THE "SDDB"

I and one or two others over the last thirty years have been in a position to be able to coin original phrases regarding the Elmira Water Crisis. Wally Ruck of Uniroyal did it with his early and infamous "NDMA is not in our vocabulary." quote. Susan Bryant did it with her "Adjusting the science according to your needs" in reference to Conestoga Rovers on behalf of Uniroyal Chemical. I have over the decades coined phrases such as describing the Ontario Ministry of Environment as "partners in pollution" with Uniroyal and their successors. I also felt no difficulty in naming the Stroh Drain as exactly that based upon my being the first member of the public to discover, photograph and make public the existence of this extraordinarily relevant, topographical feature immediately beside the Uniroyal/Lanxess east side property line. This past spring after further discoveries and revelations based upon the April 11, 2019 site tour as well as new, more accurate flood line maps from GHD, I renamed the Stroh Drain the Stroh Drain, Ditch and Berm (SDDB).

As I mentioned yesterday it certainly appears as if Lanxess through their cozy relationship with Woolwich Township's mayor (pretend) have called a timeout. Even with hand picked citizen representatives by the mayor (pretend) it seems as if Lanxess and their consultants GHD are feeling the heat. This is based upon the inherent intelligence, honesty, and decency of most of the TAG members including their Chair. Have no doubt that the Chair, whether paid directly or indirectly (i.e. Lanxess) by Woolwich Township must follow orders. This is the old "He who pays the piper, calls the tune" scenario and is well loved by politicians and others of similar ilk. That said it is my hope (and belief) that Tiffany Svensson has a line in the sand that she will not cross because both pretend mayors and multi national, multi billion dollar corporations usually do not.

TAG's first Chair, Dr. Richard Jackson, had a line in the sand and he made it clear to TAG and the attending CPAC and public what it was. The minute he understood that the Elmira cleanup problems were not technical ones but were "public policy" issues, he submitted his resignation. Ms. Svensson to date is willing to continue pushing for cleanup improvements both to the Elmira Aquifers and to the Canagagigue Creek despite knowing that governance will and backbone are historically lacking. She has the advantage over Dr. Jackson in that she is leading a now more experienced group of TAG members versus the brand new folks who started with inherent belief and confidence in the MOE (MECP) and who certainly early on were reluctant to rock the boat until they had more knowledge and experience with our local situation. Therefore her response to "public policy" failures will be somewhat dependent upon how much support TAG members continue to give her. Without that strong support she is putting her neck on the chopping block and our local powers have shown their love of using the chopping block even on informed and honest Woolwich volunteers (i.e. CPAC).

IT'S STILL ALL ABOUT THE STROH DRAIN

I've recently been refreshing my memory regarding TAG meetings held in January and February of this year. Boy there was a significant amount of deflection and distraction going on by Lanxess and GHD. I posted here a number of articles describing those TAG meetings as well as the May 9, 2019 TAG meeting. Those postings were January 25, March 1, May 10 and 11, 2019.

Also between these TAG meetings was the April 11/19 site tour. I have already stated here that I believe that tour was a disaster for Lanxess and a big reason why TAG is currently on hold until August 1 and RAC until September 5. It is just like in the bad old days at CPAC between 2000 and 2008 when Pat Mclean would arbitrarily shut down public CPAC meetings either for her or Crompton/Chemtura's convenience. Well convenience was only part of the reason. When things, credibility wise, weren't going particularly well for the polluter they tended to space out the meetings more. This allowed greater time for the guilty parties to rethink and reshape their position and for citizen volunteers to forget the specifics and details of their criticisms and concerns.

Various suggestions and comments from Lanxess and GHD regarding the Stroh Drain, the "Gap" area, the topography and hence the final destination of past overflowing east side pits (RPE 1-5) border on the absurd. Those ridiculous, illogical and even ill conceived excuses are exactly that: excuses. Some of their suggestions regarding sampling locations are just as bad. Now if all evidence and logic points to a "sink" of dioxins/furans and DDT in area "A" then instead of actually sampling Area "A" let's instead move upgradient and test there where we think these contaminants travelled on their way to Area "A". We'll call this area "B". Or in the alternative let's move several hundred metres downstream in the Stroh Drain and test the water, sediments and creek soils there. We'll call that area "C". Therefore if we find anything untoward or suspicious at Area "B" or "C" then maybe we'll go back and take a look at Area "A" after all. This is the kind of Catch 22 gamesmanship and nonsensical logic that has plagued the Elmira cleanup for the last thirty years.

NON-COMMUNICATION

Chemtura and CRA made their brag at CPAC in November 2012. They were going to TRIPLE the volume of off-site pumping and treating of the municipal aquifers. Now they did suggest that further study of matters such as ground subsidence and depletion of the aquifers was necessary. To date I can advise that in the last seven years not one public word of either matter has ever been brought forward to CPAC, RAC, or TAG by Chemtura/Lanxess or Conestoga Rovers. It's as if those particular matters/concerns have simply dropped off the face of the earth.

Months to a year or two later Jeff Merriman of Chemtura began talking about DOUBLING the amount of pumping and treating of the municipal aquifers underneath Elmira. As stated, there was still zero mention of ground subsidence or depletion of the aquifers due to greatly increased groundwater pumping. Mr. Merriman also failed to clarify why the promised tripling of pumping had suddenly become a mere doubling. You know it's almost as if Chemtura had been speaking privately to somebody outside of the purview of public CPAC meetings. Somebody perhaps who was no longer a formal representative of Woolwich citizens but whom Chemtura and the MOE still relied on to make deals. Somebody or bodies who set up a group outside of the formal CPAC to talk to Chemtura, CRA, and the MOE. A shadow committee if you will. This sounds an awful lot like the ACC which stands for APT Chemtura Committee which was set up after the new Todd Cowan council bounced Susan Bryant and Pat McLean from CPAC in 2011. The ACC met on the Chemtura site and discussed environmental and cleanup issues in Elmira.

Whether it was the CPAC Chair Pat McLean not passing on all information she received to voting CPAC members such as myself from 2000 to 2008 or her and Susan making deals on their own with Crompton/Chemtura/MOE behind CPAC's back during the same time period, it was counter productive. From the lack of communication from the company and MOE to CPAC members also between late 2010 to September 2015, it has since become clearer that communications with the public were being sidelined and sidetracked. This example regarding pump and treat promises falling into the void never to be heard from again is but one such item.

