JIGS HOLLOW GRAVEL PIT - THE BATTLE CONTINUES

It's unlikely that Preston Sand & Gravel ever felt that this pit outside Winterbourne was going to be a walk in the park. There was another Public Information Session on October 19 in St. Jacobs and residents were there demanding answers. According to the article in the Woolwich Observer the answers they did receive were not adequate. Yours truly was only able to attend right near the beginning at 4 pm. and missed the much larger turnout later on. The title of the Observer article was "Concerted opposition effort meets plan to go below water to mine Jigs Hollow gravel". I would describe it as a well written, knowledgable piece of journalism well within the usual high standards of the Observer's publications.

Various local residents who spoke and asked questions included Paul Marrow, Rick Stroobosscher and Tony Dowling of West Montrose. They are not particularily pleased with the Application for a License Amendment and for good reason. While gravel pits are inherently bad for both the environment and nearby residents, below water table gravel pits are even more harmful. They among other things provide a direct route for both natural and manmade contaminants to penetrate the aquitards protecting subsurface aquifers. They also expose shallow aquifers to direct natural contaminants when they remove soil and expose the shallow water table permanently to surface pollutants such as geese, dead animals and surface runoff of pesticides and fertilizers.

For a Region so hugely dependent upon groundwater any below water table gravel pit is an abomination but for one that is also directly beside the Grand River it is a double environmental blow. The sand and gravel in the shallow aquifer normally filters out contaminants before they discharge along with the groundwater into the Grand River. The covering soil, sand and gravel etc. also insulate the water from higher surface temperatures. This is very important for many aquatic organisms and other life including fish who need cooler temperatures in the heat of the summer. The aggregate effect of all our already existing gravel pits along the Grand River has effectively reduced the numbers of fish species in the Grand. I sincerely hope the Region of Waterloo steps into this battle on behalf of both the residents and on behalf of the natural environment.

CPAC RULES: "NOW IT TURNS OUT THE ACTIVISTS WERE RIGHT"

Well, well, well. That two faced, flipflopping Councillor Mark Bauman has done it again. First of all he is quoted in the media calling CPAC "dysfunctional" roughly a year and a half ago. Then, par for the course, he jumps in front of the parade the instant the media and public opinion change direction. The Waterloo Region Record published a front page headline story a week ago Friday titled "Chemtura starts off-site chemical probe". Yesterday the Record's own Editorial was titled "Get serious about Elmira cleanup". They state "how can it be that nearly 40 years - two generations - is not enough time for the company to complete a cleanup so necessary to public health and safety?". It sure looks as if the Record have grasped the ridiculousness, stalling and delays that have been never ending by Chemtura and the Ontario Ministry of the Environment.

Mark Bauman and Sandy Shantz scapegoated CPAC nearly two years ago as the cause of disharmony at the public advisory committee meetings. The disharmony however was the result of Chemtura and the M.O.E.'s incessant lying, disinformation, deflection and stalling. Sandy either did not know or care about the truth. Mark knew the truth full well as he attended most public CPAC meetings. Sandy and Mark then had the unmitigated brass and nerve to team up with Susan Bryant and Pat Mclean and lied like rugs at the April 9/15 pretend "stakeholders" meeting in the Woolwich Township building. They along with Chemtura and the M.O.E. lied to the Region of Waterloo, Grand River Conservation Authority and others at that private, by invitation only (Sandy's), meeting. Well the chickens are coming home to roost for both the professional and the amateur liars.

The Record are calling for a precise timetable for cleaning up the creek. They are NOT asking for another stupid, self-serving Human Health Risk Assessment (HHRA). They are asking that whatever it takes, the Elmira Aquifers will be clean by 2028. That means far more than the current, glacier like speed of pump and treat. The Waterloo Region Record have publicly acknowledged that CPAC knew what they were talking about both in 2012 regarding the impossibility of the 2028 deadline and in 2014 regarding the off-site contamination onto the Stroh farm. Quoting the Record "Now, it turns out the activists were right." News flash: the activists have always been right, often even those who lost their way decades ago by making private deals with Chemtura and the M.O.E. over DNAPLS and other issues. Yes they were wrong on DNAPLS and yes they were wrong to assist Chemtura by undermining their environmental colleagues. Eternal shame on them for that and more.

Yesterday's posting here was all about my disappointment with our local newspaper apparently egregiously ignoring this huge and vitally important issue. I mentioned all the media coverage of late including last week's front page Record article as well as CKCO-TV and 570 Radio. Well add to that yesterday's Record Editorial which I didn't read until after I had posted yesterday. Woolwich Observer if you have a valid reason for ignoring this important public matter then please tell us. If you can't or won't tell us then at least fix whatever the problem is that is preventing you from doing your professional, journalistic duties regarding the ongoing chemical contamination in our creek and groundwater.

DISAPPOINTMENT AGAIN WITH OUR SOLE REMAINING INDEPENDENT(?) NEWSPAPER

This can not go on. One week ago today the Waterloo Region Record published a front page, major headline story about the latest expansion of the Uniroyal/Chemtura story here in Elmira, Ontario. The title was "Chemtura starts offsite chemical probe". That evening CKCO-TV also covered this same story regarding soil and groundwater testing finally being planned for the Stroh farm to the east of Chemtura. CKCO-TV also publicly mentioned the discovery of PCBs on the Chemtura property. The Record article quoted among others Dr. Dan Holt former and current Chair of CPAC. The CKCO-TV story quoted Dr. Sebastian Seibel-Achenbach former and current Vice-chair of CPAC and also a TAG member. Also somewhere in there one of our local Councillors was also interviewed. The point is all these persons are local, ready and able and willing to cooperate with our now only remaining local newspaper. Oh and also 570 radio also covered this story. I waited patiently until yesterday to see the coverage from the Observer. Nada, nyet, nothing.

What the hell. This is a major local story as clearly indicated by media organizations much bigger and further away from Woolwich and Elmira than the Observer. They are literally just down the street from Chemtura. Our local paper have been here for twenty years and overall their professionalism and their product have been excellent. Joe and Patrick are both local boys and their parents are here in town as well. I've known and respected their Dad for twenty years plus as I'm sure have decades worth of his students when he taught at Elmira District Secondary School.

I have previously suggested that there is a reason for the Observer's apparent reticence to publish articles regarding Chemtura and our local contamination. My suggestion was speculative albeit based upon pretty solid observations and facts. My suggestions/speculation as to reasons was not appreciated by Joe Merlihan hence I will not repeat them here. That said I respectfully suggest that the Woolwich Observer, whom I believe have an excellent reputation, need to address their non coverage of Chemtura/M.O.E. significant issues here in Elmira and Woolwich Township. Addressing that gap in coverage does not mean attacking me. It means confronting, dealing with and resolving whatever problem or obstacle is inhibiting you from covering this subject with the same journalistic integrity and professionalism that you have displayed in the rest of your fine coverage for the last twenty years.

ARE THE M.O.E. LYING TO US (AGAIN)?

Maybe it's just a misunderstanding. Maybe they have simply goofed in their Fish Advisory Tables. Perhaps the thoughtful M.O.E. simply don't want to disturb our local Mennonite population who enjoy catching and eating northern Pike. Or perhaps not.

We seem to have conflicting information between two different documents both purporting to be discussing contaminants in fish in the Grand River watershed. The first is authored by the Ministry of Environment and is titled "Eating Fish from Canagagigue Creek". It was handed out to the Technical Advisory Group (TAG) this past May (2016). The second is titled Report No.: WMPPT-2013-13 "Water Management Plan: Technical Memorandum". It was written by staff from the Grand River Conservation Authority.

The first report claims that the only fish in the Canagagigue Creek (Gig) that have a consumption advisory due to Dioxins are White Suckers. Now they do admit that they did not test the top predator, pike, for Dioxins allegedly because mercury "is known to drive advisories". I believe that comment from them is worth about a seven on the drivel scale. Other fish with advisories in the creek are Common Carp, Redhorse Sucker and Rock Bass although their advisories are solely due to either mercury, PCBs or both. Odd that the White Sucker has advisories for all three and the others don't.

Then we look carefully at the document from the Grand River Consrvation Authority. Lo and behold they do actually finger Uniroyal Chemical as THE source for Dioxins in the Canagagigue Creek (Gig) and in the Grand River. In fact they appear to give credit to Uniroyal for putting Dioxins into Common Carp from the Belwood Dam upstream of the mouth of the Gig all the way downstream through Waterloo and Kitchener to the Mannheim weir across the Grand River. Oh and not only do they add Common Carp to the list of contaminated fish with eating restrictions due to Dioxins but they also include Rock Bass as well.

