DOES THE MECP ONLY DISCOVER THEIR BACKBONE ONCE OR TWICE A YEAR?

 Getting back to the Ministry of Environment's serious critiques of Stantec's Risk Assessment of the Canagagigue Creek dated December 7 and December 20, 2023; let me emphasize how serious indeed these criticisms are. Above and beyond what I've already posted, the MECP are refuting Stantec's position that chicken and egg exposure to dioxins/DDT is negligible. Stantec state that quantitative analysis simply isn't needed versus qualitative analysis. In other words as I understand this "quantitative"  would entail actual scientific measurement of concentrations of dioxns and DDT in both chickens and their eggs followed by mathematical calculations to determine risk. This is vastly different from "qualitative" analysis which I believe entails asking questions and using those verbal answers to come to theoretical conclusions that the exposure of receptors is limited enough to have only negligible risks.

Other issues as per the Ministry of Environment's reports include the fact that 500 sediment samples and 400 soil samples were taken in total over a two decade period combined with the distance of the Creek being much longer than 8 kilometres when one considers the that there are multiple channels along this Creek. The MECP believe that a worst-case scenario needs to be assessed. Also maximum exposure point concentrations should be used to inform the potential for health risks versus the proponent (Stantec/Lanxess) merely advising that the "hotspots" do not pose unacceptable risks. 

A reminder that the controversy about shovels being used for sediment samples versus proper core samplers has been clarified by the MECP.  The MECP categorically have stated that their "...2014/15 sediment samples were dominated by silt and clay while Lanxess's sediment data collected by GHD in 2017 was dominated by coarse sand and gravel". I have previously described here as to the fact that both dioxins/furans and DDT bind more strongly with fines (sand, silt etc.) than with stones, cobbles and gravel hence Lanxess and GHD have artificially reduced the contaminant concentrations by their collection method of sediments. Core samplers include the fines whereas pulling an open shovel upwards through the water column from the bottom of the Creek loses the fines leaving stones, cobbles and coarse gravel behind.

All in all simply more examples of polluters using junk science to minimize the extent of their pollution.