TAG : STRIKE TWO PLEASE DON'T SWING AND MISS AGAIN

MORE PRIVATE MOE/MECP & UNIROYAL/LANXESS DEAL MAKING AS LANXESS ATTEMPTS TO WIMP OUT OF FULL CLEANUP ...................... I have been very supportive of TAG and its members for several years. That is despite STRIKE ONE a couple of years ago when they permitted/accepted an excavation on the Stroh farm beside the border with Lanxess of only fifteen centimetres or 5.9 inches deep. That was idiotic. STRIKE TWO occurred last evening. That was the apparent decision, according to the TAG Chair, of TAG members out of the public eye to not accept the likelihood that overland flow from Uniroyal Chemical's east side pits had crossed the property line not only at the north end but also further south beside the Stroh Drain, Ditch & Berm (SDDB). The north end flow eastwards onto the Stroh property has been proven via even pitiful soil and groundwater testing. Lanxess with MOE/MECP corrupt support have studiously aqvoided soil and groundwater testing around the SDDB hence they can continue to bleat that there is no evidence of overland flow of toxic liquid wastes into the Stroh Drain and area some of which at least has flowed southwards into the Canagagigue Creek. ............. The TAG Chair did not even have the courtesy to explain this so called "decision" of TAG. No reasons given and no rationale as to how overland flow can be admitted to have flowed further south into GP-1 and GP-2 while not flowing via gravity into the lower lying ground surface on the Stroh property both at and immediately east of the Stroh Drain. ..................................................................... As with most bull.... promulgated by Lanxess and friends (MECP, GHD, Woolwich Twp.) it has to be dressed up with a fancy name. Let's see "Optimization" has been taken. So has "Rationalization". So let's call this wimping out of Lanxess's legal responsibilities "Flux Based Approach". Essentially it's an attempt to greatly reduce their pumping and treating of the contaminated Elmira Aquifers by pretending that as long as you have reduced the concentrations near the production wells in an aquifer and that the pumping well is pulling cleaner water from the opposite direction of the contamination source, then you might have enough dilution to make the overall concentration less than the Ontario Drinking Water Standards (ODWS). Also other "management" actions can be taken such as combining contaminated water from one well with clean water from wells much further away. Again this is no more then "Dilution is the solution to pollution. This of course is in complete contradiction to the principles of the McConnell Commission which occurred after the Walkertion crisis, massive sickness and some deaths. That commission stated that ALL steps in the water production process had to be protected and independently kept clean. Therefore using contaminated water from a well and then counting on, downstream in the process, treatment to remove either chemical or biological contaminants was unacceptable. The Region of waterloo have set the precedent with their "managing" of contaminated groundwater both in Cambridge and Waterloo for decades. ................................................................................................... Of course this will all be legitimized via our Ministry of Expanded Corporate Pollution (MECP) issuing a new Control Order to replace the one ordering complete cleanup of the Elmira Aquifers. Yes this will require the MOE/MECP to contort themselves and their credibility beyond all belief but they've had lots of practice in so doing.

GHD (LANXESS) CONCLUSIONS REGARDING YESTERDAY"S POST & THE REPORT IT WAS BASED ON

Section 6.3 (Conclusions and Recommendations) are on pages 15 and 16. They are in my opinion typical of Uniroyal/Lanxess and CRA/GHD Conclusions over the last thirty years regarding each and every environmental report published. In other words they are incredibly self-serving, highly subjective and not remotely objective. For example allegedly the extent of groundwater contamination beneath the Stroh property has now been fully delineated. That is absolute bull with only six or seven shallow wells along the Lanxess/Stroh border and only three wells (OW 188- OW 190) both shallow and deep, 240 metres to the east allegedly encompassing the entire Stroh farm and property. Rubbish and nonsense! Also keep in mind that there are multiple aquifers (UA1, UA3, MU, ML, BR) below ground not just one Upper Aquifer (UA1, UA3) and not just one deeper aquifer (MU, ML, Bedrock). The Stroh property goes both much further east as well as much further south and east with the entire Stroh Drain, Ditch & Berm (SDDB) plus areas that it is draining both ground and surface water. Some of both of these are still coming from the Lanxess property. The Conclusions claim falsely with little or no credible science behind them that there are no receptors being impacted. That claim is beyond contemptible. As long as the polluter makes sure that he doesn't test huge expanses of the Stroh property and that he doesn't do a biological study of animals in and around the SDDB who are drinking the water, then he can make and will make all the phony claims that he wants. The Conclusions claim that the groundwater flow directions combined with natural attenuation "...have maintained the integrity of MA groundwater quality beneath the Property...". Again those idiots pretend that detections of NDMA, 2,4 dichlorophenol and 2,4,6 trichlorophenol albeit mostly below the Ontario Drinking Water Standards somehow are O.K. That is just disgusting. They are toxins and should never be in the natural environment at any concentration and begs the question as to how bad they were decades ago. It also begs the question if you have found concentraions 240 metres cross-gradient and off-site why aren't you looking further? Finally they are intentionally ignoring the change in shallow groundwater flow direction caused by the Stroh Drain since 1983. That Drain is pulling contaminated Uniroyal/Lanxess groundwater off-site and over to the Stroh property. Lastly GHD reccommend that all the monitoring wells on the Stroh property should be sealed and abandoned. Good job you @#$%^&*(. Make certain that second or third rounds of testing don't embarass you further. In other words cut and run and bury the evidence behind you. Beyond contemptible.

HOW HAVE UNIROYAL CONTAMINANTS ENDED UP 240 METRES EAST (CROSS-GRADIENT) ONTO THE STROH FARM

The title of the report written by GHD on behalf of Lanxess Canada (formerly Uniroyal) is "Supplemental East Side Off-Site Groundwater Investigation". It is dated May 2020. The contaminants tested for in groundwater, both shallow and deep, are NDMA, 2,4-dichlorophenol and 2,4,6 trichorophenol. Oddly, GHD appear to be using the acronym 2,4-D which I've always understood to mean 2,4 dichlorophenoxyacetic acid, a herbicide whose raw material is 2,4 dichlorophenol.

Not only were wells drilled along the Lanxess/Stroh border but they were also drilled 240 metres eastwards along the roadway which runs from Church St. (Hwy #86) southwards towards the Stroh home. These wells were OW 190-8, OW 190-29, OW 189-8, OW 189-24 and OW 188-6, OW 188-22. Another well OW191 was drilled closer to the Lanxess/Stroh border.

The three contaminants were all produced whether intentionally or unintentionally in the case of NDMA. Both 2,4-D and 2,4,5-T were mixed together to produce the infamous Agent Orange used in Vietnam as well as in Ontario and New Brunswick. Exactly why GHD chose 2,4,6 trichlorophenol versus 2,4,5 trichlorophenol, I am not sure. All three contaminants were found in groundwater both shallow and deep in the wells along the road into the Stroh farm. The direction of groundwater flow, both shallow and deep, is primarily southwards albeit somewhat westwards as well. It does not on the face of it make much sense to be found 240 metres due eastwards, especially fifty years AFTER Uniroyal Chemical's overflowing east side pits (RPE 1-5) were no longer in use.

These pits definitely did overflow onto the Stroh farm as well as gravity flowing southwards towards the Martin farm and the Canagagigue Creek. One thought I have is that perhaps the volumes flowing eastwards were even greater than I had imagined. Another unworthy thought is that perhaps there was intentional dumping further east or even onto the farm north of the Stroh farm. It is worthy of pursuing which means it is highly unlikely to happen. Lanxess and GHD are certainly capable of coming up with their own self-serving story to "explain" away this contamination so far off the accepted flow directions.