This is why all UPAC and CPAC meetings were to be held in public. These public meetings were also attended by the media (Elmira Independent) from 1992 until July 2015. This is exactly why individuals allegedly representing UPAC or CPAC should never have been communicating privately outside the UPAC/CPAC forum with Uniroyal/Crompton/Chemtura or Lanxess. Finally this is why the company and the Ministry of Environment should never have been sitting down publicly with CPAC from 2011 to late 2014 while also holding private, by invitation meetings only, on their property with the ACC. This gave our local polluter and their lapdog regulator far too much wiggle room on issues. On each matter they and they alone chose which citizens they wanted to go along with. This was an intentional undermining of formal, public consultation. In fact it made a mockery of true public consultation and at the end of the 2010-2014 term of Council (and CPAC), our world class polluter chose which type of "public consultation" they preferred. Obviously they preferred the Mclean/Bryant version where everything is done in private and even small corporate or government tokens of appreciation to the deal makers are acceptable.

CHEMTURA LAST DITCH PUFFERY REGARDING 2028 DEADLINE

Well we've gotten rid of Josef Olejarz of Chemtura and his nonsense as stated in the Woolwich Observer on December 15, 2012 namely "Our intention is to meet the deadline. We have no reason to believe we won't meet the deadline." Unfortunately that still leaves lots of client driven consultants not to mention the ever loyal (to their "clients") MOE (MECP).

At a CPAC meeting a few days prior, Chemtura and their consultants, CRA, unveiled a 3D model of the groundwater under their site and under Elmira. Of course they had had this model for several years and just decided to share it with the public and CPAC in December 2012. Also we learned that as part of the payoff (my opinion) for past cooperation they had years prior given a copy of this 3D computer model to Susan Bryant. She had not shared it with either CPAC, UPAC, her colleagues, the public, and probably not with her fellow APT members if any other than Shannon Perves Smith still exist.

Dr. Dan Holt addressed Woolwich Council and it absolutely incensed Chemtura. Dwight Este of Chemtura denied that the verification team from the Chemical Industry Association of Canada (CIAC) had rejected Chemtura's latest attempt to be reverified under *Responsible Care. Dr. Holt had advised Council that a discussion among the verification team members made it clear that they were not satisfied with Chemtura's efforts and public outreach. While accurate, nevertheless the verification team members including Pat McLean reversed themselves and gave Chemtura their verification. For me this was the final straw with the CIAC. I felt that like their predecessors the CCPA they were no more than a public relations facade, promoting Canadian chemical companies so called outreach and dialogue with the public. It was all a sham.

STORM WATER POND OUTLET STILL NOT COMPLETED

In fact, despite the ongoing rain received as recently as last evening, the subsurface outlet hasn't even been started. Despite the fact that there were severe weather warnings issued for the Cambridge area yesterday evening and overnite, the GRCA (& MOE (MECP)) apparently are satisfied to allow muddy water to bypass the intended outlet area and discharge into the reservoir outside of the boom that is floating in the water to catch silt and sediment. What a way to run a railroad folks.

The boom is located appropriately to catch muddy discharges as the storm water gravity flows to the Lions Trail and presumably then flows across it to discharge ten feet down the slope into the Woolwich Reservoir. The problem is that the muddy discharges are not flowing directly across the Lions Trail and directly into the Reservoir. Instead as the trail itself is on a slope the muddy water is turning ninety degrees to the right (north-east) and flowing down the trail back towards the dam itself. Eventually it finds its way down the slope into the Reservoir well away from the sediment and silt containment booms. Oh well at least the booms look nice and allow the GRCA to pretend that they've done everything possible.

My guesstimate is that we are getting very close to this situation having been ongoing for about two months now. This despite my having sent a number of e-mails to both the GRCA and the MOE (MECP). Oh well as they've demonstrated for decades now, toxic solvents and more being discharged into our public water bodies by various corporate entities don't get them very excited so why should silts and sediments?

HUMAN HEALTH STUDIES LONG REFUSED SO WHAT ABOUT ANIMAL STUDIES?

Out of sight, out of mind. Contaminated deep aquifers under Elmira can't be seen, smelled nor the water consumed anymore. Hence for most , no problem. The contaminated soils, sediments and water in the Canagagigue Creek on the north and east sides of town are rarely seen by locals. The vast majority here in town do not swim or fish in the creek, especially with the warning signs posted on the bridges crossing the creek between here and the Grand River just downstream from West Montrose. Fish studies have been done and they are very bad news. But hey, fish aren't cuddly and if we aren't eating them then who cares?

Well for starts the wildlife in and along the Canagagigue Creek downstream of Elmira care. Fortunately for the provincial Ministry of Environment as well as municipal and regional politicians, they don't vote. Many animals scavenge on dead fish. Others predate upon them such as herons, hawks, eagles, mink, muskrat, raccoon. Perhaps the odd hungry coyote or fox makes the occasional meal from a fish found in shallow water. Certainly this month carp can be readily seen and heard splashing in the shallows as they spawn and are vulnerable to being caught and eaten.

All the dioxin, DDT, PCBs and mercury then move up the food chain. These toxic chemicals will negatively affect wildlife as much or more than they affect human beings. Birds of prey suffer egg shell thinning from DDT exposure which resulted in the prohibition of DDT. The current levels in creek bank soils and creek bottom sediments far exceed both provincial and federal criteria. The concentrations in fish in the Canagagigue Creek also far exceed tissue residue guidelines (TRG) designed to protect consuming wildlife. Isn't it far past time to determine how far up the food chain these toxins have travelled? Isn't it far past time to determine the ongoing damage to wildlife from our collective failure to remove these contaminants from the natural environment?

I'm sure that Lanxess and the MOE wouldn't object. After all they could spin these studies out literally over a minimum of five years and possibly even for ten years. This would give them yet another excuse to keep the shovels out of the ground and refuse to start the decades overdue cleanup of the Canagagigue Creek.

FURTHER QUESTIONS, SOME CLARIFICATIONS REGARDING SURFACE WATER RESULTS

Questions first. Why the inconsistency in format, month to month, in Table C.1 in these monthly Progress Reports? Some months five Volatile Organics (VOCs) are allegedly sampled and other months thirteen are. Similarly some months thirteen Base Nuetral Acid Extractables (BNAs) are sampled and other months only seven. Pesticides and herbicides the same thing. One month it`s only Lindane and the next month supposedly eight pesticides are sampled although as with the VOCs and BNAs the specific compounds names are not listed. That`s a little bizarre. Also why are the detection limits (RDL) and provincial water quality objectives (PWQO) listed in some months and not in others. Is there actually a rationale for these ongoing changes in format or is it simply to keep citizen readers confused and unable to understand what is going on in surface water. The last question I have is why does the January 2019 Lanxess Progress Report refer to Table C.2 in the text but in fact it isn`t included in Appendix 2. In fact it`s nowhere to be found.