Considering that pike are the top fish predator in the Gig it seems odd that they are not mentioned in either report as having restrictions due to Dioxins. Afterall Dioxins are both bio-accumulative and bio-magnified. It couldn't be that pike are far more targeted for eating by non-ethnic minorities (ie.WASPS) could it?

WHAT ELSE DO WILDLIFE HAVE TO DEAL WITH IN THE CREEK?

The Ministry of Environment have focused on Dioxins/Furans and DDT. We've included the PCBs found in the creek and recently on Chemtura property. Then we included the initial "dirty dozen" chemicals from the Stockholm Convention of which Chemtura have contributed most of them to the creek. We followed that with the recent chemical additions that have been added to the initial "dirty dozen" which have also been discharged by Uniroyal/Chemtura. Could there be anything else that Chemtura and the M.O.E. have "forgotten" to mention?

Keep in mind that in the 1940s-1970 Uniroyal were discharging to mostly unlined pits and ponds a plethora of solvents. These included your everyday toluene, xylenes, benzenes, chlorinated solvents and so much more. Discharge from the bottom of the pits slowed down somewhat after more clay lining occurred although they did not cease entirely. After the removal from the waste process of many more pits in the mid 80s discharges of solvents would have been further reduced. That left grossly contaminated groundwater still discharging to the creek throughout the site. A major component of that was finally, dramatically reduced in 1996 after implementation of the UACTS or Upper Aquifer Containment & Treatment System. Of course that system was only in Uniroyal's south-west corner and ignored the other three quadrants of the site. That the M.O.E. accepted it I believe is evidence of their knowledge of the surrepticious discharge from the eastern waste pits through the Stroh property via the Stroh Drain.

Back to my question at the end of the first paragraph. What else has Uniroyal/Chemtura discharged into the Canagagigue Creek that along with all the other Persistent Organic Pollutants is the "gift that just keeps on giving"? While most solvents readily dissolve, many chemicals such as POPS hang around for a very long time. They have low solubility in water, good solubility in solvents, they do not readily volatilize into the air, are lipophilic and are hydrophobic. Finally they tend to bind or adhere to soil particle, suspended sediment etc. Besides what we've already listed are a group of chemicals known as Polycyclic Aromatic Hydrocarbons (PAH). While they to my knowledge have not yet made it to the Stockholm list nevertheless they are very bad actors with the preceding characteristics. They can also be toxic to aquatic biota at various concentrations in the creek sediments.

The Canadian Sediment Quality Guidelines for the Protection of Aquatic Life list thirteen different PAHs which can adversely affect biota in (and around) the creek. Of these thirteen I have test results indicating that twelve of them plus a few more not on the list were discharged into the creek and are in the sediments starting at the upstream end of Chemtura essentially at non-detect and then dramatically increasing in concentration throughout their site and much further downstream towards the grand River. Many of the test results from the Bedard & Jaagumagi Report are far in excess of the guidelines.

Each and every guideline, various Effect Levels etc. are all based upon the unrealistic assumption that that chemical compound alone is the sole contaminant affecting life in the creek. Over the last few days I have indicated several groupings of Persistent Organic Pollutants (POPS) that exist to this day in the Canagagigue Creek and are adversely affecting aquatic life both in and out of the creek. For the Ontario Ministry of the Environment to claim otherwise and to fail to act according to provincial law is reprehensible.

M.O.E. MAY BE CORRUPT BUT THEY AT LEAST DO NOT LACK BRASS BALLS

Yesterday here in the Advocate we discussed the "dirty dozen". This initial list of chemicals was determined at the original Stockholm Convention. There have been since several more meetings over the years in which additions have been made to the list of Persistent Organic Pollutants (POPS). Some of these additions include well known and recognized Uniroyal/Chemtura contributions to the natural environment such as Lindane, Endosulphan(s), Pentachlorophenol, Hexachlorobutadiene and Pentachlorobenzene. Others I suspect as they are familiar hence I've probably seen them either in Uniroyal reports or Varnicolor Chemical soil or groundwater results. They include Polychlorinated Napthalenes and various Diphenyl Ethers . Further research is required on all of these nasty compounds.

The M.O.E. Jaagumagi and Bedard Report (1997) is truly amazing. I wonder if they and other involved researchers at the M.O.E. know exactly how little of their excellent work has resulted in improvements to the natural environment. I am just beginning to understand how ubiquitous toxic contaminants are in our natural environment and how they have transferred into the foods we eat, the air we breathe and the water we drink. Unfortunately this also includes chemicals used in food production as well as water treatment to remove other contaminants. I believe that the published statistics for cancer are now up to 42% of our population will be diagnosed with cancer in their lifetimes. Many of these people will be diagnosed with multiple cancers.

I can only wonder at how wildlife are suffering. The bio-accumulation and bio-magnification of so many of Uniroyal's toxins in the aquatic environment in and around the Canagagigue Creek has been ongoing. The creek was just plain dead and devoid of all life back in the 50's, 60's and early 70's. Two of the biggest improvements were the Elmira Sewage Treatment Plant in 1965 and the Upper Aquifer Containment System in 1996. These certainly brought life back into the creek albeit life capable of tolerating stressful conditions. Unfortunately this life has been uptaking persistent organic pollutants for decades and generations. Predator fish, scavengers, mink, raccoons, birds of prey, foxes and coyotes undoubtedly have suffered as they have predated upon frogs, fish, minnows and other life forms living in and around the creek.

Our Ontario Ministry of the Environment are more than willing to spend taxpayers money on red herrings and other diversions which are intended to distract and deflect attention from the real and expensive problems and solutions . The M.O.E. don't want to fight Chemtura. They would rather fight both the public and the few activists willing to engage them. The proposed Human Health Risk Assessment (HHRA) will be such a red herring and costly diversion.

COLLUSION PERHAPS? WOULD THE M.O.E. TRY AND DEFLECT OUR ATTENTION?

Saturday's posting was in regards to PCBs being both in the Canagagigue Creek and in the soil at Chemtura Canada. I asked several questions regarding whether they may have been intentionally kept on the downlow over the last three decades. One question I didn't ask last Saturday was what else is there in the creek from Uniroyal/Chemtura that we are not aware of?

Is the single most toxic contaminant, presumably dioxins, all we need to know about? Do they overrule or overshadow all other possible contaminants in and around the creek? The answer is no simply based upon the fact that PCBs also have Toxic Equivalency Factors (TEFs) similar to Dioxins and indeed to calculate the total Toxic Equivalency Quotient (TEQ) both PCBs and Dioxin/Furans need to be included. Also other contaminants may have either additive or antagonistic properties with Dioxins or PCBs. In other words science has not yet been able to determine either toxicity ratings or even health effects upon humans or wildlife in the case of exposure to multiple contaminants simultaneously. It does however make common sense when we know how toxic certain individual chemical compounds can be to confidently understand that more is not good. It is all the more unnatural disasters in the creek available to various life forms.

PCBs, Dioxins/Furans and DDT are all part of a group of Persistent Organic Pollutants (POPs) known as the "dirty dozen". These twelve chemical compounds were initially identified at the Stockholm Convention many years ago. The other nine include a who's who of man made chemical compounds all supposedly made to better life for mankind. They have turned out to be environmental and human health disasters. "Better living through chemistry" has turned out to be nothing more than exactly what it is. A slogan. No more.

The dirty dozen consist of three categories of chemicals namely pesticides, industrial chemicals and by-products. The pesticides in this group include Aldrin, Chlordane, DDT, Dieldrin, Endrin, Heptachlor, Mirex, and Toxaphene. Hexachlorobenzene is both a fungicide as well as a by-product and impurity in other industrial chenmicals and pesticides. They are lipophilic (concentrate in fatty areas of bodies), bioaccumulative and have low solubility in water. All can and are readily mobilized by industrial solvents. Over time other chemical compounds have been added to the original dirty dozen requiring worldwide bans both of manufacturing and of distribution. Endosulfan or Endosulphan is but one of these.

We have evidence of the following pesticides either on the Uniroyal/Chemtura site or in the sediments or floodplain soils of the Canagagigue Creek. Please compare them to the list above. They are hexachlorobenzene, hexachlorcyclohexane, chlordane, DDT, Dieldrin, Endrin, lindane, heptachlorepoxide, endosulphan-1,-2 & sulphate. Perhaps it would be easier to simply list the chemicals of the 'dirty dozen" that aren't in and around Uniroyal/Chemtura.

