago.


Friday, August 16, 2019


Pumping well W9 was supposed to be a significant addition to the off-site pumping (i.e. off the Uniroyal/Lanxess site) in the Elmira Aquifers. First of all it was a couple of years late in coming on line allegedly due to benzothiazole (BT)and toluene concentrations not being adequately reduced by the treatment methods being used. We then waited and waited for new equipment which we were told would take care of things. Well it did at least for a very short while. Three whole months of improved pumping and treating at W9 namely April, May, and June 2019. Now pumping and treating for July 2019 are back in the crapper. The Target Average pumping rate is supposed to be 13.6 litres per second. April was 12.6, May was 13.1 and June actually met and surpassed the Target Average with 15.2 l/sec. Last month, July 2019 has plummeted back to 4.3 l/sec.

We are advised in the July "Progress Report" that the failure of W9 yet again is due to the effluent after treatment being acutely toxic to the insect test subjects. 50% of them died in the first test and a followup killed 100% of them. Realizing that all the treated groundwater from both Uniroyal/Lanxess and the rest of Elmira is discharged into the Canagagigue Creek and you can see the problem. Cleaning Elmira's groundwater at the expense of the Canagagigue Creek is not supposed to happen although citizens certainly advised our authorities back in the early 1990s that that sure looked to be what the plan was. Well here we are three decades since the 1989 Elmira Water Crisis and it appears to me that the Canagagigue Creek continues to be the waste disposal sewer for mankind's "progress". This is more than the ongoing pumping and treating and includes the pretend creek investigation by GHD, the pretend conceptual site model for the creek and soon to be pretend Risk Assessment.

Thursday, August 15, 2019


After my Delegation to Woolwich Council Tuesday night regarding the contaminated east side Stroh property, there was perhaps at best a half-hearted attempt by the mayor to soften or minimize my concerns. She advised Council that the Technical Advisory Group (TAG) has been discussing soil samples in the "Gap" area. While this is true it only barely touches upon the issues of Persistent Organic Pollutants (POPs) deposited on the Stroh property to the east. The "Gap" area is part of the likely flow path of contaminated waste waters from Uniroyal Chemicals east side pits southwards into the former wetlands area.

Perhaps the mayor was simply buttressing her position that everything is under control and up front in regards to the cleanup of either the Elmira Aquifers or the Canagagigue Creek. Unfortunately that would be incorrect unless under the control of the polluter and corrupt regulator is OK with you. Mayor Shantz is the chair of RAC and has been recently sitting in on TAG meetings. She is a believer in the status quo and in supporting all our local authorities and agencies. I am not so inclined based upon their history right up until the present.

Overall councillors did not seem overly impressed with the mayor's comments. After all my Delegation was calm, cool, and backed with facts and maps. While in principle I don't appreciate revisionism being practiced upon a citizen's Delegation, this was not a big deal in the scheme of things.

Wednesday, August 14, 2019


Well first off I received a cordial welcome from Council and did not have any interruptions during the course of my Delegation. I believe that I may actually have run over the ten minute time limit by a minute or so but again was allowed to finish without interruption for which I thanked the Chair when I was done. I also believe that council members (less Fred Redekop who was unfortunately absent) were receptive and listening carefully. Indeed Councillor Larry Shantz had a very good question at the end of my presentation in regards to the depth and the reason for the shallow depth of the superficial excavations along the Lanxess/Stroh property line.

One piece of advice that I received later from the gallery was that councillors have a multitude of issues constantly running simultaneously and hence it is best to realize that they out of necessity are generalists not specialists who are extremely well versed in all issues. Therefore especially when dealing with Uniroyal/Lanxess and technical contamination issues it is best to keep things simple and straightforward.

I spoke about the ground surface contour lines on the east side of the Uniroyal/Lanxess property and how a number of government agencies over the years have produced these elevation (i.e. ground surface) contours and how consistent they are with each other. These agencies include MOE/MECP, GRCA, Conestoga Rovers etc. The orange arrows on my large map show the flow direction of overflowing waste waters leaving the east side pits in the late 1940s, and throughout the 1950s and 1960s. Simply following the contour lines it is clear that the massive quantities of waste waters ended up settling out in the large depression on the Stroh property to the immediate east of the Stroh Drain, Ditch, and Berm (SDDB). The failure of Lanxess to sample the soils in and around the Stroh Drain (SDDB) and of the MOE to not insist upon it is reprehensible and entirely self-serving for both groups.

Tuesday, August 13, 2019


The last couple of days we've seen three different articles in the Waterloo Region Record regarding either direct or indirect environmental problems. They have been the one about algal blooms on Lake Erie that I posted about yesterday as well as lead in the drinking water of residents of Newark, New Jersey. Finally yesterday's paper advised readers about concerns for a new gravel pit proposed along Witmer Road,south of Petersburg in Wilmot Township.

Our media understand the life and death consequences both to individuals and to humanity as a whole. Overall the media have been bringing the life altering, or worse, issue of climate change to the public regularly. And that pretty much is where it ends. Air travel expands, pipelines continue to be built and money is being made in the oilsands and will continue to do so for a long time.

Closer to home the article about the proposed gravel pit has all the local players telling us supposedly stupid citizens that gravel pits that follow the rules are not harmful. Two points to that. The first point is bull manure. The rules do not protect the public or the environment. They are far too lax. The second point is that what rules there are, simply are not enforced. Like the Ministry of Environment (MOE/MECP), the Ministry of Natural Resources (MNR) hasn't enough manpower to regularly and comprehensively monitor and supervise the plethora of gravel pits just in Waterloo Region much less throughout the province. Even if they do stumble across violations, just like the MOE they write up a ticket and personnel higher up in the MNR decide that it's not in the public interest to pursue either fines or charges.

There is a third point. The article about the Wilmot Township gravel pit near Petersburg suggests that the gravel pit will be restored to agricultural lands. More extreme bull manure. First of all the drainage beneath it has been drastically altered as the sand and gravel have been removed from beneath the soils. Secondly the fertile topsoil has been scraped away and piled up to be eventually (years or more likely decades later) spread back over the surface of the ground. Experts at the Hunder Pit Ontario Municipal Board hearing a few years back held in Woolwich Council Chambers put the lie to that scenario. Agricultural soils are filled with bacteriological and other life. Both bacteria and fungi in the soil actually assist the roots of crops in taking nutrients from the soil and making them available for crop growth and health. Disturbing this topsoil via scraping and piling drastically reduces the productivity of the soil and it can take decades for it to be restored AFTER it's been spread back out onto the ground surface.

As I said, here in Ontario and Canada it's all about lip service. Tell the people what they want to hear but do not ever even slightly impair the ability of the wealthy and powerful from exploiting our natural resources for their benefit to the detriment of the environment and the rest of our citizens.

Monday, August 12, 2019


Today's K-W Record carries the following story titled "Scientists on high alert as massive algal bloom threatens Lake Erie". The bad news is that this is nothing new. Similarly the cause is very well known yet conveniently ignored. Agriculture is a large and strong target to go after. The simple cause is too much phosphorus running off our farm fields and getting into Lake Erie where it promotes the rampant growth of algae. Sure we can blame climate change as well. Warmer temperatures in the lake increase algal growth combined with heavier rainstorms sends more phosphorus laden soils via creeks and rivers into Lake Erie.

These algal blooms can be toxic . The blue-green algae is known as cyanobacteria which produces a toxin called microcystin. Microcystin can be both harmful to humans, pets and livestock or even fatal. It has been found in various municipal water systems including Toledo in 2014. Although this story doesn't say it, I am. Gutless politicians don't want to pass laws that the agriculture industry will claim discriminate against them. Tough. Besides corn, soybean and other crops being over fertilized or fertilized too soon before heavy rains there are also problems with livestock grazing either in floodplains or walking into rivers and creeks directly. Their manure only exacerbates the problems of nutrient loading to our Great Lakes although Lake Erie is most vulnerable. Voluntary measures by farmers to date have not been adequate. Much more is needed.

