JUNK SCIENCE & CONFUSION EQUALS SUCCESS FOR LANXESS & GHD

The title above is my Conclusions and Summary of the "2020 Canagagigue Creek Sediment and Soil Investigation" report produced by GHD on behalf of Lanxess Canada and dated June 30, 2021. This is somewhat in contradiction to GHD's Concclusions and Summary on pages 24 and 25 of the text. GHD claim that their Figures 6.12, 6.13, 6.14 and 6.15 show concentrations of both soil and sediment data from both the 2017 sampling/investigation as well as from this most recent one namely 2020. These Figures allegedly show these concentrations relevant to distance from the Grand River and each Figure represents one of the four contaminants namely DDT, DDE, DDD and TEQ (dioxin) concentrations. I have to say that they are pretty Figures as in pretty useless and irrelevant. The text admits that "Non-detect data was not considered within the data analysis." In other words the majority of the data which was absolutely useless due to high Method Detection Limits leading to the majority of the data being Non-Detect, was ignored. All that was left were the detected compounds whether soil, sediment, DDT, DDE, DDD or dioxins/furans which was a function not so much of their actual concentrations present as much as a function of the size of what appeared to be arbitrary, illogical and unreasonable Method Detection Limits (MDL) used. To say that MDLs for the same parameter and in the same medium (soil or sediment) bounced around like a ping pong ball in a tornado is an understatement. ...................................................................................................................... Keep in mind that the 2017 Canagagigue Creek Investigation was also a pile of pus in scientific quality due to both bizarre MDLs as well as bizarre sediment sampling procedures namely the shovel method versus proper, formal core samplers. ................................................................................................................................ Page 25 Section 6.7 of the text then informs us that Figures 6.16 to 6.19 compares the soil and sediment data by parameter with each other versus distance from the Grand River. So already biased data will be compared within itself (soils versus sediment) to allegedly represent what: the extent of contamination in these two different mediums at different distances from the Grand River. This is nothing but more and deeper (you know what) and is also a clear example of GIGO - Garbage In = Garbage Out. Apparently GHD asked for and received from their client an exemption to this well known data processing law that says that you can't put bad data into a computer and expect it after computations to then produce good data. Hence GIGO! GHD then solemnly advise readers that "GHD recommends that the data set be evaluated under a Human Health and Ecolgical Risk Assessment framework." In other words again quoting GHD (pg. 25-26) "In order to fully understand and evaluate the data represented by this sampling program and determine appropriate next steps, a better understanding of the associated risks to human health and the environment are required.". Soooooooo I'm going to name this process GIGO-GIGO-GIGO. What this means is that Garbage In producing Garbage Out (2017 Creek Investigation) combined with more GIGO (2020 Creek Investigation) then combined with more GIGO yet (self- managed & controlled by the polluter Risk Assesssment) will produce a satisfactory (to Lanxess/GHD/MECP) result allowing a minimum of cleanup while providing the veneer of science, truth, data and logic to which all guilty parties can hide behind. TAG and RAC plus local citizens will all be victims yet again of the three B's namely Bullshit Baffles Brains.