MOE/MECP HYDROGEOLOGIST COMMENTS ON LANXESS 2019 AMR

Maybe I've gotten spoiled with a number of excellent reviews/critiques done by Cynthia Doughty, hydrogeologist for the Ontario Ministry of Environment. Some of them have been regarding past Annual Monitoring Reports (AMR). Hence when I read her four page review (dated July 15/20) of the 2019 AMR for Lanxess Canada (Elmira) I was somewhat underwhelmed. At first read it didn't seem to have the pizzaz, the punch, the blunt criticism of her earlier critiques.

I've now reread it. Possibly Lanxess/GHD have taken some of her earlier comments and criticisms to heart and have produced a clearer, better product. Regardless here is what she is advising them and us. Lanxess are currently involved in doing an evaluation of periodic losses of containment of their Elmira site. Ms. Doughty will report on their evaluation at a later date.

The 2019 AMR advises us that off-site pumping W9 will not be up and running prior to early 2021. While Ms. Doughty does not comment on that I will. It is beyond crap. The claim that W9 has been down since October 2019 is also crap. That well was scheduled to be up and running closer to 2017 than in 2019. The separate Trojan treatment system has been a bust from the get go. It is being finally scrapped and well W9 incorporated into already existing treatment trains.

Ms. Doughty advises GHD that their claim that two Upper Aquifer pumping wells are solely screened in Upper Aquifer 1 (UA1) is incorrect. She states that in fact they are either partially or fully screened in Upper Aquifer 3 (UA3) which has important hydraulic containment implications for the creek ("Gig").

On page 3 of her comments, Ms. Doughty advises that GHD's text does not correspond accurately with the facts in regards to pumping failures by on-site pumping well PW5. For me this is just shades of Conestoga Rovers and their overly optimistic conclusions in their past Uniroyal/Crompton/Chemtura reports.

Also on page 3 Ms. Doughty suggests that GHD (Lanxess's consultants) have failed to clearly indicate how well the Off-Site Containment & Treatment System (OSCTS) along with the E7 pumping well, succeeded in achieving off-site containment over the entire year (2019). She suggests that the best they did was to prove that they had full containment on December 5, 2019 perhaps leaving the readers with the impression that the rest of the 2019 year was good. That is not adequate according to Ms. Doughty.

Readers please keep in mind that the on-site pumping systems (shallow & deep) are strictly for the purpose of stopping the spread of Uniroyal/Lanxess contamination off-site throughout Elmira and possibly further. The off-site pumping systems however are both for containment and for mass extraction of those contaminants such that eventually Elmira's aquifers will be restored to drinking water standards. The shutdown of Elmira's wells was in both 1989 and 1990 and the current suggested date for cleanup is two to three decades past the provincially mandated date of 2028. Reliance on hydraulic containment only has been a much too slow process as citizens have long argued. Both on and off site source removal of hot spots should have been done twenty to twenty-five years ago to help speed up the cleanup.

PUBLIC BUT VIRTUAL TAG MEETING THIS THURSDAY

The TAG (Technical Advisory Group) meeting is set for this Thursday July 30 at 6:30 pm. Contacting Lisa Schaefer, TAG Support Person, through Woolwich Township is the way to get included (as a spectator only) in the meeting. It is not anyone from TAG's fault that the public are refused the ability to either ask questions or make comments despite this being a matter of public interest involving the Elmira Aquifers and the Canagagigue Creek. That dishonour goes primarily to Sandy Shantz as she and former councillor Mark Bauman decided to bail out the floundering Ministry of Environment and Chemtura Canada from their monthly public embarrassment that occurred at CPAC meetings when those two parties were completely unable to honestly or directly address legitimate and relevant questions and concerns from CPAC and the public. At the current time it is also relevant to indicate that virtual (i.e. on-line) meetings make sense as we are still in the midst of the Covid-19 crisis.

The package of data received includes Minutes from the February 27, 2020 live TAG meeting held in Council Chambers as well as from two Webinars (July 9 & 16/20) dealing with Risk Assessments. Also included in the package was a written submission from myself dealing with the Stroh Drain, Ditch & Berm (SDDB) which included an excellent electronic version of my well known 2 1/2' x 3' map of the east side of Uniroyal/Lanxess Canada as well as two more pages (one included a Conestoga Rovers ground surface elevation contour map and the second was an explanation of my east side Uniroyal/Lanxess map. Two TAG members, Joe Kelly and Dustin Martin also had written comments prepared after the February meeting dealing with the Conceptual Site Model (CSM) and the Contaminants of Potential Concern (COPC) document. Both of their comments were excellent.

This Thursday's meeting will include an update from Lanxess regarding the Canagagigue Creek investigation and Risk Assessment process as well as more excuses for their off-site groundwater pumping failures including the W9 ongoing pumping fiasco. There may also be a review of recent TAG submissions hopefully including mine. The problem of course in excluding either long term stakeholders from speaking, such as myself and the general public, is that knowledge and relevant information are not the sole purview of either credentialed individuals or of appointed by council members of TAG. There are subtleties and nuances involved with the SDDB that frankly 99% of even the better informed folks are missing. This of course is all music to the self-serving ears of both Lanxess, GHD and the MOE/MECP.

ENVIRONMENTAL ASSESSMENT REDESIGN

Last Thursday the Waterloo Region Record carried the following story titled "Activists raise alarm as province passes environmental assessment redesign during pandemic". I have been reading different reports about either Bill 195 or Bill 197 which include environmental assessment "reforms". Once again it appears that our governments are of the attitude that no good crisis should be wasted in passing ideological legislation. If you're a right wing Conservative then that means slashing both labour and environmental regulations whenever you can.

The current Ontario initiative is called the "COVID-19 Economic Recovery Act". It is an omnibus bill that will change dozens of pieces of Ontario legislation. Environmental groups both locally and nationally are condemning the environmental changes suggested in this new proposed legislation. Supposedly the legislation will reduce the time required for governments to approve projects. This is done by dividing projects into high-impact ones and medium-impact projects. The medium-impact projects will go through a streamlined environmental assessment. There are also concerns that more environmental changes to regulations etc. will not be posted on the Environmental Registry for 30 days as they used to be.

Of course the provincial opposition parties will also be upset with any attempts to by-pass legislative debate and oversight. Unfortunately as with all majority governments, opposition parties have very little ability to insist on even the most minor concessions from majority governments.

BAIT & SWITCH: ONE MORE TOOL IN POLLUTERS' ARSENAL

Keep in mind these "tools" all are for one fundamental purpose and that is to psuedo scientifically bafflegab, confuse and intimidate citizens, Ministry of Environment and stakeholders. The intimidation is more regarding the MOE/MECP. If Lanxess/GHD simply publicly told the MOE/MECP to flock off then they might actually drag Lanxess/GHD into court and ask them to repeat that in front of the judge as their defense to legitimate cleanup requests/orders from the MOE/MECP. Instead by hiding behind bought and paid for "experts" as Uniroyal/Crompton/Chemtura and now Lanxess have done for decades; our favorite local polluter have incredibly upped the financial ante for the MOE to take them to court. Uniroyal and successors have made it abundantly clear that they will fight tooth and nail any and every attempt to order them to do so much as a nickel's worth more of remediation than they can even remotely claim as being unnecessary.

Bait and Switch is all about pretending to listen to stakeholders who have and are still involved trying to clean up the awful environmental damage still existing after thirty years of supposed cleanup and remediation. The basic strategy of the companies has been delay, delay and more delay. It's hoping that time will either break down some of the toxins or that it will allow natural processes to dilute and transport the toxins of their site. This is occurring. To give the impression that the companies are listening to stakeholders, they used to regularly attend all UPAC and CPAC public meetings. By the intervention of Sandy Shantz and Mark Bauman, allegedly on behalf of Woolwich Township, they have removed even that minor inconvenience to the polluter. From monthly public meetings they now attend three to four public RAC (Remediation Advisory Committee) meetings per year and if they so feel like it they might attend a TAG (Technical Advisory Group) meeting once in a long while.

