INAPPROPRIATE OPTIMISM BY DEP'T OF FISHERIES & OCEANS?

For the last few days there have been a number of articles both in our local paper the Waterloo Region Record as well as others regarding fish and other mass die-offs in the Halifax area. These die-offs have included bottom dwellers as well as fish and perhaps coincidentally a dead whale has also washed up on shore. Yesterday's article in the Record was titled ""perplexing" Nova Scotia fish kill not too worrisome: ocean officials".

What has me concerned is not only the large die-offs but also the fact that multiple tests have all come back negative. Officials have been testing for toxic algae, contaminants, dissolved oxygen, salinity and other indicators as to why this has happened. Maybe it's about time that both our federal officials as well as our provincial Ministry of the Environment become more honest with Canadians. The fact certainly seems to be that science can only see and understand so much. There are many other factors that to date science is either unaware of or simply have not mastered yet. Given time we will eventually better understand our natural ecosystems and be able to pinpoint causes of conditions that result in massive die-offs of previously healthy populations. To date we continue to poison our environment and then hide behind incomplete scientific proof as to what the cause is.

WOOLWICH'S MEDIA RELEASE- ROGER's INTERNET DOWN

Here are a couple of items on the Township's Media Release that will not please either Chemtura or the Ontario M.O.E.. RAC categorically have stated that the Ministry's Notice to Residents last May is inaccurate and RAC does not support the claim that Dioxin levels are have decreased substantially since the 1990's.

Secondly RAC wants all hotspots in the Canagagigue Creek which exceed Canadian criteria for Dioxins/DDT & more remediated. This means removal of all these hot spots not just a couple that Chemtura and the M.O.E. favour.

Finally the current Draft of the East Side Workplan is unacceptable. Greater coverage of areas near the "Gap" on both sides of the Chemtura Stroh border need to be tested , both soils and groundwater.

This Media Release is a long overdue huge step forward. This kind of effort thirty years ago versus apologizing for asking our local world class polluter to clean up would have made a world of difference. About bloody time!

SO WHAT IS GOING ON WITH WOOLWICH TOWNSHIP?

To date we have had one excellent TAG Chair namely Dr. Jackson. It is a major shame that he has departed. The second Chair is Tiffany Svenson and I recall Dr. Jackson approving of her nomination to the position. That bodes well. We have had Woolwich post warning signs along the Canagagigue Creek despite the Ontario M.O.E.'s objections. TAG (Technical Advisory Group) quite frankly have been hammering Chemtura and the Ministry of Environment (M.O.E.) for over a year now. That is both accurate and appropriate as well as music to my ears. Not only TAG but also RAC (Remediation Advisory Committee) have been passing Motions criticizing the M.O.E.'s words and actions. That is also honest and appropriate and frankly a pleasant surprise to my ears. I did not give them much hope based upon so many politicians (municipal) and bureaucrats as well as decades of not aggressively stepping up and demanding both honesty and appropriate action from Chemtura and the M.O.E.. Lastly I have checked on the Township's website and by gosh they do indeed have a Media Release in regards to the last (Dec.8/16) RAC meeting. Assuming they did send that along to at least the local media, then good on them.

Why would a Township who have vigorously defended Chemtura and the M.O.E. for so long using age old tactics such as appointing tame committees (UPAC & Crompton/Chemtura Public Advisory Committee), totally under their thumbs, now decide to get aggressive? Why would Woolwich who enabled and assisted Chemtura and the M.O.E. in their fake CPAC boycott (Oct./14-Aug./15) now decide to get tough? Why would Woolwich lie, deceive and slander the last and best CPAC both verbally and in writing (April 9/15 "stakeholders" meeting)? Why would they focus their disrespect upon Woolwich volunteers especially including Dr. Dan Holt and myself who have done nothing but truthfully point out the falsehoods of Chemtura and the M.O.E. over the years? Everything CPAC (late 2010-Aug.2015) publicly stated in direct contradiction to Chemtura and the M.O.E. has come true and is now being espoused by Woolwich Township, TAG and RAC.

Imitation is the sincerest form of flattery I am told. O.K. so myself and many CPAC members are flattered. Some Woolwich politicians and bureaucrats have complained about style versus substance. They whined about hurt feelings and disrespect shown to Chemtura and the M.O.E.. Boo hoo, so sad. The reality is that the Township's TAG Committee appropriately were soft and fuzzy right up until they caught those two parties lying, dissembling and disrespecting them. At that point, exactly as with CPAC, TAG turned up the heat. In fact other than myself, I would suggest that TAG's "heat" often exceeded CPAC's. The Chair (Dr. Holt) and vice-Chair (Dr. Seibel-Achenbach) are gentlemen through and through. So are Ron Campbell, Graham Chevreau and while she does not suffer rudeness or sexism gladly (just ask Todd C.), Vivienne Delaney is a lady. That leaves Richard Clausi and Dr. Henry Regier of the SWAT sub-committee). They too both are polite and respectful but neither is a pushover and will push back hard when needed.

While the Citizens Public Advisory Committee (CPAC) are pleased with the direction of RAC, TAG and Woolwich Township and frankly disgusted yet again with Chemtura, GHD and the M.O.E.; is it any wonder that we do not remotely trust the Township? Why would we? What has motivated their disgusting behaviour? Is it all personal to the point that they would harass, disrespect and replace multiple volunteers just to get at me and or Dr. Holt who never did anything to disrespect the Township? Or on the other hand are the Township under Sandy and Mark's lead just playing yet another game? Are they play acting again as tough protectors of the environment all the while greasing Chemtura's easy exit from accountability and cleanup? Time as always will tell.

RAC MINUTES FROM DECEMBER 8/16

As usual I post about these public environmental meetings the morning after and then sometimes we wait forever (weeks or months) and other times barely three weeks to see the formal, published Minutes. Regardless I enjoy reading my interpretation of the meeting and then later reading what has come from the formalized Minutes process handled by the Township. Overall I would say that I am pleasantly surprised by the quality of the Township's efforts. Yes their's is no more perfect than mine whether typos, spelling errors or factual discrepancies. Sometimes it's no more than a different focus between the Township and myself regarding what we view as significant.

As usual the lack of Disclosures of Pecuniary Interest is absolute horse manure. Kudos however to the Township and their Recorder for appropriately recording CPAC's (Citizens Public Advisory Committee) Delegation to RAC (Remediation Advisory Committee) that was presented by yours truly. Further kudos in that my Delegation in its' entirety was included with the Minutes as they are on the Township's new website. Check under Committees of Council, then RAC. My and CPAC's Delegation focused on the sloppy, incoherent sampling methodology spread over several years used by the Ministry of Environment in their "investigation" of the downstream Canagagigue Creek.

Louis Almeida of GHD (Chemtura's consultants) acknowledged that there are still concerns with the reissued off-site East Side Work Plan and the lack of either soil or groundwater sampling in the area known as the "Gap". RAC have also criticized the lack of sampling in the Gap area as well as TAG and CPAC. Finally access to the Stroh property has become an issue. Mr. Almeida claims that the M.O.E. will issue an order for access if it is not soon forthcoming.

Jason Rice of the M.O.E. while obstinate and close minded still is no Terri Buhlman in that department. He advised that the M.O.E. will not revise or reissue the inaccurate Bulletin they handed out last spring to downstream Canagagigue Creek residents. Shame on them. The Ministry are also clearly trying to narrow the total downstream investigation to but two small areas namely Station #20 & #21. RAC passed a Motion condemning the M.O.E.'s May 2016 Bulletin and called it "misleading". It was noted that TAG are also upset with the M.O.E.'s narrow focus on only two spots in the creek. Clearly the M.O.E., one way or the other, are bought and paid for by Chemtura and their interests.

Susan Bryant pointed out that another report by the M.O.E. regarding a soil survey for Dioxins west and north of Station #21 was confusing. In this report, despite many other Dioxin criteria used in Canada and Ontario, the M.O.E. are now suggesting that the defining criteria is 48 pg/g TEQ or 48 parts per trillion (ppt). There are both lower and higher criteria although the 21.5 ppt and 36 ppt formerly used would seem more appropriate.

Again the English/Wabigoon river system through the Grassy Narrows area was raised. This was also in relation to the M.O.E.'s nonsense that a hard criteria alone regarding sediment concentrations of toxic chemicals is not enough to predict biological effects. Dr. Richard Jackson is not buying that nor are I believe any other citizens.

It sounds as if two more reports are coming from the M.O.E. regarding the creek. One is an Ecological Risk Assessment due by the end of February however raw data may be available sooner. The other report is yet another creek sediment sampling Work Plan. Based on the M.O.E.'s history of deception, stalling and misdirection it's difficult to believe that either of these will be more than further efforts to minimize Chemtura's downstream cleanup efforts. Isn't it grand that citizens' taxes are supporting our local world class polluter, soon to be known as Lanxess.

Dr. Jackson's theory and calculations regarding Aquitard diffusion of NDMA and Chlorobenzene back into the Elmira Aquifers has after many months not been disputed by any parties. Louis Almeida (GHD) has not so subtly stated that Chemtura will develop a Workplan for the creek based upon "the areas the MOECC has highlighted." Isn't that cute how one hand washes the other? How one guilty party to the environmental crisis supports the other guilty party? Afterall it's all in the family.

Dr. Jackson again pointed out that two new TAG members will be appointed to be RAC representatives. This is important but will certainly have the two current "control freaks" in a tizzy.

There is supposed to be from now on a Township Media Release on these matters distributed to the media as well as put on the Township website. I believe it is on the Township website under News or News reports. This is an excellent idea if it is followed through. The next RAC meeting is March 9/17 4 pm. and the next two TAG meetings are February 2 & 16/17 at 6:30 pm. all in Woolwich Council Chambers.

THE TRUTH IS GETTING OUT

Yesterday's Waterloo Region Record carries the following article on page B1 namely "Local politics in Waterloo Region from a to Z". Guess what is the third entry ie. C ? You've got it. It's Chemtura. What an excellent write up castigating the powers to be for only recently recognizing chemical contamination has migrated eastwards off the Chemtura site onto a neighbour's farm. The article states "this is the first acknowledgement contamination may have migrated east of the site.". The fact that it took nearly thirty years and that it was yours truly and CPAC who first announced this issue is doubly damning to the Ontario Ministry of Environment, Chemtura and Conestoga Rovers their consultants.

TOMORROW IS CHRISTMAS !

MERRY CHRISTMAS & A HAPPY NEW YEAR TO ALL

CHEMTURA NOVEMBER 2016 PROGRESS REPORT

All off-site pumping wells successfully achieved their pumping target rates. Of course those target pumping rates have as yet not been adjusted upwards either double or triple as promised. We await.

