MONEY IS THE ROOT OF ALL EVIL - JUST ASK CONESTOGA ROVERS & ASSOC.

 

As soon as I saw the phrase Conestoga Lands Inc. in reference to the proposed zoning change and breach of the country side line on Bridge St. in Waterloo, Ontario I smelled something rotten in the air. Was it possible that a (in my opinion) rotten company, long ago merged with a bigger maybe less rotten firm, could still be spreading their anti social, anti environmental actions upon unsuspecting citizens? Well now that is a tricky question. I did a little bit of research trying to find out if the developers behind this proposed industrial site located beside Martin Grove Village in north Waterloo were indeed the former Conestoga Rovers & Associates (CRA) who made their initial claim to fame with the Love Canal disaster in the United States.

Well things get a little murky here. First of all CRA merged with GHD an Australian engineering firm around 2015 or so and carried on in name as GHD. CRA employees and shareholders were given shares in GHD and many (most ?) carried on with the new group. That being said the reference to CRA Lands Limited does refer to my least favourite engineering firm who are multiple winners of the MACHO Award.  They were presented with this award for their work with Uniroyal Chemical in Elmira and the award name stands for Memorial Award for Creative HydrogeOlogy. 

Now here's the rub. According to Google/AI,  CRA Lands Limited while referring to lands formerly owned by Conestoga Rovers & Assoc. are actually owned by a group of land developers. Maybe they thought that CRA had a good reputation environmentally or perhaps a good reputation as engineering consultants. I think it would be fair to suggest that dirty, rotten, polluting industries just love companies like CRA who give them the veneer of scientific oversight in their environmental decision making. Of course my harsh comments concerning dirty, rotten, polluting industries are a result of my working with/against CRA in Elmira for a couple of decades at least as they psuedo scientifically and drastically reduced  Uniroyal Chemical's cleanup costs.  

Now I don't claim to be any kind of land expert but it appears as if CRA Lands Limited and CRA Lands II Limited are controlled by Cook Lands Group. This company, again according to AI, is owned and operated by "...local Waterloo developer Ian Cook, founder of Cook Homes Limited,...". So here we appear to have once again the tail wagging the dog as home builders and developers are attempting to expand the hard country side line in order to obtain more lands to build profitable for them homes. 

I guess that I am less appalled because it isn't CRA directly behind this attempt to crack the countryside line; but only slightly less appalled. With Woolwich Township's penchant for sleeping with polluters and their fellow travellors, I expect smooth sailing for anybody riding on CRA's coattails.   

I REVIEWED PAST MEDIA STORIES ABOUT ELMIRA- SO DISAPPOINTING

 

And so inaccurate. I guess that's not too surprising. They took an educated guess and guessed wrong. They've backed the wrong horse and aren't going to admit it now. There was a large article in the Record last November with a number of pretty obvious errors in it. I contacted the Record in writing with specifics and details and basically got nowhere. They weren't interested in having to change any part of the narrative, accurate or inaccurate. I might add that there is a good comment published on yesterday's Blog posting regarding what appears to be Lanxess's intentional leakage and even pumping of contaminated groundwater pulling it off the Uniroyal/Lanxess site into the Elmira drinking water aquifers. 

Overall media coverage has been pathetic for years despite ongoing RAC & TAG meetings later followed by TRAC meetings. My initial name for TRAC was "Totally Rotten & Corrupt" but I have softened that to "Too Reticent and Compromising". Either one works for me although the second is politer and acknowledges that there are at least a couple of members whose intentions are good. The rest know what the game is and are fine with going through the motions and providing the Ministry (MECP), Lanxess and  Woolwich Township with the cover and credibility they require. Following is the verbatim Comment from yesterday's Blog posting:

 AnonymousAugust 19, 2026 at 9:08 PM

Yesterday's Analysis is SHOCKING!!! "By pumping less on-site and more off-site they are intentionally losing on-site hydraulic containment. This means that they are purposefully drawing contaminants off their site where they Lanxess only pay 50% of those cleanup costs versus 100% of all on-site treatment costs." so they drained the surface with ditches and swales and trenches into the river AND the parts of the Aquifer that were most contaminated they are attempting to just flush away downstream as well. Wow that is so environmentally mindboggling.

