GREATER SPECIFICITY ABOUT "LOCATIONAL BIAS"

I have likely indicated that the majority of soil and sediment sampling took place at or very near the New Jerusalem Rd. bridge over the Canagagigue Creek as well as just upriver towards Lanxess Canada and lastly much further downstream at the Northfield Dr. bridge over the Creek. The obvious common feature is very easy road access to these locations whether public roads or even some private farm lanes between Lanxess and the New Jerusalem Rd. This private access would likely be the Martin farm and it's private bridge across the Creek as well as easy access along the river.

GHD have broken the entire length of the Canagagigue (Gig) into four reaches. Starting at the mouth of the Gig as it enters the Grand River just south of West Montrose up to Northfield Dr. is referred to as Reach One. From there to a few hundred metres east of New Jerusalem Rd. is Reach Two and Reach Three is from there to a couple of hundred metres south and east of the Lanxess site in Elmira. Lastly Reach Four goes from there through the Lanxess site and ends at Church St. (Hwy # 86) in Elmira. The majority of soil and sediment sampling is therefore in Reach Three and Four. Also the majority of actual creek length is in Reach One and TWO.

All of this locational bias might be acceptable if the assumption being used is that Reach One and Two are equally as contaminated in soils and sediments as is Reach Three and Four. However my expectation is that instead the assumption will be is that right at Northfield Dr. (Reach One to the east and Reach Two to the west) requires some remediation as does Reach Three at the New Jerusalem Rd. as well as just to the west of New Jerusalem Rd. Therefore cleanup is most likely to occur at the criteria exceedances while avoiding the areas that were not sampled. This would be a typical CRA/GHD "cleanup" based upon the last thirty years of "cleanups" around the site in my opinion.