Saturday, August 10, 2019


Most of us everyday citizens, that is non-politicians or government bureaucrats, figure that once the cat is out of the bag, then forget lying and covering up. Not politicians and their ilk. They are hard wired to always gild the lily or put the best face on unfortunate or negative events that reflect badly on them. One obvious example is Uniroyal Chemical and the 1989 Elmira Water Crisis. Uniroyal's waste disposal methods were beyond primitive and third world like until around 1968-1970. They destroyed the local creek, polluted the Grand River, and destroyed the Elmira drinking water aquifers. I say destroyed because thirty years later we are still waiting for their "restoration" with the latest estimates being another thirty years. I'll believe that "restoration" when I see it and I'm within a whisker of being seventy years old.

Part of the public exposure through the 1990s of the self-serving and dishonest behaviour of Uniroyal Chemical also reflects upon our Ministry of Errors and Excuses when it was known as the MOEE. The behaviour that I am referring to is ongoing public statements (i.e. lies) by the Ministry of Environment (currently known as MECP) in the 1970s and 80s that everything was fine, under control, and that the Elmira drinking wells were protected. Uniroyal when asked then and now like to use the MOE/MECP as a shield. Oh they say we do as we are told by the MOE. They are fair but firm. Uniroyal and successors have always known that this crap they have been espousing is exactly that, namely crap. They have consistently pressured, threatened, and intimidated the Ontario MOE constantly looking for concessions, exceptions, and relief from onerous environmental interpretations of the law.

Then we have the Walkerton crisis in 2000. Same thing all over again except this time it was Walkerton's council and staff who messed up along with the typical incompetence demonstrated by the Ontario Ministry of Environment. They couldn't find their own butts in a snowstorm much less find serious environmental infractions and if they do find them rest assured they will go nowhere until there is a crisis. This folks is what happens when the politicians at the top (provincial and municipal) are always in coverup mode and their attitude of ignoring and covering up serious problems permeates downwards through the ranks. I sometimes wonder if those that get promoted in the MOE are essentially yes men and women and those who are forthright and honest get career sidetracked into positions where their honesty cannot harm those in charge.

Again the Varnicolor Chemical scandal which is ongoing to this day. Full coverup mode even thirty years later and after the owner actually got sent to jail with an eight month sentence. The company were an illegal toxic liquid dumping organization who were protected by the MOE both before and after I and others publicly exposed the company. Even today the MOE will not release to the public documents pertaining to this site and its ongoing remediation over the last twenty-five years. Why would they when both they and provincial politicians would rather this embarrassment go the route of all the others.

In Cambridge we had the Northstar Aerospace disaster. Hundreds of homes and occupants in the Bishop St. community inhaled trichloroethylene (TCE) and Trichloroethane (TCA) fumes for decades due to vapour intrusion courtesy of Northstar and another commercial neighbour. Allegedly the MOE inspected this site and missed everything going on throughout this period. Or the inspectors simply didn't want to rock the boat. Were their job reviews based upon finding environmental infractions or perhaps just the opposite? Clearly the system is rotten.

Politicians, government ministries, and accompanying bureaucrats rely on the short attention span of citizens. Most of us are focusing on our every day lives including jobs and families and health. We pay through the nose for government services and far too often get poorly served by them. These politicians and governments have our money and busy lives to hide behind. They become experts at puffery and bull.... . Each and every failure is chalked up to a one time exception or "slipping through the cracks". They will claim that their agencies are "world class". That is their puffery and bull.... in action. Systemic failures will not be admitted to. When pressed they use their financial might (paid for by you) to use the courts to support them and harass citizens. That is the unfortunate behaviour of some school boards among other agencies.

The last brief coverup of past failures I will mention is the last Woolwich Council's behaviour to hide their failure to properly oversee and supervise the potentially explosive methane issues in and around Bolender Park in Elmira, Ontario. The methane originates from the Bolender Landfill, possibly due north of the Park although far from proven not to include parts of the park itself. The last council continue to hide behind their consultants Conestoga Rovers and their successors GHD. This includes denying everything while actually beginning to take some appropriate steps to make up for their benign neglect for decades. Council either denied the lack of regular and ongoing monitoring as well as denying the failure to monitor the entire perimeter of the former landfill. Even their failure to determine the exact location of the entire landfill is mind boggling. They appear to prefer to be ignorant in order to maintain their plausible deniability if it turns out that citizens and children are playing above methane infused garbage. It is also their refusal to provide honest communications with citizens asking hard questions that is so disgraceful. Rest assured if the worse happens that they will suddenly discover the hard way that coverups are not in the public interest.

All in all the behaviour of unaccountable and morally suspect politicians.

Friday, August 9, 2019


The March 7, 2013 edition of the Elmira Independent carries the following story titled "Committee opposes partial excavation of waste pits." CPAC (Chemtura Public Advisory Committee) wanted both gravel pits, GP-1 and GP-2 excavated and contaminated soils (dioxin/furans, DDT, & more) removed. In order to save a buck, Chemtura only wanted to excavate parts of GP-1 and cap then GP-2 in order to reduce water infiltration into the pit. All in all it was an excellent scam by both the company and the Ontario Ministry of Environment.

To date Chemtura or their successor Lanxess have not so much as acknowledged or commented on the probable relocation of GP-1 despite as always the evidence is from sources intimately associated with the company and its site in Elmira, Ontario. Both text from reports in the 1980s and early 90s as well as a 1983 and 1992 maps indicate the earlier accepted location of GP-1. Conestoga Rovers has even admitted that they have over time made adjustments to the size and shape of Gp-1 in particular. They have not admitted to outright relocation however.

If as I believe that GP-1 was arbitrarily and bilaterally moved by Uniroyal Chemical and CRA then indeed the cleanup of the likely much less contaminated pretend GP-1 should have been voluntary. What is indescribable and heinous however is the potential Ontario Ministry of Environment's (MOE/MECP) collusion with Uniroyal on the matter. I'm sure that they would prefer the word "negotiated" but that would be a misnomer. I very much doubt that they have the right to "negotiate" away the legal responsibilities of a coporate polluter who has contaminated their neighbour's property. If the MOE did collude with Uniroyal and CRA on this matter, then it is trilateral not bilateral relocation of a contaminated area. The original (via the 1983 map) GP-1 was on Uniroyal's property but was located in the lower lying area on the north-east side of the diagonal ridge of high ground in their south-east corner. This diagonal ridge (north-west to south-east orientation) of higher ground is what deflected the overland flow of waste waters from the east side pits south-east onto the neighbouring Stroh property. Therefore overland flow into the real GP-1 would have more obviously continued south-eastwards through the "Gap" area and onto the Stroh property and farm.

Thursday, August 8, 2019


Sometimes I wonder why I have such disrespect for various alleged professional consultants, spokespersons, and experts who all amazingly to me, not so much to others, find ways to interpret facts favourably to their clients or even misstate facts also favourably to their clients. There is an immense advantage to being the proponent for either development proposals or remediation proposals for your own property. Firstly, generally speaking, you control the facts and hence the narrative. Also, generally speaking, there is no real government regulator in serious, open confrontation with you, unless of course you are a small fry and then things can change in a hurry. Just ask Varnicolor Chemical owner Severin Argenton about that. Some former government employed drinking buddies quickly jumped ship when the tide turned against Severin and the MOE back in the early 1990s.

Over the last two days I have posted here about the pumping of waste waters from the west side of the creek (Canagagigue) over to the east side pits on the top of the hill. I also posted here about synonyms, typos, and other misstatements and errors amazingly all being helpful to the narrative that the polluter and sometimes their guilty regulator preferred.

