BACK IN 2004 DR. HENRY REGIER WROTE AN ESSAY ON MODERN RISK ASSESSMENT (RA) AFTER RESEARCHING CHEMTURA'S RA OF THEIR SITE

 

I remember being shocked and flabbergasted by the shallowness and apparent amateurishness of Chemtura's results. Their RA was to determine if their site somehow was a threat to either human beings or wildlife. According to their scientific study the only human beings at risk were trespassers and the only wildlife at risk were shrews. Now the shrews ate worms contaminated with dioxin which explained their health risks but nary a word about predators of shrews . Keep in mind that both DDT and dioxins bio-accumulate in concentration as they move up the food chain. So what about hawks, owls, foxes, mink, weasels, coyotes and other consumers of shrews?  

Trespassers wandering aimlessly on their site allegedly were at risk. Perhaps these trespassers were kind enough to wear large signs distinguishing themselves from employees, contractors, invited visitors etc.  This would of course explain why only errant and  occasional trespassers were more susceptible to any of the hundreds of various manufactured poisons as well as poisons produced as by-products of fungicides, herbicides, pesticides, insecticides etc. Also from personal experience I can testify as to the noxious odours and fumes emanating from the two east side consolidation pits prior to their removal from the sub-surface.

Dr. Regier along with myself and others were members of CPAC (Chemtura Public Advisory Committee). Chemtura explained their various RA rationales and assumptions to CPAC although not particularly in detail or with specifics. Dr. Regier made it his business to professionally investigate the process and procedures around this Risk Assessment (RA). He by invitation and in person talked to a number of Ministry of Environment personnel with expertise in RA as well as other professional sources. He then later synthesized what he was told and advised into an essay which he provided//published in 2004.

I enclose merely the first several sentences of it as follows: 

"In recent years the environment agencies of the Canadian and Ontario governments have implemented a bureaucratic process of Risk Assessment ostensibly to satisfy a commitment to the Precautionary Principle, inter alia. In effect the process abstracts, truncates and devolves difficult issues from the political arena to a conventional bureaucracy with limited competence on these matters. A costly, junk science version of a shell game may result. Whether or not it was the subversive intention of political operators "unfriendly to the environment" to do so, the process of Risk Assessment actually implemented seems designed to cripple a commitment to effective precaution or clean-up. In addition to treating this subject generically from a perspective of post-normal science, personal experiences with Risk Assessment related to contamination of a creek in Elmira will be described. An alternative participatory process for making decisions in such cases was published by officials of Ontario's environment ministry some years ago, but seems to have been ignored."

Dr. Regier thankfully is still alive and kicking and recently passed this essay and words onto some academic colleagues as well as myself.  These words as well as my personal experiences with TWO Risk Assessments, one by Chemtura and one by Lanxess Canada have formed my opinion of the second RA regarding the downstream Canagagigue Creek. To call that most recent RA a "...costly, junk science version of a shell game..." is far too kind.  The TRAC and TAG committees of Woolwich Council have either forgotten or never understood the criticism and concerns of myself and some committee members. One former member, Joe Kelly, was both accurate and clear in his descriptions of shovel sediment sampling versus using core samplers. Other issues included a plethora of Non-Detect (ND) results due to lab Method Detection Limits (MDL) in excess of health criteria. Locational sampling biases were but another flaw in the field work surrounding a RA which claimed that there were 

                              "...NO UNACCEPTABLE RISKS "  in the downstream Creek.

No proper, independent health studies combined with junk sampling and junk science. I mean Woolwich Township will happily throw their own volunteer citizen committee members under the bus as they have in the past (2008 & 2015). That is your eventual purpose TRAC. Do you think professional politicians are dumb enough to take the blame both after the 2028 groundwater failure and professional, unbiased academic papers begin to condemn decades of Elmira/Uniroyal junk science?   

HAS A WILMOT GRAVEL PIT EXPOSED AN ONGOING SOURCE OF SALT IN OUR GROUNDWATER?

 

Remember the groundwater contamination in Waterloo Region is not only TCE (trichloroethylene), benzene, chlorinated solvents, NDMA; it's also nitrates, glyphosate (Round Up) and salt.  The salt of course comes from our roads and sidewalks in the winter to reduce slips and falls as well as auto accidents. In today's K-W Record however we learn that a new gravel pit in Wilmot Township, situated above the Waterloo Moraine has been accepting truckloads of snow this winter.  The title of the article by Terry Pender is "Ministry shuts down snow dump in Wilmot Township". One estimate is 50 truckloads of snow in the past two weeks being dumped at the surface of the Waterloo Moraine in the groundwater recharge zone.  The likelihood of this snow being contaminated with salt either from roads, driveways or parking lots is extremely high. 