More specifically Bait & Switch involves allegedly embracing a good idea, say for sampling in a specific location, and then slightly modifying it just in case the good idea finds serious contamination requiring more cleanup expenditures. This was done for example along the Stroh/Lanxess property line. Sampling consisted of a limited suite of parameters combined with a width of only ten metres and most ridiculously a depth of fifteen centimetres (i.e. 5.9 inches). As usual this nonsense was not scientifically justified by independent consultants or experts.

The next attempt to carry out a Bait & Switch will be Lanxess's manipulations to avoid properly sampling the Stroh Drain, Ditch & Berm area on the Stroh (and Martin) property. Under very appropriate pressure from TAG they will likely nibble around the edges of where the soil (and more) samples should be taken. They will likely rely on co-opted individuals to make poor to mediocre suggestions which they will leap on. If TAG members make different sampling proposals they will pick and choose to their benefit. If TAG are unanimous then it may be the result of behind the scenes negotiating and compromising among the members. Polluters just love compromises as they save them millions of dollars which are transferred onto the back of the environment, wildlife and human receptors. It is obvious where sampling needs to take place but Lanxess/GHD as they have to date will resist. It is a damning indictment that it has taken six years and zero sampling has been done since October 2014 when CPAC and their consultant (MTE) exposed the off-site flow of contaminants onto the Stroh farm. By following via ground surface contours, the surface flow of liquid wastes from the east side pits (RPE 1-5) over to the lowest lying areas on the Stroh farm, one can determine where to sample. Lanxess and consultants continue to refuse.

I SENT MEMBER OF PARLIAMENT TIM LOUIS AN E-MAIL TODAY

The front page article in today's Woolwich Observer is titled "Open letter about lead in drinking water sparks research effort by local MP". Interestingly the Observer incorrectly informs us that lead is not an issue in the Region of Waterloo. Regardless, Mr. Louis has apparently decided to do some research before signing on to an open letter sent by some of his colleagues for Ottawa to invest $400 million to "...address the public health crisis". It seems it was a media led expose of the extent of lead pipe still in use in Canadian towns and cities which has gotten the attention of a number of our members of parliament. Also interestingly lead pipes are known to be still in use in day care centres as well as in schools. It may be that the lead pipes are what are known as the service lines running from the main water line below the street into separate houses, schools and other buildings.

Here in Woolwich Township (Elmira) our municipal council has authorized the removal of lead water pipes as they are exposed during road construction and infrastructure replacement. Unfortunately the township will only replace the lead service line up to the property line of the building. They are supposed to ask the property owner if they wish to replace the rest of the service line at their own expense. My understanding from on-line info provided by the Waterloo Region District School Board (WRDSB) is that they have not replaced these lead service lines en masse, a long time ago. I find that bizarre and worse considering that lead is much more harmful to children than it is to adults. Two schools in Elmira (John Mahood, Elmira District Secondary School) either still have or as recently as 2017 still had lead service lines taking drinking water into their schools.

PULLING MUNICIPAL POLITICIANS OFF THEIR SELF PROCLAIMED PEDESTALS

In regards to the title above "It's an awesome responsibility but someone has to do it." Quoting the still improperly in office Mayor Sandy Shantz: "Politicians are human too." While there are some who would argue that, I would suggest that that is exactly the point. Politicians are far too human at times. They are dumb, greedy, self-serving and far too often way too full of themselves. Convincing uninformed voters that you are the best thing since sliced bread isn't difficult. What is difficult is being even half the person you've held yourself out to be to the voters.

The Waterloo Region Record published a story titled "Trouble in the townships" in their March 5, 2016 edition. I have to admit that that story was a ray of light in that it made pretty clear that some of our local politicians just aren't too bright. Again for the slow ones let me say this. You are there for the support and well being of all your constituents. You are not there for the support and well being of local big shots, developers, family or friends. Your goal is first and last, the public interest. If it isn't in the public interest then why are you doing it?

Wellesley, North Dumfries, and Woolwich Townships were singled out for their recent very public issues. Some of the best quotes and comments came from Mark Bauman, Sandy Shantz and Scott Hahn, all of Woolwich Township. All three had been caught red handed in egregious, dumb or lazy actions regarding their municipal election expense reports. Oh and just to make it very clear: illegal behaviours and actions. Some of those actions were more lazy than others. Some were more dumb than others. And some I firmly believe were done intentionally for purposes ranging from covering up earlier errors to wanting to pretend that the winning candidate hadn't outspent her three rival candidates combined by a factor of three. Ooh that might give a few voters pause if they got the idea that money can buy elections (it certainly can).

The election expense issues followed this very same council, albeit with the focus on two councillors namely Mark and Sandy, who had recently manufactured a "crisis" for the purpose of extricating both Chemtura Canada and the Ontario Ministry of Environment (MOE) from the decades long web of lies they were involved in. They had been delaying and obfuscating on the cleanup of Elmira's aquifers and of the Canagagigue Creek since they were exposed in November 1989 for their dishonesty and environmental coverups. Local citizens through CPAC (Chemtura Public Advisory Committee) had them and their lies on the ropes and were publicly exposing them. In came Sandy and Mark for the sole purpose of rescuing and restoring the status quo such that large polluters and their "captured" regulators could continue their nasty, dishonest ways without being publicly exposed for their misdeeds and dishonesty.

While all the election expense allegations against Scott, Mark and Sandy were proven accurate, nevertheless I did not hide my motivations. Mark and Sandy needed to be publicly exposed for their incompetence, laziness and or dishonesty to the public on those issues and as well they needed to be exposed as being untrustworthy and less than honest on the Chemtura, MOE, CPAC manufactured crisis. Any politician who blatantly lies and points fingers at their own appointed volunteers have crossed a serious line and there will be repercussions.

PUTTING THE CART BEFORE THE HORSE

O.K. so I had my meeting with Woolwich's head of the planning department yesterday afternoon. Mr. Jeremy Vink, in my opinion, went out of his way to be informative and to clarify the rationale behind the decision for Woolwich to go eastwards for future industrial/commercial expansion of "employment lands". I would describe Mr. Vink as polite, courteous and respectful. I would also suggest that he is a personable young man and frankly I was positively impressed throughout our discussion. All that being said, recall that my impressions here today are based upon my time spent talking with him yesterday. If any other Woolwich citizens have had negative experiences with Mr. Vink, I am in no position to dispute them. Also a second hand impression I previously had of Mr. Vink in relation to asbestos waterpipes in Elmira was less flattering of him. Overall I do feel now that there is some legitimate rationale for putting Elmira's further industrial/commercial expansion on the east side of Elmira despite agricultural land being taken out of production and despite the huge issue of persistent organic pollutants (DDT, dioxins/furans, lindane etc.) likely in the soils in the floodplain of the Canagagigue Creek, on the Stroh farm at a minimum.

Mr. Vink spoke of issues involved when residential zoning is next to industrial zoning. Here in Elmira we are much too familiar with the horrible years of 1998-2001 when Uniroyal Chemical was stinking out Elmira and especially Duke St. Prior to that was years of Uniroyal's stench wafting downtown on the occasions when the prevailing west to east winds were reversed. Hence Mr. Vink suggested that putting future industrial /employment lands next to residential subdivisions on the north, west or even beside the new south end residential developments was not good planning. He also pointed out that while there was the Canagagigue Creek to deal with on the east side of town there were also creeks in the north end (Larch's Creek) as well as in the south end. I don't know the name of the creek in the south end but going south on Arthur St. while leaving town one can see where they go under the road in two locations. All fair enough.