Funny isn't it how Chemtura and the M.O.E. have our attention solely focused on DDT and Dioxins. Funny how they want to further focus our attention solely on human health risks via a Human Health Risk Assessment (HHRA). The last thing they want to admit is how willing they are to sacrifice the natural environment and other life forms.

PCBsPCBsPCBsPCBsPCBsPCBsPCBsPCBsPCBs

I've been on the lookout for PCB soil or groundwater results for the last twenty to twenty-five years on the Uniroyal/Chemtura site in Elmira, Ontario. How is it possible that only now in 2016 they have appeared? How many other times were they positively identified and the results never published in reports or those reports buried? How many times were they positively identified via lab testing and either the consultants or Uniroyal/Chemtura expunged them from reports that were then made available to the public? As far as I am concerned this is the equivalent of a convicted child molester appearing at a parole board hearing and the board members not advised that oh yes he also has a couple of convictions for murder as well.

Yesterday the public were advised via CKCO-TV Kitchener that PCBs were found on the Chemtura property eight feet below ground surface. This data came from the recent Supplementary On-Site Investigation Report (July 29/16) which reported on two test pits on the east side very close to the Stroh farm. As Dr. Dan Holt did a wonderful job in yesterday's Waterloo Region Record, so did Dr. Sebastian Seibel-Achenbach in last evening's (6 & 11:30 pm.) two televised broadcasts. As congratulations go to Paige Desmond of the Record they also go to Abigail Bimman of CKCO-TV.

PCBs potentially on the Uniroyal site first came to my attention twenty years ago when they were discovered in the Bedard and Jaagumagi (M.O.E.) 1996 study of the Canagagigue Creek. I have long wondered where else possibly they could have come from other than Uniroyal. To this time I would equate it to the discovery of NDMA in Elmira's groundwater in 1989. NDMA it turns out can be found in many different sources however the evidence all strongly pointed to Uniroyal in 1989. Hindsight being 20/20 I believe that while Uniroyal certainly led the parade with irresponsible disposal of toxins, they were far from the only contributor to the destruction of Elmira's groundwater. At this time we now have positive evidence of Chemtura's complicity with PCBs but to my knowledge no other sources have been proven.

The toxic effects of PCBs on humans, wildlife and plant life are well known and documented. Unlike DDT which affects birds and animals more than humans; PCBS like Dioxins do incredible damage to human beings. To date the M.O.E. have been down playing DDT in the creek because of its' much lower effects upon human receptors. They have also been ignoring the effects of HCB, Mercury and PCBs on both humans and other lifeforms. They have also not categorically indicated the vastly increased threat to both humans and the environment from all these persistent and toxic substances combined. Perhaps science does not have a single magic number combining all these proven, serious threats but that should not stop the Ontario Ministry of the Environment from doing their job. Order Chemtura to clean up their mess in the Canagagigue Creek from their plant downstream to the Grand River at a minimum! Polluter pays should be more than a handy slogan for politicians and the M.O.E.. It should be an enforceable law.

THERE ARE A THOUSAND MORE "I told you so " COMING

Mark Bauman is at least temporarily back on side. He's doing what he always does which is say the words that the listener at the moment wants to hear. Right now that is crapping upon our corrupt Ministry of the Environment. Today's front page headline in the Waterloo Region Record is "Chemtura starts offsite chemical probe". This story written by Paige Desmond captures the reality and history of this issue. CPAC formerly Chemtura Public Advisory Committee are now known as the Citizens Public Advisory Committee (ie. still CPAC). We are NOT a committee of Woolwich Council or any other inherently dishonest group of politicians. We brought this issue forward over two years ago and it was confirmed via Peter Gray of MTE Consulting in his October 2014 Report.

Two years later and the Ont. M.O.E. and Chemtura are simply in the Work Plan stage regarding soil and groundwater testing on the Stroh farm on Chemtura's eastern property line. Keep in mind this is a working, producing farm and has been for decades and decades. Also keep in mind that the M.O.E., Chemtura and their consultants at the time, Conestoga Rovers, never felt the need to share the huge fact that there was a manmade Drain excavated parallel to the Uniroyal east side property line around 1985. This Stroh Drain drains the lowest lying areas on both sides of the property line and then conveys the water (and more) southwards past the Martin pond and into the Canagagigue Creek.

The guilty parties in the Uniroyal Chemical disaster have long known that the property east of Uniroyal/Chemtura was contaminated. As far back as 1990 a M.O.E. hydrogeologist bluntly stated that toxins from two eastern pits (RPE 4 & 5) had contaminated groundwater which had flowed eastwards across the property line. Other reports back into the 1980s also made it clear that both surface and groundwater had flowed eastwards and contaminated the Stroh farm. Local lore has the now deceased patriarch receiving an envelope (cheque?) every Christmas from a senior Uniroyal manager. This allegedly was due to crop damage caused by the eastern pits flowing onto his property.

Two years since a professional report commissioned by CPAC confirmed off-site flow and Chemtura/M.O.E. still haven't done off-site soil and groundwater testing. All they are doing is running out the clock enabled by a passive, cowardly Woolwich Council who would rather dismiss a strong citizens group appointed by the preceding Council.

FRIENDS OF THE WINTERBOURNE VALLEY

Second day in a row we have an article in the Waterloo Region Record regarding the Jigs Hollow Pit beside Winterbourne. The title is "Residents oppose gravel pit operator's request to dig under water table". There was a public meeting (sort of) yesterday held in St. Jacobs. I attended the 4-7 pm. meeting early on and it was very quiet at that time. Essentially the room has two rows of posters set up showing various aspects of the proposed below water table pit currently, during extraction and after "rehabilitation". Essentially there will be a large lake beside the Grand River as the extracted area below the water table fills up with groundwater.

When this pit was first proposed six years ago as an above water table gravel pit local residents knew that that was ridiculous. Maps of the subsurface deposits of gravel made it clear that the bulk of the gravel was too deep for above water table extraction to be economically feasible. Lo and behold they were correct and now Preston Sand & Gravel want to extract below the water table, beside the Grand River.

The company require approvals from the Ministry of Natural Resources (MNR). I don't see that as any significant roadblock. They also need approval (sort of) from Woolwich township in order to mine below the water table. The Township in recent years had opposed both the proposed gravel pit in West Montrose by Capitol Paving and also the private proposal just outside Conestogo within sight of the Preston Sand & Gravel Pit. It was called the Hunder Pit. The Ontario Municipal Board was involved in the Hunder Pit and most surprisingly turned the pit down. I attended the hearing and believe it was an entirely political decision (provincial). While I did not want to see that pit go forward nevertheless it was my opinion that the proponent dotted his i's and crossed his t's and did everything required in order to as a matter of course receive his go ahead.

Woolwich Township vigorously opposed the Hunder Pit including the Director of Engineering, Dan Kennally testifying against it. That was then and with a different Council. This is what I've learned. These approvals are rarely made or lost based upon the environmental facts and conditions. They are rarely won or lost based upon sound science, logic or common sense. It's all about the politics folks. Look carefully at our current Council and understand whose interests they will protect. The Friends of the Winterbourne Valley have a tough battle ahead of them. Best of luck.

THE GRAND RIVER: DEATH BY A THOUSAND CUTS

Today's Waterloo Region Record has an article by Paige Desmond titled "Residents oppose rule change for gravel pit". This is the Jigs Hollow Pit owned by Preston Sand & Gravel. An agreement had been reached in 2013 between the Township of Woolwich and the gravel company through the Ontario Municipal Board. The agreement stipulated only above water table extraction. Allegedly higher groundwater levels found in 2014 have brought about an amendment application to permit below water table extraction. To date the Region of Waterloo has appropriately been against below water table extraction due to its potential and indeed likelihood to lessen groundwater quality. As we are a large area dependent upon groundwater for our drinking water this simply makes good sense. As it is Waterloo Region overall are forced to spend millions of dollars annually to treat both our ground and surface (Grand River) water prior to putting it into the distribution system. This is essentially a direct subsidy to polluters past and present in our Region.

There is a public information session from 4-7 pm. at the St. Jacobs Community centre at 31 Parkside Dr. in St. Jacobs this afternoon. Friends of the Winterbourne Valley will also host a parallel meeting downstairs at the centre at 5:45 pm.. Keep in mind that the last time around the old lame duck Council who had been kicked out in the October 2010 election gave last second approval to this pit. Then the new more progressive Council dug in their heels and insisted upon no below water table extraction. Now we are back to the likes of Murray Martin, Mark Bauman, and Sandy Shantz. My prediction is that those pro industry, pro environment via rhetoric only Councillors will be in favour of giving Preston Sand & Gravel what they want. The only hope for citizens is to raise a racket similar to the Breslau rebellion and to remind councillors of their antidemocratic stance last May when they got publicly hammered for trying to deny Delegations to Council on Chemtura and Ministry of the Environment matters.