Reply

alan August 20, 2026 at 10:47 AM

TRAC whether you know it or not your mandate includes enhancing not undermining the cleanup of Elmira's groundwater. Your willingness to be led around by the nose on matters of Agenda and Discussion items is disgraceful. Your naivety and trust in corporate Lanxess and the corrupt MECP has and will continue to damage the environment as well as the health of all inhabitants, human and wildlife.

TRAC THIS IS ALSO YOUR RESPONSIBILITY TO BE MONITORING & INSISTING UPON COMPLIANCE FROM LANXESS CANADA

 

Look it's one thing to be a cheerleader versus a watchdog but at some point you have to insist that Lanxess comply with their Control Orders, Environmental Compliance Agreements, MISA requirements and other mandated conditions affecting Elmira's groundwater cleanup as well as the cleanup of the Canagagigue Creek. Yesterday we discussed their failure to maintain the balance between on and off-site pumping necessary to ensure hydraulic containment in both areas. 

Again I have the data going back to 1997 at my fingertips showing the volume of pumping from the UACS (Upper Aquifer Containment & Treatment System). Each month I transfer the pumping results from the ongoing Progress Reports onto one individual page for the year thus reducing 12 monthly reports pumping information for all containment systems to a single page. Now if Lanxess Canada had made some sort of breakthrough several years ago that magically reduced the required amount of pumping and treating of groundwater, they certainly haven't publicly made a big deal of it. In fact for many years the Target pumping rates for each well along with the actual pumping that particular month were discussed in detail. Uniroyal, Crompton and Chemtura were occasionally balancing and adjusting based upon water level conditions ("Gig") and other factors which they openly and properly discussed with the UPAC and CPAC committees. We were often advised that short term reductions were not necessarily a problem however the Target pumping rates were carefully set in order to maintain the necessary hydraulic containment and avoid loss of contaminants from on-site either to off-site groundwater or for the leakage of contaminants from the on-site Upper Aquifer to the discharge point into the Canagagigue Creek.     

Above and beyond the committee members themselves is the fact that all actions and particularly changes from past practices are to be discussed at the public RAC/TAG and now TRAC meetings. When pump & treat is the primary remediation method it is of particular public interest to discuss rationales for any changes in pumping regimens, especially reductions. This has not been done either for on-site Municipal Upper Aquifer (MU) pumping or for on-site shallow groundwater (i.e. Upper Aquifer-UA) pumping. The pumping rates have simply been getting lower and lower over the last several years with no public discussion involved. Whether or not I have been able to stomach in person attendance at these alleged public meetings the fact is that I have watched and listened to them in their entirety via their on-line presence. I have also written critiques of each and every one afterwards. Perhaps there are implications to these Lanxess Canada, MECP and TRAC UA pumping failures somewhat similar to the implications I wrote about yesterday concerning the Municipal Upper Aquifer (MU) pumping failures.

ARE LANXESS & THE MECP INTENTIONALLY SABOTAGING THE ELMIRA GROUNDWATER CLEANUP?

Why would they do that? Money obviously is the most likely culprit. Have they figured out that if they can't reach the 2028 Elmira groundwater cleanup deadline then they may as well cut back on pumping and treating in order to save themselves money? But wait a minute! Their off-site (i.e. beneath Elmira vs. beneath their site)  pumping figures don't reflect that. In fact they are pumping as much or more off-site than they've ever pumped. Ahh! The dirty, slimy, rotten so and so's! Notice here that I have not named Hadley, Lou, Jason or Lubna or anybody else from Lanxess/GHD/MECP as specifically being the "...dirty, slimy, rotten so and so's."  That could be construed as either rude or disrespectful and heaven forbid I'd never want anybody to suspect that I have zero respect for professional liars, especially those on the taxpayers' payroll, who would dissemble or deceive their true employers.

