Tuesday, July 5, 2022

MECP COMMENTS ON DRAFT RISK ASSESSMENT (RA)

   Well the July TAG meeting was pushed back to August in order for the members to be sure to have time to read the Min. of Environment comments prior to the meeting. Well they've been available since a day or two after the last TAG meeting on June 23/22. I've actually read the report three times to date as well as high lighting many of the most important statements and the fact is I'm still unsure as to how significant the Ministry's (MECP) comments actually are. The reason is because I've been reading the Ministry's comments on technical reports from Lanxess/Uniroyal and their consultants for over three decades now and I've learned that no matter how much "concern", "criticism", "anger" is expressed by the MECP it rarely changes anything. Somehow magically all the serious flaws in Lanxess/Uniroyal reports are "addressed" when in fact they rarely are. I no longer will be surprised if at some future time we learn that Uniroyal and corporate friends have been extorting compromises from the Ministry of Environment for decades.   

   There is a two page attachment on the front of the nine page unsigned MECP report titled "Review  Comments on the draft report entitled Risk Assessment-Canagagigue Creek, Elmira, Ontario (Stantec) dated February 16,2022" . The two page attachment is signed by Jason Rice Regional Engineer MECP. It has a brief summary not of requirements but of requests hence again why I am skeptical. These requests are for a revised draft report (RA) and allegedly are "...to undertake additional human health evaluation...". These requests include:                                                                                                                                   

"* further evaluation of areas of sediment in the creek and creek bank soil where elevated levels of contaminants were found ('hot spots');                                                                                                                                                                                                                                                                                        * further assessment of the potential risk to human health from consuming farm animals (i.e. chicken, eggs, cattle, dairy products) that may graze on the creek flood plain and could be exposed to contaminants;                                                                                                                                                                                                                                                                                      * additional evaluation of potential exposures through the consumption of fish from the creek; and,                                                                                                                                                                                  *provide additional information and assessment of groundwater" 

    The nine page report is of course more detailed and it raises some interesting questions for me including why is this RA voluntary and NOT being conducted under the regulatory requirements of Ontario Regulation 153/04. This statement is on page 1 of the nine page review and also states "For example, there are several requirements within the regulation that this risk assessment would not be fulfilling." Of course as I and other informed citizens have been discriminated against via being refused either membership in TAG OR the right to ask questions/demand answers of Lanxess/MECP/GHD/Stantec etc. then most likely these questions and others will go unanswered. 

 

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