MINISTRY ABANDONS ALL PRETENSE OF CREDIBILITY

The Ontario Ministry of the Environment (M.O.E.) are now publicly advising TAG (Technical Advisory Group) that they do not have provincial sediment quality guidelines which would enable them to order a cleanup of the Canagagigue Creek by Chemtura Canada. Yes they acknowledge the existence of Canadian Sediment Quality Guidelines but when asked why those are not acceptable they simply respond because they aren't provincial guidelines. As of yesterday I have made available the fact that these Canadian Guidelines actually include on page 4 a reference to the contamination in the Canagagigue Creek as well as the name of the study done by Bedard and Jaagumagi in 1995-96 titled "Sediment and Biological Assessment of Canagagigue Creek at the Uniroyal Chemical Ltd. Plant, Elmira, Ontario. 1995-96". In other words the Canadian Guidelines are actually built upon the ground breaking study done right here in Elmira, Ontario in the very same creek that our M.O.E. claims it has no provincial sediment guidelines for.

This 1995-96 study includes a biological assessment of the uptake of contaminants including Dioxins.Furans and DDT in the benthic community as well as in fish species. The conclusion is that indeed these contaminants are available and are being absorbed and bioaccumulated within lifeforms in the creek. Also of interest is Appendix A of this report. It is titled "Provincial Sediment Quality Guidelines". Isn't that interesting? Some of the other potentially dioxin like contaminants present in the creek include PCBs and HCB (Hexachlorobenzene?). To date no effort has been made to determine how significant their contribution is to the total toxic effects of Dioxins/Furans.`

George Karlos, Deputy Director of the West Central Region of the M.O.E. advised CPAC in 2012 that they the M.O.E. were going to do another study of the creek, its' sediments and floodplain soils. They would also two years later do testing on fish and compare the results to their Tissue Residue Guidelines (TRGs). The first report was titled "Canagagigue Creek 2012 Downstream Sampling March 28, 2013". The second report was titled "Canagagigue Creek 2013 Additional Sediment Sampling at Stn 21S and Soil Sampling at Martin Pond Berm September 26, 2013". The third report was titled "Canagagigue Creek: Sediment and fish results from 2014 and update on sampling conducted in 2015 September 30, 2015".

Guess what? All three of these reports are filled with references to and comparisons to various criteria and guidelines. They include ISQG - Interim Sediment Quality Guidelines, NEL - No Effect Level, PSQG - Provincial Sediment Quality Guidelines, SEL - Severe Effect Level, LEL - Lowest Effect Level, Canadian Interim SQG and Canadian Probable Effect Level - PEL. Not a peep out of the Ministry that they have no criteria or guidelines. In spots they make comments such as "Could not validate 2012 SEL results", "2013 results did not exceed PSQG SEL" etc. as well as "Exceedance of PSQG SEL is expected to impair benthics".

The 2014 Report states (pg.8) "Data compared to historical data and appropriate guidelines for assessing potential impacts" and then lists Sediment Guidelines including both Provincial and Federal (CCME) Guidelines. It also then lists Fish Guidelines namely "Federal (CCME) tissue residue guidelines (TRG) (Young of the year fish). There are both exceedances as well as samples below guideline levels. The point is the blatant and grotesque hypocrisy of the Ontario M.O.E. to now in 2016 suggest that they don't have appropriate guidelines to base remediation decisions upon after confidently proclaiming them and their use in 2012, 2013 and 2014.

One key component requiring remediation of a site is being able to prove adverse effects ie. adverse environmental effects upon lifeforms. We have had overwhelming evidence of that over the last twenty years and in fact DDT for example has been found at much higher adverse levels in 2012 and 2014 than it was twenty years ago. There is no technical excuse for not ordering a cleanup of the Canagagigue Creek. There is only political corruption standing in the way.

TWO YEARS PLUS OF CHEMTURA/M.O.E. STALLING

Sub:Title : THANK YOU SANDY & MARK FOR YOUR TIMELY ASSISTANCE TO THIS

This is huge albeit painstakingly slow and tedious. The report titled "Off-Site Investigation Work Plan ...Elmira Site" is dated August 8, 2016 whereas I received my copy last Thursday (October 13/16). It has been two years since the MTE Report indicating the high probability of Uniroyal liquid wastes having travelled east and south-east onto the neighbouring Stroh property. That momentum and so much more was intentionally broken up by Mark and Sandy as they struggled heroically to bring Chemtura and the M.O.E. back into the fold. This entailed Mark and Sandy bending over backwards to kiss their respective butts and beg them to come back and recapture their places of prominence and superiority around the Woolwich Council table. Chemtura and the M.O.E. graciously accepted Mark and Sandy's prostration and obsequious pleas.

So of what calibre might this report be? I would call it par for the course as the guilty parties continue to stickhandle and wiggle on the hook to avoid both more blame and responsibility for their past coverups of pollution and illegal waste disposal. Neither TAG members nor the M.O.E. were particularly impressed with the location of surficial soil sampling . One Cynthia Doughty of the M.O.E. has responded in a September 7/16 Memorandum requesting numerous changes and upgrades to the proposed Work Plan. Basically she feels the Work Plan as presented does not achieve its' aim which is to delineate off-site (Stroh farm) contamination which has moved from Uniroyal/Chemtura east and south-east onto the Stroh property.

I submitted a last second one page document to Dr. Jackson with my (and CPAC's) criticisms just prior to the start of the meeting. When one receives the document the same day it is difficult to read, absorb and then write a response to be submitted for a meeting that day. This is par for the last thirty years of gamesmanship and deceit practiced by Chemtura, the M.O.E. and enabled by the cowardly behaviour of the vast majority of Woolwich Councils since Uniroyal/Chemtura came to town in the 1940s.

Among four criticisms I had was the obvious and blatant fact that zero soil samples were committed to by GHD in the area of the "Gap", the Stroh Drain or the nearby "Sink". Also the soil depths were once again far too shallow. A reference to 15 cm. being adequate as per the December 2015 East Side Investigation is pure horse manure. There was no such evidence presented despite GHD's claims to the contrary. Keep in mind this is but a "Work Plan". It will have to be amended , recommented on and then samples taken and wells drilled. Then we will wait for months for the data to be analysed and a report written. Then there will be another report and further discussion as to what remediation if any that will be done. This crap will go on for years exactly as Chemtura and the M.O.E. have been doing for the last thirty years. This will continue as long as our local, idiot councillors continue to treat the guilty partieswith kid gloves and continue to kiss their asses every time they whine and complain that citizens are too hard on them.

MORE SPECIFICS ON THURSDAY EVENING'S TAG MEETING

Thank You Sebastian for your opening question to Dr. Jackson, Chair of TAG (Technical Advisory Group). You asked why TAG members were only asked to declare pecuniary conflicts of interest. Firstly there appears to be no distinction as to whether members are declaring current or past pecuniary conflicts and secondly there are many other conflicts of interest other than pecuniary ones. Dr. Jackson clearly was surprised by your question and was unable to give what I would refer to as a considered response. Two TAG members have serious conflicts of interest whether still pecuniary or not although they certainly have been.

Dr. Jackson was all over Chemtura and their consultants (GHD) due to the "Gap" along Chemtura's south-east property line. He referenced a 210 metre gap between soil samples and a 350 metre gap between monitoring wells OW38 (northerly) and OW15 (southerly). My refernce to the "Gap" usually encompasses a 175 metre stretch parallel to the Stroh Drain where it is closest to Chemtura's eastern property line. This area is the crucial low lying location where Uniroyal's liquid wastes are most likely in large volume to have left their property and crossed over to the Stroh property.

Astoundingly TAG had the M.O.E. response to GHD's Off-Site Investigation Work Plan a couple of weeks prior to having the actual Work Plan itself. Of course other stakeholders such as myself and CPAC still don't have the M.O.E.'s comments about Chemtura's proposed investigation of the Stroh property.

Joe Kelly spoke positively about these M.O.E. comments. He feels the M.O.E. did a good job in pointing out unclear parts of GHD's Work Plan as well as other problems. Sebastian suggested deeper test pits rather than the usual 15 cm. (6 inches) only. As another hydrophobic compound (P.C.B.) was found in the Supplementary Investigation last summer, eight feet below ground surface, Sebastian's comments are right on the money.