Concerning the MISA (Municipal Industrial Strategy for Abatement) outlets on the Chemtura site which discharge into the Canagagigue Creek we do see that Lindane concentrations are decreasing for MISA outlet 0400 and MISA SWS. Aniline is decreasing as well in its' concentrations as it discharges from MISA SWS. Other than that most contaminants have no trend, either increasing or decreasing.

There is a slight change in surface water (Canagagigue) sampling results and it is for the worse. BEHP has for a long while actually been higher upstream coming onto the site than downstream as it leaves the site. Toluene of course has a statistically higher concentration on average as it leaves the site versus as it enters from upstream. The change appears to be in m& p xylenes. They now have a higher average concentration downstream than upstream indicating additions from the Chemtura site. Nice work guys.

I view this as typical glacial progress. Two steps forward and one back. 2050 or later and the site and creek will still be a toxic mess but hopefully the Elmira Aquifers will be close to drinkable. That is until the power goes off and or Chemtura (Lanxess) abandon the site. Then everything on-site will continue leaking off-site without even partial containment.

FOUR YEARS AND STILL WAITING

This is what the Elmira "cleanup" is all about. Four and a half years ago CPAC advised Woolwich Township and the public that Chemtura and the Ministry of Environment promises to clean up the Elmira Aquifers by 2028 were nonsense. We made it clear that the current method (hydraulic containment) ie. pump & treat just wasn't going to do the job. Initially Chemtura and the M.O.E. vehemently denied our conclusions. However then Chemtura and CRA announced in November 2012 that they were going to both triple the volume of off-site pumping AND use In Situ Chemical Oxidation (ISCO) in some of the hot spots. Over four years later and we are still waiting.

ISCO has been tested with trial runs. They were done poorly somewhat similar to the entire cleanup to date. Dr. Jackson, former TAG Chair has advised Chemtura and now GHD who they need to consult on that matter. More pumping wells have been dug, others replaced (W3R), treatment systems enhanced, right of ways negotiated and permits granted. Over four years later and no tripling of the volume of groundwater pumped and treated. Oh by the way they also changed their tune during the last four years. Now they are only promising to double the pumping rates and volumes. We await....patiently.

In the interim even Chemtura are now admitting the unliklihood of coming even close to a 2028 cleanup even with their so called improvements (greater pumping). The M.O.E. also acknowledge the obvious. Perhaps by 2048...if we're lucky. Keep on making profits Chemtura (Lanxess?).

IS THE MUNICIPAL ELECTION OVERSIGHT PROCESS LEGITIMATE?

To date the answer is a clear no. The oversight process through the Municipal Elections Act has been captured by our local politicians. On paper and in principle alone there are issues. Afterall relying on watchdog citizens to firstly find errors, omissions and downright falsehoods in the submitted Financial Statements of candidates is unlikely. The proof of that is in the blatantcy and outright crassness of the three cases here in Woolwich Township during the last municipal election in October 2014. That two senior, longtime politicians would pull what they did was way beyond embarassing. That the new boy on the block, Scott Hahn, would avoid claiming thousands of dollars in sign and brochure costs because he thought that as they were donated to him he didn't have to, is frankly incredible. That he then, despite ample opportunities to receive advice and assistance, failed to include them at all in his Financial Statements is beyond negligent. That the Municipal Clerk signed off on his Financial Statement frankly is mind boggling. Didn't she even ask him about sign costs?

Once we get by the necessity of vigilance amongst citizens necessary to initiate the process is the problem of who appoints the Municipal Election Compliance Audit Committee (MECAC). My understanding is that it is the Municipal Clerks from all the cities and townships here in Waterloo Region. Keep in mind that each and every Clerk is beholden to their own municipality for their job. Then they are expected to appoint honest, aggressive and well informed individuals to determine contraventions of the Municipal Elections Act (MEA). Sure these Clerks are going to appoint people who are willing to publicly criticize and possibly remove various wayward councillors who not only can demand the local Clerk's job but also the CAO's job who is technically the Clerk's supervisor.

In our case our MECAC included former politicians such as Grace Sudden and Carl Zehr. Grace was both a municipal councillor and later a regional councillor. How likely is she to crap upon current Woolwich councillors? Apparently not very based on her decisions at MECAC. Also keep in mind based upon the sandy Shantz case, sandy was both the Woolwich mayor and a regional councillor while this regional committee (MECAC) was deciding her fate. No surprise they let her walk despite overwhelming omissions, errors and contraventions.

Then there are the mechanics, hoops and loops and time consuming court appearances necessary for citizens to pursue these cases. The judicial system is far less then citizen friendly or timely. Frankly it is a disgusting charade of justice and competentcy. In my opinion it is intentionally slow, devious, unclear and unfriendly.

Despite all this I have as yet not given up. All it takes is one good, honest and professional person in a position of authority to make a difference. We shall soon see if that person will proceed and do their duty.

BACK & FORTH COMMENTS BETWEEN CHEMTURA & THE M.O.E. DELAY ACTION

The collusion and back scratching are so ingrained that I no longer believe anything the Ministry of Environment say. Even when they "comment" on a Chemtura/GHD report and make suggestions that appear to be improvements I find myself looking for ulterior motives. I mean afterall they've burned their credibility to cinders long ago.

On December 13/16 Louis Almeida of GHD responded to M.O.E. comments regarding the 2016 Draft Off-Site Investigation Work Plan. It seems to me that to date this badly abused stakeholder, courtesy of an intentionally corrupt process, has not received all of these M.O.E. comments. The ones from M.O.E. hydrogeologist, Cynthia Doughty yes, others no.

The M.O.E. are suggesting that soil sampling should occur not just on a line 3 and 9 metres parallel to the property line between Chemtura and the Stroh farm but also within a meter of the property line. More soil samples is good but GHD are saying no. Then the M.O.E. make a totally asinine suggestion; one that I've seen before. Basically they suggest that if the 1 metre or less samples are non-detect then collected samples at 3 and 9 metres don't need to be analysed. This appears to be assuming, incorrectly, that the toxic contaminants have run in a perfectly straight line due east from the Chemtura property onto the Stroh farm. GHD actually reject this suggestion as well. Remind me again, who are the good guys and who the bad?

GHD are also proposing some test pits at the locations of their proposed off-site monitoring wells. They are attempting to delineate the extent of soil contamination emanating from Chemtura's east side pits. As previously indicated the number of parameters to be tested is inadequate.

There is a major bone of contention regarding test pit TP07-16 which was part of the Supplementary On-Site investigation near the eastern property line. The M.O.E. want this soil contamination delineated because many of the multiple parameters exceed the soil leaching guidelines. First off I'm not terribly impressed with these soil leaching guidleines in the first place. They seem to have been parachuted into the discussion after thirty years, right out of the blue. Secondly even though their exceedances have been mentioned as well in Cynthia Doughty's comments, GHD are simply denying those exceedances. WTF?

The M.O.E. want more parameters than Dioxins and DDT tested for east of monitoring well OW38-5(R). Dunh more parameters should be tested for at all the locations! GHD of course are saying no.

On page 6 GHD admit that their assumption is that the extent of off-site groundwater contamination is limited. They then state "If this is correct, the approach outlined in the work plan is appropriate and will provide the delineation described above.". O.K. so does that mean that if GHD's assumption is wrong then their work plan is inadequate?

And on and on. Is all of this back and forth actually improving the Work Plan? I don't see it. What I see are folks going through the motions, playing to the audience. I see two equally culpable parties delaying and game playing.

ERRORS IN CREEK SAMPLING

At the last RAC (Remediation Advisory Committee) public meeting on December 8/16 I spoke as a Delegate regarding the failures in sampling that would negatively affect our understanding of the extent and distribution of toxic contaminants in the creek. I spoke to both sampling biases in regards to parameters examined both over time and at various locations in the creek. I also spoke regarding what I viewed as location biases. My focus was on Persistent Organic Pollutants (POPs) not dissolved solvents. These POPs include of course Dioxins/Furans, DDT, PCBs and many pesticides.

It was clear to me that the Ontario Ministry of Environment had been indulging in sampling that would minimize the numbers of areas requiring remediation both by under sampling most if not all of the further downstream areas as well as by under sampling many of the different POPs that are in the creek. For example if you have ten different toxic POPs but only regularily sample two of them (Dioxins/Furans & DDT) than guess what: you are going to be focused on those two where you find them both at high concentrations and more often and only remediating their locations while ignoring lower concentrations of Dioxins/Furans & DDT that may also however have a multitude of other highly toxic POPs together.

Both further downstream creek sediment sites ( #22 & #23) as well as all the downstream floodplain soil sampling sites have been greatly under sampled since 2012. I have had discussions with a PHD in Biology who has explained the technical terms regarding sources of error in sampling. Some are relevant to my comments at RAC others less so.

There are technical errors with the equipment, sampling errors within the medium being sampled, geographic errors in that large variations in concentrations can be very close together and finally temporal errors ie. significant changes in concentration based upon seasonal factors. I would suggest that the last three errors are most relevant to these discussions. Overall these errors can be either minimized or at least put in perspective via multiple sampling events versus what has been done in the creek. Intentionally only sampling sites that first give you high concentrations guarantees that over time you will have higher concentrations at those same sites versus further downstream sites that have been essentially ignored. The Ministry "investigation" of the Canagagigue Creek has been biased and unscientific from the start. Take your pick: incompetence or bias in favour of finding fewer problems.

INDUSTRIAL LANDS EQUAL SOIL & GROUNDWATER CONTAMINATION

Today's posting is mostly a comment about how times and perceptions have changed. The Waterloo Region Record carried an Opinion piece yesterday from Luisa D'Amato titled "Multiplex report is the best gift ever". There are two references in her Opinion piece that really grabbed my eye. Twice she refers to "the land has previously been used for industrial purposes" and then "the ...site is on clean land (ie. not used for industrial purposes)". She then goes on to explain that the cost of cleanup of former industrial lands could be prohibitive.

I and many others involved in industrial pollution and contaminated soils and groundwater have long been aware of the propensity for many of our former Region of Waterloo area industrial and manufacturing operations to have given less than lip service to sustainable production. To this day the likes of Jeff Merriman (retired) and Chemtura (Uniroyal) like to claim that in ground, uncontained toxic waste disposal in the 50s, 60s and early 70s was the way that things were done. Yes it was but everybody with half a brain knew that they were saving money on proper waste disposal while buggering their neighbour's and downstream residents.

Therefore to have knowledge of past polluting manufacturing being likely sources of serious environmental contamination is a wonderful thing. Luisa while knowledgable in a number of fields, to my knowledge, has not been involved at the Record with contaminated sites etc.. Therefore perhaps that manufacturing (especially past) is equated with pollution is a good thing and demonstrates an ever growing knowledge base.