I had pressed both Mr. Welwood of the Region of Waterloo and Mr. Vink (Woolwich) for cost estimates of providing municipal services on the east side of town versus the north, south or west. I did this based upon repeated and multiple references in a number of Regional (& likely Woolwich as well) documents strongly promoting the east side expansion due to the more efficient and cost effective provision of municipal services on the east side. Well that certainly strongly suggests that a cost benefit analysis of some sort was done. In fact absolutely no costs have been provided by either the Region or the Township to me or to at least one other party who so requested. There is no getting around that major blunder/omission. If our governing authorities think that it is O.K. to gild the lily with additional "reasons" for a decision then they need to back it up. Informal, back of the envelope, estimates just don't cut it.

There is one more unfortunately legitimate reason why I suspect that industrial/commercial expansion is going eastwards. That is due to the utter failure over the past fourty years of the Ontario Ministry of Environment to fulfill their duty and mandate to protect Elmira citizens from the worst scourges of heavy industry. This includes toxic air pollution, destruction of our drinking water and of our creek (the "Gig"), and the failure to clean up our drinking water by the mandated deadline. Hence if industry was expanded on the primarily upwind side of town, even more residents would learn the hard way that the MOE/MECP are paper tigers.

Last but not least is the now proven contamination by Uniroyal Chemical and token "cleanup" of the Stroh farm. The major areas of surface water flow from the east side Uniroyal pits onto the Stroh property have been studiously ignored and to this day remain unsampled and untested. I was advised by Mr. Vink of future either EIS (Environmental Impact Statements) or EA (Environmental Assessments) being required prior to construction of the Elmira By-Pass or of the municipality approving development plans in the new east side expansion area. This is much too little much too late. For over thirty years now the MOE/MECP in conjunction with Uniroyal/Crompton/Chemtura/Lanxess have successfully bullfrittered, bafflegabbed, and DELAYED while the toxins leak off site and spread under Elmira, downstream and into the air. Every year that goes by reduces the volume on the now Lanxess site and reduces their cleanup costs by transferring those costs, both monetary and health, onto citizens/taxpayers, wildlife and the environment. As the title above states, this east side development is "Putting The Cart Before The Horse". Clean up first, then consider development and the long promised Elmira truck By-Pass.

MAYBE JUMPING THE GUN?

What I mean by the title above is that I have an in person appointment set for today to speak to the head of planning for Woolwich Township in regards to the now approved, by both the Township and the Region, east side expansion of the Elmira urban line. Hence while I have made some conclusions as to what is going on based upon e-mail correspondence with both David Welwood (Region of Waterloo) and Jeremy Vink (Woolwich Township); Mr. Vink has advised that an in-person communication today can more likely clarify some issues and better answer questions and concerns. Therefore while my current understanding of process, decision making, politics, planning principles etc. may be adequate to see the big picture, it is still possible that I may have some significant misunderstandings and or misconceptions. After all I have to my past regret not always paid appropriate attention to various planning decisions made by both Woolwich Township and by the Region of Waterloo.

There have also been other decisions by both tiers of government that I have had absolutely no doubt were not made in the public interest. While overall the Region have attempted to and succeeded in improving groundwater protection in the Region, it was unfortunately long after that ship had already sailed. Most of the damage to our groundwater occurred between 1850 and 1970. That included archaic sewage "treatment" in the Townships specifically including Elmira as well as horrendous dumping of toxic industrial solid and liquid wastes untreated into the ground as well as into local creeks and rivers. Lastly it turns out that the practice of dumping municipal garbage into low lying areas on the banks of local creeks and rivers was in full bloom back then. Those idiotic decisions need to be addressed and fixed. Unfortunately LRT and other "legacy" projects are just too tempting for our politicians.

The bottom line is that Woolwich Township have decided to develop "employment lands" (i.e. industrial/commercial development) on the east side of Elmira including the contaminated Stroh and Martin farms. But for the presence of the routinely flooding Canagagigue Creek which enters Elmira from the north and then travels primarily east towards the Grand River, they might have gotten away with this again archaic method of hiding soil, ground and surface water contamination. Woolwich's claim is that development on the east side of Elmira is more cost efficient in providing municipal services in a low lying area prone to flooding than it is to do so in a higher and drier area. When I say they "might" have gotten away with it, I should be more specific. They likely will get away with it as the few people who have paid attention certainly know that it is heavy duty bull...., as usual the rest of the population are relying upon the honesty and intelligence of their local politicians. That has rarely worked in the past.

THE BOTTOM LINE ON RISK ASSESSMENTS AS USED AND ABUSED IN ELMIRA, ONTARIO

I've been attending Webinars (on-line seminars) on Risk Assessments being put on by Woolwich Township's TAG (Technical Advisory Committee) committee. To date I've personally "attended" two of the three Webinars and I've received "Slide Decks" i.e. a written paper copy of the slides presented in the Webinars for them. In my opinion the content of the Webinars has been excellent. Yes I would have preferred live seminars or live delegations versus on-line ones but hey we are still in the midst of the Covid-19 pandemic so certain adjustments have become necessary. I may not like it but I am not yet convinced that they are not worthwhile.

What has impressed me is the extent of detail involved in these risk assessments. I am coming to believe that there may well be a place for these efforts in the scheme of environmental cleanups if they produce better cleanups, not the opposite. There are a host of generic criteria for soil, sediment, ground and surface water including chemicals, metals, radiation, and more. These generic criteria are based upon scientific evidence and risk assessments for the purpose of watering down or minimizing these criteria do not make sense to me. On the day of doing a walk around by a biologist looking for evidence certain sensitive species are using the site in question and then not finding that evidence, should not be an excuse/rationale for loosening or elevating the criteria. Just because carp can survive in horribly contaminated surface water and trout can not is not a valid reason to say oh well the generic criteria is too strict. There aren't trout here today so we don't need to clean up the water. Similarly if a certain very sensitive local mammalian species is not present is not a reason/rationale to suggest that strict generic soil criteria for mercury or polyaromatic hydrocarbons etc. should not be enforced. Not only are those sensitive species likely not currently present because of the existing contamination but that does not preclude them in the future from using the site for habitat particularly if the most offensive and obvious pollution has been somewhat diluted. They may still be at risk.

Above and beyond the issue of receptors being present as just discussed is the issue of gross conflict of interest. What would you think about a committee being formed in Parliament to determine whether the governing Liberal party violated ethics in the current alleged WE scandal? How about if membership of this committee was limited to only Liberal backbenchers? Do you have confidence that the investigation would be professional, honest and defensible? I don't.

What if a major supplier to SNC Lavallin was given the duty and responsibility to determine if their customer should be charged with corruption (bribery) in overseas markets? Do you think that this supplier would be prepared to jeopardize their profitable business arrangement with SNC Lavallin by adhering scrupulously to the standards required for an honest determination? Obviously the supplier should never be put into this situation. Only an independent investigation with no conflicts of interest of any kind should even be considered.

Conestoga Rovers & Associates (CRA) literally have had millions of dollars of business from Uniroyal Chemical and their corporate successors (Crompton, Chemtura, Lanxess Canada)over the decades. CRA were purchased by GHD who have continued on in CRA's efforts to minimize remediation costs for their client Lanxess. Indeed I would suggest that that is the primary purpose of most environmental consultants i.e. find creative ways to find cheaper options to allegedly achieve the same result. Personally I believe that you get what you pay for and that creative cleanup is not always good cleanup. But hey that's just me. In a nutshell should GHD be the company to manage a Site Specific Risk Assessment for Lanxess Canada? Of course not. We went through that crap back in about 2004 with CRA doing so for Crompton and it was a crock. Greenwashing at its best. THis is the ongoing nonsense and scam in some Canadian environmental cleanups. You do not get a good result when the fox is in charge of security for the henhouse. Why would any honest person ever think that they would get an honest, scientifically defensible result?

