DILUTION, NATURAL ATTENUATION and LACK OF MONITORING DATA

To a certain extent I can understand the Ontario Ministry of the Environment's position. They are grossly underfunded in relation to their mandate. If the 90's were called the "turnaround decade" then I expect the 2000's to be called the "appearance of the turnaround decade". I can just see the big shots sitting in a meeting asking each other how they can possibly spin their "David" of a Ministry into appearing as a force to be reckoned with against "Goliath" industry. Even worse how can they be seen as real defenders of the environment when the majority of their own colleagues in Cabinet and the legislature are at a minimum pro business and industry? Make no mistake for those with money and power, you are either with them or against them. Reasonableness and comprimise is for the weak.

The first most basic cloice is lying or telling the truth. Will the benefits of honesty such as grudging respect from citizens and a clear conscience outweigh the negatives of being honest? The negatives will expose the whole house of cards to scrutiny. Being honest is telling the citizens that the M.O.E. takes up .3% of the provincial budget. Not 3% but .3%. Being honest means that the M.O.E. must choose their battles wisely. They can not possibly enforce the current environmental legislation with all industry. Hell they can't even enforce it with most industry.

With this background I can understand their decision to proceed with puffery, terminological inexactitudes, massaging the truth and blatant horse manure. The do nothing approach is very inexpensive. You simply rename it as "monitoring". This monitoring can include for example taking groundwater readings from half a dozen wells on Varnicolor Chemical's Lot 91 in 1996 and then again in 2011. As the site is surrounded on three sides with Landfill Creek and a swamp you can safely assume that normal groundwater discharge will over time, reduce contaminant concentrations. Then be sure that you seal or decommission these wells so that they can't be used again.

At the 62 Union St. site now known as 84 Howard Ave. make sure that your wells are only in the thin Surficial Aquifer above the larger Upper Aquifer (UA). This gives you some plausible deniabilty regarding deeper contamination entering the Municipal drinking water Aquifer below the site. Conveniently refuse to acknowledge or comment on damning evidence such as DNAPLS found 100 feet below ground surface just west of Varnicolor by the Howard St. water tower. Also refuse to comment on 1,100 ppb. Petroleum Hydrocarbons found 3 metres west of the Varnicolor site at CH70D in the Municipal Aquifer.

Meanwhile back at Chemtura refuse to order them to take soil samples at GP1 & 2 more than 2 metres deep. You might find something demanding greater scrutiny and cleanup. Also when Chemtura remove 125 drums and carcasses (drums) from the M2 area in the south-west; make sure they don't present the lab results to CPAC or the public. There are people, myself included, who can understand and interpret them. This public knowledge is to be avoided at all costs.

Don't misunderstand me. Lying is not easy. It takes planning, coordination and special people. Not just anybody can do it and those that can and will must be rewarded for their loyalty.