NESTLE WANTS TO "PARTNER" WITH CENTRE WELLINGTON

Yesterday's Waterloo Region Record carried this story titled "Nestle wants to "partner" with township on well it purchased". Nestle's had representatives attend the latest Centre Wellington Council meeting where they spoke to partnering with Centre Wellington regarding the well they purchased on Middlebrook Road. The Mayor while open to discussions is appropriately skeptical. Currently Nestle can't move ahead as the provincial government has a moratorium in place due to the horrific negative publicity over this well and its' repercussions for the government. Afterall essentially giving away public resources (water) for the financial benefit of corporations does not sit well with voters already incensed with the provincial Liberal government.

Currently studies are underway to determine the future water needs for Centre Wellington. Obviously the Middlebrook well could have an impact if it was available. Nestle's have been vague in the extreme at the moment as to what they are actually proposing as a partnership. It could be for real or it could mostly be fr public relations. hard to say but worth listening to.

BELATED M.O.E. ANNUAL MONITORING REPORT COMMENTS

The report is dated December 12/16 and it covers the Ministry of the Environment's comments for both the 2014 and 2015 AMR (Annual Monitoring Report). This report actually encompasses the responses from Chemtura/GHD and they are the ones who've sent it out. I know, we are all of what, two weeks away from 2017. Getting anything on a timely basis seems impossible for these folks.

On page 2 we are advised that there is a loss of hydraulic containment in the Upper Aquifer "almost every spring, however, exceptional weather conditions in 2014 prolonged the effect.". For the record "exceptional weather conditions" are becoming the norm. It's called climate change.

We are also advised (pg. 3) that "bank storage" effects which are the cause for the above mentioned loss of hydraulic containment also contribute to "flushing" of contaminants from the creekbank areas, into the creek. Isn't that just grand? Hence GHD are stating that temporary losses of Upper Aquifer containment now are no big deal because contaminant concentrations in the area have been reduced due to past "flushing" into the creek.

On page 6 we learn that among other things GHD has a typo when they state (once) that the Drinking Water Standard for chlorobenzene is 180 ug/l. It is 80 ug/l. Also we learn that west of the Chemtura site, similar to most areas, the limiting factor to cleanup is NDMA because of its' extremely low drinking water standard.

Page 10 has a discussion of DNAPL presence in and around the Main Tank Farm (MTF) on the Chemtura site. Jaimie Connelly of the M.O.E. appropriately advises GHD that their simple criteria of groundwater concentrations of contaminants being less than 1% of the pure aqueous solubility of the contaminant proving a lack of DNAPL presence, is grossly inadequate. GHD took offense and denied DNAPL's presence without admitting that Jaimie's comments were dead on the money. GHD also used as part of their backup that the M.O.E. had concurred with them. Odd but Jaimie is the M.O.E.'s chief hydrogeologist and clearly he's not convinced.

MORE REGARDING THE REVISED OFF-SITE INVESTIGATION WORK PLAN

On page 2 of this November 23/16 report we have an admission that contaminated groundwater could be captured by the Stroh Drain. The report also suggests that surface water flowing across Chemtura's eastern border could also be captured by the Stroh Drain. There are a couple of issues however. Firstly they use a lot of ifs as in if there is contaminated groundwater and if surface water flowed across the eastern site border. This is typical consultant and Chemtura stalling and delay. In other words reinvent the wheel each and every time. Never build upon already proven facts as these are. Also I note GHD's failure to use the same terminology as everybody else. The manmade ditch is called the Stroh Drain. It is not a drain, a tilebed , a swale or anything else.

The top of Page 3 refers to one outlier in regards to groundwater sampling. Further down they reference three different monitoring wells with concentrations exceeding their respective Ontario Drinking Water Standards. Well OW36-5 is not an outlier. Also allegedly the source of contaminants to well OW 36-5 is impacted fill. So what exactly? The entire area is one former uncontained series of waste pits and holes in the ground. Where are you not going to find impacted soil, impacted fill and or highly contaminated soil and groundwater? Yes there have been excavations and re-excavations on the east side.

GHD also claim that the Supplementary test pits produced a pattern of decreasing concentrations to the east towards the property line with the Stroh farm. Just more nonsense. There is no such pattern.

The parameters to be tested for in this tiny investigation of the Stroh farm include Dioxins/Furans and DDT. Sometimes. As limited as those parameters are it's only some of the test pits that will be investigated for both. Are you kidding me? The rationale is based upon past testing results on the Chemtura side of the border. If Dioxins exceeded the criteria then the alleged corresponding test pit off-site will only be tested for Dioxins as well. This is beyond asinine.

Page 8 has the same nonsense as was described in the preceding paragraph. Basically off-site wells will only be tested for the parameters that were found on the supposedly corresponding on-site wells. This is ridiculous and an obvious attempt at restricting detected parameters by minimizing the number of parameters beforehand.

This "investigation" follows all the tried and true deceptions and gamesmanship that has successfully been pulled for the last thirty years on this site. When will citizens ever get honest brokers in charge of these investigations and cleanups?

CHEMTURA'S NEW CLIENT DRIVEN CONSULTANTS CARRY THE TORCH

Same old. Same old. Even Mr. Flip Flop, Mark Bauman, has publicly advised Chemtura and GHD that their investigation will have no credibility if they do not sample the "Gap" area which is an approximate 175 metre stretch between Chemtura and the Stroh farm. GHD's "Revised Off-Site Investigation Work Plan" came out on November 23/16. I received a copy last evening exactly nineteen days later and precisely four days after the RAC meeting of December 8/16. This also is same old, same old. It makes timely discussion of issues and problems even more impossible than simply refusing CPAC members and citizens the right to publicly ask Chemtura questions at RAC or TAG meetings.

So regarding the "Gap" area here is what we have. The new off-site investigation has composite surficial soil samples predetermined at five locations just south of the cemetery on Arthur St. (Hwy #86) down to the former on-site investigation sampling areas of SS07 & SS08. The former on-site investigation had an SS09 immediately south of SS08 . Even this SS09 location was too far north to encompass the crucial "Gap" area. Hence GHD on behalf of Chemtura have totally refused to extend sampling further south where we feel the bulk of overland flow of contaminated waste waters flowed. They have thrown us a bone however. They have positively, absolutely committed to ... nothing. On page 6 they state that they will inspect areas to the east of SS09. Their Figure 3.1 however indicates an "Area of Inspection" that is both east and south of SS09. Then they commit to sampling "up to three additional" soil samples. In other words that could be one, two, three or zero "where, based on field observations, surface water is anticipated to flow or pond.". Gee based upon my observations today I will commit to sending Chemtura a cheque for up to three million dollars, subject to where I feel the current snowfall is going to accumulate on my property.

There is much more nonsense in this report including a lack of testing for all appropriate parameters. So Councillor Bauman as you received this report prior to the last RAC meeting why didn't you call them on their lack of commitment to sampling the "Gap" area? Are these reports just a little too tough for you? Meanwhile Susan Bryant advised at the RAC meeting that there is sampling scheduled at the north end of the "Gap" area. That is incorrect and suggests that she failed to put Figure 3.1 from this new report beside a better map showing where the Stroh Drain begins which is at the south end of the SS09 composite sampling area. There is absolutely no commitment to sample the "Gap" area whatsoever.

CRUNCH TIME FOR MUNICIPAL ELECTION ACT CHARGES

Numerous witnesses have been contacted and resulting documentation has been sent to the out of town, conflict of interest prosecutor. His deadline for this information is this coming Friday. That will give him several days to fully understand the fact that there is concrete professional evidence of serious contraventions of the MEA (Municipal Elections Act) by Councillor Scott Hahn as stated in the August 11/15 Forensic Audit produced by Froese Forensic Partners. It will also allow him to realize that this is by no means a one man show. Numerous Woolwich citizens have been involved with examining these contraventions of the MEA and furthermore been shocked by the stickhandling and improper behaviour displayed both by individuals, private citizens and a number of our local politicians and Woolwich Staff. This to me speaks loudly in regards to "public interest". Allowing Mr. Hahn's egregious and multiple contraventions to slide by without proper accountability is serious enough. Allowing the process of MECAC and legal accountability to be subverted and or circumvented via either tricks, gamesmanship, politicking or outright illegal behaviour is reprehensible and must be addressed. Keep in mind that while the Forensic Audit unequivocally called out the many contraventions of the MEA, the Auditors were somewhat subtle in regards to alleged illegal behaviour designed to mask, cover up or justify some of these contraventions.

To my mind the production of receipts and invoices late in the day that absolutely could not be verified through appropriate paper trails was stunning. The Auditor pursued them via computer records at the corporate end as well as through private bank accounts at the individuals' end. There simply was no proper and appropriate records of this documentation which is another offence (section #69) in it's own right. If the courts were to determine that these receipts or invoices were produced long after the fact and were produced for improper and or self-serving purposes; then this case could become more serious. It is also possible that the courts might have some words of censure for MECAC who refused to send on the Scott Hahn case to the courts. Myself and others believe that MECAC overstepped their authority as well as failed in their duty to follow the intent of the MEA. The actual public announcement of the prosecutor's decision to proceed with these charges or not will be on January 25, 2017 9 am. at Provincial Offences Court, 77 Queen St. Courtroom #101, Kitchener, Ontario.

CHEMTURA'S CLEANUP DELAYS MORE THAN $$$ ? DEFLATING LIABILITIES $$ CRUCIAL?

Certainly delay is a potent weapon used by polluters and their friends in high places. It combined with decades of technical reports tends to weed out serious objectors and citizen activists. This then allows companies to more easily sell their version of reality. Since the Elmira water crisis began in 1989 Uniroyal Chemical has become Crompton, and then Chemtura. Now on the horizon is the possibility of yet another change in ownership to Lanxess of Germany.

I have long felt that $250-350 Million would go a long ways towards some serious source removal on the Chemtura site. This would entail contaminated soil removal as well as free phase and residual DNAPL removal beneath the west side retention ponds namely RPW-1 & 2 in the north and RPW-3, 4, 5, 6, 7, 8 further south. Of course the allegedly incapable of removal to date pool of LNAPL floating on top of the water table, originally from Building #15, could also finally be removed. Then on the east side we also have the retention pits RPE-1,2,3,4,& 5. Here we also have had work done over the decades albeit never deep enough or beneath the pits where DNAPLS have found a home. Some of the nasty results of these pits are just now being discovered via East Side Investigations which include test pits, soil samples and more groundwater sampling.

Only since the waning days (2014) of the best Council appointed CPAC (Chemtura Public Advisory Committee) ever have we learned of the extent of Uniroyal/Chemtura damage off-site to the east. We've all known of the damage to the Elmira aquifers west and south of the Chemtura site. Yes we did know that at one time the Canagagigue Creek was devoid of life. Not just fish, frogs, clams etc. but everything. Since the advent of both the Elmira Sewage Treatment Plant as well as the Upper Aquifer Containment & Treatment System (UACTS), discharge of dissolved chlorophenols and other solvents has been greatly reduced and life has returned to the creek. Since 2012 we have learned unfortunately that Persistent Organic Pollutants (POPs) are still in the creek sediments as well as Floodplain Soils.