THE PROCESS STINKS

And I believe that it's intended to stink. It's intended NOT to be user friendly. It's intended to drag out municipal issues and initiatives literally for years to decades simply hoping any opposition will either die or go away. I'm talking issues such as the Jigs Hollow gravel pit expansion to below the water table. I'm talking the past Hunder Pit proposal. I'm talking the expansion of the east side of Elmira to include the contaminated Stroh farm and the adjoining Martin farm. Lest we forget even the Environmental Appeal Board (EAB) hearings in Elmira from decades ago that lasted a couple of years or more before being abruptly stopped by Uniroyal and the Ontario MOE. Besides the time issues we have the monetary issues. OMG but the costs of hiring lawyers and keeping them available for each and every Board, Tribunal, Council meeting spread over years to decades is prohibitive. The process is intended to weed out ordinary citizens with ordinary financial resources and to leave the games to the big boys. The system is a pathetic joke. At one time there was Intervenor Funding for citizens at some of these hearings but those days are long gone to the shame of our provincial governments.

June 16, 2020 I was a virtual Delegate to Waterloo Regional Council in regards to the expansion of Elmira eastwards onto the Stroh and Martin farms etc. Regional councillors at the Planning Committee had ample time to examine the maps and text I provided in advance. Yet not so much as a sniff of a concern or question of me or a request for clarification. It was obviously a long time done deal before it ever got to that stage. Then on July 2, 2020 I received an e-mail with the region's Notice of Adoption of these proposed changes in Elmira. Again in the interim not so much as a call or e-mail requesting information. In fact in the interim I had discovered that a Ministry of Environment Director's Order had been issued to the owner of the Stroh farm three years previously. This Director's Order allegedly had not been given to Woolwich Township and hence neither their municipal environmental committee (TAG). This information was relevant and I sent it along to a number of regional councillors. Again not even an acknowledgement from them. Gosh I hope that that information wasn't embarrassing to them.

July 6, 2020 I sent a request to the Region for clarification and for municipal costs for the east side expansion versus the costs for either north, south or westwards expansion. Nine days later I received a reply from the Region (Mr. Welwood) advising me that it would be advisable for me to contact Woolwich Township for clarification of costs data. Of course Mr. Welwood's slow e-mail response has eaten up more of the very limited time allowed for an appeal of the Region's Notice of Adoption. That appeal period ends next Wednesday, July 22, 2020. I e-mailed Woolwich Township the next day (July 16) and was advised by automatic e-mail response that the appropriate person was out of the office until this coming Monday, July 20, 2020. Fortunately the Township person involved did send me an e-mail late last evening which I read this morning. He is trying to set up a meeting this Monday afternoon with me. And the appeal deadline including a cheque is two days later. As I said "The Process Stinks". Various individuals do not but the process does. It is intentional.

POLITICS: GO ALONG (WITH CRAP) TO GET ALONG (WITH SOMETHING A LITTLE BETTER?)

So what exactly are the Region of Waterloo buying with the freebies they've tossed around to the Townships with their "Rationalization" initiative? Allowing the Townships to change their minds on development locations based on newer political realities is quite the perk. Could that be for their relative quiet on the LRT front? Was that the deal? We the Region will give you and your favourite developers a one time freebie to make more money in exchange for if not support at least not outright political and legal opposition to our spending a billion dollars on Light Rail Transit which doesn't benefit the Townships at all? Maybe there are other quid pro quos involved whether past support for pet projects, legacy projects or whatever regional politicians have their little hearts set on. Maybe the payoff for the region is being kept carefully out of sight so as to make it difficult for alert citizens to see/smell what's going on.

Keep something clearly in mind. Politicians always assume that their government revenue is a bottomless barrel. After all they have a monopoly in what they are selling to the public. Be it water, sewers, garbage collection, police services etc., sidewalks or firefighters; where else are you going to be able to get those services from? Therefore it's only about scheduling. Keep your employees and managers well paid and you will have much less worries about nasty whistle blowers embarrassing you publicly about your profligacy and bad decisions. Maybe your project won't get off the ground this year but next year, short of something like a Covid crisis, should be just fine.

Woolwich Township are planning on developing industrial/commercial employment lands on the east side as well as putting the long hoped for Elmira By-Pass over there. As an additional bonus they will also give lanxess/Uniroyal Chemical a sweetner by burying both the complaints from activists along with the soil contamination on the east side of the world class polluter, namely the Stroh and Martin farms. True all guilty parties have been hiding that contamination for decades including refusing to test soils and waters in the most appropriate areas. Woolwich have long catered to the chemical company on their east side and they sure aren't about to change that if they can help it. It's better however to hide their support for Uniroyal/Lanxess behind the need (?) for employment lands and for an Elmira By-Pass.

THOUGHTFUL CITIZENS SHOULD READ BETWEEN THE LINES REGARDING WSIB, MINISTRY OF LABOUR

Puffery and bullshit are the defining characteristics that enable certain employees to advance. Most certainly they are needed in abundance to advance within the Ministry of Environment C&P as well as within the Ministry of Labour and the WSIB (Workplace safety & Insurance Board) formerly the Workmen's Compensation Board (WCB). The WCB began rotten to the core and remains so to this day. I do not blame Mr. Paul Demers for his optimism. He has just spent a year and a half writing a detailed report for the Ministry of Labour who ordered the report in January 2019 AFTER the Waterloo Region Record "...published multiple stories exposing how hundreds of sick rubber workers and their families in Waterloo Region had their claims for compensation rejected...".

The glare of media exposure and the accompanying tarnishing of the WSIB's stature, integrity and honesty was the motivating factor for the Ministry of Labour to take action. Sort of, that is. They ordered a report...Woo hooo! They also talked the talk while blissfully and intentionally NOT walking the walk. They made all the right noises. They will continue to bafflegab and bull.... Ontario workers in order to keep insurance premiums low even for repeat offenders (employers) who rely on other employers to make safe workplaces while they themselves get a free ride. It's a free ride when they can't be sued by their injured workers and their bad safety records are spread over the whole province and subsidized by the good employers.

By the way the WSIB reviewed 300 previously denied worker compensation claims from former Kitchener rubber workers and reversed the decision on a grand total of 31 claims. All the while keeping up their bull....about scientific evidence being difficult, scarce or inconclusive. Put those pieces of crap into the same factories working for a week and see how quickly they change their attitudes. Human beings in 2020 should not have to be killing themselves in order to make a living. The Record's story titled "Review calls for changes to WSIB" was published on July 11, 2020.

WELLINGTON WATER WATCHERS, NESTLE, ROBERT CASE

Today's Waterloo Region Record carries the following article by Leah Gerber, titled "Activist happy Nestle gone, seeks end to bottling permits". Dr. Robert Case (WLU) has been environmentally active for a very long time including researching and writing papers regarding Uniroyal Chemical in Elmira, Ontario. He has also been involved with the Wellington Water Watchers (WWW) for considerable time and along with them can take credit for Nestle's local discomfort in making money using a public resource and at the public's expense. As he states "Good for us that we raised enough of a stink to make it uncomfortable for Nestle to do business here". Nestle have sold their local interests to Ice River Water Bottling company.

Mr. Case and the WWW want to phase out all water bottling permits whether or not the water bottling industry is negatively affecting the resource or not. As he states "Water is for life, not profit." He is absolutely right. Selling water rights to corporations through water bottling permits is short sighted and can only lead to shortages, hoarding, and keeping the bulk of the public resource in private hands for private profit likely to the detriment of the rest of us whether today, tomorrow or in a decade. The sale to Ice River includes a factory in Puslinch, Ontario, Hope B.C. as well as the Middlebrook Wells near Elora, Ontario.

