LOCATION, LOCATION & LOCATION

The above well known real estate truism describes the last nearly five years of Ministry of Environment "investigations" of the Canagagigue Creek. Firstly they repeatedly over tested upstream areas very close to the Uniroyal/Chemtura site while at the same time under testing locations further downstream. It's called a sampling bias and is a simple way to focus attention where you want it, not where it should be. If you sample three sites downstream miles from the Uniroyal/Chemtura site but once or twice while testing two or three sites upstream very close to the factory six to ten times then guess what? Not only do you have way more detections of toxic compounds where you've most tested but you are also likely going to hit higher concentrations the more you sample. In other words when the entire area is contaminated it is not difficult to fake "hot" spots exactly where you want them. This includes primarily testing right by road accesses such as the New Jerusalem Rd., Northfield Dr.(#22) and Jigs Hollow Rd. (#46). Afterall it's so much easier to mobilize remediation equipment and personnel where you have road access rather than marching and carrying equipment through fields, wetlands and bush.

The second location issue refers to where fish tissue residue samples were taken on the fish. Internal organs, especially the liver, accumulate persistent organic pollutants. Secondly fatty areas of the fish also accumulate POPs more than leaner areas. Notice that the fish samples were primarily skinless, boneless fillets on the leaner areas of the fish namely the upper back. This was no accident. Even then the concentrations significantly exceeded fish residue criteria. Imagine if they'd tested the more likely fatty areas and internal organs.

Finally persistent organic pollutants (POPs) bioaccumulate up the food chain. Hence higher predators end up having much higher concentrations than organisms lower down the chain. Therefore hawks, eagles, osprey have much higher tissue residues than benthic organisms (midges, mayflies) or fish. The same goes with coyotes, raccoons, mink etc.. Even directly in the aquatic environment higher fish predators such as pike and bass will accumulate greater concentrations of POPs than bottom feeders such as carp and suckers. Therefore once again by carefully choosing which fish (location) to test and which not to test our Ontario Ministry of the Environment have flavoured the outcome of their impending Ecological (Risk) Assessment.

They have minimized every variable possible in order to downplay the extent of the unremediated contamination in the natural environment (five miles of Canagagigue Creek and surrounding areas). They have also minimized the alleged "hot spots" to a very few locations very close to the Uniroyal/Chemtura site. It is decades past time to clean house both at the M.O.E.C.C. and also with the politicians whom they have served for decades.