Efforts were made both to stabilize the creekbanks on the west side only, as well as to remove certain highly contaminated, with Dioxins and DDT, creekbank soils. Again these excavations were solely on the west side of the creek. It's almost as if Uniroyal and their successors were aware of some sort of already in place containment or bypass on the east side. The previously mentioned UACTS is a series of pumping wells in Chemtura's south-west corner only. APT Environment left UPAC (Uniroyal Public Advisory Committee) in June of 1994 over their refusal to hydraulically contain the rest of the creek including the entire east side. Once again it's almost as if Chemtura and Conestoga Rovers had knowledge of some already, surreptitious, containment and or east side groundwater by-pass system in place.

The Ontario Ministry of the Environment have now conducted sampling primarily in the creek sediments in 2012, 2013, 2014 and 2015. We did get a hint two days ago (RAC meeting) of some new sampling that may have taken place this past summer. The results are often above the multitude of various criteria for creek sediments as well as Floodplain Soils when sampled. Dioxins and DDT lead the charge for criteria exceedances although the multitude of other contaminants includes mercury, PCBs, Lindane, Endosulphan, Endrin, Aldrin and so much more.

We also have solvents, PCBs, Dioxins/Furans and DDT found in test pits both along the eastern property line as well as in nine test pits mostly east of RPE-5. Soil samples as well as groundwater in this area beside the Stroh farm are highly contaminated. Chemtura and their consultants (GHD) appear extraordinarily reluctant to proceed with ordered soil and groundwater testing on the Stroh farm itself. Excuses include waiting for crops to be removed as well as problems receiving access permission. They have also to date studiously avoided soil and groundwater testing in the areas I refer to as the "Gap" and the "Sink". They are just off Chemtura's South-east property line on the Stroh property in and around where the Stroh Drain runs parallel to the property line for about 175 metres.

There is evidence, as only slightly subtly referred to earlier, of some sort of containment system for the east side. This has never been admitted to by Uniroyal or Chemtura. Satellite maps show what appears to be a manmade structure between the east side pits and the creek which runs southwards and then eastwards crossing over to the Stroh property just below (south) RPE-5. Coincidentally due south perhaps a hundred metres away is an outlet pipe running north to south which discharges into the top end of the Stroh Drain. This discharge pipe could be groundwater from field tile on the Stroh property, contaminated groundwater from the Chemtura property or a combination of both. I believe that the satellite images show some sort of Interceptor Trench designed to collect contaminated groundwater coming from the east side pits and preventing it from discharging naturally westwards into the Canagagigue Creek on the Chemtura property. This collected contaminated groundwater is possibly then being redirected via gravity flow southwards and eastwards onto their neighbour's property into the Stroh Drain where it eventually winds its' way eventually into the Canagagigue Creek much further downstream.

Where is the Ontario M.O.E., currently called the MOECC, in all of this? Basically up to their corrupt eyeballs. If they don't know exactly what's going on with the Stroh farm next door it's because they don't want to know. George Karlos of the M.O.E., both verbally and then in writing publicly stated in 2013 that he had personally walked the south-east corner of Chemtura over to the Martin swimming pond east and further south and that there was no reasonable pathway for contaminants from Chemtura's east side to get into the pond. A year later I walked the same area and discovered the Stroh Drain which had been kept secret form UPAC, CPAC and the public for three decades. Later on I and a current TAG member (Sebastian) confirmed that indeed there was a pipe diverting a small amount of the Stroh Drain water directly into the Martin swimming pond. How can we not believe that the M.O.E. have been enabling Chemtura's deception for a very long time?

Will these chickens come home to roost before or after Chemtura is sold to Lanxess? Will Lanxess shareholders be made privy to these further immense financial liabilities prior to any purchase decision? Granted I'm no accountant but I believe that $250 - 350 Million is needed to clean up on site and perhaps another $200 Million off-site for the Stroh, Martin and downstream Canagagigue Creek. Buyer beware folks.

KUDOS TO RAC WITH A DASH OF HYPOCRISY ON THE SIDE

I've had many nice things to say about TAG (Technical Advisory Group) here in the Advocate but not so much for RAC. Well yesterday afternoon and early evening is going to change that. They passed a couple of Motions unanimously in an attempt to put pressure on the Ministry of Environment as well as on Chemtura Canada. Some of the more aggressive RAC members towards Chemtura and the M.O.E., hypocritically were Pat Mclean, Susan Bryant and he of the forked tongue, Mark Bauman. Wow how their tune has changed from the April 9, 2015 pretend stakeholders meeting. It's as if after nearly thirty years they've discovered what slimy, dishonest actors Chemtura and the Ontario Ministry of Environment really are. Turns out that CPAC aren't the only ones fed up with the lying, deceit, misrepresentation and manipulation surrounding the remediation efforts in and downstream of Elmira.

First non-shocker. Turns out the claim that Chemtura and their consultants GHD would get access to the Stroh property this fall after the crop was off was untrue. Firstly there are no crops in the southern area including the "Gap", the Stroh Drain and the "Sink". Secondly in the more northerly direction the crops are off yet allegedly Mr. Stroh has refused access to date. This will set back soil testing and groundwater well installations and testing close to six months. Winter is a much more difficult time to be traversing wetlands, creeks and Drains. Mark Bauman suggested that Chemtura may have to rent the land from Stroh in order to ensure access next spring and summer.

This stakeholder has as yet not received the most updated East Side Work Plan. RAC, TAG and allegedly Council have. Nice public consultation there Sandy and Chemtura when a nearly thirty year active stakeholder is being denied technical documents. Susan Bryant advised that the updated plan is only going to be soil testing a little bit of the northern part of the "Gap". Chemtura and GHD continue to hide from the truth.

Two interesting comments from she who has supported Chemtura's winning *Responsible Care verification in the past (and who knows maybe again recently-local reps names have been kept hush hush). Firstly Pat McLean advised Louis Almeida of GHD that he and they don't have their ducks in a row regarding access to the Stroh property for testing. Even more surprising she publicly stated that she agreed with everything in Mr. Marshall's (moi) Delegation regarding the downstream Canagagigue Creek. Yes my comments were decisive, definitive and accurate but after pulling Pat's knife out of my back several years ago (2007-08) I tend not to turn my back on either her or Susan Bryant. I'm not sure how to interpret her remarks. Perhaps a truce while we battle Chemtura's downstream gamesmanship?

Jason Rice of the M.O.E. categorically stated that they would not revise or reissue the Bulletin that they gave residents along the downstream Canagagigue Creek last May. He did hold forth an olive branch however by suggesting that the next Bulletin would be sent to RAC & TAG first for their input. Pat Mclean blasted him on that and indicated the Motion that TAG had passed advising that the M.O.E.'s May Bulletin was inaccurate regarding allegedly lower Dioxin concentrations in recent times. Dr. Dick Jackson also strongly criticized the Ministry's Bulletin by stating that "The Bulletin wasn't correct in May and it certainly isn't correct after the 2014/2015 data. The M.O.E. Bulletin is misleading.".

Dr. Jackson laid it out starkly for RAC and the public regarding the Ontario Ministry of Environment's absolute failures in cleaning up grossly contaminated sites affecting both wildlife and human life. He pointed out the Mercury contamination in Grassy Narrows, part of the English-Wabigoon River systems. He mentioned the recent Globe & Mail Editorial and the failure to do the right thing. He suggested that our Ontario M.O.E. are still guided by the old industry line that dredging of sediments makes things worse by mobilizing contaminants. The U.S. EPA finally got tough with General Electric and has forced them to dredge the Upper Hudson River to remove their contaminants. Dick stated that Jason Rice's (M.O.E.) opinion that hard sediment criteria isn't appropriate is completely wrong. The M.O.E.'s plan is a Risk Assessment (HHRA) to which Dr. Jackson stated "Risk Assessment's have lead nowhere in the past.".
No doubt this is why Industry and Chemtura favour them.

While Jason and the M.O.E. believe that sediment chemistry results are merely screening tools, Dr. Jackson has also pointed out that they are fully accepted at face value in both Vietnam and the U.S.. They stop the gamesmanship and long term stickhandling by industries to avoid doing necessary cleanups. They eliminate a plethora of unnecessary, time consuming, speculative and subjective risk assessments done by client driven toxicologists and worse.

Nancy Davy of the GRCA responded to a question regarding GRCA approvals necessary for work in the creek. She advised that the GRCA would be supportive of such remediation work with only routine conditions necessary for their approvals.

The meeting switched from the creek to the Elmira Aquifers. Dr. Jackson (Dick) further elaborated on his earlier comments regarding back diffusion from the relatively impermeable Aquitards (clay & silt) into the more permeable Aquifers (sand & gravel). He advised that there are No proven remediation strategies for Aquitards. The rate limiting effect is the Aquitards as they can only diffuse slowly back into the Aquifers as the aquifer concentrations are greatly reduced. He also advised that he has never come across an Aquifer where the Drinking Water Standard was in parts per trillion. This is a thousand times lower than most organic chemical Drinking Water Standards such as Chlorobenzene at 80 parts per billion (ppb) versus NDMA at 9 parts per trillion (ppt). Dr. Jackson believes that NDMA was diffused into the Aquitards from the Aquifers over a period of fifty years approximately 1943-1993 and that it may well take fifty years to fully reverse that (ie. 1993-2043) or longer.

Anybody have any confidence left in Conestoga Rovers or Chemtura after that revelation?

The new Chair of TAG was named and introduced in person last evening. Her first name certainly is Tiffany and the best my ears could catch for a last name was Swenson/Svenson??? She was introduced I believe as a hydrologist working at Bluemetric in Kitchener. Obviously a little Google search will be underway very shortly. Dr. Jackson again mentioned that he expects that she will be naming two different TAG members to be on RAC shortly. Perhaps this has something to do with Pat & Susan's hardnosed, aggressive stance with Chemtura and the M.O.E. last night.

Sandy Shantz indicated that Woolwich Township staff were involved in planning a media strategy regarding moving things along. This strategy might include Media Releases being issued after RAC and TAG meetings which I believe is an excellent idea.

Helder Botello of Chemtura gave an update on the proposed buyout of Chemtura by a German firm namely Lanxess. It is still in the works and subject to regulatory and shareholder approval. Interestingly Lanxess have been dropping by the Elmira Advocate to learn a few things about Chemtura, their cleanup and residents' views of that.

The next tentative date for RAC is March 9/17 although that needs to be confirmed.