A possible clarification. It would be nice if each and every month at the bottom of Table C.2 if the authors would advise how Non Detects are calculated as numerical concentrations. I suspect that this may be part of the reason that some of the numbers stay the same over long periods of time as well as having identical concentrations with other compounds. In other words if the detection limits are identical and two different compounds are both non-detect then possibly their published concentrations in Table C.2 could end up being the same. Quoting Cochran`s statistical test or the Behrens-Fisher test isn`t that helpful to ordinary citizens.

One item that readers need to understand and that is that surface water can and does hide a number of contaminants simply by the volume of flowing water involved. It`s also important to understand that that volume of water can and does change dramatically directly related to recent precipitation. Therefore all non-detects at a flow rate of 2000 litres per second as during spring runoff really doesn`t tell us much as `dilution is the soultion to pollution` still in Ontario. Even at 400 litres per second flow a small amount of contaminant released into the Canagagigue Creek is unlikely to be measured unless the timing and location of the release and subsequent measurement are equisitely in tune. Measuring surface water but once a month allows an awful lot of water to flow downstream unmeasured (i.e. 400 litres per second X 60 seconds per minute X 60 minutes per hour X 24 hours per day X 30 days per month). Sometimes we get lucky and catch the contaminants, most times not.

MONTHLY PROGRESS REPORTS ARE RIDICULOUS - EXPLANATIONS REQUIRED

Each month I post about Lanxess's (formerly Chemtura/Crompton/Uniroyal) monthly Progress Reports. I usually indicate anomalies and or just plain silly claims such as "With the exception of W5A, W6A, W6B, W9 and E7 all wells operated at pumping rates greater than their target average pumping rates for April 2019." This dumb statement is akin to suggesting that but for the following list of twenty-five regieme murdered political opponents both Syria and Saudi Arabia have made great strides forward in human rights.

First off a shout out to Lanxess. Exactly six and a half years after Chemtura and CRA promised to triple off-site pumping, then at approximately 53 litres per second, Lanxess for the first time have exceeded the 70 litre per second mark with 73.45 litres per second average pumping rate in May 2019. That is the best ever albeit far short of either a doubling or a tripling as promised.

OH I forgot! Lanxess and the Ontario MOE don't due explanations. In fact we aren't likely to see either one before the rescheduled September 5, 2019 RAC meeting that was initially scheduled for May 16, 2019. It doesn't make much difference because they do not allow questions from the general public (only pre-registered Delegations) and even if a Delegation asks a question, they won't answer it. This is the Sandy Shantz version of public consultation and is coincidentally most preferred by Lanxess and the MOE..

Something is seriously buggered with Table C.2 on each Lanxess monthly Progress Report. For example exactly how likely is it for the arithmetic mean of concentrations of a dozen different chemicals in the Canagagigue Creek to be exact, month after month, to each other? Yes, allegedly these chemical concentrations consist of anywhere from thirteen to thirty-seven different samples all calculated to come up with an arithmetic mean which turns out to be common with a whole bunch of other arithmetic means to four decimal places? Reading over these reports it looks like a computer is generating these numbers and no one including the MOE are paying attention to them.

There is also the wee problem that the water samples are being taken every month and then incorporated into the calculations. Well then how is it that again to four decimal places the same numbers keep being generated month after month? I repeat as per the title EXPLANATIONS REQUIRED and a whole lot sooner than September!

WOOLWICH BIO-EN INC. PRESENTS TO WOOLWICH COUNCIL

Today's Woolwich Observer published the following story titled "Biogas plant operator proposes some changes to the Elmira facility". Over six years ago there were convoluted and complicated discussions and negotiations involving local citizens and Woolwich Bio-En Inc. Formal hearings appeared to be necessary although eventually a deal was worked out between the lawyer for the citizens' group and Bio-En. The deal included regular public meetings between the company and a group of citizens. I attended those meetings for at least a couple of years or more and overall was very satisfied with the company's willingness and forthrightness. At the time I posted here in the Elmira Advocate after each public meeting.

In hindsight I believe that Chuck Martin, Earl Brubacher and others to a certain degree were victimized by the Ontario Ministry of Environment's (MOE) absolutely horrid reputation as paper tigers. Assurances to the public that any obnoxious odours escaping the plant would be dealt with severely by the MOE were met with bitter laughter based upon the MOE's impotence regarding Uniroyal Chemical, Scavenger Recycling, and the pet food plant.

At last night's council meeting Chuck Martin advised councillors that the draft deal with the MOE stated that 80 trucks per day in and 80 trucks per day out was to be the maximum but somehow that was reduced to 40 trucks in and 40 trucks out. Vivienne Delaney was permitted to speak briefly to that and advised that the reduced number was no accident but a result of discussions/negotiations with the citizens group.

Overall after five years of operation it would be difficult to criticize the company and its operations. Yes truck traffic both for congestion at Church and Arthur St. was and is an issue but there is also the health hazards directly linked to diesel engine exhaust. That said the numbers of gas and diesel vehicles going through that intersection can hardly be blamed on one small nearby company. This company appears to have a very good track record with the neighbours and they have lived up to their commitments. Increasing their maximum truck movements per day is a MOE decision and Mr. Martin was essentially updating council and the public on the matter.

LATEST TRANS MOUNTAIN PIPELINE DECISION

Against the pipeline: David Suzuki, Ecojustice, Greenpeace, Stand Earth, Council of Canadians, Green Party, NDP, many native/indigenous groups, province of British Columbia-sort of/maybe.

In favour of the Alberta to B.C. pipeline: Canadian government ie. Liberals, also the Progressive Conservatives, province of Alberta, oil and gas companies


Sooooo do we see some partisan support in favour of the pipeline? I tend to look at it as the big money wants it to happen, the rest of us maybe not so much.

The Liberal government (& Alberta) are all about jobs, jobs, jobs. The oil and gas companies are all about profits, profits, profits. British Columbia, native groups and environmentalists are horrified by the possibility/probability of either pipeline leaks or breaks combined with the horrific vision of tanker leaks, spills or far worse in west coast waters.