There are a few but very significant errors in Table 3.1 in the August 1991 Environmental Audit written by Conestoga Rovers (CRA) on behalf of Uniroyal Chemical. These include inaccurate dates of disposal as well as not clearly indicating the exact dates that various west side ponds were constructed which would then give a clearer indication of how many years they were actually in operation say compared to the east side pits. Similarly it would help if this "Waste Disposal Summary Table" more clearly indicated which pits and ponds were primarily for liquids versus solids or sludges. Also DDT is mentioned as being in the Building 8 sump but there is no indication in this Table as to the final destination for this product (it was into RPE-4).

Even the nomenclature for RPE and RPW is deceptive. RPW refers to the west side "ponds" as in Retention Pond West and RPE refers to the east side "pits" as in Retention Pit East. This certainly gave me for a very long time the false belief that the process liquids primarily were disposed into the west side "ponds" versus into the east side "pits". Uniroyal and successors had a multitude of opportunities to correct those misunderstandings at public UPAC and CPAC meetings for decades but did not.

Both the August 1991 and the January 1992 Environmental Audits are seriously convoluted and complicated in regards to explaining to citizens and lay persons exactly where solid and liquid wastes ended up. Yes they are clear that in the first few years just about everything liquid went directly or indirectly into the Canagagigue Creek. After that the company used more convoluted routes to essentially get the same result. After 1946 the Uniroyal Chemical sewer and sump systems sent the vast majority of waste waters to the east side pits which already by 1948 were causing vegetative distress to further east crops (Stroh property) as well as along the creek on the Uniroyal property. Clearly the information we received in the early 90s about Mr. Stroh senior having received compensation for crop damage makes sense.

If the guilty parties had been up front at the start of public consultation (i.e. UPAC) then citizens would have focused much more on the east side long before the discovery of the Stroh Drain, Ditch & Berm in May 2014.

Wednesday, August 7, 2019


Following is copy of an e-mail sent earlier this morning to Tiffany Svensson, (TAG Chair), Joe Kelly (member), Sebastian Seibel-Achenbach (CPAC & TAG member) and Lisa Schaefer (Support Co-ordinator for RAC/TAG - Woolwich Township employee)

Tiffany & Joe: I have been rereading old but very relevant reports describing the overland flow of liquid wastes from the east side pits. Two of the sources are the 1985 "A History of Uniroyal Waste Management at Elmira" by W. Jackman, J. Ralston,and A. Smith. The first two gentlemen are from the Ontario MOE and the last is from the GRCA. The second report is the August 1991 "Environmental Audit" produced by Conestoga Rovers (CRA) under order from the MOE and on behalf of Uniroyal Chemical.

The 1985 report states on page 4 : "By 1948, seepage from the ponds was being collected in open ditches and drained to a gravel pit (GP on Fig. 1)."
"The 2,4-D wastewater continued to be pumped to the ponds until 1965 when the municipal waste treatment plant..."

And on page 6 : "Any wash water from the 2,4,5-T process entered the same waste streams as the 2,45-D process."

The August 1991 Environmental Audit on Page 37 states that liquid wastes leaked out the bottom of RPE-1 because it was built on a sand lens and caused "vegetative stress" on both crops on the east side and vegetation on the west side. as far away as the Canagagigue Creek.

However as per page 38, pits RPE-2, 3.4 were built on top of clay and hence there was much less and much slower leakage through the bottom. The obvious fact was that ongoing and daily pumping of liquid wastes into these pits resulted in significant overflows of wastewater versus CRA's claim of "intermittent" flow.

Page 39 states: "Intermittent overflow from the pits was collected in open ditches and drained to a gravel pit on the south-east portion of the property." Furthermore "This seepage toward the gravel pit continued until approximately 1965, when the Elmira STP began to receive wastes from Uniroyal." And on the same page "...the east pits continued to be used to equalize the loadings to the Elmira STP."

Page 43 states: "Seepage and overflow from the pits RPE-1 to RPE-5 was directed by drainage ditches into gravel pits located in the south-east portion of the site. This practice began in the early 1940s until approximately 1970 when the east side ponds were closed and /or lined. Liquids would pond in the gravel pits and eventually seep down into the subsurface soils. Liquid waste water was continuously standing in the gravel pits until the east side pits were closed. When seepage from these pits subsided in the early 1970s, the gravel pits dried up."

Prior to my commenting/criticizing CRA's obvious conflict of interest (i.e. client driven and paid for reports) and choice of language (
"seepage", "intermittent") to minimize the extent of pollution and cost of cleanup to their client (Uniroyal Chemical) I wish to ask Lisa Schaefer to please send this e-mail report to all of TAG at a minimum. Thank you Lisa. Secondly I wish to advise that Woolwich Township should have both these reports, and much more, in their archives. If not then either the MOE/MECP or Lanxess should be able to provide them to Lisa, Tiffany and all TAG members. As a last resort I am the proud owner of a complete set of Uniroyal to Lanxess reports (approx. 1980 - 2019) and I would either e-mail you entire pages as Attachments or possibly bring in the reports for you to examine with myself present.

Point One: Note in the above quotes how many times seepage and overflows were directed into a gravel pit (SINGULAR!) versus gravel pits plural. That is because they were directed towards a gravel pit (GP-1) only, however GP-1 was not in the current location where CRA conveniently moved it to on their maps over the last three decades. I have the maps showing its relocation from its original location on the north-east side of the diagonal ridge of high ground that a number of us walked on top of on April 11, 2019 during our site tour.

Point Two: We are supposed to believe that "seepage" or "intermittent overflow" of the east side pits resulted in surface drainage in open ditches (versus say in an enclosed pipe) over a distance of 300 metres from RPE-5 and closer to 750 metres from RPE-2 which is much further north. That is ridiculous nonsense. Only very large volumes of liquids waste waters would flow that distance without being entirely absorbed into the soil along the way. Furthermore CRA have stated that these waste water flows resulted in "continuously standing" liquids in the gravel pits.

Point Three: From 1946 until very close to 1970, the east side pits were the recipients of the vast bulk of process waste waters and liquid wastes generated by Uniroyal and successors production processes on the west side of the creek. From 1942 until 1946 liquid wastes were simply put directly into Shirt Factory Creek (SFC) and from there the Canagagigue or directly allowed to run off the river flats into the Canagagigue Creek. From 1946 until 1970 they were pumped via two pipelines across the creek and over to the east side pits. The waste waters averaged around 165,000 Imperial Gallons Per Day (IGPD) with lows of 140,000 gallons and highs of 240,000 IGPD. These daily volumes could not possibly be absorbed by the soil and indeed they were not. They flowed southwards and eastwards following the ground surface elevation contours until they ended in a large depression on the Stroh property to the immediate east of the Stroh Drain, Ditch & Berm. Yes these liquid wastes were not in a pipe and certainly spread out with some going west towards the creek on Uniroyal's property and some going into the currently known GP-1 location. Most however went over to the Stroh property. Ground surface elevation contours do not lie. My large map has these contours now for the entire east side and these contours are sourced from the MOE/MECP, GRCA, CRA, MTE and others and are consistent with each other.

Joe, in regards to the small pond just south of RPE-5 your observation was worthy however that depression is the result of contaminated soil being excavated and put into RPE-5 in 1969 essentially after the east side pits were out of service. This information is also in the Environmental Audit.

Sincerely Alan Marshall CPAC & EH-Team member P.S. TAG & CPAC member Sebastian Seibel- Achenbach has more current and extensive knowledge of these matters than TAG hence his position being closer to mine than to some TAG members.

Tuesday, August 6, 2019


There are several reports from the 1980s and very early 1990s written by consultants for Uniroyal Chemical and the Ontario Ministry of Environment (MOE/MECP) that have become the "bibles" for environmental activists and citizens who have seriously pursued the truth for the last three decades regarding the 1989 Elmira Water Crisis. There were a couple of others from consultants hired by the Region of Waterloo namely CH2M HILL and one done by consulting firm Terraqua. These last two, especially the Terreaqua report (1986) I have very little difficulty with.