So what are the poor, misguided, obviously soul and ethics damaged folks at Lanxess doing? Well simply by looking backwards, something I challenge TRAC to do now and then, one can learn the answer. Since 2019 Lanxess, right in front of the Ontario Ministry of Environment (MECP), are significantly cutting back on their on-site Municipal Upper Aquifer pumping. Now keep in mind they've already achieved permission not to have to maintain 100% hydraulic containment on their site as they were originally ordered to do. The sad theory is that contaminants that escape from their north-west property boundary allegedly are recaptured by either on-site PW4 or off-site W5 A/B. This scheme supported by CPAC, APTE and the MECP at the time appears not to worry that they (Uniroyal/Crompton) have increased contamination for private property owners along the west side of their industrial site. This concession saved the company money just as their unilateral/bilateral decision starting in 2019 to cut back on pumping the most heavily contaminated and hence most expensive pump & treat on-site area did so. 

Way back in time, before RAC/TAG & later TRAC came along, one Jeff Merriman from Chemtura promised CPAC that on-site pumping (PW4 & PW5 at the time)  would average 6.0 litres per second in order to assure full on-site hydraulic containment. Averages probably for a while were closer to 5.8 or 5.9  litres/sec but they were at least close. Then under Lanxess Canada they started to fall and continued to do so. Now certain honest, albeit softly misguided individuals currently on TRAC such as Sebastian do not have the full past pumping  regimens of all pumping wells at their fingertips as I do. Most certainly neither does Susan Bryant who does not share Sebastian's attributes of honesty and being only softly misguided. Hence TRAC mostly composed of citizen members with less than five years experience  have simply ignored both on and off site pumping rates because they have nothing to compare them to despite 34 1/2 years of on-site pumping and more than 28 years of off-site pumping. All the data are in the monthly Progress Reports although that's too onerous for volunteers to dig through as I have.

So in the short term Lanxess cut back on their most expensive pumping and treatment costs AND guess what? By pumping less on-site and more off-site they are intentionally losing on-site hydraulic containment. This means that they are purposefully drawing contaminants off their site where they Lanxess only pay 50% of those cleanup costs versus 100% of all on-site treatment costs. We the taxpayers pay the other 50% of the off-site costs. This of course also lengthens and stretches out  the time needed to fully and properly remediate the (off-site) Elmira Aquifers.

I call this at the least gamesmanship and at the worst fraud. Certainly it also shows gross disrespect of Elmira citizens and all citizen taxpayers. Not a peep out of RAC/TAG or TRAC because mayor Sandy Shantz intentionally eliminated those of us on CPAC in late 2015 with the knowledge and honesty to oppose this deception and gamesmanship.   

K-W RECORD ARTICLE MISSES THE ENVIRONMENTAL MARK - "THE SHANLEY"

 The article in last Saturday's Record is titled "Long journey to transform former Kitchener industrial site almost complete". My first concern is the inaccurate or at least deceptive claim that the building was "abandoned and derelict for years," Nice try as it sat there rotting above ground and leaking trichloroethylene (TCE) below ground for many decades. The words "contaminated" and remediation" are used twice and once respectively.

What it doesn't say are the negative health effects that TCE has had on the neighbourhood, the residents and local wildlife likely since early in its life more than 120 years ago. The article also doesn't give us any idea as to the extent of remediation. Did mayor Vrbanovic  and local illuminaries ask for and receive the Cadillac cleanup as promised here in Elmira or instead did they receive the Volkswagon Beetle cleanup as we have here? TCE is a DNAPL chemical. Did they find remaining pools of TCE and if so what did they do with them? How deep did the soil and groundwater contamination go? What other chemicals were released along with the TCE? One component spills, releases and dumpings are mostly a fiction perpetrated by those looking for cleanup shortcuts. 