Then of course there is the elephant in the room. Climate Change. The Canadian government have just declared in the House of Commons that there is a climate emergency in Canada and the world. You guessed it, primarily caused by the human use of fossil fuels. And this pipeline is to be built to continue the exploitation and sale of ...you guessed it: fossil fuels. What is wrong with this picture?????

LANXESS'S GROUNDWATER TREATMENT SYSTEM

The adage ignore what they say and scrutinize what they do is never more true with this company and their predecessors (Uniroyal/Crompton/Chemtura) in Elmira, Ontario. Generally every month there is a large schematic in Appendix A of their monthly Progress Report. The schematic is also usually titled Figure A.1 . It tells the contamination tale far more accurately and honestly than any words or text produced by either Conestoga Rovers or GHD on behalf of Lanxess etc.

What is significant is which wells are directed towards which specific treatment. Vitally important of course, readers need to know exactly where each well is located and which aquifer they are screened in. Of course this vital information is not provided in this Figure or Appendix. Other reports over the decades have maps showing these various locations ranging from on-site (Lanxess) upper aquifer wells along the Creek to off-site (i.e. under the town of Elmira) municipal Aquifer wells whether in the municipal upper aquifer (MU) or the municipal lower (ML) aquifer. There are no pumping wells situated in the Bedrock Aquifer although it is contaminated with NDMA well above drinking water guidelines.

For example the on-site upper aquifer (UA) wells are the only ones that go through a LNAPL (light non aqueous phase liquid) Separator prior to being treated by granular activated carbon. This is because of the sub-surface pool of LNAPL (toluene) announced to Elmira citizens way back in 1995. It is much less expensive to pump and treat (horribly slowly) this toluene than to actually physically remove it from the ground in any kind of decent time frame.

Similarly ammonia is removed from some of the pumping wells including all the on-site pumping wells (shallow & deep) as well as off-site pumping wells W5A, W5B, W6A, W6B, and W8. When it was pumping, W4 behind (west of) Varnicolor near the Elmira water tower also went through ammonia removal treatment. This tells me that ammonia originates both on the Nutrite property (W8), the Uniroyal property (PW4, PW5, UA wells), and spread off-site to nearby W5A and W5B and also likely originates from former pig farms located on and south of the former Varnicolor Chemical on Union St. where pumping wells W6A and W6B are now located. The fairly shallow Yara (Nutrite) pumping wells are the only wells that only require ammonia removal and not other solvents and chemicals. The deeper W8 pumping well on the west side of Yara (Nutrite) requires both ammonia and solvent removal treatment telling me that the solvents flowed westwards from Uniroyal off-site beneath the Nutrite property. .

Pumping well W9 is located beside the former shirt factory on Park Avenue at Union Street and beside Shirt Factory Creek. Also located either immediately on this small property or very close nearby was the M-1 Landfill depending on which map is currently in favour. W9 does not require ammonia removal but has been plagued for the last few years with toluene and benzothiazole contamination requiring treatment upgrades. These chemicals were both common at Uniroyal Chemical and tells me that likely they were disposed of in the M-1 municipal landfill whether legally or otherwise.

Well W3R is the furthest south well that goes through this on the Lanxess site, treatment processes (E7 beside Voisin Motors has it's own NDMA, ultarviolet treatment system). W3R is at south of Industrial Drive and Oriole Parkway beside the Midas(?) muffler shop and immediately beside Landfill Creek. W3R receives activated carbon and ultraviolet treatment for NDMA, chlorobenzene etc. but does not receive ammonia removal treatment.

A careful look at not only the current pumping wells and their treatment as well as having watched the past twenty-seven years of on-site and twenty-one years of off-site pump and treat has told the tale. Years ago W4 behind (west of) Varnicolor Chemical was a major pumping well. It is now shut down. PW1 and PW3 on site used to be major pumping wells to contain contamination in the north-west and south-east corners. They are now shut down. The locations of these wells are crucial in understanding where the sources of contamination originated and how adding pumping wells (W9, W6, W8) belatedly off-site has likely exacerbated the failure to achieve the cleanup of the Elmira Aquifers in thirty years (1989-2019) much less by the 2028 deadline. Current estimates are 2050 or later. Well done Uniroyal Chemical, Ontario Ministry of Environment, municipal and regional governments although the Region did try harder than the rest.

CURRENT DEMONSTRABLE CONCERNS

I have recently been exposed to an inside look at what pushes politicians buttons. It is not necessarily the big ticket items such as jobs, abortion, proportional representation, global warming, etc. It is often much more mundane, albeit immediate. It is, if you will, the short term concerns or complaints of several citizens who have actually sent a letter, an e-mail or even phoned their local representative on a matter that is upsetting them personally today or yesterday.

This helps explain to me why locally for example Elmira citizens are not en masse protesting ongoing Uniroyal/Lanxess issues including the grossly delayed cleanup of the Elmira Aquifers and also of the Canagagigue Creek. The groundwater aquifers obviously are out of sight and hence out of mind. As long as our taps still produce reasonably clean water then it is not an item of immediate concern or crisis. However watch the clamor for our own local water to be restored the day after there is a problem with either the pipeline down to Waterloo or the water coming from it.

Similarly watch the clamor via letters, e-mails, and phone calls to our municipal and regional councillors and even to our M.P.P.s if our drinking water takings from the Grand River were halted due to pollution from the Canagagigue Creek.

Back in 1998-2000 our local councillors were on the bandwagon and putting pressure on Uniroyal Chemical because of the ongoing complaints they were receiving about gross odours and air pollution in Elmira. Most of these same councillors were perfectly happy to bend over backwards for Uniroyal otherwise despite a decade's worth of scandal and public exposure as to how Uniroyal had abused the air, groundwater/drinking water and the surface water of the Creek. In other words the immediate issues rated political attention but the longer term issues of contaminated drinking water had been at least superficially resolved via the pipeline to Waterloo.

Currently it doesn't seem to have hit our local media but Woolwich councillors are watching carefully the Elmira Pet Products plant because of their odours and multiple citizen complaints to council. Local political response to immediate, in your face, problems is a good thing. Part of the problem though is that the perpetrators know that citizens and politicians aren't looking for the best, most appropriate, long term solution. They both simply want the appearance (or smell) to go away today. Hence often cosmetic solutions and bandaid style first aid solutions are embraced versus sustainable solutions that benefit everybody.