Dr. Jackson suggested the possibility/probability that overflow or drainage from the closest east side pits, RPE-5 and BAE-1, likely discharge into the Stroh Drain. Hence the sediments in the bottom of the Drain, at the very least, will be contaminated. Dr. Jackson also kindly indicated to TAG that I had given him some helpful input and information recently. Dick (Dr. Jackson) again reminded all that it has taken the M.O.E. thirteen months to date to produce a report from data that they shared with TAG back in September 2015. Even for the M.O.E. that is pretty bad. Dick further made comments as to the so called fencing off of the creek to cattle many years ago as he mentioned that the "cattle were free to cross and drink as they go" at the New Jerusalem site. Indeed I now have pictures of that location as well as of the Northfield Dr. crossing area.

It was pointed out that criteria for Dioxins were exceeded in Tables 1,2 and 8 in the floodplain area on the north side of the creek upstream of New Jerusalem Rd.. David Hofbauer of TAG asked "Do they trigger further action in the M.O.E. world?". He then stated that the criteria and Tables were "geared towards property transfer" and that banks are the biggest users of these Tables (ie. mortgages, liability concerns) . He further suggested that the farms between Chemtura and the Grand River could not be sold because of the known contamination of the creek and floodplains. Susan Bryant suggested that the Old Order Mennonites were more likely to simply pass the farms on to the next generation rather than sell them. She also pointed out that the EPA's 2003 review of Dioxins stated that they were a Non-Threshold toxin which means that there is no safe level for them hence all these criteria were sketchy.

There was discussion between David H., Sebastian, Linda Dickson and Dick Jackson regarding the M.O.E.'s latest criteria of 48 pg/g or parts per trillion (ppt). It appears as if the lower criteria of 13 ppt is for mammals and birds whereas the higher criteria of 48 ppt is for soil contact by human beings. Both David and Dick made it clear that the M.O.E.'s proposed Human Health Risk Assessment (HHRA) will ignore harm to birds and critters with the higher criteria. Dick also pointed out that "there is no boundary between creek sediments and the floodplain". In other words the contaminated soils on the floodplain are all coming from the contaminated creek sediments during flooding episodes.

Sebastian may have started the discussion but other TAG members chimed in regarding TAG being played, intentionally delayed by the M.O.E. and overall the issues going around in circles for years. Much of this part of the discussion I posted about yesterday here in the Advocate. Dick referred to it as "running into a wall of public policy indifference and bureaucratic lethargy.". Wow I am going to miss him after his December 31/16 retirement. Further comments by Dick include "TAG's technical arguments are sound" and in reference to the Ontario M.O.E. he said "there is not a matter of good faith here." Lastly he and others said "The HHRA is unlikely to be helpful in cleaning up the creek.".

Interestingly that despite the "cringeworthy" setup of TAG (& RAC) I do see some gentle relaxing of Sandy's draconian and disgusting rules prohibiting either questions or comments from other stakeholders and concerned citizens attending TAG meetings. Dr. Jackson (Dick) recognized and permitted a comment from audience member Viv Delaney as well as once again allowing Sandy Shantz to address TAG and the public. Furthermore yours truly again twice briefly added some facts to the mix from the gallery without being hassled or threatened by Sandy.

Lastly Dick Jackson suggested that he would like Hatfield consultants to do an independent Risk Assessment of the creek as they are recognized international experts on Dioxin contamination. Dick also suggested a trip to the Environmental Commissioner regarding technical evidence that the M.O.E. are violating Ontario law.

Once again no media present to record this excellent meeting. Shame on the pack of them and yes I do sorely miss Gail Martin and the Elmira Independent since their closing.

TAG MEMBERS EVISCERATE "FORTRESS" M.O.E.

My, my the sweet irony. The vindication. The complete turnaround in public understanding that Chemtura and the M.O.E. were not poor victims of a hostile CPAC at all. That lie was courtesy of two professional liars and politicians namely Sandy Shantz and Mark Bauman. Last evening Sandy's own friends that she handpicked for TAG made that clear. TAG members one after another discussed the intransgience, incompetence and inherent corruption that is the Ontario Ministry of Environment and Climate Change. This was no one man show with Dr. Richard (Dick) Jackson going head to head with Terri Buhlman or Jason Rice of the M.O.E.. This was Tag members, one after another, discussing how to deal with "Fortress" M.O.E..

"Fortress" was the term one of them used and it described an insular, dogmatic, isolated Ministry both afraid of their own shadow when dealing with corporate power and at the same time defensive and antagonistic when dealing with citizens or other levels of government insisting the M.O.E. do their jobs. Repeatedly it was made clear that TAG have presented technical arguments and facts which are undisputed indicating that the Canagagigue Creek needs to be cleaned up. Repeatedly the M.O.E.'s failures and refusal to clean up the English-Wabigoon Rivers in Grassy Narrows was mentioned as an example of the incredible uselessness of this Ministry.

Through all this our alleged mayor sat at the back of the room perhaps keeping an eye on Chairman Dick Jackson. Is she even smart enough to understand what a huge turnaround this is? Almost two years since Chemtura/M.O.E. stopped attending CPAC meetings and only thirteen months since TAG held their first meeting; TAG have learned that the M.O.E. are contemptible. Between the two year mark and the start of TAG, Mark and Sandy lied like dogs blaming CPAC for the M.O.E. and Chemtura's non-attendance at public CPAC meetings. What a farce. Did anyone see either Chemtura or the M.O.E. last night? Of course not! They still don't attend meetings in which honest, informed citizens criticize their behaviour. Four RAC (Remediation Advisory Committee) meetings a year they can handle. Those meetings have more politicians and bureaucrats involved, hence less blunt truths and more sweetness and light.

There are two TAG members who are more concerned with their own self-aggrandizement than anything else. They are spoiled brats unwilling to share the credit with CPAC or anyone else. They are not and never have been team players although both fake it really well. I've been advised that Sandy really isn't smart enough to have been the brains behind the "manufactured crisis" of two years ago when Chemtura and the M.O.E. suddenly stopped attending CPAC meetings after the new Council were elected. These two TAG members (former CPAC) along with Mark Bauman, Chemtura and the M.O.E. came up with the "manufactured crisis" plan. If that is the case then Sandy is less corrupt and more stupid than I've given her credit for.

RAW, BLATANT CORRUPTION ASSISTED BY WOOLWICH TOWNSHIP DECISIONS

A week ago we received the Agenda for tonite's TAG meeting. Item 3.3 is a M.O.E. Letter commenting on two Chemtura (GHD) Reports of which we had not received the "Draft Off-Site Investigation Work Plan Review". I sent inquiries to a TAG member as well as to the TAG Support person. Both replied quickly stating that they had not yet received the report although it had been requested.

Lo and behold this report came in to me via e-mail last evening. I saw it this morning at 7:30 am.. Meanwhile it is on tonite's Agenda for discussion thus making it virtually impossible for the public including CPAC to comment on it. There are no Delegations allowed to TAG thanks to Sandy (alleged mayor) & Mark ( councillor) and even written comments must be sent to TAG I believe at least 48 hours in advance of the meeting. This is the current state of public consultation here in Woolwich.

Having only skimmed the Report to date as well as having looked at two of the maps it is clear that Chemtura (GHD) are still intentionally avoiding the "Gap". This "Gap" is the 175 metre long area on Chemtura's south-east corner directly beside the length of the Stroh Drain which runs parallel to Chemtura's property line. It is the low lying, former swampy area that drains south and east off-site onto the Stroh property. This is the most likely repository or sink of DDT, Dioxins/Furans and P.C.B.s and probably more.

This information has been made publicly at RAC and TAG meetings. In fact Mark Bauman publicly stated that Chemtura's report will have no credibility unless this area is tested. Let's see what the master of speaking out of both sides of his mouth has to say tonite.

GHD have stated (pg.5) that they will do a visual inspection of the area and will collect between zero and three surficial soil samples from low lying areas where surface water may pool. This is total bullshit Luis Almeida (GHD) and you and every professional liar at Chemtura and the M.O.E. know it. Three samples are grossly inadequate. Surficial soil samples are grossly inadequate. Show us exactly now where you intend to sample or not sample. Also do groundwater monitoring in this area. Your promises aren't any more confidence inspiring than Chemtura and the M.O.E.'s minimal and improper actions over the last thirty years.