There are serious problems with the 1985 "History of Uniroyal Chemical Waste Management" produced by the MOE and GRCA as well as with the two Environmental Audits produced by Conestoga Rovers in August 1991 and January 1992. There are too many times that either products, building names, sumps, waste pits and ponds are referred to using synonyms without explanation or clarification. There are what look like typographical errors whereby a building number is one digit off what it was previously, again without explanation or clarification. As far as the wastewater distribution and disposal system there are a plethora of names and numbers for the very same sumps for example. Also there are incorrect dates and waste pit locations in the Environmental Audit.

All of this almost seems to be a bit of showing off. You know when you try to talk to a person about their work and they try to impress you with a ton of acronyms and or a ton of meaningless numbers thrown in to make their jobs and knowledge seem both greater than yours and vaster than it really is. Some consultants aren't happy unless they are basically speaking a different language than their audience which may also have the intent of discouraging questions if you have been totally lost during the presentation. Using synonyms to confuse your audience can be no more than trying to impress or it can be simple rudeness or finally it can be to intentionally confuse your audience.

Recently I've been rereading these reports, yet again. Keeping them all on the table at the same time and going back and forth between them is helpful. One can slowly pick out the confusing if not contradictory statements and see how it is done. The why is a little more subjective although from the experience and viewpoint of dealing with these two groups for three decades one can readily come to one's own conclusion. Sometimes there are blatant errors and other times it is careful word choice to make you think one thing until you reread it and compare to the other reports. Between multiple reports and authors one can slowly pick one's way through the smoke and haze. All of this further hinders true public consultation.

Saturday, August 3, 2019


Yesterday's post included comments from Jason Rice MOE/MECP) (in a letter to Tiffany Svensson) regarding why MDLs vary between ALS labs and the MECP labs. Various reasons include:

For dioxin/furan analysis ALS uses EPA Method 8290 instead of EPA Method 1613. The latter is the superior of the two and the one used by the MOE/MECP.

Regarding DDT analysis ALS labs uses Method E3487 versus ALS labs using Methods WT-TM 1102 and 1302. While those numbers are Greek to me apparently using the ALS Method results in higher Method Detection Limits (MDLs). Also the MECP use more sensitive instrument equipment than ALS which lowers MDLs. Finally The MECP lab method has a larger final volume of sample extract also lowering MDLs.

For both dioxin/furans and DDT there are also superior versus inferior clean-up steps involving the lab equipment used. Mr. Rice (MECP) believes that the ALS steps are inferior to the MOE's.

My take on all this is that you get what you pay for and hence Lanxess had no incentive to get the best lab work done as it would cost more money upfront to the lab and then later with the greater cleanup of the Creek occasioned by the greater number of criteria exceedances that the lab would find if they used the superior methods.

Friday, August 2, 2019


First off everybody behaved nicely including Sandy Shantz politely and respectfully giving me her condolences on the passing of my father-in-law, Aden Brubacher. A couple of others did as well. I thanked them sincerely including our pretend mayor, Sandy. No I did not call her that but treated her as respectfully and courteously as she treated me.

The meeting was odd for many reasons. First of all there were no MOE staff present. Neither was Ramin Ansari, Dwighte Este, Helder Botellho from Lanxess present. Therefore as usual exactly zero questions could be asked by either TAG members or the public of the MOE (MECP) or Lanxess which is exactly as those two bodies seem to prefer. As if the public could ask questions even if the MOE and Lanxess were present courtesy of the horse.... Terms of Reference for TAG and RAC. Also odd was Sandy Shantz (RAC co-chair) sitting at the front with TAG chair Tiffany Svensson. Sandy has spent the last two meetings in the gallery with the rest of us plebes and that's exactly where she should be sitting, not at the front. What the hell is she doing...supervising or micromanaging her own appointee as chair of TAG???

Two new TAG members were introduced last evening namely Katharina Richter and Dustin Martin. They both live in Elmira, Woolwich Township whereas another TAG member Susan Bryant lives in neither. Both new members certainly seem well qualified although I believe that both have zero experience regarding Uniroyal and Elmira issues. That they will eventually (years) get up to speed is likely if they become keen and continue on. It will take years partly due to the history and complexity of the issues and also due to the reduced number of meetings per year. Unfortunately last night's meeting was incredibly dull and somewhat technical with lots of acronyms being thrown around. The dullness is partly due to the lack of input from MOE and Lanxess. While UPAC and CPAC have suffered in the past from too much time taken up by Conestoga Rovers on behalf of Uniroyal/Crompton/Chemtura the opposite is currently happening.

Tiffany and TAG have messed up again. The earlier messup was accepting the 5.9 inch (15 cm.) only sampling and later excavations on the north-west side of the Stroh property. This one is accepting Lanxess's (Ramin's) self-serving refusal to do soil testing further south on the Stroh property in and around the Stroh Drain, Ditch and Berm (SDDB). This was done despite TAG member Sebastian Seibel-Achenbach's disagreement.

David Hofbauer advised that in his opinion the MOE in their comments to Lanxess were attempting to get more data into the Risk Assessment process unless Lanxess/GHD can better explain why it isn't needed.

Jason Rice replied to Tiffany Svensson's request for information regarding Method Detection Limits (MDL). Clearly ALS labs testing is inferior to both the MOE labs and probably Maxxam who have been used for years by Uni/Crompton/Chemtura. When I say inferior I strongly suspect intentionally inferior as they (ALS) were likely contracted to do the less expensive and less accurate testing and inherent higher MDLs by Lanxess all in the name of saving money AND in the name of generating many more NON-DETECTS (ND) in the soil and sediment samples in the downstream Canagagigue Creek. This is what occurs when the MDLs are higher than the criteria and health guidelines. Instead of more exceedances of criteria in the samples, simply more ND are generated. Talk about a win-win for Lanxess and a lose-lose for the public and the environment. The extent of gross and toxic contamination in the Canagagigue Creek is once again minimized thus lowering cleanup costs dramatically.The scam and sham of the Elmira cleanup continues. Bless you all politicians, fellow travellors and self-serving bureaucrats for keeping your heads down and letting them get away with it.

Thursday, August 1, 2019


First of all today's TAG meeting at 6:30 pm. in Woolwich Council Chambers will have a detailed discussion regarding the Ministry of Environment's (MOE/MECP) written comments on both Contaminants of Potential Concern (COPC) and on the Canagagigue Creek Conceptual Site Model (CSM). Lanxess and their consultants GHD have been working on these two matters for some time now.

Rather than go through the MOE's comments in detail I am going to boil it down to the basics. Lanxess, the proud owners of a still disgustingly contaminated site (i.e. Uniroyal in Elmira) do not wish, like every owner before them, to spend one nickel more than absolutely necessary on the cleanup of either their own site or of the Elmira Aquifers and the downstream Canagagigue Creek. The Elmira cleanup has for decades made a mockery of the politicians mantra that "Polluter Pays". All the successive owners of the Uniroyal Chemical site including Uniroyal themselves played the system shamelessly.

The MOE/MECP have touched on only a couple of the games that have been played over the decades. This includes the failures of the Upper Aquifer Containment and Treatment System (UACTS) to fully hydraulically contain the south-west corner of the site much less to contain the shallow aquifers discharge to the creek throughout the site. They have also advised that on page 2 of their July 30/19 document that Lanxess did not evaluate COPC's in groundwater "because the groundwater COPC evaluation was reportedly documented in the Annual Monitoring Report No. 28". "However, AMR No. 28 does not specifically identify the groundwater COPCs."

Elmira citizens and the environment have been on the receiving end of these "errors", falsehoods and deceptions for thirty years now. It is long past time for the games to stop and the truth to be told by both polluters and regulators.