Snow dumping is not permitted at this gravel pit under the license issued by the Ministry of Natural Resources (MNR) hence the owner was ordered to cease and desist. Allegedly the MNR. conduct regular inspections to ensure compliance with the terms of their gravel pit license however just like their sister ministry the MECP (Ministry of Environment, Conservation and Parks), that is highly unlikely especially in the winter time. This case like many was initiated by local citizens' complaints. 

The timing of course is exquisite as just last week the Region of Waterloo announced that more water would be diverted from the Shingleton Wellfield in Wilmot Township to K-W and Elmira. Kudos to Rory Farnan and Samantha Lernout of "Citizens for Safe Groundwater"  for their vigilance and action. 

I too in decades past have reported gravel pits for illegal dumping up here in Woolwich Township. Unfortunately there wasn't at the time a very public water supply crisis and absolutely nothing was done by our unesteemed Ministry of Environment (MOE) . Unfortunately gravel pits especially near the end of their gravel production time are prime areas for burying stuff you can't (or shouldn't) take to the Waterloo Region, Erb St. Landfill. I would think that dirty snow from our streets and highways is a prime candidate for illegal dumping in multiple Regional gravel pits in the winter because come spring the evidence literally melts away. 

Closer to home let's not forget our own snowdump here in Woolwich Township. It's right above the former First St. Landfill which is actually sitting upon reclaimed ground that used to be below the Canagagigue Creek before it was straightened in 1963 or 64 to allow the building of the Elmira Sewage Treatment Plant. Where exactly do you think all the salt, debris and contaminants end up every spring after snowmelt?  

Quoting Rory Farnan "All this talk of protection, but no teeth." He is correct and it is done intentionally by our politicians at all levels. They pass legislation allegedly to protect their citizens but rarely include serious enforcement provisions because afterall our developers, industrialists, gravel pit operators and employers are all well organized into lobby groups and who also financially support political parties while demanding relief from onerous and strict enforcement of many laws. Finally is it not likely that politicians themselves are reluctant to see laws affecting themselves and their duties being enforced rigorously? Hypothetically perhaps this might even include laws around election financing and reporting. 

WILL "WATER BANKRUPTCY" BE THE END OF THE WILMOT LAND GRAB AS WELL AS OF THE NON-CLEANUPS IN ELMIRA & CAMBRIDGE?

 

It may be too much to hope for. Our politicians do best looking at short term problems not long term ones. Federally that would also apply to crime which by its' nature tends to be quiet and at least somewhat hidden from most of our views especially depending upon where we live. I expect that illegal drug use and petty crime go hand in hand in our inner cities and organized crime more obvious in Toronto, Hamilton, Montreal and Vancouver with unfortunate hot spots in Winnipeg, Thunder Bay and economically disadvantaged cities. Our federal government's response is to confiscate legally acquired firearms whose owners are licensed from the very same federal government. My understanding is that convicted criminals plus those with a history of serious mental illness can not obtain firearms licenses. So the federal government's crime fighting consists of disarming those proven to be law abiding.  That plan should work by fooling the public for what ten minutes, ten days, ten months ?

On January 26, 2026 the K-W Record published an article by a Director of the Institute for Water, Environment and Health, Mr. Kaveh Madani. His premise is that "Many natural water systems are no longer able to return to their historical conditions. These systems are in a state of failure - water bankruptcy." He further states "Despite these problems, nations continue to increase water withdrawals to support the expansion of cities, farmland, industries and now data centres." He has many other suggestions including respecting the science that tells our politicians when enough is enough. In other words don't keep growing and expanding population and economic growth blindly believing that engineering can solve all problems including water shortages. On its' own it cannot.