ELMIRA PET PRODUCTS

This is an interesting case from a number of perspectives. In hindsight I wonder why there hasn't been more organized opposition over the decades to the odours coming from this plant. It is especially odd when you consider the organized opposition that occurred when the Woolwich Bio-En facility was first proposed to be built beside the pet food plant on Arthur St. north. Again while there were issues in regards to truck traffic, the largest concern seemed to be that of odours. Afterall the bio-energy plant was taking food wastes and turning them into methane gas to run a generator to produce electricity which was then sold back into our hydro grid. It seemed that local residents knew what they were stuck with regarding pet food production odours and either felt that more was simply too much or that the odours from Woolwich Bio-En might be worse.

I have had communications from several Elmira locals as well as residents closer to the downtown. Some of the local residents are very upset and angry that these unpleasant but presumably (?) non-toxic odours continue to make their backyards on occasion unusable. The legal term is that citizens have a right to the enjoyment of their property and this company off and on for decades has infringed upon that legal right. Quoting myself "Canada has the best legal system in the world, that money can buy." Without the addition of citizens' hard earned money, the law is essentially an ass and that's exactly how the powers that be intended it to be. Afterall in their opinions laws are for the little people while the wealthy and powerful can and do buy their way around the law.

Two different citizens have suggested to me that despite all the fancy language and technical jargon from Elmira Pet Products supposedly explaining their difficulties stopping odours over the last couple of years that in fact it's all about money and cost of filters or scrubbers that are cheaper either not to clean/maintain/replace on a regular basis or simply to by-pass. I do not know if that is accurate or not but I do know that outside experts blasted Uniroyal Chemical in 1999-2000 after years/decades of toxic and odourous emissions. Outdated air models, uncovered outside storage of sludges and a far too slow upgrading of their emissions controls were all exposed as the cause of the horrible and disgusting Duke St. fumigations that went on for three summers in a row (1998-2001).

If Elmira Pet Products are playing similar games then they deserve the condemnation of all residents of Elmira as well as of local, regional and provincial politicians. Of course expecting politicians to take sides against industry may be going against the grain for them.

ANY RELATION TO KEN SEILING? - FORMER ELECTROHOME SITE ON SHANLEY ST.

The Waterloo Region Record have had two recent stories regarding the abandoned and decaying factory at 152 Shanley St. in Kitchener. They are titled "Building owner wants deadline extended" and the earlier article was "Owners of Electrohome site have a history of property standards violations in Waterloo". This first article outlined a number of rental properties owned by the Spylo family which have been problematic for the City of Waterloo over the years. There have been dozens of complaints to the City of Waterloo from tenants and the City have stated that there were problems either getting the work done in a timely fashion or to an acceptable standard.

The article about the deadline extension request advises that the Spylos have requested an extension to a City of Kitchener order demanding an application for a permit either to make repairs to the structurally unsound Shanley St. building or to demolish it by June 17, 2019. The building which has become an eyesore in the community for many years due to grass, weed, and snow issues is now suffering from decades of neglect including a leaking roof which has severely damaged interior floors and joists. Mike Seiling, Kitchener's chief building official, is considering granting a deadline extension if the owners provide the City with a written engineer's report attesting that the building hasn't gotten any worse in terms of its structural stability.

It is my understanding that developer Mr. Spylo purchased this old building back in 1998 and has essentially let it sit and rot for over two decades. Clearly he views it as an investment that will eventually pay off while he does not do legally mandated upkeep both inside and outside the building. Are our municipal by-laws really this weak or is it a case of selective enforcement with a city council unwilling to force a recalcitrant property owner and business person to follow the rules that the rest of us are expected to? Lastly what about the TRICHLOROETHYLENE (TCE) on this property? Where is the Ontario Ministry of Environment (MOE/MECP)? Have they any recent soil and groundwater test results that prove the TCE has not left the property and is not threatening residential neighbours? If not then shame on them yet again for their negligence.

SAME OLD GOVERNMENT & BUREAUCRATIC RESPONSES TO THE PUBLIC

Last Saturday I posted an update here on my looking into an alleged storm water pond being constructed on the property of Floradale Feed Mill that discharges into the Woolwich Reservoir. Excuse me all to hell if I believe that the Woolwich Dam (& reservoir) are public property as in bought and paid for by taxpayers' money. Yes of course there is a private benefit involved namely to Lanxess Canada and possibly their predecessor Uniroyal Chemical donated some money towards this alleged flood control and recreational project back in the very early 1970s. If Uniroyal did so (?) it was because they would have been the immediate beneficiaries of a steady supply of water in the dry summer months to flush their toxic wastes downstream in the Canagagigue Creek towards the Grand River.

In my post of last Saturday I mentioned that I had requested a copy of the Grand River Conservation Authority (GRCA) permit given to the Floradale Feed Mill allowing their construction of a storm water pond and discharge outlet to the Woolwich reservoir. In a timely manner I received a response from Beth Brown of the GRCA advising that she was unable to provide a copy of that permit and that I would need to submit a Freedom of Information (FOI) request. I responded immediately as follows:

"Ms. Brown: Thank you for the information that you were able to provide. As an aside I have wondered over the years if FOI legislation has been somehow reversed such that it has become simply one more hurdle to be overcome by citizens rather than an actual assist to greater openness and transparency resulting in greater cooperation and trust between government agencies and the public. I do hope to see the outlet installation completed before we receive any more heavy rainfalls."

Sincerely Alan Marshall


As an aside there was yet another rainfall last evening. The water in the storm water pond will gravity flow right towards the Lions Trail, across the surface of it and then fall directly ten feet down the dirt and ground embankment into the reservoir. It would seem obvious to me that a steel or concrete outlet should have been installed first not last in order to avoid erosion of both the Trail and of the embankment above the reservoir.

ELMIRA PET PRODUCTS CONTINUE TO STINK OUT THE PLACE

So let me get this straight. Sandy Shantz representing Woolwich Township and the Ontario Ministry of Environment are involved in the apparently God awful odours coming from the former Heintz and former Martin Pet Food Plant here in Elmira. Now keep in mind that "God awful odours" are both my words, not local residents words as far as I know, and that odours are somewhat subjective. In other words maybe there are people out there who either have lost their sense of smell or even possibly enjoy the odour of pet food production. Others not so much.

You know based upon the local history of enforcement, moral and legal suasion, I bet that Elmira Pet Products are absolutely shaking in their boots knowing that Sandy and the MOE (MECP) are on the job. I'll bet that Bryan Cook and Mark Adams of Elmira Pet Products are terrified that either our municipal, regional or provincial governments are poised, ready, and willing to swoop down on them and politely demand, request, beg, and pray for forgiveness for bothering and interrupting them.