I'M GOING TO ANSWER LUISA D'AMATO'S QUESTION

In today's Waterloo Region Record, Luisa poses the following question in the headline of her Opinion piece: "What does it take for a Black person to get on the police board?". What it takes is for the Black person to be one of the old boys network. What it takes is for the Black person to be preferably a good human being with absolutely no hint of activism, agenda, or willingness to mix it up when being bafflegabbed or stonewalled.

Here's a much broader definition of who both our regional councillors and the province want on our police boards: "nice", polite Canadians with complete confidence in our institutions and government. No one, black, white, or brown, male or female, gay, straight, or bi who go in there with great concerns or deep understanding of the failures of both our police and their mickey mouse oversight Police Services Board. The Black woman (Ms. Hogarth-presumably Dr. Hogarth?) represents exactly what our old boys political network are terrified of. This is an educated AND knowledgeable individual who also has life experiences dealing with police and discrimination. Sure there are women regional councillors (including the Chair) as well as women on the Police Services Board over the years. As long as those women have been vetted by the old boys network of primarily white men and they feel that the women are like themselves in believing in the status quo and the inherent superiority of the few then they will be not only accepted but treated reasonably well.

I expect that a very successful Black businessperson who showed every indication of enjoying and appreciating the fruits of their success and who absolutely weren't left wing or active in speaking out against various social ills, would be acceptable on the Police Services Board. Just for the record there have been many old white guys as well as old white ladies who have applied to be on that Board. I'm one of them and I've never even gotten a sniff at being appointed. Why would I? I'm an environmental and human rights activist. I've spent decades fighting with various government bureaucracies and ministries whose real agenda is maintaining the status quo, not in supplying to citizens the help and services listed in their mandates. Can anyone imagine me working for the WSIB? How about for the Ministry of Environment, Ministry of labour or even the Ministry of Transportation? I would have blown the whistle on their deceit and corruption as soon as I had the goods on them.

People in authority do not hire or appoint based upon merit. They hire or appoint based upon their comfort level with like minded persons. In politics as well as in some businesses this includes hiring friends and relatives. It's called nepotism and cronyism and is alive and well. "Nice" people do not upset the apple cart. They "go along to get along". These are the kinds of people who are quickly appointed to these positions. Brains or good looks are merely icing on the cake. Being outspoken is the kiss of death for applicants.

TWO HUNDRED YEARS OF CRIMINALIZATION ABOUT TO BE REVERSED, YET AGAIN?

Let's see now: Decriminalizing homosexuality, marijuana use, topless women, and now maybe drug and opiate users. What the heck is next? Hmm maybe we've got to enact some more stupid laws before we can decriminalize more behaviour. Got it, let's criminalize farting in public. Geez even making a joke about it could backfire with the braintrusts (politicians) we have in charge. Today's Waterloo Region Record carries the following story titled "Jailing addicts fixes nothing Kitchener defence lawyers say". The arguments in favour of decriminalizing drug users have been around for a very long time. The same goes for those other formerly illegal acts. Are we seeing some sort of Wallmart "rollback" going on in Canada?

I always like to ask myself: "What is the impetus behind this action?" "Who benefits?" Perhaps the hint is near the end of the article. "With Covid-19 creating a backlog in the court system, there is no better time to meaningfully address these changes." The backlog they are referring to is because our courts have been shut down for a while. Judges and lawyers certainly don't want to get infected by any of the "riff raff" that the system depends on to pay the bills. Bills like cars, boats, cottages, and university educations for their children. Let's be honest here. Marijuana useage paid for the lifestyle of many in the legal system. The "harder" drugs have done the same. But for the plethora of criminal charges with likely jail time to follow, how many lawyers would be forced to discount their hourly prices? Can you imagine judges not being paid so far in excess of a mere six figures per year, that they could no longer afford either annual or even twice a year trips either to Europe or to warmer climates each year? The judicial system would lose it's allure as a lovely place to soak up everlasting millions of taxpayers dollars with the vast bulk going to wages and salaries for the lucky participants.

The problem of course is that the system has been greedy. More adjournments, more delays, more court appearances, more time for lawyers to bill clients for more Motions, more police charges, more, more, more. The system was too successful in manufacturing their own very profitable business. Our courts have been clogged and plugged for so long that not even a heavy duty plumber could clean out the crap and unnecessary red tape in the system. So perhaps the easiest way to reduce the once again, very profitable, volume of work is to decriminalize certain behaviours that are not in the public's interest to be seen as requiring police and judicial system intervention. After all if the judicial system can't clean up the court and judicial mess that we've been in for decades (i.e. too expensive and too time consuming), then some enterprising politicians just might do it for them. Of course they should have done it a very long time ago.

ELMIRA POLLUTION IS BOTH WORLD CLASS & A MICROCOSM OF THE REST OF THE WORLD

Fish in the Canagagigue Creek in Elmira, Ontario and downstream have the following compounds in their tissues at concentrations exceeding the Ontario Tissue Residue Guidelines (TRG) namely PCBs (polychlorinated biphenyls), Mercury, DDT, Dioxins/Furans, and more. These concentrations were minimized by the Ontario Ministry of Environment (MECP) using creative sampling techniques such as not sampling the livers of the fish as well as sampling lean tissues versus fatty tissues.

An environmental colleague and friend from out of town has sent me a history of major contamination events in Michigan, USA. There are both similarities and differences in the perpetrators as well as in the toxic compounds so readily released into the natural environment.

Shortly after the Second World war the U.S. government estimated that 5.9 million gallons of oil and other petroleum products were released into the Detroit and Rouge Rivers each year. There was a massive mortality of ducks and geese (11,000) that were killed by the oil etc. on the surfasce of the water. Downstream duck hunters collected the carcasses from the river and took them to the state capitol of Lansing, Michigan and dumped them on the State Capitol sidewalk in protest. This event started the industrial pollution control event in Michigan. Here in Elmira, Jeff Merriman of Chemtura once piously advised myself and CPAC members that the Chemtura site did not have petroleum hydrocarbons (PHC) in the sub-surface. Apparently he had forgotten the 10,000-15,000 gallons of PHC floating on the water table that had leaked out of Uniroyal's/Chemtura Building #15.

Michigan was the first state to ban DDT in 1969, three years before it was banned nationally in 1972. Throughout the 1950s and 60s there were massive die-offs of robins in various Michigan towns and cities due to DDT spraying. Grassroots activism ended the spraying practices and pushed for the ban.

In 1969 both the Rouge River and the Cuyahoga Rivers caught fire. The latter got most of the bad press and of course the cause was petroleum hydrocarbons (gas & oil) floating on the rivers from nearby industries.

Mercury, courtesy of Dow Chemical, was found in the sediments of the St. Clair River resulting in the closing of the fishery from southern Lake Huron to Lake Erie. This was the Mercury Crisis of 1970. Unlike in Elmira, Ontario, Dow Chemical spent $75 million back then to control leaking sources of mercury in sewers, drains and landfills plus another $18 million to remediate sediments in the river between 2001 and 2005. Here in Elmira we get peanut cleanups along with Risk Assessments and other paperwork games produced by Uniroyal/ Chemtura/ Lanxess Canada. That however still exceeds the token amounts of cleanup in northern Ontario caused by mercury discharge (Reid Paper) into the English/Wabigoon River systems.

Polybrominated Biphenyls (PBB) are kissing cousins of PCBs and also highly toxic. In the early 1970s Velsicol Chemical in Michigan inadvertently shipped PBBs to a livestock feed plant contaminating cattle, chickens, pigs, and humans. Furthermore the Pine River was contaminated from a nearby leaking landfill containing PBB wastes.

Again Dow Chemical managed to contaminate the Tittabawassee River in Michigan with dioxins. This river as well as the Saginaw River have had fish consumption advisory warnings for decades and Dow has been involved in the site cleanup. A recent major flood may have distributed these contaminants further downstream and into previously clean floodplains. Here in Elmira we are starting the Risk Assessment process in order to minimize the cleanup of both the sediments and the floodplain soils of the Canagagigue Creek. Meanwhile the landbased source areas remain unremediated and they too will continue to erode during flood events and carry the dioxins and more downstream into the Grand River.