DRAFT RAC MINUTES FOR A SECOND TIME

Back in early October I posted here in regards to the Draft Minutes of the September 15/16 RAC (Remediation Advisory Committee) meeting. I've just recently reread them after having some difficulty finding them on the Township's new website. Lisa Schaefer (Woolwich Twp.) assisted me in finding them.

The second page of the Draft Minutes indicates that a pipe diverts part of the Stroh Drain and puts it directly into the downstream Martin swimming pond. This is beyond horrific and the only thing worse is that our authorities and public health care experts are not investigating.

Contrary to Mr. Almeida's (GHD) claim, soil conditions do not improve as you move east towards Mr. Stroh's property. That is wishful thinking combined with hopeless, self-serving optimism. GHD claim that they want to carefully inspect the Stroh Drain and determine where sediments and silts are accumulating. This is a good thing if they do follow through.

GHD's claims of a more comprehensive, holistic approach to the program of remediating the creek has a strong odour, taste and appearance of heavy duty bullshit. Based upon Chemtura's history this surprises no one.

The only suspended sediment transport study to date for the Canagagigue Creek was done by Stone and Haight in 1988. That would be Murray Haight of Elmira whom I wished a Merry Christmas to yesterday. The M.O.E. continue to fudge on doing another one.

Regarding the proposed HHRA (Human Health Risk Assessment) a member (possibly Susan?) stated that the community has zero to no faith in an HHRA. They also stated that "the community still has enormous cynicism about the HHRA process.". Furthermore "Part of it lies in the fact that for many years the community drank NDMA contaminated water and no epidemiological assessment was conducted. There is a disconnect between the standards that are set, such the Ontario Drinking Water Quality Standards, and human health effects.".

In Situ Chemical Oxidation (ISCO) was briefly mentioned as an alternative and additional remediation method. Yours truly presented a Delegation to the old CPAC back about 2008 pointing out the good results that occurred with ISCO in Cambridge as part of the Northstar Aerospace cleanup. My Delegation was ignored by Chemtura, M.O.E. and the old CPAC. No surprise and yet now they admit its' validity. Assholes!

RAC passed a couple of excellent Motions at this meeting including looking at a madia strategy once all the creek data is in. TAG and RAC both seem to be agreeing that the problem is not technical ones but a public policy one as in politics and politicians. Finally!

The M.O.E. claims that there are three downstream cow crossing structures. Further details are required as the one I've examined to date (New Jerusalem Rd.) is inadequate and indeed the cattle stir up the creek as well as drink directly from it after they've stirred it up. Unacceptable. Why would I believe on faith that the other two are any better?

See you at RAC at 4 pm. today in Council Chambers.

CPAC ARE A FORCE TO BE RECKONED WITH

What a damning indictment of the stupidity and bias of our local politicians. This includes our former mayor who decided to clean house in regards to CPAC (at that time the Chemtura Public Advisory Committee). While I agreed with him that they (CPAC) had gotten way off the track in regards to ground and surface water cleanup, nevertheless they had at least a few members who could have continued to do good things. This included Gerry Heideburt (air issues), possibly Ron Ormson (air), Ken Drieger and Sandra Baer. Subsequent events have made me realize my error in regards to Sandra Baer.

Similarily only worse has been the current Woolwich Council's dismissal and subsequent attempts to disparage and slander CPAC after the October 2014 election. Sandy and Mark either led the manufactured crisis whereby Chemtura and the M.O.E. boycotted CPAC or at the minimum they enabled it solely to give the two guilty parties a new, even more powerless, citizens group (TAG).

The Chemtura Public Advisory Committee has morphed into CPAC, the Citizens Public Advisory Committee. It consists of the old CPAC members from 2011-2015 plus their sub-committee SWAT. SWAT stands for Soil, Water, Air & Technical. Chemtura were unhappy about the designation SWAT. Tomorrow afternoon I will be speaking on behalf of CPAC as a Delegate to RAC. I will be discussing the last five studies of the Canagagigue Creek namely the 1995-96, 2012, 2013, 2014 and 2015 studies.

While past CPACs have had talented and technically competent members such as Dr. Henry Regier, myself, Ron Ormson and Gerry Heideburt, no CPAC has had the experience of the current one. Again we have Dr. Regier, myself, Ron Campbell (owner of Acute Environmental), Graham Chevreau (certified chemist), plus a half dozen other experienced members. This CPAC has set the ongoing Agenda with the focus on the uncontained east side of Chemtura plus the ongoing downstream Canagagigue Creek and its' ongoing contamination. Meanwhile the Council continue to exclude both CPAC and the public from actively taking part in discussions, debate and questioning of Chemtura, their consultants and the M.O.E.. Clearly Woolwich Council are still afraid of the truth and of the public's right to know it.

WELL WHY DIDN'T YOU SAY SO?

Yesterday's Waterloo Region Record carried the following story titled "Region awarded "Brownie" for LRT". Are you kidding me? Years after many Regional Councillors reversed their election positions in order to vote in favour of the LRT, angering many regional residents; now you tell us that it was all about the environment. Really?

This story written by Paige Desmond advises us that an organization of industries involved in environmental cleanups has named our LRT project the best large project in Canada. The group are known as the Brownfield Network and I must admit to knowing little about them. Allegedly according to regional staff in 2013 there are hundreds of brownfields (ie. contaminated former industrial/commercial sites) region wide and many are congregated along the downtowns and main corridors of the cities. Councillor Galloway mentioned the Breithaupt Block, the Barrel Yards and the Lang Tannery. While I was aware of the last two the Breithaupt Block was a bit of a surprise. My father retired from the Uniroyal plant on Breithaupt St. in 1980.

If indeed this is true and our regional councillors who moved heaven and earth to sell this project to skeptical residents actually were thinking about brownfield redevelopment; then I am pleasantly surprised. A little skeptical while also surprised. Why not tell us this a long time ago? Why not finally share with us the history of environmental contamination and all those responsible for it over the last 150 years? Why not share with us the extent of remediation that allegedly has been done over the last two years? In fact how about some documentation advising before and after soil concentrations of contaminants etc.? That would certainly back up your story now about all the good this LRT has done in cleaning up these previously mostly very quiet contaminated sites.

TAG NOVEMBER 17/16 DRAFT MINUTES

Yours truly posted here about this meeting on November 18, the day after the TAG meeting. Today's post is about the formal, albeit Draft Minutes of the meeting that have just been released.

TAG endorses both test pits along the south-east property line of Chemtura beside or on the Stroh farm as well as monitoring wells in this same area known as the "Gap". It is known as the "Gap" due to Chemtura's and GHD's willingness so far to conveniently avoid testing the area. It is the gap between the further north test pits and the ones right down at the extreme south end of their eastern property line.

Terri Buhlman of the M.O.E sent a letter on October 31/16 which TAG was unimpressed with. This included suddenly advising that their final report due October 31/16 would not be completed until February 28, 2017. Also the self-serving analysis of fish tissues will likely not include fatty areas or internal organs such as the liver which accumulate lipophilic and persistent toxins.

TAG also advised at their meeting that the claim by the M.O.E. that they had 20 different sites was "misleading" as in fact it was actually a number of samples taken at only four sites. TAG as well as myself and CPAC have both stated that the M.O.E. have failed to sample the same locations over the years and they have failed to conduct periodic suspended sediment sampling. Failing to do that makes it more difficult to prove that the contamination is indeed moving down the creek (moi-and probably being refreshed at the upstream end regularily). Finally TAG dispute the M.O.E.'s claim that Dioxin levels in the creek have been decreased substantially since the 1990s.

TAG strongly and formally advised the MOECC to revise their bulletin sent to downstream residents this past May due to its' claims of improving conditions in the creek.

TAG will be advising RAC that the creek exceeds the standards in a number of MOE Tables and hence that is a primary cause for concern. Also by their own definition of causing adverse effects in the Environmental Protection Act; remediation needs to be done in the creek.

Again in the Draft Minutes, Dr. Jackson has indicated that two new members of TAG will need to be determined to represent TAG at RAC meetings. My opinion is that Pat and Susan will scheme behind the scenes to try and keep themselves in that position, contrary to the Chair's (Dr. Jackson) plans.

A reminder that RAC will meet this Thursday at 4 pm. in Woolwich Council Chambers.

"CLIMATE LEADERS DON'T BUILD PIPELINES"

I've put the title above in quotes. The problem is I'm not sure who's the source. Possibly it's David Suzuki. Regardless I admit that I'm not convinced one way or the other. This week Prime Minister Trudeau announced rejection of one proposed pipeline and acceptance of another. I believe the rejected one was through British Columbia to deliver Alberta bitumen to the west coast for export. The go ahead pipeline I believe was from Alberta south to the United States. One of its' names is the Trans Mountain pipeline.

So if Mr. Suzuki and many more like minded groups from Sierra Legal, Council of Canadians, Friends of the Earth etc. are all against ANY new oil or gas pipelines; has Prime Minister Trudeau screwed up royally? I believe the Waterloo Region Record earlier this week commented on how the Green Party and the NDP say yes he did by approving the one new pipeline (to date) as the Conservative party also said that Mr. Trudeau screwed up however by refusing the one pipeline go ahead that he did. Therefore our Prime Minister has confidently seized the middle ground with the loyal opposition diametrically opposed to his position.

Sooooo the easy position to take is the typical Canadian middle of the road position which our governing Liberal Party are on. That said when I look at the actors involved from the Green Party, NDP, David Suzuki, Sierra, Council of Canadians etc. versus the Conservatives position for all pipelines and the Liberal position in favour of only some pipelines I'm starting to lean towards the no pipeline position. Almost everybody (except Trump & Canadian Conservatives) admits that the world must get off our petroleum addiction due to global warming and so many more environmental crises.

No the world cannot literally go cold turkey. But are we going to move away from petroleum and it's awful consequences so incredibly slowly that we are going to continue to build infrastructure for it? To me that doesn't seem to recognize the urgency of the world's crisis.

ONTARIANS ANGRY OVER BOTTLED WATER RULES

Today's Waterloo Region Record carries the following story titled "Wide support for action on bottled water plants". Basically it is informing us that more than 20,000 people (myself included) have responded to the government's proposed moratorium on water taking permits for new or expanded bottled water operations. The majority of responders are in favour of the ban.

Much credit must go to the Wellington Water Watchers in Guelph who brought this issue to the forefront. They have been fighting Nestle in regards to their Aberfoyle water takings for some time now. Then when they learned of Nestle's plans in regards to the Middleton Rd. well outside of Elora they really ramped up the pressure. The Elora area well it turned out had been on the radar of the municipality of Centre Wellington. Unfortunately they were much too slow in getting an offer in to the current owner.