REVIEW TIME: HOW & WHY DID CHEMTURA EXCAVATE THE WRONG LOCATION FOR GP1

First of all this information was not known prior to 2014 AFTER GP2 was simply covered over and GP1 primarily excavated all of one foot deep (.3 metre). At the north end of GP1 there was a much deeper excavation (2.5 metre-8') based upon findings in the field of deeper contamination. There were also three supplementary deeper excavations after that. The location of these deeper excavations are crucial in that they start right below the gap in the high ground (ridge) that blocks the bulk of Uniroyal's waste waters from flowing due south into the purported GP1 area. Conestoga Rovers released topographical maps along with their GP1 & 2 reports that I found odd. They showed a very low lying area off the Chemtura site immediately east of their property line. This area corresponded with the swampy, wet area including the manmade Drain that I found on the Stroh property. Their topographical lines amazingly ended (disappeared) when approaching the Chemtura/Stroh property line as if that would somehow decrease their credibility. Strange?

Conestoga Rovers borrowed the location of GP1 & 2 from maps published in the 1985 "History of Uniroyal Wastes" written by Jackman and Ralston of the M.O.E. along with Tony Smith of the GRCA. This map is dated 1983 and both Conestoga Rovers (CRA) and CH2MHILL misplaced the location of GP1 in subsequent publications of their own. Those two parties actually misplaced the location of GP1 differently. While the 1983 map and 1985 report had GP1 on the north-east side of the high ridge of land (in a low lying area), CH2MHILL placed GP1 ON TOP OF the ridge which would have made it impossible for Uniroyal's massive volumes of waste waters to flow into GP1. CRA however did one better by placing GP1 on the south-west side of the diagonal ridge in a low lying area. The problem of course was in getting the waste waters to CRA's location. Fortunately there appears to be a small gap in the natural ridge which would allow at least a small proportion of the waste waters from the north-east pits to flow into CRA's location. Whether this small gap is natural or manmade I do not currently know. While it is shown on CRA's topographical map oddly it does not show up on the M.O.E.s 100 year floodplain map. That map clearly shows that the ridge is continuous.

Why put GP1 in a different location? One it is much further away from the neighbouring Stroh property thus reducing the likelihood that a citizen activist (moi) would make the connection and understand the significance. Two there would be a much smaller volume of contamination required for excavation if and when GP1 was remediated. Three if and when the Stroh Drain (approx. 1985) was publicly discovered (moi in 2014) it would appear less likely that it's purpose was to help drain and dispose of the grossly contaminated low lying areas on both sides of the Uniroyal/Stroh property line.

The question is how much was the Ontario Ministry of the Environment involved in these wrongdoings? Are they incredibly incompetent and stupid as allegedly George Karlos's (M.O.E.) walk through the area in 2013 would indicate? He claimed he saw no pathway for contaminants to flow into the downstream Martin swimming pond. He failed to mention the existence of a surface water body running parallel to Chemtura's property line, past the Martin pond and then into the "Gig". In fact there is a pipe diverting part of the Stroh Drain directly into the Martin Pond. Did the Ontario M.O.E. collude directly with Uniroyal and then Chemtura to coverup this off-site flow of toxic Uniroyal wastewaters onto farmland and then into the Canagagigue Creek further downstream? When will there be a public inquiry into the Ontario Ministry of Environment's dealings with Uniroyal, Crompton and Chemtura?

IT'S STILL A SHAM FOLKS

Pretend investigations. Pretend cleanups. Pretend concern for either human health or ecological health. That is the reality in Elmira, Ontario. We've had two recent rebellions with the 2010-2015 CPAC and then from September 2015 until now with Dr. Richard Jackson at the helm of TAG. He has been a breathe of fresh air mixed in with the foul stench that emanates from Chemtura, their consultants and the M.O.E.. While both CPAC and Dr. Jackson have at least been controlling the Agendas that is likely to soon end. Dr. Jackson has resigned as TAG Chair effective the end of the year. This is a huge loss to Woolwich Township residents and the vast majority of them don't even know it thanks to our local ineffective media.

CPAC were removed as a committee of council by Mark and Sandy despite the last Council's support for them and despite Mark being a member of that last council. Of course Mark did what Mark does best when facing strong opposition which was hide in the woods until the trouble passed. With the election of Sandy, Murray and a couple of other straw votes Mark came out of hiding in order to remove the best CPAC there ever was.

It is typical of Chemtura/M.O.E./Woolwich Twp. that many of the Agenda Item reports for this week's (Thursday) TAG meeting have not been distributed to ALL stakeholders ahead of time. It is not typical over the last twenty-five years that only the people appointed by Council are allowed to speak. That is undemocratic and blatantly not public consultation. That is to the shame of the same Woolwich Council who attempted to refuse citizens the right to bring Chemtura/M.O.E. issues to Council as Delegations last spring. Fortunately Woolwich Councillors got their heads handed to them when they went that far. Even the media rose up as one and said what the hell are the politicians doing up in Woolwich Township. Refusing public Delegations to TAG (Technical Advisory Group) in regards to the cleanup of our drinking water and our creek is grotesque. Refusing it to former CPAC members who have far more knowledge and history of the Uniroyal/Chemtura site than most of the TAG members is an abomination. That folks is sham public consultation and it's born and bred right here in Woolwich Township.

"PEACE IN OUR TIME" - WITH THE ONT. M.O.E. - AT ANY PRICE

Repeated public confrontation and clearly enunciated contempt will result in change. Neverending acquiescence to the status quo will not. The Ontario Ministry of the Environment are literally killing us and our descendants. Their mandate is public manipulation via extreme lying, distraction, deflection, puffery and bullshit.

Their latest pile of pus is a June 2016 "Technical Memorandum" titled "Soil Survey to Detect Dioxin and Furan Contamination in the Canagagigue Creek Floodplain West of new Jerusalem Road, Elmira, Ontario (2015)". This is a thirteen page report including photographs which tells us that while as already known there are Dioxins and Furans in the floodplain; not to worry they aren't a human health concern.

Once again they have tested the top 6 inches (15 cm.) of soil and while they have detections at all sites they are higher nearest the creek and only at "background" levels 115 metres away from the creek. Did you know that we have background levels of Dioxins (and much more) in our foods, milk and even in our bodies?

NEWSFLASH: The conclusion of this taxpayer funded nonsense is that the Dioxins are not coming from the nearby farmers' fields, rather they are courtesy of Uniroyal/Chemtura's waste disposal practices. The second not so startling conclusion is that even the highest floodplain result (40 parts per trillion) isn't a threat because gosh and golly they now have advised us of a new guideline namely 48 pg/g or ppt (parts per trillion). It is becoming obvious that these monkeys simply have a list of guidelines for each and every, any and all, soil conditions, distance from waterbodies, types of land development, age and gender of humans, time of year, weather conditions, political party in power, religious and ethnic makeup of human receptors etc.. O.K. maybe I've slightly overstated the numbers and types of guidelines they have but maybe I've also missed a few. You get the picture.

Lastly this report like so much of the M.O.E.'s crap is meaningless. Allegedly the presence of Dioxins/Furans in these floodplain soils isn't a health threat. Gosh neither is the non presence of dinosaurs. What about the presence of DDT and its' metabolytes? What about the presence of P.C.B.s? Lead and mercury are in the fish in the creek. Are they also in the floodplain soils? If you're going to do a taxpayer study then make it a worthwhile one. Make it relative to the reality of this horribly, most likely permanently contaminated creek discharging into our Heritage River, the Grand. Make it relative to the people who live, work and play along this creek.

TAG MEETS NEXT THURSDAY AT 6:30 pm. IN WOOLWICH COUNCIL CHAMBERS

The Agenda has been distributed for next week's Technical Advisory Group meeting. Essentially the entire meeting is focused on the east side of the Chemtura site as well as their eastern neighbour (Stroh) and then the downstream Canagagigue Creek. This Woolwich citizens and any public servants with a brain or ethics can thank CPAC for. Starting in 2014 after I discovered the presence of the "Stroh Drain" the then CPAC (Chemtura Public Advisory Committee) understood and decided to explore the gaping chasm of non data and information this contaminated area represented. It gave the appearance of an intentionally contaminated zone that had been kept in the dark. It even appeared as if this was an alternate route or pathway for Uniroyal/Chemtura's contaminants to circumvent monitoring while on their way into the creek and further downstream.