Wednesday, July 31, 2019


This is not the first time that I have sung the praises of Cynthia Doughty, hydrogeologist, for the Ontario Ministry of Environment. She has done it again in a letter to Jason Rice, Regional Project Manager (MOE) dated June 20, 2019. Of course the question is how much will her employers (the MOE) support her. On page 2 Ms. Doughty states "However, for at least the last three years, the UACS has temporarily lost hydraulic containment." Then on page 3 she states "The UACS has not consistently maintained hydraulic containment since operation began in 1997." Holy crap ! That is huge.

The UACS is the Upper Aquifer Containment and Treatment System. It is the reviled and long criticized "least expensive and least effective " containment system that Uniroyal and CRA installed in 1997 to stop the grossly contaminated upper aquifer discharges to the Canagagigue Creek. Uniroyal, Chemtura etc. have bragged about it's effectiveness for decades. It appears that if it had been done properly it could have been much more effective.

I have been commenting in this Blog for years as well as at the last CPAC that the so called difference in surface water elevation in the creek and the elevation of the nearby groundwater was inadequate. I even recall discussions with Eric Hodgins of the Region of Waterloo where he defended the very small differential in water elevations as likely being adequate. He was wrong and I was right and this is not by a great deal the only time that citizen scientists or simply well informed residents and citizens have spoken truth to those in authority, only to be ignored and marginalized.

Tuesday, July 30, 2019


The above remark I believe was made by Pat Potter in 1995 regarding Uniroyal Chemical and the Elmira Water Crisis. If my memory serves correctly this occurred at a public meeting in the old arena complex on Snyder Avenue in Elmira, Ontario. At this meeting many experts as well as laypersons spoke in regards to Uniroyal Chemical's (once again) mickey mouse plans to hydraulically contain the shallow aquifer on only one quarter of their site (i.e. south-west corner).

As of this date the "Uniroyal trials" are not imminent. Based upon my hard earned knowledge and experience of the last thirty years, it would be easy to conclude that either the original corporate body or the current one are home free. Except. Uniroyal and their successors have shown over the decades an uncanny ability to seize defeat from the very jaws of victory. They have done this via fires, explosions, air releases, and more at the most inopportune times for them. Similarly just as environmental activists begin to give up on the majority of citizens ever rising up and demanding environmental improvements, they surprise us. A routine fugitive release of BLE-25 in September 2010 was enough to get all of Woolwich Council ejected in the next month's municipal election with the exception of councillor Mark Bauman from St. Jacobs. Almost a perfect election despite some of the less than stellar replacements in hindsight.

Time is both the weapon of choice of corporate polluters and their regulators as well as their greatest worry. What is coming down the pike to expose their coverups and failures in honesty and forthrightness? Dr. Richard Jackson was one such surprise for them. His criticisms from September 2015 until December 2016 of the MOE, CRA, and Uniroyal/Chemtura were incomparable and highly damaging to them. The failure of the local media to capture Dr. Jackson's public comments was unfortunate however his comments were indeed captured and published nevertheless. There is a record of them. I expect that more is coming. Every local person who has passed on prematurely from diseases that are not inevitable but exacerbated by bad air, food, and or water have left family members behind with long memories. They will not forget Uniroyal Chemical nor their fellow travellors.

Monday, July 29, 2019


It is unfortunate however necessary as sometimes life intrudes upon one's plans. Likely my Delegation in regards to the properties east and south of the Lanxess property and their impact upon the Canagagigue Creek will be rescheduled for August 13, 2019. Initially I was going to speak as a Delegate to the May 16, 2019 RAC (Remediation Advisory Committee) meeting however that august body had their meeting postponed from mid May to September 5, 2019. That to my mind pretty much sends the message to all citizens that take both the Elmira aquifer contamination and the Canagagigue Creek contamination seriously; that our politicians and varying authorities do not.

RAC were advertised by Sandy Shantz as a group of concerned stakeholders. What a joke! They consist of the Grand River Conservation Authority (GRCA), Region of Waterloo (RMOW), Woolwich Township, Lanxess, GHD, and the Ontario Ministry of Environment (MOE/MECP). Some of those so called "stakeholders" had been missing in action for more than a decade and had not attended CPAC meetings much less sat as members. I will say that the Region of Waterloo had done good things in the past and they preceded their departure from the long ago CPAC with a warning that if CPAC did not listen more carefully and pay more attention to their position that they would depart as they did.

Hopefully my Delegation to Council will occur on August 13/19. While certain Council members such as Sandy and Murray (at the minimum) may prefer citizen Delegations about Lanxess and contamination go to RAC rather than council, that is too bad. Especially it is too bad as Sandy fairly recently reduced the minimum number of yearly RAC meetings to three. Yes three! That too speaks to me as an attempt to slowly wind things down. I'm sure that Lanxess and their consultants GHD would like to run their mickey mouse Risk Assessment game on the Canagagigue Creek and get their pre-determined minimal cleanup so that they can put this whole thing behind them. Of course the result will be the never ending and still ongoing slow leakage of contamination both from on-site (Lanxess) as well as from off-site areas that were impacted by Uniroyal Chemical but never acknowledged. This would include the former Nutrite site as well as possibly near OW57-33 (Elmira Water Tower) (DNAPLS) unless of course the ones near the water tower came from Borg Textiles. It also includes Persistent Organic pollutants (POPs) on the Stroh property east of Lanxess.

Saturday, July 27, 2019


Recently a friend and colleague advised me that well known environmental activist, Pat Potter, had been known to go to public meetings regarding environmental matters wearing a button which said "THEY ALL LIE". Now my understanding of that conversation was that Pat was referring to corporate polluters, the Ministry of Environment, consultants to corporate polluters, and any and all politicians prepared to voice advice or opinions on the matter at hand. Stating the old joke, I don't think it's fair to paint all the members of those groups with the same brush just because 95% of them are guilty.

Two and a half weeks ago I posted here about the December 2012 blowup at Woolwich Council Chambers regarding the decision to re-verify Chemtura or not with the *Responsible Care logo and membership. Dr. Holt got into it big time with Chemtura reps Josef Olejarz and Dwight Este. The January 31, 2013 Elmira Independent carried more news on the issue that occurred at the monthly CPAC meeting at the end of January. Bob Masterson of the Chemical Industry Association of Canada (CIAC) attended and spoke about the *Responsible Care program. Myself, Vivienne Delaney, Dr. Dan Holt, and Richard Clausi (SWAT) all strongly criticized Chemtura's behaviour at the December 18/12 Council meeting in which they took turns misrepresenting and making false allegations against CPAC Chair, Dr. Dan Holt.

At this January 2013 CPAC meeting there was also strong criticism of Pat McLean being appointed to the verification committee by Chemtura. The criticism, plus details, came from Richard Clausi. He made it clear that Pat McLean, based upon her past behaviour, was viewed as being far too sympathetic with Chemtura Canada. For me the final takeaway from this entire episode was that *Responsible Care and the CIAC are simply a public relations tool in Canada for the chemical industry. They are just part and parcel of the entire sham of community public consultation. The polluter's hands are on the controls throughout the entire process of cleanup, "research", and unfortunately they even have major input into who represents citizens on public advisory committees and verification teams. It is all a pathetic joke aided and abetted by local municipal councils and the provincial ministry of environment.

Friday, July 26, 2019


The TAG Agenda for this Thursday (6:30 pm.) was sent out yesterday along with the Minutes from the May 9/19 TAG meeting. This Tuesday at 7 pm. I will be a Delegate at Woolwich Council speaking about Canagagigue Creek issues and possible solutions. The TAG meeting two days later will also likely touch upon some of these identical issues. Certainly the 32 page handout (Agenda & Minutes) has some very interesting maps showing primarily Lanxess's south-east corner via Google Earth although a picture of my large 2 1/2 foot by 3 1/2 foot map is also included which shows the entire east side of the site as well as part of the west side.