Where are the Phase 1 and 2 Environmental Assessments? Who did those assessments? Was a Risk Assessment completed allegedly to determine exactly how much cleanup was required? Were monitoring wells ever installed in both shallow and deeper aquifers to determine how far from the source the TCE (and other)  contamination has spread? Was any testing of nearby homes ever undertaken to determine if TCE had penetrated into them via vapour intrusion? How many cancers, lung and heart diseases may have been caused or exacerbated by TCE and other contaminants?

Sorry K-W Record but this article is simply a puff piece to help re-elect Berry Vrbanovic in October. Yes "The Shanley" probably makes the neighbourhood look better now but where was the cleanup 25 to 50 years ago when it was most needed?  As a society are we going to continue letting toxic contamination sit in residential areas for decades and pretend that no harm has been done?

LUISA DAMATO HITS IT OUT OF THE PARK - ALL WHO SIGNED NON-DISCLOSURE AGREEMENTS NEED TO BE VOTED OUT OF OFFICE

 

Today's K-W Record has a large Opinion article by Luisa D'Amato on page A3 titled " Something big is happening at Wilmot's industrial megasite. Why are we in the dark?" Personally I find the timing very telling. Remember the haste to prematurely cut the corn crop in one of the fields a year or two ago? That seemed to be sending a message to critics which was we the Region bought the field and we'll do with it as we please. Now just two months before municipal elections I have to wonder if the increase in activity including removing buildings, hiring security guards to patrol access roads and archeologists on site doing research is to defeat any negative response by citizens at the upcoming polls. Are regional councillors afraid that the election might actually reverse the process if citizens kick all the bums out of office?

As Luisa D'Amato indicates, a non-disclosure agreement prior to the bulk of the land being assembled might be justified on the basis of land costs being affected, but after the fact seems unreasonable. It is unreasonable because the public who are actually footing the bills have a right to know how this project "...will affect our environment, our food security, our water supply and our road and sewer infrastructure."  To date all requests for studies such as traffic, wildlife,  declining farmland capacity, electrical usage and water supply needs and capabilities have all been ignored. That is grossly unacceptable and exactly why those buggars need to be fired by their employers (i.e. us). 

Add to all that is the recent recognition of the frailty of our water system in Waterloo Region. This proposed megasite is close to the Wilmot Centre Wellfield which is already under enormous pumping pressure plus hampered by high Nitrates contamination. Ms. D'Amato mentions the concerns around a chemical spill. This is why subsurface stratigraphic conditions directly beneath the megasite need to be publicly published as well as the overlying soil/clay/sand/gravel above the wellscreens for the Wilmot Centre Wellfield. My recollection is that there are parts of the Waterloo Moraine in Wilmot Township with minimal to no clay aquitards between the ground surface and the predominate two aquifers beneath. Those areas are extremely vulnerable to chemical spills and could quickly finish off any hope of continued groundwater usage in large parts of Waterloo Region.

REGION'S COMPLAINTS PROCESS SURVEY - LIKELY JUST MORE OF THE SAME

 

You know I'd like to fill out a survey that I had some confidence was actually honest and above board. One that for example I could see my survey responses at some later date had not only been received but kept as part of the documentation on file. Do I really believe that my or anybody else's comments have actually been taken to heart by regional staff or politicians? Not a hope. 

The survey I filled out today was advertised in the K-W Record and is the second that I have completed. It makes me wonder what the results of the first survey were. Is the Region hoping to come off looking better simply by their proposed new procedure that was in yesterday's newspaper and probably introduced at regional council the day before? If their ratings have already risen does that mean that they can then backtrack by the five councillors of the appeal group deciding to automatically torpedo 95% of all appeals coming their way?

Surveys and dog and pony shows such as past regional games playing and likely the latest "public information and consultation session"  scheduled for August 20/26 are not true public consultation. Public consultation is less scripted and more public. Citizens ask questions from a microphone so that all present can hear their questions and then also hear the responses back from whomever is representing the government or industry behind the public meeting. Something like that would be worth attending. Private one on one discussions with staff are a waste of time and do nothing.