Of concern is the lack of timely presentation of data both to TAG and to the public including CPAC, now known as the Citizens Public Advisory Committee. This is an old trick of Chemtura and the Ontario Ministry of the Environment. When you know that Work Plans and or decisions are pathetic then simply do not distribute the data and or reports ahead of time. Afterall that would allow the public and appointed members to prepare themselves and to have penetrating, difficult questions ready ahead of time.

For example the Draft Off-Site Investigation Work Plan has been prepared. This is the plan indicating where and how many soil and groundwater samples will be taken on the Stroh farm near Chemtura's eastern border. To my knowledge it has neither been distributed to TAG or to CPAC and the public. The same thing goes for the M.O.E.'s Comments to Chemtura (GHD) regarding that plan as well as their earlier Supplemental On-Site Investigation report. Finally we have Soil Survey Results for Dioxins & Furans in the floodplain just west of the New Jerusalem Rd.. We were advised a while back that the M.O.E. were going to attempt to blame this floodplain area for the high results in the creek sediments in and around New Jerusalem Rd.. As the Dioxins & Furans are all coming from the Chemtura property and being transported via the creek they can be expected to be deposited both on the floodplain as well as in the creek sediments. Hence blaming floodplain "sources" for high creek sediments in one specific area is like blaming the rug in your living room when the room smells after your dog has "dumped" on it.

DRAFT RAC MINUTES POSTED - CHEMTURA/M.O.E. GETTING EXPOSED FOR WHAT THEY ARE

The last Remediation Advisory Committee meeting was held on September 15/16 and the Draft Minutes are out. They are an embarassment both to Chemtura and to their defensive blockers, the Ontario Ministry Of Environment and Climate Change (MOECC). The outright lies along with the deflections, stickhandling and contempt for transparency and forthrightness are beyond blatant. These Draft Minutes can be found on the Woolwich Township website under Committees of Council and under RAC/TAG.

Item 2.1 Responsible care Update. What a pathetic joke the Chemical Industry Association of Canada (CIAC) are. *Responsible Care
verification is supposed to include a component of community input. The whole process is secretive and non-transparent. Tell me readers how many of you know who the local delegates are to this years Verifcation Team? Don't ask me because while I attend all RAC & TAG meetings, unlike Pat & Susan who may have attended 1/4 - 1/3 of CPAC meetings, no mention of the Team's membership, either local or out of town, was publicly given to the two committees allegedly representing Woolwich citizens.

To date CPAC and myself are the last to receive reports and testing. We are stakeholders and have been for years, in some cases decades. Thank you Mark and Sandy one more time for your contempt for honest public consultation. This includes refusing to allow questions from the public at RAC & TAG meetings as well as refusing Delegations to TAG. You are beyond filth in your disrespect for Woolwich citizens. But then that was all publicly exposed last May in the media as you publicly humiliated yourselves attempting to ban Delegations to Council meetings. To date you are getting away with it but your time is coming and you've richly bought and paid for it.

page 3 Mr. Almeida referred to a "holistic" approach regarding remediating the Canagagigue Creek. Utter bullshit Mr. Almeida (GHD- consultants to Chemtura). Similarily Chemtura's refusal to conform to generic standards and guidelines in the creek for DDT, Dioxins, P.C.B.s is beneath contempt. There are both Canadian creek sediment guidelines as well as floodplain and agricultural soil standards. Chemtura wish to ignore them while retaining "hired guns" to do risk assessments and determine that there are few "receptors" and few complete "pathways"etc.. Bullshit built upon a foundation of bullshit.

Suspended sediment transport has been requested by Dr. Richard Jackson for the last year. It has been refused by Chemtura and their partners in pollution the Ontario M.O.E.. This testing would prove the obvious in that sediments are mobilized one on a annual basis with the spring floods and two each and every time there is a major storm. Hence Chemtura's on-site shallow contamination is flushed on an ongoing basis into and down the creek. It is NOT contained by a pump & treat system only encompassing 1/4 of their shallow aquifer ie. the south-west corner.

CPAC, RAC and TAG have bluntly told Chemtura , GHD and the M.O.E. to stick their Human Health Risk Assessment (HHRA) up their collective wazoos. Kudos to RAC & TAG for that and shame on Chemtura and the M.O.E.. The community deserve better than their never ending lies and bullshit. Shame on Mark & Sandy if they don't apologize and beg forgiveness of CPAC for telling Council how corrupt and perverted Chemtura and the M.O.E. are. In response Mark & Sandy kissed Chemtura's and the M.O.E.'s asses by removing CPAC members from the equation as best they could. Well tell me now Mark & Sandy: Are Chemtura and the M.O.E. not the unreasonable corrupt liars we told you they were? Or did you already know that and are only embarassed because you look so stupid right now? You can not deal politely and reasonably with bulletproof, unreasonable liars and YOU and some former councils are the reason they are bulletproof from public condemnation.

MR. HAHN'S INITIAL FINANCIAL STATEMENT

As per the Forensic Audit of August 11. 2015:

page 4

paragraph 1.19 : "Subsection 67(1) of the Act states that "costs incurred for goods and services by or on behalf of a person wholly or partly for use in his or her election campaign are expenses".

1.20 : "Item 2 of subsection 67(2) sets out amounts that are expenses, and campaign expenses include "the value of contributions of goods and services". Accordingly, any contribution of goods or services is also a campaign expense of the same amount."

2.2 : "Scott Hahn's family assisted his campaign by arranging for the purchase of 200 signs from a third party printing company and printing 3,000 brochures from a business owned by his in-laws. The signs and brochures were at no cost to him or his campaign. No receipts or documentation were provided to Scott at the time, and he advises that he was told several times by family members and his in-laws that there was no cost (to him) for the signs or for the brochures.".

2.5 : "Mr. Hahn acknowledged to MECAC at its' May 4, 2015 meeting that he omitted including the cost of signs and brochures in the Financial Statement and he acknowledges that he failed to obtain a sufficient understanding of the Act or related guidance during the election campaign and in the preparation of the Financial Statement. He advised MECAC that the total costs were $2,883.76, with the cost of brochures being $962.76. with the cost split equally between his father-in-law, Dale Martin, and his sister-in-law, Laci Martin. He advised MECAC that the cost of the signs was $1,921.00, split equally between his parents, Katherine and Michael Hahn, and his sister, Cassandra Hahn ($643.33 each)."

2.6 : "Scott Hahn provided MECAC with invoices supporting the sign and flyer costs for its May 11, 2015 meeting. The invoices totalled $2,714.26, the difference from the earlier estimated cost being the cost of signs. He obtained these invoices from his parents and in-laws in early May 2015. He advised that his parents had been away when he had attended the May 4, 2014 meeting and the amounts he provided verbally were based on what they had told him versus the invoices."

2.7 : "The issues with the initial Financial Statement relate to unrecorded expenses and contributions that are not reflected in the Financial Statement, as required by the Act. The issues become more complex once documentation for the signs and the brochures was produced, along with the amended Financial Statement."


Apparent Contraventions - Initial Financial Statement

2.8 : "We identified the following apparent contraventions in relation to the initial Financial Statement:

1) Failure to value all contributions of goods and services in relation to the contributions in kind of signs and brochures (69)(1)(d);

2) Failure to obtain receipts for every expense and issue receipts for every contribution (69)(1)(e), (f) and (g);

3) Failure to prepare financial statements in accordance with sections 78 and 79.1 in relation to the inclusion of all expenses and all contributions; and

4) Failure to provide proper direction to persons authorized to incur expenses on behalf of the campaign (69)(1)(1).".

Scott Hahn's initial Financial Statement can best be described as awful. He claimed a grand total of $328 and totally ignored the fact that he had $3,000 in expenses when he included his signs and brochures. Then he produced receipts that could not be substantiated in regards to his mother, father and sister regarding his election signs. It is of interest that these unsubstantiated receipts avoid the further problematic and legal issue of an overcontribution by a corporate entity ie. his father's company.

AGAIN " THE PROBLEMS WEREN'T SIGNIFICANT ENOUGH"

"A review and forensic audit found that while the councillor's paperwork was inadequate the problems weren't significant enough to pass the file over to the provincial court for legal action.". Or at least so says last week's Woolwich Observer.

I am now going to quote from the MECAC Minutes of the August 27, 2015 public meeting in which MECAC voted five versus one to not send Mr. Hahn on to the courts. I will also include two quotes taken from my notes of the meeting. They do not conflict with the Minutes but I believe add some clarity.


Kevin Bambrick page 4-5

"He reported that the Committee's decision to proceed with an audit request should have prompted Mr. Hahn to get all financial statements in order. The audit report details apparent contraventions on page 12 relating to the amended financial statements." "He noted that as with the original statement, there was a failure to provide proper direction to persons authorized to incur expenses on his behalf for the campaign. Mr Bambrick requested that this matter be referred to a prosecuting attorney for further consideration.".