Joe Kelly had a hand held device that read ground surface elevations and it did indicate the direction of surface water flow into the former wetland area to the immediate west of the Stroh Drain, Ditch, and Berm (SDDB). It also indicated surface flow into a small and shallow pond just south of the former RPE-5. Sebastian Seibel-Achenbach indicated his belief that overland flow of massive quantities of Uniroyal Chemical's waste water would quickly fill the small pond and move further south and then east onto the Stroh property. Indeed Uniroyal and Chemtura themselves have clearly indicated that the waste waters flowed well past the tiny unnamed pond, past the SDDB and into GP-1 and GP-2. GP-2 in fact is right at the extreme southern boundary of the Uniroyal/Lanxess property.

Of course water and accompanying contaminants will flow via gravity towards the lowest lying areas. Contaminated waste water does not flow towards the most accessible and least expensive to clean up areas just because polluters' hired guns (consultants) say so.

Thursday, July 25, 2019


Hydrogeology is not rocket science. The fact that water flows either under gravity or under pressure is about the most basic knowledge anyone needs, to be able, via common sense and some study of the facts and physical properties of a site, to understand where groundwater is going and whether it is likely to be contaminated. Surface water flow in my opinion is even easier to understand. Groundwater is out of sight, out of mind. Surface water flow however can be directly observed. It can also be directly plotted and determined by very simple ground surface contour lines. These are based upon extremely accurate elevation above sea level measurements which have been done for the entire Uniroyal Chemical/Lanxess Canada site.

These elevation levels have been published by Conestoga Rovers, GHD, the Ontario Ministry of Environment (MOE/MECP), MTE, and possibly even the GRCA. The information has been available for the Uniroyal site at least since 1985, probably earlier. Last Monday I posted here an article titled "Three Very Difficult Facts For Lanxess". At least one additional fact needs to be added.

Jeff Merriman, environmental engineer for Chemtura Canada (i.e. Uniroyal), publicly assured CPAC members that Uniroyal Chemical had ploughed furrows in a north to south direction on the east side of their site in order to funnel and direct overflowing waste waters from their east side waste pits due south towards gravel pits GP-1 and GP-2. Now under gravity these waste water discharges would have flowed both westwards directly to the Creek as well as southwards into the former wetlands that comprised most of the south-eastern corner of their site. The former furrows however can be seen on some older photographs and do appear intended to lessen westward flow towards the Creek. Also there is a very large swale that can be seen both in photographs from the 1990s as well as from satellite photos. This swale is on the immediate west side of pits RPE-2 southwards to RPE-5 and past. It too appears designed to funnel east side waste waters into the former wetlands in the south-east corner.

So why does Lanxess and their predecessors all admit to this contaminated waste water flow going south but not eastwards over on to the neighbouring Stroh property. The answer is obvious. Money needed for more cleanup. Why won't the MOE admit to it? The same reason they lied to the public in October 1991 and supported Uniroyal Chemical's claim that they Uniroyal were the sole source of contamination to the Elmira municipal aquifers. We now know that at a minimum Nutrite (Yara) as well as Varnicolor Chemical had a piece of that action as well. The MOE looked incompetent enough after decades of falsely reassuring Elmira residents that their water supply was safe from Uniroyal Chemical to then admit it wasn't safe from multiple different sources in Elmira.

Wednesday, July 24, 2019


Money can buy you an acquittal and it is used by the Crown to convict. The party without it is at a huge disadvantage even if the Crown have a weak case. Just look at the numbers of citizens both in the U.S. and Canada who are exonerated after being convicted of serious crimes and sentenced to decades in jail. Two groups of lawyers come to mind namely Innocence Canada and the Association for the Wrongfully Convicted. Both groups have freed many wrongfully convicted citizens and have long waiting lists for their services.

Yesterday's Waterloo Region Record carried the following story titled " Murder case highlights how money can be a key to defence". It is about the Dennis Oland murder case in New Brunswick and is the poster child for monied defendants receiving much different outcomes from our judicial system. Nicole O'Byrne, a law professor at the University of New Brunswick said that Mr. Oland "had the resources to pay a defence team to follow up on every aspect of the case by hiring experts and by taking portions of the case to the Supreme Court of Canada for determination." She further added that "...not all citizens have equal access to resources that may be needed to mount a successful defence".

Kirk Makin, co-president of Innocence Canada stated that "...many of the people wrongfully convicted of crimes and later exonerated are poor people who can't afford the best defence." He added "Dennis Oland is a very fortunate man. The difference is profound between someone who has the means to get the best defence and pursue every avenue of appeal vigorously. The vast majority of people don't."

Mr. Makin also stated that people with top lawyers are treated differently by the courts (i.e. by judges). "When a top lawyer such as an Eddie Greenspan walks into court they are taken very seriously. There's a deference that's shown to them because of their reputation and skill". I interpret that as meaning that their words are given more weight by judges and juries.

Poor people are usually convicted. Rich people often aren't. Whatever happened to guilty beyond a reasonable doubt? Whatever happened to being judged upon the evidence presented? I've been there and an asshole judge with a bias or a personal animosity or who is simply incompetent can make a mockery of our entire judicial system. And the judicial system let them get away with it forever. Shame on the pack of them and the political apparatus that doesn't care.

Tuesday, July 23, 2019


Today's Waterloo Region Record has a Letter To The Editor written by Robert and Dale DeMatteo, two Occupational health researchers from Campbellcroft, Ontario. The title at the beginning of the Letter is "Why workers are demanding a public inquiry into WSIB." They have read numerous denial of claim decisions from the Workplace Safety & Insurance Board (WSIB) in regards to General Electric cases in Peterborough, Ontario. These two researchers refer to the WSIB as using "science" as a weapon against injured workers. And thus has it always been. The WSIB and its forerunner the Workmans Compensation Board (WCB) were set up essentially to allow employers to save money and increase their profits on the backs of their workers. Sometimes literally. With workers being refused access to the courts for proper compensation after being injured on the job, the financial burden was transferred from private employers to the public purse. As it always has been whenever possible. It's called externalizing of costs and the most obvious example is companies transferring their waste disposal costs onto the public via dumping into the common air and common waterways.

This Letter To The Editor makes clear that the Board have long used standards and criteria not enshrined in law. They have demanded evidence and "proof" of the cause of injury far in excess of that which the Act demands. In other words the Board has and continues to weed out claimants from just compensation. Hence workers who had zero say in the original formation of the two compensation boards removing workers rights to sue have even less say in the management and operation of a compensation system that is biased against them. What I also find disheartening is the arbitrary nature of the WSIB decision process. They appear to deny obvious claims of groups of workers (GE in Peterborough & rubber workers in K-W) in order to save money but allow other individual, questionable claims possibly in order to indicate that they do pay out for some claims. A car insurance company pulling this crap would likely be run out of town as should the Ontario WSIB.

Monday, July 22, 2019


1) Both they and the MOE have long ago confirmed that waste waters from RPE 1-5 flowed as far south as GP-2 which is well past the low lying area on the Stroh property which I believe is a "sink" for dioxins/furans, DDT and more.

2) The Canagagigue Creek has these toxic persistent organic pollutants (POPs) downstream in its sediments and creekbank soils for the next five miles (approx. 8 km).

3) Uniroyal Chemical produced these toxic POPs on this site.

As I have stated many times here in the Advocate as well as publicly at Woolwich Council meetings as well as at CPAC and RAC meetings, the likelihood of these chemicals being exactly where I have shown them to be is extremely high. No reasonable unbroken links exist in the evidence chain. On the balance of probabilities criteria, honest and unbiased experts and citizens understand and acknowledge this situation. Unsurprisingly those with either culpability issues (MOE perhaps) and those with cleanup money on the line continue to ignore the obvious and refuse to do legitimate testing necessary to make my assertions proven beyond a reasonable doubt.