Seriously why should the company be even remotely concerned about food odours when their neighbour Uniroyal Chemical liberally sprayed Elmira residents for decades with toxic solvents and worse? It was finally a civil lawsuit from four Duke St. families (Machens, Posts, Fulchers and Chalmers) in the early 2000s that put an end to the ongoing toxic emissions.

This Sandy is the direct result of all levels of government being securely in bed with local business interests. The laws of the land simply are not enforced when there are employment and money interests involved. Talk till you are blue in the face and the company are likely to say the right things about what they are in the process of doing. The problem is the number of years that this company Martin, Heintz or Elmira Pet Products have not been good corporate neighbours with residents on George, High, Charles St. and more.

MUST BE AN ELECTION ON THE HORIZON

Today's Waterloo Region Record has two new legislative announcements from our federal government. Amazing isn't it how governments can always come up, at election time especially, with some new desperately needed legislation. Today's articles are titled "Federal ban on single-use plastics would hit Stryofoam and straws" and "Ottawa passes legislation banning whale captivity". Yes I believe that both of these issues deserve federal attention however they deserved that attention literally years to decades ago. The current timing is opportunistic albeit better later than never.

The ban will take effect in 2021 and will affect plastic plates, cutlery, cups, straws, stir sticks and styrofoam cups and takeout containers. Plastic water bottles will not be included in the ban. Hmm. There will be however greater requirements for bottle producers to use recycled plastic in their bottles. Suggestions have been made that a 90% plastics recycling rate in Canada could lead to up to 42,000 new jobs.

The whale captivity legislation reflects not only an acknowledgement of the intelligence of whale species but also of the harm captivity does to them. Animal rights groups and others have been seeking an end to the commercial exploitation of these animals for a very long time.

CHEMTURA GOES ON THE OFFENSIVE

Starting in October 2012 Chemtura and Conestoga Rovers began announcing a new offensive intended to get the off-site Elmira Aquifers whipped into shape by the 2028 deadline. It was of course too little too late even if they had kept their initial promise of tripling the off-site groundwater pumping and treating. Perhaps if as they later amended their promise to a doubling of the off-site pumping and treating, they had actually done so, even that might have at least brought them closer to their mandated cleanup date. But of course they haven't. Not even close.

The Elmira Independent had a series of articles and Editorials in and around October 4, 18, 25 and November 8, 2012 describing both the past failures of Chemtura and their predecessors (Uniroyal & Crompton) as well as the hope that maybe, just maybe, they are serious this time. Events such as an Open House for Elmira residents combined with the company's vigorous response to the new CPAC's public announcement in May 29012 that the 2028 cleanup was a fantasy had stung both the company and the MOE. Time as always tells the tale. Their response and continued denials of what was obvious to both the public, lay persons and professionals on CPAC did the guilty parties credibility no good whatsoever. It is now in 2019 common knowledge throughout Elmira, Woolwich Township and Waterloo Region that our aquifers will not be restored to drinking water standards by 2028. With the long ago exit (both threatened and then done) of the Region of Waterloo from CPAC public meetings I wonder when exactly they began to understand that the cleanup has been a sham? I wonder how many people remember me putting a large banner on the roof of my car over fifteen years ago stating that the Elmira cleanup is a sham?

As always time tells the truth. The only question is how many people remember that it was citizens telling the truth while the self-serving, client driven professionals spoke gibberish, psuedo science and just plain horse manure?

UPDATE ON THE STORMWATER FACILITY BEHIND THE FLORADALE FEED MILL

Well first of all the MOE's (MECP) Marsha Smith responded very quickly to my e-mail regarding the earthworks being constructed between the Floradale Feed Mill and the Woolwich Reservoir. She has advised however that she and the Ontario Ministry of Environment have no involvement with the site at this time. There have been no applications for Environmental Compliance Agreements (ECA formerly called C. of A.-Certificates of Approval) etc.

I will admit that this environmental issue is outside my usual area of concern and expertise however based upon some local concerns as well as my growing awareness that something seems peculiar or amiss, I have put a little more effort into determining exactly what's happening here. Therefore I have sent off two more e-mails this morning. The first went to Beth Brown of the Grand River Conservation Authority (GRCA) and fifteen minutes later I forwarded that e-mail onto Ms. Smith of the Ministry of Environment (MECP). The e-mail to the GRCA was to advise them that this in process construction has been roughly excavated and just sitting for a minimum of two weeks and probably longer. Undoubtedly the weather has not been helpful for outdoor work but that is part of the point. Surface water drainage is indeed going directly to the trail and the Woolwich reservoir where it is undoubtedly carrying sediment and soils into the reservoir. How much or how long the boom in the water will contain it likely depends upon the volume and intensity of rain we receive.

The reason I forwarded the GRCA e-mail onto the MECP is because I am concerned that the MECP may indeed have to get involved but unfortunately after damage to the water quality in the reservoir has occurred if heavy rains wash and erode large amounts of sediment and soils into the reservoir. My e-mail to the MECP also suggests that an early examination of the lack of a proper outlet that should be below the surface of the trail and the embankment above the reservoir might avoid the worst erosion of the trail and embankment into the reservoir during heavy storms.I have also asked the GRCA for a copy of the permit given to the Floradale Feed Mill.

A NEW STORM WATER POND DISCHARGING INTO THE WOOLWICH RESERVOIR?

To date I and some friends have examined some earthworks visible from the Lions Trail going up the east side of the Woolwich Reservoir. We've also talked to a few fellow walkers and the comments have ranged from the ho hum not a big deal to outrage as to what appears to be damage to both the trail and to the water quality in at least the closest area of the reservoir. I did send two e-mails off a week ago and to date have only received an answer from the Grand River Conservation Authority (GRCA). The Ministry of Environment (MOE) rep (Kevin Knoll) sent me an e-mail advising that he was no longer the MOE rep for Wellesley and Woolwich and giving the name of the new rep.

Now Mr. Knoll did not advise whether or not he had sent my information request along to his replacement so I waited several days to see if she responded to me. She did not so I sent her an e-mail earlier this morning. The GRCA rep did advise me that the Floradale Feed Mill are constructing a stormwater management facility and outlet and that they had a permit from the GRCA. Well on the face of it that certainly seems plausible. That said I would like to see confirmation from the MOE as I do have a couple of questions. The first one is in regards to the outlet. At the moment it appears that the storm water will be flowing directly over the bank (and the trail) and dropping into the reservoir from several feet up. I assume that instead of that they will put a below grade outlet pipe of some sort simply to avoid the otherwise inevitable erosion. Nevertheless it would be nice to know that for sure prior to discharges actually happening.