Larry Aberle page 5

"Mr. Aberle stated that he felt there was no deceit intended, and the result would not have changed had the proper financial reports been filed." "The related companies that may have violated the act are now passed any time period under which they could have been charged.".


Thomas Jutzi page 5

"...there is no evidence that the candidate committed the more serious offences under the Act." "The candidate gained no advantage in filing incomplete financial statements. Mr Jutzi commented that in his opinion it was an inadvertent error in judgement, in failing to learn the rules of the MEA.". "It was not intended to coverup any of the more serious contraventions....". "Mr. Jutzi expressed that he is convinced the candidate did not knowingly commit these offenses.".

My personal notes taken during the meeting have the following quote by Mr. Jutzi namely: "paper trail may have been done after the fact.".


Murray Stoddart page 6

"Mr. Stoddart reported the committee is left to consider if this was done with intent and was an advantage gained in the election. He commented that in both cases the answer is no. He noted that while the courts would find that Mr. Hahn had contravened the Act, he expressed that the Courts would certainly not apply the penalties meant for different situations.".

My personal notes indicate that Mr. Stoddart also stated that he gave no weight to the excuses of family and their receipts as there was a complete lack of verifiable documentation. The Courts would find Scott guilty if it went there.



Grace Sudden page 6

"Mrs. Sudden said while this cannot be condoned, there is no reason to push this any further. She stressed the role of processes in educating people, and using it as an opportunity to get wiser about the importance of understanding of what's involved when someone runs for office. She noted that it is a necessity for any community to have good people run for office. She expressed appreciation that candidate's were willing to put themselves forward.".



Bob Williams page 6

"He noted that prospects for convictions on similar cases is very low. The Courts have not been willing to impose sanctions on cases with even more egregious violations. Mr. Williams commented that the errors made did not affect the outcome of the election. He reported that nothing would be served by taking it to a Court that is probably going to throw it out anyway and the Committee has gone as far as it should go.".



Chair Carl Zehr page 6

"He noted there were apparent technical contraventions of the Act. In similar cases where there were contraventions, the Courts did not take any punitive action against the candidate, particularly in cases where candidates actions were particularly more egregious. Mr. Zehr reported that he doesn't believe there was an intent to cover up the errors made, it was simply ignorance of the Act.". "He expressed his reluctance to take the matter any further because the conclusions would be the same as the majority of the Committee has expressed.".




Some points from myself: Yes the politically appointed MECAC downplayed the significance of Scott Hahn's contraventions of the Act (MEA). They also threw in a whole other litany of excuses totally irrelevant to the appropriate criteria to determine whether to send the case on to the courts. Finally multiple MECAC members seem to believe that they are not just political appointees but judges. They (MECAC) have pre-determined what the judge's verdict would be if Scott Hahn were tried on multiple MEA charges. Some of MECAC's excuses might possibly speak to the penalty portion of a judge's decision after conviction. Otherwise they are mostly irrelevant to their mandated responsibilties.

MORE ON SCOTT HAHN'S FORENSIC AUDIT

Allegedly Mr. Hahn's problems/contraventions of the Act (MEA) were not significant enough to pass on to the courts according to our local paper last Thursday. Allegedly this was the conclusion of both MECAC and the August 11, 2015 Forensic Audit. I dispute the accuracy of those allegations.

from the Forensic Audit:
page 11

3.28 The brochures being designed, created and printed with no invoices or paperwork and no money changing hands does not demonstrate an in-depth knowledge of the requirements of the Municipal Elections Act. The sample invoice dated September 8, 2014 addressed to Dale and Laci Martin is consistent with a greater knowledge of the Municipal Elections Act and its requirements to value contributions in kind at an amount consistent with what would be charged to the general public and for a contributor to not exceed $750 in contributions to any one candidate.

3.30 We understand that no actual invoice was created for the 3,000 brochures and concluded that the sample invoice was created when an invoice or paperwork was requested by Scott Hahn in April or May 2015. Scott Hahn says that he was not aware of the available documentation for the brochures until he asked for information from his in-laws. The sample invoice provided by his in-laws is consistent with the Amended Financial Statement.

3.31 We are unable to conclude whether Scott Hahn believes, or ought to believe, that the contribution was in effect from KKP Waterloo and not the individuals to whom the sample invoice was addressed.

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My takeaways are as follows. Note the date on the "sample" invoice in paragraph 3.28 namely September 8, 2014 way before the election in late October. Then note paragraph 3.30 in which Froese Forensic Partners states that they conclude that the sample invoice was created in April or May 2015 months after the election was over and AFTER a Compliance Audit was requested by Dr. Dan Holt.

Paragraph 3.31 is similar to Froese's paragraph 3.22 in regards to the election signs that were allegedly paid for by Scott's parents and sister. Froese are saying that they do not know if Scott Hahn even ought to believe that his father-in-law and sister in law donated the brochures to his campaign. In other words that scenario is essentially unbelieveable. In fact it is after the fact impossible as JoAnne Martin (mother-in-law) has stated that no money changed hands. Therefore the claim that Mr. Hahn's father-in-law and sister-in-law paid for his brochures and thus there was not an exceedance of the $750 maximum contribution is false.

"THE PROBLEMS WEREN'T SIGNIFICANT ENOUGH"

At least according to our local paper the problems/errors in Scott Hahn's two Financial Statements "weren't significant enough to pass the file over to the provincial court for legal action.". According to them this was the conclusion of both the "review" ie. MECAC and of the forensic audit. Fine, then let's look at the exact words of the August 11, 2015 Forensic Audit.


page 8

3.12 The Tri-Mach cheque was not charged to a shareholder loan account or to the petty cash account. Michael Hahn advised that he provided $1,751.50 in cash to Tri-Mach's petty cash fund as repayment for the cost of the signs. He advised them that he received the cash from himself, his wife, and their daughter, Cassandra.

3.13 Three invoices were prepared from Tri-Mach and addressed to Michael Hahn, Katherine Hahn and Cassandra Hahn. Tri-Mach's Controller advised that he prepared the three invoices at Michael Hahn's instruction. They were prepared outside of Tri-Mach's normal invoicing system and as such, they would not be recorded as revenue or a reduction of expenses in the company's financial records.

3.14 When asked to locate the electronic files to establish the dates the invoices were prepared, the Controller advised that he could not locate the electronic files, with the process made difficult as he did not recall their file names, and that they may have been created on a spare computer that is used by different employees as required. He also advised that their IT support person searched for the files and also could not locate them.

3.15 Each invoice includes handwriting by Michael Hahn that states "Pd Cash Oct 7/14". We asked the Controller, who maintains the petty cash on behalf of Tri-Mach, for records related to petty cash. We were advised that no records are maintained for "ins and outs" to petty cash and there were no postings through to the general ledger. Accordingly we have no documentation available from Tri-Mach to support the timing of the petty cash reimbursement, or verification that it occurred.


page 9

3.19 The way the signs were ordered by Michael Hahn and paid using a Tri-Mach cheque, combined with the purchase being "helping the kid out", does not demonstrate an in-depth knowledge of the requirements related to contributions in the Municipal Elections Act at the time the signs were purchased. Having three invoices dated October 1, 2014 and marked as paid October 7, 2014 is consistent with much more knowledge of the Municipal Elections Act.


page 10

3.22 We are unable to conclude whether Scott Hahn believes, or ought to believe, that the information on the contributors, as reported in the Amended Financial Statement is true. That is, whether the three family members actually contributed cash to Tri-Mach's petty cash in or around October 2014.

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The Auditor's were very careful not to make any legal findings. For example it would not be appropriate for them to suggest that paragraph's 3.19 and 3.22 above could be indicative of a possible/potential fraud. When read carefully these last two paragraphs I believe are strongly suggesting that authorities with greater expertise, probably legal, should be examining the situation.


These above paragraphs are only dealing with the issue of the unreported signs in Mr. Hahn's Financial Statement submitted by the legal deadline. There are similar issues with his $962.76 worth of brochures also unreported in his original Financial Statement as well as with an Invoice with an unlikely date on it. This entire Forensic/Compliance Audit is on the Woolwich Township website. Click on the top left side where it says Council. Scroll down to 2014 Municipal Election and click on it. Then scroll down to Scott Hahn and you will see a date of August 27, 2015 on the left. Move across to the right to Compliance Audit Report and click on it. There you are.