So far since the discovery of the Stroh Drain, Ditch and Berm (SDDB) five years have been wasted by Chemtura/Lanxess and the Ontario Ministry of Environment. All our local authorities appear to be firmly behind them. I am ever hopeful that some politicians will come to their senses and or discover the truth for themselves sooner than later.

Saturday, July 20, 2019


The following is a verbatim copy of a Delegation given to the then Woolwich Council appointed Chemtura Public Advisory Committee (CPAC) now known as the Citizens Public Advisory Committee (CPAC) by citizen and SWAT (soil, water, air, & technical sub-committee) member Richard Clausi.

"Thank You.

I would like to take this opportunity to thank this CPAC for the wonderful work you have done on behalf of Elmira and all water users downstream.

I especially want to thank Dr. Dan Holt for his leadership and guidance as your committee has made significant strides in investigating and initiating work, East and Suth, that heretofore has been ignored....even to the point of obtaining grant money to do studies that the Ministry of Environment should be doing.

Your credentials are impressive:

2 PHD's, Dr. Dan Holt and Dr. Sebastian Seibel-Achenbach

1 professional nurse,

2 technical savvy professionals who each have their own environmental consulting companies and a SWAT that includes nationally recognized experts in their field, most notably,

Dr. Henry Regier, yet ANOTHER PHD, and also a recipient of the Order of Canada.

Of course you have engaged professional peer reviews to obtain paid opinions on items that you as volunteers have stated and know to be true. Perhaps, the greatest tribute to your work is that both the Ministry and the Company have boycotted these public meetings because they are unable to answer your specific and informed technical questions.

I point this out because, as you know, at a private meeting on April 9th, many outlandish claims were made by a group of stakeholders, indeed 14 of 17, have had no direct contact with this CPAC. Among the most troubling was the suggestion that you do not have the technical expertise to deal with these complex issues. I am also very concerned with the suggestion that CPAC meet less often, and, worse,that small technical committees meet privately, out of the public eye. It has been to your credit that you have insisted on transparency and the public right to hear all the information regarding the remediation efforts.

I find it amazing that "stakeholders" who have never shown their face at CPAC, and yet contributed to the poisonous, negative comments in the April 9 report/minutes or meeting notes which appeared on township letterhead, again, despite special invitation to attend tonight, are nowhere to be seen. These include folks from the GRCA, the Region, chemtura, ministry and even Council, who were personally invited at the last council meeting. I suggest that, the so called dysfunction is not within the CPAC committee but rather with the stakeholders who seem to be nowhere in sight tonight.

So what is the agenda? Have no fear, the "boycottees" will return when the right conditions are presented to them. It would appear that rather than being unable to understand the subtleties, you CPAC, are too smart, too savvy and, unfortunately, not passive or compliant enough. My fear is that the successful effort to smother real progress on cleanup, will put your work into a weird hibernation, perhaps to wake up in 2028 with a declaration that the water is now "safe". Grand River Users, be very, very afraid."

Advocate readers: Please note that Mr. Clausi has not used the word "liar" even once. Nor has he used the inflammatory term "corruption" even once. Nor has he specifically named the pretend mayor Sandy Shantz, who presided over this meeting even once. Nor the names Susan Bryant and Pat McLean who aided and abetted this travesty and attempted smearing of Woolwich Township volunteers. Lastly he did not mention, now thankfully departed, then councillor Mark Bauman who was also part of this disgusting and contemptible meeting orchestrated to undermine public consultation for the benefit of Chemtura Canada and their partners in pollution, the Ontario Ministry of Environment. Yes readers my language is harsher and blunter than many. But many other honest citizens believe the exact same things that I do albeit they are better at choosing gentler words and phrases to describe exactly the same thing as I do.

Friday, July 19, 2019


This sad individual comments on almost all my postings. His bias is in favour of the Ministry of Environment (MOE), "professional" consultants, the GRCA, and various credentialed experts. He of course is a former employee of the federal government and he rubbed shoulders with the MOE (MECP) and GRCA during his time with the feds.

His expertise in groundwater or hydrogeology is nil. That said he does have knowledge of surface water, sedimentation, erosion and deposition. His knowledge of chemical contamination whether ground or surface water is also nil. He has never attended a single public meeting in regards to Uniroyal Chemical in Elmira over the past thirty years. His knowledge, if any, regarding Uniroyal, their consultants, and the MOE's behaviour here in Elmira is all second or third hand. He has never heard their nonsense and self-serving drivel at public meetings here in Elmira.

Here's the thing. If he wasn't such a rude and biased individual he actually could add something to the conversation regarding Canagagigue Creek. His expertise could be helpful to those of us with first hand knowledge of the contamination of our air, ground water, surface water, soils and sediments with dioxins/furans, DDT and metabolites. As well there are mercury and PCBs and more in the fish in the Creek. The problem is that almost every comment he makes, informed and worthwhile or not, does not get published because he intentionally insults myself the author of this Blog. The insults are mostly childish and inaccurate. He thinks that that's O.K. because I insult Uniroyal and successors, plus the MOE. I do this based upon first hand dealings with them over the last thirty years. He and other local twits (some politicians) believe that MOE and Uniroyal (now Lanxess) deception or lying to the public is O.K. and should be tolerated whereas I do not. Lying is the ultimate disrespect and insult and most especially should not be tolerated from people working for the government and paid for by us the citizens, residents, and taxpayers.

Until professional and pathological liars including most(?) politicians understand that the public do not condone lying the way that they do, they will never understand that activists' contempt and disrespect for corporate and government liars will continue until they stop lying. In other words when the lying and accompanying insults to the public stop so will my responding insults. Meanwhile anyone with an opinion, informed or not, may comment here on the Elmira Advocate but forget the personal insults. Why would I publish them on my Blog? Leave out the personal garbage and yes I may criticize some uninformed or inaccurate comments but I won't insult them.

Thursday, July 18, 2019


Tough to argue with the above title but entitled, privileged, corporate employees have no problem doing so. Today's posting concerns yesterday's post and map. The highest elevation on the former Uniroyal Chemical site is 361.8 metres above sea level. The lowest is 344 metres above sea level and occurs along the banks of the creek in the southern portion of the site. The highest elevation is located on the north-east corner (i.e. top right). The daily volume of waste waters being pumped into the east side pits in the 1960s was 173,000 imperial gallons per day as per both Uniroyal and the MOE. On a five and half day work week that is just about one million gallons of contaminated waste water PER WEEK being dumped into the natural environment by Uniroyal and with the full knowledge of the Ontario Water Resources Commission (OWRC), forerunner of the Ontario Ministry of Environment (MOE).

CPAC and the public have been advised by Chemtura employees that Uniroyal ploughed furrows into the ground surface running north to south for the express purpose of channelling all the overflowing waste waters southwards versus some of them flowing westwards. Besides these man made furrows there is also a large swale on the immediate west (left) side of the former pits that runs southwards from the bottom of RPE-1 (the most northern RPE) past RPE-5 (the most southern RPE). It appears that the idea was both to discharge these toxic waste waters back into the Canagagigue Creek downstream of Uniroyal (out of sight out of mind?) and possibly they felt that the longer the liquid wastes were held on the soil versus the most direct route into the Creek, the more time they would have to break down, possibly.

Yesterday's map has both the Martin and Stroh properties clearly marked although they do not show up well on the image on my Blog. The large red arrows are on the Stroh property and indicate the location of a probable "sink" of dioxin/furans, DDT and more. This area unfortunately is submerged during major flood events as per the GRCA map presented here on Monday July 8/19. The smaller red arrows indicate a tiny pond on the Uniroyal/Lanxess property that also should be examined as a possible smaller "sink".