I'm still waiting for Wilmot Township to respond to the Region's plans for taking more water from their groundwater to satisfy Kitchener, Waterloo , Elmira etc. Why shouldn't the mayor of Wilmot, Natasha Salonen tell Woolwich to clean up their own act? Clean up our Uniroyal, Nutrite and Varnicolor Chemical contaminated groundwater so that we can once again be self-sufficient in water. When Cambridge finally admit their issues with TCE (and more) contaminated groundwater and actually seriously attempt to remove it at source rather than at their treatment facilities (Middleton Well Field etc.) then they might actually have enough reasonably priced water to send to K-W. The failure to clean up Breslube (now Safety-Kleen) decades ago assisted in shutting down two Kitchener wells, K70 and K71. Does Ms. Salonen think building a massive 700 acre industrial facility on top of agricultural land, combined with pumping groundwater on behalf of Kitchener-Waterloo  actually solve anything?

Difficult decisions in the PUBLIC interest need to be made now.   

REGION'S WATER SUPPLY CRISIS GETTING NASTY: THANK GOODNESS

Why do I say "Thank Goodness" above regarding our water crisis getting nasty? I say it because history has shown that when all the stakeholders get together, hold hands and sing from the same choirbook; the public get it in the ear. In fact it's almost a given. The prime local example is the 1989 Elmira Water Crisis.  As long as the Ministry of Environment (M.O.E.) and Uniroyal Chemical were at each others throats in front of the Environmental Appeal Board (EAB), then the public were learning all the dirty environmental secrets of a multi-national, multi-billion dollar corporation . The plan was for the M.O.E. to then take the stand for examination and cross-examination after Uniroyal were finished. It never happened because Uniroyal knew that they had the dirt and the goods on the M.O.E. who were more than willing to sell out the public interest in order to save their own credibility and reputations. This the M.O.E. did by offering a sweetheart deal which allowed Uniroyal to save hundreds of millions of dollars in cleanup costs. These saved cleanup costs included both the downstream Canagagigue Creek as well as not forcing Uniroyal to remove as many DNAPLS as possible on and off their site.

The hoped for nastiness today is between local developers & builders  against the Region of Waterloo. It's even possible that we might see some sort of Region versus the province nastiness if we are very lucky. Do not be fooled by peace, love and harmony between essentially hard nosed, play it close to the line parties with vastly different interests. The developers and builders will quite happily build homes and commercial buildings to our very last drop of water as long as they get paid to do so. Regional Council politicians want status, recognition and when possible legacy projects to cement their reputations. Unfortunately most of them aren't remotely smart enough to actually be able to understand water systems or for that matter anything technical at all. including financing and budgets. This they do not want exposed hence they too will do almost anything to escape close scrutiny for the water crisis including selling out their constituents. Melissa Durell Executive Officer at Build Urban threw the first grenade when she suggested that the development freeze/water crisis was a "manufactured crisis".  

Both articles in today's K-W Record by Luisa D'Amato and Terry Pender suggested that regional staff and councillors might face civil and or criminal liability. Hallelujah it's about time. Generally speaking politicians like police officers have way too much immunity from prosecution or even accountability.  Throw all the stones you want and let the chips lay where they fall. If regional councillors have been ignoring staff water warnings for years and going full speed ahead on development then they need to be charged for putting all of us at risk of water shortages. The problem is there usually is enough mutual blame for the stakeholders to stop throwing stones, make nice, lie to the public and cobble together some kind of second class deal to stave off the worst of the consequences all while removing blame from the equation exactly as they did in Elmira. 

LEST WE FORGET: DEVELOPERS & BUILDERS INTERESTS ARE NOT THE SAME AS THOSE OF WATERLOO REGION RESIDENTS AS A WHOLE

 

Developers and builders want to make money today not tomorrow and the housing gravy train has been very good to them for many decades.  Just as they prefer to talk about building overpriced and grossly out of reach homes for the unhoused we have our Regional Chair Karen Redman  jauntily advising all and sundry that "...this is not about blame, this is about building a path forward." While I disagree with much of Kitchener mayor Barry Vrbanovic's comments which appear to show his dedication to the development industry, nevertheless he did strike a chord with his wish for all to know what happened to suddenly drop the bottom out of being ready for one million people here in the Region by 2051. 

Mrs. Puopolo and Masseo, developers, both want to believe that the water shortage is an engineering problem not an environmental or sustainability issue.  Minor (to them) facts such as low water elevation readings in a major aquifer are not setting off alarms as they should. I expect that these two gentlemen wouldn't concede a water shortage until the day they turn on the tap and nothing but dust comes out. Clearly freezing development permits until after the problem is both clearly defined AND if required greatly improved; is the proper action. 