Hooker Chemical were the source of contaminated chlorophenols to Uniroyal Chemical in Elmira, Ontario back in the 1950s and 60s. Hooker Chemical in Montague, Michigan produced hexachlorcyclopentadiene (C-56) and many other chlorinated hydrocarbons for use in pesticides all of which contaminated ground and surface waters in and around White lake, Michigan. Hooker started cleanup in 1981-82. Many of Hooker's chemicals are similar or identical to those improperly disposed of by Uniroyal Chemical in Elmira.

Dow Chemical again was responsible for the "blob" in the St. Clair River. This was a DNAPL chemical, namely perchloroethylene (PCE) which was discharged and sank to the bottom of the river where it would slowly dissolve over decades. Dow eventually recovered most of the nearly 3,000 gallons of PCE which it had spilled into the river. Elmira, Ontario has very little PCE but lots of other chlorinated solvents in their soils, ground water and surface waters such as chlorobenzene, chlorophenols etc.

What have our authorities learned from all of this? Apparently very little as they continue to delay unconscionably for decades and continue to "study" to death that which should have been cleaned up decades ago. "Study" however continues to be less expensive than cleanup and our politicians continue to back major polluters while publicly mouthing platitudes about a clean environment.

GOOD NEWS/BAD NEWS

The good news is that I am feeling very good about the willingness and cooperation demonstrated by the TAG Chair to ensure that TAG are seen as transparent and accountable. I have recently here advised of the unfortunate incident whereby neither CPAC, the general public, nor TAG members had been given a copy of a Director's Order issued upon the owner of the contaminated (by Uniroyal) property on the immediate east side of Uniroyal/Lanxess, three years ago. July 26, 2017 to be specific. I had made some assumptions/educated guesses as to the source of the failure to distribute the document to all stakeholders and it turns out that my assumptions/educated guesses were just that and no more. Included in my educated guesses was the belief that our illustrious mayor (Ha!) had been involved and did the Ministry of Environment a favour by agreeing to their request not to distribute the Order.

After further discussion/e-mails it now seems clear that indeed our very own, not in the public interest, Ontario Ministry of Environment are the culprits, all on their own. All communications I have received lay the responsibility for the non-public, non-distributed Order directly at the feet of the Ministry (MECP). That they may have been persuaded by the property owner (Ron Stroh) not to distribute the Order is a possibility. That that non-distribution included the Township of Woolwich is both remarkable and contemptible. That it included the TAG Chair and members is frankly shocking. That it included CPAC and the public is merely disgraceful and totally typical of the MECP and their partners in pollution Uniroyal/Lanxess.

In my book "Elmira Water Woes: The Triumph Of Corruption, Deceit, And Citizen Betrayal" I make my position on the decades long behaviour of the Ontario Ministry of Environment, by any name (MOE/MOEE/MECP), exquisitely clear: their sole purpose is to protect the government of Ontario, not its' citizens and certainly not the environment. They have done this by aligning themselves with the powerful players (multi-national corporations) and simply negotiating face saving deals because the Ministry know that they do not have government backing to come down hard on the big polluters. This is the bad news. This failure to inform stakeholders and the public is exactly what we've come to expect from this co-opted friend of polluters.

"MAKE ELMIRA'S WATER SAFE AGAIN" K-W RECORD

The above headline is from the K-W Record May 8, 2012 edition. It is an Editorial done by the Record in response to Woolwich Township endorsing their committee's determination that the 2028 mandatory deadline wasn't going to happen. Dr. Gail Krantzberg of McMaster University who has extensive experience dealing with contaminated sites had been hired by CPAC/Woolwich to look at the current cleanup plans of the Ministry of Environment (MOE) and Chemtura Canada. She found them wanting badly.

The Record are appalled at the time that's already transpired and the provincial government's "insipid" response of "trust us, the cleanup is working". The Record describe this as totally inadequate and they are correct. Besides Dr. Krantzberg's opinion there are experts in biology, hydrogeology and remediation sitting on CPAC (Chemtura Public Advisory Committee) who all agree that the 2028 cleanup is not going to happen with the current plan of hydraulic containment.

Of course all the vested interests and guilty parties howled in outrage at both CPAC's position and Woolwich Township's endorsement of them. History would prove a mere three years later that the MOE and Chemtura combined with a new more reactionary Woolwich Council had the solution. It was to attack and slander CPAC, get rid of them and start with a totally new and mostly inexperienced committee of Council namely TAG and RAC. TAG in hindsight have worked diligently despite their overall inexperience whereas RAC were nothing but the same old bureaucrats and agencies that have always been part of the status quo and the "trust us" environment.

OUR MUNICIPAL & REGIONAL POLITICIANS ARE EXPERTS AT USURPING/ABUSING AUTHORITY

They know their way around any and all attempts to make themselves either transparent or accountable. But then why shouldn't they? After all it was their colleagues and contemporaries who wrote the rules in the first place. They sure as heck didn't want to be cornered or inhibited when it came to making decisions that would help themselves, their friends, family or political supporters. It's all about maintaining the status quo. Clearly our society (or at least those at the top of it) have thrived by always having an underclass willing and able to follow the rules and do the very necessary but dirty jobs out there. From grossly underpaid Personal Support Workers to garbage men, roofers, asphalt pavers, bathroom cleaners, maids, contract workers with poor pay and zero benefits, migrant agricultural workers, the list goes on and on. Our society depends on everyone possible contributing but our upper echelons clearly discriminate based upon family name, financial status, income, property ownership and a host of other social variables. The masses are there to be exploited as much as humanly and legally possible. If you wish to exploit them even more than is legal, for example by paying less than minimum wage or working them extra long hours with little or no compensation then the rules are in place to help at least a few of them. Token accountability if you will. The Ministry of Labour through its' Employment Standards Act might, after a long wait, insist that you pay some back wages. That's it, there is no real downside. Just like most of our environmental legislation you can pollute to save yourself millions of dollars and one in a thousand will get caught and have to pay a small part of the cleanup. But real, serious consequences? Extremely unlikely and especially if you are a big boy. Severin Argenton (Varnicolor Chemical) in Elmira, Ontario was a local big fish but in the Region he was little or nothing. Jail time for him. Three and a half months of an eight month sentence. Meanwhile literally a couple of hundred metres away, Uniroyal Chemical, its owners and management never saw the inside of a jail cell despite decades of illegal behaviour, obfuscation and anti-social toxic waste dumping that adversely affected the environment, wildlife and human life. It was of course our local and regional politicians who went to bat for them whenever citizens got a little too pushy for environmental justice. How dare we riff raff call their integrity and ethics into doubt. How dare we demand accountability.

Today's Waterloo Region Record advises that a WLU prof (Karin Schnarr) has been appointed to a three year term on the Waterloo Regional Police Services Board. What a joke. First of all if she had a reputation or career background and lots of knowledge of police issues, problems and misbehaviour, rest assured she'd never have gotten the appointment. Secondly I expect that she is a very smart person and presumably has the normal human characteristics of empathy, common sense and decency. The key is the other six people on the Police Services Board. Even in the scenario that she was a hard nosed, independent thinking person wanting to dramatically improving local policing she'd be outnumbered six to one. And those six have all been selected carefully to be full fledged members of the Do Not Rock The Boat club. The status quo is just fine here in waterloo Region and don't you forget it. Lastly the term of her appointment is a joke. Three years is barely enough to get her up to speed and that's assuming that she's got lots of time to dig deep and to dig up all the local skeletons. Kelly Donovan and the other police women who have been treated badly are but one issue. The Police Board did nothing for them. Carding has been an issue. Driving while Black has been an issue. And on and on and nothing ever changes. Court Settlements with confidentiality clauses are a problem. When the police screw up badly enough and harass the wrong person and then get nailed by both lawyers and courts (civil case), far too often the police pay out even more in return for a confidentiality clause so that the public never learn of their misbehaviour.