Clearly with expected climate change issues that include both more floods and more droughts it makes sense for municipalities to secure our jointly owned water supplies first rather than let corporations tie up our groundwater for future profits. This essentially is what sand and gravel companies have been doing for decades. While the resource should be everybodies, private companies have been buying properties and then getting licences to extract gravel and sand even when they have no immediate market for their products. It's all about staking their claim before the next company.

ONGOING EFFORTS

I have been spending considerable time preparing my Delegation for next Thursday's RAC meeting. By the way that meeting is advertised in today's Woolwich Observer. Kudos to both Woolwich Township and the Observer for so publishing that public service announcement. Yesterday I sent my revised Draft off to CPAC members for any further comments or suggestions. The Ministry of Environment must also be given due where credit is due. Their ability to drag out second rate and unscientific sediment, floodplain soil (sort of) and tissue residue fish tests over a five year period is world class. Their inconsistent and incoherent sampling locations combined with their self-serving fish tissue residue protocols make possible trends nearly impossible to understand. All of this is after they were a party to a boycott of public consultation in Elmira from October 2014 until September 2015. They only went back to the table after their two local buddies were put back on the committee and their honest and appropriate critics removed. This can best be described as the stuff of legends. Perhaps other provincial ministries should be taking lessons from the Ontario M.O.E..

Regarding our ongoing 2014 municipal election scandals I can report progress. Witnesses who were unimpressed with both Woolwich Township manipulation and worse are stepping up. They are prepared to do their civic duty and are cooperating with the authorities. Needless to say this does not mean with Township authorities who have been part of the problem, not the solution. The private, in camera alleged "education meetings" for the Compliance Audit Committee (MECAC), conducted by the Township's law firm Smith-Valeriote was ridiculous at best and corruption at worst. As Woolwich Township are long time clients of Smith-Valeriote then clearly their law firm was in a conflict of interest position in giving legal advice to an "independent" committee investigating two members of Woolwich Council including their mayor.

THINGS HEATING UP ON THE SCOTT HAHN FRONT

At the request of the conflict of interest prosecutor, also known (to me at least) as the out of town prosecutor, I have been interviewing likely prosecution witnesses for a trial if it happens regarding the Municipal Elections Act (MEA) charges laid against Woolwich Councillor Scott Hahn. While I am certainly in the dark as to what is and what isn't appropriate to discuss publicly prior to Mr. Carnegie making his decision to go ahead with the charges or not; I have to use common sense and hope that is adequate. Therefore I will not be discussing here specific testimony that these witnesses have indicated to me that they are prepared to state under oath in a courtroom. Similarily while naming the potential Crown witnesses is probably not a good idea; I think all parties involved in the MECAC hearings have a pretty good idea who at least some of them will be.

Obviously the purpose of these interviews is to be able to send this testimony to Mr. Carnegie ahead of time for him to determine its' strength and relevance to the charges. Hopefully he will after learning of their proposed testimony then interview these witnesses himself, whether in person or by phone. I already have an in-person interview scheduled with Mr. Carnegie to discuss all things relevant to these MEA charges against Mr. Hahn. As Mr. Carnegie has advised that there will be no more Adjournments after the January 25/17 court date, obviously he will have his decision made prior to that regarding advancing or not. I have been advised that there are but two criteria namely 1) Can a conviction against the accused be achieved? and 2) Is it in the public interest to proceed on these charges? The first is a slam dunk thanks to the $12,000 Forensic Audit. The second I and several witnesses also believe is obvious. The charges and circumstances are both serious and repetitive. If the Ontario legislature did not feel that the multiple Sections of the MEA that Mr. Hahn has contravened were not in the public interest than they would not have written and enacted the legislation in the first place.

HAVE ELMIRA PROPERTY VALUES PLAYED INTO LOCAL ENVIRONMENTAL CLEANUP DECISIONS?

I've certainly stated that our local Woolwich Councils generally do not have much to be proud of in regards to the lack of full cleanup of the Uniroyal/Chemtura site here in Elmira. Recently at a TAG meeting it was suggested that certain environmental criteria are more likely to come into play when properties are being sold and titles transferred. It was also explained that this was because banks and mortgage holders would not lend money for the purchase of contaminated properties and their accompanying liabilities. At that point another TAG member suggested that the contaminated properties in the downstream floodplain may have not triggered cleanups because they are primarily owned by Old Order Mennonites who are less likely to sell and more likely to hand their farms down to their children.

Regarding property values in the rest of Elmira I was amazed back in the very early 90's that there seemed to be absolutely no effect on real estate prices. To this day I don't think anyone in Elmira has lost money due to any alleged property devaluation based upon Elmira's well known contamination, primarily from Uniroyal Chemical. Whether Council intervention and go slow (glacial) and quietly behaviour has assisted this or not I do not know. Whether Council's avoidance of confrontation of either Chemtura Canada and the Ministry of Environment has helped avoid property value losses I do not know. At the same time I do not believe the efforts of the last Council which were far less tolerant of Chemtura/M.O.E. behaviour, has in any way slowed property inflation. Our current Council took a symbolic and more action by posting warning signs along the creek. I don't believe that that in any way affected real estate prices in Elmira.

A friend and colleague here in Elmira, Richard Clausi, has often suggested that the only way to seriously get the majority of Elmira residents up in arms environmentally, would be if half of them woke up one morning to find the other half had died during the night courtesy of Chemtura fugitive air emissions. I suspect that it would take something similar to negatively affect property values and that is a good thing. It does not however excuse Woolwich Council's lack of action over the last thirty years. It seems, granted in hindsight, that property values are highly resistant to degradation based upon environmental factors, even serious ones.

UPCOMING LOCAL ENVIRONMENTAL DATES & VENUES

The title doesn't specify but I'm looking at upcoming environmental dates dealing with Chemtura Canada here in this posting. There are other ongoing local environmental issues including the Jigs Hollow Pit also known as the Kuntz Pit.

A week from this Thursday on December 8th at 4 pm. will be a public meeting of RAC (Remediation Advisory Committee). It will as usual be held in the Woolwich Council Chambers. Yours truly has advised the appropriate folks that I will be a Delegate on behalf of CPAC in regards to the Ministry of Environment's multiple Canagagigue Creek studies. This has been agreed to in principle by CPAC (Citizens Public Advisory Committee) hence I simply need to get a rough Draft of my words to them ahead of time for final O.K..

The next two TAG (Technical Advisory Group) meetings will be held in Woolwich Council Chambers (6:30 pm.) on January 19/17 and then on February 16/17. Dr. Jackson unfortunately will have retired by then and we will presumably meet the new Chairperson. While I have major forebodings I will say that Dr. Jackson did express confidence in the new person at the TAG meeting earlier this month.

Lastly we have recently been advised that the "final" M.O.E.C.C. Canagagigue Report will be available sometime in February 2017. While it would both be nice and appropriate to receive it at least a week or more before the February 16/16 TAG meeting; I won't hold my breathe. This report will allegedly be looking at fish tissue residues, bio-accumulation and will focus on the more recent (2014 & 2015 ?) creek sediment data. Based upon the inconsistent and unscientific sampling done from 2012-2015 I fail to see how any conclusions or recommendations made by the Ontario Ministry of Environment will be much more than self-serving or Chemtura Canada serving.

FOLLOWING UP ON YESTERDAY'S "SOURCE REMOVAL" POSTING

Chemtura are between a rock and a hard place technically and factually. However as Dr. Dick Jackson has clearly pointed out the bottlenecks and lack of cleanup are not technical issues, they are public policy issues. Public policy as in the people in positions of authority including politicians are unwilling or unable to do their jobs. This would include incompetence and general ignorance on the issues as well as relatively knowledgeable politicians who like their jobs and aren't willing to take career risks for the sake of either the environment or what they see as others human health. Even "professional" bureaucrats whether at the Region of Waterloo or the Grand River Conservation Authority (GRCA) are either indirectly controlled by municipal, regional or provincial politicians or they themselves such as voting GRCA members are career municipal politicians. The last thing career politicians ever wish to do is to alienate or antagonize powerful people and institutions. That is the quickest road to political suicide.

Here in Elmira, Ontario we have needed our local municipal Council to step up, confront the Ministry of Environment and demand proper cleanup of the Uniroyal/Chemtura property. While there has been the odd former councilor over the last thirty years who individually on a Woolwich Council would have done the right thing, they have been consistently outvoted with the exception of the 2010-2014 Woolwich Council. While that Council had it's own problems, particularily Mayor Cowan, nevertheless they were not in anybody's pocket, especially Chemtura's.

All parties know where Source Removal needs to be done both on the Chemtura property and just off-site, both on the west side (Yara/Nutrite) and on the east side primarily the Stroh property although also likely grossly contaminated sediments in the Stroh Drain where it passes through the Martin farm.

The Stroh property cleanup not only includes the north-west side of the Stroh property next to Chemtura's east side pits (RPE 1-5 etc.) but also much further south in the low lying areas prior to the building of the Stroh Drain. To date Chemtura and GHD their consultants have done their utmost to avoid sampling these areas despite recommendations from both CPAC and TAG to do so.

The Martin property requires soil and sediment testing the length of the Stroh Drain as it passes through on it's way to the Canagagigue Creek. As Sebastian Seibel-Achenbach of both TAG and CPAC, as well as myself and two gentlemen from MBN Environmental have walked up the Stroh Drain through the Martin property; we have an excellent idea of where sediments have been deposited and collected over the decades.

The on-site source removal of course includes both free phase and residual DNAPL removal. While Wilf Ruland has been a major disappointment to me over the years primarily because of his failure to stand up to CRA and the M.O.E., nevertheless I was pleasantly surprised by both he and Jaimie Connelly's (M.O.E. hydrogeologist) digging in their heels in letters which were released to CPAC (approx. 2011-12) several years after being distributed to some of the stakeholders at the time. While I was a voting CPAC member at the time those letters were written, they were suppressed such that I did not receive them.

Cleaning up the Canagagigue is absolutely necessary. However do we really want to clean the creek BEFORE we fully stop the ongoing flow of persistent organic pollutants and more from the Chemtura site, into the creek? Only part of the west side of the creek and its' banks has been remediated or stabilized. Much more needs to be done there. The amount of creekbank stabilization or removal on the east side may be a function of how much contamination has flowed via ground and surface water. Keep in mind that hydrophobic POPs (persistent organic pollutants) are readily mobilized by solvents and Uniroyal discharged millions of gallons of solvent laden waste waters. Chemtura's difficult question is whether or not to admit how much from the east side flowed west directly into the creek versus how much they successfully diverted south and east to eventually go into the creek further downstream.