Proper action also includes answering the question how did this problem sneak up on us? Obviously the Region's water department does not have an accurate handle on how much water is available from the Waterloo and Wellesley Moraines  plus from other aquifers in and around the Region of Waterloo such as Bedrock Aquifers in Cambridge, the Elmira Aquifers and more. Also I wonder just how reliable the Grand River is looking these days with the effects of greater extremes in weather upon us. 

It seems to me that often those like ex Woolwich councillor Mark Bauman and Regional Chair Karen Redman who trumpet "I won't play the blame game" do exactly that while pointing the finger at others rather than themselves.  

I SURE HOPE REGIONAL COUNCILLORS ARE PAYING ATTENTION

 

Your master is speaking and I sure as hell don't mean me or any other local citizens and residents.  Scott Higgins, President of Hip Developments Inc., is speaking and maybe he's forgotten the way of the world. You'd think that his company name would remind him though: Hip Developments as in "joined at the hip"  with our local powers that be i.e. regional government. Come on boys and girls democracy functions best when the ruled (us) can sort of believe that we have a small say in things. For that to happen the real powers of money and influence have to work together with our sort of democratically elected representatives. In other words Scott soften your approach when you blurt out "I think it's a reaction to the ineptitude in water management." Of course it is but far more than likely it's not professional water staff who are inept as much as it is non-professional, untrained for anything except shmoozing, talking and politiking regional politicians who are just trying to vote in line with the powerful and influential but sometimes they get confused.  Once you're no longer in the habit of  thinking for yourself but of simply following orders then you get into trouble.

I also enjoyed Mr. Higgins shot at our Regional Police Service. Of course their budgets are out of control and have been for decades. Again you have a bunch of twits rubber stamping police budgets with the financially challenged mayor Shantz as part of the Police Board. At least she appears to have learned how to properly fill out the amazingly simple and easy Financial Election Statements after several tries.

I will say that Mr. Marcolongo of Environmental Defence does make a strong argument to restore the Region's planning authority that was removed by Doug Ford's provincial Conservatives. Mr. Marcolongo's suggestions at least in my mind make much more sense than regional councillor Doug Craig's attempts. There is one point however that I agree with Mr. Craig on and that is that we the public should learn the history of how we got to this point in the water crisis without being notified . Of course this is dangerously assuming that it is indeed the truth that regional councillors had not been notified much earlier.

SOME WATER "SOLUTIONS" FROM THE REGION YES BUT PROBLEMS PERSIST INCLUDING INCOMPLETE ANSWERS

 

Todays K-W Record has another article by Terry Pender advising us of a staff report released yesterday. Repairs and changes to both the dormant Greenbrook water facility and the Mannheim water treatment plant are being proposed. The first would be completed by this coming September whereas the work at Mannheim will tale six to eighteen months to complete. There is also the suggestion to reallocate water from Wilmot Township to Kitchener and Waterloo. Gee I wonder how well that will be taken by folks in Wilmot Township firstly without the 700 acre land grab and secondly with that land grab included.

The Greenbrook wells have some industrial contamination in them from the nearby Ottawa St. Landfill. How extensive the "modifications" would be I do not know but wonder if they are primarily treatment issues. The Mannheim System may have it's disinfection system altered as part of their "changes" or not. Again our regional folks are being very cagey regarding chlorine versus chloramine disinfection between the two Systems as well as whether the AOP (Advanced Oxidation Process) treatment to remove trichloroethylene (TCE)  from the  Middleton Wellfield in Cambridge is problematic as well or not.

I find the so called water "surplus" in Cambridge very strange. Is this "surplus" counting all the contaminated wells and if so have they been "resting" until recently with K-W water making up the difference? Or have Cambridge residents been enjoying the thrills involved with drinking highly treated water that may have added toxic by-products of disinfection included?  For example is the alleged "stink" produced by mixing Mannheim water with Cambridge (Middleton wellfield) water merely the result of so much chlorine in both systems making the chlorine stink worse than we all ready know? Or is it something totally different and if so what is it? Also how exactly are the proposed new pumping station and watermains supposed to integrate these two systems? Pumps and watermains are not treatment facilities, they are parts of the distribution system whether internal distribution during treatment or external distribution from house to house or city to city. Once trust has been lost by authorities either gilding the lily or outright lying to citizens, then their word means nothing.

P.S. I particularly enjoyed the reporter's shots at the Mike Harris family who have done so much for the Conservative Party and so little for Ontario citizens.  Thank you for your service and goodbye.