It is quite possible/likely that based on gravity flow some of the east side pits toxic contents flowed westwards after their diversion southwards and that they then discharged into the Canagagigue Creek on the Uniroyal property. Also there may be a small gap at the top (north) of the diagonal ridge of high ground (in red) that permitted entry of these gravity flowing waste waters into GP-1. In hindsight both GP-1 and GP-2 were somewhat red herrings put forth by both Chemtura and the MOE in 2013-2014 for remediation partly in order to pretend that large quantities of Uniroyal's wastes had not flowed eastwards onto the Stroh property and southwards onto the Martin property. That behaviour and public deception in my opinion is a form of corruption.

Wednesday, July 17, 2019


Recently I have included two maps along with my postings here in the Elmira Advocate. One was on Friday July 5/19 and the next on Monday July 8/19 a mere nine days ago. The first map (Friday) showed the map that I put together back in late 2014 and in an environmental universe of logic, reason, and common sense that map would have unilaterally blown thirty years of public relations efforts, lying, and junk science from government (MOE/MECP), consultants, and Uniroyal/Crompton/Chemtura, out the window. It did not because logic, reason, and common sense have not prevailed against money, power, professional liars, and all their fellow travellors. The bottom half of my map was constructed from a May 2013 CRA (Conestoga Rovers & Assoc. Dwg. C-02) map and included ground surface contour lines on it which clearly indicated where the toxic contents of decades of overflowing east side pits ended up primarily on the Stroh property.

The second map from Monday July 8/19 shows the Grand River Conservation Authority's (GRCA) 100 year floodline across the Lanxess (Uniroyal) south-east corner as well as across the Stroh and Martin property. It helps explain the planning and rationale behind the Stroh Drain, Ditch and Berm (SDDB). Of course I have slowly learned over the decades that presenting clear facts to our authorities is a waste of time. For them it's all about plausible deniability. One has to spoon feed the facts to politicians, their supporting bureaucrats, and polluters in order to slowly eliminate all unlikely and bizarre possible interpretations that they can and will come up with.

Following is another nail in their credibility coffin. This map shows via clearly visible yellow arrows exactly where the bulk of Uniroyal Chemical's overland flow of waste waters travelled. The yellow arrows follow the decreasing contour lines and hence indicate the direction of surface flow. The contour lines have been determined by CRA, MOE, GRCA, MTE, and others and are consistent with each group.The red arrows show exactly where the toxins (dioxin/furans, DDT etc.) settled in the lowest lying surface depressions. This is where sampling and probable remediation is desperately required to stop the ongoing flow of these Persistent Organic Pollutants (POPs) into the Canagagigue Creek. They are mobilized by heavy rains, snow melt and ongoing flooding.

Tuesday, July 16, 2019


In June 2019, a mere six years and seven months after the November 2012 public announcement that they, CRA and Chemtura, would triple the volume of off-site pumping, they have still failed to do so. That said they have set a high mark for off-site pumping of 77 litres per second average for the month of June. Back in 2012 they were averaging around 53 litres per second. This included all the off-site pumping wells at that time which were W4, W3, W5A, W5B, and E7. Currently they are pumping W3R, W8, W9, W6A/B, W5A, W5B, and E7. The W6 wells and W8 however are at tiny pumping rates with the heavy lifting being done by E7, W3R, and W9 (finally).

In May 2019 Uniroyal / Lanxess broke the 70 litre per second mark for the first time. Even higher the following month of June. Do I believe that they will ever double or triple the 53 litre per second mark of 2012? I do not. That would require over 100 litres per second to double it and over 150 litres per second to triple it. The track record for this site over the last thirty years has been one of bull manure, delay, and obfuscation. Their promises and words are nothing but wind. Also keep in mind that that promised tripling was supposed to include In Situ Chemical Oxidation (ISCO) in order to quickly decrease certain hot spots in the off-site municipal aquifers. That attempt was an unmitigated failure and Chemtura were grilled by Dr. Richard Jackson for their substandard efforts to implement it.

Monday, July 15, 2019


I have no doubt that residents in both Conestogo and Winterbourne will have negative impacts from the Jigs Hollow Pit (gravel). This would occur whether above or below groundwater extraction however below will exacerbate those negative impacts. At the same time I understand that the proponent (Kuntz & Preston Sand & Gravel) have a right to timely due process which they have not received.

For me it's about the bigger picture. It's about the proliferation of gravel pits all across the Region and across Ontario. Aggregate producers like to pretend that they are environmentally responsible by having a multitude of different gravel pits everywhere thus allowing them to underbid gravel contracts if their put is closer to the required gravel needs than their competition. I don't buy that for a second. It's all about them making more profit via more contracts via having the most pits licensed. The gas and diesel savings from haulage are going directly into their pockets and the nearby residents to these pits are merely collateral damage to their profits. Of course our Ontario government and Ministry of Natural Resources have been in a form of collusion with the aggregate producers forever. Why wouldn't they be. The association of aggregate producers are far more likely to make political party donations than the nearby individual residents.

There are indeed some necessary uses for sand and gravel. House and road construction come to mind. But each and every gravel pit located along the Grand River (and others) is death by a thousand cuts to the water quality in those rivers. That sand and gravel located along the rivers act as natural groundwater filters in removing sediments, bacteria, and other harmful matter from discharging
into creeks and rivers. Once removed by extraction that loss of a filter is permanent to the water body. As far as restoring prime agricultural soils via remediation after gravel extraction, that is just plain hooey. We had that explained by experts at the OMB hearing into the Hunder Pit (outside Conestogo) several years ago. Disturbed soil put into piles and then eventually regraded back takes decades to ever have its microbiological components restored to their original quality.

Gravel is a natural resource but it historically has not been extracted to the benefit of society or the environment as a whole. It has been extracted solely to the benefit of the aggregate producers and their fellow political travellors at the regional or provincial levels.

Saturday, July 13, 2019


Well it took them long enough. And our so called public Conservation Authority, the Grand River Conservation Authority (GRCA), should be ashamed of their public relations. Also they should be ashamed of their lack of transparency in their attempts to hide from accountability. Finally they should be ashamed of their willful abuse of Ontario legislation by hiding behind our Freedom of Information laws in order to avoid answering very simple and straightforward questions from not just one local concerned citizen but from many who had verbally expressed concerns with the lack of a proper outlet from the new storm water pond behind the Floradale Feed Mill that was discharging into the Woolwich Reservoir via overland flow of rainwater and mud.

Yesterday I was again at the scene albeit for the first time in two weeks. Not so much as an update or even an estimated time of construction had been provided to me after I had sent several e-mails to both the MOE (MECP) and the GRCA. They also had refused to provide me a copy of the permit (presumably with drawings included) that would have shown the intended construction of a proper outlet to the reservoir. I had indicated in those e-mails that other users of the trail had expressed serious concerns with the scenario of having the storm water pond built, including gravity flow channel directly to the trail overlooking the perhaps eight foot embankment down to the reservoir. At that point both during the spring rainy season and afterwards the rainwater and mud was either running down the trail (northwards) or over the embankment directly into the Woolwich Reservoir.

Do these bureaucrats actually believe that these are matters of national security? Do they believe that terrorists might somehow learn something that could undermine the stability and security of the Woolwich Dam? Why is it so important to them to keep secret the date of construction of a concrete outlet from a storm water pond into the Woolwich Reservoir? Do they think that responding to open, legitimate information requests from the public somehow weakens their power and authority in all matters pertaining to surface water in the Grand River valley? Or are they perhaps even more scared of increased observation and accountability, not from fellow political travellors, but from the unbiased general public?

Last question: Are they so petty and jealous of their authority that their biggest priority is to avoid the public ever learning that the squeaky wheel gets the grease?

Last comment: I'm not an engineer but the concrete outlet looks impressive and professional. Presumably the felt type material covering the inlet on the east side of the trail is to filter out the mud and sediments accompanying the storm water flow. Also presumably when that felt type covering becomes clogged it will be either cleaned or replaced. The outlet then goes underneath the trail and emerges on the face of the embankment (west side of the trail) above the level of the water in the reservoir whereupon it discharges into the reservoir.