SOURCE REMOVAL - THE DIRTY WORDS CHEMTURA CANADA MOST HATES

Over the last week I have been posting about the toxic contaminants in the Canagagigue Creek sediments and immediately nearby floodplain soils. I have indicated both the unscientific, essentially mickey mouse sampling dates, locations and parameter choices. I have also advised of a very few specific contaminant concentrations and their locations in the creek, outside the creek (very little testing) as well as their distance downstream from the Chemtura facility here in Elmira. Just for clarity my concerns are for not only the "natural" environment including sediment dwelling organisms, fish, birds, reptiles and mammals further up the food chain but also for human beings either fishing in the creek, living beside it and children playing in and around it. Finally there are other life forms which have been affected by the toxic contamination in the Canagagigue Creek and that is domesticated animals. With my own eyes this year (2016) I have seen cattle crossing the creek, stirring it up and drinking from it. So much for the bull manure we at CPAC have been told for many years about cattle being fenced away from the creek. Just more lies from Chemtura and their friends in both high and low places. These cattle of course are used for both commercial milk production and also human consumed beef.

All these Persistent Organic Pollutants (POPs) plus other classes, contrary to Chemtura, their consultants and the Ministry of Environment's advice are not stablized. They are not locked up in the soil. They are not biologically unavailable. They have been intentionally drained via both groundwater and surface flow from the east side retention pits (RPE 1-5 & more) southwards and slightly eastwards onto the Stroh and Martin properties. Here a fraction of them have been temporarily stored both at ground surface and deeper, chemically attached to soil particles. These chemical bonds are a function of soil type as well as of Total Organic Carbon (TOC) in the soils.

Why are these toxic "sinks" still able to mobilize? Partly it's because of normal, ongoing surface water flow and runoff. The biggest problem however is the coming 100 year flood. As Dr. Jackson has advised; with climate change, it's not if it's when. In fact there is a map of the 100 year floodplain dated May 2012, in a Conestoga Rovers (Chemtura's consultant) report titled "Scoped Environmental Impact Study" dated May 2013. This map clearly shows that not only is a huge area of former waste disposal ponds submerged on the west side of the creek but also but for one high ridge of land the entire south-east corner of Chemtura including the Stroh Drain and the surrounding soils is also going to be submerged and scoured by the rampaging Canagagigue creek. These submerged soils include the most likely repository of Dioxins/Furans, DDT, PCBs and other POPs.

All of this will end up downstream most likely for many miles on both sides of the Canagagigue as well as on both sides of the Grand River. Is this bad luck or was this forseen a very long time ago Did the Ontario M.O.E. and Chemtura count on downstream flushing from the getgo to help clean the Chemtura site in Elmira

ONE NEONICOTINOID BEING BANNED BY CANADIAN GOVERNMENT

I would call it a classic case of leading from the rear. Our federal government have publicly decided that they will phase out imidacloprid over the next three to five years. Health Canada stated that "Based on currently available information, the continued high volume use of imidacloprid in agricultural areas is not sustainable". This and other neonicotinoid pesticides have been blamed for many years by scientists and others for mass bee dieoffs. The federal government also stated that new mitigation methods introduced in 2014 greatly reduced bee kills from neonicotinoid treatment of corn and soybean crops.

A Toronto based environmental group, Environmental Defence has stated that the three to five year phase-out period is too long. Health Canada are also beginning "special reviews" of two other neonicotinoids namely clothianidin and thiamethoxam.

Og great interest to me is that Health Canada's 2014 review of neonicotinoid pesticides also found that "scientific research shows long-term effects on pollinators can result from sub-lethal exposure levels. Sub-lethal exposure levels are lower levels of exposure that do not result in immediate mortality.". This is the elephant in the room for me regarding the multitude of pesticides, solvents, persistent organic pollutants and other toxic contaminants in the Canagagigue Creek sediments, soils and water. While the soluble (dissolved) contaminants have been greatly reduced over the last fifty years the rest have not. Whether all these toxins are above or below various criteria and alleged safe concentrations is irrelevant. They all have some deleterious effect upon lifeforms in and around the creek including human beings whether or not they can be scientifically measured and or proven.

Today's Waterloo Region Record carries this story titled "Feds move to ban common neonicotinoid insecticide".

SPECIFIC CHEMICALS & CONCENTRATIONS IN THE CANAGAGIGUE

The last few days I've been commenting on inconsistencies and non scientifically rigorous sampling for contaminants in our local creek. Today I will be giving just a few specific chemicals and their locations in the creek from Chemtura Canada (Uniroyal) in Elmira all the way down to the mouth of the creek where it discharges into the Grand River five miles away. That discharge is approximately 1/2 a mile downstream of West Montrose.

These following results are from Tables 3, 4 & 13 in the Ministry of Environment Memorandum released to TAG (Technical Advisory Group) dated October 31, 2016. The time frame for the sampling was 2014 and 2015.

DDT & Metabolytes in creek Sediments at Station #23 (Jigs Hollow Rd.) just upstream from the Grand River. 321 parts per billion (ppb). The LEL or Lowest Effect level is 7 ppb and the site specific SEL or Severe Effect Level is 540 ppb.

Dioxin Toxic Equivalency Quotient (TEQ) in creek sediments at 750-B, the south end of Chemtura's property. 38.48 parts per trillion (ppt). The sediment criteria is 21.5 ppt. A little further downstream past Chemtura at Station #20 the Dioxin TEQ is 63.66 ppt.

Dioxins in sediments further downstream at the New Jerusalem Rd. Station #21 are 182.27, 722.70 and 1,689.15 ppt. TEQ. The three samples represent increasing depths into the creek sediments. Keep in mind the criteria is 21.5 ppt TEQ.

Lindane (gamma hexachlorocyclohexane) (pesticide) was also found at location 750 (Chemtura) at 2 ppb. with a criteria (LEL) of 3 ppb. A quarter mile downstream it was found at 8 ppb. well above the Lowest Effect Level (LEL).

Aldrin (pesticide) was found at Station #21 (New Jerusalem Rd. at 2 ppb. which equals the LEL.

DDT & Metabolytes were found at Station #20 at 851 ppb. with a site specific Severe Effect Level (SEL) of 324 ppb. They were also found at Station #21 at 498 ppb. with a site specific SEL of 288 pbb.

Heptachlor Epoxide/PCB(74) was found at 3 ppb in the creek sediments at FP-9. This location is just upstream of the Grand River. The LEL is 5 ppb. At the same location DDT & Metabolytes were found at 133 ppb. While well below the SEL keep in mind the Lowest Effect Level (LEL) is but 7 ppb.

Dioxins were found at the next upstream location (FP-8) at 10.2 ppt. While below the criteria of 21.5 nevertheless they contribute to the toxic load all the way down the creek to the Grand River.

PAHs (polycyclic aromatic hydrocarbons) were only tested for in sediments at Chemtura and very nearby downstream sites. Benzo perylene exceeded the LEL of 170 ppb with a reading of 180 ppb. both at Chemtura and 1/4 mile downstream. Total PAHs at the same two locations were around 3,000 ppb. with the LEL of total PAHs being 4,000 ppb..


These sampling results are but a tiny proportion of all the chemicals and their concentrations found in the Canagagigue Creek and downstream Floodplain soils. The entire creek is contaminated both in the creek sediments and the floodplain soils all the way down to the Grand River. That this has not been remediated after more than half a century of knowledge is disgraceful. Thank your Ontario government and specifically the Ontario Ministry of Environment and Climate Change (MOECC).

POLYCYCLIC AROMATIC HYDROCARBONS IN THE "GIG"

Following the trend of inconsistency throughout the nearly five years of Canagagigue Creek testing, we have the example of Polycyclic Aromatic Hydrocarbons or PAH for short. They were sampled in July 1995 up and down the creek in the sediments only. This sediment testing took place from slightly above Uniroyal Chemical down as far as Station #23 (Jigs Hollow Rd. #46) just above the Grand River. Sixteen different PAHs were tested for and while none were found upstream of Uniroyal Chemical all but one were found downstream at various sampling locations. Yes that is fifteen out of sixteen parameters sampled for were detected. The concentrations vary from Trace amounts at 40 parts per billion (ppb) up to 7,800 ppb. for Fluoranthene. Keep in mind that the Method Detection Limit was fairly high in these 1995 samplings. In comparison the only other sampling of PAHs took place in 2015 and there were Trace amounts detected as low as 4.2 ppb.

In comparison the 2015 sampling was also in sediments only versus sediments and floodplain soils as were most of the other parameters tested in 1995-96. The failure to consistently measure all parameters in all the same locations over time is one of the huge failures in the Ministry of Environment's Canagagigue studies. While broad generalizations can be made when comparing data I believe that actual statistical conclusions are nearly impossible to make. That said the 1995 PAH sediment data did at least go as far down the creek as Station #23 very close to the Grand River. This is in contradiction to the 2015 data which only geographically covers the south end of Chemtura and then as far downstream as one of the Station #21 locations (ie. New Jerusalem Rd.).

The 2015 data indicate that all 20 parameters were detected (versus 16 parameters in 1995) albeit five were at Trace levels. As difficult as it is to compare geographically it appears as if the total concentrations of PAHs are slightly higher in 2015 than in 1995.

While I believe that statistically significant trends are almost impossible to conclude I doubt that that will stop the M.O.E. from doing exactly that. They have a new TAG (1 year +), a brand new Chair of TAG and proven, experienced, technically competent citizen stakeholders (CPAC) that have been marginalized, excluded and refused the right to ask questions and make comments during public meetings. This should be a walk in the park for the partners in pollution namely Chemtura and the Ontario M.O.E.. Real public consultation it is not.

M.O.E. INTENTIONALLY OBSCURING CANAGAGIGUE DATA

Outrageous and blatant best describes the Ministry of Environment's handling of the Canagagigue Creek studies. Incompetent is also a possibility albeit the Ministry's history of deceit makes the former more likely. Last spring or summer the M.O.E. had promised the final 2015 data and report by October 31/16. Dr. Jackson after advising that the roadblocks to progress were not technical they were public policy (politics); resigned as Chair of TAG effective December 31/16. This should have given him two months to study and comment on the Ministry's final conclusions regarding the contamination in the creek. Lo and behold on October 31/16 indeed another report was produced by the M.O.E. with both more data from 2014 and data from 2015 however we were advised that the final, final report isn't until February 2017, two months after Dr. Jackson is gone. It allegedly will also include more data on bio-accumulation and possibly further contaminants in fish tissues. Nicely played M.O.E..

Last Saturday I posted that the M.O.E. studies are sketchy. Further to that the M.O.E. have a bag of tricks which they employ to dissuade citizen participation and critique of their work. It includes issuing reports either the day of or after they have been presented publicly by M.O.E. personnel. This makes intelligent questioning of reports and data impossible in a timely manner.