LUISA D'AMATO ASKS "WHO KNOWS IF THE WATER IS SAFE IN CAMBRIDGE?"

The answer to that question in today's Record is fairly clear. Likely Stantec, one insurance company, and the Ontario Ministry of Environment have at least a reasonably good idea. Perhaps the detailed surface water report has been shared with the Region of Waterloo as well. Maybe even with the City of Cambridge. The problem is that there are more issues involved than just comparing numbers. Currently myself, CPAC and TAG are wrestling with a soil and sediment report for the Canagagigue Creek. Surface water testing measures dissolved concentrations of contaminants (such as jet fuel components) in the water. It does not measure for example persistent organic pollutants in either creek bank soils or creek bottom sediments. These contaminants are up taken by small organisms in the bottom of the creek (Benthics) and as well creek bank soils can be eroded over time and end up back in the creek. Other problems include method detection limits being set higher than either federal or provincial health and safety criteria. When laboratory detection limits are artificially set too high than exceedances of criteria are effectively camouflaged.

Surface water results generally greatly minimize the extent of contamination in the water. This is due to simple dilution. Time and distance from a spill can make an incredible difference as to what is found dissolved in the surface water. Unlike groundwater which is only somewhat recharged after a significant rain event, surface water is constantly recharged from up river (i.e. up gradient). Groundwater can and will hold toxic contaminations literally for decades or longer. Surface water is moving so much faster that in a few days the bulk of a spill can literally be miles downstream. Yes residual contamination is likely to show up in water samples for a while but the numbers are a miniscule fraction of what they were in the first couple of days.

What our various government bodies conveniently forget is that while some of them may "own" the report; Mill Creek, Shades Mill Conservation Authority, and the Grand River are owned by us, not them. We canoe, swim, fish and drink the water from the Grand River. I have bluntly stated that the Ontario MOE are corrupt. I suggest that based upon my definition of corruption most of our government bodies are as well. Thank you very much GRCA, Region of Waterloo, MOE, Ontario government, Cambridge Council (?), and whoever else are making my case for me by refusing to publicly release these surface water reports.

PERSONAL WORK ENVIRONMENTS

O.K. this is maybe a stretch for an environmental blog but what the heck here goes. Today's Waterloo Region Record carries the following opinion piece titled "Sick workers aren't forgotten". The author is Janice Martell who is the founder of the McIntyre Powder Project. That project name refers to the powder that was liberally doused over miners in northern Ontario allegedly to protect them from silicosis I think. That lung disease was common among miners due to possibly exposure to asbestos or perhaps another underground compound. Oh heck as you can see I'm not certain which toxic compound it was supposed to protect miners from but it turns out that the McIntyre Powder itself was toxic. I have a personal friend here in Elmira whose father died when my friend was only five years old, courtesy of McIntyre Powder.

June 1 is the annual Injured Workers Day and workers and their families gather both locally and in Toronto at Queen's Park (Ontario legislature). Ms. Martell in her opinion piece is praising Greg Mercer of the Record for his series on local rubber workers in Kitchener-Waterloo and their suffering from occupational diseases. She is also points out that there currently are four known occupational disease clusters in Ontario namely the McIntyre Powder Project, GE Peterborough workers and widows, Victims of Chemical Valley (Sarnia) and Kitchener rubber workers. While neighbours, families, and residents may suffer health and environmental effects from these industries, clearly the workers spending eight hours per day or more in close proximity to the toxins involved suffer horribly. Ms. Martell is sending a rallying cry out to those victimized through no more fault then trying to provide for their families.

PUBLIC CONSULTATION & TIMING OF MEETINGS

This post is I suppose an extension of my comments about the new RAC and TAG Terms of Reference that I posted here last Saturday. I will generally avoid comments about the inherently undemocratic and plainly ridiculous claims that either RAC or TAG are legitimate forms of public consultation because neither one is and that is intentionally done by the Township to please both Lanxess and the Ontario MOE. Hence while the entire process is an illegitimate and perverse facade many of the individual members of TAG are sincere and honest.

Today's blog posting is primarily about the number of meetings per year. RAC's original Terms of Reference stated that they would have a minimum of four meetings per year. That was ridiculous and frankly a huge concession to Chemtura Canada who found that regular monthly meetings with CPAC from 2011 until Chemtura bailed in October 2014, reduced their ability to delay and avoid. Now after Sandy Shantz's announcement followed by these new Terms of Reference, Lanxess Canada are only expected to attend three times per year! This means that even with the six times per year minimum meetings for TAG, they and the public very well may only be able to speak to Lanxess three times per year. To me this is simply the partners in pollution, MOE and Lanxess (now joined by Woolwich Township), insulating themselves from timely accountability. A designated TAG member only (not all) asks them a question and they can respond (after research) four months later at the next regularly scheduled RAC meeting. Such utter horseshit!

This year is the thirtieth anniversary of the Elmira Water Crisis. Uniroyal and their plethora of successors are masters of delay. They don't need help from anyone, especially from the so called representatives of the citizens of Woolwich Township. The last TAG meeting was on Thursday May 9, 2019. There was supposed to be a RAC meeting the following Thursday, May 16, 2019. I went through the appropriate process to speak to RAC as a Delegate.

My topic was the current major ongoing issue with both RAC and TAG, namely contamination in the Canagagigue Creek as well as the March 2019 report by GHD (on behalf of Lanxess) describing the findings of dioxins/furans and DDT in Creek sediments and soils as well as in floodplain soils. TAG members have been discussing this major issue and I have submitted written reports to TAG on the matter. TAG Chair Tiffany Svensson has indicated her concerns regarding criticisms from both TAG members and myself including her attempting to get expert advice regarding method detection limits for soil and sediment samples and why they are so much higher than both the federal and provincial health & safety criteria. Essentially it is my position that these elevated detection limits render the entire report moot. Eighty percent of the sediment samples are non-detect because the detection limits are so high and thus we can not state with any accuracy at all as to how severely contaminated the Creek actually is. These detection limits by the way are far higher than detection limits used in numerous previous reports and thus many criteria exceedances are hidden.