It's all about managing what little laws, rules and regulations there are. Municipal Elections Act? Nobody and I mean nobody municipally or regionally wants to touch it with a ten foot pole no matter how egregious the contraventions are. And on and on.

RECORD ARTICLE TWENTY-FIVE YEARS AGO RELEVANT TODAY

The article was written by a K-W Record reporter by the name of Prita Yalaja. She stated that Woolwich Council essentially did what local big shot developers insisted on. There was of course the predictable denials and howls of outrage by the slighted politicians and staff bleating about process and how only good planning resulted in the final decisions. Here in Elmira development seems to have bounced around from the south end (first residential then industrial/commercial) to the west end (residential) with plans at one time for more development in the north end of Elmira. Surprise, surprise for the last several years it's been all about developing "employment lands" on the contaminated floodplain of the Canagagigue Creek. This of course also includes losing current farmland but hey what kind of planning puts chemical factories directly beside productive farmland in the first place?

Numerous parties have attended the Woolwich public meetings both with and without professional assistance. Any concerns and criticisms of east side development have been effectively ignored with little or no intelligent and reasoned rebuttal. I am still waiting to see the so called costing that would prove that municipal services can be provided more cost effectively on the east side than elsewhere. It seems to me that it's all about developing where your friends and influential people can make even more money while "unexpected" costs and overuns will of course be borne by the taxpayers. Between the contaminated soils and groundwater south and east of Uniroyal/Lanxess as well as the regular flooding I think that huge money as usual will be made by a few with the taxpayers picking up the tab for the additional costs of developing on the east side. This after all has always been the impetus behind growing populations: i.e. download as many costs as possible upon the masses while the privileged accrue the lion's share of the profits.

THE RECORD COMES THROUGH WITH STORY ABOUT UNIROYAL CONTAMINATION ON STROH FARM

Media coverage of Elmira chemical contamination has generally been awful since the Elmira Independent packed it in back in July 2015. I know that the Waterloo Region Record did do a story about the shallow excavations on the Stroh farm (beside Uniroyal/Lanxess) likely in January 2019. Today's story in the Record is titled "Watchdogs say not enough testing near new urban zone in east Elmira". The Record reporter who wrote the story is one Leah Gerber. Oddly while she did e-mail me a week or so ago she never followed up with any phone call or e-mails asking questions or clarifications nor requesting a comment from me. That said she did obviously approach Susan Bryant asking for input which is rather peculiar given Susan's minimal knowledge and input in regards to the east side contamination on the Stroh farm. Either Sebastian Seibel-Achenbach or TAG (Technical Advisory Group) Chair, Tiffany Svensson could have done a better job.

The good news is that despite several errors in the reporting due to not confirming the facts with myself, the author did achieve a number of goals. She had an excellent photograph included which showed the signs along the Canagagigue Creek warning fishermen not to consume any fish that they caught due to chemical contamination. Excellent! Secondly she included the fact that 175,000 gallons per day of LIQUID toxic wastes were were dumped on the east side property from 1948-1970. Thirdly Susan Bryant did at least indicate that the "drainage ditch" i.e. the Stroh Drain, Ditch & Berm (SDDB) still needs to be investigated and that the investigation work on the Stroh property remains unfinished until the ditch is tested. Of course who knows what is going on in the private meetings outside the public purview. This may well include private discussions with tame, co-opted "environmentalists" who will continue to give the Ministry of Environment, Uniroyal/Lanxess and Woolwich Township the veneer of "public consultation".

DID HELL JUST FREEZE OVER?

Today's Waterloo Region Record carries the following title on an article: "Ford government water-taking reforms win applause from environmental critics". Yes we are talking about Doug Ford the Premier of Ontario and the leader of the CONSERVATIVE party of Ontario! This is he same premier and same party who were caught on video promising developers that he'd open a big chunk of the Greenbelt for them. Ford and the Conservatives quickly backtracked on that proposed environmentally regressive plan and now they are actually tightening regulations for commercial water bottling companies. These regulations include municipalities having greater input into proposed water taking permits.

Other protections would include priorities being set for water taking when there is short supply and competing demands. Drinking water comes first with environmental needs such as maintaining stream flows, followed by agricultural irrigation. Further down the priority list would be commercial and industrial uses of water such as irrigating golf courses. This article even suggests that golf courses and gravel companies should also pay the same per litre of water rates that bottling companies are now being charged. All of this seems to be good news and environmental groups such as Environmental Defence are publicly saying so.

POLITICIANS ARE REPEAT OFFENDERS BECAUSE THE PUNISHMENT IS NOTHING MORE THAN A SLAP ON THE WRIST

"Power corrupts and absolute power corrupts absolutely". I'm sure we've all heard that old saying and generally speaking it is true. The "corruption" mentioned of course can be gross, can be severe, can be life-threatening or it can be no more than timid politicians merely breaking rules for which they have no respect. This lack of respect is primarily because of lack of enforcement. Yes we've had too many politicians who think that they can expense all kinds of personal expenses onto the public. This includes costs of one politician's son's wedding. We've also had a former Prime Minister accepting a bag (s?) full of cash from a German lobbyist. In the former case criminal proceedings were undertaken resulting in a conviction and public denunciation. In the latter case nothing.

One of the most common offenses by politicians is the habit of closing what are legally mandated public meetings. While there are only about three legitimate reasons permitted for closed municipal meetings for example, local politicians routinely get creative and manage to slide just about whatever topic they want into those three categories (personal discussions of individuals, legal advice, real estate or proposed property purchases by a municipality). The real purpose of a closed meeting is for a council to discuss something controversial without having to be accountable for their misstatements, inaccuracies and downright sketchy motives on occasion. For example let's say that a municipality has an annual Maple Syrup Festival. Do you think that the municipality want to publicly discuss closing that Festival because they've just learned that their drinking water is contaminated? Hell no. That is going to cost them a ton of lost money which usually ends up assisting/supporting numerous causes in their community. Those politicians do not want to be known at the next election as the politicians who shut down the Festival. Therefore they talk illegally among themselves; individuals present biased or inaccurate information and the rest of the councillors go along with the plan (eg. keeping silent) making less than stellar decisions based upon less than stellar facts and advice. The public are treated as if they were five year olds and incapable of making sound decisions whether to attend or not.

Today's Waterloo Region Record has an Opinion piece by Luisa D'Amato titled "Wilmot council discussions should have been open to the public". These discussions were about both the public behaviour of mayor Les Armstrong as well as about the future of famous/infamous statues currently residing in Wilmot Township. A few years back yours truly got fed up with Woolwich Council and decided that they needed a public upbraiding. One of the upbraidings was in regards to their penchant for closed meetings. At that time they routinely hid from the public without even making much attempt to justify their various closed meetings. Since the provincial Ombudsman at the time (Andre Marin) rapped their knuckles they have improved by at least stating the specific exemption which permits them to have a closed meeting. Of course flagrant lying will defeat this rule and I have no doubt that that has occurred.

So here we have another Waterloo Region Township (i.e. Wilmot) holding private council meetings. Clearly they are more afraid of the public's reaction to their positions regarding their mayor, regarding their statues and regarding racism than they are of the provincial legislation demanding public meetings. Clearly they know all too well that despite Woolwich Township's slight embarrassment over being caught by the Ombudsman, that the "discipline" was just about zero. Hence they break the law of the land with impunity and with disrespect. It seems to me that there is a gross selective enforcement of our laws at all levels of government and that politicians are treated more favourably than those of us who break laws with even less public harm being caused.