The scientific validity of their studies are questionable. If you want to examine toxic contaminants over time in a creek then you attempt to minimize other variables as much as possible. Hence if you take ten samples at ten different locations in year one then subsequent years you would sample the same parameter at the same location hopefully around the same time of year. The same time of year is to reduce seasonal variability due to temperature, spring floods etc.. The M.O.E. absolutely have not done that. Their locations change constantly including skipping from floodplain soils in 1996 to alleged floodplain sediments in 2012 (1 location) and 2015 (several locations). To date the M.O.E. have failed to explain how or why sediments in the bottom of the creek should be labelled as floodplain locations ie. FP-1,2,3,4 etc..

Sediment locations Station #22 and #23 were skipped in 2012 and 2013 with no rationale given. Floodplain soils (FP-1 to FP-10) were skipped entirely after 1996 with the exception of FP-5 & 6 in 2012. This is not remotely a scientifically valid study. It is an intentionally obtuse, confusing, hide the forest with the trees attempt to swamp citizens with data that cannot readily be compared from year to year. It is for the purpose of thinning out public criticism and allowing the M.O.E. and their buddies Chemtura to interpret the data absolutely any way they wish without opposition.

Professional con artists would refer to this as the long con. Indeed professional thieves could take lessons from the M.O.E. in regards to duping the public albeit professional thieves steal money and valuables (jewelry etc.) whereas the M.O.E. steals our health and lifespan.

MINISTRY OF ENVIRONMENT CREEK STUDIES (the "Gig") ARE SKETCHY

Partly they are poorly written. This I pointed out to M.O.E. Biologist Mike Spencer back in 2012 and 2013. He came to CPAC to explain what he had done in these studies examining Dioxins/Furans and DDT in the Canagagigue creekbed sediments and floodplain soils. Terminology and definitions were inconsistent from report to report. For example I've lost count of the times in these numerous reports (1996, 2012, 2013, 2014 & 2015) when "sediments" and "soils" have been used interchangeably and confusingly. Also I have seen conclusions stated by the M.O.E. in these reports that I feel are not well supported by the data. For example they state that the deeper sediments in the creek have higher concentrations of contaminants. This is at best a generalization as in fact there are a number of contrary examples. Scientific consistency is a problem throughout as well. Many sediment samples go from 0-10 cm and then 10 to 20 cm only to have the next sampling round be 0-12 and 12-24 cm. for example. That is not scientifically rigorous whatsoever.

Sample locations also vary over these studies. Any study allegedly comparing data over time should have as much as possible other variables consistent. Hence DDT sampled at Station #21 in the creek sediments should use the exact same location for each and every different sampling round over the years. This has not occurred. Station #21 started off downstream of the New Jerusalem Rd. bridge in 1996 then moved upstream. Then it changed from one location to three different ones being sampled albeit close together. A skeptic could easily conclude that the samplers realized that a nearby location consistently had much greater deposition of sediments on an ongoing basis hence they moved to where they knew they would get higher concentrations of DDT and Dioxins all in the hopes of minimizing the eventual dollars Chemtura needs to spend to "clean up" the creek. This is done via a sampling bias that magnifys the number of concentrations of toxins requiring cleanup closer to the Chemtura site and minimizes the concentrations found downstream which exceed the applicable criteria. Of course when citizens are dealing with an inherently dishonest and corrupt M.O.E. these doubts are exacerbated.

The number of sediment sampling locations has always been problematic. Station #21 is located at New Jerusalem Rd., Station #22 at Northfield Dr. and Station #23 at Jigs Hollow Rd.. In other words we have but three sediment sampling stations spread over a creek distance from Chemtura to the Grand River of over 7 kilometres (5 miles). Making the huge and unrealistic assumption that these three sites are representative of the whole seven kilometres of creek is sketchy at best. Then when we look carefully at the amount of sampling for the two furthest downstream we find that they have been sampled far less than Station #21. Station #21 was sampled in each of the five sampling years. Stations #22 and #23 only in 1996 and 2014. You of course will never find what you do not look for. Finally think about this. If we assume that these three sites are representative of seven kilometres of creekbed then we must understand that the entire creek is contaminated not just the miniscule area around each sampling location. Hence the entire creek needs to be cleaned up.

Suggestions that both Dioxins and DDT are at higher concentrations closer to Chemtura are borne out at some locations, sometimes. Unfortunately they are also contradicted by the data sometimes. DDT for example back in 1996 was found at the highest concentrations in the sediments just downstream of Regional Rd. #22 (Station #22). It was also found at the highest concentration in the floodplain soils upstream of Station #22 albeit closer to Stn. #22 than #21. Similarily Dioxins were found at the highest concentration in floodplain soils upstream of Station #22 and the second highest of these ten sample sites was upstream of Station #23 midway between Stn. #22 and #23. Dioxins were also found at higher concentrations in 1996 in the creek sediments at Station #22 and #23 than at Stn. #21. All this begs the question as to why the sampling focus on Station #21 since then unless it is to simply be able to sell a small cleanup to Chemtura and to bamboozle the public.

Sampling bias also includes what parameters are tested for. Dioxins and DDT have been relatively consistent in their sampling. The "dirty dozen" pesticides from the Stockholm Convention have not. Endrin, aldrin, BHC, heptachlor, endosulphan, chlordane etc. tested for in 1996 have not been tested for since. *** [Oops! 7:08 pm. They weren't tested for in 2012 and 2013 but were sampled for in 2014 and 2015] My bad. Similarily PAHs (polychlorinated aromatic hydrocarbons) were tested for in 1996 and again but once recently. PCBs have only had a few types tested for and found twice in the creek. What about all the others? What about testing for them as often as Dioxins and DDT? All of these sampling biases and failures serve to minimize the human and environmental health hazards in the creek thus allowing the M.O.E. to order (ha! negotiate) a much smaller cleanup.

In the first paragraph I had referred to the M.O.E.'s claim that the concentrations of contaminants are higher in deeper sediments. They also now are publicly advising downstream landowners that these deeper sediments are not biologically available to wildlife and humans. Both these statements are not borne out by the facts. There are many results in both the sediments and the floodplain soils where shallower samples are either higher than deeper ones or at worst extremely close in concentration. Perhaps another significant factor (variable) might be the time of year that sediment samples are taken. Again however the M.O.E. have not been rigorous in keeping their sampling dates consistent. That said what used to be the biggest flooding time of the year namely the spring freshet may have been supplanted by climate change induced more vigorous storms throughout the year. Regardless one would expect that heavier rain events would result in greater flushing of sediments and greater mobilization of deeper sediments along with their being transported downstream and into the Grand River.

I have found one striking (to me) fact while studying this data. To my surprise flooddplain soils generally appear to have much higher concentrations of both Dioxins and DDT than do creek sediments. At least in the original M.O.E. Jaagumagi and Bedard study (95-96) they did. From that point on things get confusing courtesy of the M.O.E. apparently using the same alphanumeric descriptions for Floodplain (FP-1,2,3 etc,) SOIL locations AND for Floodplain SEDIMENT locations. What the bloody hell! This refers back to my first paragraph where I referred to Soils and Sediments terminology apparently being used interchangeably. Well maybe they aren't. I believe I've just had a small epiphany. This may well be the M.O.E. intentionally or possibly stupidly muddying the waters so to speak. Keep in mind I believe I raised this issue with Mike Spencer (M.O.E.) regarding the 2012 study. Only three Floodplain sites were sampled for soils namely FP-1, FP-5 and FP-6. FP-1 appeared to be tested for Sediments rather than soils which was why I asked Mr. Spencer what was going on. His answer was inadequate and unclear, whatever the reason. Then there were no Floodplain sites tested in 2013. Lo and behold the 2014 study also seemed to be conflating ( mixing up) Soils and Sediments in reference to what had been Floodplain Soil locations namely FP-1,2,3,4 etc.. Also keep in mind that by the time we received the 2014 results (Sept. 2015) Mayor Shantz and Councillor Bauman had removed CPAC and myself intentionally from being able to either speak or ask questions at public meetings involving Chemtura or the Ontario M.O.E.. Anyhow as of now I believe that they are indeed sampling sediments in the creek while using Floodplain names ie. FP-1,2,3 etc.. Talk about a bait and switch.

Hence there are three issues. Firstly if indeed Floodplain Soils downstream have not been tested for since 2012 but rather those locations have been changed into sediment testing locations then this is a huge sampling bias against floodplain Soils. Those downstream results were much higher for both Dioxins/Furans and DDT than the sediment results in the 95-96 sampling. Therefore by eliminating them and focusing only on sediment results downstream, the M.O.E. have artificially once again focused attention only upon lower concentration sediment sites probably in an attempt to pretend that the downstream is not a problem. Secondly if indeed as was clearly demonstrated in the 95-96 sampling; the downstream Floodplains are much more contaminated with Dioxins/Furans and DDT then they are also likely much more contaminated with PCBs, PAHs and Persistent Organic Pollutants (dirty dozen etc.). Finally (thirdly) this raises the question. How can floodplain Soils all the way down the creek have higher concentrations of contaminants than the creek which is the initial source to the Floodplain soils? The answer may be extremely troubling. The bulk of the contaminants via suspended sediments are constantly travelling down the creek and discharging into the Grand River. The Floodplain soils are only "enriched" after flooding in the creek has carried contaminated suspended sediments over the creekbanks and deposited them on the floodplains. In other words the creek sediments are constantly being resuspended into the water column during high flows and moving all the way down the creek. The Floodplain soils on the other hand are not being either eroded or resuspended nearly as readily or often. They are more stable plus they are not nearly as often submerged or in contact with heavy flows of water as the sediments in the bottom of the creek are.

This may be why Dr. Richard Jackson has been so insistent upon suspended sediment testing in the creek and why the M.O.E. have been so reluctant to do so. If indeed the bulk of the contaminated sediments are constantly being transported downstream then that magnifies the obvious size of the problem of their ongoing discharge from the Chemtura site as they are constantly being refreshed and redeposited in the creek . Secondly it puts in perspective the fact that our heritage river, the Grand, may well be displaying "adverse effects" from the mouth of the Canagagigue Creek for who knows how far downstream. This may be a can of worms that the M.O.E. do not want to open.

These reports spread over five years, as the final complete report is due in February 2017, I believe are intentionally obtuse, difficult, poorly written and misleading. Dr. Jackson likely could have cut through the final report due next spring but he is retiring at the end of December 2016 and we will have a new Chair of TAG. Meanwhile yours truly and CPAC are intentionally excluded from full participation in both TAG and RAC meetings. No pointed and embarrassing questions for Chemtura, GHD or the Ministry (M.O.E.). No verbal Delegations to TAG and but four times a year can we address RAC. This has been the purpose of getting rid of CPAC as full partners and stakeholders in this very public environmental disaster. After Dr. Jackson is gone there will be exactly zero stakeholders with even a tiny fraction of the knowledge, expertise and history as CPAC and myself have.