AUGUST 26/07 CRITIQUE OF CRA'S DNAPL INVESTIGATION REPORT

There have been many different critiques of Conestoga Rover's various DNAPL plans and investigations during the last twenty years. They have included critiques by APT Environment, the Elmira Environmental Hazards (EH) Team, the Soil & Water sub-committee of CPAC, Citizens Environmental Consulting, the Region of Waterloo and the Ministry of the Environment. Yours truly has been involved in the researching and writing of many of these including APTE, EH-Team and the Soil & Water sub-committee.

By August 26, 2007 I had had way more than enough of CRA's blatant bullshit. They would receive serious critique's and sometimes respond to them clearly and competently. Other responses were simply for show so that at a later date they could say "See we responded to each and every point of concern" when in fact they did no such thing. My critique of August 26, 2007 was the culmination of a years long coverup of DNAPL issues by Chemtura and CRA. That critique was harsh and included terminology such as client driven, nonsensical, misleading, misrepresentative, psuedo science, deceit, falsehoods and bullshit. It also included however a grand total of nine pages of referenced, specific criticisms of their so called investigation. It quoted passages from their report as well as passages from the Region of Waterloo's critiques and the other critiques mentioned above. A face to face meeting with Doctors J. Cherry and B.Parker from the University of Waterloo giving their world renowned opinions and positions on DNAPL was included.

I have just reread my August 26, 2007 nine page report. I stand by every word and criticism of CRA's DNAPL Report. While CRA reference various comments/concerns from the other parties above in their reports, they have never acknowledged or responded to this one. They have responded to Soil & Water critiques, APTE and others but never to this most specific, targeted assault upon their client driven, junk science DNAPL Report.

Also having recently read Jaimie Connolly's May 2, 2008 letter giving comments upon CRA's August 2007 DNAPL Report has been an eye opener. Wheras Wilf Ruland (CEC) has occasionally written critiques a few weeks after M.O.E. critiques, borrowing heavily from them (April 21,2006 & May 15,2008) ; my August 26/07 critique supercedes Jaimie's by eight months. Jaimie raises exactly the same criticism of CRA's Effective Solubilty calculations in his report as I did eight months earlier. Perhaps this alone is embarassing to CRA. Afterall it does not suit their purposes to ever have to acknowledge that there is a citizen knowledgable enough on DNAPL matters to pick out flaws in their reports before the experts (M.O.E. etc.) weigh in. I will shortly be sending my 2007 report to all CPAC and SWAT members.