Last month's RAC meeting was postponed a week ahead of the scheduled meeting. We still don't have a new date although I have been advised that the new RAC meeting will be sometime after the next TAG meeting. We were just informed this morning that the next TAG meeting is scheduled for August 1, 2019. Not a bad way to defuse what might have been strong criticism of Lanxess and the MOE by TAG members. From May 16/19 until presumably in August or September TAG members will have time to forget the specifics and details of their concerns. Delay always favours the guilty and well off. They have the money to pay their consultants to review and stay on top of issues for years and decades whereas citizens with families and full time jobs are doing this work for free in their spare time. Having to redo the same thing over and over again is simply impossible and polluters and their partners and fellow travellors know that. TAG members also have more months to forget details and specifics that they learned at the April 11/19 site tour. All the better for the interests of the polluter and worse for the public interest.

SPEAKING THE TRUTH

The following is a Letter To The Editor (Elmira Independent) published on October 11, 2012 titled "Speaking the truth".


To THE Editor:

We are on the cusp of a political crisis originating here in Elmira. For 21 years , our authorities-municipal, regional and provincial -have closed ranks and colluded to deceive the public. Our new Woolwich Council made the decision that restoring Elmira's drinking water aquifers was more important than maintaining the status quo and fiction that the aquifers were "resting" and the ongoing non-cleanup was working.

It is not and never will because our Ontario Ministry of the Environment for the low, low price of saving their reputation and credibility, sold the farm to Uniroyal Chemical back in October 1991. The MOE permitted the company to save hundreds of millions of dollars in cleanup costs by giving them an indemnity (free pass) for known contamination.

This is the moral equivalent of giving Paul Bernardo a free pass for his known past murders while self-righteously proclaiming that the full weight of the law will descend upon him if the authorities learn of other murders down the road. Last Thursday, we saw a further crack in the ranks. The Region of Waterloo have stepped off the sinking ship of deception and reversed themselves regarding the hopes of the Elmira aquifers being restored. They have unequivocally stated that they have no present or future plans for the use of the Elmira Aquifers for drinking water.

What's left is our provincial Ministry of the Environment continuing to prop up the sweetheart deal they gave Uniroyal in 1991. It's all unraveling and there should be political and bureaucratic careers hanging in the balance. Whether the aquifers are ever restored or not, both the young Chemtura Public Advisory Committee (CPAC) and new Woolwich Council deserve credit for stepping up and speaking the truth.

Alan Marshall
Elmira Environmental Hazards Team, SWAT member (sub-committee of CPAC)

YET ANOTHER ATTEMPT AT WHITE/GREEN WASHING?

You know when you read a document that is supposed to be a reference document outlining the form and function as well as the duties, responsibilities and authority of two advisory groups that instead focuses on the conduct of different parties, then you know you've got a problem on your hands. A problem that can not be resolved through unenforceable rules or sugar coated platitudes. It is my opinion that these most recent Terms of Reference (May 2019) for RAC and TAG are just another attempt to greenwash the failures of ALL our political and bureaucratic authorities. News flash: we are not going to achieve the 2028 cleanup of the Elmira Aquifers and this has been admitted to by everybody albeit belatedly. From Dr. Richard Jackson, Dr. Neil Thompson, CPAC & me (first), Chemtura, Lanxess and the MOE (MECP) all have so confirmed. Of course this stupid document says otherwise but it was mostly written by David Brenneman CAO for Woolwich Township at the direction of the mayor. David always does what mayors tell him to do even when they are wrong. He thinks that is his job.

As I read this piece of fluff, the impression I believe that it gives is that darn all the delays and holdups and failures are simply because we can't all get along together. Hold hands and sing Kumbya and Elmira residents will magically transform the hearts and souls of our world class local polluter. The problem is that Uniroyal/Crompton/Chemtura and Lanxess do not have hearts and souls. They are a corporation whose sole focus is shareholder earnings and stock value.

Further to this is the fact that you can not build a successful organization on a foundation of lies and deceit. That describes the entire second paragraph of these Terms of Reference. The "previous consultation process" was no more than a PRIVATE bitch session of long past stakeholders who knew next to nothing about the most recent four to eight year history of the Chemtura Public Advisory Committee. Hence they listened to two co-opted, noses out of joint, shills of Chemtura along with the self-serving fictions of both Chemtura and the Ministry of Environment (MOE).Even then the MOE reps weren't the same ones who regularly attended PUBLIC CPAC meetings. Only one of the regularly attending CPAC and SWAT citizens was invited to this April 9, 2015 closed and private meeting at the Woolwich Township administrative building. The Chair of CPAC, Dr. Holt, appropriately insisted that the meeting had to be open and that he have other CPAC members present. This was refused so he did not attend what was a setup to scapegoat CPAC for the failures, lies and deceptions of both Chemtura and the MOE.

The Minutes of this April 9, 2015 bitch session are nothing but lies and filth propagated by yellow cowards who didn't even have the courage to reference their names with specific comments made. Can you believe that? Personal attacks suggesting physical intimidation of big burly middle aged MOE officers by senior citizens on CPAC and SWAT. According to that document Dr. Holt and I plus all the other CPAC and SWAT members including several doctors, a retired ICU nurse, a retired teacher, a registered chemist and a current environmental professional are the devils incarnate. No wonder Sandy and her uninformed buddies combined with the truly guilty parties (Chemtura & MOE) didn't want other CPAC members present or this meeting held in public. The amateur and professional liars emboldened by the privacy and among fellow travellors would have been at least partially constrained to either the truth or to at least less egregious and blatant lying.

The crux of the matter is that Uniroyal and all their successors have been hiding behind a long co-opted and corrupt Ministry of Environment. This is an MOE who hold meetings with the public while negotiating deals privately with polluters as they have always done. Partly this is due to the fact that successive provincial governments will not give them the budget or authority to do what needs to be done with corporate polluters who save millions by downloading their waste treatment costs on to the public via air, soil and water discharges whenever possible. The other crux is that both the MOE and the polluter feel absolutely zero need to tell the truth to citizen advisory panels. Lying and employing intellectual prostitutes (i.e. consultants) is the name of the game. Small wonder citizens get exasperated with them yet it is the polluter who ran for their mommy (Sandy) when the going got tough in public meetings. CPAC (2010-2015) no longer tolerated long winded fairy tales and insisted upon facts, reports and honest answers to their questions. For the second time (first in 1999) Uniroyal/Chemtura bailed on the public advisory committee but this time they in conjunction with the MOE and new Woolwich mayor manufactured a crisis in order to attempt to justify CPAC's removal. The Woolwich Observer were not fooled and lambasted Woolwich Council repeatedly for their removal of real polluter accountability.

These Terms of Reference for RAC and TAG are simply another pathetic attempt to rewrite history. They are no more than political revisionism at its worst.