POSSIBLE ROUGH DRAFT FOR MY DELEGATION TO WATERLOO REGIONAL COUNCIL ON JUNE 16/20

I just started drafting this last evening and have not to date completed it. That said I believe the issues are important and while I do not expect to receive much of a sympathetic audience from most of the regional councillors, nevertheless this matter needs to be stated yet again:

"My comments and concerns today are solely in regards to the proposed expanded Elmira Township Area on the east side of Elmira specifically including two working farms (Martin & Stroh) east of the former Uniroyal Chemical, now Lanxess Canada. These two properties also encompass an alleged agricultural drain known as the Stroh Drain initially and later as the Stroh Drain, Ditch and Berm (SDDB).

It was the volunteer citizen group known as the Chemtura Public Advisory Committee (CPAC) who with my assistance assembled approximately 35 to 40 year old MOE, GRCA, Morrison-Beatty and other consultants reports indicating major contamination had migrated from Uniroyal Chemical directly over to the Stroh farm both via surface and groundwater flow. CPAC also hired MTE Consultants who, after their research including interviewing myself, Ron Campbell (owner of Acute Environmental), and Graham Chevreau (certified chemist and Health & Safety consultant) presented its findings to CPAC in late 2014. Woolwich Council of the day both endorsed that report as well as CPAC members and their efforts. Alas that political support vanished with the new incoming council.

These findings by CPAC and MTE were in contradiction to what Uniroyal plus later ownership, their consultants and the Ontario Ministry of Environment (MOE) told CPAC and the public from approximately 1992 until at least 2015. After Uniroyal/Lanxess conducted very limited testing and some surficial/superficial cleanup of the first thirty feet to a depth of only 5.9 inches (15 cm.) of the Stroh farm from the border between their properties; CPAC's contoversial and highly upsetting findings were at least partly vindicated. Nevertheless Lanxess and their consultants GHD have obstinately and obtusely refused to expand soil and water testing further south on the Stroh property especially including the SDDB and lower elevation soils to the immediate east of it. The large red arrows on the submitted map point to this area which has been the recipient of decades of surface waste water flow from Uniroyal's east side pits which via two pipelines were at one time (1948-1970) receiving 175,000 IGPD (Imperial Gallons Per Day)of toxic waste waters including solvents, NDMA, DDT, and dioxins/furans.

The investigation and study of the extent of contamination both laterally and vertically into the Stroh and Martin farms has unfortunately been similar to the quality of studies and investigations done both on the Uniroyal site and throughout Elmira, Ontario. These "investigations" have been bought and paid for by the polluter and the politest terms to describe them are client driven and self-serving. The cleanup of both the Elmira Aquifers and the Canagagigue Creek have been lackadaisical, unduly delayed and inadequate. The promised date of 2028 for complete remediation of the Elmira Aquifers to drinking water standards has been pushed back to more likely 2050 or 2060. These approximate dates have been suggested by both Eric Hodgins (Region of Waterloo) and by Dr. Richard Jackson, the first Chair of the Technical Advisory Group (TAG) which started in 2015. The later date likely includes a number of years of additional testing required by the Region to ensure that "rebound" of contaminant detections does not occur as well as for drilling of new wells.

There are a number of other reasons for not allowing industrial/commercial development of the east side of Elmira. These have been well covered by other citizens at public meetings and include higher construction costs for roads and bridges due to the routinely flooding Canagagigue Creek which runs north-west to south-east through the Uniroyal/Lanxess property on its way to the Grand River. Also I expect that changing the zoning from residential/agricultural to industrial/commercial will change and weaken the cleanup criteria allowing even more contamination to be left behind to continue to erode for decades and move downstream in the Canagagigue Creek and into the Grand River."

Alan Marshall proud member of CPAC (Citizens Public Advisory Committee) and the Elmira EH-Team